United States Department of Agriculture

Stanislaus

National Forest

Forest R5-MB-279 November 2015

Service

Rim Fire Reforestation(45612)

Draft Environmental Impact 

Statement

Stanislaus National Forest

Lead Agency: USDA Forest Service

Cooperating Agencies: None

Responsible Official: Jeanne M. Higgins, Forest Supervisor

Stanislaus National Forest

19777 Greenley Road

Sonora, CA 95370

(209) 532-3671

Information Contact: Maria Benech, Team Leader

Stanislaus National Forest

19777 Greenley Road

Sonora, CA 95370

(209) 532-3671

Abstract: This Draft Environmental Impact Statement (DEIS) describes a proposal for about 48,000 acres of 

treatments on National Forest System lands within the 2013 Rim Fire including: deer habitat enhancement; 

natural regeneration; noxious weed eradication; reforestation; and, thin existing plantations. The DEIS discloses 

the direct, indirect and cumulative environmental effects that would result from the proposed action, a no action 

alternative and three additional action alternatives. The Responsible Official has not identified a preferred 

alternative at this stage.

Mail comments to: Stanislaus National Forest

Attn: Rim Reforestation

19777 Greenley Road

Sonora, CA 95370

E-mail Comments to: comments-pacificsouthwest-stanislaus@fs.fed.us [Subject: Rim Reforestation] 

Comment Period: Comment period starts the day after the Environmental Protection Agency publishes 

a Notice of Availability for the DEIS in the Federal Register.

Reviewer’s Note: It is important that reviewers provide their comments at such times and in such a way that 

they are useful to the Agency’s preparation of the EIS. Therefore, comments should be provided prior to the 

close of the comment period and should clearly articulate the reviewer’s concerns and contentions. The 

submission of timely and specific comments can affect a reviewer’s ability to participate in subsequent 

administrative review or judicial review. Comments received in response to this solicitation, including names and 

addresses of those who comment, will be part of the public record for this proposed action. Comments submitted 

anonymously will be accepted and considered; however, anonymous comments will not provide the respondent 

with standing to participate in subsequent administrative review or judicial review.
Cover Photo: The EIS proposes reforestation for this 2013 

Rim Fire high severity burn area located off Road 1S04 near 

Sawmill Mountain. The photo shows bear clover, grasses and 

forbs returning in the foreground and standing dead trees in the 

background. (Forest Service, October 28, 2015)

In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its 

Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating 

based on race, color, national origin, religion, sex, gender identity (including gender expression), sexual orientation, disability, age, marital 

status, family/parental status, income derived from a public assistance program, political beliefs, or reprisal or retaliation for prior civil rights 

activity, in any program or activity conducted or funded by USDA (not all bases apply to all programs). Remedies and complaint filing 

deadlines vary by program or incident.

Persons with disabilities who require alternative means of communication for program information (e.g., Braille, large print, audiotape, 

American Sign Language, etc.) should contact the responsible Agency or USDA’s TARGET Center at (202) 720-2600 (voice and TTY) or 

contact USDA through the Federal Relay Service at (800) 877-8339. Additionally, program information may be made available in 

languages other than English.

To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, AD-3027, found online at 

http://www.ascr.usda.gov/complaint_filing_cust.html and at any USDA office or write a letter addressed to USDA and provide in the letter 

all of the information requested in the form. To request a copy of the complaint form, call (866) 632-9992. Submit your completed form or 

letter to USDA by (1) mail: U.S. Department of Agriculture, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue 

SW, Washington, D.C. 20250-9410; (2) fax: (202) 690-7442; or, (3) email: program.intake@usda.gov. 

USDA is an equal opportunity provider, employer, and lender.
Rim Fire Reforestation (45612)

Draft Environmental Impact Statement Table of Contents

Table of Contents

Summary ............................................................................................................................................ xiii

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

1.01 DOCUMENT STRUCTURE........................................................................................................................... 1

1.02 BACKGROUND ......................................................................................................................................... 1

Project Location .................................................................................................................................... 2

Forest Plan Direction............................................................................................................................. 4

Strategy ................................................................................................................................................. 4

Relation to Other Rim Fire Projects....................................................................................................... 5

1.03 PURPOSE AND NEED ............................................................................................................................... 7

Purpose................................................................................................................................................. 7

Desired Future Conditions................................................................................................................. 8

Needs.................................................................................................................................................... 9

1. Return Mixed Conifer Forest to the Landscape............................................................................ 9

2. Restore Old Forest for Wildlife Habitat and Connectivity ............................................................. 9

3. Reduce Fuels for Future Fire Resiliency ...................................................................................... 9

4. Enhance Deer Habitat................................................................................................................ 10

5. Eradicate Noxious Weeds..........................................................................................................10

Project Development...........................................................................................................................10

1.04 PROPOSED ACTION................................................................................................................................12

Proposed Action Maps ........................................................................................................................14

Updates to the Proposed Action..........................................................................................................14

1.05 PRINCIPAL LAWS AND REGULATIONS ......................................................................................................14

1.06 DECISION FRAMEWORK ..........................................................................................................................15

1.07 PUBLIC INVOLVEMENT ............................................................................................................................15

1.08 ISSUES..................................................................................................................................................17

1.09 GIS DATA ...........................................................................................................................................18

2. The Alternatives ........................................................................................................................... 19

Map Package ......................................................................................................................................19

2.01 HOW THE ALTERNATIVES WERE DEVELOPED ...........................................................................................20

Proposed Treatments with Adaptive Management..............................................................................20

Deer Habitat Enhancement .............................................................................................................20

Natural Regeneration ......................................................................................................................21

Noxious Weed Eradication ..............................................................................................................21

Reforestation ...................................................................................................................................21

Thin Existing Plantations .................................................................................................................22

Management Requirements ............................................................................................................23

2.02 ALTERNATIVES CONSIDERED IN DETAIL ...................................................................................................24

Alternative 1 (Proposed Action)...........................................................................................................24

Deer Habitat Enhancement .............................................................................................................24

Natural Regeneration ......................................................................................................................24

Noxious Weed Eradication ..............................................................................................................24

Reforestation ...................................................................................................................................24

Thin Existing Plantations .................................................................................................................30

Management Requirements ............................................................................................................30

Alternative 2 (No Action) .....................................................................................................................32

Alternative 3 ........................................................................................................................................32

Deer Habitat Enhancement .............................................................................................................33

Natural Regeneration ......................................................................................................................33

Noxious Weed Eradication ..............................................................................................................33

Reforestation ...................................................................................................................................33

Thin Existing Plantations .................................................................................................................34

Management Requirements ............................................................................................................34

Alternative 4 ........................................................................................................................................35

Deer Habitat Enhancement .............................................................................................................35

Natural Regeneration ......................................................................................................................35

Noxious Weed Eradication ..............................................................................................................35

Reforestation ...................................................................................................................................35

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Thin Existing Plantations .................................................................................................................36

Management Requirements ............................................................................................................36

Alternative 5 ........................................................................................................................................37

Deer Habitat Enhancement .............................................................................................................37

Natural Regeneration.......................................................................................................................37

Noxious Weed Eradication ..............................................................................................................37

Reforestation ...................................................................................................................................37

Thin Existing Plantations .................................................................................................................38

Management Requirements ............................................................................................................38

2.03 MANAGEMENT REQUIREMENTS COMMON TO ALL ACTION ALTERNATIVES ...................................................39

2.04 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM DETAILED STUDY.......................................................47

2.05 COMPARISON OF THE ALTERNATIVES.......................................................................................................50

3. Affected Environment and Environmental Consequences......................................................55

3.01 INTRODUCTION.......................................................................................................................................55

Analysis Process................................................................................................................................. 55

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

Forest Plan Direction .......................................................................................................................56

Incomplete or Unavailable Information ............................................................................................57

Resource Reports............................................................................................................................57

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

Information on Other Resource Issues................................................................................................59

Climate Change...............................................................................................................................59

Inventoried Roadless Areas.............................................................................................................60

Transportation ................................................................................................................................. 61

Yosemite National Park ...................................................................................................................61

Analysis Framework............................................................................................................................61

CEQA and NEPA Compliance ............................................................................................................62

3.02 AIR QUALITY .........................................................................................................................................63

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction ......................................63

Air Quality Management Practices...................................................................................................63

Effects Analysis Methodology .............................................................................................................64

Assumptions Specific to Air Quality ................................................................................................. 64

Data Sources...................................................................................................................................64

Air Quality Indicators........................................................................................................................65

Affected Environment..........................................................................................................................66

Existing Conditions ..........................................................................................................................66

Environmental Consequences ............................................................................................................66

Effects Common to all Alternatives..................................................................................................66

Alternative 1 (Proposed Action).......................................................................................................68

Alternative 2 (No Action)..................................................................................................................68

Alternative 3.....................................................................................................................................69

Alternative 4.....................................................................................................................................69

Alternative 5.....................................................................................................................................69

Summary of Effects Analysis across All Alternatives...........................................................................70

3.03 AQUATIC SPECIES..................................................................................................................................71

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction ......................................71

Regional Forester Sensitive Species...............................................................................................71

Threatened, Endangered, Candidate and Proposed Species..........................................................71

Effects Analysis Methodology .............................................................................................................72

Assumptions Specific to Aquatic Species ........................................................................................72

Data Sources...................................................................................................................................73

Aquatic Species Indicators ..............................................................................................................73

Aquatic Species Methodology by Action..........................................................................................74

Affected Environment..........................................................................................................................75

Environmental Consequences ............................................................................................................85

Alternative 1 (Proposed Action).......................................................................................................85

Alternative 2 (No Action)..................................................................................................................98

Alternative 3.....................................................................................................................................98

Alternative 4...................................................................................................................................100

Alternative 5...................................................................................................................................101

Summary of Effects Analysis across All Alternatives.........................................................................102

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3.04 CULTURAL RESOURCES .......................................................................................................................105

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction ....................................105

Effects Analysis Methodology ...........................................................................................................106

Assumptions Specific to Cultural Resources .................................................................................106

Data Sources................................................................................................................................. 106

Cultural Resources Indicators........................................................................................................106

Cultural Resources Methodology by Action...................................................................................106

Affected Environment........................................................................................................................107

Existing Conditions ........................................................................................................................107

Environmental Consequences ..........................................................................................................108

Alternative 1 (Proposed Action).....................................................................................................108

Alternative 2 (No Action)................................................................................................................109

Alternative 3...................................................................................................................................110

Alternative 4...................................................................................................................................110

Alternative 5...................................................................................................................................111

Summary of Effects Analysis across All Alternatives ........................................................................111

3.05 FIRE AND FUELS ..................................................................................................................................113

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction ....................................113

Effects Analysis Methodology ...........................................................................................................113

Assumptions Specific to Fire and Fuels.........................................................................................113

Data Sources................................................................................................................................. 113

Fire and Fuels Indicators ...............................................................................................................114

Fire and Fuels Methodology by Action ..........................................................................................114

Affected Environment........................................................................................................................116

Existing Conditions ........................................................................................................................116

Environmental Consequences ..........................................................................................................117

Alternative 1 (Proposed Action).....................................................................................................117

Alternative 2 (No Action)................................................................................................................118

Alternative 3...................................................................................................................................120

Alternative 4...................................................................................................................................120

Alternative 5...................................................................................................................................121

Summary of Effects Analysis across All Alternatives ........................................................................121

3.06 INVASIVE SPECIES ...............................................................................................................................123

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction ....................................123

Effects Analysis Methodology ...........................................................................................................123

Assumptions Specific to Invasive Species.....................................................................................123

Data Sources................................................................................................................................. 123

Invasive Species Indicators ...........................................................................................................123

Invasive Species Methodology by Action ......................................................................................123

Affected Environment........................................................................................................................123

Existing Conditions ........................................................................................................................123

Environmental Consequences ..........................................................................................................126

Alternative 1 (Proposed Action).....................................................................................................127

Alternative 2 (No Action)................................................................................................................128

Alternative 3...................................................................................................................................129

Alternative 4...................................................................................................................................129

Alternative 5...................................................................................................................................129

Summary of Effects Analysis across All Alternatives ........................................................................130

3.07 RANGE ...............................................................................................................................................131

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction ....................................131

Effects Analysis Methodology ...........................................................................................................131

Assumptions Specific to Range.....................................................................................................131

Data Sources................................................................................................................................. 131

Range Indicators ...........................................................................................................................131

Range Methodology by Action.......................................................................................................131

Affected Environment........................................................................................................................132

Existing Conditions ........................................................................................................................132

Environmental Consequences ..........................................................................................................134

Alternative 1 (Proposed Action).....................................................................................................134

Alternative 2 (No Action)................................................................................................................137

Alternative 3...................................................................................................................................139

Alternative 4...................................................................................................................................140

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Alternative 5...................................................................................................................................142

Summary of Effects Analysis across All Alternatives.........................................................................143

3.08 RECREATION .......................................................................................................................................145

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction ....................................145

Effects Analysis Methodology ...........................................................................................................145

Assumptions Specific to Recreation ..............................................................................................145

Data Sources................................................................................................................................. 146

Recreation Indicators.....................................................................................................................146

Recreation Methodology by Action ................................................................................................146

Affected Environment........................................................................................................................146

Existing Conditions ........................................................................................................................146

Environmental Consequences ..........................................................................................................148

Alternative 1 (Proposed Action).....................................................................................................148

Alternative 2 (No Action)................................................................................................................151

Alternative 3...................................................................................................................................152

Alternative 4...................................................................................................................................153

Alternative 5...................................................................................................................................154

Summary of Effects Analysis across All Alternatives.........................................................................154

3.09 SENSITIVE PLANTS...............................................................................................................................155

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction ....................................155

Effects Analysis Methodology ...........................................................................................................155

Assumptions Specific to Sensitive Plants ......................................................................................155

Data Sources................................................................................................................................. 155

Sensitive Plant Indicators ..............................................................................................................155

Sensitive Plants Methodology by Action........................................................................................156

Affected Environment........................................................................................................................156

Existing Habitat Conditions............................................................................................................156

Sensitive Species ..........................................................................................................................157

Environmental Consequences ..........................................................................................................159

Alternative 1 (Proposed Action).....................................................................................................159

Alternative 2 (No Action)................................................................................................................161

Alternative 3...................................................................................................................................162

Alternative 4...................................................................................................................................162

Alternative 5...................................................................................................................................163

Summary of Effects Analysis across All Alternatives.........................................................................163

3.10 SOCIETY, CULTURE AND ECONOMY .......................................................................................................165

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction ....................................165

Effects Analysis Methodology ...........................................................................................................165

Assumptions Specific to Society, Culture and Economy................................................................165

Data Sources................................................................................................................................. 165

Society, Culture and Economy Indicators ......................................................................................165

Society, Culture and Economy Methodology by Action ................................................................. 166

Affected Environment........................................................................................................................169

Existing Conditions ........................................................................................................................170

Environmental Consequences ..........................................................................................................175

Alternative 1 (Proposed Action).....................................................................................................175

Alternative 2 (No Action)................................................................................................................180

Alternative 3...................................................................................................................................182

Alternative 4...................................................................................................................................184

Alternative 5...................................................................................................................................187

Summary of Effects Analysis across All Alternatives.........................................................................189

Economic Efficiency.......................................................................................................................189

Economic Impact ...........................................................................................................................189

Social Analysis...............................................................................................................................190

Environmental Justice....................................................................................................................190

3.11 SOILS .................................................................................................................................................191

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction ....................................191

Effects Analysis Methodology ...........................................................................................................191

Assumptions Specific to Soils........................................................................................................192

Data Sources................................................................................................................................. 192

Soils Indicators ..............................................................................................................................192

Soils Methodology by Action..........................................................................................................193

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Affected Environment........................................................................................................................194

Soil Properties ...............................................................................................................................194

Existing Conditions ........................................................................................................................195

Environmental Consequences ..........................................................................................................196

Alternative 1 (Proposed Action).....................................................................................................197

Alternative 2 (No Action)................................................................................................................203

Alternative 3...................................................................................................................................205

Alternative 4...................................................................................................................................207

Alternative 5...................................................................................................................................208

Summary of Effects Analysis across All Alternatives ........................................................................210

3.12 SPECIAL AREAS ..................................................................................................................................211

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction ....................................211

Special Interest Areas ...................................................................................................................211

Wild and Scenic Rivers..................................................................................................................211

Wilderness.....................................................................................................................................212

Effects Analysis Methodology ...........................................................................................................212

Assumptions Specific to Special Areas .........................................................................................212

Data Sources................................................................................................................................. 213

Special Areas Indicators................................................................................................................213

Special Areas Methodology by Action...............................................................................................214

Special Interest Areas: Affected Environment..................................................................................215

Existing Conditions ........................................................................................................................215

Special Interest Areas: Environmental Consequences ....................................................................216

Alternative 1 (Proposed Action).....................................................................................................216

Alternative 2 (No Action)................................................................................................................217

Alternative 3...................................................................................................................................218

Alternative 4...................................................................................................................................218

Alternative 5...................................................................................................................................218

Wild and Scenic Rivers: Affected Environment ................................................................................219

Clavey Proposed Wild and Scenic River .......................................................................................219

South Fork Tuolumne Proposed Wild and Scenic River................................................................221

Tuolumne Wild and Scenic River...................................................................................................221

Wild and Scenic Rivers: Environmental Consequences...................................................................222

Alternative 1 (Proposed Action).....................................................................................................222

Alternative 2 (No Action)................................................................................................................223

Alternative 3...................................................................................................................................223

Alternative 4...................................................................................................................................224

Alternative 5...................................................................................................................................224

Wilderness: Affected Environment ...................................................................................................224

Wilderness: Environmental Consequences......................................................................................225

Alternative 1 (Proposed Action).....................................................................................................225

Alternative 2 (No Action)................................................................................................................226

Alternative 3...................................................................................................................................226

Alternative 4...................................................................................................................................226

Alternative 5...................................................................................................................................226

Summary of Effects Analysis across All Alternatives ........................................................................227

Special Interest Areas ...................................................................................................................227

Wild and Scenic Rivers..................................................................................................................227

Wilderness.....................................................................................................................................227

3.13 VEGETATION .......................................................................................................................................229

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction ....................................229

Effects Analysis Methodology ...........................................................................................................231

Assumptions Specific to Vegetation ..............................................................................................231

Data Sources................................................................................................................................. 231

Vegetation Indicators.....................................................................................................................232

Vegetation Methodology by Action ................................................................................................234

Affected Environment........................................................................................................................244

Historic Forest Structure................................................................................................................245

Pre-Fire Vegetation .......................................................................................................................247

Rim Fire.........................................................................................................................................249

Existing Conditions ........................................................................................................................250

Environmental Consequences ..........................................................................................................256

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Alternative 1 (Proposed Action).....................................................................................................256

Alternative 2 (No Action)................................................................................................................269

Alternative 3...................................................................................................................................277

Alternative 4...................................................................................................................................281

Alternative 5...................................................................................................................................284

Summary of Effects Analysis across All Alternatives.........................................................................286

3.14 VISUAL RESOURCES ............................................................................................................................289

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction ....................................289

Effects Analysis Methodology ...........................................................................................................289

Assumptions Specific to Visual Resources....................................................................................289

Data Sources................................................................................................................................. 289

Visual Resources Indicators ..........................................................................................................289

Visual Resources Methodology by Action......................................................................................289

Affected Environment........................................................................................................................290

Existing Conditions ........................................................................................................................290

Environmental Consequences ..........................................................................................................293

Alternative 1 (Proposed Action).....................................................................................................293

Alternative 2 (No Action)................................................................................................................296

Alternative 3...................................................................................................................................296

Alternative 4...................................................................................................................................297

Alternative 5...................................................................................................................................298

Summary of Effects Analysis across All Alternatives.........................................................................298

VQOs Achieved Indicator ..............................................................................................................298

Degree of Natural Appearance Indicator .......................................................................................298

3.15 WATERSHED .......................................................................................................................................299

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction ....................................299

Effects Analysis Methodology ...........................................................................................................299

Assumptions Specific to Watershed ..............................................................................................300

Data Sources................................................................................................................................. 300

Watershed Indicators.....................................................................................................................300

Watershed Methodology by Action ................................................................................................300

Affected Environment........................................................................................................................301

Watershed Setting .........................................................................................................................301

Existing Conditions ........................................................................................................................304

Environmental Consequences ..........................................................................................................311

Alternative 1 (Proposed Action).....................................................................................................311

Alternative 2 (No Action)................................................................................................................328

Alternative 3...................................................................................................................................331

Alternative 4...................................................................................................................................333

Alternative 5...................................................................................................................................335

Summary of Effects Analysis across All Alternatives.........................................................................336

Beneficial Uses of Water ...............................................................................................................336

Erosion and Sedimentation............................................................................................................336

Fuel Loading..................................................................................................................................337

Riparian Vegetation .......................................................................................................................337

Stream Condition...........................................................................................................................337

Water Quality................................................................................................................................. 338

3.16 WILDLIFE ............................................................................................................................................339

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction ....................................339

Regional Forester Sensitive Species.............................................................................................339

Threatened, Endangered, Candidate and Proposed Species........................................................339

Effects Analysis Methodology ...........................................................................................................340

Assumptions Specific to Wildlife ....................................................................................................340

Data Sources................................................................................................................................. 341

Wildlife Indicators...........................................................................................................................341

Wildlife Methodology by Action......................................................................................................341

Terrestrial Wildlife: Herbicide Risk Assessment (toxicological effects)..............................................342

Reforestation ................................................................................................................................. 342

Noxious Weeds..............................................................................................................................342

Chemical Descriptions ...................................................................................................................343

Surrogate Species .........................................................................................................................344

Types of Exposure.........................................................................................................................344

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Scenarios ......................................................................................................................................344

Glyphosate Analysis ......................................................................................................................347

Clopyralid Analysis ........................................................................................................................351

Aminopyralid Analysis ...................................................................................................................352

Clethodim Analysis ........................................................................................................................353

Valley Elderberry Longhorn Beetle: Affected Environment ...............................................................358

Species and Habitat Account.........................................................................................................358

Valley Elderberry Longhorn Beetle: Environmental Consequences..................................................359

Death, Injury and Disturbance .......................................................................................................359

Project Related Modifications to Habitat Quality............................................................................359

Indicators.......................................................................................................................................359

Alternatives 1, 3 and 5...................................................................................................................360

Alternatives 1 and 5.......................................................................................................................361

Alternative 2...................................................................................................................................361

Alternative 3...................................................................................................................................362

Alternative 4...................................................................................................................................362

Valley Elderberry Longhorn Beetle: Summary of Effects ..................................................................362

Determinations ..............................................................................................................................362

Valley Elderberry Longhorn Beetle: Compliance...............................................................................363

Bald Eagle: Affected Environment.....................................................................................................364

Species and Habitat Account.........................................................................................................364

Bald Eagle: Environmental Consequences .......................................................................................365

Death, Injury and Disturbance .......................................................................................................365

Habitat Modification.......................................................................................................................365

Indicators.......................................................................................................................................365

Alternatives 1, 3 and 5...................................................................................................................365

Alternative 2...................................................................................................................................367

Alternative 4...................................................................................................................................367

Bald Eagle: Summary of Effects........................................................................................................368

Determinations ..............................................................................................................................368

Bald Eagle: Compliance....................................................................................................................369

California Spotted Owl: Affected Environment ..................................................................................369

Species and Habitat Account.........................................................................................................369

California Spotted Owl: Environmental Consequences.....................................................................372

Death, Injury and Disturbance .......................................................................................................372

Habitat Modification.......................................................................................................................372

Indicators.......................................................................................................................................374

Alternatives 1, 3 and 5...................................................................................................................374

Alternative 2...................................................................................................................................378

Alternative 4...................................................................................................................................378

California Spotted Owl: Summary of Effects .....................................................................................381

California Spotted Owl: Consistency with Draft Interim Recommendations for the Management of 

California Spotted Owl Habitat on NFS Lands ..................................................................................383

Applicable Interim Recommendations ...........................................................................................383

Interim Guidance Consistency.......................................................................................................383

Great Gray Owl: Affected Environment.............................................................................................384

Species and Habitat Account.........................................................................................................384

Great Gray Owl: Environmental Consequences ...............................................................................386

Death, Injury and Disturbance .......................................................................................................387

Habitat modification.......................................................................................................................387

Indicators.......................................................................................................................................387

Alternatives 1, 3 and 5...................................................................................................................387

Alternative 2...................................................................................................................................389

Alternative 4...................................................................................................................................390

Great Gray Owl: Summary of Effects ................................................................................................391

Northern Goshawk: Affected Environment........................................................................................392

Species and Habitat Account.........................................................................................................392

Northern Goshawk: Environmental Consequences...........................................................................394

Death, Injury and Disturbance .......................................................................................................394

Habitat Modification.......................................................................................................................395

Indicators.......................................................................................................................................396

Alternatives 1, 3 and 5...................................................................................................................396

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Alternative 2...................................................................................................................................398

Alternative 4...................................................................................................................................399

Northern Goshawk: Summary of Effects ...........................................................................................400

Determinations...............................................................................................................................401

Pacific Marten: Affected Environment ...............................................................................................402

Species and Habitat Account.........................................................................................................402

Pacific Marten: Environment Consequences.....................................................................................404

Death, Injury and Disturbance .......................................................................................................404

Habitat Modification .......................................................................................................................405

Indicators .......................................................................................................................................405

Alternatives 1, 3 and 5...................................................................................................................406

Alternative 2...................................................................................................................................407

Alternative 4...................................................................................................................................408

Pacific Marten: Summary of Effects ..................................................................................................409

Determinations...............................................................................................................................409

Fisher: Affected Environment............................................................................................................410

Species and Habitat Account.........................................................................................................410

Fisher: Environmental Consequences...............................................................................................414

Death, Injury and Disturbance .......................................................................................................415

Habitat Modification .......................................................................................................................415

Indicators .......................................................................................................................................416

Alternatives 1, 3 and 5...................................................................................................................416

Alternative 2...................................................................................................................................418

Alternative 4...................................................................................................................................419

Fisher: Summary of Effects ...............................................................................................................420

Determinations...............................................................................................................................420

Fisher: Consistency with the Fisher Conservation Strategy ..............................................................422

Applicable Conservation Measures from the Conservation Strategy.............................................422

Consistency with the Fisher Conservation Strategy.......................................................................422

Fringed Myotis, Pallid and Townsend’s Big-Eared Bat: Affected Environment..................................423

Species and Habitat Accounts.......................................................................................................423

Fringed Myotis, Pallid and Townsend’s Big-Eared Bat: Environmental Consequences ....................425

Death, Injury and Disturbance .......................................................................................................426

Habitat Modification .......................................................................................................................426

Indicators .......................................................................................................................................426

Effects Common to Alternatives 1, 3 and 5....................................................................................426

Alternative 2...................................................................................................................................428

Alternative 4...................................................................................................................................429

Fringed Myotis, Pallid and Townsend’s Big-Eared Bat: Summary of Effects.....................................429

Determinations...............................................................................................................................429

Western Bumble Bee: Affected Environment ....................................................................................430

Species and Habitat Accounts.......................................................................................................430

Western Bumble Bee: Environmental Consequences.......................................................................432

Death, Injury and Disturbance .......................................................................................................432

Habitat Modification .......................................................................................................................432

Indicators .......................................................................................................................................433

Alternatives 1, 3 and 5...................................................................................................................433

Alternative 2...................................................................................................................................435

Alternative 4................................................................................................................................... 436

Western Bumble Bee: Summary of Effects .......................................................................................437

Determinations...............................................................................................................................437

Black-Backed Woodpecker: Affected Environment ...........................................................................438

Species and Habitat Account.........................................................................................................438

Black-Backed Woodpecker: Environmental Consequences..............................................................442

Death, Injury and Disturbance .......................................................................................................443

Habitat Modification .......................................................................................................................443

Indicators .......................................................................................................................................444

Alternatives 1, 3 and 5...................................................................................................................444

Alternative 2...................................................................................................................................445

Alternative 4...................................................................................................................................446

Black-backed Woodpecker: Summary of Effects ..............................................................................446

Black-backed Woodpecker: Consistency with Conservation Strategy...............................................447

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Draft Environmental Impact Statement Table of Contents

Mule Deer: Affected Environment .....................................................................................................448

Species and Habitat Account.........................................................................................................448

Mule Deer: Environmental Consequences........................................................................................450

Death, Injury and Disturbance .......................................................................................................450

Habitat Modification.......................................................................................................................450

Indicators.......................................................................................................................................450

Alternative 1, 3 and 5.....................................................................................................................451

Alternative 2...................................................................................................................................453

Alternative 4...................................................................................................................................454

Mule Deer: Summary of Effects ........................................................................................................455

3.17 SHORT-TERM USES AND LONG-TERM PRODUCTIVITY .............................................................................457

3.18 UNAVOIDABLE ADVERSE EFFECTS ........................................................................................................457

3.19 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS ................................................................................457

3.20 OTHER REQUIRED DISCLOSURES ..........................................................................................................457

National Environmental Policy Act ....................................................................................................457

Clean Air Act .....................................................................................................................................458

Clean Water Act................................................................................................................................458

Endangered Species Act...................................................................................................................458

Rim Fire Recovery (2014) .............................................................................................................458

Rim Fire Reforestation (2015) .......................................................................................................459

Environmental Justice.......................................................................................................................459

Floodplain Management....................................................................................................................459

Migratory Bird Treaty Act ..................................................................................................................459

National Forest Management Act......................................................................................................460

National Historic Preservation Act.....................................................................................................461

Protection of Wetlands ......................................................................................................................461

4. Consultation and Coordination ................................................................................................ 463

4.01 PREPARERS AND CONTRIBUTORS..........................................................................................................463

4.02 DISTRIBUTION OF THE DEIS..................................................................................................................467

Index .................................................................................................................................................. 469

References ........................................................................................................................................ 471

A. Abbreviations and Acronyms ................................................................................................... 505

B. Cumulative Effects Analysis..................................................................................................... 509

C. Glossary...................................................................................................................................... 515

D. Human Health and Ecological Risk Assessment ................................................................... 527

E. Treatments.................................................................................................................................. 547

N. Noxious Weed Schedule .........................................................................................project record

R. Reforestation Schedule...........................................................................................project record

List of Maps included in Map Package

Map 1 Desired Future Condition - Alternatives 1, 3, 4 and 5 .......................................... map package

Map 2 Proposed Treatment - Alternatives 1, 3 and 5...................................................... map package

Map 3 Proposed Treatment - Alternative 4 ..................................................................... map package

Map 4 Noxious Weed Treatment - Alternatives 1 and 5.................................................. map package

Map 5 Noxious Weed Treatment - Alternatives 3 and 4.................................................. map package

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Table of Contents National Forest

List of Figures

Figure 1.02-1 Rim Fire view shows mosaic of vegetation burn severity with different reforestation needs ... 2

Figure 1.02-2 Rim Fire Vicinity Map .............................................................................................................. 3

Figure 1.02-3 Large Fire History Map ........................................................................................................... 6

Figure 1.03-1 2014 view of private land (brush) and NFS land planted in 1993............................................ 8

Figure 1.04-1 Rim Fire Reforestation Proposed Action Treatment Units ....................................................13

Figure 2.02-1 Alternative 1 Planting Prescriptions ......................................................................................27

Figure 2.02-2 Alternative 1 Planting Prescriptions with 25% Expected Mortality.........................................28

Figure 2.02-3 Reforestation landscape strategy..........................................................................................29

Figure 2.02-4 Meadow prescription strategy ...............................................................................................29

Figure 3.02-1 Smoke from the Rim Fire Billlows Over Groveland and Affects Air Quality...........................66

Figure 3.05-1 Shrub Regeneration Two Years after the 2013 Rim Fire ....................................................119

Figure 3.11-1 Surface Organic Mulch after Different Treatments..............................................................197

Figure 3.13-1 Average Landscape Forest Structure before Rim Fire Compared to Historic Conditions ...247

Figure 3.13-2 Average Landscape Forest Structure after Rim Fire Compared to Historic Conditions ......250

Figure 3.13-3 Retention of Standing Dead Trees during Salvage in Femmons Meadow Area .................251

Figure 3.13-4 Distribution of Natural Conifer Regeneration within Areas Proposed for Reforestation ......255

Figure 3.13-5 Understory Vegetation in 15-Year Old Walton Cabin Plantations Prior to the Rim Fire ......257

Figure 3.13-6 Forest Regeneration Comparison near Crane Meadow Following 1973 Granite Fire.........270

Figure 3.14-1 View from the Highway 120 Rim of the World Vista (October 2013)...................................291

Figure 3.14-2 Lightly Burned Landscape Surrounding Rainbow Pool Day Use Area (May 2015).............291

Figure 3.14-3 Shrub Regeneration After Two Growing Seasons (May 2015) ...........................................292

Figure 3.14-4 Lupine in Foreground with burned Oaks and Conifers in the Background (May 2015).......292

Figure 3.14-6 Fifty Year Old Pine Plantation (Wrights Creek Fire) Near the Rim Fire (May 2015)............294

Figure 3.15-1 HUC Level 6 Watersheds in the Rim Fire Area...................................................................303

Figure 3.16-1 Pre-Rim Fire Suitable Female Fisher Home Ranges (2015)...............................................413

List of Tables

Table S.01-1 Significant Issues ................................................................................................................. xiv

Table S.01-2 Comparison of Alternatives: Proposed Treatments..............................................................xvii

Table S.01-3 Comparison of Alternatives: Summary of Effects for Selected Indicators ............................xvii

Table 1.03-1 Structural characteristics of single trees, small, medium and large clumps ..........................11

Table 1.04-1 Updates to the Proposed Action ...........................................................................................14

Table 1.08-1 Significant Issues ..................................................................................................................18

Table 2.02-1 Deer Habitat Treatments.......................................................................................................24

Table 2.02-2 Planting Design by Landscape Position in Alternative 1 .......................................................26

Table 2.02-3 Management requirements incorporating BMPs and Forest Plan S&Gs ..............................32

Table 2.02-4 Variable tree planting strategy ..............................................................................................34

Table 2.03-1 Operating requirements for mechanized equipment operations in RCAs .............................44

Table 2.03-2 Management requirements incorporating BMPs and Forest Plan S&Gs ..............................45

Table 2.05-1 Comparison of Alternatives: Proposed Treatments...............................................................50

Table 2.05-2 Comparison of Alternatives: Reforestation Treatments outside Deer Habitat Enhancement 50

Table 2.05-3 Comparison of Alternatives: Fuel Breaks and Other Key Fire Areas ....................................51

Table 2.05-4 Comparison of Alternatives: Summary of Effects..................................................................51

Table 3.02-1 Alternatives 1, 2, 3, 4 and 5: Emissions under understory and jackpot burning (tons).........67

Table 3.02-2 Alternatives 1, 2, 3, 4 and 5: Smoke Emissions at Year 20 (Wildfire Conditions, tons)........67

Table 3.02-3 Alternatives 1, 2, 3, 4 and 5: Greenhouse Gas Emissions (Prescribed Burning).................68

Table 3.02-4 Alternatives 1, 2, 3, 4 and 5: Greenhouse Gas Emissions (Wildfire Conditions)..................68

Table 3.03-1 Existing Condition Summary for Suitable CRLF Breeding Habitats ...................................... 77

Table 3.03-2 Occupied and Suitable Habitat for FYLF in the Project Area ................................................80

Table 3.03-3 Occupied and Suitable Habitat for WPT in the Project Area .................................................81

Table 3.03-4 Watersheds and Streams with FYLF Suitable Habitat with Watershed Post-fire Response . 84

Table 3.03-5 CRLF and SNYLF Direct and Indirect Effect Indicators for Each Alternative ........................88

Table 3.03-6 Alternative 1: Buffer Treatment in FYLF Suitable Habitat ....................................................92

Table 3.03-7 Alternative 1: WPT Buffer Affected Units .............................................................................94

Table 3.05-1 Surface Fire Flame Length and Fireline Intensity Suppression Interpretations...................115

Table 3.05-2 Fuel Models within the Rim Reforestation Project Area......................................................115

Table 3.05-3 Weather Parameters for High Conditions (90th Percentile Weather)..................................116

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Table 3.06-1 Invasive Species within Rim Fire and Known Populations Proposed for Treatment...........124

Table 3.06-2 Ground Disturbing Activities by Alternative.........................................................................126

Table 3.07-1 Estimated Acres of Impactive Weeds in Grazing Allotments ..............................................133

Table 3.07-2 Alternative 1: Treatments in Grazing Allotments................................................................134

Table 3.07-3 Reforestation in Capable Rangeland ..................................................................................134

Table 3.07-4 Alternative 1: Noxious Weed Eradication in Capable Rangeland ......................................136

Table 3.07-5 Alternative 3: Noxious Weed Eradication in Capable Rangeland ......................................140

Table 3.07-6 Alternative 4: Treatments in Grazing Allotments................................................................141

Table 3.07-8 Comparison of Alternatives: Treatments within Allotments and Capable Rangelands........143

Table 3.08-1 Recreation Opportunity Spectrum Classes within the Rim Reforestation project area .......147

Table 3.09-1 Alternatives 1, 3 and 5: Sensitive Plant Occurences Overlapping Treatment Areas..........159

Table 3.09-2 Alternative 1: Occurrences Intersecting Manual Treatments .............................................160

Table 3.09-3 Alternatives 1, 3, 4 and 5: Sensitive Plants Overlapping Cumulative Effects Activities......161

Table 3.09-4 Alternative 4: Sensitive Plants Overlapping Proposed Reforestation Activities..................162

Table 3.09-8 Comparison of Alternatives: Impacts to Sensitive Plants....................................................164

Table 3.10-1 Average Estimated Cost of Treatment Actions per Acre.....................................................167

Table 3.10-2 Real Discount Rates to be Used in Federal Decisions Considered in 2015........................168

Table 3.10-3 Historical Population by County for U.S. Census Years: 1970 – 2010................................170

Table 3.10-4 Projected Population by County for 10-Year Periods: 2015 – 2055....................................170

Table 3.10-5 Ethnic Minority Populations in the Region of Impact...........................................................171

Table 3.10-6 Age, Income and Poverty Characteristics in the Region of Impact .....................................171

Table 3.10-7 Tuolumne County Industry Employment and Labor Force by Annual Average...................172

Table 3.10-8 Mariposa County Industry Employment and Labor Force by Annual Average....................173

Table 3.10-9 Alternative 1: Present Net Cost of Treatments...................................................................176

Table 3.10-10 Alternative 1: Present Net Benefits Derived from Thinning or Harvesting Timber..............177

Table 3.10-11 Alternative 1: Jobs Created in Tuolumne and Mariposa Counties .....................................178

Table 3.10-12 Alternative 2: Present Net Benefits Derived from Thinning or Harvesting Timber..............181

Table 3.10-13 Alternative 3: Present Net Cost of Treatments...................................................................183

Table 3.10-14 Alternative 3: Present Net Benefits Derived from Thinning or Harvesting Timber..............183

Table 3.10-15 Alternative 3: Jobs Created in Tuolumne and Mariposa Counties .....................................184

Table 3.10-16 Alternative 4: Present Net Cost of Treatments...................................................................185

Table 3.10-17 Alternative 4: Present Net Benefits Derived from Thinning or Harvesting Timber..............185

Table 3.10-18 Alternative 4: Jobs Created in Tuolumne and Mariposa Counties .....................................186

Table 3.10-19 Alternative 5: Present Net Cost of Treatments to be Performed........................................187

Table 3.10-20 Alternative 5: Present Net Benefits Derived from Thinning or Harvesting Timber..............188

Table 3.10-21 Alternative 5: Jobs Created in Tuolumne and Mariposa Counties .....................................188

Table 3.10-22 Summary of Economic Efficiency by Alternative (in $1,000s).............................................189

Table 3.10-23 Summary of Jobs Created by Alternative (in FTEs)............................................................190

Table 3.11-1 Soil Families and Associated Properties Used in Analysis .................................................195

Table 3.11-2 Summary of Existing Condition of Indicators ......................................................................196

Table 3.11-3 Comparison of Alternatives: Summary of Erosion Hazard Rating (EHR)............................210

Table 3.12-1 Outstandingly Remarkable Values and River Classifications for Wild and Scenic Rivers...214

Table 3.12-2 Wild and Scenic River Corridors Affected by the Rim Fire..................................................219

Table 3.12-3 Tuolumne Wild and Scenic River Classifications ................................................................222

Table 3.13-1 California Wildlife Habitat Relationship (CWHR) size classes ............................................233

Table 3.13-2 California Wildlife Habitat Relationship (CWHR) density classes .......................................234

Table 3.13-3 Adaption of CALVEG and CWHR to Forest Successional Classes ....................................234

Table 3.13-4 Third-Year Seedling Survival: Weighted Average Estimates Based on Local Records ......240

Table 3.13-5 Acres of CALVEG Cover Types within the Rim Fire Perimeter, STF and Project Area ......247

Table 3.13-6 Acres by Pre-Rim Fire CWHR Vegetation Type, Tree Size, Canopy and Seral Stage .......248

Table 3.13-7 Acres by Post-Rim Fire CWHR Vegetation Type, Tree Size, Canopy and Seral Stage......252

Table 3.13-8 Natural Conifer Regeneration within Areas Proposed for Reforestation .............................255

Table 3.13-9 Alternative 1 Tree Density and Characteristics at Years 10, 20 and 60..............................259

Table 3.13-10 Alternative 2 Tree Density and Characteristics at Years 10, 20 and 60..............................271

Table 3.13-11 Alternative 3 Tree Density and Characteristics at Years 10, 20 and 60..............................278

Table 3.13-12 Alternative 4 Tree Density and Characteristics at Years 10, 20 and 60..............................281

Table 3.13-13 Alternative 5 Tree Density and Characteristics at Years 10, 20 and 60..............................284

Table 3.13-14 Comparison of Alternatives: Summary of Effects for Reforestation ....................................288

Table 3.13-15 Comparison of Alternatives: Summary of Effects for Existing Plantations ..........................288

Table 3.15-1 Hydrologic Unit Code System (HUC)..................................................................................301

Table 3.15-2 Rim Fire Area Principal Watersheds and Condition Overview............................................302

Table 3.15-3 Soil Burn Severity for Selected Fires in Relation to the Rim Fire........................................305

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Table 3.15-4 Riparian Conservation Area Soil and Vegetation Burn Severity..........................................308

Table 3.15-5 Rim Fire Stream Condition Summary for Stream Channel and Stream Habitat Indicators . 309

Table 3.15-6 Alternative 1: Mechanical Activities by Soil Burn Severity..................................................312

Table 3.15-7 Alternative 1: Annual Percent ERA for HUC 6 and HUC 7 Analysis Watersheds ..............324

Table 3.15-8 Alternative 2: Annual Percent ERA for HUC 6 and HUC 7 Analysis Watershed ................331

Table 3.15-9 Alternative 3: Mechanical Activities by Soil Burn Severity..................................................332

Table 3.15-10 Alternative 3: Annual Percent ERA for HUC 6 and HUC 7 Analysis Watershed ................333

Table 3.15-11 Alternative 4: Mechanical Activities by Soil Burn Severity..................................................334

Table 3.15-12 Alternative 4: Annual Percent ERA for HUC 6 and HUC 7 Analysis Watershed ................335

Table 3.15-13 Alternative 5: Annual Percent ERA for HUC 6 and HUC 7 Analysis Watershed ................336

Table 3.16-1 Endangered, Threatened, Candidate, Sensitive and Species of Conservation Concern ....340

Table 3.16-2 Summary of Hazard Quotients for Terrestrial Wildlife – Glyphosate...................................354

Table 3.16-3 Summary of Hazard Quotients for Terrestrial Wildlife – Clopyralid .....................................355

Table 3.16-4 Summary of Hazard Quotients for Terrestrial Wildlife – Aminopyralid ................................356

Table 3.16-5 Summary of Hazard Quotients for Terrestrial Wildlife – Clethodim.....................................357

Table 3.16-6 Alternatives 1, 3 and 5: Spotted Owl PAC Acres by Treatments and Desired Condition ...375

Table 3.16-7 Alternatives 1, 3 and 5: Spotted Owl HRCA Acres by Treatment and Desired Condition ..376

Table 3.16-8 Alternative 4: Spotted owl HRCA Acres by Treatment and Desired Condition...................379

Table 3.16-9 California Spotted Owl Summary of Effects: Future Moderate to High Capability Habitat ..381

Table 3.16-10 Great Gray Owl Summary of Effects: Future Moderate to High Capability Habitat ............391

Table 3.16-11 Alternatives 1, 3 and 5: Proposed Treatment Acres within Goshawk Post-fledging Areas 397

Table 3.16-12 Alternative 4: Proposed Treatment Acres within Goshawk Post-fledging Areas ................400

Table 3.16-13 Northern Goshawk Summary of Effects: Future Moderate to High Capability Habitat .......401

Table 3.16-14 Pacific Marten Summary of Effects: Future Moderate to High Capability Habitat ..............409

Table 3.16-15 Fisher Summary of Effects: Future Moderate to High Capability Habitat...........................420

Table 3.16-16 Western Bumble Bee Summary of Effects: Habitat Modified ..............................................437

Table 3.16-17 Amount of Suitable Black-Backed Woodpecker Habitat in the Rim Fire Area.....................441

Table 3.16-18 Blacked-Backed Woodpecker Summary of Direct and Indirect Effects...............................447

Table 3.16-19 Blacked-Backed Woodpecker Summary of Cumulative Effects..........................................447

Table 3.16-20 Mule Deer Summary of Effects ...........................................................................................455

Table B.01-1 Present National Forest System land disturbance actions..................................................510

Table B.01-2 Reasonably foreseeable National Forest System land disturbance actions........................512

Table D.01-1 Proposed Application Rates of Glyphosate.........................................................................528

Table D.01-2 Worker Exposure from Backpack Application of Glyphosate ..............................................535

Table D.01-3 General Public Exposure from Backpack Application of Glyphosate ..................................536

Table D.01-4 Worker Hazard Quotients (Toxicity)....................................................................................538

Table D.01-5 Hazard Quotients (Toxicity) for the General Public .............................................................538

Table E.01-1 Alternative 1: Reforestation Treatments.............................................................................547

Table E.01-2 Alternative 3: Reforestation Treatments.............................................................................555

Table E.01-3 Alternative 4: Reforestation Treatments.............................................................................563

Table E.01-4 Alternative 5: Reforestation Treatments.............................................................................567

Table E.02-1 Alternative 1: Natural Regeneration Treatments................................................................577

Table E.02-2 Alternative 3: Natural Regeneration Treatments................................................................579

Table E.03-1 Alternatives 1, 3, 4 and 5: Thin Existing Plantation Treatments .........................................581

Table E.04-1 Alternative 1: Deer Reforestation Treatments....................................................................587

Table E.04-2 Alternative 3: Deer Reforestation Treatments....................................................................587

Table E.04-3 Alternative 4: Deer Reforestation Treatments....................................................................588

Table E.04-4 Alternative 5: Deer Reforestation Treatments....................................................................588

Table E.05-1 Alternatives 1, 3, 4 and 5: Deer Habitat Enhancement Treatments ...................................589

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Draft Environmental Impact Statement Summary

Summary

The Forest Service prepared this Draft Environmental Impact Statement (DEIS) in compliance with 

the National Environmental Policy Act (NEPA) and other relevant Federal and State laws and 

regulations. This DEIS discloses the environmental impacts that would result from the proposed 

action, a no action alternative and 3 additional action alternatives developed in response to issues 

raised by the public. The Responsible Official has not identified a preferred alternative at this stage.

Background

The Rim Fire started on August 17, 2013 in a remote area of the Stanislaus National Forest near the 

confluence of the Clavey and Tuolumne Rivers about 20 miles east of Sonora, CA. Over several 

weeks it burned 257,314 acres, or 400 square miles including 154,530 acres of National Forest 

System (NFS) lands. The fire also burned within Yosemite National Park (78,895 acres), Sierra 

Pacific Industries private timberland (16,035 acres), other private land (7,725 acres) and Bureau of 

Land Management (BLM) land (129 acres). The Rim Fire Reforestation (Rim Reforestation) project 

is located within the Rim Fire perimeter in the Stanislaus National Forest on portions of the Mi-Wok 

and Groveland Ranger Districts (T3N-T2S, R16E-R19E; MDBM). The project area includes all NFS 

lands within the fire. It does not include Wilderness or any private, state or other federal lands.

Purpose and Need

Based on Forest Plan Direction, the overall purpose of the Rim Reforestation project is to: create a 

fire resilient mixed conifer forest that contributes to an ecologically healthy and resilient landscape 

rich in biodiversity. The following needs are based on the overall purpose and desired future 

conditions for Old Forest Mosaic, Open Canopy Mosaic and Deer Emphasis. Chapter 1.03 provides 

additional details. 

1. Return Mixed Conifer Forest to the Landscape

Promote the re-establishment and recovery of conifer forests with diverse structure and composition 

to quickly meet future resource needs for wildlife, recreation, watershed and timber while taking into 

account potential pressures of a changing climate. The overall goal is to re-establish a conifer forest in 

an effort to contribute to an ecologically healthy and resilient landscape rich in biodiversity. This 

landscape would have an increased capacity to adapt and survive natural disturbances, especially

under changing and uncertain future environmental conditions, such as those driven by climate 

change and human use. This project looks at the short-term (up to 10 years) proposing activities that 

incrementally move toward these long-term (60 to 100 years) goals, returning healthy vigorous trees 

in a mosaic of forest conditions across the landscape. (Old Forest Mosaic, Open Canopy Mosaic and 

Deer Emphasis Desired Future Conditions)

2. Restore Old Forest for Wildlife Habitat and Connectivity

Restore old forest composition and structure to provide critical habitat for sensitive wildlife species 

such as the California spotted owl, northern goshawk and fisher. This includes restoring habitat 

connectivity compromised in the Rim Fire that is essential for wildlife dispersal, migration, and use of 

suitable habitat across the landscape. (Old Forest Mosaic Desired Future Condition)

3. Reduce Fuels for Future Fire Resiliency

Reduce the fuel load that exists from standing dead trees and re-sprouting brush, including portions of 

the burned area within existing older plantations. Re-establish open canopy forest stands to safely 

reintroduce fire into the landscape through fuels and vegetation management. (Open Canopy Mosaic 

Desired Future Condition) 

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Stanislaus

Summary National Forest

4. Enhance Deer Habitat

Restore forested conditions within critical winter deer range, providing thermal and hiding cover and 

access to high quality forage essential for over-wintering deer. (Deer Emphasis Desired Future 

Condition) 

5. Eradicate Noxious Weeds

Prevent new infestations of noxious weeds and the spread of existing weeds as the result of project 

activities. Reduce the quantity and extent of noxious weeds, and manage their adverse impacts on 

ecosystem structure and function, contribution to fine fuels, competition to young seedlings and 

impacts to biodiversity and native plants. (Old Forest Mosaic, Open Canopy Mosaic and Deer 

Emphasis Desired Future Conditions) 

Proposed Action

The Forest Service proposed action described in more detail as Alternative 1 (Proposed Action) 

includes the following treatments: Deer Habitat Enhancement (3,833 acres); Natural Regeneration 

(4,031 acres); Noxious Weed Eradication (5,915 acres); Reforestation (21,300 acres); and, Thin 

Existing Plantations (12,769 acres). Chapter 1.04 and Chapter 2.02 provide additional details.

Significant Issues

Scoping identified significant issues which are used to formulate alternatives, prescribe mitigations 

measures, or analyze environmental effects. Table S.01-1 displays the significant issues with issue 

statements based on public comments. Chapter 1.08 provides additional details. 

Table S.01-1 Significant Issues

Issue/Element Cause and Effect

1. Herbicides: The proposed herbicide applications may adversely affect human and other natural resources.

1.1 Human Health a. Toxins may contaminate the water supply, food chain and land, impacting residents and visitors 

through reproductive and developmental harm.

1.2 Native Species 

Health and 

Diversity

a. Herbicides may irretrievably alter natural post-fire successional habitat causing loss of significant 

biodiversity.

b. Application of glyphosate formulations and other less understood herbicides may have negative 

direct, indirect and cumulative effects on aquatic species and terrestrial wildlife including: mortality; 

impaired growth and development; modified behavior; and, physiological or morphological effects.

2. Reforestation 

Method:

The proposed reforestation methods may adversely affect human and other natural resources.

2.1 Local Economy a. Reforestation at low rates may take too long to reclaim control of the brush and competing vegetation.

b. Future budgets may not provide adequate funding to control competing vegetation or thin trees.

c. Low density planting may not provide a sustainable, long-term supply of wood needed to maintain the 

forest products infrastructure in Tuolumne County.

2.2 Native Species 

Health and 

Diversity

a. High density planting may limit fire use and foster unhealthy landscapes lacking biodiversity with 

reduced resiliency to drought, insects and wildfire.

b. Low density planting may reduce wildlife hiding cover subjecting wildlife to increased vehicle related 

mortality, predation and poaching.

2.3 Forest 

Establishment

a. Wide and variable spacing and gaps between planted trees may complicate the planting process,

favor competing vegetation and delay establishment of a new forest.

2.4 Fire Hazard a. High density planting may result in fire-prone trees preventing early and frequent use of prescribed 

and natural fire.

b. Wide and variable spacing and gaps between planted trees may result in areas with undesirable 

vegetation and increased fuel loading.

Alternatives Considered in Detail

The action alternatives (Alternatives 1, 3, 4 and 5) and the no action alternative (Alternative 2) are 

considered in detail. Chapter 2.02 provides more details for the following alternatives. 

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Rim Fire Reforestation (45612)

Draft Environmental Impact Statement Summary

Alternative 1 (Proposed Action)

Alternative 1 includes planting conifers on up to 21,300 acres, utilizing landscape position, Strategic 

Fire Management Areas and elevation to determine composition and density. Site preparation for 

planting includes: deep till and forest cultivation, mechanically removing or pile and burning dead 

material, manually applying herbicides, mastication, and prescribed fire (understory burning and 

jackpot burning). Release treatments include hand grubbing or manually applying herbicides 

(glyphosate) on up to 21,300 acres. Prescribed fire is proposed in new plantations within the first ten 

years. Deer habitat enhancement includes: planting conifers on up to 646 acres, monitoring 33 acres 

for natural regeneration, thinning 1,164 acres of existing plantation, and prescribed burning on 3,833 

acres. Proposed natural regeneration includes monitoring 4,031 acres for conifer species composition 

and number of trees across the landscape to determine if site preparation, planting, release, and

prescribed burning would occur. Alternative 1 includes understory burning and thinning on up to 

12,769 acres within existing plantations (outside of Deer Enhancement areas). Noxious weed 

eradication is proposed on up to 5,915 acres. 

Alternative 2 (No Action)

Alternative 2 (No Action) as required by the implementing regulations of NEPA, serves as a baseline 

for comparison among the alternatives (73 Federal Register 143, July 24, 2008; p. 43084-43099). 

Under Alternative 2, deer habitat enhancement, noxious weed eradication, reforestation (site 

preparation, planting conifers, release and reintroduction of prescribed fire) and thinning would not 

occur. Current management plans would continue to guide management of the project area.

Alternative 3

Alternative 3 responds to the significant issues and concerns identified through public scoping by 

proposing: additional human and native species health protections (no herbicides) and a different fuel 

break ridge treatment responding to the reforestation issue of fire hazard. Because no herbicides 

would be used for site preparation, release or noxious weed eradication, additional deep tilling and 

forest cultivation and manual grubbing treatments were added. Proposed reforestation includes a 

variable density planting design with more trees initially planted due to higher expected mortality. 

Noxious weed eradication is proposed on 3,350 acres, about one half of the acres proposed under 

Alternative 1.

Alternative 4

Alternative 4 responds to the significant issues and concerns identified through public scoping by 

proposing: considerably fewer planted acres and trees and the reintroduction of early and frequent use 

of prescribed and natural fire within and adjacent to these stands. Thousands of acres, proposed in 

Alternative 1, would not have initial mechanical fuels treatments and would remain unplanted in 

Alternative 4. Reforestation would occur on 2,867 acres using a founder stand planting design; small 

variable-shaped planted areas ranging from 2 to 10 acre in size that occupy about 20 percent of each 

unit. Release treatments include manually applying herbicides (glyphosate) on up to 4,012 acres. In 

addition, complex early seral forest is left intact and removed from reforestation consideration. 

Noxious weed eradication is proposed on 3,350 acres, about one half of the acres proposed under 

Alternative 1.

Alternative 5

Alternative 5 responds to the significant issues and concerns identified through public scoping by 

proposing: planting at a denser 7-foot by 14-foot spacing throughout deer habitat enhancement areas, 

natural regeneration units and reforestation units that include thinning into an open mosaic structure. 

This would result in a 6 to 8-foot by 12 to 16-foot spacing when applied on the ground at 444 trees 

per acre. Alternative 5 does not include prescribed fire post-planting in new plantations.

xv
Stanislaus

Summary National Forest

Alternatives Considered but Eliminated from Detailed Study

NEPA requires that federal agencies rigorously explore and objectively evaluate all reasonable 

alternatives and briefly discuss the reasons for eliminating any alternatives that were not developed in 

detail (40 CFR 1502.14). Public comments and internal scoping suggested the alternatives briefly 

described below. Chapter 2.04 provides the reasons for eliminating them from detailed study. 

a. Natural Succession

Allow the forest to recover naturally. This differs from “No Action” by including measures to 

thin existing plantations. Natural forest recovery occurs through recruitment of new populations 

from adjacent seed sources rather than planted seedlings.

b. Natural Regeneration with Founder Stands

Allow most of the forest to recover naturally. Outside complex early seral forest, plant founder 

stands: small variable-shaped areas less than 2 acres in size within a larger (10-acre total) area. 

On each of the 2 acres, plant 40 5-tree clusters spaced 6 feet between each tree and spaced 33 feet 

apart. Planting would not occur within 1,000 feet of an established conifer. On areas where no 

natural regeneration occurs, between 1,000 and 2,000 feet from established conifers, reforest 63 

acres beginning 5 years after the 2013 Rim Fire. Only 20% of the 63 acres (i.e., 13 acres) would 

be planted. 

c. Natural Regeneration with Founder Stands with tighter buffers

This alternative is similar to Alternative b (Natural Regeneration with Founder Stands) except for 

planting would not occur within 500 feet of established conifers. On areas between 500 and 1,000 

feet from established conifers where no natural regeneration occurs, reforest 20% of 866 acres 

(173 acres) beginning 5 years after the 2013 Rim Fire using the founder stand guidelines. When 

natural regeneration is not occurring in areas greater than 1,000 feet from live conifer trees, 

reforest immediately to create founder stands on up to 20% of 47 acres (9 acres). 

d. Low Density Planting (Plant 40 to100 Trees per Acre)

This alternative would plant fewer trees per acre to provide an open pre-settlement condition. 

e. Maximum Acres of Planting

Plant all possible areas identified on photos as lacking conifers. Forest recovery occurs through

recruitment of new populations from planted augmentation. 

f. One Herbicide Application

Glyphosate spraying would be limited to either a single site preparation treatment, and then rely 

entirely on hand grubbing or tree growth to out-perform competition, or to use alternative site 

preparation techniques coupled with a single herbicide release treatment in year 1 or 2 to give the 

newly planted tree a boost against competition.

g. Two Herbicide Applications

A maximum of two spray treatments would occur across every acre planted. This option would 

allow no more than one site prep treatment and one release treatment.

h. Spray Areas with 40% or More Bear Clover (two applications)

Glyphosate would only be applied in stands where bear clover covered 40% or more of each acre 

to be planted or 40% of the overall planting unit. Where used to setback bear clover, glyphosate 

in this alternative could be applied for both site prep and for a single release treatment in the year 

chosen by Forest staff as most essential for survival based on field visits for a maximum of two 

applications. 

xvi
Rim Fire Reforestation (45612)

Draft Environmental Impact Statement Summary

Comparison of Alternatives

Table S.01-2 provides a summary comparison of proposed treatments under each alternative. Chapter 

2.05 includes additional details. 

Table S.01-2 Comparison of Alternatives: Proposed Treatments

Proposed Treatments (acres) Alternative 1 

(Proposed Action)

Alternative 2 

(No Action)

Alternative 3 Alternative 4 Alternative 5

Deer habitat enhancement 3,833 0 3,833 1,164 3,833

Natural regeneration 4,031 0 4,031 22,464 0

Noxious weed eradication 5,915 0 3,350 3,350 5,915

Reforestation 21,300 0 21,300 2,867 25,331

Thin existing plantations 12,769 0 12,769 12,769 12,769

Prescribed fire only 0 0 0 34,344 0

Summary of Environmental Consequences

Table S.01-3 provides a summary comparison of effects for selected indicators under each alternative. 

Chapter 3 includes additional details. 

Table S.01-3 Comparison of Alternatives: Summary of Effects for Selected Indicators

Resource and 

Indicator

Alternative 1

(Proposed Action)

Alternative 2

(No Action)

Alternative 3 Alternative 4 Alternative 5

Air Quality: Smoke 

emissions from 

broadcast and machine 

pile burning

Minimal effects to 

local communities 

and Yosemite. 

Wildfire emissions 

would impact sensitive 

groups. 

Same as 1. Similar to 1, but 

more smoke from 

burning.

Same as 1.

Aquatic T&E: 

California red-legged 

frog; Sierra Nevada 

yellow-legged frog

Effects to habitat

from ground

disturbance, fire and 

herbicides. Effects to 

individuals highly 

unlikely due to 

probable absence.

No effects to 

individuals.

Similar to 1, but no 

herbicide use.

Similar to 1, but on 

fewer acres.

Similar to 1, 

but chance of 

increased 

sediment.

Aquatic Sensitive: 

Foothill Yellow-legged 

frog; Hardhead; 

Western pond turtle

Effects to habitat

and individuals from 

ground disturbance, 

fire and herbicides.

No effects to 

individuals.

Similar to 1, but 

increased 

sedimentation and 

no herbicides.

Similar to 1, but on 

fewer acres and 

reduced herbicides. 

Similar to 1, 

but chance of 

increased 

sediment.

Cultural Resources: 

Exposure and integrity 

of prehistoric and 

historic sites.

No effects due to 

following Rim PA

and limited herbicide 

use in prehistoric 

sites.

Indirect effects on

fragile sites from fireweakened trees.

Similar to 1, but 

increased site prep 

may uncover 

unknown cultural 

sites.

Similar to 1, but 

reduced site prep 

and increased 

burning may impact

historic sites.

Same as 1.

Fire and Fuels: Fire 

Behavior

Reduced fire effects 

in treated areas.

Indirect effects may 

create difficult wildfire 

behavior.

Same as 1. Same as 1. Same as 1.

Fire and Fuels:

Strategic Fire 

Management Features

Beneficial effects 

from fuel breaks, 

primary ridge 

treatments and 

emergency travel 

routes.

Indirect effects may 

create difficult fire 

management.

Similar to 1, but 

slightly less 

beneficial effects.

Same as 2. Same as 1.

Invasive Species: Risk 

of Spread

Moderate High High High Moderate

Invasive Species: 

Eradication

High None Moderate Moderate High

xvii
Stanislaus

Summary National Forest

Resource and 

Indicator

Alternative 1

(Proposed Action)

Alternative 2

(No Action)

Alternative 3 Alternative 4 Alternative 5

Range: Impacts to 

range vegetation, 

administration, livestock 

movement and 

infrastructure

Short-term negative 

effects to vegetation 

and livestock 

movement. Longterm benefits from 

noxious weed 

control.

Indirect effects to 

vegetation, 

administration, 

livestock movement 

and infrastructure. 

Similar to 1, but 

increased effects 

to livestock 

movement and no 

noxious weed 

control benefits.

Similar to 1, but no 

noxious weed 

control benefits. 

Same as 1.

Recreation: Short-term

loss of recreation 

opportunities

Short-term effects 

from herbicides;

sights and sounds of 

machinery or 

workers; closures or 

travel delays; and, 

smoke.

None Similar to 1, but 

longer impacts

from machinery or 

workers. 

Similar to 1, but 

diminished in scope.

Similar to 1, 

but with less 

smoke 

impacts.

Recreation: Long-term 

loss of recreation 

opportunity

Beneficial effects

from increased

forest resiliency and 

reduced wildfire risk. 

Recreation patterns 

may shift to other 

areas.

Indirect effects from 

weeds, wildfire risk and

loss of shade in 

favorite areas. 

Similar to 1, but 

increased effects 

on dispersed use.

Same as 1 in treated 

areas. Same as 2 in 

areas not treated. 

Same as 1.

Sensitive Plants May affect 

individuals, but is not 

likely to result in a 

trend toward federal 

listing or loss of 

species viability.

Same as 1. Same as 1. Same as 1. Same as 1.

Society: Present Net 

Value (in $1,000s)

($75,134) $1,871 ($229,626) ($28,042) ($72,294)

Society: Total Jobs 

Supported (in FTEs)

2,369 0 7,764 283 2,302

Soils: Soil Stability Increased short-term 

erosion risk. High 

EHR in 14% of 

treated areas.

Lowest short-term 

erosion risk. Low to 

Moderate EHR only.

Highest short-term 

erosion risk. High 

EHR in 22% of 

treated areas.

Similar to 2, but 

slightly higher 

erosion risk. High 

EHR in 2% of 

treated areas.

Similar to 1, 

but slightly 

higher 

erosion risk.

Soils: Surface Organic 

Matter and Soil Organic 

Matter (SOM)

Reduced surface 

organic matter. 

Short-term increase 

and possible longterm decrease in 

SOM.

None Similar to 1, but 

most reduction in 

surface organic 

matter. 

Similar to 1, but 

least reduction in 

surface organic 

matter (best cover)

and least impact to 

SOM.

Similar to 1, 

but more 

surface 

organic 

matter. 

Special Areas: 

Wilderness Character

Short-term effects

from drift smoke and 

sights and sounds of 

machinery or 

workers near 

Wilderness 

boundary.

None Same as 1. Similar to 1, but 

more smoke 

impacts. 

Similar to 1, 

but less 

smoke 

impacts.

Vegetation: Average 

conifer DBH at year 20 

(inches)

4.3 1.7 2.8 1.9 4.3

Vegetation: Average 

conifer height at year 20 

(feet)

23.2 12.4 16.3 13.1 23.6

Vegetation: Future 

potential timber yield 

(million board feet)

163 42 48 42 160 

xviii
Rim Fire Reforestation (45612)

Draft Environmental Impact Statement Summary

Resource and 

Indicator

Alternative 1

(Proposed Action)

Alternative 2

(No Action)

Alternative 3 Alternative 4 Alternative 5

Watershed: Erosion 

and Sedimentation 

(Thinning and Site 

Preparation Activities)

Creation of sediment 

transport networks. 

No new sediment 

transport networks 

created; hydrological 

and erosional 

responses to the Rim 

Fire would still occur; 

existing skid trail 

sediment transport 

networks remain.

Slight increase in 

ground 

disturbance and 

the potential of 

erosion and 

sediment delivery 

to streams 1. 

Dramatic reduction 

in the creation of 

effective sediment 

transport networks. 

Much less potential 

for erosion and 

sedimentation than 

1. 

Same as 1.

Watershed: Riparian 

Vegetation

Slight beneficial 

effects to riparian 

obligate species, 

SAFs and meadows.

No disturbance to

riparian species. 

Indirect effects from 

lack of sunlight and 

weed control.

Similar to 1, but 

less weed control.

Same as 3. Same as 1.

Watershed: Stream 

Condition

Beneficial effects 

from restoration

improving hillslope 

and riparian 

functions.

Indirect effects from 

continued loss of 

hillslope and riparian 

functions.

Same as 1. Similar to 1, but on 

fewer acres. 

Same as 1.

Watershed: Water 

Quality (Beneficial Uses 

of Water)

No effects to water 

temperature or 

beneficial uses. 

Beneficial effects 

from accelerated 

return to conifer 

forest. Low potential 

for herbicides to 

contaminate water.

None Similar to 1, but no 

herbicides.

Similar to 1, but less 

return to conifer 

forest and 

herbicides. 

Same as 1.

Wildlife T&E: Valley 

elderberry longhorn 

beetle

May affect but is not 

likely to adversely 

affect; will not affect 

Designated Critical 

Habitat.

Same as 1. Same as 1. Same as 1. Same as 1.

Wildlife Proposed 

T&E: Fisher

May affect but is not 

likely to jeopardize 

continued existence.

Same as 1. Same as 1. Same as 1. Same as 1.

Wildlife Sensitive: 

Bald eagle; California 

spotted owl; Great gray 

owl; Northern goshawk; 

Pacific marten; Pallid 

bat, fringed myotis, and 

Townsend’s big-eared 

bat; Western Bumble 

Bee

May affect 

individuals but is not 

likely to result in a 

trend toward federal 

listing or loss of 

viability. 

Same as 1. Same as 1. Same as 1. Same as 1.

Wildlife: Black-backed 

woodpecker

Retains 76 percent 

of modeled pairs.

Retains 100 percent of 

modeled pairs.

Same as 1. Same as 2. Same as 1.

Wildlife: Mule deer Improves 7,000 

acres of critical 

winter deer range.

No improved critical 

winter deer range. 

Same as 1. Improves 3,200 

acres of critical 

winter deer range.

Same as 1.

xix
Stanislaus

Summary National Forest

xx
Rim Fire Reforestation (45612) Chapter 1

Draft Environmental Impact Statement Purpose of and Need for Action

1. Purpose of and Need for Action

The Forest Service prepared this Draft Environmental Impact Statement (DEIS) in compliance with 

the National Environmental Policy Act (NEPA) and other relevant Federal and State laws and 

regulations. This DEIS discloses the direct, indirect and cumulative environmental impacts that would 

result from the proposed action and alternatives.

1.01 DOCUMENT STRUCTURE

The document is organized into the following chapters and sections: 

 Chapter 1 (Purpose of and Need for Action): briefly describes the proposed action, the need for 

that action, and other purposes to be achieved by the proposal. It also details how the Forest 

Service informed the public of the proposed action and how the public responded. 

 Chapter 2 (The Alternatives): provides a detailed description of the proposed action as well as 

alternatives developed in response to comments raised by the public during scoping and 

information gained after the formulation of the proposed action and public scoping period. It 

includes a summary comparison of the action and effects of the alternatives.

 Chapter 3 (Affected Environment and Environmental Consequences): describes the 

environmental impacts of the proposed action and alternatives. 

 Chapter 4 (Consultation and Coordination): provides a list of preparers and others consulted 

during the development of the DEIS.

 Index: provides page numbers by document topic. 

 References: provides a list of references and literature cited in the DEIS.

 Appendices: provide more detailed information to support the analyses presented in the DEIS.

 Map Package: the separate map package includes large scale maps showing treatment units and 

noxious weed areas by Alternative (Chapter 2).

Additional documentation, including detailed analyses of project area resources, may be found in the 

project record located at: Stanislaus National Forest; 19777 Greenley Road; Sonora, CA 95370. 

1.02 BACKGROUND

The Rim Fire started on August 17, 2013 in a remote area of the Stanislaus National Forest near the 

confluence of the Clavey and Tuolumne Rivers about 20 miles east of Sonora, CA. Exhibiting high to 

extreme fire behavior with multiple flaming fronts, the fire made runs of 30,000 to 50,000 acres on 

two consecutive days. It quickly spread up the Tuolumne River watershed and its main tributaries: 

Clavey River, North Fork Tuolumne, Middle Fork Tuolumne, South Fork Tuolumne and Cherry 

Creek. It also overlapped into the North Fork Merced River. Overall, 98% of the Rim Fire occurred in 

the Tuolumne River watershed. Over several weeks it burned 257,314 acres, or 400 square miles

including 154,530 acres of National Forest System (NFS) lands.

1 
Chapter 1 Stanislaus

Purpose of and Need for Action National Forest

The fire also burned within Yosemite National Park (78,895 acres), Sierra Pacific Industries private 

timberland (16,035 acres), other private land (7,725 acres) and Bureau of Land Management (BLM) 

land (129 acres)1

. 

The Rim Fire is the third largest wildfire in California history and the largest wildfire in the recorded 

history of the Sierra Nevada. It is also California’s largest forest fire, burning across a largely conifer 

dominated forest landscape. The two larger fires were wind driven brush fires near San Diego in 2003 

and in Lassen County in 2012. 

The Rim Fire burned between 1,000 to 7,000 feet in elevation in a mixed severity mosaic pattern 

through all its principal vegetative communities. The fire impacted a range of California Wildlife 

Habitat Relationships (CWHR) vegetation types including grass-oak woodlands, chaparral, lower 

westside ponderosa pine, mixed conifer forests and high elevation true fir and lodgepole pine. Figure 

1.02-1 shows an example of the mosaic burn pattern created by the fire. Reforestation is proposed 

within and adjacent to areas that were salvage logged or had fuels treatments under the Rim Fire 

Recovery EIS, within burned 15-to 40-year-old existing plantations and large areas where conifer 

stocking is low and the site is capable, available and suitable for conifer growth. The mosaic pattern 

of the fire resulted in areas of high, moderate and low vegetation burn, and reforestation focuses on 

areas where few if any conifers survived to provide forest cover to meet desired future conditions.

Figure 1.02-1 Rim Fire view shows mosaic of vegetation burn severity with different reforestation needs

Project Location

The Rim Fire Reforestation (Rim Reforestation) project is located within the Rim Fire perimeter 

within portions of the Mi-Wok and Groveland Ranger Districts on the Stanislaus National Forest 

(T3N-T2S, R16E-R19E; MDBM). The project area includes all NFS lands within the fire. It does not 

include Wilderness or any private, state or other federal lands.

1 All acreage figures are based on fire perimeter and land ownership information as of October 24, 2013.

2 

 
Rim Fire Reforestation (45612) Chapter 1

Draft Environmental Impact Statement Purpose of and Need for Action

Figure 1.02-2 shows the location of the Rim Fire within the boundaries of the Stanislaus National 

Forest, Yosemite National Park and the local counties (Mariposa and Tuolumne).

Figure 1.02-2 Rim Fire Vicinity Map

3 
Chapter 1 Stanislaus

Purpose of and Need for Action National Forest

Forest Plan Direction

The Forest Service completed the Stanislaus National Forest Land and Resource Management Plan 

(Forest Plan) on October 28, 1991 (USDA 1991). The Stanislaus National Forest “Forest Plan 

Direction” presents the current Forest Plan management direction, based on the original Forest Plan, 

as amended (USDA 2010a). The Forest Plan Compliance Checklist (project record) provides 

additional details.

The Forest Plan includes Goals, Strategies and Objectives for this project (p. 5-7 and 11-15). The 

following key goals and objectives guided project development. 

Aquatic, Riparian, and Meadow Ecosystems and Associated Species: Maintain and restore 

habitat to support viable populations, spatial and temporal connectivity for aquatic and riparian 

species, water quality and desired physical structures and conditions of streams.

Diversity: Maintain or increase diversity of plants and animals, with a balance of vegetation types 

currently represented on the Forest which best provide for meeting the resource goals and objectives 

of the Forest Plan. 

Fire and Fuels: Provide a cost-effective fire management program to protect Forest resources, life 

and property from the effects of wildfire. Maintain natural and activity fuels at levels commensurate 

with minimizing resource losses from wildfire. Strategically place treatment areas across landscapes 

to interrupt potential fire spread.

Fish and Wildlife: Provide habitat for viable populations of all native and desired non-native 

wildlife, fish and plants. Maintain and improve habitat for Threatened and Endangered species and 

give special attention to sensitive species to see that they do not become Federally listed as 

Threatened or Endangered. 

Noxious Weed Management: Prevent the introduction of new invaders; conduct early treatment of 

new infestations; and, contain and control established infestations.

Old Forest Ecosystems and Associated Species: Restore forest species composition and structure 

following large scale, stand-replacing disturbance events.

Water: Maintain or improve water quality and watershed condition to meet applicable state and 

federal requirements. Realize feasible increases in the quantity of water yield and delays in the timing 

of runoff by including water yield modification as an objective in the design and manipulation of 

commercial and non-commercial vegetation.

Strategy

An event as large as the Rim Fire provides an opportunity to look at restoration at a landscape scale, 

and to consider the many features and structures that are desirable and sustainable for future forested 

conditions. The Forest Plan long-term management goals include goals to create a fire resilient forest 

with a more historic heterogeneous structure where fire is an integral part of the system, not a 

landscape altering force (USDA 2010a, p. 5-15). To sustain forests into the future, natural and 

prescribed fire will be an important tool to protect this area from another landscape-altering event. To 

that end, Forest Service Fire and Fuels staff from the Stanislaus and Pacific Southwest Research 

Station compiled a strategy for the Rim Fire area outlining conditions along with features on the 

landscape that could help reduce the size and severity of future fires.

As a component of this strategy, Fire Emphasis Areas were mapped for the entire burned area as 

Strategic Fire Management Features (emergency travel routes and fuel breaks) and Strategic Fire 

Management Areas (large blocks of land where lower density forest would be found adjacent to 

critical areas). The Fire Emphasis Areas strategy was used to identify key areas across this landscape 

as well as guiding planting and thinning patterns and densities. Other strategy conditions include 

4 
Rim Fire Reforestation (45612) Chapter 1

Draft Environmental Impact Statement Purpose of and Need for Action

heterogeneous forest structure throughout the area (clumped and variable spaced trees), limited 

amounts of trees in plantations on southern and southwestern slopes where natural fire return intervals 

are high and the tree growing ability is low and prescribed and natural fire occurs within stands every 

5 to 20 years. 

Reforestation would be focused on areas that are best suited to support a forest and be more resilient 

when the next fire comes. One of the primary goals of the strategy is to reintroduce fire and/or to let 

natural fire back into proposed and existing plantations as soon as possible in order to ensure the 

long-term existence and viability of this new forest and to follow-up with fuel maintenance 

treatments. The Forest Service recognizes that fire will occur here again and setting up a fire-resilient 

landscape is critical.

In March 2009, PSW released General Technical Report 220, “An Ecosystem Management Strategy 

for Sierran Mixed-Conifer Forests” (GTR 220) (North et al. 2009). GTR 220 emphasized the 

importance of learning from historic conditions to determine sustainable desired conditions. This 

report summarized recent scientific literature suggesting that land managers produce different stand

structures and densities across the landscape using topography and historic fire behavior to guide 

treatments. Historically, both topography and fire influenced forest structure and composition in the 

Sierra Nevada. Management that creates and mimics those historic stand structures and fire-mediated

processes will help restore the natural role of fire on the landscape, create structural heterogeneity at 

multiple scales, and improve habitat quality by providing multilayered canopies and other key 

structures associated with sensitive wildlife species, such as the Pacific fisher, California spotted owl, 

and northern goshawk. 

Forest Service direction and intent, recent science summarized by GTR 220, and the Rim Fire 

Vegetation Resiliency Strategy (project record) provided an extensive foundation of information to 

draw from during the Rim Reforestation planning effort. The analysis in this document focuses on 

restoring ecosystem function, process, and resiliency by addressing issues related to vegetative 

composition and structure, forest health, fuels, hardwood and wildlife habitat improvement, and 

socio-economic objectives. Although these are long-term goals, how and where reforestation is 

conducted, if done at all, will set the stage for future activities in this area and provide some habitat 

components within the burn that will not naturally be available for decades.

The Rim Fire is not the first wildfire that occurred in this area. Since 1944, 20 large fires burned fully 

or partially within the Rim Fire area leaving portions of the area now burned up to four times over 

that period. Figure 1.02-3 shows the large fire history of this wildfire dominated landscape.

Relation to Other Rim Fire Projects

The Rim Fire Hazard Tree (Rim HT) project and the Rim Fire Recovery (Rim Recovery) project 

began the Rim Fire restoration process. Rim HT is essentially complete and Rim Recovery is about 

70% complete and implementation will continue regardless of the decision that is made for the Rim 

Reforestation project. This DEIS considers the effects of the initial two projects as part of the existing 

condition in the cumulative effects analysis (Appendix B).

The Rim Fire Rehabilitation and Rim Fire Habitat Improvement Decision Memo projects were also 

completed to address the repair or improvement of habitat and natural resources, including wildlife 

and sensitive plants, and the protection and improvement of meadow, stream, and spring functions. 

The Rim Reforestation project treatment areas do not overlap with the Rim Fire Rehabilitation and 

Habitat Improvement project treatment areas. Therefore, while this DEIS considers the effects of the 

previously analyzed Rim projects as part of the cumulative effects analysis, they are not connected 

actions under the Council on Environmental Quality (CEQ) NEPA regulations (40 CFR 1508.25 (1)). 

5 
Chapter 1 Stanislaus

Purpose of and Need for Action National Forest

Figure 1.02-3 Large Fire History Map

6 
Rim Fire Reforestation (45612) Chapter 1

Draft Environmental Impact Statement Purpose of and Need for Action

Much of what happens with future restoration actions will depend on information that is simply 

unavailable at this point, and may not be known for months, or even years. Because the Rim 

Reforestation project has independent utility and may proceed regardless of whether future agency 

actions occur within the Rim Fire area, the future actions and this project are not connected actions 

under the CEQ NEPA regulations. Furthermore, because none of the future actions have reached the 

stage of being “identified proposals” that can be meaningfully evaluated, those future actions do not 

meet the definition of “reasonably foreseeable future actions” in the Forest Service NEPA regulations 

(36 CFR 220.3, 220.4(a)(1)). Therefore, additional future restoration and recovery actions are not 

included in the cumulative effects analysis for this project. If there are cumulative effects arising from 

future projects in combination with the residual effects of this project, those cumulative effects will 

be considered as part of the environmental effects analysis for those future projects, to the extent 

required by NEPA. 

1.03 PURPOSE AND NEED

The Interdisciplinary (ID) team identified the following purpose and needs for the Rim Reforestation 

project.

Purpose

Based on the Forest Plan Direction, the overall purpose of the Rim Reforestation project is to: create 

a fire resilient mixed conifer forest that contributes to an ecologically healthy and resilient 

landscape rich in biodiversity. 

Several sensitive wildlife species lost critical habitat when extensive amounts of mature trees were 

burned within the Rim Fire. Large amounts of those dead trees remain. Providing opportunities to

establish forests to this area is critical to sustain populations and for connectivity of habitat for 

wildlife movement and expansion. Without mature live trees to provide a seed source within close 

proximity to the burned areas, or the lack of a viable and healthy cone crop, natural conifer 

regeneration cannot be counted on within large portions of the Rim Fire area. In addition, brush is 

already beginning to dominate sites, inhibiting conifer survival and growth. Without intervention the 

rapidly resprouting brush prevents the slower growing tree seedlings from reaching the sunlight and 

limited water needed for establishment. The land will mostly return to continuous woody brushfields 

that impede wildlife movement and remove the possible establishment of diverse forest habitat. The 

brushfields, along with the dead trees that fall among them, can also quickly spread high intensity 

fire. Under these situations, natural conifer regeneration resulting in a forested landscape could take 

hundreds of years to develop. Figure 1.03-1 shows an example of an area burned in the same fire with 

an unplanted brushfield adjacent to actively reforested land where the prescription included 

mechanical site preparation followed by herbicide release and inter-planting. 

The desired mature forest structures include shaded fuel breaks along key roads and strategic 

locations, large blocks of forest with lower tree densities adjacent to critical areas (i.e. private 

property and old forest emphasis areas), heterogeneous forest structure throughout the area (a mix of 

tree species, sizes, and spacing) and prescribed and natural fire within these stands within the first 10 

years with a 5 to 10 year fire return interval. Such features located across the landscape provide areas 

where fire can be slowed or stopped and provide safe locations for firefighters to work from during 

wildfires and to utilize during prescribed burning activities (Johnson et al. 2013). 

In general, across the landscape, the desired future stand densities range from moderately to lightly 

forested along ridge tops and southerly aspects. Openings are generally less than 0.25 acres 

mimicking historic conditions. Denser stands with high canopy cover are found in drainage bottoms, 

riparian areas and bottom portions of northeast facing slopes with riparian vegetation and conifers 

shading the creeks. Riparian areas have the greatest amounts of large woody material. Openings are 

7 
Chapter 1 Stanislaus

Purpose of and Need for Action National Forest

small and of the lowest spatial frequency in the moister topographic areas. High to moderate stand 

densities and canopy cover is desired mid-slope on north-northeast aspects with higher gap frequency 

and size compared to drainage bottoms, decreasing in density and increasing in openness with 

progression upslope. South-southwest facing slopes are more open with lower tree densities than 

northeast aspects and drainage bottoms. These drier southerly facing slopes have the most drought 

tolerant tree species (ponderosa pine), with fewer trees per acre, open stand conditions and more 

frequent and larger gaps than northeast aspects. Ridgetops and upper southwest topographic positions 

will have the lowest tree densities and most drought tolerant species (ponderosa pine).

Figure 1.03-1 2014 view of private land (brush) and NFS land planted in 1993

Desired Future Conditions 

The desired future conditions described below are based on Forest Plan Direction and input from the 

public, the ID team, and a group of resource specialists representing major disciplines associated with

forest management. This desired landscape would have an increased capacity to adapt and survive 

natural disturbances, especially under changing and uncertain future environmental conditions, such 

as those driven by climate change and human use. This project looks at the short-term (up to 10 years) 

by proposing activities that incrementally move toward these long-term (60 to 100 years) goals, 

returning healthy vigorous trees in a mosaic of forest conditions across the landscape.

OLD FOREST MOSAIC

The desired long-term (60 to 100 years) Old Forest Mosaic condition is heterogeneous Sierran mixedconifer forest based on topographically driven variations in plant water availability (North et al. 

2009). Moderate to high stand densities, a greater proportion of large clumps and generally small 

openings characterize this area. The desired condition consists of Old Forest Emphasis Area (USDA 

2010a, p. 190) characteristics with high levels of horizontal and vertical diversity composed of 

roughly even-aged vegetation groups varying in size, species and structure. It contains patches of 

large trees, an average of 60% to 80% canopy cover and diverse multi-layered canopy and vegetative 

species.

8 
Rim Fire Reforestation (45612) Chapter 1

Draft Environmental Impact Statement Purpose of and Need for Action

OPEN CANOPY MOSAIC

The desired long-term Open Canopy Mosaic forest condition is heterogeneous stands tolerant of high 

frequency low-to-mixed intensity fire with emphasis on fire resiliency. When compared with Old 

Forest Mosaic, a larger proportion of individual trees and small clumps with large and frequent 

openings, characterize this area. The primary desired condition is widely spaced and highly drought 

tolerant ponderosa pines and oaks on south facing slopes and ridge tops. Mixed species are present in 

drainages. Average canopy cover ranges from 40% to 50%. These conditions support the fire and 

fuels objectives while maintaining wildlife habitat and connectivity across the landscape. Fire hazard, 

Strategic Fire Management Areas, wildlife habitat needs, topographic position and soil characteristics 

guide the relative proportion of open stand density, canopy cover and opening size and frequency 

within Open Canopy Mosaic units. 

DEER EMPHASIS

The desired long-term Deer Emphasis condition is a heterogeneous mosaic of forested and high 

quality forage habitat throughout the mule deer winter range and migration corridors, tolerant of lowto-mixed severity fire. Forest areas, primarily ponderosa pine, are found in close proximity, but 

separated from oaks, a primary emphasis within these units. Forest habitat is comprised of both hiding 

and thermal cover. Hiding cover is designed to conceal deer from predators and consists of open 

stands with a canopy cover less than 50% in discrete locations up to 25 acres in size. Thermal cover is 

designed to provide protection from inclement weather and consists of denser stands with an average 

canopy cover of 60% or greater in discrete locations up to 5 acres in size.

Needs 

The following 5 needs are based on Forest Plan Direction, the overall purpose to create a fire 

resilient mixed conifer forest that contributes to an ecologically healthy and resilient landscape 

rich in biodiversity and desired future conditions for Old Forest Mosaic, Open Canopy Mosaic and 

Deer Emphasis. 

1. Return Mixed Conifer Forest to the Landscape

Promote the re-establishment and recovery of conifer forests with diverse structure and composition 

to quickly meet future resource needs for wildlife, recreation, watershed and timber while taking into 

account potential pressures of a changing climate. The overall goal is to re-establish a conifer forest in 

an effort to contribute to an ecologically healthy and resilient landscape rich in biodiversity. This 

landscape would have an increased capacity to adapt and survive natural disturbances, especially 

under changing and uncertain future environmental conditions, such as those driven by climate 

change and human use. This project looks at the short-term (up to 10 years) proposing activities that 

incrementally move toward these long-term (60 to 100 years) goals, returning healthy vigorous trees 

in a mosaic of forest conditions across the landscape. (Old Forest Mosaic, Open Canopy Mosaic and 

Deer Emphasis Desired Future Conditions) 

2. Restore Old Forest for Wildlife Habitat and Connectivity

Restore old forest composition and structure to provide critical habitat for sensitive wildlife species 

such as the California spotted owl, northern goshawk and fisher. This includes restoring habitat 

connectivity compromised in the Rim Fire that is essential for wildlife dispersal, migration, and use of 

suitable habitat across the landscape. (Old Forest Mosaic Desired Future Condition)

3. Reduce Fuels for Future Fire Resiliency

Reduce the fuel load that exists from standing dead trees and re-sprouting brush, including portions of 

the burned area within existing older plantations. Re-establish open canopy forest stands to safely 

reintroduce fire into the landscape through fuels and vegetation management. (Open Canopy Mosaic 

Desired Future Condition) 

9 
Chapter 1 Stanislaus

Purpose of and Need for Action National Forest

4. Enhance Deer Habitat

Restore forested conditions within critical winter deer range, providing thermal cover essential for 

over-wintering deer. (Deer Emphasis Desired Future Conditions) 

5. Eradicate Noxious Weeds

Prevent new infestations of noxious weeds and the spread of existing weeds as the result of project 

activities. Reduce the quantity and extent of noxious weeds, and manage their adverse impacts on 

ecosystem structure and function, contribution to fine fuels, competition to young seedlings and 

impacts to biodiversity and native plants. (Old Forest Mosaic, Open Canopy Mosaic and Deer 

Emphasis Desired Future Conditions)

Project Development

Historically, wildfire and topography interacted with vegetation, creating an array of tree spatial 

patterns (or structures) that can be categorized into three primary components: individual trees, tree 

clumps and openings, referred to as ICO (Churchill et al. 2013; Lydersen et al. 2013). Lydersen et al. 

(2013) studied historic stand structures from the Stanislaus Tuolumne Experimental Forest, just north 

of the Rim Reforestation project area. Table 1.03-1 shows the historic data indicated that more 

frequent fire was likely associated with a greater proportion of the trees being shade-intolerant pine 

existing as individuals and in small clumps, while periods of less frequent fire allowed for ingrowth 

of shade-tolerant species that resulted in higher proportions of the trees existing in large clumps with 

higher tree densities.2

Gap sizes, or forest openings, within a stand can also vary depending on the extent, severity and 

frequency of disturbances. In the case of mixed-severity fire, tree mortality can be isolated to 

individual trees or large patches of trees. In the Rim Fire high severity patches were 

uncharacteristically large and accounted for a larger proportion (35%) of the burned area than 

historically occurred (Miller et al. 2009). Lydersen et al. (2013) defined the minimum size for gaps as 

being an opening in the canopy that is comparable in size to the area dominated by a large tree crown. 

Table 1 shows the range of gap sizes that occurred at the Stanislaus-Tuolumne Experimental Forest. 

While the majority of these gaps were smaller and likely influenced by factors such as low to 

moderate severity disturbances and stand development dynamics, some larger gaps likely occurred as 

a result of high-severity fire. In yellow pine and mixed conifer forests, historic mean high-severity 

patch sizes ranged from 4.2 to 22.5 acres with the majority of the high-severity patches being less 

than 10 acres (Collins and Stephens 2010; Miller et al. 2012; Mallek et al. 2013). Larger mean patch 

sizes were associated with fir-dominated areas, while pine-dominated areas were more likely to 

experience smaller (<15 acres) mean high-severity patches (Collins and Stephens 2010). 

The Forest Service proposed action is guided by the purpose and need, reflecting multiple approaches 

to begin developing the desired future condition. The approaches include using various reforestation 

techniques (e.g., site preparation, planting and release from vegetative competition), actively 

managing residual plantations (thinning to create an ICO structure and favoring a diversity of species)

and promoting natural regeneration where it occurs. Existing conditions, fire potential, long-term 

wildlife habitat needs and topography helped identify and prioritize treatment areas. 

The interdisciplinary team of resource specialists (ID team) spent months developing the proposed 

planting strategies and working with interested publics, attempting to balance short and long-term 

goals. The team looked at planting in various clump and spacing configurations, but found that too 

2 Assumes that the 1929 ≥ 10 inch and 1929 ≥ 4 inch datasets are representative of time since the last fire. That is, more small trees (4-

10 inches) are likely to establish during longer periods without fire. Lydersen et al. (2013) gives further explanation. Assumption is also 

based on an estimated average fire return interval of 5 years with a range of 1 to 40 years in similar forest types throughout the Sierra 

Nevada (Mallek et al. 2013).

10

 
Rim Fire Reforestation (45612) Chapter 1

Draft Environmental Impact Statement Purpose of and Need for Action

few trees per acre would be initially planted in the proposed Old Forest Mosaic areas where the 

desired canopy cover is 60% to 80%. Only by “clumping” trees 1 to 2 feet apart can higher numbers 

be reached, requiring removal in a pre-commercial thin (a situation the ID team wanted to avoid) if all 

trees in a cluster survive. Instead, the ID team looked at several planting scenarios with a typical 

spatial pattern (i.e. 14 feet by 14 feet) allowing for desired canopy cover to be reached sooner in these 

Old Forest Mosaic stands. To break up the spatial continuity, the team is proposing several different 

sized buffers around oaks, roads, riparian vegetation and meadows in addition to no-plant areas such 

as sensitive plant and research sites. Where future desired canopies are 40% to 50% in the Open 

Canopy Mosaic areas, the Forest Service is proposing a variable clumped and spaced planting design, 

focusing on structure or open spacing between crowns to allow for more effective fire management in 

these stands.

Table 1.03-1 Structural characteristics of single trees, small, medium and large clumps

Structure Recently Burned 40 Years Since Last Fire

Single Trees

Singles per acre 6.7 7.3

Proportion of trees (%) 12.6 5.6

Nearest neighbor distance (feet) 28.5 21.0

Small Clumps (2-4 trees)

Clumps per acre 5.8 5.9

Proportion of trees (%) 30.4 13.4

Nearest neighbor distance (feet) 11.2 9.2

Medium Clumps (5-9 trees)

Clumps per acre 2.0 2.9

Proportion of trees (%) 23.5 14.8

Nearest neighbor distance (feet) 10.2 6.6

Large Clumps (10-33 trees)

Clumps per acre 1.3 2.8

Proportion of trees (%) 33.5 66.2

Nearest neighbor distance (feet) 10.2 6.6

Gap Frequency Per Acre

0.03-0.06 acre gaps 0.9 1.3

0.06-0.12 acre gaps 0.7 0.4

0.12-0.25 acre gaps 0.3 0.4

≥0.25 acre gaps 0.5 0.1

(Lydersen et al. 2013)

It is also important to note that 10,635 acres of potential conifer forestland are not being proposed for 

any reforestation treatment for the following reasons: 1) areas were too steep for mechanical 

treatment and the competing vegetation too tall to treat by hand; 2) the number of acres burned fall 

within the historical range of natural variability (contiguous openings without live trees were less than 

22 acres in size); 3) areas are surrounded by green and mature trees with natural regeneration very 

likely to occur; 4) ongoing research projects; 5) fire management objectives and goals; and 6) some 

deer emphasis areas where oak is the desired dominant species. In addition, 13,934 acres of 

plantations planted during the 1970s through the 1990s survived the Rim Fire with limited mortality. 

These older plantations were planted in a range of 8 feet by 8 feet (680 trees per acre) to 10 feet by 10 

feet (435 trees per acre) without regard for existing oaks, residual green trees or natural regeneration, 

and many were inter-planted to ensure full site occupancy. These plantations with their wellestablished trees provide an excellent opportunity to create the desired ICO structure and the Forest 

Service is proposing thinning to accomplish this long-term goal.

11
Chapter 1 Stanislaus

Purpose of and Need for Action National Forest

1.04 PROPOSED ACTION

This is the Proposed Action, as described in the Notice of Intent (80 Federal Register 39, February 27, 

2015; p. 10663-10664), with corrections based on updated data and map information. The Forest 

Service proposed action includes about 42,000 acres of deer habitat enhancement, natural 

regeneration, noxious weed eradication, reforestation, thin existing plantations and associated 

management requirements on NFS lands within the 2013 Rim Fire (Figure 1.04-1). Chapter 2.02 

includes a detailed description of this proposal under Alternative 1 (Proposed Action). No treatments 

are proposed within Wilderness, Inventoried Roadless Areas, or the Wild classification segments of 

Wild and Scenic Rivers or Proposed Wild and Scenic Rivers. Project design will incorporate Best 

Management Practices (BMPs) according to regional and national guidance. It is anticipated site 

preparation would begin as soon as fall 2016 and treatments would continue for up to 10 years. 

Deer Habitat Enhancement

Deer Habitat Enhancement treatments (3,833 acres) include: reforestation; prescribed burning; 

thinning; and, noxious weed eradication within this critical deer area. 

Natural Regeneration

Natural Regeneration treatments (4,031 acres) include: utilizing an adaptive management approach, 

monitor these units to determine if the area has sufficient natural regeneration (a minimum of 300 

trees per acre well dispersed across the unit). Reduce fuels on these sites where amounts exceed the 

fire and fuels management requirements (10 to 20 tons per acre depending on location). If natural 

regeneration is not adequate after five years in regards to the species and number of trees, then 

complete site preparation, plant and release treatments, as described under reforestation. Release 

treatments may be used if initial regeneration is successful, but brush species start dominating the site.

Noxious Weed Eradication

Noxious Weed Eradication treatments (5,915 acres) include the following Environmental Protection 

Agency (EPA) approved herbicides: Glyphosate; Clopyralid; Aminopyralid; and, Clethodim. These 

noxious weed treatments either overlap or are adjacent to the reforestation, plantation thinning or deer

habitat enhancement areas described.

Reforestation

Reforestation treatments (21,300 acres) include: manual application of herbicides (Glyphosate) and 

hand and mechanical site preparation; prescribed burning; planting a diversity of conifer tree species 

using various patterns and densities (trees per acre) across the landscape (up and down slopes, with 

fewer on ridges and more in drainage bottoms) to develop a resilient mixed conifer forest and 

enhance wildlife (including deer) habitat; manual herbicide release (Glyphosate) when vegetation 

competition begins to inhibit survival and growth; and, noxious weed eradication as described above. 

Thin Existing Plantations

Thin existing plantation treatments (12,769 acres) include hand and mechanical treatments to achieve 

the ICO pattern to maximize heterogeneity and wildlife (including deer) habitat while creating more 

fire resilient stands. Prescribed burning to reduce ground fuels within these plantations would be done 

prior to hand or mechanical operations in order for any tree mortality to be utilized in creating the 

ICO structure during those treatments. 

12
Rim Fire Reforestation (45612) Chapter 1

Draft Environmental Impact Statement Purpose of and Need for Action

Figure 1.04-1 Rim Fire Reforestation Proposed Action Treatment Units

13
Chapter 1 Stanislaus

Purpose of and Need for Action National Forest

Proposed Action Maps

The following detailed maps are available online at: http://www.fs.usda.gov/project/?project=45612. 

Map 1 - Desired Future Condition Alternatives 1, 3, 4 and 5

Plotter size (42 inch by 60 inch) map showing desired future conditions and fire emphasis areas. 

Map 2 - Proposed Treatment Alternatives 1, 3 and 5

Plotter size (42 inch by 60 inch) map showing treatments (adaptive management; deer

enhancement; natural regeneration; reforestation; and, thinning).

Map 4 - Noxious Weed Treatment Alternatives 1 and 5

Plotter size (42 inch by 60 inch) map showing invasive plant sites identified for noxious weed 

eradication.

Updates to the Proposed Action

The Forest Service updated the proposed action based on subsequent field information and surveys. 

The updated proposed action differs from the original scoping package (Scoping) with most changes 

in relation to additional field data collection. The way the treatments are displayed also changed from 

the scoping package in order to more clearly identify the proposed treatments, their locations and 

purpose. Table 1.04-1 displays and compares the Proposed Action from Scoping with the updates 

identified for Alternative 1 (Proposed Action) in this DEIS.

Table 1.04-1 Updates to the Proposed Action

Action Treatment Proposed Action

(Scoping)

Alternative 1

(Proposed Action)

Deer Habitat Enhancement Planting, underburning, thinning and 

noxious weed eradication

481 3,833

Natural Regeneration Monitoring and adaptive management 0 4,031

Noxious Weed Eradication Manually apply herbicides 4,963 5,915

Reforestation Site preparation, plant and release 30,065 21,300

Thin Existing Plantations Hand or mechanical tree removal 11,285 12,769

Overall Treatment Acres1 46,794 47,848

1 Treatment acres for noxious weed eradication overlap and are not additive.

1.05 PRINCIPAL LAWSAND REGULATIONS

NEPA requires that all major federal actions significantly affecting the human environment be 

analyzed to determine the magnitude and intensity of those impacts and that the results be shared with 

the public and the public given opportunity to comment. The regulations implementing NEPA further 

require that to the fullest extent possible, agencies shall prepare EISs concurrently with and integrated 

with environmental analyses and related surveys and studies required by the Endangered Species Act 

of 1973, the National Historic Preservation Act of 1966, and other environmental review laws and 

executive orders. Other laws that apply to this project include: the Multiple Use and Sustained Yield 

Act of 1960; the National Forest Management Act of 1976; the Clean Air Act of 1990; the Clean 

Water Act of 1972; and, the Forest and Rangeland Renewable Resources Planning Act of 1974. 

14
Rim Fire Reforestation (45612) Chapter 1

Draft Environmental Impact Statement Purpose of and Need for Action

1.06 DECISION FRAMEWORK

As the Responsible Official, the Forest Supervisor may decide to: (1) select the proposed action; (2) 

select one of the alternatives; (3) select one of the alternatives after modifying the alternative with 

additional mitigating measures or combination of activities from other alternatives; or, (4) select the 

no action alternative, choosing not to authorize the Rim Reforestation project. In making this 

decision, the Forest Supervisor will consider such questions as: 

 How well does the selected alternative meet the purpose and need described in this DEIS?

 How well does the selected alternative move the project area toward the desired conditions 

established in the Forest Plan? 

 Does the selected alternative mitigate potential adverse effects?

Project-Level Pre-decisional Administrative Review (Objection) Process

This project is subject to comment pursuant to 36 CFR 218, Subparts A and B. Only those who 

submit timely project specific written comments3

 during a public comment period are eligible to file 

an objection. Individuals or representatives of an entity submitting comments must sign the comments 

or verify identity upon request. Comments received, including the names and addresses of those who 

comment, will be considered part of the public record on this proposal and will be available for public 

inspection. 

1.07 PUBLIC INVOLVEMENT

Public participation is important at numerous points during the analysis. The Forest Service seeks 

information, comments and assistance from federal, state and local agencies and individuals or 

organizations that may be interested in or affected by the proposed action. 

Because of the scope and scale of this project public involvement was focused on from the very 

beginning. The Forest Service engaged two large collaborative groups. One local group, Yosemite 

Stanislaus Solutions (YSS) includes a wide variety of local county stakeholders including the timber 

industry, environmental organizations and business leaders. YSS fosters partnerships among private, 

nonprofit, state and federal entities with a common interest in the health and well-being of the 

landscape and communities in the Tuolumne River Watershed. The group fosters an all-lands strategy 

to create a heightened degree of environmental stewardship, local jobs, greater local economic

stability, and healthy forests and communities. The other group, known as the Rim Fire Technical 

Team consists of representatives from state and national environmental organizations, the timber 

industry and other government entities with a more national or statewide interest base. The Forest 

Service met with both of these groups on several occasions including field trips into the burn area and 

all day workshops identifying the long-term goals of this landscape and future desired conditions. 

The Forest Service held its first field trip into the Rim Fire on October 16, 2013 with individuals from 

the Tuolumne Band of Me-Wuk Indians, Central Sierra Environmental Resource Center (CSERC), 

Sierra Club, Tuolumne County Alliance for Resources and Environment (TuCARE), California Fish 

and Wildlife Service, Audubon Society, Tuolumne County Supervisors, logging companies, 

sawmills, Sierra Nevada Conservancy and the local collaborative group YSS. On November 14, 2013 

the Rim Fire Technical Team toured the burn area with several stops and discussions with Forest 

3 Specific written comments. Written comments are those submitted to the responsible official or designee during a designated 

opportunity for public participation (§ 218.5(a)) provided for a proposed project. Written comments can include submission of

transcriptions or other notes from oral statements or presentation. For the purposes of this rule, specific written comments should be 

within the scope of the proposed action, have a direct relationship to the proposed action, and must include supporting reasons for the 

responsible official to consider.

15

 
Chapter 1 Stanislaus

Purpose of and Need for Action National Forest

Service managers and researchers. Several field trips and meetings followed focusing initially on the 

salvage.

The Rim Fire Technical Team held its first reforestation specific workshop on July 10, 2014 in 

Sacramento, California. This was followed by a two day workshop on August 18 and 19, 2014. Each 

of these workshops included presentations on reforestation by scientists from the Forest Service 

Pacific Southwest Research Station (PSW) and other experts followed by small group discussions and 

proposal development.

On December 16, 2014 a public pre-scoping meeting was held to discuss the initial proposed action 

developed by the Forest Service ID team. Members of YSS, the Rim Fire Technical Team and others 

attended (a total of 32 people).

Public Scoping Period (45 days) for the Notice of Intent

The Forest Service conducts scoping according to the CEQ regulations (40 CFR 1501.7). In addition 

to other public involvement, scoping initiates an early and open process for determining the scope of 

issues to be addressed in the DEIS and for identifying the significant issues related to a proposed 

action. This scoping process allows the Forest Service not only to identify significant environmental 

issues deserving of study, but also to deemphasize insignificant issues, narrowing the scope of the 

DEIS process accordingly (40 CFR 1500.4(g)). 

The Forest Service first listed the Rim Reforestation project online [http://data.ecosystemmanagement.org/nepaweb/current-sopa.php?forest=110516] in the Stanislaus National Forest 

Schedule of Proposed Actions (SOPA) on October 7, 2014. The project first appeared in the 

published quarterly SOPA in January 2015. The Forest Service distributes the SOPA to about 160 

parties and it is available on the internet [http://www.fs.fed.us/sopa/forest-level.php?110516].

The Forest Supervisor sent a scoping letter and package to 376 individuals, permittees, organizations, 

agencies, landowners, and Tribes interested in this project on February 27, 2015. The letter requested 

specific written comments on the Proposed Action during the initial 45-day designated opportunity 

for public participation. The Forest Service published a Notice of Intent (NOI) that asked for public 

comment on the proposal between February 27, 2015 and April 13, 2015 (80 Federal Register 39, 

February 27, 2015; p. 10663-10664). Interested parties submitted 63 total letters during the comment 

period. Other interested parties submitted 2 letters (late) after the comment period closed. The 

Scoping Summary (project record) identifies specific comments and shows how the ID team used 

them to identify issues (Chapter 1.08). 

The Forest Service organized field trips with the Tuolumne Band of Me-Wuk Indians on March 13, 

2014 and March 17, 2014 followed by a Tribal consultation day on May 9, 2014. 

Several public presentations of the scoping package were given to interested groups during the 

scoping period including the Tuolumne County Alliance for Resources and the Environment 

(TuCARE) Board of Directors, the local Sierra Club group and the Forest Range Permittees. A 

workshop was also held on April 8, 2015 and 17 people attended. Public open houses were also held 

on April 8 and April 10, 2015 where the Forest Service described the preliminary purpose and need 

for the project as well as proposed recovery treatments. ID team members participated and answered 

questions regarding the project and proposed action. They were advertised on local radio stations, in 

the local newspaper, on the Stanislaus National Forest website, through direct mailings to those on the 

SOPA mailing list, and to those who showed interest in the project. 

16
Rim Fire Reforestation (45612) Chapter 1

Draft Environmental Impact Statement Purpose of and Need for Action

Ongoing Public Involvement

After the initial 45-day scoping period, the Forest Service continued scoping with interested parties. 

The Forest Service hosted another public workshop on July 8, 2015, to share the alternatives 

developed since the initial scoping, 17 interested individuals attended. The Forest Service continued 

field trips with interested groups and individuals including the Tuolumne Band of Me-Wuk Indians 

on July 15, 2015. The Forest Service also provided presentation to other interested groups including 

the Lions Club and TuCARE. 

1.08 ISSUES

The Forest Service reviewed the purpose and need, proposed action and scoping comments in order to 

identify issues (Scoping Summary, project record). An issue is a point of discussion, dispute, or 

debate with the Proposed Action; an issue is an effect on a physical, biological, social, or economic

resource; an issue is not an activity; instead, the predicted effects of the activity create the issue. The 

Forest Service separated the issues into two groups: significant and non-significant. The Council on 

Environmental Quality (CEQ) NEPA regulations explain this delineation in Sec. 1501.7, “...identify 

and eliminate from detailed study the issues which are not significant or which have been covered by 

prior environmental review (Sec. 1506.3)...”

Significant issues are defined as those directly or indirectly caused by implementing the proposed 

action. Significant Issues are used to formulate alternatives, prescribe mitigation measures, or analyze 

environmental effects. Issues are significant because of the extent of their geographic distribution, the 

duration of their effects, or the intensity of interest or resource conflicts.

Non-Significant Issues are those: 1) outside of the scope of the proposed action; 2) already 

determined through law, regulation, Forest Plan, or other higher level decision; 3) irrelevant to the 

decision to be made; 4) conjectural and not supported by scientific fact; 5) a comment, opinion, or 

statement of position; or, 6) a question for clarification or information. Although non-significant 

issues are not used to formulate alternatives or prescribe management requirements, the DEIS will 

disclose all significant environmental effects including any related to non-significant issues. The 

Scoping Summary (project record) identifies non-significant issues and reasons why they were found 

non-significant.

Significant Issues

As described above, issues are significant because of the extent of their geographic distribution, the 

duration of their effects, or the intensity of interest or resource conflicts. Based on public comments, 

the Forest Service developed significant issues to formulate and compare alternatives, prescribe 

management requirements, or analyze and compare the environmental effects of each alternative. 

Table 1.08-1 displays significant issues with issue statements based on public comments submitted 

during scoping. 

17
Chapter 1 Stanislaus

Purpose of and Need for Action National Forest

Table 1.08-1 Significant Issues

Issue/Element Cause and Effect

1. Herbicides: The proposed herbicide applications may adversely affect human and other natural resources.

1.1 Human Health a. Toxins may contaminate the water supply, food chain and land, impacting residents and visitors 

through reproductive and developmental harm.

1.2 Native Species 

Health and 

Diversity

a. Herbicides may irretrievably alter natural post-fire successional habitat causing loss of significant 

biodiversity.

b. Application of glyphosate formulations and other less understood herbicides may have negative 

direct, indirect and cumulative effects on aquatic species and terrestrial wildlife including: mortality; 

impaired growth and development; modified behavior; and, physiological or morphological effects.

2. Reforestation 

Method: 

The proposed reforestation methods may adversely affect human and other natural resources.

2.1 Local Economy a. Reforestation at low rates may take too long to reclaim control of the brush and competing vegetation.

b. Future budgets may not provide adequate funding to control competing vegetation or thin trees.

c. Low density planting may not provide a sustainable, long-term supply of wood needed to maintain the 

forest products infrastructure in Tuolumne County.

2.2 Native Species 

Health and 

Diversity

a. High density planting may limit fire use and foster unhealthy landscapes lacking biodiversity with 

reduced resiliency to drought, insects and wildfire.

b. Low density planting may reduce wildlife hiding cover subjecting wildlife to increased vehicle related 

mortality, predation and poaching.

2.3 Forest 

Establishment

a. Wide and variable spacing and gaps between planted trees may complicate the planting process,

favor competing vegetation and delay establishment of a new forest.

2.4 Fire Hazard a. High density planting may result in fire-prone trees preventing early and frequent use of prescribed 

and natural fire.

b. Wide and variable spacing and gaps between planted trees may result in areas with undesirable 

vegetation and increased fuel loadings.

1.09 GISDATA

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

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

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

while being created or revised. Using GIS products for purposes other than those intended may yield 

inaccurate or misleading results. The Forest Service reserves the right to correct, update, modify, or 

replace GIS products without notification. The information contained within Chapter 2 (The 

Alternatives) of this DEIS takes precedence in case of disagreement with the GIS data (including 

maps created using that data).

18
Rim Fire Reforestation (45612) Chapter 2

Draft Environmental Impact Statement The Alternatives

2. The Alternatives

This Chapter describes and compares the alternatives considered for the Rim Reforestation project. It 

presents the alternatives in comparative form, defining the differences between each alternative and 

providing a clear basis for choice among the options for the Responsible Official and the public. It 

includes the action alternative or the proposed action (Alternative 1), the no action alternative 

(Alternative 2), and three additional action alternatives (3, 4 and 5) that provide a comprehensive 

range for the decision maker. The no action alternative serves as a baseline for comparison purposes 

(73 Federal Register 143, July 24, 2008; p. 43084-43099). Based on the issues identified through 

public comment on the proposed action as well as the unique opportunities created by the Rim Fire, 

the Forest Service developed the other action alternatives that achieve the purpose and need through 

different combinations and types of activities than the proposed action. Some of the information used 

to compare the alternatives is based on the design of the alternative, and some of the information is 

based upon the environmental, social and economic effects of implementing each alternative.

This chapter is divided into five sections:

 Chapter 2.01 describes how the alternatives were developed. 

 Chapter 2.02 presents the alternatives considered in detail.

 Chapter 2.03 describes the management requirements common to all action alternatives.

 Chapter 2.04 presents the alternatives considered, but eliminated from detailed study, including 

the rationale for eliminating them.

 Chapter 2.05 compares the alternatives based on their environmental, social and economic

consequences including a comparative display of the projected effects of the alternatives.

Map Package

The following detailed maps are available online at: http://www.fs.usda.gov/project/?project=45612. 

Map 1 - Desired Future Condition Alternatives 1, 3, 4 and 5

Plotter size (42 inch by 60 inch) map showing desired future conditions and fire emphasis areas. 

Map 2 - Proposed Treatment Alternatives 1, 3 and 5

Plotter size (42 inch by 60 inch) map showing treatments (adaptive management; deer

enhancement; natural regeneration; reforestation; and, thinning).

Map 3 - Proposed Treatment Alternative 4

Plotter size (42 inch by 60 inch) map showing treatments (adaptive management; deer

enhancement; natural regeneration; reforestation; and, thinning).

Map 4 - Noxious Weed Treatment Alternatives 1 and 5

Plotter size (42 inch by 60 inch) map showing invasive plant sites identified for noxious weed 

eradication.

Map 5 - Noxious Weed Treatment Alternatives 3 and 4

Plotter size (42 inch by 60 inch) map showing invasive plant sites identified for noxious weed 

eradication.

19
Chapter 2 Stanislaus

The Alternatives National Forest

2.01 HOW THE ALTERNATIVES WERE DEVELOPED

The project area includes NFS lands on the Stanislaus National Forest outside of Wilderness. It does 

not include any private, state or other federal lands. Each alternative assumes that other adjacent 

federal lands, such as those administered by Yosemite National Park will be managed according to 

existing management plans and applicable federal laws. Each alternative also assumes that private 

lands will meet applicable state and federal land use regulations.

Chapter 2.02 displays the alternatives fully considered in detail including four action alternatives and 

the no action alternative. Chapter 2.04 describes other alternatives considered, but eliminated from 

detailed study. Appendix E (Treatments) provides detailed information related to the specific 

treatment units in each action alternative. Appendix N (Noxious Weed Schedule, project record) 

displays the implementation schedule for noxious weed eradication under each action alternative. 

Appendix R (Reforestation Schedule, project record) displays the implementation schedule for 

reforestation treatments under each action alternative. The map package includes large scale maps 

showing treatment units and other information included in each alternative. 

Proposed Treatments with Adaptive Management

The ID team developed the action alternatives to represent a wide range of perspectives designed to 

address the purpose and need (Chapter 1.03) and the issues identified through scoping (Chapter 1.08). 

Next, they developed site-specific prescriptions focused on tree survival and the reintroduction of fire 

into planted areas while incorporating an adaptive management strategy for implementation. Adaptive 

management is a cycle of making a plan, applying appropriate land management tools with on-theground actions, monitoring results, and adjusting plans as necessary. Finally, the Responsible Official 

approved the range of alternatives described below. These action alternatives apply to the following 

activity groups and actions were adjusted appropriately to achieve the desired results with the least 

adverse impacts. Not all activity groups or actions apply to every alternative, refer to specific 

alternative descriptions.

Deer Habitat Enhancement

Favor oak species throughout all these units. 

REFORESTATION IN DEER HABITAT

Use site preparation, plant, release, and prescribed burning treatments, utilizing adaptive management

as described under reforestation, to promote successful reforestation. Plant hiding cover in discrete 

areas up to 25 acres in size using a cluster planting design; alternate planting of 3-tree and 5-tree 

clusters. Space trees in the clusters 10 to 12 feet apart and space clusters no wider than 27 feet apart. 

These more open stand conditions allow for recruitment of understory vegetation, increasing the 

effectiveness of these areas as hiding cover. Plant conifers for thermal cover in discrete areas up to 5 

acres in size with trees spaced 10 to 14 feet apart. These areas are designed to provide dense canopy 

cover to protect deer from inclement weather. Strategically place both hiding and thermal cover in 

close proximity to high quality foraging habitat (oak, grass and shrubs). 

THIN FOR HIDING AND THERMAL COVER STRUCTURE WITHIN EXISTING PLANTATIONS IN DEER HABITAT

Create openings around established oaks or groups of oaks (live trees or saplings greater than or equal 

to six inches dbh) by removing conifers within 30 feet of the bole to allow oak to flourish. 

Create hiding cover by clumping conifers with an average of 30 feet between clumps. Average four to 

seven conifers per clump with each acre having equal proportions of each clump size. Trees within 

the clumps should be 10 to 12 feet apart. 

Create thermal cover by thinning individual conifer trees 17 to 23 feet apart. 

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Natural Regeneration

In areas with high potential for natural seeding from live green trees within and adjacent to the unit, 

monitor the site to determine if the area has sufficient natural regeneration (a minimum of 300 trees 

per acre well dispersed across the unit). The seedling density, species and dispersal needs to be 

similar to the Desired Future Condition identified for the specific location to be considered naturally 

regenerated. If it does not meet these goals, implement the adaptive management strategy to plant 

additional trees. Reduce fuels on these sites where amounts exceed the fire and fuels management 

requirements (10 to 20 tons per acre depending on location). If natural regeneration is not adequate 

after five years, in regards to the species and number of trees across the landscape, then complete site 

preparation, planting and release treatments, as described under reforestation, to promote successful 

forest establishment. Release treatments may be used with natural regeneration if vegetation 

competition is prohibiting growth and impacting seedling survival. 

Noxious Weed Eradication

Utilize an Integrated Pest Management (IPM) approach as the adaptive management strategy for 

weed eradication. Methods for removing noxious weeds include burning, targeted grazing, grubbing, 

herbicides and hand pulling. 

On the Jawbone Lava Flat area, utilize prescribed fire to remove the thatch and other larger-sprouting 

vegetation. Follow burning with livestock grazing where feasible. Directly apply herbicide on the 

remaining noxious weeds. Monitor and use fire, targeted grazing or directed herbicide applications 

until the remaining noxious weeds are eliminated. Utilize hand pulling and grubbing on species and 

small populations that can be effectively treated in this manner (i.e. bull thistle in meadows).

Utilize hand pulling as the preferred method where it can effectively eradicate noxious weed

populations. Where herbicides are required to meet this goal, use backpack sprayers for direct 

application with EPA approved herbicides (glyphosate, clopyralid, aminopyralid and clethodim) to 

target noxious weeds and invasive non-native pest plants in and adjacent to units. The goal is to 

eradicate noxious weed populations and reduce spread within the Rim Fire area. Treatments would 

include yearly applications to prevent seed production and eventually eliminate the weed seed banks.

Identified noxious weeds include: bachelor button, barbed goatgrass, cut-leaf blackberry, Himalayan 

blackberry, black mustard/shortpod mustard, blessed milkthistle, bull thistle, Canada thistle, 

cheatgrass, Dyers woad, field bindweed, french broom, hedgeparsley, italian thistle, Johnsongrass, 

Klamathweed, medusahead grass, perennial sweetpea, puncturevine, scotch broom, spanish broom, 

spotted knapweed, tocalote, tumble mustard, woolly mullein and yellow star-thistle.

Reforestation

Reforestation uses adaptive management tools to reduce fuels, prepare the site for planting, plant 

conifers, release them from competition and re-introduce prescribed fire into the young plantations. 

SITE PREPARATION

Site preparation, may require a combination of the following methods: deep till followed by forest 

cultivation; feller buncher (remove biomass or pile and burn); hand cut, hand pile and burn or jackpot 

burn on steep slopes; machine pile and burn; manually apply herbicides; and, mastication (shred).

Use site preparation when the amount of dead fuel on the site exceeds 10 or 20 tons per acre 

(depending on location) or when greater than 20 percent of the land is vegetated with grass or shrubs. 

Adaptive management starts with fuels reduction. Treat fuels with feller bunchers or dozers to 

machine pile and burn or masticate. On steep slopes hand cut, hand pile and burn or jackpot burn the 

woody fuels. Deep till and cultivate every acre for site preparation that is less than 30 or 35 percent 

slope, on the right soil type, and that is not fragmented by protected areas such as: sensitive plants, 

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cultural resources or stream zones. Use chemical site preparation where competing vegetation cannot 

be effectively controlled or where deep tilling and cultivating would not be appropriate. 

PLANT CONIFERS

Plant conifers after site preparation on acres with limited (less than prescribed in regards to the 

species and number of trees dispersed throughout the unit) or no natural regeneration. 

Plant bare-root or container stock ponderosa pine, sugar pine, incense cedar, Douglas-fir, white fir 

and giant sequoia based on seed zones and elevation to meet the desired future condition (i.e., Open 

Canopy Mosaic and Old Forest Mosaic). Scalp a 1-foot square area to bare mineral soil prior to 

digging a hole for the seedling. Integrate existing conifers into the prescribed planting pattern, 

spacing off them the same distance as a planted seedling.

Planting will not occur in the following situations: natural regeneration areas, oak aggregates, 

riparian vegetation areas, selected openings, rock outcrops, along cliffs, cultural sites except where 

requested by the Tribe, sensitive plant sites or on poor soils (low site class). 

RELEASE

Release improves survival of conifer seedlings by reducing competition for soil moisture, light and 

nutrients. The adaptive management trigger for release is when greater than 20 percent of the land is 

vegetated with grass or shrubs.

Manually grub vegetation by using hand tools such as modified hoes or loppers to sever all live 

vegetation below the root collar at ground level within 5 feet of each seedling. The severed 

vegetation, duff, and litter is removed down to bare mineral soil. Hand grubbing would need to occur 

twice a year (early and late spring) in order to remove the competing vegetation to an effective level. 

It is estimated that hand grubbing would be done twice a year for 5 years.

Use chemical release where competing vegetation cannot be effectively controlled with hoeing or 

grubbing (this includes areas with sprouting species such as bear clover and deer brush). Glyphosate, 

along with the surfactants and colorants, Syl-tacTM and ColorfastTM Purple for chemical release may 

occur up to 3 times to ensure seedling survival and the established trees are free to grow among the 

grass, bearclover or other competing woody shrubs. 

PRESCRIBED FIRE

Utilize adaptive management to introduce prescribed fire into young plantations. The goal is to return 

fire back into the ecosystem within the first 10 years while sustaining the majority of the establishing 

trees. Due to the extent of the area, conditions advantageous to tree survivability will vary based on 

tree species, slope, environmental conditions, and fuel loading and will be evaluated through tree 

mortality modeling to determine the most opportune time and place for fire reintroduction. 

Thin Existing Plantations

Thinning for Individuals, Clumps, and Openings (ICO) structure within existing plantations would 

require one of the following methods: feller buncher (remove biomass or pile and burn); hand cut, 

hand pile and burn; or mastication (shred). Prescribed fire (understory burning) would be done prior 

to the mechanical activities to reduce the existing fuels within these stands.

Thin individual conifer trees to 22 to 28 feet between boles (stems). The order of preference for leave 

trees is: sugar pine, Douglas-fir, incense cedar, white fir, and giant sequoia. Favor cutting ponderosa 

and Jeffery pines. All healthy sugar pine would remain on site per Regional direction regardless of 

spacing. 

Clump the leave trees with an average of 30 feet between clumps or nearest single tree. Smaller 

clumps should average 8 conifers each and larger clumps should consist of 15 conifers. Leave an 

22
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average of 6 small clumps and 2 large clumps per acre across the unit with more clumps near the 

drainages. Incorporate incense cedar, Douglas-fir, white fir and giant sequoia into clumps where 

feasible.

Create openings around established oaks or groups of oaks or other hardwoods (i.e. dogwood) by 

removing conifers within 30 feet of the bole to allow oaks to flourish and to create the open areas 

within the ICO structure. Thinning around 1 oak is about the same area as that of 1 conifer clump. No 

oaks would be cut, but a maximum of five oaks per acre would have the 30-foot clearance. Oaks 

should be clumped where possible. 

Meadows: Remove all conifers less than 24 inches dbh, except healthy sugar pine without evident 

blister rust, within 25 feet of meadow edges. From 25 to 50 feet of the meadow edge, leave 4 clumps 

of 5 conifers, evenly dispersed around the meadow or space clumps 150 feet apart around larger 

meadows. Between 50 to 100 feet, leave 4 clumps of 10 conifers evenly dispersed around the 

meadow and off-set from those retained within the first ring or for larger meadows space clumps midpoint of the interior ring, about 150 feet apart. Figure 6 shows an example of how the meadow 

strategy would look on the landscape. Beyond the 100 feet, resume ICO prescription. 

Streams: Along perennial and intermittent streams, remove conifers 20 feet from riparian obligate 

vegetation. Leave all sugar pine without evident blister rust.

Emergency Travel Routes: Remove conifers within 12 feet of an Emergency Travel Route except 

conifers 16 inches dbh and larger. Prune 10 feet up the bole of residual trees, including oaks. 

Primary Ridges and Fuelbreaks: Within these features, thin conifers to a 30-foot spacing. Use the 

30-foot buffer around all oaks. Where feasible, but no closer than one mile apart, incorporate 

helispots into thinning design by expanding upon existing openings. Minimum helispot size is 75 feet 

in diameter clear of all vegetation greater than 1-foot high. 

Management Requirements

The action alternatives include management requirements designed to implement the Forest Plan and 

to minimize or avoid potential adverse impacts. Each action alternative lists the management 

requirements specific to it, while Chapter 2.03 identifies those common to all action alternatives. 

Management requirements are mandatory components of each alternative and will be implemented as 

part of the proposed activities. Most management requirements were utilized in other past projects 

and, through monitoring, were shown to be very effective in protecting or enhancing resources. 

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2.02 ALTERNATIVES CONSIDERED IN DETAIL

The action alternatives (Alternatives 1, 3, 4 and 5) and the no action alternative (Alternative 2) are 

considered in detail. The no action alternative, as required by the implementing regulations of NEPA, 

serves as a baseline for comparison among the alternatives (73 Federal Register 143, July 24, 2008; p. 

43084-43099). The following sections describe each of the alternatives considered in detail. The map 

package and project record contain detailed maps of each action alternative.

Alternative 1 (Proposed Action)

This is the Proposed Action, as described in the Notice of Intent (80 Federal Register 39, February 27, 

2015; p. 10663-10664), with corrections based on additional field surveys (i.e. new noxious weed 

populations discovered) and mapping refinement (Chapter 1.04). Alternative 1 includes the treatments 

and actions described below and shown on Map 1, Map 2 and Map 4 (map package). Chapter 2.01 

provides more details about each treatment. Table 2.05-1 provides a summary of the proposed 

activities by alternative. Appendix E (Treatments) provides detailed information related to the 

specific treatment units in this alternative.

Deer Habitat Enhancement

Enhance deer habitat through conifer planting on 646 acres within the 3,833 deer acres. An additional 

33 acres will be monitored for Natural Regeneration within the Deer Enhancement habitat. Table 

2.02-1 shows the proposed treatment activities within these units.

Table 2.02-1 Deer Habitat Treatments

Proposed Action Unit 

Acres FB MP HC HP PF HERB/SP PLANT HERB/REL

Reforestation 646 39 25 646 646 646 646

Natural Regeneration 33 33

Thin 1,164 1,153 11 11 1,164

Prescribed Fire Only 1,990 1,990

Totals 3,833 1,192 25 11 11 3,833 646 646 646

FB=Feller Buncher; HC=Hand Cut; HERB=manual herbicide application; HP=Hand Pile; MP=Machine Pile (with dozer);

PF=Prescribed Fire; SP=Site Preparation; REL=Release

Natural Regeneration

Alternative 1 includes natural regeneration on up to 4,031 acres. Reduce fuels if the amount exceeds 

the maximum (10 or 20 tons per acre) amount within the specific units. Monitor species and number 

of trees across the landscape to decide if site preparation, planting, release and burning would occur. 

Noxious Weed Eradication

Alternative 1 includes noxious weed eradication on up to 5,915 acres. The majority of the noxious 

weed treatments are within the reforestation units. Appendix N (Noxious Weed Schedule, project 

record) displays the implementation schedule for noxious weed eradication under this alternative.

Reforestation

All acreages described under this section do not include reforestation acres proposed for deer habitat 

enhancement or natural regeneration. Appendix E (Treatments) provides detailed information related 

to the specific treatment units in this alternative. Appendix R (Reforestation Schedule, project record) 

displays the implementation schedule for reforestation treatments under this alternative.

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SITE PREPARATION

Alternative 1 includes site preparation on up to 21,300 acres using a combination of the following 

methods (some units having more than one treatment applied, Appendix E): deep till followed by 

forest cultivation on 5,085 acres on less than 30 percent slopes; feller buncher (remove biomass or 

pile and burn, 3,139 acres); hand cut, hand pile and burn (74 acres) or jackpot burn on steep slopes 

(237 acres); machine pile and burn (912 acres); manually apply herbicides (16,215 acres); and 

mastication (shred, 1,844 acres). Site preparation activities are described below.

Deep Till and Forest Cultivate (subsoil): Deep till utilizing tractor drawn ripper shanks with subsoil 

wings to pass through the soil at a depth of as much as 30 inches along the contour slope. Tractors 

may pull 2 or 3 ripper shanks evenly spaced behind the tractor. This is followed by pulling a forest 

cultivator, with ripper shanks more frequently spaced on a V-shaped bar, to cultivate to an 18 inch 

depth. The cultivation treatment also occurs along the contour slope to prevent channeling of water in 

rainstorms. Deep tilling is designed to reduce soil compaction, improve planting quality, and reduce 

vegetation as forest cultivation is used to uproot competing vegetation species.

Feller Buncher: Use feller bunchers to cut trees. Mechanically remove material, as firewood, 

shavings logs, pulpwood, or chipped biomass fuel for electric cogeneration plants, or deck on site for 

public firewood cutting. If these options prove infeasible, then bunch material into piles and burn. 

Within existing plantations, remove both dead and live conifers to reduce live conifer density and 

promote desired ICO structure, favoring the healthiest conifers and the most diverse mix of tree 

species. 

Hand Cut, Hand Pile and Burn: Hand cut trees that cannot be treated mechanically for various 

reasons such as slope conditions and resource concerns. Remove both dead and live conifers to 

reduce live conifer density and promote desired ICO structure in existing plantations, favoring the 

healthiest conifers and the most diverse mix of tree species. In new reforestation units, cut only dead 

trees and pile for burning. 

Machine Pile and Burn: Push brush, small trees and downed fuels into piles for burning. This 

treatment may sometimes include hand felling larger dead trees. Use this method in areas with high 

down fuel loads and areas with standing dead trees that would inhibit access and worker safety and 

result in high tree or seedling mortality if burned. 

Manually Apply Herbicides (Glyphosate): Use backpack sprayers for application of Glyphosate 

(plus a surfactant and colorant) to initially set back competing vegetation.

Mastication (shred): Mastication treatments consist of a tractor, excavator or loader with a cutting 

head used to shred brush, small trees, and large downed woody debris. Shredded material remains on 

site. Cut both dead and live conifers as necessary to reduce live conifer density and promote desired 

ICO structure, favoring the healthiest conifers and diverse mix of tree species. Both live and dead 

brush would be treated. 

Prescribed Fire (Understory Burning and Jackpot Burning): Understory burns (using low 

intensity fire) in areas where fuel needs to be removed prior to planting or where natural regeneration 

is left free to grow. Jackpot burn (consume fuel concentrations) where feasible, but entire units may 

be treated to remove excess fuels and/or vegetation prior to planting. This is also proposed in existing 

plantations prior to thinning.

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PLANT CONIFERS

Alternative 1 includes planting conifers on up to 21,300 acres. Base composition and density on 

landscape position, Strategic Fire Management Areas (SFMA) and elevation. Table 2.02-2 describes 

the planting design by landscape position. 

Table 2.02-2 Planting Design by Landscape Position in Alternative 1

Landscape 

Position Planting Design Within SFMA Planting Design Outside SFMA Size

(acres)

Percent 

of Area

Emergency 

Travel Routes

12 to 16-foot spaced 20-tree pyramid (no top,

Figure 2.02-1. A no-conifer zone is within 12 feet 

of the road. The next zone has pyramid shaped 

clusters of 20 conifers out to 68 feet from the 

road. (152 trees per acre).

Same as within SFMA 866 4

Fuel Break 30-foot no plant strip centered in the middle with 

150 feet on each side planted with 13 to 17-foot 

spaced conifers (176 trees per acre) creating a 

330 foot wide strip.

Same as within SFMA 642 3

Primary Ridge Same as Fuel Break design. 183 acres. 13 to 17-foot spaced conifers in a 250-foot 

wide strip (194 trees per acre). 308 acres.

491 2

Mid-slope 

Open Canopy 

Mosaic

Macro-clusters, 25 trees per cluster. Plant 

individual trees on a 10 to 14 foot spacing, plant 

5 rows and skip 1 row in both directions (210 

trees per acre, Figure 2.02-1). 4,259 acres.

4-Tree micro-clusters, as shown in Figure 

2.02-1, with 14 feet between outside trees, 

7 feet to the middle tree and 26 feet 

between cluster centers. Closest tree to 

tree is 12 feet and farthest tree to tree is 27 

feet (257 trees per acre, Figure 2.02-1). 

4,691 acres.

8,951 43

Mid-slope Old 

Forest Mosaic 

Macro clusters, 100 trees per cluster. Plant 

individual trees on a 10 to 14-foot spacing, plant 

10 rows and skip 1 row in both directions (250 

trees per acre). 903 acres.

Plant individual trees using a 10 to 14-foot 

spacing (303 trees per acre, Figure 2.02-1). 

5,587 acres.

6,491 30

Drainages Plant individual trees using a 10 to 14-foot 

spacing in a 300-foot wide planting area (303 

trees per acre). Where a road crosses a 

drainage, the Emergency Travel Routes 

prescription takes precedence.

Same as within SFMA 3,859 18

Totals 21,300 100

SFMA=Strategic Fire Management Areas. Numbers may not total due to rounding errors.

Oak Buffers: Offset conifer planting 25 feet from the bole of remnant oaks (defined as 8 feet tall and 

0.5 inches dbh) or regenerating oak aggregates regardless of topographic position at up to 5 oaks per 

acre. Within 20 feet of oaks, do not apply herbicides for reforestation unless needed to control 

invasive species.

Meadows: A no-tree zone is within 25 feet of meadows. Plant 4 clumps of 5 conifers, evenly 

dispersed in a 25 to 50-foot zone from the meadow edge, or space clumps 150 feet apart around larger 

meadows. In the next 50 to 100-foot zone, plant 4 clumps of 10 conifers evenly dispersed and off-set 

from those retained within the first zone, or for larger meadows space clumps mid-point of the 

interior zone, about 150 feet apart. Beyond the 100 feet, resume prescription. 

Figure 2.02-1 and Figure 2.02-2 illustrate how initial planting would look for some of the various 

landscape positions described above. Figure 2.02-1 includes the maximum number of seedlings that 

would be planted with five oaks per acre buffered by 25 feet; it does not show other non-planting 

areas such as rock outcrops or sensitive plant sites which would be encountered in most areas. Figure 

2.02-2 uses the exact pattern as Figure 2.02-1, but randomly removed 25% of the trees to represent 

the maximum amount of surviving seedlings expected five years after site preparation and release 

treatments. In areas where only mechanical and hand treatments are proposed (Alternative 3) the 

mortality is expected to be 30 to 50%. 

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Draft Environmental Impact Statement The Alternatives

Figure 2.02-1 shows an example of planting individual trees using a 10 to 14-foot spacing (mid-slope 

old forest mosaic outside of SFMA), Emergency Travel Routes, and both mid-slope open canopy 

mosaic prescriptions in and outside of SFMAs. Oaks with buffers are interspersed with conifers.

Figure 2.02-1 Alternative 1 Planting Prescriptions

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The Alternatives National Forest

Figure 2.02-2 shows 25% expected mortality in areas treated with DTFC and herbicides. 

Approximately 50% mortality is expected in areas that only have mechanical and/or hand treatments. 

Figure 2.02-2 Alternative 1 Planting Prescriptions with 25% Expected Mortality

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Figure 2.02-3 shows the reforestation landscape strategy for fuelbreaks and primary ridgelines, midslopes, Emergency Travel Routes and drainages.

Figure 2.02-3 Reforestation landscape strategy

Figure 2.02-4 shows an example of how the meadow strategy would look on the landscape. 

Figure 2.02-4 Meadow prescription strategy

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The Alternatives National Forest

RELEASE

Alternative 1 includes hand grubbing or manually applying herbicides (glyphosate) on up to 21,300 

acres.

PRESCRIBED FIRE

Alternative 1 includes prescribed fire in new plantations on up to 21,300 acres.

Thin ExistingPlantations

Alternative 1 includes prescribed understory burning and thinning within existing plantations (outside 

of Deer Enhancement areas) on up to 12,769 acres. Deer Enhancement areas are also proposed for 

ICO thinning, but have their own specific prescription.

Management Requirements

Alternative 1 includes the following management requirements in addition to the Management 

Requirements Common to All Action Alternatives (Chapter 2.03). 

AQUATIC SPECIES

1. Herbicide Operations 

a. Do not refill individual herbicide backpacks within 50 feet of any stream with surface water.

b. Do not use stream water for mixing herbicides or for rinsing equipment or containers that 

have contained herbicide mix.

c. Do not apply herbicide formulations within 50 feet of Eleanor Creek or the two ponds on 

Kibbie Ridge.

d. Between June 1 and September 1, avoid herbicide applications within 100 feet of habitats 

known to be occupied by Western Pond Turtle (WPT).

e. Do not apply herbicide formulations within 25 feet of streams with known occurrences of 

foothill yellow-legged frogs unless approved by an aquatic biologist. 

f. Do not apply herbicide within 107 feet of suitable habitat of Sierra Nevada yellow-legged 

frogs unless reviewed by an aquatic biologist.

g. Restrict herbicide type in both upland and near-aquatic suitable habitat for California redlegged frog; permitted herbicides include aminopyralid and glyphosate (aquatic formulation) 

only. 

CULTURAL RESOURCES

2. Flag and avoid all eligible and unevaluated cultural resources during implementation except for 

the following activities which are allowed under the Rim Programmatic Agreement (PA): 

a. Herbicide application within historic sites such as railroad logging camps, logging activity 

areas, railroad grades, historic trails/roads and ditches is permitted. 

b. Spot apply noxious weed treatments within prehistoric site boundaries, as long as the 

herbicide does not affect the use of resources by Native Americans.

3. Place signage, indicating application date and herbicide name, on-site once herbicide treatments 

begin and leave on-site for 30 days after application ends. Additionally, place a map at the 

Tuolumne Rancheria Tribal Hall indicating where and when areas were sprayed.

RANGE

4. Notify a range specialist at least 8 weeks in advance of application if withholding of grazing is 

recommended by herbicide product label. 

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SOILS

5. Deep Tilling and Forest Cultivation

a. On slopes over 20%, maintain at least one 8 to 10-foot vegetated buffer strip for every 100 

feet of contour deep tilling or forest cultivation; this area can overlap with the unplanted rows 

or areas in planting design. In units with only portions identified that are suitable for deep 

tilling, consult with a soil scientist to assist in delineating these areas on the ground before the 

work begins. 

b. For deep tilling units with slopes greater than 15%, leave a buffer strip of 12 feet on the 

downhill side of roads that may concentrate water and drain onto a deep tilled unit. 

c. Deep till followed by forest cultivation on less than 30% slopes. 

SPECIAL INTEREST AREAS

6. Do not apply herbicides within 20 feet of madrone trees, saplings, and seedlings unless needed to 

control invasive species. Ensure all madrones are protected during noxious weed herbicide

applications. 

TERRESTRIAL WILDLIFE

7. Flag and avoid elderberry plants greater than one inch stem diameter in unit Z030. Prohibit 

herbicide application within 100 feet of elderberry shrubs.

VEGETATION

8. Herbicide Operations 

a. Inspect sites prior to herbicide application to ensure that no one is present who is not 

officially participating in the application process.

b. Post signs after application, identifying the date and chemical used, adjacent to units at 

common entry points. Posted information includes the type of herbicide applied, date of 

treatment and a contact name and phone number. 

c. Restrict access into the treated areas until the liquid herbicide solution has dried. 

d. Follow all label requirements for personal protective equipment (PPE). 

e. Use minimum protective clothing, unless specified otherwise on the label. This includes: 

coveralls over shirt and pants, socks, boots, safety glasses or goggles, hardhats and chemical 

resistant gloves. All clothing will be clean at the start of the day. Change clothing and clean 

the skin with soap and water if the herbicide mixture penetrates the clothing.

f. Provide soap and clean water at the work site. Wash with soap and water immediately after 

contact with the herbicide mixture. Wash with soap and water before eating, smoking or 

going to the bathroom. 

g. To reduce off-site movement, drift, or volatilization, do not apply when the following 

weather parameters are observed:

 Sustained winds in excess of 5 mph. 

 Precipitation, or a 70% or greater chance, predicted within 24 hours. 

 Foggy weather 

 Excess dew on target plants 

 Less than 30% relative humidity

 Temperature that exceeds 85 degrees Fahrenheit

 Temperature inversions that could lead to off-site movement of the herbicide mixture 

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WATERSHED

9. Management Requirements Incorporating BMPs and Forest Plan S&Gs: Table 2.02-3 presents 

management requirements pertaining to vegetation manipulation by herbicide application. 

Table 2.02-3 Management requirements incorporating BMPs and Forest Plan S&Gs 

Management Requirements BMPs/Forest Plan1/Locations

Vegetation Manipulation/Herbicide Use

- Comply with all label and other applicable legal requirements for herbicide use 

and cleaning and disposal of pesticide equipment and containers. Incorporate a 

spill contingency plan into the project safety plan and have on site during herbicide 

application.

- To protect streams and special aquatic features, do not apply Glyphosate within 

the following designated buffers zones: 10 feet from the edge of any perennial 

stream, intermittent streams, ephemeral streams, 10 feet from any special aquatic 

features such as spring, seep, fens, and 10 feet away from obligate riparian 

vegetation. 10-foot buffer does not apply if any intermittent stream or ephemeral 

stream is dry at the time of application.

- Do not apply Clopyralid, Aminopyralid and Clethodim within the following 

designated buffer zones: 50 feet from edge of any perennial stream 50 feet from 

edge of any intermittent or ephemeral stream, special aquatic feature, or wet area 

that has standing water at the time of application, or ten feet away from obligate 

riparian vegetation. 15 feet from edge of any intermittent or ephemeral stream, or 

special aquatic feature that is dry at the time of application.

- Do not apply Clopyralid, Aminopyralid and Clethodim to areas with high surface 

runoff potential such as road surfaces, roadside ditches, shallow soils, and rocky 

or compacted slopes adjacent to perennial or intermittent streams. To avoid 

excessive leaching, soils should not be saturated at time of application. Soil 

moisture should be drier than field capacity.

- Storage of Herbicides: No storage of herbicides will be allowed on RCAs other 

than what will be carried in the contractor(s) vehicle to complete each day’s work. 

Mixing and loading will be done in areas where accidental spills will not 

contaminate streams or other water. Mixing sites will be predetermined by the 

COR and should be as far from water and on ground as level as possible. Include 

spill cleanup procedures in all project plans. 

Regional BMPs

5-7 Pesticide Use Planning Process

5-8 Pesticide Application According to Label 

Directions and Applicable Legal 

Requirements

5-11 Cleaning and Disposal of Pesticide 

Containers and Equipment

5-12 Streamside Wet Area Protection During 

Pesticide Spraying

National Core BMPs

Chem-1 Chemical Use Planning

Chem-2 Follow Label Directions

Chem-3 Chemical Use Near Waterbodies

Chem-5 Chemical Handling and Disposal

Forest Plan S&Gs

193 (RCO 1)

Locations: all units with applications in RCAs.

1 Forest Plan S&Gs indicate page number from Forest Plan Direction (USDA 2010a).

Alternative 2 (No Action)

Alternative 2 (No Action) provides a baseline for comparison with the other alternatives (Table 2.05-

1). Under Alternative 2 (No Action), deer habitat enhancement, noxious weed eradication, 

reforestation (site preparation, planting conifers, release and reintroduction of prescribed fire) and 

thinning would not occur. Current management plans would continue to guide management of the 

project area.

Alternative 3

Alternative 3 responds to the significant issues and concerns identified through public scoping 

(Chapter 1.08). Compared to Alternative 1, it addresses those issues by proposing: additional human 

and native species health protections (no herbicides) and a different fuel break ridge treatment 

responding to the reforestation issue of fire hazard. Because no herbicides would be used for site 

preparation, release or noxious weed eradication, additional deep tilling and forest cultivation and 

manual grubbing treatments were added. Alternative 3 includes the treatments and actions described 

below and shown on Map 1, Map 2 and Map 5 (map package). Chapter 2.01 provides more details 

about each treatment. Table 2.05-1 provides a summary of the proposed activities by alternative. 

Appendix E (Treatments) provides detailed information related to the specific treatment units in this 

alternative.

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Rim Fire Reforestation (45612) Chapter 2

Draft Environmental Impact Statement The Alternatives

Deer Habitat Enhancement

Alternative 3 includes similar deer habitat enhancement treatments as Alternative 1 within the same 

3,833 unit acres; however, site preparation 646 acres of tilling and hand grub release to replace 

herbicide use on the 646 planted acres.

Natural Regeneration

Alternative 3 includes the same natural regeneration units as Alternative 1 on 4,031 acres that could 

potentially be planted. Treatments would be similar to Alternative 1, except mechanical site 

preparation and hand grubbing for release would replace herbicide use.

Noxious Weed Eradication

Alternative 3 proposes noxious weed eradication on approximately one half of the acres as 

Alternative 1. Only those populations and species that can be effectively eliminated through nonchemical means are proposed for treatments on 3,350 acres. Methods for removal include: burning, 

targeted grazing, grubbing, hand-pulling, and native seeding. The majority of the noxious weed 

treatments are within the reforestation units. Appendix N (Noxious Weed Schedule, project record) 

displays the implementation schedule for noxious weed eradication under this alternative. 

Reforestation

All acreages described under this section do not include reforestation acres proposed for deer habitat 

enhancement or natural regeneration. Alternative 3 would reforest the same 21,300 acres as 

Alternative 1. Appendix E (Treatments) provides detailed information related to the specific treatment 

units in this alternative. Appendix R (Reforestation Schedule, project record) displays the 

implementation schedule for reforestation treatments under this alternative.

SITE PREPARATION

Alternative 3 includes site preparation on up to 13,175 acres using a combination of the following 

methods: deep till followed by forest cultivation (8,893 acres); feller buncher (remove biomass or 

pile and burn, 3,139 acres); hand cut, hand pile and burn (74 acres) or jackpot burn on steep slopes 

(237 acres); machine pile and burn (912 acres); and mastication (shred, 1,844 acres). 

Alternative 3 deep tills and forest cultivates an additional 3,808 acres over Alternative 1 for a total of 

8,893 acres within the proposed conifer planting areas. Alternative 3 includes deep tilling and forest 

cultivation treatment on slopes up to 35% (increased from 30% in Alternative 1) and drops the two 

tilling-related management requirements for untreated buffer strips. 

Alternative 3 site preparation methods for the removal of competing vegetation just includes deep till 

and forest cultivation. Because Alternative 3 does not include the application of herbicides for the 

removal of competing vegetation, no site preparation for competing vegetation would occur on 

12,407 acres. In these areas, hand grubbing of the competing vegetation would be necessary 

immediately following tree planting to help initial survival of the seedlings.

PLANT CONIFERS

Plant conifers on 21,300 acres using a variable planting design (Table 2.02-4). Because of the higher 

expected mortality levels, space individual trees 10 to 14 feet apart and space trees in clumps 6 to 8 

feet apart within all units to help ensure over 200 trees per acre survive after 5 years. Plant clumps in 

between the individuals resulting in about 7-foot spacing (Table 2.02-4). The desired variable 

densities reflect slope position and fuels emphasis areas as stated in Alternative 1. Oak buffers and 

meadows are the same as Alternative 1.

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Chapter 2 Stanislaus

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Table 2.02-4 Variable tree planting strategy

Clump Size Trees per clump Clumps per acre Trees per acre

Individuals 1 194 to 364 194 to 364

Small 5 4 to 6 20 to 30

Medium 15 2 to 6 30 to 90

Large 30 0 to 1 0 to 30

Totals 6 to 13 244 to 514

Strategic Fire Management Areas: In Alternative 3, within reforestation units, the identified 

Strategic Fire Management Feature fuel breaks are approximately 90 feet across and are bordered by 

80 feet of 15-foot by 15-foot planting on each side for a total width of 250 feet (486 acres). Within the 

center of these fuel breaks, plant one row of 4-tree micro-clusters (14 feet between outside trees, 7 

feet to the middle tree and 26 feet between cluster centers) leaving about 32 feet of a no-plant area on 

each side before beginning the 15-foot by 15-foot spaced planting pattern. The 90 foot fuel break 

center has 74 trees per acre and the adjacent 80 foot areas have 194 trees per acre, averaging 151 trees 

per acre. Where roads are present within the center of the fuel break, alternate the planting of 4-tree 

micro-clusters on each side of the road beginning 12 feet off of the road edge. Primary ridges that do 

not include fuel breaks are the same as Alternative 1 outside of SFMAs. Emergency Travel 

Routes are the same as Alternative 1. 

On fuel breaks and along Emergency Travel Routes, separate continuous vegetation between one and 

12 feet tall, into naturally appearing clumps to break up horizontal fuels across the fuel break on an 

approximate five year maintenance interval. Remove fire ladders into the developing overstory. 

Dispose of slash by piling, burning, chipping, masticating or removing. 

RELEASE

Release would be accomplished by manually grubbing vegetation on 21,300 acres. Depending on the 

competing species, this would require more than one grub per year and several consecutive years of 

treatment to meet desired tree survival levels. Grass and sprouting species, such as bear clover, can 

only be effectively set back with more than one treatment a year. This project analyzes for an early 

spring grub (when vegetation first begins to sprout and grow and a late spring grub to eliminate the 

later sprouting and seeding species). No herbicides would be used. 

PRESCRIBED FIRE

Alternative 3 includes similar burning through new plantations post-planting as Alternative 1 on the

same 21,302 acres.

Thin Existing Plantations

Alternative 3 includes similar understory burning and thinning on 12,769 acres in existing plantations 

as Alternative 1.

Management Requirements

Alternative 3 includes the following management requirements in addition to the Management 

Requirements Common to All Action Alternatives (Chapter 2.03). 

SENSITIVE PLANTS

1. Do not deep till and forest cultivate in units BB069, BB071 and BB072. Provide a 500-foot buffer 

for Botrychium species and Eryngium sp. nov. Provide a 200-foot buffer for Cypripedium 

montanum, Mimulus filicaulis, Mimulus pulchellus occurrences.

SOILS

2. Deep till followed by forest cultivation on less than 35% slopes. 

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Rim Fire Reforestation (45612) Chapter 2

Draft Environmental Impact Statement The Alternatives

Alternative 4

Alternative 4 responds to the significant issues and concerns identified through public scoping 

(Chapter 1.08). Compared to Alternative 1, it addresses those issues by proposing: considerably fewer 

planted acres and trees and the reintroduction of early and frequent use of prescribed and natural fire 

within and adjacent to these stands. Thousands of acres, proposed in Alternative 1, would not have 

initial mechanical fuels treatments and would remain unplanted in Alternative 4. Reforestation would 

occur on 2,867 acres. In addition, complex early seral forest is left intact and removed from 

reforestation consideration.

Complex early seral forest follows stand-replacing disturbance in a mature forest and is characterized 

by abundant snags and downed logs, natural conifer regeneration, and development of a diverse 

understory community of post-disturbance vegetation and associated wildlife (DellaSala et al. 2014).

Complex early seral forest (19,971 acres) is allowed to develop unassisted except for the use of 

prescribed fire. Allow plants and tree seedlings to naturally regenerate and reoccupy the site among 

the dead over-story trees in a pattern determined only by processes and conditions unaltered by 

human intervention except for prescribed fire. Alternative 4 includes the treatments and actions 

described below and shown on Map 1, Map 3 and Map 5 (map package). Chapter 2.01 provides more 

details about each treatment. Table 2.05-1 provides a summary of the proposed activities by 

alternative Appendix E (Treatments) provides detailed information related to the specific treatment 

units in this alternative.

Deer Habitat Enhancement

The area of deer habitat enhancement (3,833 acres) in Alternative 4 has the same acres of prescribed 

burning and ICO thinning as Alternative 1 (1,164 acres). This alternative also includes 88 acres of 

planting, 558 acres fewer than Alternative 1.

Natural Regeneration

Alternative 4 does not include natural regeneration treatments as described in Alternative 1. The 

heading “Plant Conifers” describes how natural regeneration is treated in Alternative 4. 

Noxious Weed Eradication

Alternative 4 includes similar noxious weed eradication as Alternative 3 on 3,350 acres. No 

herbicides would be used. Appendix N (Noxious Weed Schedule, project record) displays the 

implementation schedule for noxious weed eradication under this alternative. 

Reforestation

Alternative 4 would reforest no more than 20% of each unit proposed in Alternative 1, 2,867 acres. 

Appendix E (Treatments) provides detailed information related to the specific treatment units in this 

alternative. Appendix R (Reforestation Schedule, project record) displays the implementation 

schedule for reforestation treatments under this alternative.

SITE PREPARATION

Alternative 4 includes similar manual site preparation treatments as described in Alternative 1, but 

only on 20% of each unit (2,867 acres). This includes the use of herbicides in order to intensely 

manage (for brush abatement and tree survival) these small areas across the landscape. Deep tilling

and forest cultivating is not proposed due to the small size of the areas proposed for treatment (less 

than 10 acres). 

PLANT CONIFERS (FOUNDERSTANDS) 

Outside of complex early seral forest, plant founder stands within the same units identified in 

Alternative 1. Founder stands are small variable-shaped planted areas ranging from 2 to 10 acres in 

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Chapter 2 Stanislaus

The Alternatives National Forest

size within a larger area. Plant up to 20% of a contiguous seedling-deficient polygon and leave the 

remainder unplanted. Plant 20 to 40 clusters per acre spaced an average of 33 feet apart, variably 

spaced based on site conditions. Within each cluster, plant 5 trees spaced 6 feet between each tree. 

This provides 100 to 200 trees per acre on a given planted acre. 

Plant 200 feet away from known sensitive plant populations. Do not plant within the designated fuel 

breaks (based on the Alternative 1 design), Emergency Travel Route corridors, along primary ridges, 

drainage bottoms, or in the thin and reforest units (surviving older plantations). Focus planting areas 

within the mid-slope of each unit where natural regeneration is less likely to occur. 

Plant bare-root or container stock ponderosa pine, sugar pine, incense cedar, Douglas-fir, white fir 

and giant sequoia based on seed zones and elevation. Scalp a 1-foot square area to bare mineral soil 

prior to digging a hole for the seedling. Plant trees in distinct groupings that allow for fire use in and 

adjacent to planted areas within a decade of being planted. Utilize or culture existing living trees as 

anchors for future regeneration. Prioritize planting in selected areas that have higher amounts of 

shading, cooling or extended water retention to enhance tree survival. Vary planting density by site 

condition and topographic position, e.g., higher density within the range for high site conditions or 

lower on a slope. 

RELEASE

Alternative 4 includes manually applying herbicides (glyphosate) on up to 4,012 acres to initially 

ensure limited vegetation competition to the planted seedlings and to maintain a buffer of 25 feet to 

50 feet around Founder Stands. Manage the buffer to maintain a lower brush component to reduce fire 

spread and increase fire resilience within the planted areas. 

PRESCRIBED FIRE

Alternative 4 treats 50% of the reforested areas (7,186 acres) and 50% (9,986 acres) of the complex 

early seral forest with prescribed fire within one fire return interval (approximately 10 years). Use a 

dozer to line the plantations prior to burning, where needed. Prescribed fire would be returned to the 

other 50% of the areas (17,172 acres) in the second decade and then repeated through time. The 

emphasis is on returning fire to this landscape.

Thin Existing Plantations

Alternative 4 includes similar understory burning and thinning on 12,768 acres in existing plantations 

as Alternative 1.

Management Requirements

Alternative 4 includes the following management requirements in addition to those included in 

Alternative 1 and the Management Requirements Common to All Action Alternatives (Chapter 2.03). 

FIRE AND FUELS

1. Outside of strategic areas identified specifically to provide for firefighter safety as part of a 

landscape-wide and long-term prescribed fire program, no standing dead trees shall be felled or 

downed wood shall be piled and burned or otherwise removed from areas that meet the desired 

conditions for complex early seral forest or are important to sustain wildlife.

2. Manage snags and other fuels in strategic areas identified specifically to provide for firefighter 

safety as part of a landscape-wide and long-term prescribed fire program. 

3. Avoid planting more than 40 trees per acre across each unit in the Strategic Fire Management 

Areas.

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Rim Fire Reforestation (45612) Chapter 2

Draft Environmental Impact Statement The Alternatives

Alternative 5

Alternative 5 responds to the significant issues and concerns identified through public scoping 

(Chapter 1.08). Compared to Alternative 1, it addresses those issues by proposing: planting at a 

denser 7-foot by 14-foot spacing throughout deer habitat enhancement areas, natural regeneration 

units and reforestation units that include thinning into an open mosaic structure. This would result in a 

6 to 8-foot by 12 to 16-foot spacing when applied on the ground at 444 trees per acre. Alternative 5 

does not include prescribed fire post-planting in new plantations. Alternative 5 includes the 

treatments and actions described below and shown on Map 1, Map 2 and Map 4 (map package). 

Chapter 2.01 provides more details about each treatment. Table 2.05-1 provides a summary of the 

proposed activities by alternative. Appendix E (Treatments) provides detailed information related to 

the specific treatment units in this alternative.

Deer Habitat Enhancement

Alternative 5 includes similar deer habitat enhancement treatments as Alternative 1 on 3,833 acres. 

Unlike Alternative 1, Alternative 5 plants the 646 acres of deer habitat enhancement areas on 7 by 14-

foot spacing and if necessary uses thinning to accomplish the desired mosaic structure. Initiate the 

thinning as early as 7 years post-planting after the trees have expressed dominance and site 

occupancy. 

Natural Regeneration

The 4,031 acres proposed for natural regeneration under Alternative 1 would be treated using the 

Alternative 5 reforestation prescription and is included in the acreage listed under reforestation.

Noxious Weed Eradication

Alternative 5 includes similar noxious weed eradication as Alternative 1 on 5,915 acres, emphasizing 

the use of herbicides. The majority of the noxious weed treatments are within the reforestation units. 

Appendix N (Noxious Weed Schedule, project record) displays the implementation schedule for 

noxious weed eradication under this alternative. 

Reforestation

All acreages described under this section do not include reforestation acres proposed for deer habitat 

enhancement. 

Alternative 5 includes similar reforestation treatments as Alternative 1 and includes the 4,031 natural 

regeneration areas for a total of the same 25,331 acres. Appendix E (Treatments) provides detailed 

information related to the specific treatment units in this alternative. Appendix R (Reforestation 

Schedule, project record) displays the implementation schedule for reforestation treatments under this 

alternative.

SITE PREPARATION

Alternative 5 includes similar site preparation as Alternative 1 on up to 25,331 acres, including the 

manual application of herbicides. Alternative 5 includes deep till and forest cultivation treatments in 

the same areas proposed in Alternative 1 (5,085 acres) on slopes up to 35%. 

PLANT CONIFERS

Alternative 5 proposes planting conifers on 25,331 acres in the same areas proposed in Alternative 1, 

including the natural regeneration units. Unlike Alternative 1, Alternative 5 plants all the proposed 

units and areas on 7 by 14-foot spacing regardless of landscape location and Strategic Fire 

Management Areas (SFMA). Scalp a 1-foot square area to bare mineral soil prior to digging a hole 

for the seedling. Integrate existing desired conifers into the prescribed planting pattern, spacing off 

them the same distance as a planted seedling. Planting will not occur in the following situations: 

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Chapter 2 Stanislaus

The Alternatives National Forest

natural regeneration areas, oak aggregates, riparian vegetation areas, selected openings, rock 

outcrops, along cliffs, cultural sites except where requested by the Tribe, sensitive plant sites or on 

poor soils (low site class). Oak buffers are the same as Alternative 1.

Meadows: Plant conifers outside of meadows and beyond a 25-foot meadow buffer utilizing oaks, 

seedling mortality and thinning to create the desired mosaic and minimal tree structure adjacent to 

meadows.

RELEASE

Alternative 5 includes similar release treatments as Alternative 1 and includes the additional 4,031 

acres of natural regeneration acres to manually apply herbicides (glyphosate) on up to 25,331 acres.

PRESCRIBED FIRE

Unlike Alternative 1, Alternative 5 does not include prescribed fire in new plantations within the first 

10 years.

THINNEW PLANTATIONS

If desired ICO or fuel break structure is not created through oak buffers, riparian species, seedling 

mortality, and other factors, plantations could be thinned to achieve the desired structure based on 

landscape position and SFMA. Thinning could be initiated as early as 7 years post-planting once the 

trees have expressed dominance and site occupancy.

Thin Existing Plantations

Alternative 5 includes similar understory burning and thinning on 12,769 acres in existing plantations 

as described in Alternative 1.

Management Requirements

Alternative 5 includes the same management requirements as Alternative 1 except the Soils

requirements. Alternative 5 also includes the following management requirement in addition to the 

Management Requirements Common to All Action Alternatives (Chapter 2.03). 

SOILS

1. Deep till followed by forest cultivation on less than 35% slopes. 

2. On slopes over 20%, maintain at least one 8 to 10-foot vegetated buffer strip for every 100 feet of 

contour deep tilling or forest cultivation; this area can overlap with the unplanted rows or areas in 

planting design. In units with only portions identified that are suitable for deep tilling, consult 

with a soil scientist to assist in delineating these areas on the ground before the work begins. 

3. For deep tilling units with slopes greater than 15%, leave a buffer strip of 12 feet on the downhill 

side of roads that may concentrate water and drain onto a deep tilled unit.

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Rim Fire Reforestation (45612) Chapter 2

Draft Environmental Impact Statement The Alternatives

2.03 MANAGEMENT REQUIREMENTS COMMON TO ALL ACTION 

ALTERNATIVES

Based on a site specific review of each alternative, resource specialists identified the following 

management requirements that would be implemented under the action alternatives (1, 3, 4 and 5).

AIR QUALITY

1. Limited Operating Periods (LOPs):

a. Complete all burning under approved burn and smoke management plans. Acquire burn 

permits from the appropriate county Air Pollution Control District(s) which will determine 

when burning is allowed. The California Air Resources Board provides daily information on 

"burn" or "no burn" conditions. Design and implement burn plans to minimize particulate 

emissions.

AQUATIC SPECIES

2. Limited Operating Periods (LOPs):

a. Prohibit mechanical operations and herbicide applications within 1 mile of areas identified as 

suitable California red-legged frog (CRLF) breeding habitat during the wet season (the first 

rainfall event depositing more than 0.25 inches of rain on or after October 15 until April 15). 

b. Within 300 feet of occupied WPT habitat, prohibit all project activities between May 15 and 

July 15.

c. Prohibit equipment operations within 300 feet of Abernathy Meadow and Big and Little 

Kibbie Ponds from June 1 through July 15 and during periods when these features have no 

standing water. 

3. Aquatic Habitat: 

a. Do not locate burn piles within 100 feet of suitable CRLF breeding habitat or occupied WPT 

habitat, or within 50 feet of CRLF non-breeding aquatic habitat. 

b. Within 1 mile of suitable CRLF breeding habitat and 300 feet of occupied WPT habitat, 

ignite all burn piles on only one side, not to exceed half the circumference of the pile, on the 

side furthest from the nearest aquatic feature.

c. Do not deep till within 100 feet of aquatic features occupied by WPT unless reviewed by an 

aquatic biologist.

d. Use screening devices on water drafting pumps and use pumps with low entry velocity to 

minimize impacts to aquatic species. A drafting box measuring 2 feet on all sides covered in a 

maximum of 0.125 inch screening is required. 

CULTURAL RESOURCES

4. Project implementation will comply with the stipulations of the Programmatic Agreement Among 

the United States Forest Service, Stanislaus National Forest, The California State Historic 

Preservation Officer, and The Advisory Council on Historic Preservation, Regarding the Program 

of Rim Fire Emergency Recovery Undertakings, Tuolumne County, California (Rim PA).

5. Flag and avoid all eligible and unevaluated cultural resources during implementation except for 

the following activities which are allowed under the Rim PA: 

a. Allow one-end suspension where tree removal within cultural resource site boundaries is 

found to benefit and improve site protection. In all cases a cultural resource specialist will be 

present to direct access within site boundaries. 

b. Non-flammable sites may be burned over. However, consult with the cultural resource

specialist to determine if certain cultural features need a reduction in fuel load (e.g. hand 

thinning) prior to burning. 

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Chapter 2 Stanislaus

The Alternatives National Forest

c. The cultural resource specialist will identify sites where tree planting will occur within sites, 

for erosion control or to shield vulnerable site features.

6. Leave in place any tree inadvertently felled into a cultural site boundary until the incident is 

evaluated by the cultural resource specialist. 

7. Construct all piles outside of identified cultural resource site boundaries. 

8. Exclude historic sites with wooden remains from the project area or protect during burning using 

one of the following: hand or dozer constructed firelines, foam wetting agents, or fire shelter 

fabric. 

9. Do not cut line within flagged areas.

10. Remove /cut vegetation away from the sites to reduce flare-up near the site. 

11. Where sites are linear and have excessive wooden features, burn away from sites instead of 

toward them (blackline sites).

12. Notify the cultural resource specialist if a new cultural site is discovered during project 

implementation, and cease all activities within 150 feet of the resource until consultations are 

completed. 

FIRE AND FUELS

13. Strategic Fire Management Features (FEATURE)

a. Maintain the desired vegetation structure throughout the life of the FEATURE on a 5 year 

rotation and based on site conditions. 

b. Limit woody debris to less than 10 tons per acre on average with a fuel bed depth less than or 

equal to 12 inches. 

c. Limit the number of down logs greater than 20 inches in diameter to 5 or less logs per acre on 

average. 

14. Strategic Fire Management Areas (AREA)

a. Maintain the desired vegetation structure on a 5 to 10 year rotation and based on site 

conditions. 

b. Limit snags to 6 or less per acre on average. Do not leave snags adjacent to FEATUREs or 

roads. 

c. Limit woody debris to less than 20 tons per acre on average. 

d. Limit the number of down logs greater than 20 inches in diameter to 5 or less logs per acre on 

average.

INVASIVE PLANTS

15. Reduce risk of weed spread

a. All vehicles and equipment that goes off road, clothing, particularly footwear, and transport 

vehicles must be free of soil, mud (wet or dried), seeds, vegetative matter or other debris that 

could contain seeds in order to prevent new infestations of noxious weeds in the project area. 

Dust or very light dirt, which would not contain weed seed, is not a concern. 

b. Treat weed sites prior to implementing mechanical activities, timing the treatments to 

effectively eliminate seed production in the year of the mechanical activity. Where possible, 

treat in years prior to the mechanical activity to reduce or eliminate the weed infestations in 

those sites.

c. Flag and avoid noxious weed populations if pre-treatment cannot be done. In areas where 

noxious weeds cover large areas, mechanical treatments can be done within sites, but 

equipment must be cleaned before leaving the unit. 

d. Do not stage equipment, material or personnel in areas with noxious weed infestations. 

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Rim Fire Reforestation (45612) Chapter 2

Draft Environmental Impact Statement The Alternatives

e. After using equipment in infested areas, clean equipment so that it is free of soil, seeds, 

vegetative matter or other debris prior to being moved off site. Within infested units, conduct 

project activities in uninfested portions first. In order to move equipment from one infested 

area to another, the infestations in both areas must be the same species and the new area must 

have widespread infestations. If both situations are not present, then equipment must be 

cleaned prior to moving into the next area. 

f. The Forest Service will designate the order, or progression, of unit completion to emphasize 

treating uninfested units before treating infested units. 

RANGE

16. Protect range resources:

a. Do not plant within 10 feet of rangeland infrastructures. 

b. Repair to Forest Service standards any serviceable or intact infrastructure that is damaged 

during implementation. 

c. Provide for site stabilization in areas adjacent to meadows that are disturbed by project 

activities (fuels treatments, thinning, etc.). Use native seed collected locally from within the 

project area.

d. Do not schedule treatments (chemical or mechanical) on more than 20% of the capable 

rangeland in any allotment and no more than 20% of the total allotment area each year. 

Grazing allotments with a high proportion of area proposed for treatment include Jawbone, 

Rosasco, Middle Fork, Curtin, and Hunter Creek. 

RECREATION

17. Protect recreation resources:

a. No biomass hauling or spray vehicles on Evergreen Road or Cherry Lake Road: from July 3 

through July 5; during Memorial and Labor Day weekends (3:00 p.m. Friday through 

Monday); or, on other weekends (3:00 p.m. Friday through Sunday) between Memorial Day 

and Labor Day. 

b. No operations on weekends beginning Memorial Day through Labor Day in areas adjacent to 

Lost Claim and Sweetwater Campgrounds.

c. Identify and protect National Forest System Trails (NFST) during mechanical operations. 

Restore trails, if damaged, in kind according to Forest Service standards including the 

placement of rolling dips. 

d. Do not use water sources in developed recreation sites when open to the public. 

SENSITIVE PLANTS

18. Protect sensitive plants:

a. Flag and avoid occurrences of Sensitive Plants, Watchlist Plants and Forest Botanical Interest 

plants. Flag and buffer adequately the occurrences of sun-loving species to avoid future 

shading by the planted trees.

b. Flag and avoid known and new occurrences of Sensitive Plants except as allowed below:

1. Manual fuel reduction may take place within Clarkia australis, Clarkia biloba ssp.

australis, Mimulus filicaulis or Mimulus pulchellus occurrences only during the dry nongrowing period. Pile or scatter all material outside Sensitive Plant occurrences.

2. Mastication and feller buncher and deep tilling/forest cultivation may be conducted 

within Clarkia australis occurrences only during the dry non-growing period. Do not 

track masticator through occurrences smaller than 0.25 acre. Minimize tracking in 

occurrences larger than 0.25 acre. Wherever possible, reach into occurrences with 

masticator head to conduct the work instead of tracking through. 

c. Plant Douglas-fir adjacent to Cypripedium montanum occurrences in order to restore the 

mycorrhizal fungal partnerships necessary for the survival of the Cypripedium. 

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Chapter 2 Stanislaus

The Alternatives National Forest

d. In order to protect occurrences of Peltigera gowardii, conduct project activities near 

perennial streams in such a way that sediment is not added to or accumulates within 

occurrences.

e. Do not allow foot traffic by contractors, forest workers or work inspectors within flagged 

occurrences.

f. Protect any new occurrences discovered in the project area.

SOILS

19. Follow Forest Service Manual 2550 Soil Management R5 Supplement (USDA 2012) and Forest 

Plan Direction (USDA 2010a) to identify Soil Management Practices (SMPs) that minimize soil 

impacts.

a. Limit skidding with rubber-tired or fixed track equipment to slopes less than 35%; limit low 

ground pressure tracked equipment (e.g. masticator or feller buncher) to less than 45%; limit 

dozer piling and other (non-deep tilling) mechanical site preparation to less than 30%, or less 

than 25% on soils with Erosion Hazard Ratings higher than moderate. 

b. Replace or recontour soil when excessive soil displacement occurs.

c. The soil scientist will monitor ground-based operations occurring between November 1 and 

June 1 (test for soil moisture and traffic-ability). Ground-based equipment will operate on 

relatively dry soils of high soil strength, or bearing capacity to prevent soil compaction. 

d. Maintain a well-distributed soil cover of 50% after site preparation, prescribed fire or release 

treatments on slopes less than 25%. Maintain 60% cover on steeper slopes and within 

Riparian Conservation Areas (RCAs). Soil cover consists of duff and litter, basal live plant 

cover, fine woody debris, surface rocks, and downed logs. Deep tilling (subsoiling) and forest 

cultivation site preparation treatments are excluded from this requirement and fuel’s 

requirements also take priority in order to ensure fuels reduction on these sites.

e. Where existing ground cover is less than desired, some trees may be felled and left in place or 

masticated into pieces less than 2 feet in length to reduce potential soil erosion and maintain 

soil productivity. 

20. Mechanical Site Preparation

a. Use a brush rake for all dozer piling work. Keep the blade about 6 inches above ground level 

to prevent soil, litter, and duff material from being piled. Piles should be relatively free of soil 

(less than 10% soil material), and will be re-spread and rebuilt if they do not meet these 

specifications. 

b. For deep tilling, ensure that contract specifications plan include the maximum depth of 

furrowing, a requirement for backblading when the depth of furrowing is exceeded, and 

winged ripper tool design specifications. 

c. Perform deep tilling when soils are below their plastic limit throughout the top 18 inches. The 

soil should crumble when attempting to form a ‘ribbon’ or roll a thread. In addition, for areas 

with heavy clay content, do not perform deep tilling when soil is dry; this will allow for 

proper fracturing of soil without creating excessive disturbance. Examples of soils with heavy 

clay content include: Jocal (Josephine), Sites, Stump Springs, Musick, and Hoda. 

d. Deep till along the contour with slope measured in deep tilled furrows being less than 5%. If 

contour deep tilling cannot be achieved in some areas, select these as sites for vegetated 

buffer strips. 

e. Leave a no-till strip below drainage outlets. 

SPECIAL INTEREST AREAS

21. Offset conifer planting 25 feet from all madrone trees, saplings, and seedlings.

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Rim Fire Reforestation (45612) Chapter 2

Draft Environmental Impact Statement The Alternatives

TERRESTRIAL WILDLIFE

22. Snags and down woody material. 

a. Snag retention in OFEA and Home Range Core Area (HRCA) units: Retain all hardwood 

snags greater than or equal to 12 inches diameter at breast height (dbh). Retain an average of 

30 square feet of basal area of conifer snags across each unit by starting at the largest snag 

and working down, with a minimum of four and a maximum of 6 per acre. Do not leave 

snags along roadsides, critical ridge areas, identified fuel breaks or within 1 tree length of any 

infrastructure.

b. In general forest units and outside of fuelbreaks, retain 1) all hardwood snags greater than 12 

inches dbh and 2) retain the largest conifer snags greater than 15 inches dbh at the rate of 4 

per acre on a unit basis. 

c. In existing plantation units and outside of fuelbreaks, retain 1) all hardwood snags greater 

than 12 inches dbh and 2) retain the largest conifer snags available at the rate of 4 per acre on 

a unit basis. 

d. Retain 5 of the largest down logs per acre on a unit basis. Use logs greater than or equal to 20 

inches dbh and at least 20 feet long to meet this requirement where available. Retained down 

logs should be greater than 100 feet from roadsides. 

e. Retain all conifer snags greater than 15 inches and hardwood snags greater than 12 inches 

dbh in units GG063, HH014, R037, and R039. 

f. Inside Strategic Fire Management Areas; retain up to 6 hardwood snags greater than 15 

inches dbh per acre. Minimize damage to re-sprouting oaks when removing hardwood snags 

by directionally felling away from the largest sprout where feasible and avoiding hitting the 

stump while moving the downed material. 

g. Retain high capability habitat for black-backed woodpeckers in units HH029, HH031, K013, 

K018, L002, L003, L005, N010, and N019 eight years post-fire, beginning reforestation 

efforts no sooner than 2021. 

23. Plant blue oaks if needed to supplement natural regeneration in units R041, S004 T021, and 

T024. 

24. Maintain a Limited Operating Period (LOP) prohibiting mechanical operations within 0.25 mile 

of a protected activity center (PAC) during the breeding season for California spotted owls 

(March 1 through August 15), northern goshawks (February 15 through September 15), great 

gray owls (March 1 through August 15) and within 0.5 miles of the known bald eagle nest 

(January 1 through August 31) unless surveys conducted by a Forest Service biologist confirm 

non-nesting status. LOPs may be reduced to a 0.25 mile area around a nest site if surveys are 

conducted. 

25. Prior to pile burning, coordinate with District Wildlife Biologist to ensure disturbance to sensitive 

species does not occur. 

26. Conduct surveys in compliance with the Pacific Southwest Region’s survey protocols to establish 

or confirm the location of the nest activity center for spotted owl, great gray owl and goshawk. 

27. Flag and avoid elderberry plants greater than one inch stem in unit Z030. 

a. Prohibit ground based mechanical operations and burning within 10 feet of elderberry plants. 

b. Maintain an LOP prohibiting pile burning and mechanical activities within 100 feet of 

flagged shrubs from April 1 through June 30 of any given year to avoid fire and dust impacts 

to valley elderberry longhorn beetles.

c. If additional elderberry shrubs with stems over 1 inch diameter are found prior to or during 

project implementation, they will be similarly avoided and the District wildlife biologist will 

be notified immediately.

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Chapter 2 Stanislaus

The Alternatives National Forest

28. Notify the District Wildlife Biologist if any Federally Threatened, Endangered, Candidate species 

or any Region 5 Forest Service Sensitive species are discovered during project implementation so 

that LOPs or other protective measures can be applied, if needed.

VEGETATION

29. Reforestation

a. No planting within 100 feet of power lines. 

b. Flag and avoid 0.2 acre research vegetation plots with 20-foot buffers across the project area. 

WATERSHED

30. Protect beneficial uses of water through implementation of Best Management Practices (BMPs) 

in accordance with Regional Water Quality Management Plan (USDA 2011b) and the National 

BMPs for Water Quality Management on National Forest System Lands (USDA 2012) and the 

following requirements. 

a. Follow Forest Plan Direction (USDA 2010a) for protection of Riparian Conservation Areas 

(RCAs) through compliance with the Riparian Conservation Objectives (RCOs). Table 2.03-1 

provides a summary of the operating requirements for mechanical operations in RCAs. 

Table 2.03-1 Operating requirements for mechanized equipment operations in RCAs

Stream 

Type1

Zone Width

(feet)

MECH2 SKID3 Operating Requirements

PER/INT/SAF Exclusion4 0-15 Prohibited Prohibited N/A

PER/INT/SAF Exclusion 15-50 Allowed Prohibited N/A

PER/INT/SAF Transition 15-50 Allowed Prohibited Remove operation-created debris from stream channels unless 

prescribed for resource benefit. Retain remaining obligate riparian 

shrubs and trees (e.g. willows, alder, aspen). Do not damage 

streambanks with equipment and retain sufficient vegetation to 

maintain streambank stability.

PER/INT/SAF Transition 50-100 Allowed Allowed Use existing skid trails except where unacceptable impact would 

result. The number of crossings should not exceed an average of 2 

per mile.

PER/SAF Outer 100-300 Allowed Allowed Density and intensity of skid trails will gradually increase as distance 

increases from the Transition Zone.

INT Outer 100-150 Allowed Allowed Density and intensity of skid trails will gradually increase as distance 

increases from the Transition Zone.

EPH Exclusion5 0-15 Prohibited Prohibited N/A

EPH Exclusion 15-25 Allowed Prohibited N/A

EPH Transition 25-50 Allowed Allowed The number of crossings should not exceed an average of 3 per mile.

1 PER=Perennial; INT=Intermittent; EPH=Ephemeral; SAF=Special Aquatics Features (lakes, meadows, bogs, fens, wetlands, vernal 

pools, and springs) 2 MECH=Mechanical Harvesting or Shredding (low ground pressure track-laying machines such as feller bunchers and masticators) 3 SKID=Skidding (rubber-tired skidders and track laying tractors) 4 The exclusion zone for perennial/intermittent streams starts at: A. The edge of the active channel where slopes rise uniformly from the 

stream, or at the outer edge of the following features, whichever is the furthest from the stream. B. The first slope-break adjacent to the 

stream (e.g., stream bank, inner gorge). C. Flat or nearly flat ground adjacent to the channel (e.g., floodplain or terrace). D. Obligate 

riparian shrub and/or tree communities associated with any of the above. The exclusion zone for SAFs begins at: A. The outer edge of 

obligate trees, shrubs or herbaceous plants in wet meadows, bogs, fens and springs, or the high water line of lakes and vernal pools. B. 

The top of the first slope-break immediately adjacent to the special aquatic feature if further than the obligate vegetation or high water 

line.

5 The exclusion zone begins at the edge of the channel where slopes rise uniformly or at the edge of the stream bank, whichever is 

furthest from the stream.

b. Management Requirements Incorporating BMPs and Forest Plan S&Gs: Table 2.03-2 

presents management requirements pertaining to: erosion control plans; operations in RCAs; 

road activities; log landings; skid trails; water sources; servicing and refueling of equipment; 

burn piles; prescribed fire; water quality monitoring; and cumulative watershed effects.

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Table 2.03-2 Management requirements incorporating BMPs and Forest Plan S&Gs 

Management Requirements BMPs/Forest Plan1/Locations

Erosion Control Plan

- Prepare a project area Erosion Control Plan (USDA 2011b) approved by the 

Forest Supervisor prior to the commencement of any ground-disturbing project 

activities. Prepare a BMP checklist before implementation.

Regional BMPs

2-13 Erosion Control Plans (roads and other 

activities)

1-13 Erosion Prevention and Control 

Measures During Operations

1-21 Acceptance of Timber Sale Erosion 

Control Measures before Sale Closure

National Core BMPs

Veg-2 Erosion Prevention and Control

Forest Plan S&Gs

194 (RCO 4)

Locations: all areas where ground-disturbing 

activities occur.

Operations in Riparian Conservation Areas

- Delineate riparian buffers within RCAs around all streams and special aquatic 

features within project treatment units. Riparian buffer widths are described in 

Table A-1. 

- Fell trees harvested within RCAs directionally away from stream channels and 

SAFs unless otherwise recommended by a hydrologist or biologist. 

- A minimum of 60% well distributed ground cover is desired within 100 feet of 

perennial and intermittent streams and SAFs.

- Project administrator shall coordinate with a hydrologist prior to operating in units 

BB035, BB050, and BB036 to protect the Bear Gully restoration site, the stream 

channel downstream of the site, and the alluvial flat.

- Exclude mechanized equipment between the near-stream roads that closely 

parallel both sides of Corral Creek in Units R037 and T005 (1N01 and 1N08 on 

the west, and 1N74 and 1N74C on the east) unless otherwise recommended by a 

hydrologist or soil scientist. 

- Planting: For perennial and intermittent streams, do not plant within 15 feet of the 

streambank or 20 feet of their associated riparian vegetation, whichever is more.

- Exclude dozer operations within 50 feet from the start of the exclusion zone for all 

perennial and intermittent and SAFs and 25 feet from the start of the exclusion 

zone for all ephemerals.

Regional BMPs

1-4 Using Sale Area Maps and/or Project 

Maps for Designating Water Quality 

Protection Needs

1-8 Streamside Zone Designation

1-10 Tractor Skidding Design

1-18 Meadow Protection During Timber 

Harvesting

1-19 Streamcourse and Aquatic Protection

5-3 Tractor Operation Limitations in 

Wetlands and Meadows

5-5 Disposal of Organic Debris

7-3 Protection of Wetlands

National Core BMPs

Aq Eco-2 Operations in Aquatic Ecosystems

Plan-3 Aquatic Management Zone Planning

Veg-1 Vegetation Management Planning

Veg-2 Erosion Prevention and Control

Veg-3 Aquatic Management Zones

Veg-4 Ground-Based Skidding and Yarding 

Operations

Forest Plan S&Gs

193 (RCO 2)

194 (RCO 3)

194 (RCO 4)

195 (RCO 5)

Locations: All units containing RCAs and 

SAFs, and specifically the portions of units 

mentioned in this section.

Road Construction and Reconstruction

- Maintain functioning erosion-control measures during road construction and 

reconstruction and in accordance with the erosion control plan.

- Stabilize disturbed areas with mulch, erosion fabric, vegetation, rock, large organic 

material, engineered structures, or other measures according to specifications in

the erosion control plan.

Regional BMPs

2-2 General Guidelines for the Location and 

Design of Roads

2-3 Road Construction and Reconstruction

2-8 Stream Crossings

2-13 Erosion Control Plans (roads and other 

activities)

National Core BMPs

Road-3 Road Construction and 

Reconstruction

Forest Plan S&Gs

62

193 (RCO 2)

194 (RCO 4)

Locations: all roads to be reconstructed.

Road Maintenance and Operations

- Maintain road surfaces to dissipate intercepted water in a uniform manner along 

the road by outsloping with rolling dips, insloping with drains or crowning with 

drains. Where feasible and consistent with protecting public safety, utilize 

outsloping and rolling the grade (rolling dips) as the primary drainage technique. 

- Adjust surface drainage structures to minimize hydrologic connectivity by: 

discharging road runoff to areas of high infiltration and high surface roughness, 

Regional BMPs

2-4 Road Maintenance and Operations

2-13 Erosion Control Plans (roads and other 

activities)

National Core BMPs

Road-4 Road Operations and Maintenance

Veg-2 Erosion Prevention and Control

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Chapter 2 Stanislaus

The Alternatives National Forest

Management Requirements BMPs/Forest Plan1/Locations

armoring drainage outlets to prevent gully initiation, and increasing the number of 

drainage facilities within RCAs. 

Forest Plan S&Gs

193 (RCO 2)

194 (RCO 4)

Locations: all roads with maintenance or 

project use.

Log Landings

- Re-use log landings to the extent feasible.

- Do not construct new landings within 100 feet of perennial or intermittent streams 

and SAFs or 50 feet of ephemeral streams. 

- Deep till all landings when biomass operations are complete.

Regional BMPs

1-12 Log Landing Location

1-16 Log Landing Erosion

National Core BMPs

Veg-6 Landings

Veg-2 Erosion Prevention and Control

Forest Plan S&Gs

194 (RCO 4)

Locations: Biomass Removal: all landings.

Skid Trails

- Use existing skid trails wherever possible, except where unacceptable resource 

damage may result. Locate skid trails at least 50 feet from perennial and 

intermittent streams and SAFs and 25 feet from ephemeral streams.

- Install waterbars and other erosion control measures as needed on skid trails 

immediately following completion of biomass operations.

- Remove skid trails berms that concentrated flows to improve surface drainage 

following use.

Regional BMPs

1-10 Tractor Skidding Design

1-17 Erosion Control on Skid Trails

National Core BMPs

Veg-2 Erosion Prevention and Control

Veg-4 Ground-Based Skidding and Yarding 

Operations

Forest Plan S&Gs

194 (RCO 4)

Locations: all ground-based yarding system 

units.

Water Sources

- For water drafting on fish-bearing streams: do not exceed 350 gallons per minute 

for streamflow greater than or equal to 4.0 cubic feet per second (cfs); do not 

exceed 20 percent of surface flows below 4.0 cfs; and, cease drafting when 

bypass surface flow drops below 1.5 cfs. 

- For water drafting on non-fish-bearing streams: do not exceed 350 gallons per 

minute for streamflow greater than or equal to 2.0 cfs; do not exceed 50 percent of 

surface flow; and, cease drafting when bypass surface flow drops below 10 

gallons per minute.

Regional BMPs

2-5 Water Source Development and 

Utilization

2-13 Erosion Control Plans (roads and other 

activities)

National Core BMPs

WatUses-3 Administrative Water 

Developments

AqEco-2 Operations in Aquatic Ecosystems

Forest Plan S&Gs

193 (RCO 2)

194 (RCO 4)

Locations: all water drafting sites.

Servicing, Refueling, and Cleaning Equipment and Parking/Staging Areas

- Allow temporary refueling and servicing only at approved sites located outside of 

RCAs.

- Rehabilitate temporary staging, parking, and refueling/servicing areas immediately 

following use.

- A Spill Prevention and Containment and Counter Measures (SPCC) plan is 

required where total oil products on site in above-ground storage tanks exceed 

1320 gallons or where a single container exceeds 660 gallons. Review and ensure 

spill plans are up-to-date.

- Report spills and initiate appropriate clean-up action in accordance with applicable

State and Federal laws, rules and regulations. The Forest Service’s hazardous 

materials coordinator’s name and phone number shall be available to Forest 

Service personnel who administer or manage activities utilizing petroleumpowered equipment.

- Remove contaminated soil and other material from NFS lands and dispose of this 

material in a manner according to controlling regulations.

Regional BMPs

2-10 Parking and Staging Areas

2-11 Equipment Refueling and Servicing

National Core BMPs

Road-9 Parking and Staging Areas

Road-10 Equipment Refueling and Servicing

Fac-7 Vehicle and Equipment Wash Water

Forest Plan S&Gs

193 (RCO 1)

Locations: designated temporary refueling, 

servicing and cleaning sites and 

parking/staging areas.

Burn Piles

- Place burn piles a minimum of 50 feet away from perennial and intermittent 

streams and SAFs and 25 feet from ephemeral streams. Locate piles outside 

areas that may receive runoff from roads. 

- Avoid disturbance to obligate riparian vegetation. 

- Do not dozer pile in sensitive watershed areas and on areas where mastication or 

drop and lop were prescribed under the Rim Recovery Project. Grapple piling2 is 

allowed in these areas, but is subject to the mechanized equipment restrictions for 

RCAs. When grapple piling in sensitive watershed areas, consult a hydrologist or 

soil scientist if less than 70% ground cover would be retained. 

Prescribed Fire

Regional BMPs

6-2 Consideration of Water Quality in 

Formulating Fire Prescriptions

6-3 Protection of Water Quality from 

Prescribed Burning Effects

National Core BMPs

Fire-1 Wildland Fire Management Planning

Fire-2 Use of Prescribed Fire

Forest Plan S&Gs

194 (RCO 4)

Locations: all pile burning areas, sensitive 

46
Rim Fire Reforestation (45612) Chapter 2

Draft Environmental Impact Statement The Alternatives

Management Requirements BMPs/Forest Plan1/Locations

- Avoid damage to obligate riparian vegetation (e.g., willows, alders, cottonwoods).

- Do not burn over Bear Gully restoration site (contained in parts of units BB035, 

BB050, and BB036). 

- In order to maintain the wood component or temporary fences proposed under the 

Rim Fire Rehabilitation Project and the Rim Fire Habitat Improvement Project, 

coordinate with a hydrologist prior to conducting prescribed fire on the following 

units: M024, M021, M019, M016, R025, R033, I062, I063, I067, N019, T017, 

T022, S004, Y030, Y027, BB011, I131, I132, I137, M008, R041, R042, R034, 

Z011, AA001.

- Maintain a minimum of 60% ground cover within 100 feet of perennial and 

intermittent streams and 50 feet of ephemeral streams. 

- Avoid direct ignition within RCAs, including ephemeral channels; fire may back 

into the riparian area as long as ground cover is maintained.

- Avoid constructing fire lines within RCAs unless there is no alternative. Do not 

construct new dozer lines within 100 feet of perennial and intermittent streams and 

50 feet of ephemeral streams. 

- Restore constructed fire lines upon completion of prescribed burning and/or prior 

to each winter when fire lines are exposed to the potential for erosion.

- Restoration should consist of water barring hand and dozer lines, re-contouring of 

benched trails, and deep tilling of detrimentally compacted dozer lines.

- No debris or soil that might impede water flow or cause stream bank degradation 

will be placed in any stream.

- Do not bulldoze the surface within SMZs or near streams. Favor hand tools and 

equipment on steep slopes, fragile soils and in sensitive areas such as 

Streamside Management Zones.

- Install fire lines on the contour as much as possible.

watershed areas. All units that are planned for 

prescribed fire.

Water Quality Monitoring

- Conduct implementation and effectiveness monitoring using the Best 

Management Practices Evaluation Program (BMPEP) (USDA 2002) and the 

National Core Monitoring Protocols (FS-990b) (USDA 2012).

Regional BMPs

7-6 Water Quality Monitoring

Locations: Monitoring locations will be 

detailed in a project monitoring plan.

Cumulative Watershed Effects (CWE) Analysis

- CWE analysis will be conducted for the project.

Regional BMPs

7-8 Cumulative Off-Site Watershed Effects

Locations: All activities within the project 

watersheds will be analyzed

1 Forest Plan S&Gs indicate page number from Forest Plan Direction (USDA 2010a). 2 Grapple piling is a site preparation technique that uses tracked excavator type equipment with an articulating arm equipped with a clam 

type pincher head that lifts and piles brush and logs. Usually followed by jackpot burning.

2.04 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM DETAILED 

STUDY

NEPA requires that federal agencies rigorously explore and objectively evaluate all reasonable 

alternatives and briefly discuss the reasons for eliminating any alternatives that were not developed in 

detail (40 CFR 1502.14). Public comments and internal scoping suggested the alternatives described 

below along with the reasons for eliminating them from detailed study.

a. Natural Succession

This alternative, based on scoping comments, would allow the forest to recover naturally. This 

differs from “No Action” by including measures to thin existing plantations. Natural forest

recovery occurs through recruitment of new populations from adjacent seed sources rather than 

planted seedlings. It was considered but eliminated from detailed study for the following reasons: 

- It does not meet the purpose and need to restore old forest for wildlife habitat and 

connectivity. Some wildlife species rely on dense canopy closure for forage, cover, and 

nesting. This habitat would only be suitable for early-seral-stage dependent wildlife species.

- It does not meet the purpose and need to return mixed conifer forest to the landscape since 

many large areas within the burn do not have mature trees to provide a seed source for 

recruiting seedlings. 

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Chapter 2 Stanislaus

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- It does not meet the purpose and need of reducing fuels for future forest resiliency. No 

biomass would be treated and over 21,768 acres of needed fuel treatments would not occur 

with this alternative. The large amount of fuel in these areas would make future fires difficult 

to manage and contain, jeopardizing future vegetation resiliency and fire fighter safety. 

- Eradicating noxious weeds associated with the proposed reforestation units would not occur 

on over 6,227 acres. 

b. Natural Regeneration with Founder Stands

This alternative, based on scoping comments, would allow much of the forest to recover 

naturally. Outside complex early seral forest, plant founder stands: small variable-shaped areas 

less than 2 acres in size within a larger (10-acre total) area. On each of the 2 acres, plant 40 5-tree 

clusters spaced 6 feet between each tree and spaced 33 feet apart. Planting would not occur within 

1,000 feet of an established conifer. On areas where no natural regeneration occurs, between 

1,000 and 2,000 feet from established conifers, reforest 63 acres beginning 5 years after the 2013 

Rim Fire. Only 20% of the 63 acres (i.e., 13 acres) would be planted. It was considered but 

eliminated from detailed study for the following reasons:

- Very few acres were proposed for planting.

- It does not meet the purpose and need to restore old forest for wildlife habitat and 

connectivity. Some wildlife species rely on dense canopy closure for forage, cover, and 

nesting. This habitat would only be suitable for early-seral-stage dependent wildlife species.

- It does not meet the purpose and need to return mixed conifer forest to the landscape since it 

does not promote the quick reestablishment of conifers. The fewer trees planted results in 

fewer opportunities for trees to grow in the best soil and water microsite conditions. 

- The units would not meet stocking standards set by the Region. It is expected that up to 25% 

of the planted trees would die within 5 years resulting in understocked stands.

- It does not meet the Forest Plan Direction for old forest ecosystems to restore forest species 

composition and structure following large scale, stand-replacing disturbance events.

c. Natural Regeneration with Founder Standswith tighter buffers

This alternative, based on scoping comments is similar to “b” above. The only difference is the 

distance to planting areas adjacent to established cone producing conifers. Planting would not 

occur within 500 feet of established conifers. On areas between 500 and 1,000 feet from 

established conifers where no natural regeneration has occurs, reforest 20% of 866 acres (173 

acres) beginning 5 years after the 2013 Rim Fire using the founder stand guidelines. When natural 

regeneration is not occurring in areas greater than 1,000 feet from live conifer trees, reforest 

immediately to create founder stands on up to 20% of 47 acres (9 acres). It was considered but 

eliminated from detailed study for the following reasons: 

- Very few acres were proposed for planting.

- It does not meet the purpose and need to restore old forest for wildlife habitat and 

connectivity. Some wildlife species rely on dense canopy closure for forage, cover, and 

nesting. This habitat would only be suitable for early-seral-stage dependent wildlife species. 

- It does not meet the purpose and need to return mixed conifer forest to the landscape since it 

does not promote the quick reestablishment of conifers. The fewer trees planted results in less 

opportunities for trees to grow in the best soil and water microsite conditions.

- The units would not meet stocking standards set by the Region. It is expected that up to 60% 

of the trees would die within 5 years resulting in understocked stands. 

- It does not meet the Forest Plan Direction for old forest ecosystems to restore forest species 

composition and structure following large scale, stand-replacing disturbance events.

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Draft Environmental Impact Statement The Alternatives

d. Low Density Planting (Plant 40 to 100 Trees per Acre)

This alternative, based on scoping comments, would incorporate selected aspects of Alternative 1 

(Proposed Action). This alternative would plant fewer trees per acre to provide an open presettlement condition. 

- It does not meet the purpose and need to restore old forest for wildlife habitat and 

connectivity. Some wildlife species rely on dense canopy closure for forage, cover, and 

nesting. This habitat would only be suitable for early-seral-stage dependent wildlife species.

- It does not meet the purpose and need to return mixed conifer forest to the landscape since it 

does not promote the quick reestablishment of conifers. The fewer trees planted results in 

fewer opportunities for trees to grow in the best soil and water microsite conditions. 

- The units would not meet stocking standards set by the Region. It is expected that up to 25 to 

50% of the planted trees would die within 5 years resulting in understocked stands.

- It does not meet the Forest Plan Direction for old forest ecosystems to restore forest species 

composition and structure following large scale, stand-replacing disturbance events. 

e. Maximum Acres of Planting

This alternative, based on scoping comments, would plant all possible areas identified on photos 

as lacking conifers. Forest recovery occurs through recruitment of new populations from planted 

augmentation. It was considered but eliminated from detailed study for the following reasons: 

- Poor site conditions for growing conifers such as: existing meadow, poor soil, rocky sites, hot 

dry south-facing slope, steep slopes difficult to maintain, poor access, identified as an area 

that reburns frequently, fuel break locations, wilderness, near natural or Wild and Scenic 

River corridors. 

- Small existing openings with adjacent green trees are within the realm of natural variation 

and provide diversity on the landscape. 

- Already has decent stocking.

f. One Herbicide Application

This alternative, based on scoping comments, would incorporate selected aspects of Alternative 1 

(Proposed Action). Glyphosate spraying would be limited to either a single site preparation 

treatment, and then rely entirely on hand grubbing or tree growth to out-perform competition, or 

to use alternative site preparation techniques coupled with a single herbicide release treatment in 

year 1 or 2 to give the newly planted tree a boost against competition.

- It is similar to an alternative already considered in detail (Alternative 1) with effects within 

the range of the alternative already considered in detail.

g. Two Herbicide Applications

This alternative, based on scoping comments, would incorporate selected aspects of Alternative 1 

(Proposed Action). A maximum of two spray treatments would occur across every acre planted. 

This option would allow no more than one site preparation treatment and one release treatment.

- It is similar to an alternative already considered in detail (Alternative 1) with effects within 

the range of the alternative already considered in detail.

h. Spray Areas with 40% or More Bear Clover (two applications)

This alternative, based on scoping comments, would incorporate selected aspects of Alternative 1 

(Proposed Action). Glyphosate would only be applied in stands where bear clover covered 40% 

or more of each acre to be planted or 40% of the overall planting unit; and, only for both site 

preparation and a single release treatment in the year chosen by Forest staff as most essential for 

survival based on field visits for a maximum of two applications.

- It is similar to an alternative already considered in detail (Alternative 1) with effects within 

the range of the alternative already considered in detail.

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Chapter 2 Stanislaus

The Alternatives National Forest

2.05 COMPARISON OF THE ALTERNATIVES

Chapter 3 describes the environmental consequences of the alternatives. This section compares the 

alternatives by providing summary tables showing the key differences between alternatives. The 

Alternative Comparison Map (project record) displays the locations of treatments considered in all 

action alternatives. Table 2.05-1 compares the alternatives by proposed action group identified in 

Chapter 2.01. Table 2.05-2 compares the alternatives with a summary of the proposed reforestation 

treatments. Table 2.05-3 compares the alternatives with a summary of proposed fuel break and other 

key fire areas. 

Table 2.05-1 Comparison of Alternatives: Proposed Treatments

Proposed Treatments (acres) Alternative 1 

(Proposed Action)

Alternative 2 

(No Action)

Alternative 3 Alternative 4 Alternative 5

Deer habitat enhancement 3,833 0 3,833 1,164 3,833

Natural regeneration 4,031 0 4,031 22,464 0

Noxious weed eradication 5,915 0 3,350 3,350 5,915

Reforestation 21,300 0 21,300 2,867 25,331

Thin existing plantations 12,769 0 12,769 12,769 12,769

Prescribed fire only 0 0 0 34,344 0

Table 2.05-2 Comparison of Alternatives: Reforestation Treatments outside Deer Habitat Enhancement

Proposed Treatments (acres) Alternative 1 

(Proposed Action)

Alternative 2 

(No Action)

Alternative 

3

Alternative 

4

Alternative 

5

Feller buncher 3,139 0 3,139 140 3,318

Feller buncher and mastication 351 0 351 0 423

Hand cut, hand pile and burn 74 0 74 0 271

Hand cut, prescribed fire (understory and 

jackpot) 237 0 237 51 237

Machine pile and burn 912 0 912 76 925

Mastication 1,493 0 1,493 32 1,528

Total Initial Site Preparation 6,206 0 6,206 299 6,704

Deep till and forest cultivate 5,085 0 8,893 0 5,085

Manually apply herbicides (Glyphosate) 16,2151 0 0 2,867 20,246

Total Site Preparation 21,300 0 8,893 2,867 25,331

Total Plant 21,300 0 21,300 2,867 25,331

Release with grubbing 0 0 21,3002 0 0

Release with glyphosate 21,300 0 0 4,0123 25,331

Total Release 21,300 42,600 4,012 25,331

Total Prescribed Fire at Year 10 21,300 0 21,300 0 0

Total Thin New Plantations 0 0 0 0 25,3314

Additional Prescribed Fire in First Decade 17,172

1 Does not include proposed 4,031 acres of natural regeneration units that may have herbicide treatment. 2 Hand release would be required twice annually on the same acres for most competing species. 3 Release with glyphosate acreage includes treatment of the buffer adjacent to the planted areas.

4 Thin plantations where needed to create desired ICO structure and to meet fire and fuels structure goals.

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Rim Fire Reforestation (45612) Chapter 2

Draft Environmental Impact Statement The Alternatives

Table 2.05-3 Comparison of Alternatives: Fuel Breaks and Other Key Fire Areas

Landscape 

Position

Alternative 1 

(Proposed Action)

Alternative 2 

(No Action)

Alternative 3 Alternative 4 Alternative 5

Fuel Breaks 30-foot no plant strip 

centered in middle 

with 150 feet on each 

side planted with 13 

to 17-foot spaced 

conifers (176 trees 

per acre) creating a 

330 foot wide strip.

No SFMFs 

implemented. 

90 feet across bordered by 80 feet of 15-

foot by 15-foot planting on each side for a 

total width of 250 feet. Plant one row of 4-

tree micro-clusters (14 feet between 

outside trees, 7 feet to middle tree and 26 

feet between cluster centers) leaving about 

32 feet of no-plant area on each side 

before beginning 15-foot by 15-foot spaced 

planting pattern (150 trees per acre). 

Where roads are present in center of 

fuelbreak, alternate planting of 4-tree 

micro-clusters on each side of road 

beginning 12 feet off of road edge.

No Planting No SFMFs

implemented 

with initial 

planting.

Primary 

Ridges 

Within SFMA

Same as Fuel Breaks. No SFMFs

implemented. 

Same as Fuel Breaks. No Planting No SFMFs

implemented 

with initial 

planting.

Primary 

Ridges 

Outside 

SFMA

13 to 17-foot spaced 

conifers in a 250-foot 

wide strip (194 trees 

per acre).

No SFMFs

implemented. 

Same as 1. No Planting No SFMFs

implemented 

with initial 

planting.

Emergency 

Travel 

Routes

12 to 16-foot spaced 

20-tree pyramid (no 

top, Figure 2.02-2). 

Starts 12 feet from 

road and ends 68 feet 

from road (152 trees 

per acre).

No SFMFs

implemented. 

Same as 1. No Planting No SFMFs

implemented 

with initial 

planting.

SFMA=Strategic Fire Management Area; SFMF=Strategic Fire Management Feature

Table 2.05-4 provides a summary comparison of effects for selected indicators under each alternative. 

Chapter 3 includes additional details. 

Table 2.05-4 Comparison of Alternatives: Summary of Effects

Resource and 

Indicator

Alternative 1

(Proposed Action)

Alternative 2

(No Action)

Alternative 3 Alternative 4 Alternative 5

Air Quality: Smoke 

emissions from 

broadcast and machine 

pile burning

Minimal effects to 

local communities 

and Yosemite. 

Wildfire emissions 

would impact sensitive 

groups. 

Same as 1. Similar to 1, but 

more smoke from 

burning.

Same as 1.

Aquatic T&E: 

California red-legged 

frog; Sierra Nevada 

yellow-legged frog

Effects to habitat

from ground

disturbance, fire and 

herbicides. Effects to 

individuals highly 

unlikely due to 

probable absence.

No effects to 

individuals.

Similar to 1, but no 

herbicide use.

Similar to 1, but on 

fewer acres.

Similar to 1, 

but chance of 

increased 

sediment.

Aquatic Sensitive: 

Foothill Yellow-legged 

frog; Hardhead; 

Western pond turtle

Effects to habitat

and individuals from 

ground disturbance, 

fire and herbicides.

No effects to 

individuals.

Similar to 1, but 

increased 

sedimentation and 

no herbicides.

Similar to 1, but on 

fewer acres and 

reduced herbicides. 

Similar to 1, 

but chance of 

increased 

sediment.

Cultural Resources: 

Exposure and integrity 

of prehistoric and 

historic sites.

No effects due to 

following Rim PA

and limited herbicide

use in prehistoric 

sites.

Indirect effects on

fragile sites from fireweakened trees.

Similar to 1, but 

increased site prep 

may uncover 

unknown cultural 

sites.

Similar to 1, but 

reduced site prep 

and increased 

burning may impact

historic sites.

Same as 1.

Fire and Fuels: Fire 

Behavior

Reduced fire effects 

in treated areas.

Indirect effects may 

create difficult wildfire 

behavior.

Same as 1. Same as 1. Same as 1.

51
Chapter 2 Stanislaus

The Alternatives National Forest

Resource and 

Indicator

Alternative 1

(Proposed Action)

Alternative 2

(No Action)

Alternative 3 Alternative 4 Alternative 5

Fire and Fuels:

Strategic Fire 

Management Features

Beneficial effects 

from fuel breaks, 

primary ridge 

treatments and 

emergency travel 

routes.

Indirect effects may 

create difficult fire 

management.

Similar to 1, but 

slightly less 

beneficial effects.

Same as 2. Same as 1.

Invasive Species: Risk 

of Spread

Moderate High High High Moderate

Invasive Species: 

Eradication

High None Moderate Moderate High

Range: Impacts to 

range vegetation, 

administration, livestock 

movement and 

infrastructure

Short-term negative 

effects to vegetation 

and livestock 

movement. Longterm benefits from 

noxious weed

control.

Indirect effects to 

vegetation, 

administration, 

livestock movement 

and infrastructure. 

Similar to 1, but 

increased effects 

to livestock 

movement and no 

noxious weed

control benefits.

Similar to 1, but no 

noxious weed

control benefits. 

Same as 1.

Recreation: Short-term

loss of recreation 

opportunities

Short-term effects 

from herbicides;

sights and sounds of 

machinery or 

workers; closures or 

travel delays; and, 

smoke.

None Similar to 1, but 

longer impacts

from machinery or 

workers. 

Similar to 1, but 

diminished in scope.

Similar to 1, 

but with less 

smoke

impacts.

Recreation: Long-term 

loss of recreation 

opportunity

Beneficial effects

from increased

forest resiliency and 

reduced wildfire risk. 

Recreation patterns 

may shift to other 

areas.

Indirect effects from 

weeds, wildfire risk and

loss of shade in 

favorite areas. 

Similar to 1, but 

increased effects 

on dispersed use.

Same as 1 in treated 

areas. Same as 2 in 

areas not treated. 

Same as 1.

Sensitive Plants May affect 

individuals, but is not 

likely to result in a 

trend toward federal 

listing or loss of 

species viability.

Same as 1. Same as 1. Same as 1. Same as 1.

Society: Present Net 

Value (in $1,000s)

($75,134) $1,871 ($229,626) ($28,042) ($72,294)

Society: Total Jobs 

Supported (in FTEs)

2,369 0 7,764 283 2,302

Soils: Soil Stability Increased short-term 

erosion risk. High 

EHR in 14% of 

treated areas.

Lowest short-term 

erosion risk. Low to 

Moderate EHR only.

Highest short-term 

erosion risk. High 

EHR in 22% of 

treated areas.

Similar to 2, but 

slightly higher 

erosion risk. High 

EHR in 2% of 

treated areas.

Similar to 1, 

but slightly 

higher 

erosion risk.

Soils: Surface Organic 

Matter and Soil Organic 

Matter (SOM)

Reduced surface 

organic matter. 

Short-term increase 

and possible longterm decrease in 

SOM.

None Similar to 1, but 

most reduction in 

surface organic

matter. 

Similar to 1, but 

least reduction in 

surface organic 

matter (best cover)

and least impact to 

SOM.

Similar to 1, 

but more 

surface 

organic 

matter. 

Special Areas: 

Wilderness Character

Short-term effects

from drift smoke and 

sights and sounds of 

machinery or 

workers near 

Wilderness 

boundary.

None Same as 1. Similar to 1, but 

more smoke

impacts. 

Similar to 1, 

but less 

smoke

impacts.

Vegetation: Average 

conifer DBH at year 20 

(inches)

4.3 1.7 2.8 1.9 4.3

Vegetation: Average 

conifer height at year 20 

(feet)

23.2 12.4 16.3 13.1 23.6

52
Rim Fire Reforestation (45612) Chapter 2

Draft Environmental Impact Statement The Alternatives

Resource and 

Indicator

Alternative 1

(Proposed Action)

Alternative 2

(No Action)

Alternative 3 Alternative 4 Alternative 5

Vegetation: Future 

potential timber yield 

(million board feet)

163 42 48 42 160

Watershed: Erosion 

and Sedimentation 

(Thinning and Site 

Preparation Activities)

Creation of sediment 

transport networks. 

No new sediment 

transport networks 

created; hydrological 

and erosional 

responses to the Rim 

Fire would still occur; 

existing skid trail 

sediment transport 

networks remain.

Slight increase in 

ground 

disturbance and 

the potential of 

erosion and 

sediment delivery 

to streams 1. 

Dramatic reduction 

in the creation of 

effective sediment 

transport networks. 

Much less potential 

for erosion and 

sedimentation than 

1. 

Same as 1.

Watershed: Riparian 

Vegetation

Slight beneficial 

effects to riparian 

obligate species, 

SAFs and meadows.

No disturbance to

riparian species. 

Indirect effects from 

lack of sunlight and 

weed control.

Similar to 1, but 

less weed control.

Same as 3. Same as 1.

Watershed: Stream 

Condition

Beneficial effects 

from restoration

improving hillslope 

and riparian 

functions.

Indirect effects from 

continued loss of 

hillslope and riparian 

functions.

Same as 1. Similar to 1, but on 

fewer acres. 

Same as 1.

Watershed: Water 

Quality (Beneficial Uses 

of Water)

No effects to water 

temperature or 

beneficial uses. 

Beneficial effects 

from accelerated 

return to conifer 

forest. Low potential 

for herbicides to 

contaminate water.

None Similar to 1, but no 

herbicides.

Similar to 1, but less 

return to conifer 

forest and 

herbicides. 

Same as 1.

Wildlife T&E: Valley 

elderberry longhorn 

beetle

May affect but is not 

likely to adversely 

affect; will not affect 

Designated Critical 

Habitat.

Same as 1. Same as 1. Same as 1. Same as 1.

Wildlife Proposed 

T&E: Fisher

May affect but is not 

likely to jeopardize 

continued existence.

Same as 1. Same as 1. Same as 1. Same as 1.

Wildlife Sensitive: 

Bald eagle; California 

spotted owl; Great gray 

owl; Northern goshawk; 

Pacific marten; Pallid 

bat, fringed myotis, and 

Townsend’s big-eared 

bat; Western Bumble 

Bee

May affect 

individuals but is not 

likely to result in a 

trend toward federal 

listing or loss of 

viability. 

Same as 1. Same as 1. Same as 1. Same as 1.

Wildlife: Black-backed 

woodpecker

Retains 76 percent 

of modeled pairs.

Retains 100 percent of 

modeled pairs.

Same as 1. Same as 2. Same as 1.

Wildlife: Mule deer Improves 7,000 

acres of critical 

winter deer range.

No improved critical 

winter deer range. 

Same as 1. Improves 3,200 

acres of critical 

winter deer range.

Same as 1.

53
Chapter 2 Stanislaus

The Alternatives National Forest

54
Rim Fire Reforestation (45612) Affected Environment

Draft Environmental Impact Statement and Environmental Consequences

3. Affected Environment and Environmental 

Consequences

3.01 INTRODUCTION

Chapter 3 summarizes the physical, biological, social, and economic environments that are affected 

by the proposed action and alternatives and the effects on that environment that would result from 

implementation of the alternatives considered in detail. This Chapter also presents the scientific and 

analytical basis for the comparison of alternatives presented in Chapter 2.

The “Affected Environment” section under each Chapter 3 resource section describes the existing 

condition against which environmental effects were evaluated and from which progress toward the 

desired condition can be measured. Environmental consequences form the scientific and analytical 

basis for comparison of alternatives, including the proposed action, through compliance with 

standards set forth in the Stanislaus National Forest Land and Resource Management Plan, as 

amended (Forest Plan). The environmental consequences discussion centers on direct, indirect and 

cumulative effects, along with applicable mitigation measures. Effects can be neutral, beneficial or 

adverse while the determination of significance is based on the context and intensity factors identified 

in Council on Environmental Quality (CEQ) NEPA regulations (40 CFR 1508.27). The “Irreversible 

and Irretrievable Commitments of Resources” section (Chapter 3.19) is located at the end of this 

Chapter. These terms are defined as follows:

 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, or further removed in distance, but 

are still reasonably foreseeable.

 Cumulative effects are those that result from the incremental impact of the action when added to 

other past, present, and reasonably foreseeable future actions. 

Analysis Process

The environmental consequences presented in Chapter 3 address the impacts of the actions proposed 

under each alternative. The effects analysis was done at the project scale (the scale of the proposed 

action as discussed in Chapter 1). However, the effects findings in this Chapter are based on sitespecific analyses. Each resource specialist assessed every alternative at a level sufficient to support 

their effects analysis and identify any necessary site-specific mitigation. Most resources considered 

the short-term temporal analysis bounds to generally be the life of the active projects, about five to 

ten years. Beyond that time frame are the long-term effects. The resource reports (project record) 

contain additional details about the analysis process.

Cumulative Effects

According to the CEQ NEPA regulations, “cumulative impact” is the impact on the environment 

which results from the incremental impact of the action when added to other past, present, and 

reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person 

undertakes such actions (40 CFR 1508.7). The cumulative effects analysis area is described under 

each resource, but in most cases includes all NFS, private and other public lands that lie within the 

Rim Fire perimeter. Past activities are considered part of the existing condition and are discussed in 

the “Affected Environment (Existing Conditions)” and “Environmental Consequences” sections 

under each resource.

55
Chapter 3.01 Stanislaus

Introduction National Forest

In order to understand the contribution of past actions to the cumulative effects of the alternatives, 

this analysis relies on current environmental conditions as a proxy for the impacts of past actions. 

Existing conditions reflect the aggregate impact of all prior human actions and natural events that 

affected the environment and might contribute to cumulative effects. This cumulative effects analysis 

does not attempt to quantify the effects of past human actions by adding up all prior actions on an 

action-by-action basis for three reasons:

 First, a catalog and analysis of all past actions is impractical to compile and unduly costly to 

obtain. Innumerable actions over the last century (and beyond) impacted current conditions and 

trying to isolate the individual actions with residual impacts would be nearly impossible.

 Second, providing details of past actions on an individual basis would not be useful to predict the 

cumulative effects of the alternatives. In fact, focusing on individual actions would be less 

accurate than looking at existing conditions, because information on the impacts of individual 

past actions is limited and one cannot reasonably identify every action over the last century that 

contributed to current conditions. Focusing on impacts of past human actions risks ignoring the 

important residual effects of past natural events which may contribute to cumulative effects as 

much as human actions. Looking at current conditions captures all residual effects of past human 

actions and natural events, regardless of which particular action or event contributed to effects.

 Finally, the CEQ issued an interpretive memorandum on June 24, 2005 regarding analysis of past 

actions, which states, “agencies can conduct an adequate cumulative effects analysis by focusing 

on the current aggregate effects of past actions without delving into the historical details of 

individual past actions” (CEQ 2005). 

The cumulative effects analysis is consistent with Forest Service NEPA regulations (73 Federal 

Register 143, July 24, 2008; p. 43084-43099), which state, in part: 

“CEQ regulations do not require the consideration of the individual effects of all past actions to 

determine the present effects of past actions. Once the agency has identified those present effects 

of past actions that warrant consideration, the agency assesses the extent that the effects of the 

proposal for agency action or its alternatives will add to, modify, or mitigate those effects. The 

final analysis documents an agency assessment of the cumulative effects of the actions considered 

(including past, present, and reasonable foreseeable future actions) on the affected environment. 

With respect to past actions, during the scoping process and subsequent preparation of the 

analysis, the agency must determine what information regarding past actions is useful and relevant 

to the required analysis of cumulative effects. Cataloging past actions and specific information 

about the direct and indirect effects of their design and implementation could in some contexts be 

useful to predict the cumulative effects of the proposal. The CEQ regulations, however, do not 

require agencies to catalogue or exhaustively list and analyze all individual past actions. Simply 

because information about past actions may be available or obtained with reasonable effort does 

not mean that it is relevant and necessary to inform decision making. (40 CFR 1508.7)”

For these reasons, the analysis of past actions in Chapter 3 is based on current environmental 

conditions. Appendix B (Cumulative Effects Analysis) lists present and reasonably foreseeable future 

actions potentially contributing to cumulative effects.

Forest Plan Direction

The Forest Service completed the Stanislaus National Forest Land and Resource Management Plan 

(Forest Plan) on October 28, 1991. The “Forest Plan Direction” (USDA 2010a) presents the current 

Forest Plan management direction, based on the original Forest Plan, as amended. The Forest Plan 

identifies land allocations and management areas within the project area including: Wild and Scenic 

Rivers and Proposed Wild and Scenic Rivers; Critical Aquatic Refuge (CAR); Riparian Conservation 

Areas (RCAs); Near Natural; Scenic Corridor; Special Interest Areas; Wildland Urban Intermix; 

Protected Activity Centers (PACs); Old Forest Emphasis Areas; and, Developed Recreation Sites.

The Forest Plan Compliance (project record) document identifies the Forest Plan Standards and 

Guidelines that specifically apply to this project and related information about compliance with the 

Forest Plan. 

56
Rim Fire Reforestation (45612) Affected Environment

Draft Environmental Impact Statement and Environmental Consequences

Incomplete or Unavailable Information

CEQ regulations for implementing NEPA describe how Federal agencies must handle instances 

where information relevant to evaluating “reasonably foreseeable” 4 adverse impacts of the 

alternatives is incomplete or unavailable. According to 40 CFR 1502.22: 

When an agency is evaluating reasonably foreseeable significant adverse effects on the human 

environment in an EIS and there is incomplete or unavailable information, the agency shall always 

make clear that such information is lacking.

a. If the incomplete information relevant to reasonably foreseeable significant adverse impacts is 

essential to a reasoned choice among alternatives and the overall costs of obtaining it are not 

exorbitant, the agency shall include the information in the EIS.

b. If the information relevant to reasonably foreseeable significant adverse impacts cannot be 

obtained because the overall costs of obtaining it are exorbitant or the means to obtain it are 

not known, the agency shall include within the EIS:

1. A statement that such information is incomplete or unavailable;

2. A statement of the relevance of the incomplete or unavailable information to evaluating 

reasonably foreseeable significant adverse impacts on the human environment;

3. A summary of existing credible scientific evidence which is relevant to evaluating the 

reasonably foreseeable significant adverse impacts on the human environment; and,

4. The agency’s evaluation of such impacts based upon theoretical approaches or research 

methods generally accepted in the scientific community.

Chapter 3 identifies incomplete or unavailable information so the reader understands how they are 

addressed. The EIS summarizes existing credible scientific evidence relative to environmental effects 

and makes estimates of effects on theoretical approaches or research methods generally accepted in 

the scientific community. 

Resource Reports

The resource sections in this Chapter provide a summary of these project-specific reports and other 

documents (project record); they are available by request and are incorporated by reference.

 Aquatic Species: Biological Assessment for Threatened and Endangered Species for Aquatic 

Species and Terrestrial Wildlife for US Fish and Wildlife Service review of proposed action (see 

wildlife); Aquatic Biological Assessment and Biological Evaluation (Aquatic BA and BE); 

Aquatic Management Indicator Species Report (Aquatic MIS Report); and, Fisheries Report.

 Cultural Resources: Cultural Resources Report

 Fire and Fuels: Fuels Report including Air Quality

 Invasive Species: Noxious Weed Risk Assessment (NWRA)

 Range: Rangeland Specialist Report (Range Report)

 Recreation: Recreation Report 

 Sensitive Plants: Botanical Resources Report (Botany Report); and, Biological Evaluation for 

Sensitive Plants (Sensitive Plants BE)

 Soils: Soils Report

 Vegetation: Forest Vegetation Report

 Watershed: Watershed Management Report including cumulative watershed effects (Watershed 

Report); Watershed Monitoring Plan; and, Erosion Control Plan

 Wildlife: Terrestrial Biological Assessment, Biological Evaluation and Wildlife Report 

(Terrestrial BE); Terrestrial Wildlife Management Indicator Species Report (Wildlife MIS 

Report); and, Migratory Landbird Conservation Report 

4 For the purposes of this rule, CEQ states: ‘‘reasonably foreseeable’’ includes impacts which have catastrophic consequences, even if 

their probability of occurrence is low, provided that the analysis of the impacts is supported by credible scientific evidence, is not based on 

pure conjecture, and is within the rule of reason (40 CFR 1502.22). 

57

 
Chapter 3.01 Stanislaus

Introduction National Forest

Affected Environment Overview

All resources share many aspects of the affected environment. To avoid repetition in each resource 

section, the following general elements of the affected environment are provided. The 400-squaremile Rim Fire encompasses a diverse and complex landscape. Landforms within the Rim Fire area are 

dramatic, punctuated by river canyons, glaciation, a lava cap and large expanses of gentle to 

moderately steep slopes. Geology is varied and includes all three of the principal geologic types in the 

Sierra Nevada mountain range. Metamorphic rock occupies much of the lower elevations and the 

Sierra granitic batholith and relic volcanic flows generally occur at higher elevations. The watersheds, 

rising in elevation from about 2,000 to 7,000 feet, include rock-rimmed river canyons, mountain 

meadows, major rivers and small secluded streams. Oak grasslands occur at the lowest elevations, 

with large expanses of mixed conifer forests at mid-elevation and even some red fir-lodgepole pine 

stands growing at the highest elevations. Cottonwoods and quaking aspens occupy occasional 

streamside and meadow sites at mid-to-high elevations. As in many areas of the Sierra Nevada, the 

landscape was heavily influenced over the last 150 years by past management activities including; 

mining, grazing, fire exclusion, large high-severity fires and drought. Railroad logging also occurred 

throughout the area and almost all of the burned forest consists of second growth trees. 

The Rim Fire area lies within a Mediterranean climate zone consisting of warm, mostly dry summers 

and cool, wet winters. Average summer high temperatures are about 95 degrees Fahrenheit at the 

lowest elevations and 75 degrees Fahrenheit at higher elevations. Average low winter temperatures 

are about 30 to 20 degrees Fahrenheit at the lowest and highest elevations respectively. Extreme high 

and low temperatures vary about 10 to 15 degrees from average. Precipitation increases in elevation, 

with a range of about 30 to 50 inches per year across the fire area.

The Rim Fire, like almost all wildfires, burned in a mosaic pattern of high, moderate and low soil 

burn severity with some unburned areas within its perimeter. While the Rim Fire is the largest fire to 

ever occur on the Stanislaus National Forest, the soil burn severity was relatively low. The high soil 

burn severity is the second lowest of the principal fires within its perimeter that occurred since 1973. 

Of the 154,530 acres burned on NFS land, 7% (10,000 acres) resulted in high soil burn severity 

leaving very little ground cover (0 to 20%) distributed in various sized patches. Ground cover in the 

moderate soil burn severity areas was also substantially reduced as nearly all trees were killed by the 

fire. Post fire, cover exists on about 56% of the area (the total of the low soil burn severity and the 

unburned portion within the fire perimeter). This cover consists of living vegetation which primarily 

includes conifer trees with forest floor litter and duff, plus brush and smaller woody shrubs. 

The Rim Fire burned through numerous watersheds which are an important component of the water 

supply, fish and wildlife habitat, recreation, timber production and other values of the Sierra Nevada. 

Portions of these watersheds previously burned in several fires during the last century, while some 

areas have not burned in over 100 years. About 98% of the Rim Fire burned within the Tuolumne 

River watershed. The remaining 2% burned in the North Fork Merced River watershed along the 

southern edge of the fire. The Rim Fire burned less severely near streams than in the uplands in 

almost all watersheds, and substantially less in many. And though it burned less in these locations 

there was still a notable loss of the stream shade capacity of conifers and riparian obligate trees and. 

While it may take conifers decades to return and once again provide shade, the riparian trees will fill 

the void in the short-term and also provide biodiversity along stream reaches burned in the Rim Fire. 

Road density in the area ranges from one to six miles of road per square mile, with an average of 

about 4 miles, similar to other roaded areas of the forest. Road sediment discharge increases are 

expected as a result of the Rim Fire. Most increases are likely to occur in high soil burn severity 

areas, and to a lesser extent in moderate soil burn severity areas. Problems include locations of 

improper road drainage function and culvert issues at road-stream crossings. The undersized culverts 

cannot handle post-fire flow volume and the additional woody debris and sediment it carries. 

58
Rim Fire Reforestation (45612) Affected Environment

Draft Environmental Impact Statement and Environmental Consequences

Information on Other Resource Issues

The alternatives considered in detail do not affect the following resources or localized effects are 

disclosed under other resources; they are not further discussed in Chapter 3. 

Climate Change

The following elements of global climate change are known with near certainty (IPCC 2014): 

1. Human activities associated with economic and population growth are changing the composition 

of the Earth’s atmosphere. Increasing levels of greenhouse gases, like carbon dioxide (CO2) in 

the atmosphere since pre-industrial times, are well-documented and understood. 

2. The continued emission and atmospheric buildup of CO2 and other greenhouse gases is largely 

the result of human activities such as the burning of fossil fuels.

3. An “unequivocal” warming trend of about 1.0 degrees to 1.7 degrees Fahrenheit occurred from 

1906-2005. Warming occurred in both the Northern and Southern Hemispheres and throughout 

the oceans. The amounts of snow and ice declined. The warmest 30-year period in the Northern 

Hemisphere over the past 1400 years was likely from 1983 to 2012. 

4. The major greenhouse gases emitted by human activities remain in the atmosphere for periods 

ranging from decades to centuries. It is virtually certain that atmospheric concentrations of 

greenhouse gases will continue to rise over the next few decades.

5. Unprecedented increases in greenhouse gas concentrations are the dominant cause of a warming 

global climate.

The following are known climate trends derived from data collected over the last century and future 

climate predictions applicable to the Stanislaus National Forest (Meyer and Safford 2010): 

1. Most of the Stanislaus National Forest experienced increases in temperature of 1.8 oF or more 

over the last 75 years.

2. The occurrence of nighttime freezing temperatures decreased over the last century, likely 

contributing to trends of declining snowpack, snowpack longevity and snow water equivalents. 

3. Precipitation across the Stanislaus National Forest varied over the last century.

4. The form of precipitation is likely changing from winter snowfall, persistent snowpack and 

snowpack melt to wetter winter snow, earlier snowpack ripening and runoff. 

5. Summers are predicted to be drier than they are currently, regardless of annual precipitation.

6. There is broad consensus warming is predicted for California.

7. Wildfire activity, size and severity increased since the 1980s and this trend is expected to 

continue in the Sierra Nevada.

According to IPCC (2014), it is uncertain how much warming will occur, how fast that warming will 

occur, and how the warming will affect the rest of the climate system including precipitation patterns. 

Given what is known and what is not known about global climate change, the following discussion 

outlines the cumulative effects of this project on greenhouse gas emissions and the effects of climate 

change on forest resources. 

Carbon Dioxide (CO2), Methane (CH4) and Nitrous Oxide (N20) emissions generated by project 

activities are expected to contribute to the global concentration of greenhouse gases that affect

climate change. Projected climate change impacts include air temperature increases, sea level rise, 

changes in the timing, location, and quantity of precipitation, and increased frequency of extreme 

weather events such as heat waves, droughts, and floods. The intensity and severity of these effects 

are expected to vary regionally and even locally, making any discussion of potential site-specific 

effects of global climate change on forest resources speculative.

Because greenhouse gases from project activities mix readily into the global pool of greenhouse 

gases, it is not currently possible to discern the effects of this project from the effects of all other 

59
Chapter 3.01 Stanislaus

Introduction National Forest

greenhouse gas sources worldwide, nor is it expected that attempting to do so would provide a 

practical or meaningful analysis of project effects. Potential regional and local variability in climate 

change effects add to the uncertainty regarding the actual intensity of this project’s effects on global 

climate change. Further, emissions associated with this project are extremely small in the global 

atmospheric CO2 context, making it impossible to measure the incremental cumulative impact on 

global climate from emissions associated with this project.

In summary, the potential for cumulative effects is considered negligible for all alternatives because 

none of the alternatives would result in measurable direct and indirect effects on air quality, 

atmospheric greenhouse gas composition or global climatic patterns.

Inventoried Roadless Areas

The Forest Service Land Management Planning FSH 1909.12, Chapter 70 (Wilderness Evaluation) 

provides direction for inventory of all lands that may be suitable for inclusion in the National 

Wilderness Preservation System including areas identified in the Forest Service Roadless Area

Conservation Final EIS (Volume 2, November 2000). It includes direction to comprehensively 

evaluate the wilderness characteristics (natural; undeveloped; outstanding opportunities for solitude 

or a primitive and unconfined type of recreation; special features; and, manageability) of each 

roadless area pursuant to criteria set forth in the Wilderness Act of 1964. 

The Department of Agriculture, Forest Service adopted the Roadless Area Conservation Rule in 2001 

with the purpose “to establish prohibitions on road construction, road reconstruction, and timber 

harvesting in inventoried roadless areas on National Forest System lands. The intent of this final rule 

is to provide lasting protection for inventoried roadless areas within the National Forest System in the 

context of multiple-use management.” (66 Federal Register 9, January 12, 2001; p. 3244). As a result, 

the Agency established a national level rule for the management of roadless areas. Within this rule, 

the cutting, sale, or removal of trees must be clearly shown through project level analysis to 

contribute to the ecological objectives described in the Rule or under certain other circumstances. 

Such management activities are expected to be rare and to focus on small diameter trees. Thinning of 

small diameter trees, for example, that became established as the result of missed fire return intervals 

due to fire suppression and the condition of which greatly increases the likelihood of uncharacteristic 

wildfire effects would be permissible.

All or portions of three Inventoried Roadless Areas (IRAs) are located on NFS lands within the Rim 

Fire perimeter: 1) the Cherry Lake IRA (1,000 acres) in the east-central portion of the Forest adjacent 

to the Emigrant Wilderness and Yosemite National Park; 2) the North Mountain IRA (8,100 acres) in 

the southeast part of the Forest adjacent to Yosemite National Park; and, 3) the Tuolumne River IRA 

(17,300 acres) in the southwest part of the Forest containing the lower Clavey River and about 18 

miles of the Tuolumne Wild and Scenic River (USDA 2014). The alternatives considered in detail do 

not include any activities within or adjacent to these IRAs. Nearby short-term project induced noise is 

consistent with the Roadless Area Characteristics5 identified in the 2001 Roadless Rule. Therefore, 

the alternatives are not likely to result in direct, indirect or cumulative effects on those characteristics. 

The alternatives would have no perceivable impact on the existing manageability value of the 

roadless lands in the analysis area. No new permanent roads are proposed that would complicate 

potential Wilderness boundary management. 

5 Roadless Area characteristics are: high quality or undisturbed soil, water, and air; sources of public drinking water; diversity of plants

and animal communities; habitat for threatened, endangered, proposed, candidate, and sensitive species, and for those species 

dependent on large, undisturbed areas of land; primitive, semi-primitive non-motorized and semi-primitive motorized classes of dispersed 

recreation; reference landscapes; natural appearing landscapes with high scenic quality; traditional cultural properties and sacred sites; 

and, other locally identified unique characteristics. (66 Federal Register 9, January 12, 2001; p. 3272).

60

 
Rim Fire Reforestation (45612) Affected Environment

Draft Environmental Impact Statement and Environmental Consequences

Transportation

The Stanislaus National Forest transportation system within the Rim Fire area is made up of 707.1 

miles of National Forest System roads and 18.2 miles of National Forest System motorized trails 

(USDA 2014). Many of these roads and trails are designated as open to public motorized traffic, for 

access to particular destinations or for motorized recreation. The Forest Motor Vehicle Use Map and 

the Stanislaus National Forest Infra database display those designations. Many roads were improved 

during the timber sales to log trees burned in the Rim Fire.

No long-term changes to public motor vehicle use are proposed under this project. Previously 

designated routes documented on the Motor Vehicle Use Map will remain open following project 

implementation. Actions that may contribute to effects include: biomass removal and Forest Service 

administrative activities such as bringing in equipment to perform initial site preparation or fuels 

treatments.

Conditions: Forest transportation system conditions change with weather and use patterns. Many of 

the roads used to access this reforestation and noxious weed project were utilized during the recent 

salvage sales and the roads were improved at that time. Although no road work or infrastructure 

improvements are proposed in this project, ongoing routine maintenance is expected to occur. Surface 

deterioration proportionate to the traffic volume will occur on those main roads. This effect is 

expected to be minor and dispersed through location. 

Traffic: During implementation, traffic will increase due to movement of equipment, forest products, 

contractor vehicles, and Forest Service personnel in and out of the project area. This effect is 

expected to be minor and dispersed through time and location. 

Health and Safety: Although most roadside hazard trees were removed during implementation of 

the Rim Recovery project and Rim HT project, additional trees may die and create a hazard along 

NFS roads. Cutting of hazard trees is a Forest administrative activity that would occur as needed.

In summary, the potential for cumulative effects is considered negligible for all alternatives because 

none of the alternatives would result in measurable direct and indirect effects on transportation 

resources. 

Yosemite National Park

The Stanislaus National Forest shares a common boundary, much of which is Wilderness, with 

Yosemite National Park to the east. The National Park Service manages park resources and values to 

leave them unimpaired for the enjoyment of future generations. The alternatives considered in detail 

will not directly affect park resources. Action alternatives will increase worker and public safety and 

improve Forest Service ability to manage future fires, which may indirectly benefit park resources 

and values. Wildlife habitat improvement activities may benefit Yosemite National Park wildlife 

populations by providing corridors for wildlife movement on the Stanislaus National Forest. 

Analysis Framework

NEPA at 40 CFR 1502.25(a) directs “to the fullest extent possible, agencies shall prepare draft 

environmental impact statements concurrently with and integrated with ...other environmental review 

laws and executive orders.” Each following Chapter 3 resource section lists the applicable laws, 

regulations, policies and Executive Orders relevant to that resource. The resource reports (project 

record) include the surveys, analyses and findings required by those laws.

61
Chapter 3.01 Stanislaus

Introduction National Forest

CEQA and NEPACompliance

NEPA requires agencies to assess the environmental effects of a proposed agency action and any 

reasonable alternatives before making a decision on whether, and if so, how to proceed. The 

California Environmental Quality Act (CEQA) applies to projects of all California state, regional or 

local agencies, but not to Federal agencies. Its purposes are similar to NEPA. They include ensuring 

informed governmental decisions, identifying ways to avoid or reduce environmental damage through 

feasible mitigation or project alternatives, and providing for public disclosure (CEQA Guidelines, 

15002, subd. (a)(1)-(4)).

The CEQ regulations for implementing NEPA encourage cooperation with state and local agencies in 

an effort to reduce duplication in the NEPA process (40 CFR 1506.2). The CEQ regulations further 

provide agencies with the ability to combine documents, by stating that “any environmental document 

in compliance with NEPA may be combined with any other agency document to reduce duplication 

and paperwork” (40 CFR 1506.4). Furthermore, if an existing document cannot be utilized, portions 

may be incorporated by reference. Like NEPA, CEQA encourages cooperation with Federal agencies 

to reduce duplication in the CEQA process. In fact, CEQA recommends that lead agencies rely on a 

Federal EIS “whenever possible,” so long as the EIS satisfies the requirements of CEQA (Cal. Pub. 

Resources Code, 21083.7). 

Overall, the resource analysis contained in this EIS meets CEQA requirements; however, the 

following information is provided since this document uses terminology not commonly used in 

CEQA and vice versa:

 Management Requirements: Chapter 2 lists management requirements. The action alternatives 

include management requirements designed to implement the Forest Plan and to minimize or 

avoid potential adverse impacts. Each action alternative lists the management requirements 

specific to it and Chapter 2.03 identifies those common to all action alternatives. Management 

requirements are mandatory components of each alternative and will be implemented as part of 

the proposed activities.

 Green House Gas Emissions: Chapter 3.01 (Climate Change) and Chapter 3.02 (Air Quality) 

describe and evaluate greenhouse gas emissions.

 Growth Inducing Impacts and Energy Impacts: Chapter 3.10 (Society, Culture and Economy) 

describes population growth and evaluates economic growth inducing impacts. No population 

growth inducing impacts are expected since NFS lands are not available for urbanization.

62
Rim Fire Reforestation (45612) Affected Environment

Draft Environmental Impact Statement and Environmental Consequences

3.02 AIR QUALITY

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction

The Federal Clean Air Act (CAA) of 1963, as amended in 1990, is the basis for national control of 

air pollution. The CAA was designed to “protect and enhance” the quality of the nation’s air 

resources. Basic elements of the CAA include national ambient air quality standards (NAAQS) for 

criteria air pollutants, technology based emission control standards for hazardous air pollutants, state 

attainment plans, a comprehensive approach to reducing motor vehicle emissions, control standards 

and permit requirements for stationary air pollution sources, acid rain control measures, stratospheric 

ozone protection, and enforcement provisions. 

The California Clean Air Act of 1988 provides the basis for air quality planning and regulation in 

California independent of federal regulations and establishes ambient air quality standards for the 

same criteria pollutants as the federal clean air legislation. Under the federal CAA, States can adopt 

air quality standards that are more stringent than the federal NAAQS. California adopted standards 

for criteria pollutants that are generally more restrictive than the federal standards. The California Air 

Resources Board (CARB) is the agency responsible for establishing California ambient air quality 

standards (CAAQS).

The Calaveras, Tuolumne and Mariposa County Air Pollution Control Districts (APCD) are 

responsible for implementing and regulating air quality programs in the Stanislaus National Forest.

The Forest Plan Compliance (project record) document identifies the Forest Plan Standards and 

Guidelines that specifically apply to this project and related information about compliance with the 

Forest Plan.

Air Quality Management Practices

Smoke from prescribed fire is managed so that emissions meet applicable state and federal standards. 

Prescribed fires are regulated and authorized by the local Air Pollution Control District (APCD) and 

the California Air Resources Board (CARB) under the process established by the California Smoke 

Management Program (Title 17). The legal basis of the program is found in the Smoke Management 

Guidelines for Agricultural and Prescribed Burning adopted by the CARB on March 23, 2001 (CARB 

2001). The Guidelines provide the framework for State and local air district regulators to conduct the 

program. Elements of the program include: 

 Registering and Permitting of Agricultural and Prescribed Burns 

 Meteorological and Smoke Management Forecasting

 Daily Burn Authorization 

 Enforcement 

The 1990 Clean Air Act (CAA) amendments and the 1998 EPA Interim Policy on Wildland and 

Prescribed Fire form the federal requirements and guidance behind the California program (Ahuja et 

al. 2006). Burn days are allocated by the responsible air quality regulatory agency when dispersion 

conditions are most likely to prevent exposure to unhealthy smoke concentrations. Allocations are 

considered on a cumulative potential for the air basin by regulatory review of a unified reporting 

system, the Prescribed Fire Information Reporting System (PFIRS), maintained by the CARB (CARB 

2012). The reporting system and a daily conference call between regulatory meteorologists, resource 

agency meteorologists, and resource agency fire managers allow for a daily discussion of ongoing 

events, smoke dispersion, allocations, and burn approval outlook. The objective of this system is to 

facilitate fuel treatment and minimize smoke exposure to the public. 

63
Chapter 3.02 Stanislaus

Air Quality National Forest

In the spring of 2011, staff of the CARB, Federal and State Land Management Agencies, and Air 

Districts in California worked together to revise the policy that governs the management of naturally 

ignited fires. The protocol, entitled “Coordination and Communication Protocol for Naturally Ignited 

Fires” (CARB 2011), establishes a framework from which smoke and emission impacts from 

wildfires would be minimized through fire suppression techniques and improved public awareness.

 The Forest Service utilizes Best Available Control Measures (BACMs) and Best Smoke 

Management Practices (BSMPS) to reduce particulate emissions (NRCS 2011). BACMs are a 

combination of practices intended to reduce emissions to the lowest practicable amount. BACMs 

are accomplished by diluting or dispersing emissions, or by preventing potential emission sources 

whenever possible. Examples of BACMs include: Reducing pollutants by limiting the mass of 

material burned, burning under moist fuel conditions when broadcast burning, shortening the 

smoldering combustion period, and increasing combustion efficiency by encouraging the flaming 

stage of fire when burning piles.

 Diluting pollutant concentrations over time by reducing the rate of release of emissions per unit 

area, burning during optimum conditions, and coordinating daily and seasonally with other 

burning permittees in the area to prevent standard exceedances. 

Effects Analysis Methodology

Smoke emissions were calculated for machine pile burning, jackpot burning, understory burning and 

wildfires. Greenhouse gas emissions were calculated.

Assumptions Specific to Air Quality

 Emissions were calculated using the formula [Ei (tons) equals (A multiplied by FL multiplied by 

percent C multiplied by EFi) all divided by 2000 to convert pounds to tons]; where: 

- Ei equals Emissions in tons for the emission type (e.g. PM2.5 or NOx or CH4);

- A equals Area in acres; 

- FL equals Fuel Loading in tons per acre; 

- percent C equals percent fuel consumed; and,

- EFi equals Emission factor for the type (in pounds per ton of dry fuel consumed).

 Percent combustion under pile burning is 100%.

 Percent combustion under jackpot burning is 50%.

 Percent combustion with understory burn is 50%. 

 Jackpot burns are similar to understory burns.

 EFs for pile, understory burns and jackpot burns were derived from Hardy et al. 2001: PM10

equals (12.4, 25), PM2.5 equals (10.8, 22), CH4 equals (11.4, 8.2), NMHC equals (8, 6.4), CO

equals (153, 178), CO2 equals (3271, 3202), NOx equals(6, 6), SOx equals (2.4, .2.4).

 GWP (Global Warming Potential) factor for greenhouse gas conversion to CO2 equivalent metric 

tons from IPCC 2007. 

 Wildfire emissions were based on a wildfire burning under 90th percentile weather conditions at 

year 20 for all scenarios.

Data Sources

 First Order Fire Effects Monitoring Program

 CARB (2010) 

 EPA (2012) 

 Inciweb (2013) 

 IPCC (2007) 

 Placer County Air Pollution Control District (2008) and Executive Office et al. (2008) 

 Springsteen et al. (2011)

 Tarnay (2014) 

64
Rim Fire Reforestation (45612) Affected Environment

Draft Environmental Impact Statement and Environmental Consequences

Air Quality Indicators

The Clean Air Act lists 189 hazardous air pollutants to be regulated. Some components of smoke, 

such as polycyclic aromatic hydrocarbons (PAH) are known to be carcinogenic. Probably the most 

carcinogenic component is benzo(a)pyrene (BaP). Other components, such as aldehydes, are acute 

irritants. In 1994 and 1997, 18 air toxins were assessed relative to the exposure of humans to smoke 

from prescribed and wildfires. The following seven pollutants are most commonly found in smoke 

from fire:

 Particulate Matter (PM2.5 and PM10 a criteria pollutant): Particulates are the most prevalent air 

pollutant from fires and are of the most concern to regulators. Research indicates a correlation 

between hospitalizations for respiratory problems and high concentrations of fine particulates. 

PM2.5 are fine particles that are 2.5 microns in diameter or less in size. PM10 are fine particles that 

are between 10 and 2.5 microns in diameter or less in size. Particulates can include carcinogens 

and other toxic compounds. Overexposure to particulates can cause irritation of mucous 

membranes, decreased lung capacity and impaired lung function. 

 Methane (CH4): Methane is an odorless, colorless flammable gas. Short-term exposure to 

methane may result in feeling tired, dizziness and headache. No long-term health effects are 

currently associated with exposure to methane. Methane is a greenhouse gas (GHG) and 

contributes to global climate warming (IPCC 2007). 

 Carbon Monoxide (CO a criteria pollutant): Carbon monoxide reduces the oxygen carrying 

capacity of the blood, a reversible effect. Low exposures can cause loss of time awareness, motor 

skills and mental acuity. Also, exposure can lead to heart attacks, especially for persons with 

heart disease. High exposures can lead to death due to lack of oxygen. 

 Carbon Dioxide (CO2): Carbon dioxide is a colorless, odorless and non-poisonous gas formed by 

combustion of carbon and in the respiration of living organisms. Carbon dioxide is the primary 

GHG emitted through human activities. Greenhouse gases act like a blanket around the Earth, 

trapping energy in the atmosphere and causing it to warm. The buildup of GHGs can change the 

Earth's climate and result in dangerous effects to human health and welfare and to ecosystems 

(IPCC 2007). 

 Nitrogen Oxide (NOx a precursor to O3): Nitrogen oxide is a group of different gases made up of 

different levels of oxygen and nitrogen. Nitrogen dioxide (NO2 a criteria pollutant) is a reddishbrown gas. Small levels can cause nausea, irritated eyes and/or nose, fluid forming in lungs and 

shortness of breath. Breathing in high levels can lead to rapid, burning spasms, swelling of throat, 

reduced oxygen intake, a larger buildup of fluids in lungs and/or death. N2O is a GHG and 

contributes to global warming.

 Ozone (O3 a criteria pollutant) is the most widespread air quality problem in the state according 

to the CARB (2010). It is not emitted directly but is formed from reactions of hydrocarbons and 

NOx in the presence of sunlight. It can cause reduced lung function and irritated eyes, nose and 

throat. It is known to cause damage to some vegetation, including ponderosa pine and Jeffrey 

pine trees (Procter et al. 2003). 

 Sulfur Oxide (SOx a criteria pollutant): Short-term exposure to high enough levels of sulfur 

dioxide (SO2) can be life threatening. Generally, exposures to SO2 cause a burning sensation in 

the nose and throat. SO2 exposure can cause difficulty breathing, including changes in the body’s 

ability to take a breath or breathe deeply, or take in as much air per breath. Long-term exposure to 

sulfur dioxide can cause changes in lung function and aggravate existing heart disease. 

Asthmatics may be sensitive to changes in respiratory effects due to SO2 exposure at low 

concentrations. Sulfur dioxide is not classified as a human carcinogen (it has not been shown to 

cause cancer in humans). SOx is not an issue in the state and has not been analyzed.

65
Chapter 3.02 Stanislaus

Air Quality National Forest

The Rim Reforestation project area is located in Tuolumne County and Mariposa County, California. 

The direct, indirect and cumulative effects analysis area for the air quality section of this report is the 

Tuolumne and Mariposa APCDs located in the Mountain Counties Air Basin. 

Affected Environment

Existing Conditions

According to the EPA Green Book, updated January 30, 2015, Tuolumne and Mariposa counties are 

Designated Non-Attainment Areas for ozone; the project area falls within these two counties. The 

Emigrant Wilderness and Yosemite National Park are Federal Class 1 areas adjacent to the project 

area. The San Joaquin Valley, a non-attainment area, runs along the western boundary of the project 

area. The Forest Service follows the guidelines assigned by the CARB [ozone State Implementation 

Plan (SIP), visibility SIPs, and Title 17] to limit state-wide exposure on a cumulative basis, in 

compliance with the Clean Air Act (CARB 2001; 2008). 

Air quality from the Rim Fire reached unhealthy levels from Yosemite to the San Joaquin Valley, 

according to an alert from the National Weather Service. People were advised to avoid strenuous 

outdoor activity or to remain indoors because fine particles in smoke can irritate the eyes and 

respiratory system and aggravate chronic heart and lung disease. Figure 3.02-1 shows the smoke from 

the Rim Fire in the Groveland area and how people responded by wearing filtering devices. 

Figure 3.02-1 Smoke from the Rim Fire Billlows Over Groveland and Affects Air Quality

Environmental Consequences

Effects Common to all Alternatives

Implementation of the initial site preparation activities of either pile burning or understory/jackpot 

burning depends on seasonal climate conditions and budget. Emissions comparisons are based on 

understory/jackpot burning which produce the highest emissions of analyzed prescribed fire 

treatments. Although understory/jackpot burning have the highest prescribed fire emissions, they are 

still lower than wildfire emissions as shown in the tables below. Emissions for all the alternatives 

including Alternative 2 (the no action alternative serves as the control) are shown the following tables 

grouped by treatments: Prescribed Fire in Table 3.02-1; Wildfires in Table 3.02-2; and, Greenhouse 

Gases in Table 3.02-3 and Table 3.02-4. 

66
Rim Fire Reforestation (45612) Affected Environment

Draft Environmental Impact Statement and Environmental Consequences

DIRECT AND INDIRECT EFFECTS

Prescribed Fires

Table 3.02-1 displays emissions for understory/jackpot burning. Burning would be completed under 

approved burn and smoke management plans. Given the ability to control ignition times to favor good 

smoke dispersion, it is not anticipated that prescribed burning would impact the local communities. 

Smoke would be transported to the northeast by typically southwest winds during the day. At night, 

some smoke from smoldering burns in the project area may move down drainages. Piles would be 

burned under weather conditions that would allow efficient combustion. 

Table 3.02-1 Alternatives 1, 2, 3, 4 and 5: Emissions under understory and jackpot burning (tons)

Emissions 

(tons)

Alternative 1

(16,696 acres)

Alternative 2

(0 acres)

Alternative 3

(16,696 acres)

Alternative 4

(19,362 acres)

Alternative 5

(16,696 acres)

PM10 3,131 0 3,131 4,175 3,131

PM2.5 2,755 0 2,755 3,674 2,755

CH4 1,027 0 1,027 1,369 1,027

NMHC 801 0 801 1,069 801

CO 22,289 0 22,289 29,726 22,289

CO2 400,954 0 400,954 534,725 400,954

NOx 751 0 751 1,002 751

Totals 431,708 0 431,708 575,740 431,708

Generally, PM2.5 emissions are the dominant public health risk and can be viewed as the primary 

indicator. The total treatment acres and emissions displayed have value as a relative comparison of 

alternatives but not as an assessment of public exposure since the fuel treatments will take place over 

multiple years and multiple times during each year. Public exposure of smoke emissions will be 

mitigated by the daily burn day permission and allocation from the California Air Resources Board 

and the local air pollution control districts. The objective of this program is to mitigate public 

exposure below health risk thresholds. Most likely the total emissions occurring on any particular 

burn day may not be allowed to exceed 100 to 200 tons of PM2.5 irrespective of the action alternative. 

Wildfires

Emissions from wildfires within the project area were modeled. Table 3.02-2 is based on the First 

Order Fire Effects Model (FOFEM 6.0), the 90th percentile weather for the project area and the 

estimated fuel loading under each Alternative at year 20 (Boucher 2014). For Alternative 2, the 

19,362 acres identified in Alternative 4 were used for the smoke emission analysis. Alternative 2 

generates the maximum emissions compared to all other alternatives. This demonstrates the emissions 

savings that can be generated from prescribed burn treatments as opposed to wildfire scenarios.

Table 3.02-2 Alternatives 1, 2, 3, 4 and 5: Smoke Emissions at Year 20 (Wildfire Conditions, tons)

Emissions 

(tons)

Alternative 1

(16,696 acres)

Alternative 2

(19,362 acres)

Alternative 3

(16,696 acres)

Alternative 4

(19,362 acres)

Alternative 5

(16,696 acres)

PM10 3,757 10,020 3,757 5,010 3,757

PM2.5 3,306 8,817 3,306 4,409 3,306

CH4 1,232 3,287 1,232 1,643 1,232

NMHC 962 2,565 962 1,283 962

CO 26,747 71,341 26,747 35,671 26,747

CO2 481,145 1,283,340 481,145 641,670 481,145

NOx 902 2,405 902 1,202 902

Totals 518,051 1,381,775 518,051 690,888 518,051

67
Chapter 3.02 Stanislaus

Air Quality National Forest

Table 3.02-3 displays the GHG produced from understory burning and jackpot burning. There are no 

GHGs generated under Alternative 2 because no jackpot or pile burning occurs. 

Table 3.02-3 Alternatives 1, 2, 3, 4 and 5: Greenhouse Gas Emissions (Prescribed Burning) 

CO2 Equivalent

(metric tons)

Alternative 1

(Proposed Action)

Alternative 2

(No Action)

Alternative 3 Alternative 4 Alternative 5

CH4 1,027 0 1,027 1,369 1,027

CO2 400,954 0 400,954 534,725 400,954

N2O 751 0 751 1,002 751

Totals 402,732 0 402,732 537,096 402,732

Table 3.02-4 displays the GHG produced by wildfires for all alternatives.

Table 3.02-4 Alternatives 1, 2, 3, 4 and 5: Greenhouse Gas Emissions (Wildfire Conditions) 

CO2 Equivalent

(metric tons)

Alternative 1

(Proposed Action)

Alternative 2

(No Action)

Alternative 3 Alternative 4 Alternative 5

CH4 1,232 3,287 1,232 1,643 1,232

CO2 481,145 1,283,340 481,145 641,670 481,145

N2O 902 2,405 902 1,202 902

Totals 483,279 1,289,032 483,279 644,515 483,279

CUMULATIVE EFFECTS

Additional projects within and adjacent to the project area utilizing prescribed burning include: Rim 

Recovery, Two-mile Ecological Restoration: Vegetation Management, Soldier Creek Timber Sale, 

Reynolds Creek Ecological Restoration and several thousand acres of pile burning on private land. 

California’s Smoke Management Program (Title 17) is designed to prevent cumulative effects from 

prescribed fire operations. The program provides allocations of emissions based on the airshed 

capacity and forecasted dispersal characteristics. The allocation process considers all burn requests, 

meteorological conditions, forecasted air pollution levels (similar to the BSMPs described by the

NRCS 2011) and uncontrollable events like wildfire. Wildfire emissions can overwhelm air basins 

and most prescribed burn requests are denied during wildfire events. As a result of the California 

Smoke Management Program and agency oversight, none of the action alternatives are expected to 

contribute toward air quality cumulative effects.

Alternative 1 (Proposed Action)

DIRECT AND INDIRECT EFFECTS

The wildfire emissions for PM2.5 and other pollutants are lower under Alternative 1 as compared to 

Alternative 2. The total GHGs produced are 402,732 CO2 equivalent metric tons from prescribed fire

treatments.

CUMULATIVE EFFECTS

Cumulative Effects would be similar as described under Effects Common to all Alternatives

Alternative 2 (No Action)

DIRECT AND INDIRECT EFFECTS

Alternative 2 does not treat any acres and therefore no emissions are displayed for understory and 

jackpot burning. Under Alternative 2, no pile burning, understory burning or jackpot burning occur; 

therefore, smoke would not be directly generated from management activities. Lightning and human 

caused ignitions are expected to continue within the perimeter of the Rim Fire. Table 3.02-2 shows 

68
Rim Fire Reforestation (45612) Affected Environment

Draft Environmental Impact Statement and Environmental Consequences

that under a wildfire scenario during 90th percentile weather conditions at year 20, PM2.5 emissions 

for Alternative 2 would be 8,817 tons as compared to 3,306 tons under Alternative 1. 

Although Alternative 2 would not produce GHGs tied to the management actions defined in the other 

alternatives it would likely produce the highest level of GHGs as a result of wildfires. The 2013 Rim 

Fire consumed about 257,000 acres and produced 11 million tons of GHGs as CO2 equivalent metric 

tons (Tarnay 2014). Table 3.02-4 shows about 1.3 million tons of GHG would be produced from 

19,362 wildfire acres under Alternative 2. 

Where wildfires cannot be contained and they burn into heavy fuels, it is expected that heavy smoke 

from fire burning or smoldering in downed logs would result. This smoke would be blown to the 

northeast towards Yosemite National Park, a Federal Class 1 area, by typical southwest winds during 

the day. At night, smoke from a fire in this area would move down the drainages and likely cause 

impacts to the San Joaquin Valley. 

CUMULATIVE EFFECTS

The cumulative effects from other projects would be the same as described under Effects Common to 

all Alternatives. However, when the effects from Alternative 2 are added, the cumulative effects are 

also much higher than the action alternatives. 

Alternative 3

DIRECT AND INDIRECT EFFECTS

Same as Alternative 1.

CUMULATIVE EFFECTS

Same as Alternative 1.

Alternative 4

DIRECT AND INDIRECT EFFECTS

Alternative 4 includes the highest amount of prescribed burning. Alternative 4 reintroduces fire to the 

landscape, but does not reduce the existing fuel loading as much as the other action alternatives. 

Under this Alternative, treatment emissions will be higher than Alternatives 1, 3 and 5. Alternative 4 

will create the most emissions under a wildfire when compared to all other action alternatives. The 

wildfire emissions for PM2.5 and other pollutants are lower under Alternative 4 as compared to 

Alternative 2. The total GHGs produced are 537,096 CO2 equivalent metric tons from prescribed fire

treatments.

CUMULATIVE EFFECTS

Cumulative effects would be similar as described under Effects Common to all Alternatives.

Alternative 5

DIRECT AND INDIRECT EFFECTS

Same as Alternative 1.

CUMULATIVE EFFECTS

Same as Alternative 1.

69
Chapter 3.02 Stanislaus

Air Quality National Forest

Summary of Effects Analysis across All Alternatives

Table 3.02-1 displays total emissions for understory and jackpot burning for each alternative. Total 

emissions from wildfires were generated using the 90th percentile weather, fuel loading at year 20 

and multiplied by the number of acres treated for each alternative except Alternative 2. For 

Alternative 2, the 19,362 acres identified in Alternative 4 were used for the smoke emission analysis.

Areas outside treatment units would experience similar fire behavior, which would result in similar 

emissions. The expected amount of smoke emissions under wildfire conditions outside of areas 

previously treated to meet desired fuel loading at year 20 would be 2.6 times more for all types of 

emissions, as shown in Table 3.02-2. 

The project is located in an area designated as non-attainment for ozone. Ozone is known to impact 

human respiratory function and the health and vigor of some vegetation including ponderosa and 

Jeffry pine (Procter et al, 2003). The burn treatments under Alternatives 1, 3, 4 and 5 will be 

conducted under an EPA approved California Smoke Management Program (SMP). Under the 

revised Conformity Rules the EPA has included a Presumption of Conformity for prescribed fires that 

are conducted in compliance with a SMP; therefore, the federal actions will be presumed to conform 

and no separate conformity determination will be made. The California Smoke Management Program 

provides for the allocation of emissions from biomass burning with respect to cumulative effects. 

Biomass burning projects are regulated and coordinated by air quality regulatory jurisdictions and all 

entities submitting burns for approval. In making those decisions, air quality regulators consider 

forecasts, dispersion conditions, locations of proposed projects and background air quality by air 

basin. These considerations have historical success in preventing cumulative effects of smoke.

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Draft Environmental Impact Statement and Environmental Consequences

3.03 AQUATIC SPECIES

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction

The Endangered Species Act of 1973 (16 USC 1531 et seq.) requires that any action authorized by a 

federal agency not be likely to jeopardize the continued existence of a TE species, or result in the 

destruction or adverse modification of habitat of such species that is determined to be critical. Section 

7 of the ESA, as amended, requires the responsible federal agency to consult the United States Fish 

and Wildlife Service (USFWS) and the National Marine Fisheries Service concerning TE species 

under their jurisdiction. It is Forest Service policy to analyze impacts to TE species to ensure 

management activities are not be likely to jeopardize the continued existence of a TE species, or 

result in the destruction or adverse modification of habitat of such species that is determined to be

critical. This assessment is documented in a Biological Assessment (BA) and is summarized and 

referenced in this Chapter.

USDA Departmental Regulation 9500-004 provides the following direction to USDA agencies. 

Regional Forester Sensitive Species

1. Assure that the values of fish and wildlife are recognized, and that their habitats, both terrestrial 

and aquatic, including wetlands, are recognized and enhanced where possible as the Department 

carries out its overall missions.

2. Consider fish and wildlife and their habitats in developing programs for these lands. Alternatives 

that maintain or enhance fish and wildlife habitat should be promoted. When compatible with 

objectives for the area, management alternatives that improve habitat will be selected.

3. Balance the competing uses for habitat supporting fish and wildlife through strong, clear policies, 

relevant programs, and effective actions to sustain and enhance fish and wildlife in desired 

locations and numbers. 

4. Recognize that fish and wildlife have inherent values as components and indicators of healthy 

ecosystems, and that they often demonstrate how altered environments may affect changes in 

quality of life for humans.

5. Avoid actions “which may cause a species to become threatened or endangered”.

Threatened, Endangered, Candidate and Proposed Species

1. Conduct activities and programs “to assist in the identification and recovery of threatened and 

endangered plant and animal species.”

2. Avoid actions “which may cause a species to become threatened or endangered.”

3. Consult “as necessary with the Departments of the Interior and/or Commerce on activities that 

may affect threatened and endangered species.” 

4. Not “approve, fund or take any action that is likely to jeopardize the continued existence of 

threatened and endangered species or destroy any habitat necessary for their conservation unless 

exemption is granted pursuant to subsection 7(h) of the Endangered Species Act of 1973, as 

amended.” 

Threatened and Endangered species are those Federally listed by the USFWS; Candidate species are 

candidates to become Proposed species but issuance of a proposed rule is currently precluded by 

higher priority listing actions (USFWS 1998). Sensitive species are those designated by the Regional 

Forester with the goal of proactively developing and implementing management practices to ensure 

that those species do not become Threatened or Endangered, and therefore require protection under 

the Endangered Species Act because of Forest Service actions (Departmental Regulation 9500-004). 

71
Chapter 3.03 Stanislaus

Aquatic Species National Forest

The Forest Plan Compliance (project record) document identifies the Forest Plan Standards and 

Guidelines that specifically apply to this project and related information about compliance with the 

Forest Plan. 

Effects Analysis Methodology

This chapter serves as a summary of the analysis for aquatic species that may be affected by the 

project. Additional analysis will be provided in the Biological Assessment and Evaluation. 

Project effects analyses covered threatened, endangered and proposed species where their geographic 

and elevation range and suitable habitat occurred within the Rim Reforestation project area. An 

official list of federal threatened, endangered and proposed species covering the project area was 

obtained from the Sacramento U.S. Fish and Wildlife Office website on December 5, 2013, and 

updated on April 17, 2014 (Document 140417112513); USFWS IPaC website checked November 

2015 to confirm species status. The Sierra Nevada yellow-legged frog status was changed to 

“Endangered” on June 30, 2014. Scientific literature, state and federal databases (CNDDB, Aquasurv) 

were also examined to determine if species may occur in the project area.

Assumptions Specific to Aquatic Species

 The map developed by Dr. Roland Knapp provides the best available estimate of the former range 

of the Sierra Nevada yellow-legged frog (SNYLF). The map was developed using a Maxent 

model and using every verified historical and current SNYLF locality. This model was also used 

by the U. S. Fish and Wildlife Service to refine the boundaries of proposed critical habitat for the 

frog (Federal Register 2013a).

 For the foothill yellow-legged frog (FYLF) and western pond turtle (WPT), all intermittent and 

perennial streams below 4,200 feet in elevation provided suitable habitat for the species. This is 

considered a conservative approach because some intermittent streams do not provide any 

perennial water, making occupancy by either species unlikely. If these small, intermittent 

tributaries have very steep pitches (e.g., 20-foot high waterfall), they are also unlikely to be used 

by the turtle (Holland 1994). Also, the WPT may also occupy streams above the 4,200 foot 

elevation because one known occupied site above this elevation, but almost all occupied sites are 

lower than 3,000 feet in elevation. Two occupied sites (ponds) are at 5,400 feet within this project 

area with no clear indication of how they became occupied by the species. It is possible that they 

occur at these sites naturally or are an artefact of introduction by humans.

 All suitable habitats are assumed to be occupied by the species because of the limitations inherent 

in visual encounter surveys. Since the FYLF can remain hidden in streamside vegetation, roots, or 

cracks in rocks and WPT detect and hide quickly from surveyors (at long distances), the lack of 

detection during a single survey does not indicate unoccupied habitat. Also, some surveys only 

cover portions of a stream which limits an assumption of occupancy for an entire stream.

 A 300-meter (984 feet) analysis buffer was used for the WPT around suitable aquatic habitats to 

account for upland habitat use. This buffer is assumed to include a large majority of the upland 

habitat use, but acknowledges that turtles sometimes move distances greater than 300 meters from 

the water. Note: This is not an exclusion buffer, treatment would occur within 300 meters of 

aquatic habitat.

 In the post-fire environment, most of the sediment from hillslope erosion is assumed to end up in 

a stream. This assumption is more valid for high soil burn severity areas on steep slopes that are 

close to streams. High-severity areas typically have no beneficial ground cover and have waterrepellent layers that allow sediment to be eroded. Roughness in topography, downed wood, rocks 

and stump holes all have the potential to trap sediment being transported downslope and the 

assumption of 100% sediment routing to stream channels is an overestimation. However, using 

this assumption allows for the comparison of erosion rates and sedimentation across all 

alternatives.

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Rim Fire Reforestation (45612) Affected Environment

Draft Environmental Impact Statement and Environmental Consequences

 Changes in sediment from project-related activity at the 5th Level Hydrologic Unit Code (HUC) 

watershed scale are assumed to be relatively minor when compared to post-fire and salvage 

logging sedimentation. For example, the amount of post-fire sediment delivered to the Clavey 

River may have small, localized consequences, but at the point of confluence with the Tuolumne, 

there would be too little sediment to significantly impair biological functions. Further, there 

would be very little detectable change in suitability for most aquatic habitats when the total 

amount of project-related sediment is added to the post-fire sediment. This is because large 

bedrock rivers are very effective at storing and transporting fine sediments.

 Species are not present where suitable habitat is not present.

 Proposed water quality BMPs and management requirements would function as designed and 

reduce the risk of both direct and indirect effects to aquatic species.

 At a minimum, herbicide use near aquatic habitat would be defined by product labels; in most 

cases, additional management requirements would increase buffer width.

 Multiple entries would be required for most units. The analysis timeframe is 10 years, and 

assumes that multiple treatments would occur within each unit over this period of time. Analysis 

assumes the vast majority of effects (e.g., sediment increase) from each treatment would have 

subsided before the same area is treated again (no additive effects). It is recognized that 

vegetation cover/structure would not fully recover over the short-term. After 5 years, heavy 

equipment use is not proposed; therefore project-related sediment increase (about 5 years) from 

actions such as herbicide use and hand grubbing are expected to be markedly less.

Data Sources

 Stanislaus National Forest basemap, watersheds delineated at multiple scales (Hydrologic Unit 

Codes 5-8), stream gradient layer.

 Stanislaus National Forest aquatic survey database (Aquasurv).

 Stanislaus Streamscape Survey Inventory (SSI) database.

 California Wildlife Habitat Relationships System (CWHR) and the California Natural Diversity 

Database.

 Sediment analysis (3.11 Soils and 3.15 Watershed). 

 Watershed, soils and geology BAER reports. 

Aquatic Species Indicators

THREATENED AND ENDANGERED SPECIES

The Aquatic BA and BE, evaluate two federally listed species: the threatened California red-legged 

frog (CRLF) and endangered Sierra Nevada yellow-legged frog (SNYLF). The indicators used for the 

analysis of potential impacts to these aquatic species are related to habitat suitability, breeding habitat 

and upland habitat. 

Breeding and Non-breeding Aquatic Habitat

 Amount of breeding habitat affected by project activities (CRLF) 

 Amount of non-breeding habitat affected by project activities (CRLF and SNYLF) 

Habitat Suitability (CRLF and SNYLF)

 Acres of vegetation change due to all project activities within species-specific terrestrial habitat 

buffers. 

SENSITIVE SPECIES

The Aquatic BE evaluates three Forest Service sensitive species: foothill yellow-legged frog (FYLF), 

western pond turtle (WPT) and hardhead. The indicators used for the analysis of potential impacts to 

these aquatic species include indicators common to all three species and indicators specific to each 

species.

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Chapter 3.03 Stanislaus

Aquatic Species National Forest

Common Indicators

 Amount of species-specific buffer affected by the activities in each alternative. 

 Proportion of available habitat potentially impacted by project activities. 

Species Specific Indicators

 Percentage of foothill yellow-legged frog buffer (in acres) affected by project activities.

 Percentage of western pond turtle buffer (in acres) affected by project activities.

Aquatic Species Methodology by Action

THREATENED AND ENDANGERED SPECIES

The methodology used in the analysis for the CLRF and the SNYLF were similar. Within the project 

area, occupancy and habitat suitability assessments identified localized analysis areas for each 

species. These analysis areas were defined by suitable breeding habitats and the non-breeding, upland 

and dispersal habitats associated with them. Within each discrete analysis area, effects to individuals 

and effects to habitats were analyzed for each alternative.

California Red-legged Frog

Perennial and intermittent aquatic habitats at elevations of 4,000 feet or less (historic localities above 

this elevation are not expected to be affected by project actions) were assessed for CRLF breeding 

and non-breeding suitability based on the primary constituent elements (PCEs) as defined by the 

USFWS (Federal Register 2010). The direct, indirect and cumulative effects for CRLF were based on 

suitable breeding habitats within one mile of the project area boundaries. The remaining habitat 

components (non-breeding aquatic, upland and dispersal) were then identified within one mile of the 

breeding habitats.

Sierra Nevada Yellow-legged Frog

A range map developed by Dr. Roland Knapp using historically and currently occupied sites was used 

as the basis for identifying suitable habitat for the SNYLF. Streams and ponds within the area covered 

by the range map were considered for analysis. The direct, indirect and cumulative effects were 

conducted for SNLYF suitable breeding, non-breeding and upland habitats where project activities 

were proposed within 984 feet of ponds and within 82 feet of any portion of a stream habitat as 

determined by the defined extent of the upland area for each of these habitats (Federal Register 

2013b). 

Existing Condition

Known pre-fire habitat characteristics were gathered and summarized to establish a baseline to 

compare how the estimated effects of the Rim Fire could affect each habitat. Most of the suitable 

breeding habitats included in this analysis had some level of pre-fire existing condition information. 

In many areas, substantial post-fire vegetation growth (predominantly brush species) has occurred. 

Pre-fire existing condition assessments utilized a variety of factors. For the CRLF, the primary factors 

considered included, bullfrog presence, water depth and other human caused disturbances (recreation, 

roads and developed areas). The primary factors contributing to SNYLF pre-fire existing condition 

assessments included fish presence, depth and gradient and pool presence. These pre-fire existing 

condition factors were used in addition to the PCEs as defined by the (Federal Register 2013b). 

Sediment Analysis

The project watershed report provides data on expected sediment input from both natural sources and 

project actions. Sediment is discussed qualitatively and comparatively in this report.

74
Rim Fire Reforestation (45612) Affected Environment

Draft Environmental Impact Statement and Environmental Consequences

Vegetation Burn Severity

Vegetation that burned at moderate to high severities provides the least amount of soil cover in the 

first few years following the fire; it is likely that the majority of fire-induced sediment input will have 

occurred prior to implementation of this project due to vegetative re-growth in many areas. Low burn

severity areas and unburned vegetation within a fire area maintain levels of soil cover capable of 

withstanding erosion. Sediment transport on moderately steep to very steep hillsides is greater than in 

areas with gently sloping terrain.

Stream Gradient

Streams with steeper gradients will typically store less sediment because flow velocity and the force 

of gravity are greater in these systems. Lower gradient streams (less than 4%) have a tendency to 

store sediment in pools and slow runs and impacts in these habitats would be more likely in the postfire and post-project environment. Therefore, this analysis adjusted the sediment storage rate in 

streams in accordance with the associated average stream gradient.

Cumulative Effects

The spatial boundary of the cumulative effects analysis is the Rim Fire perimeter. Portions of CRLF 

habitat areas outside the perimeter were included in calculation for that species only in order to make 

relevant comparisons on percentage of habitat unit affected by project activities. The downstream 

extent is located close to the confluence of the Tuolumne and North Fork Tuolumne Rivers; 

observable effects are not expected downstream of the confluence. The temporal boundary 

established for cumulative effects analysis was ten years from present, a timeline commensurate with 

the Cumulative Watershed Effects (CWE) modeling (watershed report) which estimates disturbance 

acreage to develop a threshold of concern (TOC). When the TOC is exceeded there is the risk of 

increased sedimentation in the channel, reduction in deep water habitat volume, reduction in 

interstitial spaces in the streambed, greater turbidity during high stream flow and reduced primary and 

secondary productivity. These changes in the aquatic system can affect reproduction, ability to avoid 

predation and the availability of food resources. The CWE modeling indicated all streams would 

recover to near pre-fire levels within this time frame.

SENSITIVE SPECIES

For the FYLF and WPT, all perennial and intermittent streams below 4,200 feet were identified as 

suitable for the species. For the FYLF, all of these stream miles were buffered by 100 feet on both 

sides to provide an upland area for the frog. These two steps identified the number of stream miles to 

be calculated in the project area and amount of upland habitat associated with the streams. For the 

WPT, the same streams used for the FYLF analysis were buffered by a distance of 300 meters (984 

feet) on each side to derive an upland habitat area. Both buffer areas (FYLF and WPT) are considered 

to contain the majority of upland habitat used by the species. 

With these upland areas established, the activities proposed in each of the alternatives were placed 

over the upland areas to estimate the amount of area impacted by each activity for each species. This 

estimate was used to provide a point of reference for the amount of project-related activity occurring 

close to streams and provide a basis for assigning risk of direct and indirect effects to the species and 

their habitats. 

Affected Environment

The Rim Fire affected a variety of aquatic habitats including wetlands, ponds, natural and man-made 

lakes, streams and rivers. The aquatic features at lower elevations, less than 2,500 feet, are primarily 

influenced by rainfall during the wet season (November through April), while aquatic features above 

this elevation are influenced by rainfall, snowpack, or a combination of both. Streams in the rainfall 

zone typically see peak flows following larger rain events and some intermittent streams may support 

75
Chapter 3.03 Stanislaus

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surface water for several months. Streams in the rain and snow zones may see very high peak flows if 

rain falls on a snowpack, but streams typically show a period of peak flow as the snow melts in the 

late spring and early summer.

All of the larger stream systems affected by the Rim Fire are bedrock rivers (versus alluvial rivers) 

shaped by snowmelt runoff during the late spring (mid-May) to middle summer (mid-July). 

Geomorphic complexity in bedrock rivers in the Sierra Nevada requires variable annual flow (winter 

floods, snowmelt peak flows, winter and summer baseflow), periodic inputs of large volumes of 

sediments (landslides, hillslope mass wasting), and multiple flow thresholds (variable levels of 

flooding) (McBain and Trush 2004). Most of these rivers have steep canyons, and steep tributary 

streams, ascending to more gentle terrain above the canyon rim. 

A very large proportion of the fire area occurred in the Tuolumne River watershed. The Tuolumne 

River originates in Yosemite National Park and has several large tributaries originating in the Park or 

on the STF. Five primary tributaries join the Tuolumne within the fire area: the Clavey and Middle, 

North, and South Fork Tuolumne Rivers, and Cherry Creek. The Middle and South Fork Tuolumne 

Rivers originate in Yosemite then flow in a westerly direction to join each other and then the main 

Tuolumne. Cherry Creek and the North Fork Tuolumne and Clavey Rivers originate in the Forest and 

primarily flow in a southerly direction into the Tuolumne. There are many minor tributaries to the 

Tuolumne River and its principal tributaries including: Alder, Big, Corral, Drew, Grapevine, Indian, 

and Jawbone Creeks (Tuolumne River); Basin and Hunter Creeks (North Fork Tuolumne River); Big 

Creek (South Fork Tuolumne River); Eleanor and Granite Creeks (Cherry Creek); and Hull, Reed 

(including Bourland, Reynolds, and Little Reynolds Creeks), and Twomile Creeks (Clavey River). 

Additionally, there are numerous very small, unnamed tributaries to each of these listed streams and 

rivers.

Obligate riparian vegetation (e.g., willow and alder) along most streams in the affected area is

typically restricted to a narrow (less than 50 feet) band adjacent to the edge of the water. Some 

wetlands within the project perimeter support obligate herbaceous riparian species as the dominant 

plant community type. 

The known distribution of all analyzed aquatic species follows and a description of suitable habitat 

for these species is also provided.

THREATENED AND ENDANGERED SPECIES

California Red-legged Frog

The CRLF is now likely extirpated from 70% of its former range (USFWS 2002). The CRLF 

occurred at elevations from sea level to 5,200 feet, although the highest known extant population 

occurs at 3,346 feet in Placer County (Barry and Fellers 2013). The historic localities in the Sierra 

Nevada over 3,600 feet were possibly introduced (USFWS 2002; Barry and Fellers 2013). The Fish 

and Wildlife Service has concurred that occurrences above 4,000 feet in the Sierra Nevada are 

atypical and has used this elevation as a threshold for critical habitat designation (Federal Register 

2006). 

California red-legged frogs inhabit various aquatic habitats including ponds, marshes, streams and 

lagoons (Fellers 2005). The timing of breeding varies geographically, but typically occurs from 

November through April (USFWS 2002), which coincides with what will be referred to as the wetseason throughout this section. Females lay from 2,000 to 6,000 eggs (in masses) that are usually 

attached to vegetation near the water’s surface. Eggs hatch in about 3 weeks. Tadpoles typically 

metamorphose within 11 to 20 weeks, from July to September, but overwinter aquatically at some 

sites (Fellers 2005; Bobzien and DiDonato 2007). Adult movements to terrestrial habitat or between 

aquatic habitats typically commence with the first fall rain (greater than 0.25 inches) and continue 

until April (Fellers and Kleeman 2007; Tatarian 2008). Adults may also disperse when aquatic 

76
Rim Fire Reforestation (45612) Affected Environment

Draft Environmental Impact Statement and Environmental Consequences

habitats dry out (Fellers and Kleeman 2007). Individual movements of up to 2 miles have been 

reported (Fellers 2005), but 1 mile represents a more average dispersal distance (Federal Register 

2010). 

The CRLF Recovery Plan (USFWS 2002) identifies introduced species and habitat degradation and 

loss as primary drivers of CRLF population declines. Introduced bullfrogs, crayfish, fish and plants 

which have become established throughout much of the historic CRLF range, detrimentally affect the 

CRLF through predation, competition and reduced habitat quality. Agricultural and urban 

development have destroyed and fragmented much of the historic CRLF habitat. Other factors that 

may have particularly impacted Sierra Nevada populations include dams and impoundments, mining, 

livestock overgrazing, recreation and timber harvesting.

Project actions conducted within watersheds inhabited (none currently known) by, or containing 

suitable CRLF habitat, may contribute to the degradation of instream and riparian habitat. The 

primary effect is the potential for increased sedimentation and removal or modification of cover in 

terrestrial/upland habitat.

The CRLF has not been detected on the Stanislaus National Forest since 1967 and is considered 

extirpated from the Tuolumne River watershed (USFWS 2002) which is part of the project area. 

A total of 9.7 miles of potentially suitable breeding stream habitat, 11.1 acres of potentially suitable 

breeding pond habitat, 55.7 miles of non-breeding stream habitat, and 21,593 acres of upland habitat 

was identified within the project analysis area. All other habitats were ruled out because they did not 

meet the suitability criteria. Within the Rim Reforestation project area five habitat units (Mather 

Vicinity, Drew Creek, Homestead Pond, Harden Flat and Hunter Creek) were identified that have 

suitable breeding habitat in streams (Drew Creek, Hunter Creek) and ponds (Birch Lake, Mud Lake, 

Homestead Pond and 7 unnamed ponds). Habitat characteristics including size (acres), length (miles), 

average depth (feet) and pre- and post-fire habitat quality determinations are summarized in Table 

3.03-1. The percent of the landscape within each breeding habitat’s watershed where vegetation 

remained unburned (UB) or burned at high (H), moderate (M) or low (L) severity is also displayed in 

Table 3.03-1. These values were used in determining the potential post-fire watershed response for 

the analysis.

Table 3.03-1 Existing Condition Summary for Suitable CRLF Breeding Habitats

Habitat Acres Miles1 Depth2

(feet)

Elevation

(feet)

VBS 

HIGH

VBS 

MOD

VBS 

LOW

VBS 

UB

Pre-Fire 

Habitat Quality

Post-Fire 

Habitat Quality

Birch Lake3 4.0 0.28 No data 4,500 31 14 18 37 Low No Change

Mud Lake3 2.2 0.31 No data 4,500 0 55 22 23 Low No Change

Drew Creek 1.3 1.75 2,960 to 3,300 50 23 21 5 Moderate-High Low

Harden Flat Pond 1 0.6 0.12 No data 3,500 11 40 34 16 Moderate Moderate-Low

Harden Flat Pond 2 0.4 0.12 No data 3,500 0 11 3 86 Moderate No Change

Homestead Pond3 0.2 0.06 > 6.5 3,100 86 14 0 0 Moderate Moderate

Hunter Creek4 8.4 1.6 1,600 to 4,000 13 18 18 51 Moderate Moderate-Low

Hunter Creek Pond 1 0.4 0.10 No data 3,880 10 32 44 15 Unknown Unknown

Hunter Creek Pond 2 0.2 0.07 No data 3,760 9 32 46 13 Unknown Unknown

Hunter Creek Pond 3 0.2 0.08 No data 3,880 9 17 59 14 Unknown Unknown

Hunter Creek Pond 4 0.4 0.10 No data 3,760 14 41 39 6 Unknown Unknown

Hunter Creek Pond 5 0.4 0.10 No data 3,360 13 35 47 5 Unknown Unknown

MOD=Moderate; UB=Unburned; VBS=Vegetation Burn Severity 1 Miles of stream or shoreline of ponds

2 Depths for creeks are average pool depths.

3 Bullfrogs present

4 Trout present

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Chapter 3.03 Stanislaus

Aquatic Species National Forest

Sierra Nevada Yellow-legged Frog

Prior to 2007, Rana muscosa and Rana sierrae were considered a single species referred to as 

mountain yellow-legged frogs (Vredenburg et al. 2007). Genetic information indicates that the 

contact zone between the two species is between the middle and south forks of the Kings River. Frogs 

north of this point (applies to project area) are now classified as Sierra Nevada yellow-legged frogs 

(SNYLF, Rana sierrae), and those south, remain mountain yellow-legged frogs (MYLF, Rana 

muscosa). Consequently, the analysis summarized here will address the effects of project actions on 

the SNYLF. Where information applies to both species, the two species will be referred to 

collectively as the MYLF-complex. 

Although frogs of the MYLF- complex were historically abundant throughout the Sierra Nevada, 

current research shows declines over large expanses of their range, including as much as 97% on NFS

lands. Where frogs are present, their numbers are relatively low in comparison to historical estimates 

(Brown et al. 2014). The remaining populations are restricted primarily to publicly managed lands 

within National Forests and National Parks at elevations ranging from 4,500 to 12,000 feet (CDFG 

2011). 

Frogs of the MYLF-complex inhabit high mountain lakes, ponds, marshes, meadows, tarns, and 

streams. They are highly aquatic at all life stages and extensively use ponds greater than 6.5 feet deep

and free of introduced fish. Despite their positive correlation with deep water habitats (Knapp 2005), 

both tadpoles and adults are most commonly found along open gently sloping shorelines that provide 

shallow waters of only 2 to 3 inches (Mullally and Cunningham 1956; Jennings and Hayes 1994; 

Federal Register 2013a).

At lower elevations, the species is associated with rocky streambeds and wet meadows surrounded by 

coniferous forests (Zweifel 1955; Zeiner et al. 1988). Streams utilized by adults vary from high 

gradients and numerous pools, rapids, and small waterfalls to streams with low gradients and slow 

flows, marshy edges, and sod banks (Zweifel 1955). These frogs are rarely found in small or 

ephemeral streams which frequently have insufficient depth and hydro-periods for adequate refuge 

and overwintering habitat (Jennings and Hayes 1994). 

The timing of breeding varies annually, but occurs shortly after snowmelt, typically between May and 

July (the dry season). Females lay clutches varying from 15 to 350 eggs (Vredenburg et al. 2005) 

attached to rocks, gravel, vegetation, or under banks (Wright and Wright 1949, Pope 1999). Eggs 

hatch in about 2.5 to 3 weeks (Pope 1999). Tadpoles may take more than one year (Wright and 

Wright 1949), and often require 2 to 4 years, to reach metamorphosis (Bradford et al. 1993; Knapp 

and Matthews 2000) depending on local climate conditions and site-specific variables. In aquatic 

habitats of high mountain lakes, the adult frogs typically move only a few hundred meters (Matthews 

and Pope 1999; Pope 1999), but single-season distances of up to 2.05 miles have been recorded along 

streams (Wengert 2008). Adults may move between selected breeding, feeding, and overwintering 

habitats during the course of the year. Though typically found near water, overland movements by 

adults of over 217 feet have been routinely recorded (Pope 1999). The farthest reported distance from 

water is 1,300 feet (Federal Register 2013a). 

Some factors that may impact the MYLF-complex include recreation activities, dams and water 

diversions, livestock grazing, timber management, road construction and maintenance and fire 

management activities (Helms and Tappeniner 1996; Federal Register 2013a). A large increase in 

sedimentation could potentially damage breeding habitat. Roads may contribute to habitat 

fragmentation and species disturbance, but have not been implicated as primary factors in this 

species’ decline.

In some areas, long-term fire suppression has created conditions vulnerable to increased fire severity 

and intensity (McKelvey et al. 1996; Federal Register 2013a). Excessive erosion and siltation of 

habitats following wildfire is a concern in shallow, lower elevation areas below forested stands. 

78
Rim Fire Reforestation (45612) Affected Environment

Draft Environmental Impact Statement and Environmental Consequences

Severe and intense wildfires may reduce amphibian survival (Russell et al. 1999). Amphibians may 

avoid direct mortality from fire by retreating to wet habitats or sheltering in subterranean burrows 

(Federal Register 2013a). Because these species generally occupy high-elevation habitats, where fire 

is less likely to occur, this is likely a low threat.

The SNYLF has been found throughout the STF in streams, meadows and lakes at elevations between 

5,400 feet and 9,700 feet, most commonly in high alpine lake habitats. No SNYLF (extant or historic) 

have been found within the project perimeter according to Forest Service and CNDDB records. With 

few exceptions, the stream occurrences associated with wet meadow systems are in streams adjacent 

to or connected to lakes and ponds. The majority of habitats within the project area are atypical of 

habitats where SNYLF are known to occur. 

Within the project area there are 2.6 miles of potentially suitable breeding habitat, 5.6 miles of 

suitable non-breeding stream habitat, 1.3 acres of breeding habitat in ponds, and 170 acres of upland 

habitat. Suitable habitats include sections of three different streams (Eleanor Creek, Reynolds Creek, 

and the Middle Fork Tuolumne River) and two ponds (Little Kibbie Pond and Big Kibbie Pond). 

SENSITIVE SPECIES

Foothill Yellow-legged Frog

The FYLF is a stream breeding frog that spends essentially all of its time in or in very close proximity 

to water. Breeding occurs in late spring (small streams) or early summer (larger streams) when 

predictable or receding flows occur and water temperatures warm. Breeding females typically attach 

egg masses to stable substrates (rocks) in shallow, slow water. Tadpoles emerge in a few weeks and 

begin feeding on algae and diatoms attached to streambed substrates. As tadpoles develop, they 

become wary of potential predators and seek refuge around and under streambed substrates. Tadpoles 

metamorphose into “froglets” by early fall and probably stay near the breeding area for the first 

winter. Adult and sub-adult frogs adopt one of a couple of dispersal strategies outside of the breeding 

season. One strategy involves moving up or downstream of the breeding area and the frogs remain on 

the same stream. Another strategy involves dispersal into small tributary streams near the breeding 

site. They may remain in these smaller streams associated with very small pools for most of the year. 

Sunny areas for basking and shady areas for refuge are likely important attributes in allowing the frog 

to regulate its body temperature. With the onset of spring, males will move to the breeding areas to 

establish territories and females follow several weeks to months after the males. Females probably 

leave the breeding site immediately following breeding. The FYLF has a known local elevation range 

of 900 to 4,000 feet. On the forest, the highest elevation recorded for breeding on a large river is 

3,000 feet (North Fork Tuolumne River) and 3,600 feet in a small stream (Bull Meadow Creek).

The FYLF is known to occur in the following streams in the project area: Drew Creek, Grapevine 

Creek, and Tuolumne River (Tuolumne River watershed); Basin Creek, Hunter Creek, North Fork 

Tuolumne River (North Fork Tuolumne River watershed); Bull Meadow Creek, Indian Springs 

Creek, unnamed tributary, and Clavey River (Clavey River watershed); and Bull Creek, Moore Creek, 

and North Fork Merced River (North Fork Merced River watershed). Many other streams in the fire 

area provide suitable habitat for the FYLF, but occupancy is unknown. Below the confluence of 

Cherry Creek, the Tuolumne River does not provide suitable breeding habitat for the frog because of

drastic fluctuations in water associated with releases from Dion Holm Powerhouse on Cherry Creek. 

These fluctuations occur rapidly and daily during the breeding period, and are probably large enough 

to either scour or strand egg masses, both mortality events. Also, the cold water temperatures 

associated with the discharges may be enough to slow development and prevent metamorphosis in a 

timely manner. The Tuolumne River likely played an important role in supporting a number of 

interconnected sub-populations along the river prior to the construction of upstream dams. This 

assertion is supported by the presence of FYLF populations in most of the main tributaries and in the 

Tuolumne itself upstream of Early Intake.

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Chapter 3.03 Stanislaus

Aquatic Species National Forest

Most of these populations, especially in small streams (e.g., Basin Creek) are believed to be small and 

consist of less than 20 adults. In the small tributaries that offer dispersal habitat, there could be very 

few individuals occupying the stream. The Clavey River is probably the largest remaining population 

of FYLF in the southern Sierra Nevada. Frogs are known to breed at the confluence with the 

Tuolumne River and above the bridge on Forest Service Road 1N01 (9 miles) and this analysis 

assumes multiple breeding locations between these two points. Also, the river provides many more 

miles upstream of the bridge that are suitable for breeding. Table 3.03-2 shows miles of suitable and 

occupied FYLF habitat, occupancy status, and whether surveys were conducted on the streams.

Table 3.03-2 Occupied and Suitable Habitat for FYLF in the Project Area

Watershed and Streams 

(5th level HUC)

Size 

(acres) Occupancy Survey Suitable(miles) UHA

Tuolumne River 819,000 Yes Yes 36.5 870

Alder Creek 1,525 Unknown Yes 5.5 132

Corral Creek 4,570 Unknown Yes 9.6 230

Drew Creek 1,697 Yes Yes 4.6 110

Grapevine Creek 4,488 Yes Yes 10.8 260

Indian Creek 2,344 Unknown No 2.7 64

Jawbone Creek 13,136 Unknown Yes 14.3 343

Middle Fork Tuolumne River 46,635 Unknown Yes 25.5 612

North Fork Tuolumne River 63,849 Yes Yes 75 1,796

Basin Creek 9,030 Yes Yes 17.8 427

Hunter Creek 9,482 Yes Yes 21.5 515

South Fork Tuolumne River 57,855 Unknown Yes 29.4 704

Cherry Creek 90,892 Unknown No 17.8 428

Eleanor Creek 59,906 Unknown No 2.3 55

Granite Creek 4,110 Unknown Yes 6.0 144

Clavey River 100,645 Yes Yes 29 696

Reed Creek 24,527 Unknown Yes 4.2 101

Adams Gulch 815 Unknown No 0.8 18

Bear Springs Creek 2,403 Unknown Yes 1.9 45

Bull Meadow Creek 1,430 Yes Yes 3.0 71

Indian SpringsCreek 356 Yes Yes 0.8 20

Quilty Creek 1,089 Unknown Yes 1.8 44

Unnamed Tributary 1 773 Unknown No 1.5 36

Unnamed Tributary 2 373 Unknown No 1.0 25

Unnamed Tributary 3 1,343 Unknown Yes 2.3 56

Unnamed Tributary 4 490 Unknown Yes 1.0 24

Unnamed Tributary 5 688 Yes Yes 1.7 41

Cottonwood Creek 5,307 Unknown Yes 2.3 56

Russell Creek 560 Unknown No 0.8 20

North Fork Merced River 79,110 Yes Yes 74.4 1,784

Bull Creek 21,064 Yes Yes 44.7 1,072

Deer Lick Creek 3,981 Unknown Yes 9.7 233

Moore Creek 5,896 Yes Yes 11.9 286

Scott Creek 1,627 Unknown Yes 1.9 46

UHA=Upland Habitat Acres (30-meter buffer)

The analysis area for the FYLF includes the Tuolumne River watershed from Hetch Hetchy in 

Yosemite National Park to the backwaters of Lake Don Pedro. For this portion of the Tuolumne River 

watershed, the analysis area extends upstream each tributary to the project boundary. In many 

instances, the entire watershed area of the smaller tributaries is within the project area (e.g., 

Grapevine, Corral, and Alder Creeks). For other tributary watersheds, only a portion of the total 

watershed area is affected (e.g., Clavey and the Middle, North, and South Forks of the Tuolumne). 

For the North Fork Merced River (about 100,000 acres), the project area only includes a small portion 

80
Rim Fire Reforestation (45612) Affected Environment

Draft Environmental Impact Statement and Environmental Consequences

of several headwater tributaries and the analysis boundary only includes the upper portion of the 

North Fork Merced watershed, or the 37,000 acres in the 6th level HUC. 

Western Pond Turtle

The WPT is a species that requires both aquatic and terrestrial habitat to meet its life history needs. 

Aquatic habitats are needed for breeding, eating, overwintering, regulating body temperature, refuge, 

and rearing hatchlings. Terrestrial habitats are required for nesting, aestivation, overwintering, and 

regulating body temperature. The WPT mates under water and the females excavate a nest adjacent to 

aquatic habitat. Nests are typically constructed in open areas (little or no canopy cover) with welldrained soil and on gentle slopes with good solar aspect (south to west facing slopes). The nests are 

typically found within 300 feet of the aquatic feature used by adults, but can be found almost 0.25 

mile away from the water. The eggs hatch in several months, but the hatchling turtles remain in the 

nest until the following spring or early summer. The hatchlings seek slow, shallow, and warm water 

where they can forage and grow. Adult and sub-adult turtles can spend much of their year within a 

small geographic area; however, they sometimes make long overland or upstream-downstream 

movements (Reese 1996). Like the FYLF, the turtle prefers a variety of microhabitats for regulating 

body temperature, but basking sites are most important in the early season when air and water 

temperatures are relatively low. Basking is also important for females since elevated body 

temperature contributes to the development of the eggs.

Table 3.03-3 Occupied and Suitable Habitat for WPT in the Project Area 

Watershed and Streams 

(5th level HUC) Occupancy Survey Suitable(miles)

Suitable

(acres) UHA

Tuolumne River Yes Yes 36.5 8,711

Drew Creek Yes Yes 4.6 1,011

Grapevine Creek Yes Yes 10.8 2,565

Jawbone Creek Unknown Yes 14.3 3,411

Three unnamed ponds Unknown No 10.0 277

Middle Fork Tuolumne River Yes Yes 25.5 5,365

Abernathy Meadow Yes Yes 7.5 132

Grandfather Pond Yes Yes 0.2 82

Mud Lake Yes Yes 3.0 115

North Fork Tuolumne River Yes Yes 75 16,718

Basin Creek Unknown Yes 17.8 3,902

Hunter Creek Yes Yes 21.5 4,912

South Fork Tuolumne River Yes Yes 29.4 6,411

Cherry Creek Unknown No 17.8 3,737

Eleanor Creek Unknown No 2.3 599

Big Kibbie Pond Yes Yes 1.0 98

Little Kibbie Pond Yes Yes 0.5 86

Clavey River Yes Yes 29 3,460

Reed Creek Unknown Yes 4.2 904

North Fork Merced River Yes Yes 74.4 16,908

Bull Creek Yes Yes 44.7 9,879

Deer Lick Creek Unknown Yes 9.7 2,234

Moore Creek Yes Yes 11.9 2,767

Scott Creek Unknown Yes 1.9 453

UHA=Upland Habitat Acres (30-meter buffer)

While water is required for some life history aspects, the WPT can use seasonally wet habitats. 

During periods when the aquatic feature is dry, turtles can depart the feature for another nearby 

aquatic habitat or can venture into the terrestrial environment to aestivate. Aestivation is a seasonal 

reduction in activity and body function similar to hibernation. The turtles will locate a site where they 

can dig into the leaf duff, preferably with some overhead cover (shade), and wait until the rain 

81
Chapter 3.03 Stanislaus

Aquatic Species National Forest

replenishes the aquatic habitat. Turtles can also use the terrestrial environment during the winter. The 

behavior, overwintering, is similar to aestivation because they leave the water (around October), bury 

themselves into the leaf litter under trees or shrubs, and wait until spring. During this time, they may 

move about on the landscape or move to water then back to land. 

The WPT is often found in habitats occupied by the FYLF because they share many of the same 

habitat needs. On the Forest, almost all occurrences of turtles in streams are at elevations less than 

3,500 feet, but several populations are in ponds at elevations up to 5,400 feet. Table 3.03-3 shows the 

streams, ponds, and meadow with known WPT populations and lists the primary streams that provide 

suitable habitat for the turtle.

Hardhead

The hardhead is a large species of minnow that historically occurred in a narrow low-elevation zone, 

approximately 100 to 1,500 feet in elevation, in the foothills of the Sierra Nevada (Moyle 2002). 

Moyle (2002) included the hardhead as one component of an assemblage of native warm water 

species called the pikeminnow-hardhead-sucker assemblage. On the STF, California roach (a 

minnow), riffle sculpin, and rainbow trout could also occur with the hardhead in rivers with 

unregulated flows (no dams). The species description given in Moyle (2002) is the basis for the 

species and habitat description that follows. 

Hardhead can be found in a variety of flowing water habitats from large intermittent foothill streams 

to large rivers. Larger individuals are typically associated with deep pools while smaller individuals 

are associated with shallow waters along stream edges. For most of the year, the fish does not move 

extensively up- and downstream, opting to remain in a pool or series of pools linked by deep run 

habitat. Hardhead spawn in the spring (April and May) and may migrate upstream long distances in 

larger streams, especially those impacted by reservoirs. Like other minnows, hardhead likely spawn 

in gravel substrates in run habitat or at the tail-out of pool habitat. Older fish are omnivorous, feeding 

on a mix of filamentous algae and invertebrates (e.g., crayfish, aquatic insects). Smaller fish tend to 

feed more on aquatic insects or other small invertebrates (e.g., snails). Hardhead appear to prefer 

warm [greater than 20 degrees Centigrade (68 degrees Fahrenheit)] water, but like to have access to 

deeper, cool water as water temperatures increase throughout the summer. Alteration of habitat and 

streamflow by dams and the introduction of predatory fish (mainly bass) have had major impacts on 

the distribution and abundance of the hardhead. 

The status of hardhead in the Tuolumne River is unclear. There are no records of hardhead from 

above Don Pedro Reservoir, but Moyle (2002) indicates a dramatic population decline following 

impoundment of the Tuolumne River. However, streamflow is regulated in the Tuolumne all of the 

way up to O’Shaughnessy Dam and Dion Holm Powerhouse on Cherry Creek, a main tributary to the 

Tuolumne. Forest Service personnel have conducted snorkel surveys in the lower Clavey River and 

observed schools of large minnows; but, hardhead are difficult to differentiate from Sacramento 

pikeminnow when observed from a distance. Hardhead may persist in the lower Clavey River, North 

Fork Tuolumne River, and possibly Cherry Creek upstream of Holm Powerhouse. In addition, fish 

surveys conducted on the Tuolumne River upstream of Early Intake have not determined the presence 

of hardhead either [personal communication with Mike Horvath, San Francisco Public Utilities 

Commission (Hetch Hetchy Regional Water System, Natural Resources Division)].

Expected Post-Fire Watershed Response

The Rim Fire affected a large portion of the Tuolumne River watershed and the previously forested 

landscape has been altered sufficiently that many of the “normal” watershed processes have been 

altered, sometimes dramatically. These processes include erosion of soil from hillslopes and stream 

channels, storage and transport of sediment in stream channels, stream flow, LWD recruitment, and 

maintenance of cool water temperatures. Two years post fire sprouting species and others are 

returning and the high severity vegetation burn areas which average over 70% shrub cover.

82
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Draft Environmental Impact Statement and Environmental Consequences

Hillslope erosion is a natural process that typically occurs at very low rates [0.1 to 0.5 tons per acre 

(USDA 2013)] in forested conditions. This rate can increase tremendously in landscapes affected by 

wildfire, sometimes greater than four orders of magnitude (10 to greater than 100 tons per acre). 

Factors that contribute to the extent to which the soil erodes include, but are not limited to, soil 

texture, steepness of hillslope, amount of ground cover, and rainfall intensity. 

Given large increases in erosion in the fire area, there will be areas with large volumes of sediment 

delivered to stream channels. Many of the small streams will be drastically altered by this sediment 

with the most obvious change being the streambed covered with fine sediment (the stream is “silted 

in”). Using the recent Bagley Fire on the Shasta-Trinity National Forest as an example, Forest Service 

employees measured sediment depths in excess of one meter (3.3 feet) in some stream channels 

(USDA 2013). While this example is a “worst case scenario” (caused by two uncommonly large 

storm events separated by a short period of time), our observations at one stream in the fire area, 

Skunk Creek, indicated the sediment was 1 to 2 inches deep following a below average precipitation 

year with relatively low intensity precipitation (to date). When large volumes of sediment are 

delivered to a stream channel, habitat complexity is reduced as pool and run habitats fill in and the 

stream bottom becomes relatively uniform. In larger streams like the Clavey River, extensive 

sedimentation could occur, but major reductions in pool volume are not likely because the energy of 

the streamflow is enough to keep the sediment moving downstream. Post-fire erosion rates can return 

to pre-fire rates within five to ten years. As stated previously, substantial shrub re-growth is already 

reducing the magnitude of sediment movement a few years post-fire.

With the loss of vegetation and leaf duff layer on the ground, the amount of flow in the streams, both 

base flow and peak flow, is generally expected to increase. This is because the trees are no longer 

taking up water through their roots and transpiring that water through their leaves (base flow) and the 

water repellent layers will cause the water to run off of the soil surface without being absorbed into 

the leaf duff layer and soil (peak flow). Peak flows can increase many times over in watersheds with 

extensive high severity burn conditions, especially following periods of high intensity rainfall, or 

rainfall of long duration and large amounts. As the streamflow begins to peak after a heavy rainfall in 

a burned watershed, the channel and streambanks are scoured by the water and the banks are eroded 

away. This is called channel erosion and it can be a significant source of sediment after a fire. With 

the loss of trees and other vegetation transpiring water, base flows can increase several fold 

throughout the year. Exaggerated peak flows (compared to pre-fire) should continue for three to five 

years after the fire, and increased base flows could continue for many decades. 

The amount of sediment in the channel that is moved downstream or stored in the channel (and 

floodplains) depends on several factors, primarily streamflow and the gradient, or steepness, of the 

stream. In general, the steeper the stream is, the easier it is to transport the fine sediment downstream. 

Large streamflows have more energy than lesser flows and are capable of moving large quantities of 

sediment. In the five to ten years after the fire, channel conditions should be close to pre-fire 

conditions. 

LWD recruitment generally increases after a fire because fire-killed trees eventually fall. Some of the 

trees fall into streams where they can influence stream morphology by catching sediment upstream of 

the tree and creating pool habitat downstream of the tree. Log jams can effectively trap and store 

large volumes of sediment for very long periods of time (greater than 50 years). The sediment stored 

behind the LWD can become important habitat for many aquatic species. The recruitment of LWD in 

streams is highest in the 10 to 20 years following a fire.

Water temperatures generally increase in the post-fire environment. This is largely due to the loss of 

vegetation providing shade to the surface of the water. In heavily forested conditions, very little direct 

sunlight hits the water and cool or cold water temperatures are maintained. When canopy cover is 

lost, stream temperatures can increase five degrees Fahrenheit or more for several years following the 

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Chapter 3.03 Stanislaus

Aquatic Species National Forest

fire. Obligate riparian vegetation (examples, willow and alders) typically re-grows quickly and 

provides enough shade to maintain cool and cold water.

For the FYLF, the impact to aquatic habitat is based on expected post-fire watershed response at 

various watershed scales. The estimates rely on the following: 1) the extent to which a watershed was 

affected by fire, 2) the extent of high and moderate severity fire in a watershed, 3) stream gradient, 

and 4) sediment yield calculations when compared to pre-fire conditions. The Watershed Report 

provides a general narrative for how the primary watersheds (fifth and sixth level HUC) have 

responded post-fire, and those evaluations were used to put the FYLF watersheds into categories of 

watershed response.

Three general categories were used for these watersheds: low, moderate and high post-fire response. 

For the low category, the post-fire watershed responses may not be readily observable at suitable 

breeding sites. In moderate concern habitats, extensive sedimentation of all habitats is expected, but 

deep water habitats should be maintained by the scouring action of water. In high concern watersheds, 

major impacts are expected to all habitat types, especially significant reduction of pool and other deep 

water habitat. The ability to reproduce is considered to be a key factor in maintaining recruitment as 

the watersheds recover, because most populations are small and the loss of a recruitment class could 

have a population-level consequence. Deep water habitats are refuges and critical to overwintering 

success and escape from predation attempts. Table 3.03-4 lists the watersheds suitable for FYLF and 

the expected level of watershed response.

Table 3.03-4 Watersheds and Streams with FYLF Suitable Habitat with Watershed Post-fire Response

HUC Level and Name Stream Watershed

Response

5. Big Creek-Tuolumne River Big Creek Low

6. Grapevine Creek-Tuolumne River Tuolumne River, Indian Low

Grapevine Moderate

6. Jawbone Creek-Tuolumne River Tuolumne River Low

Drew Moderate

Alder, Corral, Jawbone High

5. North Fork Tuolumne River North Fork Tuolumne River, Basin Low

Hunter Moderate

5. Clavey River Clavey River Low

6. Lower Clavey River Clavey River Low

Unnamed Tributaries 1-5, Adams Gulch, Bear 

Springs, Bull Meadow, Indian Springs, Quilty

High

6. Middle Clavey River Clavey River, Cottonwood Low

Russell Moderate

6. Reed Creek Reed Creek Low

7. Lower Reed Creek Reed Creek Moderate

5. Cherry Creek Cherry Moderate

6. Lower Cherry Creek Granite High

5. Eleanor Creek1 Eleanor Creek Moderate

5. Falls Creek-Tuolumne River1 Tuolumne River Low

5. Middle Fork Tuolumne River1 Middle Fork Tuolumne River Moderate

5. South Fork Tuolumne River1 South Fork Tuolumne River Moderate

5. North Fork Merced River North Fork Merced, Bull, Deer Lick, Moore Creek, 

Scott Creek

Low

84
Rim Fire Reforestation (45612) Affected Environment

Draft Environmental Impact Statement and Environmental Consequences

Environmental Consequences

Alternative 1 (Proposed Action)

DIRECT AND INDIRECT EFFECTS

General Effects Common to all Species

Mortality and Injury

The use of heavy equipment, application of herbicides and implementation of prescribed fire all have 

the potential to directly injure or kill aquatic organisms, particularly those occupying upland habitats. 

While most organisms close to water would be expected to escape into the water, a typical behavioral 

response by the FYLF and WPT, equipment can run over individuals that fail to flee or are unable to 

move, and prescribed fire can injure or kill organisms that remain onsite.

Four herbicides are proposed for use under this alternative, for site preparation and release 

(glyphosate) and noxious weed eradication (glyphosate, clethodim, aminopyralid and clopyralid). 

“Hazard quotient” represents the ratio of toxicant exposure to a reference value that corresponds to a 

threshold of toxicity; a hazard quotient of “1” is the level at which adverse effects could occur. The 

SERA risk assessments prepared for the project indicate a hazard quotient of “1” is not expected to be 

exceeded for amphibians for any of the chemicals applied at specified application rates; sensitive fish 

were used as a proxy for amphibians when data was lacking. In most cases, hazard quotients were at 

least an order of magnitude less than 1. Under the unlikely event of “acute accidental” exposure, 

clethodim exceeds a hazard quotient of 1 for sensitive fish, with a value of 1.5; however, management 

requirements (e.g., refilling backpack sprayers away from water) are expected to reduce this risk to a 

very low level.

Physical Disturbance

Heavy equipment use or forest workers close to a stream could affect the behavior of aquatic 

organisms that are in the terrestrial environment. The typical response is for an individual to flee into 

water. Individuals typically hide under streambanks, rocks or logs for up to 30 minutes and then 

return to the edge of the stream. They seek refuge if disturbed again and typically stay submerged 

longer or move away from the disturbance. Physical disturbance may interrupt basking, sleeping, or 

foraging, creating the potential to affect physical well-being. A single instance of disturbance may 

have negligible or no effect on an individual, but repeated disturbance has the potential to affect the 

physiological fitness of individuals (Rodriguez-Prieto and Fernandez-Juricic 2005). 

Modification of Habitat

The primary impact to habitat expected from the proposed activities is an increase in sediment 

delivery caused by equipment operations on fire-affected soils; to a lesser extent, sediment increases 

can occur through hand methods (e.g., manual grubbing), prescribed fire, and the use of herbicides 

(e.g., slightly increased soil exposure to precipitation events from leaf loss). The operation of heavy 

equipment (e.g., deep tilling) on fire-impacted soils and in near stream environments can result in 

ground disturbance capable of mobilizing susceptible soil types. Numerous project units coincide 

with areas of moderate and high burn severity, conditions that are more sensitive to disturbance. 

These areas typically have alterations in soil structure that make them more vulnerable to erosion and 

lack beneficial ground cover which can reduce erosion rates; numerous protective measures are in 

place to minimize these potential effects (Chapters 3.11 and 3.15). 

Excess sediment can cause a reduction of deep water habitats (pools and runs), loss of microhabitat 

complexity and filling the streambed with fine sediment. Pool and run habitats can be filled by excess 

sediment, especially in low gradient (less than 2%) reaches. The energy of water in higher gradient 

reaches (greater than 5%) tends to have enough erosive force to keep pools scoured and deep water 

maintained, but the overall pool volume may be reduced in low energy sites as sediment accumulates 

85
Chapter 3.03 Stanislaus

Aquatic Species National Forest

at the edges and tail of the pool. Excess sediment also reduces microhabitat complexity and the spaces 

between streambed substrates by filling the streambed with finer sized sediments (silts and sands). In 

lower gradient streams, the overall depth of the stream is typically reduced as the streambed fills with 

sediment and the water spreads out in a thin layer across this sediment. The loss of the small changes 

in streambed depth reduce microhabitat elements by eliminating velocity refuges and filling the 

spaces between larger substrates (gravel, cobble, and boulder) that are used by some species for 

breeding, foraging, and hiding. The change in streambed also influences the production of aquatic 

insects that use, including very specialized use, microhabitats in otherwise unimpaired streams. 

Aquatic insects play key roles in the breakdown of organic matter entering streams, nutrient cycling, 

and as sources of food for many aquatic and terrestrial species. Project protective measures are 

expected to reduce the risk and magnitude of these potential effects to low levels (Chapters 3.11 and 

3.15). Sediment would be expected to return to natural levels within a few years after project 

implementation.

Though observable direct effects to aquatic species are not expected to occur from herbicide use, 

effects to habitat are expected. The primary effect would be the reduction of terrestrial vegetation 

cover (mostly shrubs) in the short-term, while more rapid growth and distribution of tree-type 

vegetation is anticipated in the longer term. Most of this reduction is expected to occur away from 

waterbodies, as existing riparian vegetation would be left intact. Vegetation recovery would be 

variable in both spatial and temporal contexts, as multiple herbicide applications could occur in some 

areas. Indirect effects are also possible as a result of changes to aquatic and terrestrial food sources. 

For example, macrophytes, algae, and some invertebrates could be affected by herbicide use, as they 

are generally much more sensitive to herbicide effects (risk assessment worksheets) than vertebrate 

species. In the absence of an “accidental acute” exposure scenario, these potential effects would likely 

be limited to a very small percentage of project waters due to multiple management requirements that 

limit treatment near water and existing riparian vegetation.

LWD plays very important roles in the development of habitat complexity and sediment retention in a 

stream (USDA 1988; Montgomery et al. 1996; May and Gresswell 2003). It may take several 

centuries (greater than 300 years) for some portions of the forest to regrow large trees. This 

alternative is designed to hasten the growth of trees as compared to natural recovery rates, reducing 

the time necessary to create LWD for recruitment to aquatic habitats.

California Red-legged Frog

Direct and indirect effects to individual California red-legged frog individuals include disturbance, 

injury or mortality, and reduced fitness as a result of repeated disturbance or a reduced food supply. 

Because California red-legged frog is considered to be extirpated from the Tuolumne River basin 

(USFWS 2002) these effects are discountable. However, because extensive surveys to confirm this 

have not been completed for the frog within the project area and suitable physical habitat exists, these 

potential effects will be discussed.

Direct and indirect effects to habitat include a reduction in shade that can result in increased water 

temperatures; reduction in large downed wood recruitment that can alter stream form and limit 

creation of downstream habitat (pools) and reduce cover in upland areas; streambank damage from 

operation of equipment; a risk of chemical contamination from herbicide use, and increased 

sedimentation as a result of mechanical operations. As stated previously, numerous protective 

measures (e.g., BMPs, project management requirements) are in place to minimize or prevent these 

effects.

Effects to individuals are mainly associated with the operation of equipment, presence of forest 

workers in suitable habitats for the frog, prescribed fire, and potential water drafting. If equipment 

operates in suitable habitat, there is the risk of injury or mortality when the disturbance is initiated. As 

activities move further from aquatic habitat the risk is reduced, although California red-legged frogs 

86
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Draft Environmental Impact Statement and Environmental Consequences

can be found in the upland habitat for extended periods in rodent burrows or under available cover 

(moist vegetation and downed wood). Any frogs in the upland habitat could be vulnerable to crushing 

if the equipment hits or runs over the cover object. As the amount of activity in the upland habitat 

increases, so does the risk. Because red-legged frog are considered extirpated from the Tuolumne 

River basin, this risk is expected to be very low. The amount of are proposed for treatment within 

upland habitat is used as an indicator of risk. 

As stated above, physical disturbance is also a direct impact to individuals and is associated with 

equipment operation and forest workers in close proximity to suitable habitats. Red-legged frog are 

generally associated with aquatic habitats, but can be found in upland habitats for extended times. 

Many overland movements of red-legged frogs are associated with the wet season when 

implementation activities are stopped. Because the risk of direct impact is highest when equipment 

works in close proximity to the water, the amount of potentially suitable habitat near water and 

overlapping proposed activities is used as an indicator of risk. Table 3.03-5 identifies the number of 

miles and acres for each species.

Indirect impacts to individuals can occur when excessive sedimentation modifies habitat. When

excess sediment is supplied to a stream, deep water habitat can be reduced, the spaces between and 

under stream substrates (interstitial spaces) are filled in, and sediment covers suitable foraging 

substrates. Depth reduction of deep water habitats (pools and runs) can affect availability of breeding 

habitat. If the reduction of depth persists over many years, there could be population level impacts 

because reproductive success would be periodically reduced or eliminated. Excessive sedimentation 

also can fill in interstitial spaces and reduce the instream overhead cover available to all life stages. 

Red-legged frog tadpoles typically retreat to deep water and have also been observed burrowing in to 

sediment to escape (Bobzein and Didonato 2007). An increase in predation could result if these 

refuge habitats are limited. California red-legged frog tadpoles feed on algae and adult frogs feed on 

macroinvertebrates (Federal Register 2010). In stream habitats the larger substrates provide the algal 

resources. As excessive sedimentation begins to cover the streambed, the substrates used for foraging 

can also be covered, thereby resulting in decreased opportunities for feeding. The consequences of 

reduced food supply for tadpoles means slightly longer developmental time to metamorphosis and 

reduced size at metamorphosis. Longer developmental times could increase predation risk as 

metamorphosis occurs and tadpoles are less mobile due to presence of legs and the physiological cost 

of transforming the body. Smaller size at metamorphosis could affect individual survivorship over 

winter. Project management requirements are expected to reduce potential impacts (Chapter 2.02).

Herbicide use within potential habitat, both near aquatic and upland (up to 1 mile from suitable 

breeding sites), is restricted to glyphosate and aminopyralid formulations. These two herbicides are 

commonly used near aquatic habitat due to their lower toxicity to aquatic organisms. Risk 

assessments for this project show low risk to individual amphibians under the expected exposure 

scenarios. As stated previously, risk is further reduced because it is unlikely this species are present.

Effects to habitat should be mostly limited to a short-term reduction in vegetative cover in the upland 

terrestrial environment, most of which will be located a substantial distance from aquatic habitat due 

to project protective measures (Chapter 2.02); riparian impacts, such as temperature change due to 

near-water vegetation removal are not expected to occur due to these protective measures. The 

operation of equipment and use of herbicides can potentially damage cover in upland habitats as 

vehicles crush vegetation and displace large woody debris. The loss of cover could negatively impact 

the ability of red-legged frogs to forage or hide from predators. Equipment could also crush partially 

decayed logs and reduce potential refuge habitat under the log, though much of this cover type was 

lost in the fire. The consequences of the loss of cover provided by riparian vegetation would be very 

minor, because the extent of habitat loss would be limited to the few areas where equipment operation 

would occur in suitable habitat, and temporary, because the near-ground vegetation would likely 

regrow within a few years. The project is expected to increase the rate of tree growth, both for planted 

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Chapter 3.03 Stanislaus

Aquatic Species National Forest

conifers and most remaining native tree species, the majority of which would occur outside areas 

where riparian vegetation is re-establishing naturally.

An increase in the rate of sediment delivery to streams following deep tilling, machine piling, pile 

burning, and to a lesser extent, herbicide use and manual release methods could occur. These 

activities create soil disturbance and compaction that can lead to increased erosion and sedimentation. 

Vegetation removal has a potential for increasing sediment delivery to aquatic systems because 

ground based equipment creates soil disturbance, some of which may be mobilized during 

precipitation events. However, the potential for biologically important levels of sedimentation is low 

because the area affected represents a very minor percentage of total near-water area. Pile burning 

also creates the potential for slight increases in sediment because the burn piles can cause localized 

soil hydrophobicity under the fire due to high temperatures and relatively long residence time. The 

potential for extensive off site soil movement is low because the piles tend to be small (20 to 50 

square feet), but machine piles can have a much larger footprint (1,000 to 5,000 square feet). 

Herbicide use for site preparation, release and noxious weed abatement would reduce near-ground 

cover for a period of a few years. Noxious weed treatments would only treat the targeted invasives, 

allowing for an increase in native vegetation within a few years, an outcome that is assumed to be 

beneficial to native amphibians. 

LWD should not be displaced in near-water habitat during mechanical site preparation treatments. 

Only small diameter trees would be piled and this would only occur in a minority of these areas.

Water drafting is required by the project for dust abatement on roads when thinning existing 

plantations. Drafting has the potential to suck in tadpoles (entrainment) or other small life stages as 

the pump pulls water from a stream. Entrainment and passage through the pump could be fatal to 

individuals or if the water is dispensed on a road or during fuels management activities (pile burning) 

in an upland area, mortality would likely result. The operation of the drafting pumps generate noise 

and workers attending to the pumps also create a source of physical disturbance. To mitigate the 

potential for entrainment, the management requirement applied to drafting operations includes use of 

low intake velocity pumps and a screening device placed around the pump intake. 

Table 3.03-5 CRLF and SNYLF Direct and Indirect Effect Indicators for Each Alternative

Indicator Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5

California red-legged frog

Miles of stream habitat within units 12.4 0 12.4 1.2 12.4

Acres of breeding ponds within units 0 0 0 0 0

Acres of habitat within units – all treatment 

types1

4,044.0 

(18.7%)

0

(0%)

4,044.0 

(18.7%)

459.7

(2.1%)

4,044.0

(18.7%)

Herbicide use for noxious weeds2 577.9 0 0 0 577.9

Sierra Nevada yellow-legged frog

Miles of suitable breeding /non-breeding 

stream within units

0.4 0 0.4 0 0.4

Acres of breeding/non-breeding ponds 

within units

0.8 0 0.8 0 0.8

Acres of upland habitat within units – all 

treatment types

2.0 0 2.0 0 2.0

Herbicide (within 107 feet) near-stream for 

reforestation or noxious weeds

0 0 0 0 0

1 Includes near-aquatic and upland habitat combined. Percents represent the percent of the total in the Rim Reforestation project area. 2 Majority (>90%) of acreage overlaps with reforestation units, where only glyphosate is proposed for treatment. Only glyphosate and 

aminopyralid are allowed in California red-legged frog terrestrial habitat, with no application to aquatic habitat. 

88
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Draft Environmental Impact Statement and Environmental Consequences

Birch and Mud Lakes

No activities are proposed in the immediate vicinity of Mud Lake and all proposed activities occur 

downstream and/or downslope of the breeding habitat. No risk of injury or disturbance at the breeding 

habitat exists. No risk of increased sediment reaching the ponds due to project activities exists, or in 

reduced shading and an associated increase in temperature. The habitat suitability of the ponds would

remain low post-implementation. 

About 0.8 miles of non-breeding stream habitat overlaps proposed reforestation units. Minor 

quantities of sediment may enter the non-breeding aquatic habitat due to reforestation treatments.

Removal of small quantities of small diameter trees is not expected to reduce shade to an extent that 

would lead to increased water temperatures. LWD recruitment would not be affected along the nonbreeding stream segments.

Approximately 10% of available upland habitat would be treated mechanically and with herbicide 

(glyphosate). These activities can decrease post-fire re-growth that has occurred in the short-term; an 

increase in conifer re-growth is expected in the longer term, while existing riparian vegetation is 

expected to remain largely unaffected. There are no activities proposed within the dispersal habitat 

between Birch and Mud Lakes. 

Drew Creek

The breeding habitat along Drew Creek is not included within any proposed reforestation units and no 

risk of disturbance to breeding habitat exists. Only a few acres of reforestation treatments are 

proposed along non-breeding stream habitat. The small area of anticipated disturbance is not expected 

to result in detectable sediment above the background of the post Rim Fire erosion. 

The proposed activities would not measurably alter stream shading. There is very little activity 

proposed in this habitat area adjacent to streams. 

Noxious weed treatment would occur along about 0.56 miles of non-breeding stream, and within 120 

acres (less than 5% of total upland habitat). Glyphosate and aminopyralid are proposed in this area.

Near-ground cover would be reduced for a few years after application of glyphosate, but 

aminopyralid would only be applied to the noxious weeds and would have little effect on native 

plants. Native plant species would re-colonize and occupy the majority of treated areas posttreatment, which is assumed to be a benefit for all native amphibian species.

If any California red-legged frogs are in the upland habitat at the time of activities, they would be at 

risk for disturbance or injury. Dispersal in the habitat occurs along Drew Creek and proposed 

activities would have no effect on the existing habitat.

Harden Flat Ponds

No reforestation treatments are proposed near the ponds and no risk of injury or disturbance at the 

breeding habitat. No risk of increased sediment reaching the ponds exists and the habitat suitability of 

the pond would remain unchanged. 

About 0.25 miles of non-breeding stream habitat and 300 acres (less than 50% of available habitat) of 

upland habitat overlap proposed reforestation units. It is possible that implementation activities could 

result in some erosion and small quantities of sediment delivery to the stream. Removal of generally 

small diameter trees is not expected to reduce shade to an extent that would lead to increased water 

temperatures. LWD recruitment would not be effected. Reforestation activities can decrease cover 

and set back vegetative regrowth by a few years.

About 2 acres of available upland habitat is proposed for noxious weed treatment. Risk assessments 

indicate that herbicide concentrations would remain below levels capable of directly affecting 

amphibians; the risk assessments do not consider project management requirements (e.g., application 

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buffers), which are expected to further reduce/prevent the risk of herbicide contamination. Some nearground cover would be reduced for a few years after application, but noxious weed applications target 

the invasive species specifically and should not impact most other plants in the area. Presumably, 

native plant species would occupy the majority of these areas post-treatment, which is assumed to be 

a benefit for all native amphibian species. Both glyphosate and aminopyralid are proposed for 

noxious weed eradication, while reforestation treatments are only proposing glyphosate. 

Homestead Pond

No reforestation units are located near Homestead pond. No risk of injury or disturbance at the 

breeding habitat or impact to habitat suitability of the pond would occur. 

About 0.36 miles of non-breeding stream habitat and 285 acres (less than 20% of available habitat) of 

upland habitat overlap proposed reforestation units. It is likely that implementation activities would 

result in some erosion and there would be some sediment delivery to the stream. Removal of 

generally small diameter trees is not expected to reduce shade to an extent that would lead to 

increased water temperatures. Reforestation activities can further decrease cover from the effects of 

the fire, and can set back vegetative regrowth by a few years. If any California red-legged frogs are in 

the upland habitat at the time of reforestation activities, they would be at risk for disturbance or 

injury.

About 300 acres of available upland habitat is proposed for noxious weed treatment, with 0.36 miles 

of stream habitat contained within these areas. The majority of this acreage overlaps with the 285 

acres of reforestation units. One unit is located approximately 100 feet west of Homestead pond; this 

distance is expected to be sufficient in preventing any herbicide contamination. Risk assessments 

indicate that herbicide concentrations would remain below levels capable of directly affecting 

amphibians; the risk assessments do not consider project management requirements (e.g., application 

buffers), which are expected to further reduce/prevent the risk of herbicide contamination. Nearground cover would be reduced for a few years after application. Native plant species would recolonize and occupy the treated areas and this is assumed to be a benefit for all native amphibian 

species. Both glyphosate and aminopyralid could be used for eradication treatments, while 

reforestation only proposes the use of glyphosate. 

Hunter Creek and Ponds

No reforestation units are located near the ponds. There is no risk of injury or disturbance at the 

breeding habitat. There is no risk of increased sediment reaching the ponds due to project activities, 

or in reduced shading and an associated increase in temperature. The habitat suitability of the ponds 

would remain the same. 

About 11 miles of stream habitat (2 miles are potential breeding habitat), and 3,000 acres (less than 

35%) of upland habitat overlap proposed reforestation units. It is likely that implementation activities 

would result in some erosion and there would be some sediment delivery to the stream. Removal of 

generally small diameter trees is not expected to reduce shade to an extent that would lead to 

increased water temperatures. LWD recruitment may be slightly reduced along the non-breeding 

stream segments, but most would be small diameter. Reforestation activities can decrease cover and 

can set back vegetative regrowth by a few years. If any California red-legged frogs are in the upland 

habitat at the time of reforestation activities, they would be at risk for disturbance or injury.

About 150 acres of available upland habitat is proposed for noxious weed treatment, with 2.5 miles of 

stream habitat contained within these units. Risk assessments indicate that herbicide concentrations 

would remain below levels capable of directly affecting amphibians; the risk assessments do not 

consider project management requirements (e.g., application buffers), which are expected to further 

reduce/prevent the risk of herbicide contamination. Near-ground cover would be reduced for a few 

years after application. Presumably, native plant species would re-colonize and occupy the majority 

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of treated areas post-treatment, which is assumed to be a benefit for all native amphibian species. 

Both glyphosate and aminopyralid could be used in noxious weeds units, while reforestation units 

without noxious weeds would be treated with glyphosate only. 

Sierra Nevada Yellow-legged Frog

Despite extensive surveys of suitable habitat no SNYLF have been found within the project area and 

most habitat is of relatively low quality. Because occupancy is not definitively known in all areas, 

effects to individuals are considered. A more comprehensive, detailed description of effects is 

available in the Biological Assessment and Biological Evaluation.

Proposed activities overlap 0.4 miles of stream and 0.8 acres of pond habitat (Table 3.03-5). Survey 

efforts at the Kibbie Ponds have been adequate to determine the ponds are unoccupied and therefore 

no impacts to individuals are expected to occur. 

About 2 acres of treatment are proposed within 82 feet of potential habitat along the Middle Fork 

Tuolumne River at the border with Yosemite National Park. These units are proposed for thinning 

only. Direct impacts to individuals from tree felling could theoretically occur, though the likelihood is 

low because these large streams are atypical of SNYLF habitats on the forest and have self-sustaining 

populations of fish. In addition, occupancy is very unlikely at these sites and the risk to individuals is 

very low. SNYLF hiding in burn piles could be killed, injured, or disturbed if they are present when 

piles are ignited. Project management requirements ensure burn piles are located a minimum of 50 

feet from perennial and intermittent streams and other special aquatic features to mitigate this risk.

Due to the very small quantity of upland treatment (2 acres) habitat effects are expected to be very 

minimal. Herbicide effects should be absent since none are proposed for use within 107 feet of 

suitable SNYLF habitat. No measureable change to habitat suitability is expected.

Foothill Yellow-legged Frog

Only Grapevine Creek has occupied FYLF habitat and the potential for direct effects from the 

proposed treatments. All other known occupied sites do not have proposed units within 100 feet of 

aquatic habitat. This analysis assumes that the vast majority of effects would originate due to 

activities within the 100-foot strip along streams; however, it is recognized that small quantities of 

sediment increase could originate from outside this area. Sediment analysis at a watershed scale is 

provided in the project watershed report. 

This analysis uses a small (hydrologic unit code 7) watershed approach to estimate effects for all 

suitable habitat, with the assumption that these areas could theoretically become occupied over the 

project timeframe. Project activities within 100 feet of suitable habitat are quantified.

Table 3.03-6 shows that some sub-watersheds have a high percentage of habitat proposed for 

treatment, however, risk to individuals is substantially reduced due to project management 

requirements that prohibit most treatment near water. For example, heavy equipment would not 

operate near water (equipment exclusion zone) and existing riparian vegetation would be left intact. 

This species is highly aquatic and generally stays within a few feet of water, therefore treatment is 

unlikely to directly injure or kill individual frogs, though nearby activities may alter behavior (e.g., 

flee response). Presumably, those sub-watersheds with the highest percentage of treatment would 

have a correspondingly greater risk of creating behavioral disturbance.

The primary anticipated indirect effect is the increase of sediment delivery to the streams following 

reforestation actions. Heavy equipment use, such as tilling, would likely increase sediment yield in 

some areas (watershed report) for up to a few years, though the magnitude of potential increase is 

expected to be low. Removal or modification of vegetative cover through a variety of activities (e.g., 

mastication, herbicides, prescribed fire) would also affect terrestrial habitat. Other cover types, such 

as rodent burrows, could also be modified by heavy equipment use. Most of this activity would occur 

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in the middle and upper portion of the 100-foot buffer, which are areas less-utilized by the highly 

aquatic FYLF; therefore, the majority of utilized terrestrial habitat is likely to remain suitable.

Herbicide use poses risks to aquatic organisms, though observable direct effects to frogs are not 

expected and are below the threshold of concern (hazard quotient less than 1) (SERA risk 

assessments). Glyphosate (aquatic label) would be the herbicide used over the large majority of 

treated areas. As stated previously in the general effects discussion, it is possible that food organisms 

utilized by FYLF could be affected (directly or indirectly) if estimated concentrations (SERA risk 

assessments) were to occur. However, estimated concentrations do not consider project management 

requirements (Chapter 2.02) which would help mitigate potential indirect effects to aquatic organisms 

consumed by FYLF. Therefore, any effects would be spatially isolated and of low magnitude, with 

fast recovery likely.

Table 3.03-6 Alternative 1: Buffer Treatment in FYLF Suitable Habitat

Sub-watershed (HUC 7) FYLF1

Treated

REF/THIN2

(acres)

WEED3

(acres)

Ackerson Creek <1 3 2

Bear Springs Creek-Lower Clavey River 10 44 6

Bull Meadow Creek-Lower Clavey River 24 107 68

Cherry Lake 38 108 <1

Clavey River <1 2 0

Corral Creek 77 210 101

Cottonwood Creek 12 34 0

Deer Lick Creek 52 14 2

Granite Creek 48 209 142

Grapevine Creek 49 144 42

Gravel Range-Tuolumne River 10 46 34

Headwaters Upper North Fork Merced River 4 10 0

Hull Creek <1 0 <1

Hunter Creek 33 120 4

Lower Eleanor Creek-6 0 0 0

Lower Jawbone Creek 27 75 14

Lower Middle Fork Tuolumne River East 44 193 19

Lower Middle Fork Tuolumne River West 34 207 47

Lower South Fork Tuolumne River East 12 212 34

Lower South Fork Tuolumne River West 19 108 1

Middle Fork Day Use (Upper Middle Fork Tuolumne River) 15 20 1

Middle Jawbone Creek 13 60 0

Moore Creek-Upper North Fork Merced River 36 13 11

North Crane Creek-Upper South Fork Tuolumne River <1 1 0

Quilty Creek-Lower Clavey River 5 9 0

Reed Creek 32 144 141

Reynolds Creek 3 17 0

Two Mile Creek 2 7 0

Upper Bull Creek 38 6 0

Upper Jawbone Creek 27 134 30

Upper South Fork Tuolumne River West 1 6 0

THIN=Thin Existing Plantations; REF=Reforestation; WEED=Noxious Weed Eradication 1 Percent of total 30 meter buffer treated within FYLF Sub-Watershed. 2 FYLF Buffer Affected 3 Most noxious weed populations overlap spatially with other treatment units.

Western pond turtle

The risk of detrimental direct effects to the western pond turtle (WPT) is higher than for the FYLF

because the turtle uses the uplands more extensively during different times of the year. WPT can use 

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upland habitats up to 400 meters away from an aquatic habitat and can occur in upland habitats for 

overwintering, nesting, and aestivation. In general, turtles remain close to water from early spring 

through early fall, but in habitats with seasonal water, they can move into upland habitat when the 

seasonal feature is dry. Table 3.03-7 provides a description of the amount of proposed treatment area 

overlapping WPT habitat.

Table 3.03-7 shows that some sub-watersheds have a high percentage of habitat area proposed for 

treatment, though the majority are not currently occupied by WPT. In areas where project units 

overlap with known occupied sites (e.g., Abernathy Meadow, Kibbie Ridge Ponds), risks to 

individuals is substantially reduced by species-specific project management requirements (Chapter 

2.02). 

Management requirements would provide some level of protection for known turtle populations, 

though direct effects could occur since this species commonly utilizes terrestrial habitat far from 

water. In addition, behavior could be affected by treatment activities. The risk is substantially higher 

in areas where the turtles are not known to occur due to more intensive treatment near suitable 

habitat. If turtles are present but not discovered prior to or during project implementation, it is likely 

that a portion of the localized population could be injured or killed by heavy equipment (e.g., from 

tilling, masticating) or prescribed fire. Turtles may overwinter in the upland from October through 

April, but heavy equipment use would be unlikely at this time of year due to machinery operational 

constraints associated with soil compaction risk. During June and July, the WPT could use the 

uplands for nesting, but the availability of nesting habitat is very limited and restricted to relatively 

open, herbaceous dominated slopes. The risk increases to moderate in October if ground-disturbing 

activities continue late into the year because the turtles move into the upland habitat as the weather 

gets colder. Though short-term (few years) habitat modification is expected, the level of potential 

impact at these locations would not be sufficient to affect the long-term viability of any existing 

population. 

The primary anticipated indirect effect is the small increase of sediment delivery to water bodies 

following reforestation actions. Heavy equipment use, such as tilling, would likely increase sediment 

yield in some areas (watershed report) for a few years. Removal of vegetative cover through a variety 

of activities (e.g., mastication, herbicides, prescribed fire) would also affect terrestrial habitat. Other 

cover types could also be modified by heavy equipment use. Large woody debris (LWD), an 

important habitat component for WPT, is expected to be minimally affected, as nearly all modified or 

removed vegetation is expected to be of small diameter and not suitable for basking. Table 3.03-7 

indicates the quantity of habitat modification likely to occur in each project sub-watershed (within 

300-meter buffer).

Herbicide use poses risks to aquatic organisms, though observable direct effects to turtles are not 

expected and are below the threshold of concern (hazard quotient less than 1) (SERA risk 

assessments). Glyphosate (aquatic label) would be the herbicide used over the large majority of 

treated areas. As stated previously in the general effects discussion, it is possible that food organisms 

utilized by WPT could be affected (directly or indirectly) if estimated concentrations were to occur. 

However, estimated concentrations do not consider project management requirements (list above) 

which are likely to prevent or further reduce observable changes to food sources. Any potential 

effects would likely be short-term.

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Table 3.03-7 Alternative 1: WPT Buffer Affected Units

Sub-watershed (HUC 7) WPT1

Treated

REF/THIN2

(acres)

WEED3

(acres)

Stream buffer

Ackerson Creek 3 146 55

Basin Creek 1 5 0

Bear Springs Creek-Lower Clavey River 14 545 60

Bull Meadow Creek-Lower Clavey River 32 1152 550

Cherry Canyon-East Fork Cherry Creek 0 0 0

Cherry Lake 36 1168 1

Clavey River 1 30 0

Corral Creek 69 1781 841

Cottonwood Creek 13 334 15

Deer Lick Creek 32 147 10

Granite Creek 41 1167 614

Grapevine Creek 54 1505 72

Gravel Range-Tuolumne River 13 504 284

Headwaters Upper North Fork Merced River 8 170 1

Hull Creek 4 109 <1

Hunter Creek 31 1082 14

Kibbie Ridge-Lower Cherry Creek <1 10 0

Lower Eleanor Creek-6 1 21 0

Lower Jawbone Creek 30 732 88

Lower Middle Fork Tuolumne River East 48 1898 118

Lower Middle Fork Tuolumne River West 36 1815 284

Lower South Fork Tuolumne River East 28 2314 227

Lower South Fork Tuolumne River West 23 1070 9

Middle Fork Day Use (Upper Middle Fork Tuolumne River) 21 247 21

Middle Jawbone Creek 17 534 9

Moore Creek-Upper North Fork Merced River 37 198 110

North Crane Creek-Upper South Fork Tuolumne River 1 36 0

Plum Flat-Lower Cherry Creek <1 6 <1

Poopenaut Valley West <1 12 0

Quilty Creek-Lower Clavey River 14 198 28

Reed Creek 36 1448 1019

Reynolds Creek 7 353 0

Sugarloaf-Tuolumne River <1 5 23

Two Mile Creek 3 88 0

Upper Bull Creek 30 83 0

Upper Jawbone Creek 36 1622 127

Upper South Fork Tuolumne River West 1 41 0

Pond buffer

Cherry Lake 3 34 0

Granite Creek 24 115 19

Kibbie Ridge-Lower Cherry Creek 2 11 0

Lower Eleanor Creek-6 1 24 0

Lower Jawbone Creek 0 1 0

Lower Middle Fork Tuolumne River East 12 56 1

Lower South Fork Tuolumne River East 26 59 18

Lower South Fork Tuolumne River West 2 8 0

Middle Fork Day Use (Upper Middle Fork Tuolumne River) 28 17 5

Middle Jawbone Creek 9 80 <1

Reynolds Creek 6 9 0

Upper Jawbone Creek 16 165 14

THIN=Thin Existing Plantations; REF=Reforestation; WEED=Noxious Weed Eradication 1 Percent of 300-meter (984 feet) buffer treated, 2 WPT Buffer Affected 3 Most noxious weed populations overlap spatially with other treatment units.

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Draft Environmental Impact Statement and Environmental Consequences

Hardhead

Because very few proposed treatment units are within close proximity to suitable habitat no direct 

effects would occur to hardhead. 

The indirect effect to hardhead is only related to sediment. Because a very small portion (less than 

3%) of the North Fork Tuolumne River watershed burned at moderate severity (no high severity soil 

burn conditions), there would be no observable change to habitat conditions in the lower river. 

Because the Tuolumne River does not provide suitable breeding habitat for the hardhead (due to 

regulated streamflow), no indirect impacts on spawning habitat suitability would occur. Localized 

accumulations of sediment near the mouths of tributary streams that had a high proportion of high and 

moderate severity fire, but the sediment from all watershed sources (including the proposed project) 

would not be sufficient to have much of an effect on pool and deep run habitats. 

CUMULATIVE EFFECTS

The primary pathways considered for cumulative effects to the CRLF and SNYLF are; 1) the 

potential risk of directly impacting individuals or their habitats, and 2) the risk of increased 

sedimentation in the habitats.

The Cumulative Watershed Effects analysis for the project provides a general view of treatment 

effects as compared to the total from this project and all other actions listed in Appendix B. 

Calculations for five sub-watersheds (7th field HUC) indicated that total effects, expressed as 

Equivalent Roaded Acres (ERA), are highly variable. In the first few years of treatment, Alternative 

one would likely contribute between 10 to 50% of total effects, depending on sub-watershed.

Vegetation management on private lands and livestock grazing were the two types of cumulative 

effect stressors evaluated for the FYLF, WPT, and hardhead. These two types of actions are 

considered to have the most detectable influence on aquatic systems, especially in the post-fire 

environment. The impact of post-fire logging was discussed earlier in this document and this activity 

has the highest potential to increase erosion and sedimentation rates in a watershed. Livestock grazing 

is also discussed because the impact of concentrated livestock use in riparian areas (made more 

sensitive by moderate and high soil burn severity conditions) may have localized impacts to 

streambanks and the reestablishment of riparian vegetation. 

Livestock grazing as a cumulative stressor is discussed at a general level, because there is uncertainty 

regarding Forest Service administration of permits for allotments affected by the fire. Livestock may 

be excluded, partially or fully, from some allotments within the Rim Fire perimeter in the next few 

years. Assuming the Forest Service allows light levels of grazing in portions of the allotments, 

livestock could impact sensitive streambanks through trampling. Streambanks are more sensitive 

post-fire than in unburned conditions because much of the vegetation has been burned and there is 

little root holding capacity to resist shearing by hooves. This is especially true in low gradient reaches 

(less than 2%) where alluvial (or depositional) banks dominate. In steeper gradient reaches, the 

streambanks tend to be more armored by larger diameter substrates (rocks like cobble and boulder) 

and resistant to bank shear. These localized areas of streambank disturbance may not have much of an 

effect at larger watershed scales, but they can influence sedimentation at locally important scales. If 

livestock are allowed to graze portions of the allotments, a small increase in sedimentation would be 

expected along low gradient reaches with no discernible increase along higher gradient sections. 

However, any impact in watersheds with high levels of project actions (e.g., greater than 25% of 

FYLF and WPT buffer) could cumulatively contribute to degradation of aquatic habitat. The duration 

of this combined reduction in habitat suitability would be two to three years. After this period, 

hillslope erosion rates would quickly decrease and habitat suitability would increase to moderate 

levels.

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Another impact associated with livestock is the potential impaired recovery of riparian vegetation

because livestock can affect the recovery of obligate woody and herbaceous riparian species. The 

rapidly re-growing riparian vegetation is always a good food source, but especially late in the season 

when other forage options may have decreased in palatability. The proximity of this forage to water, 

another critical resource need for livestock, suggests livestock may congregate in sensitive post-fire 

riparian areas. Project activities would minimally affect riparian vegetation, so very little cumulative 

effect to riparian recovery is expected. 

California Red-legged Frog

Approximately 50% (about 2,000 acres) of available CRLF habitat is located within grazing 

allotments. This analysis assumes that grazing could occur within all allotments.

Livestock grazing in close proximity to streams has the potential to impact streambank stability 

through trampling and chiseling of the banks by cow hooves. Overall, the effect of livestock grazing 

relative to sedimentation is considered to be minor and is expected to recur on an annual basis. The 

minor amount of sediment attributable to grazing would potentially combine with sediment associated 

with implementation of this project. Combined, the sediment could impact slow water habitats and 

may be observable as a light dusting of silt in slow water habitats or small pockets of fine sands 

accruing behind larger stream substrates (cobbles and boulders) and in the slowest velocity areas of 

pools. This type of sediment impact is not expected to significantly reduce pool volume or the spaces 

between streambed substrates where individuals could seek refuge from predation. This type of 

sedimentation pattern would not impair foraging habitat for tadpoles to the extent that growth and 

development are impacted.

Livestock grazing could also limit the regrowth of obligate riparian species (e.g., willows, alders, 

aspen) that were impacted by the fire. If the fire effectively killed the above ground portions of these 

types of riparian vegetation, the plant responds by sending up new growth from the roots or root 

crown. These new shoots capitalize on the extensive root system that was developed by the plant by 

growing rapidly and re-establishing riparian cover in the long-term. Cattle do browse this new growth 

because it is very nutritive, but they tend to preferentially graze these plants late in the season when 

other upland forage (especially sedges) has lost its nutritional value. If the livestock greatly reduce the 

amount of regrowing vegetation, the shading and leaf fall provided by these plants would be reduced. 

The CRLF can be found in full sun habitats, but a mix of shaded conditions allows the animal to 

effectively control body temperature while not moving great distances to find a satisfactory resting 

place. The annual leaf fall by obligate riparian plants also provides a beneficial resource to streams 

through nutrients dissolved in the water and organic matter added to the stream. Primary productivity, 

the growth of algae and other biological films forming on streambed substrates, is greatly influenced 

by the nutrients dissolved from the leaves. These biological films are very important food sources for 

the frog at the tadpole stage since they are algal grazers. The organic material provided by the leaves 

is also used by many species of aquatic insects that either ingest portions of the leaves or use the 

leaves in other ways (for example, caddisfly cases). The adult forms of these aquatic insects are 

seasonally important food sources for post-metamorphic frogs. Excessive impacts to regrowing 

riparian vegetation would have moderate impacts on stream shading in the short- to mid-term (3-10 

years) and a very minor impact on aquatic insect and primary productivity. 

Other federal actions could impact about 78 additional acres, only a few acres located adjacent to 

water. As compared to the project and grazing impacts, this additional disturbance would be very 

minor. 

In the Hunter Creek habitat unit, private lands are present to the north and east. The majority of these 

lands are located away from water. Timber harvest and other ground-disturbing activities could 

contribute to project effects through vegetation removal and sediment increase, but are unlikely to 

contribute substantial effects due to the relatively small percentage of total habitat affected.

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Sierra Nevada Yellow-legged Frog

Ground disturbance from implementation of the Rim Fire Reforestation Project is expected to occur 

adjacent to the Kibbie Ridge ponds. Project management requirements are expected to minimize 

habitat effects near aquatic habitat, and would roughly equate to those effects expected from this 

project. No other actions were identified within these areas that could contribute to cumulative 

effects.

The small area of stream (about 0.5 miles) habitat potentially affected by the project is located within 

a grazing allotment. Grazing could contribute cumulatively to sediment input and riparian vegetation

disturbance, see previous discussion for CRLF. Compared to the project, grazing could produce a 

higher quantity of effects to water since livestock are not excluded from the stream. However, 

cumulative impacts are likely to be inconsequential due to the very small section of stream potentially 

affected, and the very low likelihood of species presence.

Private lands are not present near SNYLF habitat, so no cumulative effects are expected from this 

source. Yosemite National Park is located just east of suitable habitat, and no known contributing 

actions are proposed in these areas.

Foothill Yellow-legged Frog

Nearly all FYLF habitat areas are located within grazing allotments, though only certain portions of 

allotments are actually utilized by livestock. In comparison, the project could affect up to 16% of 

available habitat, see previous discussion for CRLF, and poses some risk to individual frogs from 

trampling.

All other known future actions would only impact about 14 additional acres of habitat, which is 

inconsequential as compared to the project and grazing effects.

Four sub-watersheds have substantial private lands near FYLF habitat that have the potential to 

contribute to effects, including: Reed Creek, Granite Creek, Lower Jawbone Creek, and Middle 

Jawbone Creek. Ground disturbing activity could cumulatively contribute to project sediment and 

affect FYLF habitat.

Western Pond Turtle

The discussion of cumulative effects to stream habitat for amphibians applies to the WPT because 

they use similar habitats. The main difference is that the WPT is less likely to utilize the very small, 

intermittent streams where sedimentation effects would be the highest.

As with FYLF, the majority of WPT habitat is contained within grazing allotments and would be 

subject to effects described for CRLF. In addition to habitat effects, trampling is also possible, but 

would likely only affect a very small percentage of individuals.

Other action types account for about 500 acres, the majority of which are timber management. This 

area is only about 2% of the total (project plus other actions excluding grazing). The small additional 

contribution would produce proportional effects similar to the proposed actions. 

Four sub-watersheds have substantial private lands near WPT habitat that have the potential to 

contribute to effects, including: Reed Creek, Granite Creek, Lower Jawbone Creek, and Middle 

Jawbone Creek. Ground disturbing activity could cumulatively contribute to project sediment and 

negatively affect WPT habitat.

Hardhead

Very little watershed area would be affected by cumulative actions and the sediment generated from 

those actions would not be readily detectable in suitable hardhead habitat. The Clavey and Tuolumne 

Rivers are so large and have such high capacity to transport and store fine sediment that the deep 

water habitats would be minimally impacted and deep water refuge would be maintained. The 

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Chapter 3.03 Stanislaus

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sediments that could accumulate in spawning habitats would not be likely to impair spawning success 

in the Clavey River.

Alternative 2 (No Action)

DIRECT AND INDIRECT EFFECTS

General Effects Common to All Species

No direct effect would be expected under Alternative 2. There would be no potential for mortality, 

injury, or physical disturbance of any of the three Forest Service Sensitive species created by 

reforestation actions. 

Because the Forest Service would take no action under this alternative, natural watershed recovery 

processes would occur. Over time, there would be a gradual reduction in the delivery of sediment to 

stream channels as fire-resilient plant species recolonize burned areas and the soil-repellent layers 

break up. Erosion rates for most of the burned area would approach pre-fire rates within 5 or 6 years, 

but some areas could have elevated rates for up to 10 years. Streamflows would continue to be higher 

than in the pre-fire condition and some of the mapped intermittent streams could support perennial 

flow or maintain perennial water in pool habitats for 20 years or more. With the increased streamflow 

and decreased erosion (and sediment delivery to streams) rates, the silt and sand deposited and stored 

in the stream channels would be largely scoured from the channels within 5 to 7 years and pre-fire 

streambed condition would be evident in 10 years. 

Stream shading would increase in riparian areas affected by moderate and high vegetation severity 

fire. The obligate woody riparian species would regrow from stems and root crowns and increase in 

density via dispersal of seeds along the streams. Over the next 20 years, shading would increase to the 

point where cool and cold water temperatures would be maintained.

Compared to the project alternatives, the growth rate and distribution of trees would be reduced due 

to increased competition from other vegetation (e.g., shrubs). Sediment mobilization would likely be 

less in the short- term (absence of heavy equipment use) and similar in the long-term. Long-term 

LWD recruitment from trees would be reduced due to a lengthier period of time needed to establish 

larger trees. Herbicide effects would be absent. 

California Red-legged Frog, Sierra Nevada Yellow-legged Frog, Foothill Yellow-legged frog, Western Pond Turtle, and 

Hardhead

Under this alternative no direct or indirect effects would occur to individuals as a result of project 

activities. Vegetation recovery would continue at natural/variable rates, and noxious weeds would 

presumably continue to increase. Sediment input to aquatic habitats would continue to decrease as 

vegetation recovery progresses.

CUMULATIVE EFFECTS

Due to the absence of direct and indirect effects, no cumulative effects would occur. 

Alternative 3

DIRECT AND INDIRECT EFFECTS

Under this alternative, herbicides would not be utilized, resulting in an approximate 40% reduction in 

acres proposed for noxious weed eradication. In addition, reforestation units would experience an 

increase in soil-disturbing methods (nearly double) due to the elimination of glyphosate. See Chapter 

2.02 for a detailed description of this alternative. 

California Red-legged Frog

Less than 10 acres of noxious weed treatment units within CRLF habitat would occur under 

Alternative 3, where manual methods would be used instead of herbicides. Essentially no impact 

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would be expected from this very small change. The majority of other proposed actions (about 4,000 

acres) within CRLF habitat would be treated with mechanical or hand methods rather than 

glyphosate. Non-herbicide methods disturb soil, and would likely lead to an increase in erosion and 

subsequent sediment increase to the aquatic environment.

The absence of herbicide use would eliminate the possibility of chemical contamination and 

associated indirect effects to suitable CRLF aquatic and terrestrial habitat.

Sierra Nevada Yellow-legged Frog

Same as Alternative 1 since no herbicides are proposed within 107 feet of SNYLF habitat in 

Alternative 1.

Foothill Yellow-legged Frog

Within FYLF habitat buffers, Alternative 3 would result in approximately 75% fewer noxious weed 

treatment acres (142) as compared to Alternative 1. Mechanical or hand methods would also be used 

in reforestation units, about 2,300 acres. Non-herbicide methods disturb soil, and would likely lead to 

increased erosion and subsequent sediment within aquatic habitats. The absence of herbicide use 

would eliminate the possibility of chemical contamination and associated indirect effect to frogs 

within suitable aquatic and terrestrial habitat.

Western Pond Turtle

Alternative 3 would result in an approximate 75% reduction in noxious weed units as compared to 

Alternative 1. In the remaining noxious weed units, about 1,500 acres, use of mechanical or hand 

methods is proposed rather than glyphosate. Use of mechanical or hand methods are also proposed in 

all other units (e.g., reforestation, natural regeneration) within WPT habitat. Non-herbicide methods 

disturb soil, and would likely lead to an increase in erosion and subsequent sediment increase to the 

aquatic environment. The project watershed report describes this difference. Since turtles extensively 

utilize the terrestrial environment, direct effects to turtles, such as injury or death from heavy 

equipment, would be substantially increased when compared to Alternative 1. 

The absence of herbicide use would eliminate the possibility of chemical contamination and 

associated indirect effects (e.g., food sources) to turtles within suitable aquatic and terrestrial habitat.

Hardhead

Same as Alternative 1.

CUMULATIVE EFFECTS

California Red-legged Frog

Sediment delivery would differ between Alternatives 1 and 3 due to the increased ground disturbance 

from Alternative 3. Cumulative Watershed Effects analysis indicates this alternative is likely to 

produce more sediment effects (as inferred from ERAs) than any other Alternative. Since this species 

is almost certainly absent from the project area, this effect combined with those of other actions 

would be of little consequence. Habitat suitability would be minimally affected, and sediment input 

would likely return to natural levels within a few years post-project.

Sierra Nevada Yellow-legged Frog

Same as Alternative 1.

Foothill Yellow-legged Frog

Increased ground disturbance from Alternative 3 combined with those of other adjacent actions, 

particularly in the four sub-watersheds that also have private lands within and nearby, would be 

greater under Alternative 3. Sediment input would return to natural or background levels in the longer 

term. 

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Western Pond Turtle

Increased ground disturbance from Alternative 3 combined with those of other adjacent actions, 

particularly in the four sub-watersheds that also have private lands within or nearby, would be greater 

under Alternative 3. Individual turtles would be more susceptible to direct harm from increased heavy 

equipment use. Sediment input would return to natural or background levels in the longer term. 

Hardhead

Same as Alternative 1.

Alternative 4

DIRECT AND INDIRECT EFFECTS

Alternative 4 proposes the same noxious weed treatments as Alternative 3, which includes reduced 

acreage and no herbicides. As with Alternative 3, in other units sediment input could increase due to 

increased use of soil-disturbing treatment methods. Alternative 4 proposes an approximate 85% 

reduction in reforestation units. Prescribed fire would be used extensively under this Alternative. 

California Red-legged Frog

Under Alternative 4 there would be an approximate 90% reduction in treatment units within CRLF 

habitat as compared to Alternative 1. This would substantially reduce the quantity of vegetation 

disturbance and sediment production, as well as potential effects from herbicide (glyphosate only) 

that would still be used in the remaining acres. Increased fire use could reduce sediment input 

somewhat compared to mechanical methods (e.g., deep tilling), as this method generally produces 

little soil disturbance. This alternative would likely produce the least effects to CRLF habitat of any 

action alternative (1, 3, 4, and 5). 

Sierra Nevada Yellow-legged Frog

Under Alternative 4 there is no treatment proposed near potential habitat; therefore no effects would 

be expected.

Foothill Yellow-legged Frog

Under Alternative 4 there would be an approximate 75% reduction in treatment units, including 

noxious weed units, as compared to Alternative 1. This would substantially reduce the quantity of 

vegetation disturbance and sediment production, as well as potential effects from herbicide 

(glyphosate only) that would still be used in the remaining acres. Increased fire use could reduce 

sediment input somewhat compared to mechanical methods (e.g., deep tilling), as this method 

generally produces little soil disturbance. This alternative would produce the least effects to FYLF

habitat of any action alternative (1, 3, 4, and 5). Due to their close association with water, it is likely 

that there would be little difference in direct effects to individuals; both fire and mechanical methods 

would initiate a flee response into water or near-shore cover that is unlikely to be affected.

Western Pond Turtle

Similar to FYLF, under Alternative 4 there would be an approximate 75% reduction in treatment 

units, including noxious weed units, as compared to Alternative 1. This would substantially reduce 

the quantity of vegetation disturbance and sediment production, as well as potential effects from 

herbicide (glyphosate only) that would still be used in the remaining acres. Increased fire use could 

reduce sediment input somewhat compared to mechanical methods (e.g., deep tilling), as this method 

generally produces little soil disturbance. This alternative would produce the least effects to WPT

habitat of any action alternative (1, 3, 4 and 5). Both fire and mechanical methods would pose a risk 

to individual turtles, though the reduced acreage of this Alternative would reduce risk compared to 

the other action alternatives.

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Hardhead

Same as Alternative 1.

CUMULATIVE EFFECTS

California Red-legged Frog

Cumulative effects similar to Alternative 3 in type, but moderately reduced due to lower acreage 

treated. Though herbicides are proposed for reforestation treatments, the acreage is considerably 

reduced and potential indirect effects would be minimized. 

Sierra Nevada Yellow-legged Frog

There are no direct or indirect effects; therefore no cumulative effects would occur. 

Foothill Yellow-legged Frog

Cumulative effects similar to Alternative 3 in type, but moderately reduced due to lower acreage 

treated. Though herbicides are proposed for reforestation units, the acreage is considerably reduced 

and potential indirect effects would be minimized. 

Western Pond Turtle

Cumulative effects similar to Alternative 3 in type, but moderately reduced due to lower acreage 

treated. Though herbicides are proposed for reforestation units, the acreage is considerably reduced 

and potential indirect effects would be minimized.

Hardhead

Same as Alternative 1.

Alternative 5 

DIRECT AND INDIRECT EFFECTS

Alternative 5 actions and effects are similar to those discussed under Alternative 1. The difference is 

that the 4,031 acres of natural regeneration areas would be planted immediately under this alternative 

instead of waiting to monitor for 5 years. Therefore a relatively small increase in all effects associated 

with reforestation activities discussed under Alternative 1 could occur. 

California Red-legged Frog

Small increase in all potential effects described for Alternative 1.

Sierra Nevada Yellow-legged Frog

Small increase in all potential effects described for Alternative 1.

Foothill Yellow-legged Frog

Small increase in all potential effects described for Alternative 1.

Western Pond Turtle

Small increase in all potential effects described for Alternative 1.

Hardhead

Same as Alternative 1.

CUMULATIVE EFFECTS

California Red-legged Frog

Cumulative effects similar to Alternative 1 in type and magnitude, but slightly increased due to larger 

quantity of reforestation.

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Sierra Nevada Yellow-legged Frog

Cumulative effects similar to Alternative 1 in type and magnitude, but slightly increased due to larger 

quantity of reforestation.

Foothill Yellow-legged Frog

Cumulative effects similar to Alternative 1 in type and magnitude, but slightly increased due to larger 

quantity of reforestation.

Western Pond Turtle

Cumulative effects similar to Alternative 1 in type and magnitude, but slightly increased due to larger 

quantity of reforestation.

Hardhead

Same as Alternative 1.

Summary of Effects Analysis across All Alternatives

California Red-legged Frog

The implementation Alternatives 1, 3 and 5 all pose similar risk to individual CRLF and their habitats 

although the risk is low. Though herbicide exposure would be eliminated under Alternative 3, 

increased ground disturbance and resulting sediment increase could occur. Upland habitats have the 

greatest proportion of overlap with project activities, where vegetation modification or loss would 

occur. The risk to CRLF and their habitats is lowest under Alternative 4 due to a large decrease in the 

project footprint within suitable habitat.

Possible direct effects to individuals include injury, mortality, or behavioral disturbance. For all 

Alternatives, the direct effects to aquatic habitats are minimized by management requirements 

prohibiting operations within and adjacent to aquatic features. The upland habitat would be at a 

greater risk of direct effects from change or loss of near-ground vegetation cover. A limited operating 

period in conjunction with other management requirements should mitigate these risks.

A potential increase of sediment depth in breeding and non-breeding habitat is the most likely effect 

to CRLF habitats. Sediment potential is somewhat higher for Alternatives 3 and 5 as compared to 1, 

and substantially less for Alternative 4.

Sierra Nevada Yellow-legged Frog

Similar to the CRLF, the implementation of Alternatives 1, 3 and 5 pose the greatest risk to individual 

SNYLF and their habitats although the risk is low, and little difference exists between the action 

alternatives due to the very small quantity of available habitat within the project area. Alternative 4 

would not affect this species.

Possible direct effects to individuals include injury, mortality, or behavioral disturbance. Direct 

effects to aquatic habitats are not expected to occur because management requirements prohibit 

operations within and adjacent to aquatic features. The upland habitat would be at greater risk of 

direct effects in comparison to the breeding and non-breeding aquatic habitats, although in 

comparison to CRLF, the upland habitat of SNYLF are less important to their overall survival 

because of their close affinity to water and the lack of habitats in close enough proximity to one 

another to elicit overland movements. 

A potential increase of sediment depth in breeding and non-breeding habitat is the most likely effect 

SNYLF habitats may experience, but the effects of implementing the actions proposed under 

Alternatives 1, 3 and 5 are negligible to minor in comparison to the increases in sediment from the 

effects of the Rim Fire.

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DETERMINATIONS FOR THE CALIFORNIA RED-LEGGED FROG AND SIERRA NEVADA YELLOW-LEGGED FROG

The following determination is supported by the analysis contained in this EIS. The overall project 

“may affect, likely to adversely affect” California red-legged frog and Sierra Nevada yellow-legged 

frog. The determination of “may affect, likely to adversely affect” for California red-legged frog is

limited to 7 locales. These are Drew Creek, Hunter Creek and ponds or impoundments on streams 

(Birch Lake, Mud Lake, Homestead Pond, Harden Flat ponds, Hunter Creek area ponds.) For the 

Sierra Nevada yellow-legged frog, this determination is applicable to two analysis areas: Big and 

Little Kibbie Ponds, and the Middle Fork Tuolumne River near the Yosemite National Park 

boundary. Because occupancy is assumed at these locations (except Big and Little Kibbie Ponds), 

there is the potential for project activities to directly impact individuals occurring in aquatic or upland 

habitats. The most likely direct impact is physical disturbance resulting from forest workers and 

equipment. Through multiple reforestation actions, the project would modify the upland habitat by 

reducing the availability of vegetation cover and large woody debris. These effects apply to both 

species in most cases. There are some differences between action alternatives 1, 3 and 5 in terms of 

extent and intensity of impact, though the determination for California red-legged frog is still “may 

affect, likely to adversely affect” for Alternatives 1, 3, 4 and 5. However due to the absence of 

treatment in SNYLF habitat under Alternative 4, the determination is “No affect”, and “may affect, 

likely to adversely affect” for Alternatives 1, 3 and 5.

For the No Action alternative, there would be no project-related effects to the California red-legged 

frog and Sierra Nevada yellow-legged frog. 

Foothill Yellow-legged Frog

The implementation Alternatives 1, 3 and 5 all pose similar risk to individual FYLF and their habitats 

although the risk is low since this species tends to reside very close to water, where project activity 

would generally not occur. Possible direct effects to individuals include injury, mortality, or 

behavioral disturbance. 

Though herbicide exposure would be eliminated under Alternative 3, increased ground disturbance 

and resulting sediment increase could occur. Upland habitats have the greatest proportion of overlap 

with project activities, where vegetation modification or loss would occur, though this should 

minimally affect the highly aquatic FYLF. The risk to FYLF habitats is lowest under Alternative 4 

due to a large decrease in the project footprint within suitable habitat. A potential increase of 

sediment depth in breeding and non-breeding habitat is the most likely effect to FYLF habitats. 

Sediment potential is somewhat higher for Alternatives 3 and 5 as compared to 1, and substantially 

less for Alternative 4.

For all Alternatives, the direct effects to aquatic habitats are minimized by management requirements 

prohibiting operations within and adjacent to aquatic features, and if the species is known to be 

present. A limited operating period in conjunction with other management requirements should 

mitigate the above risks.

Western Pond Turtle

The implementation Alternatives 1, 3, and 5 all pose similar risk to individual WPT and their habitats. 

The increase in ground disturbance under Alternative 3 could expose more individual frogs to direct 

effects, but protective project management requirements are in place for occupied sites. Possible 

direct effects to individuals include injury, mortality, or behavioral disturbance. Alternative 4 would 

pose the lowest risk to individuals due to a substantial reduction of the project footprint. 

Though herbicide exposure would be eliminated under Alternative 3, increased ground disturbance 

and resulting sediment increase could occur. This species is susceptible to increased heavy equipment 

use since it commonly utilizes terrestrial habitat. The risk to WPT and their habitats is lowest under 

Alternative 4 due to a large decrease in the project footprint within suitable habitat. Upland habitats 

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have the greatest proportion of overlap with project activities, where vegetation modification or loss 

would occur. A potential increase of sediment depth in breeding and non-breeding habitat is the most 

likely effect to WPT habitats. Sediment potential is somewhat higher for Alternatives 3 and 5 as 

compared to 1, and substantially less for Alternative 4. 

For all Alternatives, the direct effects to individuals and aquatic habitats are minimized by 

management requirements prohibiting operations within and adjacent to aquatic features and due to 

additional protective measures where the species is known to be present.

Hardhead

No measurable differences exist between effects to hardhead or their habitats. High suitability habitat 

for all lifestages would be maintained in the lower North Fork Tuolumne and Clavey Rivers and 

habitat for adult and sub-adult lifestages would not be measurably affected by any or all actions.

DETERMINATIONS FOR THE SENSITIVE SPECIES

A determination of “may affect individuals, but is not likely to lead to a trend in federal listing or loss 

of viability” was made for the foothill yellow-legged frog, western pond turtle, and hardhead and are 

supported by the analysis contained in this EIS. For the foothill yellow-legged frog and western pond 

turtle, this determination was based on the potential for direct effects to individuals and indirect 

effects to habitats to occur as a result of project activities. The primary anticipated impact to 

individuals is physical disturbance and the primary anticipated impact to habitat is sedimentation of 

aquatic habitat. When combined with post-fire effects to habitat and individuals and watershed level 

impacts from cumulative actions, some localized populations could have reductions in numbers. 

However, these two species are expected to occur within watersheds affected by the proposed actions 

and are well distributed across the forest and throughout their ranges. For the hardhead, slight impacts 

to habitat are anticipated because of sediment delivery to aquatic habitats, but the habitats they rely 

upon would remain available and capable of supporting all life history requirements.

The determination applies to all four action alternatives because some level of impact, even if very 

small, could occur to individuals and aquatic and upland habitats at most locations. 

For the No Action alternative, there would be no project related effects to foothill yellow-legged 

frogs, western pond turtles, or hardhead. 

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3.04 CULTURAL RESOURCES

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction

Several laws direct the Forest Service to identify, evaluate, treat, protect and manage cultural 

resources. The National Historic Preservation Act (NHPA) as amended (16 U.S.C. 470 et seq.) 

provides comprehensive direction to federal agencies regarding historic preservation. Executive Order 

11593, entitled Protection and Enhancement of the Cultural Environment, also includes direction 

about the identification and consideration of cultural resources in federal land management decisions. 

The NHPA extends the policy in the Historic Sites Act of 1935 (49 Stat. 666; 16 U.S.C. 461-467) to 

include resources that are of State and local significance, expands the National Register of Historic 

Places (NRHP), and establishes the Advisory Council on Historic Preservation (ACHP) and State 

Historic Preservation Officers. NHPA Section 106 directs all federal agencies to take into account 

effects of their undertakings (actions, financial support, and authorizations) on properties included in 

or eligible for the NRHP. The ACHP regulations (36 CFR 800) implements NHPA Section 106. 

NHPA Section 110 sets inventory, nomination, protection, and preservation responsibilities for 

Federally-owned cultural resources.

Section 106 of the NHPA and the ACHPs implementing regulations, Protection of Historic 

Properties (36 CFR Part 800), require that federal agencies take into account the effect of their 

undertakings on cultural resources, and that agencies provide the ACHP with an opportunity to 

comment on those undertakings. Programmatic agreements (36 CFR 800.14(b)) provide alternative 

procedures for complying with 36 CFR 800. 

The Stanislaus National Forest developed a specialized agreement: “Programmatic Agreement 

Among the United States Forest Service, Stanislaus National Forest, The California State Historic 

Preservation Officer, and the Advisory Council on Historic Preservation, Regarding the Compliance 

with the National Historic Preservation Act for Proposed Actions Pertaining to the Rim Fire 

Emergency Recovery Undertaking Programmatic Agreement (Rim PA, project record).” This 

agreement defines the Area of Potential Effects (APE) (36 CFR 800.4(a)(1)) and includes a strategy 

outlining the requirements for cultural resource inventory, evaluation of cultural resources, and effect 

determinations; it also includes protection and resource management measures that may be used 

where effects may occur. Additionally, this agreement provides unique and necessary opportunities to 

remove both non-commercial timber and hazard trees from within site boundaries utilizing a variety 

of harvest methods including one-end suspension and rubber tired machinery. Removal of these trees 

benefits the long term recovery and preservation of cultural resource sites by reducing future fuel 

build-up and fire weakened trees that could fall and impact already fragile resources.

Executive Order 11593: Protection and Enhancement of the Cultural Environment, issued May 13, 

1971, directs Federal agencies to inventory cultural resources under their jurisdiction, to nominate to 

the NRHP all Federally owned properties that meet the criteria, to use due caution until the inventory 

and nomination processes are completed, and to assure that Federal plans and programs contribute to 

preservation and enhancement of non-Federally owned properties. 

The Forest Plan Compliance (project record) document identifies the Forest Plan Standards and 

Guidelines that specifically apply to this project and related information about compliance with the 

Forest Plan.

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Effects Analysis Methodology

Assumptions Specific to Cultural Resources

 Site preparation including deep tilling, forest cultivation, mastication (shredding) and machine 

piling and burning will occur outside of cultural resource boundaries and thereby have no adverse 

effect to cultural resources.

 Hand or direct application of herbicides to noxious weeds within cultural resource site boundaries 

are not anticipated to have any adverse effects on cultural values, particularly plant species 

important to California Indian Basketweavers or other Native American gatherers. 

 Prescribed burning to treat noxious weed areas will enhance and promote growth of native plant 

species.

 Removal of smaller diameter non-commercial timber (biomass) and standing dead trees within 

and adjacent to cultural resources through limited mechanical and hand cutting methods will have 

no adverse effect to cultural resources.

 All slash, brush, and other vegetation removed from within and outside of cultural resource site 

boundaries will be piled and burned outside of site boundaries thereby having no adverse effect to 

cultural resources.

 Removal of smaller diameter timber and standing dead trees from within site boundaries can have

a beneficial effect on cultural resources. Removal of these trees would lessen the potential for 

damage to historic earthworks such as ditches, road, trails, and railroad grades (as they fall over 

time). Additionally, removal of this material would lessen fuel buildup that could potentially 

damage already fragile bedrock mortar outcrops.

 Use of existing breaches within linear sites, such as historic railroad grades, trails, roads and 

ditches, to access reforestation treatment units will cause no adverse effect to cultural resources.

 Use of existing water sources are not anticipated to affect cultural resources.

 According to the Rim PA (project record), all archaeological and historical sites identified within 

the APE for all alternatives are considered cultural resources for the purposes of this undertaking, 

unless they already have been determined not eligible in consultation with the SHPO or through 

other agreed on procedures (36 CFR 60.4; 36 CFR 800). 

 Activities outlined within the EIS, when combined with the past, present and foreseeable future 

actions are not expected to cumulatively lead to increased impacts to cultural resources.

Data Sources

 Site specific cultural resource inventories conducted between 1986 to present (which meet current 

archaeological survey standards) were utilized. The primary objectives of these surveys were to 

identify cultural resources in the APE that may be affected by the undertaking and collect 

information on their current condition. 

 Existing information from cultural resource records, historic archives, maps, and GIS spatial 

layers were also used.

Cultural Resources Indicators

Indicators of direct and indirect effects include: 

 Exposure of surface and subsurface artifacts through deep tilling, forest cultivation, mastication

(shredding) and machine piling. 

 The degree to which the integrity of historic property values are diminished.

Cultural Resources Methodology by Action

The 2013 Rim Fire, while destructive, also provided the rare opportunity to have an unimpeded view 

of the forest floor. Utilizing previous archaeological inventories from past projects that meet current 

survey standards (1986 to present) in addition to the recently completed 12,685 acre survey for the 

Rim Fire Recovery EIS (USDA 2014), nearly 78% of the proposed treatment areas were eliminated 

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from further inventory. Continuing with the strategy developed for the Rim Recovery project, 

reforestation areas that fell outside of Recovery treatment units were intensively surveyed utilizing a 

49 to 98-foot (15 to 30-meter) interval spacing. The strategy is consistent with both the 2013 Regional 

PA and the 2014 Rim PA (project record). 

Affected Environment

Cultural resources are archaeological, cultural, and historical legacies from our past that are more 

than 50 years old. Cultural resource information, combined with environmental data, can illuminate 

past relationships between people and the land. Cultural-ecological relationships, the result of both 

natural processes and 10,000 years of human interaction in the central Sierra Nevada, are key topics 

in this region’s anthropological, archaeological, and historical research. 

The Stanislaus National Forest currently contains 5,135 recorded prehistoric and historic 

archaeological sites (cultural resources). The vast majority of these (3,003) represent prehistoric 

Native Americans and ethnographic Miwok and Washoe land use. These include seasonal villages, 

temporary camps, toolstone quarries, and bedrock mortar milling locations. Today, the Miwok still 

actively use the Forest for gathering traditional food and medicine plants, hunting, and conducting 

ceremonies.

The project area contains 1,789 recorded sites of historic land use. These include emigrant trails, 

historic cabins, roads, bridges, lumber or mining complexes and camps, ditches, homesteads, grazing 

camps, arborglyphs (tree carvings), railroad grades, trestles, mining shafts and adits, and Forest 

Service administrative buildings and compounds. All of the historic sites found in the Forest, date 

from 1,846 to the present.

Since people today favor many of the areas preferred by Native people, 343 sites have both a 

prehistoric and historic component. 

Existing Conditions

This project encompasses the Forest’s second largest Section 106 compliance project in relation to a 

catastrophic wildfire event. The scale of the undertaking requires that an extensive field survey be 

conducted to identify cultural resources within the APE that may be affected by the various projects 

proposed under the post fire reforestation undertaking.

The Rim Reforestation project identifies 21,300 acres for reforestation (including mechanical site 

preparation, manual (hand) grubbing, herbicide treatments and prescribed fire), with an additional 

3,833 acres of deer habitat enhancement, 12,769 acres of pre-existing plantation thinning, 608 acres 

of noxious weed treatment and 4,031 acres of natural regeneration treatments. These 42,541 acres 

constitute the Rim Reforestation project APE used in the environmental consequences analysis. A 

pre-field review determined that 27,218 acres of the APE had been previously surveyed for cultural 

resources through various other projects. The result of these surveys identified 1,995 prehistoric and 

historic properties within the project boundary of which 921 are located within or adjacent to 

treatment units likely to be affected by this project.

Of these 921 properties, 344 are prehistoric sites related to food processing (bedrock milling 

features), stone tool processing (lithic scatters) and temporary living areas (rock shelters). These sites 

are associated to land use by the native inhabitants of the region, known as the Central Sierra Miwok. 

Additionally, 501 historic sites are related to railroad logging (camps, grades and associated features), 

mining (mines, hydraulic mining areas, water conveyance ditches), water development (dams and 

water conveyance ditches), grazing (structures and fence lines) and homesteading (structure remains). 

Also, 76 sites are multi-component (both prehistoric and historic) sites. The remaining sites are noted 

but not recorded through previous undertakings and will be documented prior to implementation. 

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Heritage Resource Specialists identified the remaining 11,892 acres as needing archaeological survey 

in order to ensure the protection and preservation of cultural resources. This survey will be completed 

prior to project implementation as stipulated in the Rim PA (project record). 

CONTEMPORARY NATIVE AMERICAN USE

From the onset of the Rim Fire and continuing through the Rim Recovery and Rim Reforestation 

efforts, the Forest Archaeologist consulted with the Tuolumne Band of Me-Wuk Indians regarding 

protection of traditional collection areas and sites significant to the Miwok people. Native peoples 

continue to utilize the area for traditional gathering and will continue to do so. 

HISTORIC USE

Historic records, maps and oral accounts encompassing the project boundary indicate intensive land 

use since the Gold Rush era (1849) especially in the areas of mining, water development, railroad 

logging, and ranching. Numerous mines were located along the Eastern Belt, a zone of auriferous 

quartz veins in black slate or grandodiorite which ran parallel and east of the Mother Lode. Gold was 

also extracted from the Tertiary alluvial gravels with the development of hydraulic mining through 

1884. In order to supply the mines and associated communities of Big Oak Flat and Second Garotte 

with sufficient water, a system of ditches and flumes was built by the Golden Rock Water Company 

in the late 1850s to distribute water from the Middle and South Fork Tuolumne Rivers. Remnants of 

the Golden Rock Ditch system, and other lesser known systems, run through many parts of the Rim

Fire burn area. One of the Golden Rock’s major engineering feats, the Inverted Syphon and the Big 

Gap Flume, is listed on the NRHP. 

During the first three decades of the last century, four major railroad logging systems were built into 

the Tuolumne and Merced River drainage basins: West Side Lumber Company (1899); Yosemite / 

Sugar Pine Lumber Company (1907); Hetch Hetchy Railroad (established 1917) and the associated 

railroad logging operation; and California Peach and Fig Growers (1917), extending from Hetch 

Hetchy Junction (5 miles southwest of Chinese Camp) to Hetch Hetchy Valley. The Rim Fire affected 

portions of all four railroad logging systems to various degrees. Associated features affected by the 

event include railroad grades, trestles, inclines, cut and fill earthen structures, logging camps, donkey 

sets and associated equipment.

Presently, 14 grazing allotments are either wholly or partially affected by the Rim Fire. Historic 

records, maps and oral accounts encompassing the allotment boundaries indicate intensive livestock 

grazing occurred from the 1850s to the early 1920s. Some of the existing trail system is likely 

connected to moving livestock to summer pasturage. Associated features affected by the fire include 

fences, wooden troughs and collapsed wooden structures (range cabins).

Environmental Consequences

Alternative 1 (Proposed Action) 

DIRECT AND INDIRECT EFFECTS

Potential direct effects include displacement and/or obliteration of surface and subsurface deposits 

from mechanical site preparation methods which include: deep tilling, forest cultivation (subsoiling), 

mastication (shredding), harvest of non-commercial timber using a tracked feller buncher, machine 

piling and burning, and use of prescribed fire. Activities conducted during this project have the 

potential to uncover previously unknown cultural resources where deposits are largely subsurface.

Pursuant to the Rim PA (project record), all sites will be delineated with coded flagging and/or other 

effective marking (i.e., “flag and avoid) for protection prior to project implementation. Where 

opportunities are identified and approved by the Forest Archaeologist, or their designated individual, 

the Forest will implement Stipulation II (E)(a) of the Rim PA (project record) in order to remove 

smaller diameter noncommercial timber (biomass), standing dead and hazard trees from within site 

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boundaries utilizing a variety of harvest methods including one-end suspension, a feller-buncher and 

rubber tired machinery. Removal of these trees will benefit the long term recovery and preservation 

of cultural resource sites by reducing future fuel build-up and fire weakened trees that could fall and 

impact already fragile resources. These alternative methods are low risk, and pose only minimal 

temporary impact in the form of light surface scrapes to cultural resources. In all cases Forest heritage 

resource specialists will be present to authorize and direct access within site boundaries. Also, sites 

may be avoided through project redesign. 

Additionally, Alternative 1 includes extensive use of herbicides within a variety of proposed 

treatments (i.e. reforestation site preparation and release, noxious weed eradication, natural 

regeneration treatments and deer habitat enhancement) for a total of 26,585 acres treated. In all 

treatment areas application of herbicides will be accomplished through the use of backpack sprayers 

for direct localized application. In cases where noxious weeds are within cultural resource site 

boundaries the use of herbicides will only be allowed as long as it does not affect plant species 

important to California Indian Basketweavers or other Native American gatherers. In each case a 

Forest heritage specialist will be consulted prior to treatment within sites.

A potential indirect effect resulting from the Rim Fire and post fire recovery was the exposure of 

many historic and prehistoric properties to potential human vandalism and looting for financial and 

personal gain. During the first year after the fire, the Rim burn area was closed under Forest Order 

while safety issues were mitigated. This allowed vegetation across the landscape to reestablish itself 

and help obscure these archaeological properties which reduced access and the potential for 

vandalism and looting. However, site preparation and release activities for reforestation may once 

again temporarily expose site locations by creating the appearance of “timber/vegetation islands” 

indicating the location of a cultural site. The intensive post-project monitoring of sites will determine 

the effectiveness of treatments and lessen the potential for unanticipated effects.

Due to implementation of management requirements and monitoring, no effects to historic and 

prehistoric properties are anticipated under Alternative 1. 

CUMULATIVE EFFECTS

All projects listed in Cumulative Effects Analysis (Appendix B) are subject to NHPA Section 106 

compliance and potential effects to cultural resources would be identified at that time following 

stipulations in the Rim PA (project record). 

Alternative 1, when combined with the past, present and reasonably foreseeable future actions and 

events are not expected to cumulatively lead to increased impacts to cultural resources.

Alternative 1 would continue the restoration efforts started with the Rim Recovery project. The 

reforestation plan would lessen the effects of future wildfire on these sites, protect fragile resources 

and return the ecological setting or appearance to the time of the Native American presence, thus 

preserving those values that would make these sites significant and allow for future studies.

Alternative 2 (No Action)

DIRECT AND INDIRECT EFFECTS

The no action alternative would present a low risk to cultural resources. Without new or increased 

ground-disturbing activities in the areas of known cultural resource sites, no direct effects would 

occur with Alternative 2. 

Indirect effects to the cultural resources may occur through inaction. The existing threat of fireweakened non-commercial and smaller diameter trees falling naturally, and potentially damaging 

already fragile cultural resources, would continue. The actions presented in Alternatives 1, 3, 4 and 5 

would further remove dense vegetation, biomass and hazard trees preventing damage to cultural

resources. The lack of action can adversely affect cultural resources through natural mortality where 

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fire-weakened trees may uproot within archaeological sites creating increased ground disturbance and 

damaging already fragile resources.

CUMULATIVE EFFECTS

As stated above, Alternative 2 may have an indirect effect to cultural resources where lack of 

treatments within and around cultural resource sites may increase the potential for ground disturbance 

and damage to site features through natural processes. Other projects in the future may affect cultural 

resources, however no actions associated with Alternative 2 would add to these effects. 

Alternative 3

DIRECT AND INDIRECT EFFECTS

The potential effects in Alternative 3 are similar to Alternative 1. Activities conducted during this 

project have the potential to uncover previously unknown cultural resources where deposits are 

largely subsurface. Unlike Alternative 1, ground disturbing activity will substantially increase due to 

the absence of herbicide treatments. Increased ground disturbance through deep tilling, forest 

cultivation and hand grubbing increases the chance to uncover previously unknown cultural resources 

where deposits are largely subsurface. As with any project, should heritage properties be located 

during implementation, activities will cease in the area and the District Archaeologist or designated 

individual will be notified immediately.

As this alternative does not propose the use of any herbicides for site preparation, noxious weed

treatment or deer habitat enhancement, it is not anticipated to have any effects on cultural values, 

particularly plant species important to California Indian Basketweavers or other Native American 

gatherers. 

Due to implementation of management requirements and monitoring, no effects to historic and 

prehistoric properties are anticipated under Alternative 3. 

CUMULATIVE EFFECTS

Same as Alternative 1.

Alternative 4

DIRECT AND INDIRECT EFFECTS

The potential effects in Alternative 4 are similar to Alternative 1 in that treatments will include all 

forms of mechanical site preparation; however Alternative 4 drastically reduces the amount of site 

preparation to 20% of each unit for a total of 2,867 acres and dramatically increases the use of 

prescribed fire to 30,000 acres. Due to the increased use of fire, the potential for impacting cultural 

resource sites with wooden remains increases exponentially. Additional on-site monitoring during 

implementation and post implementation by a cultural resource specialist of the identified significant 

cultural resources sites will be required to ensure protection measures are effective.

Alternative 4 also includes use of herbicides within a variety of proposed treatments (i.e. reforestation 

site preparation and release, natural regeneration treatments and deer habitat enhancement) for a total 

of 2,867 acres treated. In all treatment areas application of herbicides will be accomplished through 

the use of backpack sprayers for direct localized application. 

Due to implementation of management requirements and monitoring, no effects to historic and 

prehistoric properties are anticipated under Alternative 4. 

CUMULATIVE EFFECTS

Same as Alternative 1.

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Alternative 5

DIRECT AND INDIRECT EFFECTS

Same as Alternative 1.

CUMULATIVE EFFECTS

Same as Alternative 1.

Summary of Effects Analysis across All Alternatives

For all action alternatives, mechanical site preparation methods which include: deep tilling, forest 

cultivation (subsoiling), mastication (shredding), harvest of non-commercial timber using a tracked 

feller buncher, machine piling and burning, and use of prescribed fire would have no direct effect, 

minimal indirect effects and no cumulative effects to cultural resources. Cumulative effects for 

Alternatives 3, 4 and 5 are the same as Alternative 1. No anticipated direct effects and cumulative 

effects to cultural resources are expected under Alternative 2 (No Action), as no project activity 

would occur; however, some indirect effects are expected under Alternative 2. 

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3.05 FIRE AND FUELS

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction

The Forest Plan includes goals, strategies and objectives to move towards creating a fire resilient 

forest where fire is an integral part of the system, not a landscape altering force (USDA 2010a, p. 5 to 

7, 11 to 15). The broad scale Forest Plan goals for fire and fuels that apply to this project include:

 Provide a cost-effective fire management program to protect Forest resources, life and property 

from the effects of wildfire. Maintain natural and activity fuels at levels commensurate with 

minimizing resource losses from wildfire (p. 5). 

 Treat fuels in a manner that significantly reduces wildland fire intensity and rate of spread, 

thereby contributing to more effective fire suppression and fewer acres burned (p. 13). 

 Treat hazardous fuels in a cost-efficient manner to maximize program effectiveness (p. 13).

 Strategically place treatment areas across landscapes to interrupt potential fire spread, removing 

sufficient material in treatment areas to cause a fire to burn at lower intensities and slower rates of 

spread compared to untreated areas, and considering cost-efficiency in designing treatments to 

maximize the number of acres that can be treated under a limited budget (p. 14). 

In October 2013, Forest Service Fire and Fuels staff from the Stanislaus and Pacific Southwest 

Research Station compiled a strategy for the Rim Fire area within the Rim Fire Vegetation Resiliency 

Plan (project record). This strategy outlined conditions along with features on the landscape that 

could help reduce the size and severity of future fires, and specifically addressed reforestation. 

The Forest Plan Compliance (project record) document identifies the Forest Plan Standards and 

Guidelines that specifically apply to this project and related information about compliance with the 

Forest Plan.

Effects Analysis Methodology

 The analysis area is the project area as described in Chapter 2.

 Duration of short-term effects is 20 years; duration of long-term effects is 40 years. 

 The cumulative effects analysis area is the Rim Fire perimeter, including NFS lands and those 

under other ownership.

Assumptions Specific to Fire and Fuels

 The Rim Recovery project required units to be at 10 to 20 tons per acre post implementation. 

 Vegetation condition in areas not covered under the Rim Recovery project will be similar to past 

fires in this area that were not salvaged or did not have fuel reduction treatments. 

 Historical weather represents future conditions in these locations. This assumption is a 

conservative estimate of future weather conditions as climate change is predicted to increase 

surface air temperatures increasing the size and severity of fires in the Sierra Nevada (Miller et al. 

2009; Miller and Safford 2012; Safford 2013). 

Data Sources

 Vegetation Plots for Reforestation in proposed units 

 Stand Profiles within the Rim Fire 

 FlamMap fire behavior modeling

 FOFEM version 6.0 tree mortality modeling 

 LANDFIRE Data Access Tool (2014) 

 Forest GIS shapefiles displaying information within the Rim Fire

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Fire and Fuels Indicators

 Tree Mortality: tree mortality from wildfire and prescribed fire can be measured using crown 

scorch volume. Crown scorch volume is determined by the percentage of crown scorched on a 

tree represented as a fraction of the crown. Low-intensity fires readily kill seedlings less than 12 

inches in height, while larger seedlings, saplings and pole-sized trees may be damaged but not 

killed, especially if the burn occurred during the dormant season (Reinhardt and Ryan; 1988).

 Flame Length: the length of flame measured in feet. Increased flame lengths increase resistanceto-control and likelihood of torching events and crown fires. 

 Fireline Intensity: the rate of energy or heat release per unit length of fire front. 

 Fuel Loading: the amount of flammable material that surrounds a fire. Fuel load is measured by 

the amount of available fuel per unit area, usually tons per acre. 

Fire and Fuels Methodologyby Action

Stand profiles (a vertical cross section of a fuel bed down to mineral earth showing fuel types, size 

and amount) were gathered and analyzed using representative 0.02 acre plots throughout the project 

area. The data was used to compare current fuel loading to projected future conditions. 

The dynamics between vegetation and fire and fuels are inherently linked. Fire has a profound effect 

on vegetation establishment and development and conversely, vegetation treatments (and the absence 

thereof) have a profound effect on fuels accumulations and tree mortality. The analysis considers 

forest vegetation, fuels and fire at the stand level. 

Predicted tree mortality from fire is heavily influenced by tree species, size and height. Increased 

scorch heights and percentage of crown scorched correlate closely to higher tree mortality. Scorch 

height is influenced in part by fuel type, fuel arrangement, fuel moisture and weather conditions. 

Predicted fire effects are estimated using the predicted length of flame measured in feet and the 

predicted fireline intensity measured in British Thermal Units (BTU) per foot per second at the head 

of the fire. Increased flame lengths can increase the likelihood of torching events and crown fires. 

Flame length, like scorch height, is influenced in part by fuel type, fuel arrangement, fuel moisture 

and weather conditions. Resistance-to-control, flame length and fireline intensity influence how fast 

firelines can be constructed by different suppression resources, including hand crews and mechanical 

equipment. 

Flame lengths over 4 feet, fireline intensities over 100 BTU per foot per second, or high resistance-tocontrol may present serious control problems. These conditions are too dangerous to be directly 

contained by hand crews (Schlobohm and Brain 2002; Andrews and Rothermel 1982). Flame lengths 

over 8 feet or fireline intensities over 500 BTU per foot per second are generally not controllable by 

ground-based equipment or aerial retardant and present serious control problems including torching, 

crowning and spotting. 

Increased flame lengths increase the likelihood flame length and fireline intensity directly affecting 

suppression tactics. Table 3.05-1 outlines how flame lengths and fireline intensities influence fire 

suppression actions (Andrews et al. 2011). Predicting the potential behavior and effects of wildland 

fire is an essential task in fire management. Mathematical surface fire behavior and fire effects 

models and prediction systems are driven in part by fuelbed inputs such as load, bulk density, fuel 

particle size, heat content and moisture of extinction. 

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Table 3.05-1 Surface Fire Flame Length and Fireline Intensity Suppression Interpretations

Flame Length

(feet)

Fireline Intensity 

(BTU/feet/second) Interpretation

0 to 4.0 0 to 100 Fires can generally be attacked at the head or flanks by persons using hand tools. Hand 

line should hold the fire.

4.1 to 8.0 101 to 500 Fires are too intense for direct attack on the head by persons using hand tools. Hand line 

cannot be relied on to hold the fire. Equipment such as dozers, pumpers and retardant 

aircraft can be effective.

8.1 to 11.0 501 to 1,000 Fires may present serious control problems: torching out, crowning and spotting. Control 

efforts at the fire head may be ineffective.

11.1 plus 1,001 plus Crowning, spotting and major fire runs are probable. Control efforts at head of fire are 

ineffective.

To facilitate use in models and systems, fuelbed inputs have been formulated into fuel models (Scott 

and Burgan 2005). Table 3.05-2 displays a list of fuel models that are or can be expected to be in the 

project area over the next 20 years.

Table 3.05-2 Fuel Models within the Rim Reforestation Project Area

Fuel 

Model Description Flame Length 

(feet)

Fireline Intensity 

(BTU/feet/second)

NB9 Bare Ground 0 0

GR1 Short Grass Low Load 0-3 45

GR2 Short Grass Moderate Load 1-8 300

GS2 Grass and Shrub 4-8 500

SH1 Low Load Shrub 0-1 125

SH2 Moderate Load Shrub 1-4 400

SH5 High Load Shrub 12-25 3,700

TL1 Recently Burned 0-1 5

TL2 Low Load Broadleaf Litter 0-1 7

TL4 Small Down Log 1-4 25

TL5 High Load Conifer Litter 1-4 50

TL7 Large Down Logs 1-4 50

TL8 Timber Litter 1-4 150

SB4 Blowdown with brush and small tree intermixed 12-25 3,000

FlamMap (Finney 2006) is designed to examine the spatial variability in fire behavior assuming that 

fuel moisture, wind speed and wind direction are held constant in time, thereby allowing for more 

direct comparison of fuel treatment effects. FlamMap allows the user to easily characterize fuel 

hazard and potential fire behavior, as well as analyze fire movement and fuel treatment interactions.

The fuel models used in this analysis are based on publication GTR-153 (USDA 2005). Fuel models 

used are estimates of what the fuel loading and fire behavior are currently and what is predicted in the 

future. The results of the calculations and estimates are intended to show trends and potential effects 

and are not statistically accurate. The FlamMap modeling system was used to estimate average fire 

behavior for each alternative. Flame length and fireline intensities were used to measure the effects of 

all alternatives.

Table 3.05-3 displays the 90th percentile values taken from the Fire Family Plus (Main et al. 1990) 

program using the Mount Elizabeth Remote Automated Weather Station during the period of April 1, 

1970 to October 31, 2013. For modeling purposes the fire weather adjective defined as High (90th 

percentile weather) was used to predict fire behavior in the analysis area.

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Table 3.05-3 Weather Parameters for High Conditions (90th Percentile Weather)

Parameter Value

1-hour fuel moisture (0 to 0.25 inch diameter) 4%

10-hour fuel moisture (0.25 to 1 inch diameter) 5%

100-hour fuel moisture (1 to 3 inch diameter) 7%

1000-hour fuel moisture (3 inch plus diameter, CWD) 9%

Herbaceous fuel moisture 30%

Woody fuel moisture 70%

20-foot wind speed (mph) 10

CWD=Coarse Woody Debris; mph=miles per hour

Affected Environment

Plant communities within the project boundaries included Westside Ponderosa Pine Forest, Sierran 

Mixed Conifer Forest, several different chaparral communities such as Montane Manzanita Chaparral

and Northern Mixed Chaparral, Montane Meadow, White Alder Riparian Forest, Aspen Riparian 

Forest, Blue Oak Woodland and other oak woodland communities (Holland 1986). Many of them 

burned with a moderate to high intensity in the Rim Fire where the conifer overstory was completely 

killed.

In addition, past wildfires (prior to the Rim Fire) and the subsequent salvage logging and reforestation 

activities created over 20,000 acres of young plantations. Many plantations were in various phases of 

growth and had been thinned in the past 15 years. Due to their mostly early seral nature, the 

plantation understories had low native plant diversity and were primarily composed of disturbance 

followers such as non-native annual grasses and native shrubs like deer brush (Ceanothus 

integerrimus), manzanita (Arctostaphylos sp.), bear clover (Chamaebatia foliolosa) and Sierra 

gooseberry (Ribes roezlii).

Existing Conditions

Existing conditions include past projects (salvage logging, fuels reduction, wildfires and other 

activities) and present and future projects as listed in Appendix B. This timeframe allows the 

comparison of alternatives during the time when fuel profiles change significantly after a wildfire and 

during reforestation and is representative of the fire return interval for the project area.

The 2013 Rim Fire and the salvage and fuel treatments that occurred post fire created low fuel 

loadings (10 to 20 tons per acre depending on landscape location) within the majority of the 

reforestation and natural regeneration units, over 20,000 acres. Those units outside of these areas have 

standing dead small trees and sprouting brush remaining on site and are proposed for initial site 

preparation (fuels reduction) treatments to remove those fuels Snags and large logs are present in the 

units to meet resource needs and Forest Plan direction. Duff and litter layers are currently not present 

at a level that would affect fire behavior. Sprouting vegetation including oaks, bear clover, manzanita 

and deer brush are abundant throughout the burned area two years post-fire. Out-year fire effects are 

expected to be dominated by young shrubs, small trees and hardwoods reoccupying the site. 

Although burned in the Rim Fire, few of the deer habitat enhancement units were salvage logged post 

Rim Fire. These areas are on and adjacent to an open lava cap with oak/grasslands, existing 

plantations and brush fields. 

Within the existing plantations, trees range in size from 2 to 16 inches dbh and up to 30 feet tall. The 

understory vegetation is low, but many plantations are over stocked and have overlapping crowns. 

Duff layers exist, but are shallow, primarily developing from needle cast and dead woody brush. 

Noxious weeds are abundant throughout the project area, some of which create a more flashy fuel 

situation. As the weeds spread and increase in volume, an increase in ladder fuels occurs. Weeds such 

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Draft Environmental Impact Statement and Environmental Consequences

as Scotch broom, Medusahead, barbed goatgrass, yellow star-thistle and others, change the 

arrangement of vegetation, the amount of soil moisture at specific times of the year, the amount of 

fuel available to burn and how fire behaves (Keeley et al. 2011). 

Environmental Consequences

Alternative 1 (Proposed Action)

DIRECT AND INDIRECT EFFECTS

In Alternative 1, planted conifers would have a better chance of surviving future wildfires due to 

anticipated surface fuel load reductions through herbicide and other site preparation and release 

treatments and the incorporated fuelbreaks. 

The FOFEM 6 modeling program was used to determine tree mortality within young plantations 

(approximately 10 years old) from prescribed or natural fire. The data shows that within young 

plantations where trees are less than 4.5 feet tall, short flame lengths (2 feet) would cause the same 

mortality (80 to 100% depending on species) as the higher flame lengths (10 feet). As trees grow, the 

effects of two foot flame lengths lessen quickly and by age 20 most species see less than 10% 

mortality, but have the same range of mortality (80 to 100%) for 10 foot flame lengths. Ponderosa 

pine has the lowest mortality as trees grow through time and even by age 10 are seeing this drop in 

the shorter flame lengths. This species also grows the fastest within young plantations allowing it to 

reach these larger diameters and heights sooner.

Using empirical data for northern California forests, Weatherspoon and Skinner (1995) found that 

when wildfire in natural stands spreads to an adjacent plantation, fire intensity and damage to the 

overstory are much lower in plantations where slash has been removed following logging (Peterson et 

al. 2009). Until tree age and canopy base heights increase, younger conifer and hardwood stands 

would be susceptible to increased mortality. Younger trees have thinner bark and low canopy base 

heights allowing for easier transition to crown fire, even with predicted flame lengths at less than four 

feet over the majority of the proposed units. Maintaining lower surface fuel levels through follow-up 

herbicide release treatments on competing vegetation would help reduce tree mortality.

Proposed treatments would alter the spread and effect of fire in the project area. Units were 

strategically placed to affect fire movement on the landscape and provide advantageous areas for fire 

suppression actions. As managers continue to move the forest toward the desired condition, fire 

would be able to resume its natural role in developing and sustaining these ecosystems. Continued 

management practices can and will alter the effects of wildland fire (Agee and Skinner 2005).

As the vegetation matures, fuel loadings would increase. Continued maintenance through prescribed 

fire is designed to achieve the desired condition that would maintain fuel profiles allowing fire to 

resume its ecological role and meet Forest Plan Direction.

Suppression actions would not be restricted by fire behavior; thus direct suppression actions would be 

possible within the young plantations (Fites et al. 2010). 

The effect on fire suppression forces beyond year 20 would depend on the continued maintenance of 

the plantations. Proposed site preparation and release treatments followed by the reintroduction of fire 

into these young stands would help maintain the desired condition and not adversely impact future 

suppression. FlamMap 5.0 modeling program was used to project fire effects and production rates for 

Alternative 1. Predicted flame lengths would be less than or equal to four feet for the first 20 years 

post implementation. Fireline intensity (the rate of energy or heat release per unit length of fire front) 

would be less than 100 feet over the next 20 years. This means fires can generally be attacked at the 

head or flanks by persons using hand tools and hand line should hold the fire. 

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Alternative 1 utilizes a variety of planting patterns including low density and widely spaced patterns 

on fuelbreaks and adjacent to emergency travel routes and fewer trees per acre in clumpy patterns in 

the majority of the landscape where Open Forest Mosaic is the desired future condition. Short-term, 

within the first 20 years, these different spatial patterns do not lessen tree mortality because of 

seedling size and the amount of brush present post-reforestation treatments. These patterns also have 

no effect on flame length, fireline intensity or fuel loading because at this stage of development either 

small trees or brush will occupy the site and both have similar flammability and burn patterns.

Maintaining fuelbreaks over time would potentially reduce fire size, increase tree survivability and 

create potential anchor points and contingency lines for suppression resources. Emergency travel 

routes would create safe ingress/egress routes during wildfire events.

Long-term, the proposed units would create a fire resilient forest with a more historic heterogeneous 

structure where fire is an integral part of the system in the project area. Unit prescriptions and 

Strategic Fire Management Areas would affect fire movement on the landscape and provide 

advantageous areas for fire suppression actions. Commercial thinning could be used to maintain the 

desired stand structures and shaded fuel breaks as well as fuel treatments within the SFMAs, 

fuelbreaks and emergency travel routes.

Deer habitat enhancement units would have similar effects as the reforestation units discussed above 

because they would have similar treatments. In addition, this area calls for more prescribed fire to be 

utilized for brush reduction and within plantations to maintain smaller pockets of conifers for habitat 

needs. More frequent prescribed fire would keep the fuel loadings at a lower level.

Within existing plantations, thinning of densely planted stands into an ICO structure would increase 

survivability by reducing the continuity of fuels and the likelihood of crown fire. In addition, thinning 

these stands would encourage faster tree growth of the remaining trees, allowing them to become 

more resilient to future low intensity fires. 

Invasive species alter the natural vegetative pattern, often providing more flammable fuels into the 

system. Eradication of the noxious weeds and their flashy fuel conditions would allow native 

vegetation to return to these landscapes beneficially affecting fire behavior. 

Alternative 1 proposes treatments that would improve and maintain lower fuel levels within newly 

establishing forests which would not only promote the recovery of this landscape, but allow fire to be 

an integral part of it. It attempts to ensure long-term tree survival as well as protecting fire fighters 

and property. 

CUMULATIVE EFFECTS

Previously implemented and foreseeable fire salvage, thinning and fuels treatments on both private 

and NFS lands, in conjunction with Alternative 1, would enable effective fire suppression action to be 

conducted. Incorporating fuelbreaks and emergency travel routes into the initial planting design under 

this alternative would provide connectivity of these features within previously implemented projects. 

Coordinated fire suppression tactics would be easier to implement across all ownerships. With these 

conditions, future fires would burn as surface fires with low flame lengths and fireline intensities. 

These lower-intensity fires could be suppressed using direct attack with handtools. 

Alternative 2 (No Action)

DIRECT AND INDIRECT EFFECTS

In Alternative 2 no planting or associated site preparation and release treatments, which would 

maintain fuels at a relatively low density, would take place. Existing plantations would remain 

overstocked with dense contiguous canopies and ladder fuels. In addition, none of the noxious weed 

eradication or deer habitat enhancement would occur leaving less desirable non-native fuel types 

throughout the area. 

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Existing conditions would persist and develop unaltered by active management. It is a reasonable 

expectation that areas within the Rim Fire would develop in a similar manner as those non-planted

areas in other recent local fires. Examples of such fires include the Big Meadow Fire (2009), North 

Mountain Fire (2008), Early Fire (2004), the Ackerson Fire (1996) and Larson Fire (1987). In those 

areas, grasses such as cheat grass (Bromus tectorum) and various shrubs including ceanothus (C. 

cordulatus, C. velutinus) and manzanita (Arctostaphylos patula) now fully occupy the site and limited 

amounts of conifers have returned. Post-fire vegetation plots taken in proposed reforestation and 

natural regeneration units within high burn severity areas show that an average of more than 70% 

vegetative cover has returned to these areas and less than 40% (including the proposed natural 

regeneration units) have any natural regeneration.

Figure 3.05-1 shows shrub regeneration two years after the Rim Fire. Very few live trees per acre 

characterize the forest structure following a high-intensity fire, resulting in limited natural conifer 

regeneration. Over time, ladder and crown fuels would develop where natural regeneration 

established. 

Figure 3.05-1 Shrub Regeneration Two Years after the 2013 Rim Fire

Not implementing treatments would result in increased surface fuels and increased crown scorch 

volume resulting in higher tree mortality on the natural regeneration that does return. Overall, 

Alternative 2 would not reduce future surface fuels or predicted fire effects in both the reforestation 

and deer habitat enhancement areas. 

None of the proposed fuelbreaks, emergency travel routes, or SFMAs would be maintained over time 

creating less safe ingress/egress routes for fire firefighters during wildfire events and fewer anchor 

points for suppression. 

Existing over-stocked plantations would remain vulnerable to wildfire since they would not be 

thinned to the desired ICO structure. Tree mortality would be far higher in these stands where 

contiguous interlocking crowns would carry wildfire. These unthinned stands would also have higher 

flame lengths, higher fireline intensity and much higher fuel loading than those thinned in the action 

alternatives where the ICO structure would create openings and heterogeneity in the fuels across these 

units. 

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Eradication of noxious weeds and their flashy fuel conditions would not occur. Invasive species 

would continue to provide more flammable fuels in these areas negatively affecting fire behavior.

CUMULATIVE EFFECTS

Under Alternative 2, the salvage and fuels reduction treatments that occurred under the Rim HT and 

Rim Recovery projects would still remove hazard trees along Forest Service roads and accomplish the 

initial reduction of fuels to 10 to 20 tons per acre. Without the maintenance of these fuel levels and 

the reduction of brush from the action alternatives, much of the gain in the effects to fire behavior 

would be lost within a few years. When the effects of Alternative 2 are combined with the effects of 

implementing the foreseeable activities (Appendix B), this alternative would not maintain the 

SFMAs. Neither would it aid in future fuels management, suppression, or beneficial fire planning 

objectives. The cumulative effects of No Action would be an increase in fire behavior over time and 

negative fire effects on the landscape.

Alternative 3

DIRECT AND INDIRECT EFFECTS

Alternative 3 differs from Alternative 1 in the number of acres that would have site preparation and 

the methods of treatment. No herbicides would be used under this alternative which reduces the site 

preparation acres by 12,407 and the noxious weed treatments by 2,565 acres, but would treat the same 

number of deer habitat enhancement acres. In addition, the release treatments would only be grubbing 

vegetation in five foot radius circles around each seedling which means less than half of the area 

would have vegetation removed during each treatment (e.g. a unit with 250 seedlings per acre would 

only grub 45% of the area). This would leave the vegetation adjacent to these circles free to grow 

uninhibited. Although many of the effects would be similar to Alternative 1, these differences in the 

amount and size of vegetation on site would likely negatively affect tree mortality, flame length, 

fireline intensity and fuel loading. The five foot radius circles should break up the continuity enough 

to make these affects minor within the first 10 years of plantation development.

This alternative proposes to establish fuelbreaks and SFMAs throughout the landscape similar to 

Alternative 1; the difference is in the fuelbreak design. It proposes increasing the amount of nonplanted area within the fuelbreak for ease of maintenance and fire fighter safety during wildfires.

CUMULATIVE EFFECTS

Same as Alternative 1.

Alternative 4

DIRECT AND INDIRECT EFFECTS

Alternative 4 serves to enhance the opportunity to achieve the overall goal in the Forest Plan to 

reintroduce fire by proposing prescribed burning on more than 19,000 additional acres within the 

project area. As managers continue to move the forest toward the desired future condition, fire would 

be able to resume its natural role in developing and sustaining these ecosystems. Alternative 4 

proposes only planting 20% of the area in 2 to 10 acre blocks, but burning the adjacent areas (almost 

32,000 acres) every 20 years. It does not propose re-introducing fire into the young plantations at year 

10 or creating SFMA areas or features. However, utilizing prescribed fire outside of the reforestation 

areas to maintain low fuel levels would result in desirable fuel conditions across this landscape and 

likely prevent damage to young plantation during wildfires. Within the founder stands, none to 

limited tree mortality would be expected because these areas are being treated with herbicide to 

maintain a low brush component and provide a treated buffer enabling fire crews to protect them 

during implementation. However, the founder stand concept of natural regeneration occurring 

adjacent to these areas as planted trees mature and seed spreads would have high seedling mortality 

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during prescribed fire operations. Burning in a mosaic pattern across the landscape would enable 

some trees to survive to maturity over time, but most would be lost during implementation. 

CUMULATIVE EFFECTS

Even though no fuelbreaks or emergency travel routes are proposed in this alternative the amount of 

prescribed burning throughout the area would provide connectivity of these features within previously 

implemented and future projects. Coordinated fire suppression tactics would be easier to implement 

across all ownerships, similar to Alternative 1.

Alternative 5

DIRECT AND INDIRECT EFFECTS

Similar to Alternative 1. Although the initial planting design does not propose Strategic Fire 

Management Areas or Features, the pre-commercial thinning at age 7 would create these desired 

structures. Not re-introducing fire into the plantations would lower the tree mortality in these stands 

in the short-term, but in the long-term increase the flame length, fireline intensity and fuel loading. 

CUMULATIVE EFFECTS

Same as Alternative 1.

Summary of Effects Analysis across All Alternatives

In the short-term (20 years) the difference in tree characteristics effecting fire related mortality 

between alternatives is negligible. However, the action alternatives are designed to help protect forest 

stands through the incorporation of fuelbreaks and travel routes or vegetation control that would aid 

in fire suppression effectiveness and increase the likelihood of tree survival.

All action alternatives would have the same flame length over first 20 years post planting. Alternative 

2 is projected to have double the flame length over the first 5 years and over three times the flame 

length by year 20 (13 feet compared to only 4 feet). Fireline intensity inside treated units would be the 

same for all action alternatives, but Alternative 2 would be far higher after just five years (100 versus 

500) and by age 20 it is projected to be 10 times the rate present in the treated units. 

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Fire and Fuels National Forest

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Draft Environmental Impact Statement and Environmental Consequences

3.06 INVASIVE SPECIES

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction

The following direction guides management of invasive plants on NFS lands: 

 Executive Order 13112 Invasive Species 64 FR 6183 (Clinton 1999) 

 FSM 2900 (USDA 2011) 

 Pacific Southwest Region Noxious Weed Management Strategy (USDA 2000) 

 Noxious Weed Management Standards and Guidelines (USDA 2010a, p.52) 

The Forest Plan Compliance (project record) document identifies the Forest Plan Standards and 

Guidelines that specifically apply to this project and related information about compliance with the 

Forest Plan.

Effects Analysis Methodology

Assumptions Specific to Invasive Species

 Existing plant survey data covers approximately 98% of the total project area.

 New and expanding infestations will result from habitat alterations caused by the fire (e.g. 

decreased canopy cover, increased nitrogen and water availability) and fire suppression activities.

 The risk of creating new or expanding invasive populations throughout the project area depends 

on a variety of factors (these factors are listed in the Summary of Effects Analysis across All

Alternatives section).

 Without specific prevention and control measures, invasive non-native plants (noxious weeds) 

will continue to spread along and within project areas and into adjacent areas.

 Weeds are likely to persist long term once they are established in meadows.

Data Sources

 GIS layers of invasive plant infestations and units based on GIS shapefiles provided by the MiWok and Groveland District botanists with data collected from 2006 to 2015. 

 Information on species status, distribution, and ecology was derived from general literature 

reviews, Forest Service documents, the Forest Service Fire Effects Information System, 

California Department of Fish and Wildlife, various field books, floras, and personal 

communications. Site surveys, in conjunction with literature and input from the District botanists 

were used to determine the potential occurrence of each species, its habitat and its priority for 

eradication and control.

Invasive Species Indicators

 Acres within ground-disturbing project locations containing infestations of invasive plant species.

 Acres planned for eradication treatments or reforestation (site preparation and release) treatments.

Invasive Species Methodology by Action

This analysis evaluates the factors influencing invasive plant introduction and spread by considering 

the risks of, and vulnerability to, invasive plant establishment. 

Affected Environment

Existing Conditions

Thirty species of non-native and invasive plants are present or adjacent to (within 5 miles) the project 

area (Table 3.06-1). Bachelor button, cheat grass, scotch broom and Spanish broom are within the 

Rim Fire perimeter, but are not proposed for treatment within this project or shown in the table below. 

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Table 3.06-1 also shows the non-native invasive species (NNIS) known population acres proposed for 

treatment in each alternative.

Table 3.06-1 Invasive Species within Rim Fire and Known Populations Proposed for Treatment

Name In Rim Fire

(acres)

Alternative 1

(acres)

Alternative 3

(acres)

Alternative 4

(acres)

Alternative 5

(acres) Project Priority1

Barbed goatgrass 4.70 3.37 3.37 3.37 3.37 High

Blackberry, cutleaf0.11 0.06 0.06 0.06 0.06 Low

Blackberry, 

Himalayan

24.56 24.56 5.00 5.00 24.56 Low

Black mustard 1.33 1.31 1.31 1.31 1.31 Moderate

Bull thistle 327.73 327.73 51.81 51.81 327.73 High (dense infestations); 

Low (scattered plants)

Canada thistle 0.29 0.04 0.04 0.04 0.04 High

Dyers woad 0.74 0.74 0.74 0.11 0.74 High

Field bindweed 0.73 0.003 0.00 0.00 0.00 Moderate

French broom 0.40 0.40 0.40 0.40 0.40 Moderate

Italian thistle 30.41 25.60 14.23 14.23 25.60 High

Johnsongrass3 4,297.94 429.72 0 0 429.72 Moderate

Klamathweed 2.20 1.22 1.17 1.17 1.22 Low

Medusahead 

grass

3,486.23 3,139.33 2,472.72 2,472.72 3,139.33 High

Milk thistle 0.35 0.12 0.12 0.12 0.12 Moderate

Oxeye Daisy 0.04 0.04 0.04 0.04 0.04 High

Perennial 

sweetpea

2.40 2.40 2.40 2.40 2.40 Moderate

Puncturevine 0.10 0.00 0.00 0.00 0.00 High

Shortpod 

mustard

0.04 0.04 0.04 0.04 0.04 Moderate

Spotted 

knapweed

1.23 0.87 0.73 0.73 0.87 High

Sulphur 

cinquefoil

182.34 182.34 182.34 182.34 182.34 High

Tall Sock 

destroyer

0.02 0.02 0.02 0.02 0.02 Low

Tocalote 1,045.80 410.86 0.39 0.39 410.86 High

Tree of Heaven 0.00 0.00 0.00 0.00 0.00 Moderate

Tumble mustard 107.08 102.64 102.45 102.45 102.64 Moderate

Woolly mullein 196.23 196.23 14.52 14.52 196.23 Moderate (dense 

infestations); Low (scattered 

plants)

Yellow star-thistle 2,461.57 706.13 179.06 179.06 706.13 High

Totals 12,174.66 5,555.75 3,032.96 3,032.96 5,555.75

1 Project priority was determined by the invasive characteristics, habitat degradation potential, state rating, prevalence across the fire area 

and control factors of the plant. In addition, the risk of potential seed and reproductive part spread from project activities was considered. 20.00 Population size is less than a hundredth of an acre.

3Johnsongrass acres are mapped to heli-mulch units, and actual treatment acres are assumed to be one tenth of the acreage shown in 

mapping.

Ten species, including barbed goatgrass (Aegilops triuncialis), Italian thistle (Carduus 

pycnocephalus), tocalote (Centaurea melitensis), yellow star-thistle (Centaurea solstitialis), spotted 

knapweed (Centaurea stoebe ssp. micranthos), Canada thistle (Cirsium arvense), bull thistle (Cirsium 

vulgare), dyer’s woad (Isatis tinctoria), medusahead grass (Taeniatherum caput-medusae) and 

puncturevine (Tribulus terrestris) are considered high risk species from project activities. Eleven 

other species, including, bachelor buttons (Centaurea cyanus), field bindweed (Convolvulous 

arvensis), Scotch broom (Cytisus scoparius), French broom (Genista monospessulana), shortpod 

mustard (Hirschfeldia incana), perennial sweatpea (Lathyrus latifolius), milkthistle (Silybum 

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Draft Environmental Impact Statement and Environmental Consequences

marianum), tumblemustard (Sisymbrium altissimum), johnsongrass (Sorghum halepense), Spanish 

broom (Spartium junceum) and wooly mullein (Verbascum thapsus), are considered a moderate risk. 

The remaining five species are considered low risk. The Noxious Weed Risk Assessment (project 

record) includes a complete discussion of characteristics specific to each species, habitat impacts and 

recommended management tools. 

Past actions involving ground disturbing activities such as timber removal, fuel reduction, road and 

trail creation or maintenance, grazing, unauthorized motorized use and other dispersed recreation 

have impacted invasive plant infestations across the project area. The invasive species known to occur 

within the project area before the Rim Fire were introduced and spread primarily through transport on 

vehicles, in straw and hay, on earthmoving, mowing or weed-eating equipment, and on animals and in 

their manure associated with these activities. Weed seeds also spread quickly down streams and 

upwind along lakes and reservoirs. Livestock grazing also contributed to weed spread, due to 

transportation on their fur, decreased native grass and forb cover from preferential grazing (avoiding 

the less palatable invasive species), trampling, and other soil disturbances (Olson 1999). 

Given the current data (Table 3.06-1), Medusahead grass, tocalote, yellow star-thistle, bull thistle and 

johnsongrass are by far the most common species within the project area. Johnsongrass acreages are 

mapped to helimulch units, and actual treatment acres are assumed to be one tenth of the acreage 

shown in mapping. To a lesser extent, several other invasive weed species occur, primarily along 

roads. It should be noted however, that it is highly likely that many of the lower priority invasives 

(such as cheatgrass) are mapped at a fraction of their actual occurrence acreage given their 

commonality. All proposed treatment areas will be surveyed prior to implementation as per 

management requirements.

The risk of creating new or expanding populations depends on a variety of factors:

 Species-specific dispersal traits of weeds. Weed species with seeds dispersed by wind (Italian 

thistle), by tumbleweed (shortpod mustard), water (tamarisk), or animals (Medusahead grass) can 

potentially spread weed propagules miles from their original sources. Most seeds are not moved 

far from the parent plant, but a small proportion of seeds can be found large distances away. Even 

propagules with low innate dispersal abilities, such as stem fragments of giant reed or castor bean 

seeds which fall close to the plant, can be carried a great distance after initial dispersal by streams 

or surface runoff. However, species without wind, water, or animal-mediated dispersal are less 

likely to disperse propagules far from the original source. 

 Habitat disturbed. While many weed species are generalists that can potentially colonize a fairly 

wide range of habitat types, those with ample nutrients and soil moisture or those that have been 

recently disturbed, are more susceptible to invasion. Additionally, the suite of weed species one 

would expect to colonize a site is dependent to some degree on the habitat where the disturbance 

occurred. 

 Regional patterns in weed occurrence and propagule pressure. The project occurs across a 

transitional area with regards to microclimate, elevation, and vegetation communities. The most 

commonly observed weeds differed within these areas, possibly due to species-specific habitat 

preferences.

 Type of ground disturbance. The type of disturbance creates conditions favoring release and 

establishment of different weed species. For example, tree removal is expected to favor the 

establishment of weed species that do best in full sun, such as yellow star-thistle; burning is 

expected to favor the establishment of fire-adapted weed species such as French broom; and soil 

disturbance is expected to favor the establishment of early-colonizing weed species, such as 

mustards or tocalote, that respond favorably to disturbed, denuded soils. 

 Planned treatment of known infestations and use of standard management requirements. 

Treatment of NNIS occurrences are planned in all of the action alternatives. Additional treatment 

of NNIS would occur through site preparation and release activities by herbicide in Alternatives 

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1, 4 and 5. All action alternatives propose treatment of NNIS, but prescribe different techniques 

and differing amounts of treatment. Standard management requirements would reduce the risk of 

spread within the project area and are prescribed for all action alternatives.

These factors were used to consider the risks associated with the establishment of new weed 

infestations due to project activities. In addition to these 5 factors, the results of the Noxious Weed 

Risk Assessment focused on risks associated with the 1) release of pre-existing but currently dormant 

weed seed banks at disturbed sites; 2) rapid build-up of transient weed seed banks at disturbed sites; 

and/or 3) creation of conditions favoring weed establishment at disturbed sites. 

Environmental Consequences

Project-related activities under all action alternatives, could contribute to an increase in invasive 

plants in three major ways: 1) the creation of conditions that favor establishment of invasive plant 

(weed) species, such as soil disturbance, removal of native vegetation, or the breakup of cryptogamic 

crusts6

, 2) spread of new and pre-existing weed infestations into newly disturbed areas via project 

tools, equipment, and personnel; and 3) the subsequent release of pre-existing weed seedbanks from 

dormancy or the quick build-up of new weed seedbanks on disturbed soils. 

Table 3.06-2 displays acreages for ground disturbing treatments in each alternative. The acreages 

listed are cumulative, and no attempt is made to remove overlapping areas of treatment. Treatments 

leading to soil disturbance and canopy reduction are likely to facilitate the spread of NNIS. 

Alternative 3 is the highest in cumulative acres of ground disturbing activities because of hand 

grubbing which would expose thousands of acres of bare soil (scattered in small patches across each 

unit) for up to five years. The other action alternatives have similar acres of disturbance, but the type 

of disturbance varies. Alternatives 1 and 4 would create more bare ground following prescribed 

burning activities as opposed to Alternative 5 which would hand thin young trees at age 7 and create 

small piles of slash for burning. These burned areas would create fertile habitat for invasive species, 

but be far more isolated and dispersed than the broadcast burns proposed in Alternatives 1 and 4. 

Table 3.06-2 Ground Disturbing Activities by Alternative

Treatments Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5

Mechanized equipment 5,895 0 5,895 248 6,194

Deep till and forest cultivate 5,085 0 8,893 0 5,085

Release with grubbing2 0 0 14,415 0 0

Prescribed fire 21,300 0 21,300 32,112 0

Thin new plantations 0 0 0 0 25,3311

Totals3 (acres) 32,280 0 50,503 32,360 36,610

1 Treatment would only be done where needed to create desired ICO structure and to meet fire and fuels structure goals. 2 Assumes 40% of the total acres will be disturbed through hand grubbing. 3 Cumulative total acres of ground disturbing activities leading to soil disturbance and facilitating weed spread.

The results of the Noxious Weed Risk Assessment focused on risks associated with three avenues for 

weed proliferation: 1) the release of pre-existing, but currently dormant, weed seed banks at disturbed 

sites; 2) the rapid build-up of transient weed seed banks at disturbed sites; and 3) the creation of 

conditions favoring weed establishment at disturbed sites. The risks are labeled “high, moderate and 

low,” and are defined as follows:

 High: Chances of weed species infesting new areas range between 76 to 100%. 

 Moderate: Chances of weed species infesting new areas range between 31 to 75%. 

 Low: Chances of weed species infesting new areas range between 1 to 30%. 

6 Crypotogamic crusts are biological soil crust composed of living cyanobacteria, green algae, brown algae, fungi, lichens, and/or mosses.

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Draft Environmental Impact Statement and Environmental Consequences

Each action alternative is expected in general to be high risk (a 76 to 100% chance) for the potential 

to establish new populations of invasive species, specifically those listed as high and moderate 

priority in Table 3.06-1. This high risk ranking was chosen after careful consideration of the first four 

factors listed in the Affected Environment section (e.g. weed species dispersal traits, habitat 

disturbed, regional patterns in weed occurrence and types of disturbance), and the three avenues for 

weed proliferation stated previously. For each of the action alternatives, the ranking was determined 

to be in the high category. Those areas that are outside of the historic fire burn return interval (i.e., 

burning more or less frequently) are expected to have an even higher risk (yet still within the high risk 

category) of experiencing vegetation type conversion in the project area. 

Alternative 1 (Proposed Action)

DIRECT AND INDIRECT EFFECTS

Disturbance by heavy equipment can have long-term effects to soils and favor weed establishment if 

unmitigated. Heavy equipment can compact soils, reducing water infiltration and accelerating 

erosion. It can also displace soils and sheer off vegetative roots. If these effects are severe, a loss of 

soil productivity may occur. Numerous passes by equipment over vegetation often causes plant 

mortality or severe injury, exposing the soil organic layer and making it more susceptible to erosion. 

Loss of vegetative cover and the soil organic layer reduces the ability of the soil to hold moisture. 

Many weed species are more capable of utilizing less productive soils with less soil moisture. In 

addition, some weeds produce secondary chemical compounds that inhibit native plant germination 

and growth. These compounds also affect nutrient cycling rates by inhibiting soil microbial fauna 

activity (Sheley et al. 1999). 

Even those project sites in remote areas may be expected to contain an existing weed seedbank. 

Seedbanks are known to regularly contain a different suite of species than is represented by the 

standing vegetation due to succession, low reproduction rates of some perennials (by seed), and other 

factors (Thompson 2000). In most cases it is rare to find species in the seedbank that are not 

represented to any degree in the above-ground vegetation; the exception being seeds from invasive, 

aggressive, disturbance-adapted, and early colonizing weeds (Thompson 2000). For example, large 

cheatgrass seedbanks are commonly found throughout western North America, often regardless of 

such factors as remoteness of the site, grazing, or fire history. Within intact native communities these 

seeds are typically held in the above-ground vegetation or in crevices on cryptogamic crusts. 

Germination is therefore prevented until disturbance allows the cheatgrass seeds to come into contact 

with broken soil surfaces (Boudell et al. 2002).

Following establishment, new populations of weeds are often extremely difficult to eliminate, and 

even if controlled or eradicated, it may take several years or decades to re-establish native soil 

structure and biota. If allowed to expand, dense infestations can occur that not only displace native 

plants and animals, but also threaten natural ecosystems by fragmenting sensitive plant and animal 

habitat (Scott and Pratini 1995). For example, when equipment disturbance activities introduce or 

release weeds, the vegetative pattern is changed, often providing more flammable fuels into the 

system. As the weeds spread and increase in volume, an increase in ladder fuels occurs. Weeds such 

as Scotch broom, Medusahead, barbed goatgrass, yellow star-thistle and others, change the 

arrangement of vegetation, the amount of soil moisture at specific times of the year, the amount of 

fuel available to burn, and how fire behaves (Keeley et al. 2011). These changes in fire behavior often 

mean that areas that would not ordinarily burn frequently or at high intensity are now doing so 

(DiTomaso and Healy 2007). This is especially a concern in dry lava cap areas where weed species 

compete with sensitive plants.

Deep tilling under Alternative 1 would expose soil to colonization by weed species, but the associated 

planting could reduce this effect in the long term by establishing a canopy to discourage the continued 

occupation of the site by sun-loving weed species. Follow-up herbicide treatments would also greatly 

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reduce the likelihood of weeds spreading in deep-tilling units. Prescribed burning would have mixed 

effects depending on the species response to fire, but in general clears the understory and provides 

areas for weeds to spread into.

Alternatives 1 and 5 have the highest number of weed treatment acres prescribed, 5,915 acres. Most 

of those acres (over 95%) would also be indirectly treated with herbicide during site preparation and 

release activities. These treatments and the implementation of standard management requirements 

reduce the risk of further weed spread from Alternative 1 from high to moderate. 

CUMULATIVE EFFECTS

Factors which are not planned and are difficult to control (e.g., wildfire, dispersed recreation use, 

grazing, climate change) will likely have the greatest cumulative impact to native plant communities 

from the expansion of invasive plants for the action alternatives. Fully implementing any of these 

alternatives would add to this cumulative effect. For the purpose of this analysis, cumulative effects 

of past activities or natural events are represented within the existing conditions.

All of the activities listed in Appendix B, which spatially and temporally intersect with the project 

area, will contribute to effects on invasive plant proliferation. Within the project area, the Rim HT 

and the Rim Recovery projects are the two largest sources of ground disturbance for noxious weeds. 

These projects have the primary activities that will alter forest vegetation and impact invasive plants; 

most of the weed risk assessments for these projects show the risk to be moderate when management 

requirements are followed. Recreation management, road and trail work and decommissioning of 

unauthorized routes are additional ground disturbing activities anticipated to occur in the foreseeable 

future. Livestock grazing within the project area (13 allotments) may also proliferate weeds. All of 

these activities, in addition to other recreation activities such as dispersed camping, were ranked as 

low to moderate risk. 

These present and future projects are cumulative in nature in that some of them overlap spatially with 

the project areas, but all of them impact the ability of the Forest Service to feasibly and adequately 

manage invasive plant proliferation. With all the different projects occurring across the forest (hazard 

tree removal, fuel treatments, etc.), several of which are thousands of acres in size in addition to the 

large size of the Rim Fire itself, it becomes very difficult to physically visit all the affected areas, let 

alone perform time consuming hand removal of invasives in an adequate manner. Because of 

overlapping implementation timeframes of this project and above mentioned projects, it is also 

difficult to acquire the trained personnel necessary for mitigating project impacts.

Alternative 2 (No Action)

DIRECT AND INDIRECT EFFECTS

Under Alternative 2, areas which currently have invasive plants would continue to support these 

species, providing seed sources for dispersal into adjacent areas. However, this alternative would 

eliminate the high risk of directly and indirectly spreading weeds from ground disturbing activities 

(all part of Alternatives 1, 3, 4 and 5). The reduction in invasive plant spread would equate to lower 

risk for vegetation type conversion to non-natives and better habitat and hydrologic function 

throughout the project area. 

The risk of noxious weed spread is the highest under Alternative 2. Known noxious weeds would not 

be actively managed under this alternative. Additionally, much of the project would remain in a 

disturbed state and canopy levels would not be re-established. The majority of the known noxious 

weeds in the project area are sun loving and are prone to being shaded out under heavy canopies. The 

most important factors for reducing the risk of weed spread in the project area are reforestation 

treatments which re-establish resiliency to noxious weed invasion in conjunction with treatment of 

known noxious weeds. 

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Draft Environmental Impact Statement and Environmental Consequences

CUMULATIVE EFFECTS

All of the activities listed in Appendix B, which spatially and temporally intersect with the project 

area, will contribute to effects on invasive plant proliferation. Since no weed eradication would occur 

under Alternative 2, existing populations would also continue to spread throughout this area and 

adjacent activities would contribute to this spread. Factors that are not planned and difficult to control 

(e.g., wildfire, dispersed recreation use, grazing, and climate change) will likely pose the greatest risk 

of proliferating invasive plants. 

Alternative 3

DIRECT AND INDIRECT EFFECTS

Alternative 3 has a higher risk to spread weeds in the project area compared to Alternative 1. This 

alternative proposes 21,300 acres of hand grubbing that would expose thousands of acres of bare 

mineral soil for 5 years. Additionally this would preclude the indirect treatment of weeds through 

herbicide release. Alternative 3 only allows for hand and non-herbicide treatments of known 

infestations within the project area on 3,350 acres of weeds (2,565 fewer acres than Alternative 1). 

Non-herbicide treatments would likely result in less effective control of some species and require 

more treatments to ensure full eradication of those populations that can be eliminated. In summary, 

because Alternative 3 has the highest amount of ground disturbance and less effective noxious weed 

treatments the risk of noxious weed spread is high.

CUMULATIVE EFFECTS

Same as Alternative 1.

Alternative 4

DIRECT AND INDIRECT EFFECTS

Alternative 4 has a larger footprint than Alternatives 1 and 5 and relies heavily on natural 

regeneration and prescribed fire to meet project objectives. Some acres of indirect herbicide control of 

noxious weeds would occur during chemical site preparation and release treatments that overlap 

weeds. All planned noxious weed treatment would be done without herbicides, and would have the 

same effects as Alternative 3. The risk of spreading weeds through Alternative 4 would be high due to 

the larger amount of ground disturbance, indirect treatment of weeds with herbicides during 

reforestation, and the planned treatment of 3,350 acres of known infestations. 

CUMULATIVE EFFECTS

Similar to Alternative 1, but in a larger spatial area.

Alternative 5

DIRECT AND INDIRECT EFFECTS

Alternative 5 is similar to Alternative 1. Differences include; additional acres of reforestation versus 

natural regeneration and no post-planting broadcast burning, but instead pile burning within 

plantations thinned to achieve ICO structure and fuels objectives. This would leave far fewer acres of 

exposed soil resulting in lower potential weed spread. The acres of weeds planned for treatment with 

herbicide and those indirectly treated with herbicide are the same as Alternative 1. Alternative 5 

would have a moderate risk of increasing the chance of weed spread for the same reasons as those 

presented in Alternative 1.

CUMULATIVE EFFECTS

Same as Alternative 1.

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Chapter 3.06 Stanislaus

Invasive Species National Forest

Summary of Effects Analysis across All Alternatives

Action alternatives 1 and 5 have roughly the same affected environment and acreage of invasive plant 

species across similar treatments (Table 3.06-2). The direct, indirect and cumulative effects are also 

expected to be very similar. These alternatives are expected to have a moderate risk of spreading 

invasives.

Alternative 4 has a high risk due to its increased amount of ground disturbing activities. Alternative 3 

has a high risk of spreading weeds due to a high level of ground disturbance, no indirect benefit of 

treating weeds through reforestation activities and the use of non-herbicide tools for planned weed 

treatments. Alternative 2 has a high risk of spreading weeds since no treatments would occur and 

canopy levels would not be returned to pre-fire levels as quickly.

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Draft Environmental Impact Statement and Environmental Consequences

3.07 RANGE

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction

Legislative authorities for administration of the National Forest System range program are shown in 

FSM 2201 and objectives, policies, and responsibilities are in the FSM 2202 through 2204 and FSM 

2230 through FSM 2238 (USDA 2005a). Forest Plan Direction (USDA 2010a) provides current 

management direction for the range program. 

The Forest Plan Compliance (project record) document identifies the Forest Plan Standards and 

Guidelines that specifically apply to this project and related information about compliance with the 

Forest Plan.

Effects Analysis Methodology

Assumptions Specific toRange

 The authorization for livestock grazing and the administration of allotments will not change with 

any of the alternatives. 

 The area proposed for reforestation, thinning, and noxious weed eradication activities reflects the 

relative degree of impact each alternative will have on permitted grazing in the project area.

 Monitoring will occur during project implementation to inform livestock managers about project 

effects on grazing use and rangeland resource conditions. Adjustments are not anticipated, but if 

needed would occur through the regular permit administration process and be coordinated with 

affected permittees.

 Given sufficient notice, grazing permittees have the ability to manage livestock in ways that 

minimize potential adverse impacts of project activities (herbicides, site preparation and release) 

on grazing operations. 

Data Sources

The following information was used to describe existing condition and analyze effects on rangeland 

resources.

 Field visits to project area

 Local professional knowledge

 Project treatment information

 Allotment and unit/pasture boundaries 

 Land ownership data

 Post-fire capable rangeland 

 Rangeland infrastructure data

 Transportation data

Range Indicators

The following indicators were used to assess the effects of each alternative on rangeland resources.

 Proposed treatment area in each allotment (percent of allotment proposed for treatments)

 Proposed treatment area in capable rangelands within each allotment

 Amount of range infrastructure encompassed by proposed treatments 

Range Methodology by Action

Quantitative and qualitative comparisons of the anticipated impacts of each alternative on rangeland 

resources and the expected potential for moving existing conditions toward Forest Plan desired 

conditions were used for determining the effects on rangeland resources.

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Chapter 3.07 Stanislaus

Range National Forest

Affected Environment

Existing Conditions

The 2013 Rim Fire affected thirteen grazing allotments to varying degrees depending on the 

proportion of the allotment burned or fire severity in the burned areas. The following information 

applies to grazing allotments within the Rim Fire Reforestation project area.

Rangeland Vegetation

Current rangeland vegetation conditions are the combined result of pre-fire conditions and fire effects 

on the landscape. Some vegetation types burned more severely (chaparral), but species that dominate 

these plant communities are well adapted to recover from fire. Unburned areas and areas that burned 

at low severity are in a condition similar to that before the fire. Burned areas are naturally recovering 

following the Rim Fire, and vegetation condition has shown gradual improvement, even in severely 

burned areas.

The degree of recovery is varied based on environmental factors such as climate, soils and land 

management activities. Recognizing differences in vegetation types, identifying the stages of recovery 

and being responsive through changes in management are crucial to facilitating recovery of the 

burned landscape. Fire can cause a large scale vegetation type conversion to predominantly non-forest 

vegetation types, with many areas often dominated by brush within a few years following fire. The 

post-fire flush of palatable and nutritious forage helps to reduce utilization percentages and improve 

overall rangeland vegetation condition as recovery progresses.

Capable rangeland describes areas of land that can sustain domestic grazing and generally represent 

the portions of the landscape assumed to be most commonly used by cattle (USDA 2004a). Capable 

rangeland can be used to compare the relative amount of available grazing lands within allotments.

Livestock may graze incidentally in any area of an allotment while moving between capable grazing 

areas, but tend to spend a larger proportion of time in capable areas. Deerbrush (Ceanothus 

integerrimus) is the predominant local forage species used by livestock in the mid-elevation range of 

3,500 to 6,000 feet. Riparian areas and meadows, which occur as patches within the forest mosaic, are 

also preferred by livestock due to the availability of water, shade and high quality forage. Livestock 

also feed in forested areas and forest openings where sufficient understory forage exists. 

Due to the dramatic increase in shrub-dominated transitory range following fire, capable range has 

increased significantly in the project area. Forage production has increased dramatically in some areas 

in large part due to the abundance of deerbrush and other brush species in burned previously forested 

areas. This increase in livestock browse is desirable from a grazing standpoint, but is generally 

considered to be temporary as shrubs eventually grow above browse height and parts of the landscape 

transition over time towards tree-dominated plant communities (Crotteau et al. 2013). 

Noxious Weeds

Throughout the United States, weeds in rangeland settings cause an estimated loss of $2 billion 

annually (Quimby et al 1991). Noxious weeds, such as leafy spurge, knapweed, and yellow starthistle, can significantly reduce the carrying capacity of grazing lands. Forage can be reduced 

between 35 and 90% on weed-infested rangelands (USDI 1985). Ecologic costs of weed infestations 

are many. Weeds can reduce plant diversity, reduce wildlife habitat and forage, alter fire frequency, 

increase erosion, displace rare or sensitive plant species, and deplete soil moisture and nutrient levels 

(DiTomaso 2000). High severity fires increase the potential for weed invasion and spread (Keeley et 

al. 2003). 

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Draft Environmental Impact Statement and Environmental Consequences

Weed infestations in the project area impact livestock grazing primarily by reducing the quantity and 

quality of forage. Numerous weed species occur within the project area (Chapter 3.06). Table 3.07-1 

shows those species with the highest potential to negatively impact rangelands. Johnsongrass, only 

recently introduced into the project area, is highly invasive and can be toxic to cattle (DiTomaso et al. 

2013). Klamathweed, also known as Common St. Johnswort, is known to be toxic, causing 

photosensitization in most livestock (DiTomaso et al. 2013). Barbed goatgrass and medusahead grass 

are not toxic, but can cause mechanical injury to livestock, deer and other animals (Peters et al. 1996). 

Table 3.07-1 Estimated Acres of Impactive Weeds in Grazing Allotments

Allotment Medusahead

Grass

Johnson

Grass

Barbed

Goatgrass

Yellow

Star-thistle Tocalote Klamathweed Totals1

Jawbone-Rosasco 3,091 385 11 865 444 1 4,797

Hunter Creek 62 0 2 8 212 1 285

Duckwall 0 0 0 0 0 1 1

Middle Fork, Meyer-Ferretti, Curtin 783 44 3 1,364 199 2 2,395

Bonds, Bower Cave, Bull Creek 74 0 0 5,313 1,276 12 6,675

Westside, Lower Hull, Upper Hull 1 0 1 0 0 0 2

Totals (acres) 4,011 429 17 7,550 2,131 17 14,155

1 Totals include overlapping acres.

Allotment Administration

Forest Plan Direction provides standards and guidelines designed to provide for resource conservation 

and sustainable use of rangelands. Range monitoring is conducted as needed to ensure that grazing 

management strategies meet objectives for desired conditions. Administration of grazing allotments 

involves travel on and off roads by Forest Service staff and permittees. Administration of grazing 

allotments in a post fire landscape may require more frequent travel to and from key areas and range 

infrastructure. Dead and down trees pose a threat to human safety and make access more difficult for 

Forest staff and grazing permittees. 

Rangeland Infrastructure

Rangeland infrastructure includes fences, water developments (troughs), cattleguards, gates and 

corrals designed to control livestock movements (timing, duration, and intensity of grazing). Some 

improvements in the project area, particularly fences, are still damaged and need repair. Over time, 

dead trees are likely to fall and damage range infrastructure, even after it has been repaired. Dead 

trees adjacent to fences and troughs pose a safety risk for Forest staff and permittees responsible for 

repairing and maintaining improvements. Allotment management is more difficult without 

functioning infrastructure. 

Livestock Movements

Livestock move through the allotments throughout the grazing season to find available forage and 

water. In many burned areas dead standing trees are abundant and have begun to fall. Fallen dead 

trees have the potential to “jackstraw” inhibiting livestock movements and reducing forage 

availability. Defective trees may also pose some risk to livestock, as cattle may be injured or killed by 

falling trees or by an excess of unburned fuel and debris. An abundance of dead material also impedes 

the ability of permittees to herd livestock and achieve proper distribution. 

The allotments in the project area are open range allotments. Livestock frequently travel across and 

along roads. When vehicles approach, the cattle generally move off of roads and out of the way of the 

oncoming vehicle. To some extent, fallen dead trees along roadsides have the potential to cause or 

contribute to vehicle and cattle interactions or collisions.

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Environmental Consequences

Direct effects on rangeland resources are directly caused by project implementation. Indirect effects 

on rangeland resources are in response to the direct effects of treatments or, as with Alternative 2 (No 

Action), a lack of treatment. Project management requirements (Chapter 2) are designed to mitigate 

the direct and indirect effects of the project on rangeland resources.

Alternative 1 (Proposed Action)

DIRECT AND INDIRECT EFFECTS

Table 3.07-2 provides a summary of the Alternative 1 treatments within each allotment. 

Table 3.07-2 Alternative 1: Treatments in Grazing Allotments

Allotment Deer Habitat 

Enhancement

Natural 

Regeneration

Noxious Weed

Eradication Reforestation Thin ExistingPlantations Totals1

Jawbone-Rosasco 3,814 951 4,699 9,661 3,813 18,239

Hunter Creek 0 29 247 1,640 5,005 6,674

Duckwall 0 256 56 0 95 351

Middle Fork, Meyer-Ferretti, Curtin 0 2,473 1,776 9,418 2,382 14,273

Bonds, Bower Cave, Bull Creek 0 36 19 13 684 733

Westside, Lower Hull, Upper Hull 0 288 1 190 300 778

Totals (acres) 3,814 4,033 6,798 20,922 12,279 41,048

1 Totals include overlapping acres

Rangeland Vegetation

Activities proposed for Alternative 1 would have short and long-term impacts to rangeland 

vegetation. Generally, fuel reduction activities may result in direct short-term negative impacts to 

understory vegetation, but would result in long-term beneficial effects because they reduce the 

potential for future high severity fire. Natural regeneration is expected to improve short-term 

vegetation condition because these areas would be monitored for five years, and reforestation 

treatments that damage understory vegetation (site preparation and release) would be used only if 

natural regeneration is inadequate. Deer habitat enhancement treatments would affect only the 

Jawbone allotment, and may result in short-term negative impacts from site prep, release, and 

prescribed burning treatments which damage vegetation and can create openings for weeds. Similarly, 

weed treatments may result in short-term impacts to vegetation because even desirable, non-target 

species may be killed by burning, grubbing, and herbicides. 

Reforestation activities, other than burning, generally negatively affect rangeland vegetation on both a 

short and long-term basis because they damage understory vegetation within treatment units and favor 

growth and establishment of trees, which will eventually significantly reduce the shrubs and 

herbaceous species that are used by livestock. Table 3.07-3 shows reforestation treatments would 

reduce capable rangeland by 14,089 acres (15.5% of total capable rangeland) in the project area.

Table 3.07-3 Reforestation in Capable Rangeland

Allotment Capable Reforestation Percent Capable

Jawbone-Rosasco 25,670 6,845 27

Hunter Creek 5,667 854 15

Duckwall 3,192 0 0

Middle Fork, Meyer-Ferretti, Curtin 26,506 6,248 24

Bonds, Bower Cave, Bull Creek 10,063 5 0

Westside, Lower Hull, Upper Hull 19,946 137 1

Totals (acres) 91,044 14,089 15.5

1 Totals include overlapping acres

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Draft Environmental Impact Statement and Environmental Consequences

Reforestation activities would have the most negative affect on rangeland vegetation, including forage 

production and range capability. Site preparation and release treatments, including subsoiling, would 

directly reduce forage production and indirectly lead to dominance by tree species. Herbicide 

applications would kill competing vegetation that could otherwise be used by livestock. Herbicide use 

would dramatically reduce forage production within reforestation units and potentially in natural 

regeneration units should these treatments be needed. Reduced forage production may result in 

localized impacts to rangeland vegetation because livestock use may become somewhat more 

concentrated in untreated areas; thus, untreated areas are likely to see increased grazing use to some 

extent. Rangeland vegetation in the Jawbone, Hunter Creek, Rosasco, Middle Fork and Curtin grazing 

allotments is most likely to be affected by reforestation treatments because the proportions of the 

allotment areas to be treated are the highest. The effects of reduced forage production within each unit 

are not likely to significantly negatively impact range vegetation in untreated areas. As stated in the 

management requirements (Chapter 2.02 and 2.03), no more than 20% of capable range would be 

treated in any allotment per year. Because a majority of the project area would not be treated, there 

should be sufficient available forage in untreated areas to meet livestock nutritional needs.

Alternative 1 includes a planting strategy that limits planting around meadows. No planting would 

occur within 25 feet of a meadow, and clumps of planted conifers would be evenly dispersed and 

offset into increasing densities further away from the meadow edge. This would reduce conifer 

encroachment into meadows and suppression of herbaceous meadow species that may result from 

competition with planted trees. This meadow planting strategy is an improvement from past 

reforestation practices that resulted in plantations adjacent to and within meadows and natural 

openings. Meadow buffers will positively affect rangeland vegetation on a site specific basis. 

In general, Alternative 1 has the potential to negatively affect forage production and reduce capable 

range on a relatively high proportion of capable range within the Jawbone, Hunter Creek, Rosasco, 

Middle Fork, and Curtin grazing allotments. The overall effects of this alternative on existing 

rangeland vegetation are detrimental. It should be noted, however, that while the current abundance of 

early seral shrubs and herbaceous vegetation is considered to be the existing condition, these areas 

were generally forested before the Rim Fire. Reforestation would occur under this alternative on up to 

25,331 acres, whereas approximately 36,000 acres were forested before the Rim Fire and now have 

little overstory. While project activities would cause short-term negative impacts to shrubs and 

grasses in planting units, once the trees are established and release activities stop, these open grown 

stands will continue to provide far more forage than the more dense mature forest that existed prior to 

2013. Rangeland vegetation conditions for grazing would still be a vast improvement over pre-fire 

conditions due to the abundance of shrubs and herbaceous vegetation both inside and outside planted 

areas.

Noxious Weeds

Site prep and release activities can dramatically reduce ground cover and temporarily create openings 

for weeds, but management requirements for noxious weeds would minimize the risk of weed 

introduction and spread from project activities. Noxious weed eradication, primarily with herbicides 

applied to larger weed infestations, may be detrimental to desirable range vegetation on a short-term 

basis. Table 3.07-4 shows acres of noxious weed eradication using herbicides within capable 

rangeland under Alternative 1. In particular, noxious weed eradication on the Jawbone Lava Flat have 

the potential to significantly reduce annual forage production temporarily because Medusahead grass, 

the main target species, occupies a large expanse of the lava cap and comprises a significant portion 

of the plant community in some areas. The longer term impacts of noxious weed control and 

eradication, however, are hugely beneficial to rangeland vegetation condition because native species 

and other preferred vegetation would be favored by these treatments. Noxious weed eradication is 

expected to create a more desirable species composition in rangeland plant communities, which is 

likely to improve forage quantity and quality, vegetation condition, and ecosystem function. 

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Table 3.07-4 Alternative 1: Noxious Weed Eradication in Capable Rangeland

Allotment Medusahead

Grass

Johnson

Grass

Barbed

Goatgrass

Yellow

Star-thistle Tocalote Klamathweed Totals1

Jawbone-Rosasco 3,091 385 1 241 443 1 3,777

Hunter Creek 28 0 2 7 186 1 224

Duckwall 0 0 0 0 0 1 1

Middle Fork, Meyer-Ferretti, Curtin 772 44 2 499 131 1 1,449

Bonds, Bower Cave, Bull Creek 1 0 0 16 1 0 18

Westside, Lower Hull, Upper Hull 0 0 0 0 0 0

Totals (acres) 3,892 429 5 763 761 4 5,854

1 Totals include overlapping acres.

Allotment Administration

Alternative 1 would indirectly impact allotment administration during project implementation. 

Treatments (herbicide application and mechanical treatments) may require increased efforts on behalf 

of affected permittees to avoid activities that may alter livestock movements and to ensure proper 

distribution. During this time, more frequent monitoring may be required to ensure that range 

standards and guidelines are being met. Fuel reduction activities would result in short-term impacts, 

but would be beneficial in the long term because they improve access for permittees and forest staff to 

perform grazing program administration. 

The herbicides proposed for use in Alternative 1 are generally considered safe (when applied 

according to product labels) for application where livestock use is anticipated; however, grazing 

restrictions may apply to some herbicides, Clethodim in particular. Clethodim would mainly be used 

on the Jawbone lava cap, where medusahead grass has invaded a large expanse of annual grassland. 

Permittees would be provided with herbicide product labels and a schedule of planned treatments. If 

herbicide grazing restrictions apply, permittees would have the ability to avoid specific areas of 

herbicide application by timing, herding, salting, or use of temporary fences to prevent livestock 

grazing in treated areas immediately following application of Clethodim or other herbicides. 

Herbicides should generally be applied as early in the growing season as possible for maximum 

effectiveness, which would also maximize the amount of time between application and the beginning 

of the grazing season. The most likely potential impact to livestock movements and grazing 

operations would be a voluntary delay in livestock entry onto the allotments to minimize the risk of 

herbicide exposure or ingestion by livestock. No more than 20% of the capable range within an 

allotment would be treated per year, and permittees would be given advance notice of herbicide 

application 8 weeks prior to implementation. Appendix D gives more information about herbicide 

application rates and Appendix N provides the schedule for noxious weed applications. Overall, 

Alternative 1 would increase the need for allotment administration, which may indirectly result in 

reduced capacity for grazing program administration on other allotments on the Forest.

Rangeland Infrastructure

Alternative 1 poses some risk that project activities involving fire or heavy equipment would damage 

range infrastructure. The potential for damage to range improvements is mitigated by management 

requirements and project administration. Contracts should include language requiring project 

activities to avoid damaging functioning range fences and to repair fence damage that results from 

implementation activities. Infrastructure maintenance needs are not likely to change, but the 

functioning condition of range infrastructure may improve under Alternative 1 because access may be 

made easier by site preparation treatments. Site preparation adjacent to range infrastructure would 

improve safety conditions for persons responsible for infrastructure maintenance and have a positive 

effect on grazing management. 

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Draft Environmental Impact Statement and Environmental Consequences

Livestock Movements

Alternative 1 may result in short-term impacts to livestock movements as a result of activities that 

may scare livestock (mechanical equipment, crews of workers) and those that are detrimental to 

rangeland vegetation. During project implementation, livestock are likely to avoid areas where herbs 

and shrubs have been killed by chemical or mechanical treatment. Noise from heavy equipment 

operations may cause livestock to be skittish or stressed, making herding and gathering more 

challenging. This has the potential to disrupt normal livestock movement patterns, but this effect 

would be localized to areas where activities are occurring. Livestock may either avoid or be attracted 

to burned areas, depending on site specific recovery, proximity to water, and abundance of palatable 

forage. Long-term effects to livestock movements would be limited primarily to reforested areas 

because livestock are less likely to move into or through established plantations in search of forage. 

Long-term effects are not likely to significantly alter livestock movement patterns because cattle 

would have the ability to move freely through the allotments and tree spacing would not preclude 

livestock movements within plantations. Site preparation and prescribed fire treatments would 

remove downed wood which can impede livestock movement, thereby improving livestock dispersal. 

The majority of reforestation activities would affect the Jawbone, Rosasco, Hunter Creek, Middle 

Fork and Curtin allotments because a higher proportion of capable rangeland within these 

management units would be reforested under this alternative. 

CUMULATIVE EFFECTS

Present and reasonably foreseeable actions that affect range are shown in Appendix B and include 

timber sales, restoration projects, fuels treatments, and herbicide use on public and private lands in 

the project area. Timber harvest on over 4,000 acres may cause livestock stress, damage understory 

vegetation, and increase the potential for weed introduction and spread, but longer term effects would 

be beneficial by reducing the potential for future high severity fire, improving watershed health, and 

increasing the potential for understory forage production. Recreation and special use activities are 

unlikely to noticeably affect grazing activities. Fuels treatments would result in short-term site forage 

loss and can increase the potential for weed spread, but may also increase forage production for 

several years following treatment and would reduce the risk of future high severity fire. Planned 

herbicide use on private (15,479 acres) and public lands (up to 26,585 acres for Alternative 1, plus 

about 33 acres for other projects) would temporarily negatively affect understory vegetation, may 

require more intensive management by range permittees, and may increase the potential for livestock 

exposure to chemicals. Restoration actions (aspen stand improvement, meadow restoration, conifer 

removal, gully, repair, etc.) are generally beneficial for range, but meadow exclosures 

(fences/barriers) restrict livestock access to forage and/or water and can result in localized negative 

impacts. Cumulatively, the multitude of projects occurring in the project area would increase the need 

for program administration and livestock management. Because the effects of these activities are both 

positive and negative, the cumulative effects of Alternative 1 are expected to be neutral or slightly 

positive overall for grazing management and rangeland vegetation.

Alternative 2 (No Action)

DIRECT AND INDIRECT EFFECTS

The following information describes the indirect effects of taking no action under Alternative 2. 

Rangeland Vegetation

Alternative 2 would not cause short-term effects to rangeland vegetation from chemical and 

mechanical treatments that damage rangeland vegetation. Capable rangeland and forage production 

would not be reduced by treatments that kill competing vegetation or by reforestation. Conversion of 

rangelands to forests is likely to occur naturally over a longer timeframe in the absence of fire or 

other disturbance. In areas not utilized by livestock, shrubs may grow rapidly above browse height 

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and become unavailable to livestock. A lack of site preparation, prescribed fire, and plantation 

thinning increases the potential for indirect detrimental effects to rangeland vegetation, because these 

treatments reduce the amount of fuels and vegetation that could burn in a high severity fire. 

Noxious Weeds

The absence of noxious weed eradication in Alternative 2 is likely to negatively affect rangeland 

vegetation because weed populations in the project area would continue to expand unabated. 

Johnsongrass was only recently introduced in the Rim Fire area and has the potential to expand 

considerably, displacing native species and negatively affecting previously weed-free ecosystems. On 

the Jawbone Lava Flat, large expanses of noxious weeds will continue to negatively impact plant 

diversity, wildlife habitat, forage quality, and ecosystem function. 

Allotment Administration

Alternative 2 is not likely to affect allotment administration activities. Site preparation activities, 

which would benefit allotment administration by improving livestock movement, would not occur; 

however, there would be no need for increased allotment administration as a result of project 

activities that damage vegetation and affect livestock movement. The capacity for allotment 

administration outside of the project area would not be reduced. 

Rangeland Infrastructure

A beneficial effect of Alternative 2 would be no potential impacts to infrastructure during 

implementation. Conversely, safety conditions for persons responsible for infrastructure maintenance 

would not be improved and the existing hazards (standing dead trees) would not be treated during site 

preparation activities. 

Livestock Movements

Alternative 2 would not implement activities that can scare livestock and disrupt livestock movement 

patterns; however, treatments that would improve livestock access (site preparation, plantation 

thinning, and prescribed fire) would not occur. The overall effects on livestock movements would be 

neutral.

CUMULATIVE EFFECTS

Present and reasonably foreseeable actions may cause livestock stress, damage understory vegetation, 

and increase the potential for weed introduction and spread, but longer term effects would be 

beneficial. Recreation and special use activities are unlikely to noticeably affect grazing activities. 

Rim Fire Recovery fuels treatments will result in short-term site forage loss and can increase the 

potential for weed spread, but may also increase forage production for several years following 

treatment and would reduce the risk of future high severity fire. Herbicide use on private (15,479 

acres) and public lands (about 33 acres) would temporarily negatively affect understory vegetation, 

may require more intensive management by range permittees, and may increase the potential for 

livestock exposure to chemicals. Restoration actions (aspen stand improvement, meadow restoration, 

conifer removal, gully, repair, etc.) are generally beneficial for range, but meadow exclosures 

(fences/barriers) restrict livestock access to forage and/or water and can result in localized negative 

impacts. Cumulatively, the multitude of projects occurring in the project area would increase the need 

for program administration and livestock management. 

Because the effects of these activities are both positive and negative, the cumulative effects of 

Alternative 2 would generally be neutral or beneficial for grazing management and rangeland 

vegetation because additional chemical and mechanical treatments that damage vegetation, reduce 

forage, and stress livestock would not occur. Potential negative cumulative effects are associated with 

dramatically reduced or lack of reforestation and noxious weed eradication.

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Draft Environmental Impact Statement and Environmental Consequences

Alternative 3

DIRECT AND INDIRECT EFFECTS

Alternative 3 would treat same acres as Alternative 1, but would not use any herbicides to accomplish 

reforestation or noxious weed eradication, only hand applications. Table 3.07-2 provides a summary 

of the Alternative 3 treatments within allotments.

Rangeland Vegetation

Alternative 3 would negatively affect capable rangeland vegetation on up to 14,871 acres. Site 

preparation and release activities using hand grubbing or mechanical equipment are generally more 

detrimental to rangeland vegetation than herbicides because they not only kill shrubs and herbaceous 

vegetation, but they negatively affect soil structure and create bare soil. Whereas chemical site 

preparation, release, and weed eradication treatments kill vegetation, mechanical treatments remove 

the vegetation, exposing bare soil and creating the potential for erosion and establishment of early 

seral or undesirable species. Even with management requirements, Alternative 3 is likely to result in 

soil loss and reduced soil productivity in addition to weed introduction and spread, which may 

translate into reduced forage production and range capability. 

Alternative 3 also differs from Alternative 1 in terms of fuel break planting design: Alternative 3 fuel 

breaks would be 250 feet wide and average 151 trees per acre, whereas under Alternative 1 fuels 

breaks would be 330 feet wide and average 176 trees per acre. Release would be accomplished by 

hand grubbing to remove competing vegetation and the fuel breaks would be maintained with 

mastication where brush got above one-foot tall. Wider fuel breaks with fewer trees are more likely to 

support understory vegetation once trees are established and release treatments are no longer 

necessary. Since ridges tend to be a drier landscape position and cattle use of these areas is often 

limited, the wider fuelbreaks are not likely to contribute in meaningful ways to forage production or 

vegetation condition.

Similar to Alternative 1, Alternative 3 is likely to negatively affect forage production and reduce 

range forage on a relatively high proportion within the Jawbone (59.1%), Hunter Creek (51.7%), 

Rosasco (43.7%), Middle Fork (39.5%) and Curtin (32.1%) grazing allotments. The overall effects of 

Alternative 3 on rangeland vegetation are detrimental.

Noxious Weeds

Table 3.07-5 shows Alternative 3 would treat only a third of the acreage of noxious weeds as 

Alternative 1. Noxious weeds in the Duckwall, Bonds, Bower Cave, Bull Creek, Westside, Lower 

Hull and Upper Hull allotments would not be treated under this alternative. Non-chemical weed 

eradication methods are less likely to be effective in eradicating target weed populations than a 

treatment program including chemicals. In addition, due to the larger acreage treated by heavy 

equipment, Alternative 3 would result in an increased potential for weed introduction and spread. 

Management requirements are aimed at minimizing the potential for weed introduction and spread; 

however the potential for weed introduction and spread for Alternative 3 is higher than described for 

Alternative 1. Alternative 3 is both more likely to introduce weeds and less likely to reduce or 

eradicate weeds, and so would not be as beneficial as Alternative 1 in controlling or eradicating 

rangeland weeds.

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Table 3.07-5 Alternative 3: Noxious Weed Eradication in Capable Rangeland

Allotment Medusahead

Grass

Johnson

Grass

Barbed

Goatgrass

Yellow

Star-thistle Tocalote Klamathweed Totals1

Jawbone-Rosasco 2,589 13 1 177 1 1 2,782

Hunter Creek 1 0 1 0 1 1 4

Duckwall 0 0 0 0 0 0 0

Middle Fork, Meyer-Ferretti, Curtin 1 0 2 0 0 1 4

Bonds, Bower Cave, Bull Creek 0 0 0 0 0 0 0

Westside, Lower Hull, Upper Hull 0 0 0 0 0 0 0

Totals (acres) 2,591 13 4 177 2 3 2,790

1 Totals include overlapping acres.

Allotment Administration

Alternative 3 would indirectly impact allotment administration during project implementation. 

Treatment activities may require more frequent monitoring to ensure that range standards and 

guidelines are being met. Mechanical treatments may require increased efforts on behalf of affected 

permittees to ensure proper distribution and avoid treatments that damage vegetation and alter 

livestock movements. Fuel reduction activities would result in short-term negative impacts, but would 

be beneficial in the long-term because they improve access for permittees and forest staff to perform 

grazing program administration. 

Permittees may avoid specific areas of mechanical disturbance by using grazing management 

techniques, including timing, herding, or salting. No more than 20% of the capable range within an 

allotment would be treated per year, and permittees would be given an implementation schedule to 

facilitate avoidance of project activities, if needed.

Rangeland Infrastructure

Range infrastructure is more likely to be damaged by Alternative 3 due to the increased use of heavy 

equipment to implement site prep and release treatments, but repairing damaged facilities is required 

under this alternative and is standard for all Forest Service contracts.

Livestock Movements

Alternative 3 may impact livestock movements because project activities could scare livestock and 

damage rangeland vegetation. Due to the increased use of heavy equipment, this alternative is the 

most likely to stress and disturb livestock. Otherwise, the effects of Alternative 3 on livestock 

movements are the same as described for Alternative 1.

CUMULATIVE EFFECTS

The cumulative effects of this Alternative are similar to those described under Alternative 1. The use 

of heavy equipment is more likely to contribute to altered livestock movements when combined with 

other actions. Alternative 3 also treats fewer acres of noxious weeds while increasing the potential for 

weed introduction and spread. Alternative 3 is slightly less beneficial and slightly more detrimental 

than Alternative 1 from a cumulative effects standpoint.

Alternative 4

DIRECT AND INDIRECT EFFECTS

Table 3.07-6 provides a summary of the Alternative 4 treatments within allotments.

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Draft Environmental Impact Statement and Environmental Consequences

Table 3.07-6 Alternative 4: Treatments in Grazing Allotments

Allotment Deer Habitat 

Enhancement

Natural 

Regeneration

Noxious Weed

Eradication Reforestation Thin ExistingPlantations Totals1

Jawbone-Rosasco 445 0 3,447 1,376 3,813 9,081

Hunter Creek 0 0 12 13 5,005 5,030

Duckwall 0 0 1 0 95 96

Middle Fork, Meyer-Ferretti, Curtin 0 0 249 1,445 2,382 4,076

Bonds, Bower Cave, Bull Creek 0 0 1 0 684 685

Westside, Lower Hull, Upper Hull 0 0 1 22 300 323

Totals (acres) 445 0 3,711 2,856 12,279 19,291

1 Totals include overlapping acres

Rangeland Vegetation

The effects of Alternative 4 on rangeland vegetation would be the same as described for Alternative 

1, but would occur on only 20% of the area. The effects to rangeland vegetation from site preparation

and release with glyphosate would be the same as described for Alternative 1, but would occur on 

only up to 4,012 acres. Because the treatment activities would be much less extensive, livestock 

concentration in untreated areas is much less likely to occur. Also, because far fewer acres would be 

converted to plantations, negative effects on long-term forage production would be dramatically 

reduced from Alternatives 1 and 3. Unplanted early seral areas would eventually regenerate naturally 

into forests in the absence of disturbance, but this would take longer without active reforestation 

treatments. The increased use of prescribed fire would increase the potential for short-term damage to 

rangeland vegetation, but would be beneficial in the long-term by maintaining early seral understory 

vegetation types in burned areas, which tend to provide nutritious and palatable forage for livestock.

Noxious Weeds

Because Alternative 4 treats noxious weeds without the use of herbicides, the effects of this 

alternative are the same as described for Alternative 3.

Allotment Administration

The effects of Alternative 4 on allotment administration would be the same as described for 

Alternative 3, but would occur to a lesser extent because only about 20% of the area would be treated. 

The need for allotment administration would increase only slightly, and effects to livestock 

management would be minimal. 

Rangeland Infrastructure

The effects of Alternative 4 on range infrastructure are similar to those described for Alternative 1, 

but Alternative 4 affects only 20% of the area as other alternatives and so is 80% less likely to result 

in damage to range infrastructure. This alternative poses a greater risk that prescribed fire may 

damage range infrastructure, but the intensity of prescribed fires is assumed to be less likely to cause 

damage than an uncontrolled fire such as the Rim Fire. Like the other alternatives, infrastructure that 

is damaged by project activities would be repaired.

Livestock Movements

Alternative 4 may result in short-term impacts to livestock movements. Livestock are likely to avoid 

areas where vegetation is killed by mechanical treatment. Heavy equipment operations may cause 

livestock stress, making herding and gathering more challenging. Because this effect is localized to 

areas where activities are occurring, and because there would be significantly fewer acres treated with 

mechanical equipment, this alternative is less likely to significantly alter livestock movements than 

Alternatives 1 or 3. Alternative 4 includes more prescribed fire than other alternatives. Livestock may 

either avoid or be attracted to burned areas, depending on site specific recovery, proximity to water, 

and abundance of palatable forage. Long-term effects to livestock movements would be limited 

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primarily to reforested areas because livestock are less likely to move into or through established 

plantations in search of forage. Long-term effects are not likely to significantly alter livestock 

movement patterns because cattle would have the ability to move freely through the allotments.

CUMULATIVE EFFECTS

The cumulative effects of reforestation activities for Alternative 4 are similar to those described for 

Alternative 1, but occur on a much smaller scale due to the smaller acreage that would be treated. The 

cumulative effects of noxious weed eradication for Alternative 4 are similar to those described for 

Alternative 3. Alternative 4 treats fewer acres with herbicides and converts fewer acres to plantations, 

dramatically reducing the cumulative impacts to range.

Alternative 5

DIRECT AND INDIRECT EFFECTS

Alternative 5 includes the same treatment areas within allotments as Alternative 1 (Table 3.07-2).

Rangeland Vegetation

The effects of Alternative 5 on rangeland vegetation are similar to those described for Alternative 1, 

with the exception of range vegetation adjacent to meadows. Alternative 5 differs from Alternative 1 

in that the planting strategy around meadows would result in a 7 by 14-foot spacing of planted 

conifers 25 feet from meadows. This planting strategy does not provide for meadow vegetation or 

meadow hydrology as much as the Alternative 1 meadow buffer planting strategy. While the 25 foot 

buffer is beneficial for rangeland vegetation, the denser planting outside of the 25 foot buffer is more 

likely to contribute to conifer encroachment and other long-term negative effects to meadows and 

herbaceous vegetation. This alternative would, however, create the desired tree numbers during 

thinning at year 7 if the surviving trees exceed this amount adjacent to meadows. This would help 

prevent negative effects to rangeland vegetation adjacent to meadows.

Noxious Weeds

Same as Alternative 1.

Allotment Administration

Same as Alternative 1.

Rangeland Infrastructure

Same as Alternative 1.

Livestock Movements

The effects of Alternative 5 on livestock movements are similar as described for Alternative 1, with 

the exception that Alternative 5 does not include prescribed fire in new plantations. The lack of 

prescribed fire is more likely to negatively affect livestock movements than other action alternatives.

CUMULATIVE EFFECTS

Same as Alternative 1.

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Draft Environmental Impact Statement and Environmental Consequences

Summary of Effects Analysis across All Alternatives

The effects of each alternative are compared against the relative area proposed for treatment within 

grazing allotments and the amount of capable range in treatment areas. Table 3.07-8 displays a 

summary of this information for all alternatives.

Table 3.07-8 Comparison of Alternatives: Treatments within Allotments and Capable Rangelands

Treatments Alternative 1

Allotment

Alternative 1

Capable

Alternative 2

Allotment

Alternative 2

Capable

Alternative 3

Allotment

Alternative 3 

Capable

Alternative 4 

Allotment

Alternative 4 

Capable

Alternative 5 

Allotment

Alternative 5 

Capable

Deer Habitat 

Enhancement

3,813 2,936 0 0 3,813 2,936 3,571 2,750 3,813 2,936

Natural 

Regeneration

4,033 2,377 0 0 4,033 2,377 0 0 4,033 2,377

Noxious Weed

Eradication

6,798 5,182 0 0 3,702 3,117 3,702 3,117 6,798 5,182

Reforestation 20,922 14,089 0 0 20,922 14,089 2,955 1,953 20,922 14,089

Thin Existing 

Plantations

12,277 7,824 0 0 12,277 7,824 12,277 7,824 12,277 7,824

Totals1 (acres) 47,843 32,408 0 0 44,747 30,343 22,505 15,644 47,843 32,408

1 Totals include overlapping acres

Alternative 4 is generally the most beneficial action alternative from a range standpoint because it 

favors shrubs and herbaceous vegetation. On the other hand, while Alternatives 1 and 5 would result 

in more damage to shrubs and herbaceous vegetation, these alternatives are more likely to be effective 

in controlling and/or eradicating weed populations. Alternative 3 has the potential to be most 

detrimental because the emphasis on mechanical treatments is more likely to disturb livestock and 

damage range vegetation, and at the same time is more likely to result in weed introduction and 

spread and less likely than other alternatives to control or eradicate noxious weeds. All action 

alternatives would to some extent reduce the risk of future high severity fire by removing fuels 

through site preparation, creating fuel break structures during initial planting or pre-commercial 

thinning, and using prescribed fire. While project site preparation, release, and weed treatments will 

result in short-term negative impacts to rangeland vegetation and program administration, none of the 

alternatives are likely to result in significant long-term changes because a majority of the project area 

would not be treated and historically these acres were forested with very little vegetation in the 

understory. Even with these negative impacts, the range condition would remain improved and forage 

would be more abundant than pre-fire conditions. 

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Chapter 3.07 Stanislaus

Range National Forest

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Draft Environmental Impact Statement and Environmental Consequences

3.08 RECREATION

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction

Various Federal laws, FSM direction, as well as the Forest Plan provide the framework for the Rim 

Reforestation project. The components of this regulatory framework are outlined below. 

 Forest Plan: Contains both Forestwide and management area specific direction. The specific 

Forest Plan goal for Recreation is to: Provide a wide range of recreation opportunities directed at 

various experience levels to meet current and projected demand, including campgrounds, hiking 

trails, picnic areas, off-highway vehicle (OHV) trails, etc. (USDA 2010a). 

 FSM 2300 Recreation, Wilderness and Related Resource Management: guides management 

of recreation resources on NFS lands; it contains wide-ranging goals and objectives that serve as

the overall framework for managing recreation.

 Recreation Niche: The Stanislaus National Forest developed a recreation niche statement and 

setting map through the Recreation Facility Analysis process (USDA 2007). The niche statement 

describes the unique characteristics, opportunities, settings and activities of the Forest’s 

recreation program. The statement describes a full range of overnight opportunities, and states 

that, family oriented overnight activities are most popular and in highest demand, with a much 

higher-than-average participation by children. With easy access for urban visitors, the Forest is 

seen as an oasis to escape from winter fog, summer heat and urban life. An increase in visitation 

of 42% over the next 20 years is projected.

The Forest Plan Compliance (project record) document identifies the Forest Plan Standards and 

Guidelines that specifically apply to this project and related information about compliance with the 

Forest Plan.

Effects Analysis Methodology

The potential direct and indirect effects to recreation were considered within the Rim Reforestation 

project area. The direct effects would be short term and temporary, occurring during project 

implementation. The long-term indirect effects would be related to ecosystem restoration, changes in 

visual qualities, and other items within the project area that would influence recreation opportunities. 

The temporal bounds of the recreation analysis are generally dependent on the lasting effects of 

project activities. Effects can be either short-term in nature or long-term. Short-term effects are 

impacts from project activities that are expected to last up to 5 years. These would include 

disturbances associated with implementation of the proposed activities as well as impacts that would 

endure beyond implementation, up to five years. Long-term effects are those projected to endure 

beyond 5 years. 

Assumptions Specific to Recreation

 Forest recreation use is expected to continue based on nearby urban population growth and 

demand will continue for recreation opportunities. 

 National Visitor Use Monitoring (NVUM) data is accurate.

 Implementation of proposed activities will be completed using the management requirements 

detailed in Chapter 2.03. 

 While Forest recreation visits occur year round, the majority of them occur in the summer. 

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Recreation National Forest

Data Sources

 Stanislaus GIS Library

 National Visitor Use Monitoring (NVUM) data (USDA 2014c) 

 Recreation Facility Analysis (USDA 2007) 

 Recreation Opportunity Spectrum (ROS), Management Area and project area GIS maps

 Data from the Rim Recovery EIS (USDA 2014) 

Recreation Indicators

Temporary loss of recreation opportunity: displacement of users, or a change in recreation 

experience due to vegetation treatments/prescribed fire activities (i.e. temporary closure of 

areas/visitors avoiding the area during the vegetation treatments/prescribed fire). 

 Measure: Effects lasting up to 5 years in duration 

Long term loss of recreation opportunity: chronic displacement of users, or permanent changes in 

recreation experience due to changes in scenery following the vegetation treatments/prescribed fire

that affect the recreation setting, long-term closures, loss of trail opportunities from impacts of 

prescribed fire (increased maintenance shortfalls, erosion, downed trees) or other actions related to 

the project.

 Measure: Effects lasting more than 5 years in duration

Recreation Methodology by Action

The recreation indicators compare the effects of the alternatives on recreation access and 

opportunities. The analysis discusses the changes in recreation opportunities as a result of each 

alternative. The recreation analysis objective is used to evaluate how each alternative would enhance

or diminish recreation access and opportunities in the short and long term. 

Affected Environment

Existing Conditions

VISITOR USE

Before the Rim Fire, recreation within the project area included OHV use, passenger car driving, 

rafting, boating, hunting, swimming, mining, wood cutting, camping (dispersed and developed), 

hiking, cycling (mountain and road), fishing, backpacking, horseback riding, and winter sports. Many 

of those opportunities are once again available for visitor use due to hazard tree removal. Some of the 

traditional activities that have been attractive to the forest visitor will be less attractive because of the 

fire. Dispersed camping may be less attractive without the canopy of trees, as an example, while 

water features remain attractive.

The Rim Fire changed some recreation opportunities. The Spinning Wheel Closure Order STF 2014-

13 went into effect in November of 2014 and is set to end in November 2015. Public access is 

prohibited into this area due to instability of soils and the need for vegetation to establish (USDA 

2014a). Visitor use estimates for the entire Forest are based on the NVUM survey conducted in 2012, 

prior to the Rim Fire, and updated in April of 2014 (USDA 2014c). Recreation use on the Stanislaus 

National Forest for this period was estimated at 1,817,200 National Forest visits and 2,100,300 site 

visits. The most recent NVUM data shows the following recreation and visitation patterns:

 Roughly 30% of visitation is from within 50 miles of the Forest. There are relatively few visits 

from greater distances; only about 10% report traveling more than 200 miles. 

 Average visitation duration is about 21 hours, though more than half of visits last less than 6 

hours 

 Infrequent visitors (those who visit at most 5 times per year) account for about 53% of all visits 

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Draft Environmental Impact Statement and Environmental Consequences

 About 10% of visits are from people who report visiting more than 50 times per year 

 The activities with the highest participation rates include hiking/walking, relaxing, viewing 

natural features and viewing wildlife.

 The most hours spent doing an activity were developed and dispersed camping, resort use and 

backpacking.

Visitors were asked to select one of several substitute choices, if for some reason they were unable to 

visit this national forest. Choices included going somewhere else for the same activity they did on the 

current trip, coming back to this forest for the same activity at some later time, going someplace else 

for a different activity, staying at home and not making a recreation trip, going to work instead of 

recreating, and a residual ‘other’ category). The largest percent (38%) said they would go elsewhere 

to participate in the same activity. 

NVUM does not state the time of year when the majority of visitors come to the forest. However, 

many recreation facilities close in mid-October, limiting some opportunities in winter. The main 

activities reported by visitors through the NVUM process indicate that the majority of visitors arrive 

in the summer months when those opportunities are available. 

Outfitter-guides are currently authorized to operate within the project area. The current special uses 

database shows nine outfitters on the Mi-Wok and Groveland Ranger Districts, but whether they are 

utilizing areas within the Rim Fire is unknown (USDA 2014d). Outfitter-guide permits constantly 

change and there may be less or more outfitters permitted in 2016. Current uses include canoeing, 

hiking, rafting, fly fishing, shuttle services, sunset tours, weddings, biking and kayaking. 

OPPORTUNITY

The Forest Service uses the ROS to inventory and describe the range of recreation opportunities 

available based on the following characteristics of an area: physical (characteristics of the land and 

facilities), social (interactions and contact with others), and managerial (services and controls 

provided). The recreational settings are described on a continuum ranging from Primitive to Urban. 

The attributes of ROS are the physical (type of access, remoteness, size), the social (user density, 

encounters), and the managerial (type of facilities, visitor management and naturalness) 

characteristics of the place (USDA 1986).

The majority of the project area falls within the Roaded Natural and Semi-Primitive Non-Motorized 

classes. Table 3.08-1 shows the direction for management of these two classes. 

Table 3.08-1 Recreation Opportunity Spectrum Classes within the Rim Reforestation project area

ROS General Direction Standards and Guidelines

Semi-Primitive 

Non-Motorized 

NMFPA1

Manage the area so that on-site 

controls are minimized and 

restrictions are subtle. Provide a 

range of semi-primitive nonmotorized recreation opportunities 

and experiences.

Meet the ROS objective of Semi-primitive Non-motorized. 

Interaction between visitors is low but there is evidence of 

other users. Motorized use is normally prohibited, except 

for: 4N80Y, 5N02R (NMFPA). Resource improvements 

will normally be limited to minimum, unobtrusive facilities.

Roaded 

Natural 

Manage the area so there is only 

moderate evidence of the sights and 

sounds of man. Provide a range of 

roaded natural recreation 

opportunities and experiences.

Meet the ROS objective of Roaded Natural. Interaction 

between users is usually low to moderate with evidence of 

other users prevalent. Resource modification practices 

are evident. Conventional motorized use is provided for in 

construction standards And facilities designs. A full range 

of other resource activities is permitted to the extent that 

the general practice description is met. 1 NMFPA=Non-motorized Forest Plan Amendment (USDA 2010a, p. 2)

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Recreation National Forest

Developed Recreation Opportunities

Developed recreation sites provide infrastructure which typically include running water, structures, 

vault toilets, signage, barrier posts, interior roads, campfire rings, grills and picnic tables. Some of 

these sites are managed under special use permits. Developed campgrounds within the affected area 

are Dimond O, Lost Claim, Lumsden Bridge, Lumsden, South Fork, Sweetwater and Cherry Valley. 

Upper and Lower Carlon, Middle Fork, and Rainbow Pool Day Use Areas, Rim of the World Vista, 

Cherry Creek and Merals Pool Boat Launches are also found within the Rim Fire perimeter. Other 

developed recreation sites under special use permit within the Rim Fire perimeter include BerkeleyTuolumne Camp, Peach Growers Recreational Residence Tract, and San Jose Camp. A majority of 

the Berkeley-Tuolumne Camp was destroyed in the Rim Fire and is currently not available for use. 

San Jose Camp received some fire damage, and a vault toilet was burned at the South Fork 

Campground. Camp Tawonga is a privately owned camp that is accessed by Cherry Lake Road or 

Evergreen Road and Forest Route 1S02 (Recreation Report, project record). 

Dispersed Recreation Opportunities

Touring, or driving for pleasure by motorized vehicle, is a dominant recreation activity. Hunters, 

anglers, campers, picnickers, hikers, bikers, wood cutters, forest product gatherers, sightseers, bird 

watchers, nearby residents, rock climbers, spelunkers, kayakers, boaters, swimmers, target shooters 

and other recreationists also travel to their activity along forest roads. The journey to and from the 

activity is part of the recreation experience.

Camping often serves as a base for many other activities. Many participants enjoy camping in trailers, 

RVs, campers, and in tents near their vehicle. Outside of developed campgrounds, these “camps” are 

often established along roads or on short spurs off these roads. 

Dispersed recreation opportunities include non-motorized system trails and motorized recreation 

opportunities. The project area provides a variety of dispersed recreation opportunities that include 

475 inventoried dispersed campsites. Over 6,650 acres of treatment are proposed within .25 mile of 

the inventoried dispersed camps in the action alternatives reviewed as part of this analysis. 

Developed-dispersed camping and concentrated use areas within the Rim Fire perimeter include 

Camp Clavey, Cherry Borrow, Cherry Valley, Joe Walt Run, and Spinning Wheel. 

Non-motorized system trails include Andresen Mine, Carlon Falls, Hamby, Golden Stairs, 

Humbug/Duluke, Indian Creek, Kibbie Ridge/Huckleberry, North Mountain, Preston Falls, Tuolumne 

River Canyon, West Side Trail, and Lake Eleanor. Some trails access various points of interest along 

the Tuolumne Wild and Scenic River corridor and serve as important emergency access points for 

river users. Wilderness trailheads within the project area provide access to trails in Yosemite and 

Emigrant Wildernesses.

Motorized recreation opportunities typically provide a variety of settings and a diversity of OHV 

trails varying in length, degree of difficulty, and access to other recreation opportunities. Motorized 

Recreation Areas include Jawbone Pass, Pilot Ridge, Tuolumne Rim, Two-mile/Middle 

Clavey/Reynolds Creek, and West Side Rail Tour (Recreation Report, project record).

Environmental Consequences

Alternative 1 (Proposed Action)

DIRECT AND INDIRECT EFFECTS

Effects to visitors are often difficult to quantify, as visitor behavior and acceptance of management 

activities vary greatly by the individual. Some generalizations based on visitor use patterns can be 

made.

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Draft Environmental Impact Statement and Environmental Consequences

People would likely see treatment activities or see the effects of them, especially in popular areas like 

the units near the Rim of the World Vista or along Highway 120. The presence of a crew in the field 

may be dictated by the activity type, species being treated or planted, the method used, and the 

optimal time to administer the treatment. However, in some site-specific, popular locations, visitors 

may be temporarily displaced if they do not wish to recreate where treatments are taking place. This 

could occur where chemicals are being applied or trees are being thinned or planted. Some sites could 

be closed to short-term use for public safety while herbicide is being applied or where active thinning 

or burning is occurring. 

In addition, visitors may choose to avoid areas during prescribed burning, thinning or spraying 

activities even if those areas are not closed to public use. Commercial outfitters operating in the area 

during project implementation may also be directly affected by limited access or trail closures. Others 

may choose to avoid certain areas during times of smoke, thinning or herbicide spraying, particularly 

those who use roads (biking, touring). Adjustments to certain permits may need to be made during 

this time.

Trucks and other equipment utilizing public travel routes have the potential to increase traffic 

congestion and negatively affect the driving experience users. Since “driving for pleasure” is an 

identified recreation use within the project area, this user group, as well as those traveling to 

recreation destinations could be affected. OHV riders could also encounter vehicle traffic and 

activities along Forest roads which could cause delays or changes in their preferred routes.

The proposed vegetation treatments would cause temporary, but not permanent, changes in the some 

areas designated as Semi-Primitive Non-Motorized ROS. The objective of low interaction between 

visitors and subtle restrictions and controls would not always be met. However, no long-term changes 

to the ROS in the project area are expected. 

A short-term direct effect during project management activities could be temporary Forest closures 

implemented to protect the public from safety hazards associated with weed spraying and operation of 

mechanical equipment. These closures would reduce the public’s opportunity to access limited areas 

of public land for dispersed recreation for up to 24 hours. Advanced signage and public outreach 

would notify as many people as practical of proposed closure periods ahead of time, allowing them to 

make alternate recreation access plans. Similarly, management activities within or adjacent to 

developed recreation facilities have the potential to negatively affect visitor’s recreation experience. 

The action alternatives include a measure to manage the timing of fuels management activities when 

practical to avoid weekends when visitation rates are anticipated to be higher. 

Herbicide Use and Noxious Weed Eradication

Visitors could notice the effects of herbicide use for site preparation, release, and noxious weed

treatments, because browned out vegetation might be obvious. This evidence of treatment activities 

and effects would reduce the sense of naturalness that some visitors expect from a national forest. 

Weed treatments would not be noticed the following growing season when the residual live, green 

native vegetation dominates the view. Those who most value natural conditions would likely tolerate 

use of herbicides if treatments show rapid and significant success in promoting conifer growth and 

reducing noxious weeds. Visitors would be able to easily avoid the areas actively being sprayed by 

crews. Those visitors who oppose the use of herbicide, however, would be reluctant to return to the 

treated areas. The main effects would be to visitors who travel off trails, hunters, those who seek 

isolated dispersed campsites and harvesters of forest products. Visitors seeking forest products, such 

as morels, may avoid areas they have used in the past due to concerns about their health. Indirect 

effects of herbicide treatments could include a greater concentration of visitors in non-treated areas.

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Chapter 3.08 Stanislaus

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Reforestation

Many of the proposed reforestation units are not located in areas where visitors congregate. 

Exceptions include units within a quarter mile of Sweetwater Campground, Spinning Wheel, and 

Rainbow Pool, Dimond O Campground, Lost Claim Campground, the privately owned Camp 

Tawonga, Middle Fork picnic area, and Peach Growers. At these popular locations, implementation 

activities could temporarily impact recreation as described under prescribed fire and herbicide use. 

Impacts would be directly related to which type of adaptive management is used in the units.

The use of machinery is proposed in reforestation units for site preparation. Feller-bunchers, 

excavators and tractors used for removing biomass and piling, shredding or deep tilling would cause 

continuous noise in the immediate area. The main impacts would be to visitors wishing to camp, 

picnic, or enjoy nature in the vicinity. Those visitors passing through enroute to destinations could be 

temporarily inconvenienced by delays on roads. 

Hand cutting, hand piling or jackpot burning could also occur in these units. The impacts to recreation 

are similar to those discussed below in the prescribed fire section. 

Prescribed Fire

The direct impacts to recreation from the prescribed burning activities during project implementation 

would be the sights and sounds of people and equipment, including chainsaws and vehicles, and 

smoke in the air. Smoke in the air during the prescribed burns may have a direct affect to the quality 

of the recreation experience within the project area and in the adjacent dispersed camping areas by 

temporarily reducing air quality and visibility. Some forest roads may be affected by smoke and this 

could affect driving opportunities. 

Smoke from pile burning would result in short term effects in portions of the project area after initial 

site preparation or thinning has occurred and slash piles are treated. Effects could include user 

dissatisfaction, user displacement, and temporary reduction in setting qualities due to smoke 

obscuring the surrounding visual quality. Pile burning is often completed on the day of ignition, but 

the effects could last longer if there are large fuels present in piles.

Smoke from understory burning would be more obvious, since in some cases entire units would be 

burned. The effects would be less concentrated as pile burning, but would be spread over a larger area 

and depending on the fuel, humidity and prescription; smoke could linger for several days. Large logs 

and snags could smolder and burn for indefinite periods.

ThinExisting Plantations

Noise, dust and increased traffic on forest roads would be expected during thinning treatments. The 

direct impacts to recreation from the thinning activities would be to the sights and sounds of 

equipment including chainsaws. Indirect effects to recreation would result from changes to the 

appearance of the units following the thinning activities. These changes could be perceived as 

beneficial or negative, depending on the viewer. Thinning could create favorable conditions for 

dispersed recreation and enhance hunting experiences for some. Other visitors could feel a loss of 

“sense of place” as conditions change in site specific areas from what they are used to experiencing.

Comparatively few studies have been conducted on public perceptions of mechanized thinning to 

reduce hazardous fuels; however, some insight can be gained from the literature assessing attitudes 

toward alternative harvesting techniques. Not surprisingly most studies found that people preferred 

stands with little or no modification over highly manipulated forest stands. Many visitors would be 

unable to tell the difference between plantations and natural stands in several years, however. 

Several studies have identified a greater level of sophistication among fire-affected communities in 

both their understanding and acceptance of fire management techniques when compared to the 

general population. Additional work in fire-prone areas indicates a number of similar factors 

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Draft Environmental Impact Statement and Environmental Consequences

influence public support for fuel treatments despite geographic and economic differences. Though 

treatments could be ongoing, visitors who are aware of the drivers behind these treatments may be 

more willing to recreate in these areas rather than be displaced by them (Shindler and Toman 2003). 

Educational messages on the need for treatments could influence visitor acceptance and behavior in 

this area.

CUMULATIVE EFFECTS

Past human activities and natural disturbance processes influenced the current condition of the project 

area and continue to affect the vegetation structure, spatial arrangement and pattern, composition and 

diversity, natural processes (such as fire), and movement towards increased forest resiliency and 

function. 

Recreational activities such as hunting, camping, hiking, OHV travel on primitive roads, and 

snowmobiling and cross-country skiing in the winter are expected to continue within the analysis 

area. Other ongoing and reasonably foreseeable activities that would occur within the analysis area

include hazard tree removal, weed treatments, road and trail maintenance, commercial guided 

recreation and special events, firewood cutting and continued use of grazing allotments. All of these 

activities, when added to the activities proposed in the Rim Reforestation project have the potential to 

cumulatively affect the recreation experience within the project area. The primary impacts would be 

due to the increased presence of people, vehicles and associated noise that would directly affect the 

ability of visitors to enjoy their desired recreation experience, and may lead to the short-term 

displacement of visitors who choose to avoid the area during implementation of the various activities.

When considered with the recent Rim Recovery project, portions of the project area may appear 

crowded with workers and equipment for the several years that it takes to complete treatments.

The longer-term impacts of ongoing and reasonably foreseeable activities, when added to the 

activities proposed in the Rim Reforestation project, have the potential to cumulatively impact the 

recreation setting by causing changes to the scenic qualities within the project area and creating a 

setting where resource modifications and utilization practices are evident Most of these effects would 

be beneficial because they would increase the resiliency of forest conditions, and reduce the risk of 

potential negative impacts from severe wildfire, therefore, maintaining the recreation settings 

currently valued by the public. However, due to the length and widespread level of activities, lasting 

over many years, there could be long term changes to recreation patterns. Fire not only changes the 

landscape; it changes how people move through it based on their preferences. Often people do not 

wish to recreate in recently burned areas, and it is expected that shifting of recreation to other areas is 

likely to occur.

The current and planned vegetation management treatments cumulatively would result in 

improvements in forest health and sustainability that are large and widespread. In the event of a 

wildfire, or insect infestation the restored forest would likely experience more typical low severity 

fire and small scale insect infestation. This would indirectly benefit recreation in the long term.

Alternative 2 (No Action)

DIRECT AND INDIRECT EFFECTS

This alternative would result in no short term or direct effects to the recreation resources, access or 

quality of recreation experience within the project area. Existing patterns of recreation use are 

expected to remain, and to increase in volume over time. Closures for safety could continue, however, 

and these areas would be unavailable for visitor use.

The risk of severe wildfire would remain, though not in the short term. In the long term, this may 

result in indirect effects to recreation resources, potentially resulting in changes to the recreation 

setting or scenic quality of the project area. These could include closures, lost opportunities due to 

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Chapter 3.08 Stanislaus

Recreation National Forest

destruction of recreation facilities by fire, and changes to access due to hazards such as snags, brush, 

and fallen trees.

Visitors’ experience may be diminished if they are aware of weeds. Weeds can negatively affect a 

wide array of environmental attributes that are important to support recreation, including but not 

limited to soil quality, water quality and quantity, plant diversity, availability of forage and cover, and 

animal diversity and abundance (Eiswerth et al. 2005). Weeds could establish in some dispersed sites, 

limiting the availability of that area for recreation. However, those visitors who oppose chemical 

treatments would be more likely to recreate in an area where this type of treatment would not occur.

The natural recolonization of a fire area could be a draw for some who are interested in this process. 

Some areas with seed trees that survived the Rim Fire are producing regeneration; this could be 

interesting to visitors and an educational look at benefits of fire. However, there are many areas that 

experienced high burn severity and regeneration is currently occurring in the form of manzanita, oak 

and deer brush. These shrubs can be difficult to pass through and off-trail hikers and hunters would 

avoid those areas.

In addition, visitors may avoid the areas that do not naturally recolonize with conifers, since shade 

and the views they are accustomed to or desire would not be present. This avoidance could persist for 

decades.

CUMULATIVE EFFECTS

Cumulative effects are expected to be limited to those areas where closures or subsequent fires could 

cause changes to recreation patterns. Without reforestation activities, the vegetation that colonizes the 

fire area could cause long-term changes in how visitors distribute themselves across the landscape, 

and in combination with other projects occuring in the same area, would incur shifts in how people 

experience the Forest, particularly off-trail users.

Alternative 3

DIRECT AND INDIRECT EFFECTS

The main differences between Alternative 1 and 3 include the lack of herbicide use and differences in 

planting prescriptions. 

Noxious Weed Eradication

Alternative 3 proposes non-chemical site preparation, release and noxious weed treatments using 

methods such as: burning, grazing, grubbing, hand-pulling, and native seeding. Because herbicides 

would not be used, some noxious weeds would continue to grow and flourish. Visitors’ experience 

may be diminished if they are aware of weeds. Weeds can negatively affect a wide array of 

environmental attributes that are important to support recreation, including but not limited to soil 

quality, water quality and quantity, plant diversity, availability of forage and cover, and animal 

diversity and abundance (Eiswerth et al. 2005). Weeds and woody shrubs in some dispersed sites

would limit the recreation area’s availability. However, those visitors who oppose chemical 

treatments would be more likely to recreate in an area where this type of treatment would not occur.

However, due to the increased effort involved in hand treatments, the presence of crews would be 

prolonged over the other action alternatives. 

Reforestation

Alternative 3 would reforest the same amount of acres as Alternative 1, though the spacing and a 

different fuel break ridge treatment are different as discussed under Visual Resources (Chapter 3.01). 

In the long term, visitors could be aware of large spaces used as fuel breaks, but the majority of 

visitors would not be affected by the spacing. Impacts to recreation would be the same as under 

Alternative 1, although there would be additional deep tilling in Alternative 3. The presence of crews 

and machinery would be more pronounced. Grubbing treatments would occur for several years, 

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Draft Environmental Impact Statement and Environmental Consequences

increasing the amount of workers in the field during that time over other alternatives. Visitors who 

did not want to encounter work crews or machinery could be displaced for longer periods under 

Alternative 3.

Prescribed Fire

Same as Alternative 1.

ThinExisting Plantations

The direct effect of Alternative 3 is that in some cases weeds would continue to grow and spread. 

People would not be exposed to herbicides under Alternative 3, but would continue to experience the 

effects of weeds and woody shrubs, such as noticeable changes to natural conditions and processes 

expected as part of a forest setting. 

CUMULATIVE EFFECTS

Cumulative effects would be similar to Alternative 1, although visitors would see and hear additional 

and longer-term evidence of workers in the project area due to the additional machinery and time 

needed for machine and hand treatments instead of herbicide applications. 

Alternative 4

DIRECT AND INDIRECT EFFECTS

Herbicide Use and Noxious Weed Eradication

Alternative 4 includes similar noxious weed eradication and effects as Alternative 3, without the use 

of herbicides. However, herbicides would be used for release and planting activities. For those areas, 

impacts would be similar to Alternative 1, on a much smaller scale.

Reforestation

The main difference to recreation impacts under Alternative 4 would be less treatments proposed. 

There would be considerably fewer planted acres and trees than in Alternative 1. Reforestation would 

occur on only 20% of each unit proposed in Alternative 1. In addition, complex early seral forest is 

left intact and removed from reforestation consideration. 

Effects would be similar to Alternative 1, but diminished in scope. Since far fewer acres proposed for 

treatment in Alternative 1 would not be treated under Alternative 4, the presence of crews, herbicide

use, machinery, and burning would impact visitors in very few instances. Though some displacement 

could occur, recreation patterns would be expected to continue in a normal manner. However, impacts 

from lack of reforestation activities on the areas not treated would be similar to Alternative 2. Due to 

lack of reforestation, visitors could see a relatively open landscape in some areas, facilitating off trail 

travel, until brush development prohibited access, or until natural regeneration occurs.

Prescribed Fire

Much more burning would occur under this alternative; over 10 years, nearly 16,000 acres would be 

burned. Impacts would depend on rotation, location and size of each unit. If burn times are staggered, 

visitors would likely not be displaced or inconvenienced. If adjacent units are burned consecutively, 

visitors could be bothered by lingering smoke, delays, and the presence of fire crews. In some 

instances nearby roads and facilities could be temporarily closed during burn windows. The presence 

of active fire, while controlled, could cause some visitors anxiety and they could change their travel 

plans. Visitors with breathing challenges would tend to avoid the area entirely. Since units are fairly 

scattered through a large area, effects would be minor and short term. 

ThinExisting Plantations

Same as Alternative 1.

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CUMULATIVE EFFECTS

Effects would be similar to, but considerably less than, Alternative 1 for the treated areas, and similar 

to Alternative 2 for those areas not treated. .If a severe wildfire season that impeded recreation 

opportunities on a large part of the forest preceded the prescribed burning activities; the combination 

of the burning proposed in this alternative with the wildfire event would negatively affect recreation 

for that particular year.

Alternative 5

DIRECT AND INDIRECT EFFECTS

Herbicide Use and Noxious Weed Eradication

Same as Alternative 1.

Reforestation

Alternative 5 proposes planting conifers in the same areas proposed in Alternative 1, including the 

natural regeneration units, though some prescriptions are different. Impacts to recreation should not 

differ from Alternative 1. The spacing prescription is different than in the other action alternatives; 

instead of clumps or clusters, a more traditional approach is proposed. To some visitors, the even 

spacing may appear unnatural. Thinning of new plantations to create the ICO structure would make 

the stands appear more natural. The appearance is not expected to affect recreation patterns 

significantly. Refer to the Visual Resources (Chapter 3.01) for more discussion. 

Prescribed Fire

Alternative 5 only includes prescribed fire in existing plantations. Effects from smoke would be less 

than the other action alternatives.

Thin Existing Plantations

Same as Alternative 1.

CUMULATIVE EFFECTS

Cumulative effects would be similar to Alternative 1.

Summary of Effects Analysis across All Alternatives

Alternatives 1, 3 and 5 would be similar. These include temporary negative effects of noise, dust and 

increased traffic on the recreation experiences of Forest users. The use of herbicides in Alternatives 1, 

4 and 5 would cause temporary negative effects to visitors who are concerned about health issues 

associated with those treatments. Effects would include seasonal displacement, change in travel 

routes, or simple avoidance until after treatments are completed. Each action alternative proposes 

some form of weed treatment, which would ultimately benefit forest health, indirectly improving 

recreation in the area.

Alternative 4 would have much less impact on recreation from noise, dust and increased traffic, since 

considerably fewer acres are being treated. Impacts of smoke would be greater and persist for more 

years under this alternative, and for short periods could cause more smoke-related displacement of 

visitors than the other alternatives.

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3.09 SENSITIVE PLANTS

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction

No federally listed plants occur on the Stanislaus National Forest. FSM 2670 and the Forest Plan 

provide direction for management of sensitive plants.

Sensitive Plants are defined as “those plant ... species identified by a regional forester for which 

population viability is a concern, as evidenced by: a) significant current or predicted downward 

trends in population numbers or density and b) significant current or predicted downward trends in 

habitat capability that would reduce a species' existing distribution” (FSM 2670.5). It is the Secretary

of Agriculture's direction to "avoid actions which may cause a species to become threatened or 

endangered" (USDA 2008d). Further, it is a Forest Service objective to "maintain viable populations 

of all native ... plant species in habitats distributed throughout their geographic range on National 

Forest System lands" (FSM 2670.22). Forest Service policy set out in FSM 2670.32 is to "avoid or 

minimize impacts to [Sensitive] species whose viability has been identified as a concern." Where it is 

determined that impacts cannot be avoided, "the line officer with project approval authority, [may 

make] the decision to allow or disallow impact, but the decision must not result in loss of species 

viability or create significant trends toward federal listing."

Forest Plan direction for Sensitive Plants is to "provide for protection and habitat needs of sensitive 

plants, so that Forest activities will not jeopardize their continued existence." Forest Plan Standards 

and Guidelines advise to "modify planned projects to avoid or minimize adverse impacts to sensitive 

plants" (USDA 2010a, p. 60). 

The Forest Plan Compliance (project record) document identifies the Forest Plan Standards and 

Guidelines that specifically apply to this project and related information about compliance with the 

Forest Plan.

Effects Analysis Methodology

Assumptions Specific to Sensitive Plants

 The remaining 2% of the area that has not been surveyed for Sensitive Plants would be completed 

prior to implementation. 

 Management requirements would be applied to the newly discovered populations. 

Data Sources

 Rare plant occurrences, survey locations and habitats (GIS).

 RareFind 5 Database from the California Natural Diversity Data Base (CDFW 2014c), California 

Department of Fish and Wildlife (CDFW 2014d). 

 Soil Survey, Stanislaus National Forest Area, California (USDA 1981). 

 Tuolumne County Lithography. 

 2009 GIS Ortho Photo layers. 

 Google Earth satellite aerial photos.

 Specimen herbarium records (CCH 2014). 

 The paper-based Groveland Ranger District surveys completed atlas.

Sensitive Plant Indicators

 Sensitive Plant occurrences.

 Suitable habitat for sensitive plants and the condition of those habitats.

 Number of sensitive plants impacted by the project, the intensity of the impacts and the duration 

of the impacts.

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Sensitive Plants Methodology by Action

A list of all federally listed Threatened, Endangered or Proposed plant species which might occur in 

the STF was acquired from the U.S. Fish and Wildlife Service (USFWS 2015).

A pre-field review was conducted to determine which sensitive plant species might occur or are 

known to occur within the project area (project record). Habitat attributes such as geology and soil 

types, elevation range, aspect and presence of closed canopy and forest openings were used to 

determine availability of suitable habitat for each species.

The effects of the Rim Reforestation project were analyzed using data from sensitive plant

inventories, local observations of effects to the various plant species, anecdotal information for 

specific species documented in Regional Sensitive List revision forms and, where available, 

published research papers.

The project area will serve as the geographic bounds for effects analysis of sensitive plants. The 

project area is an appropriate size to assess the effects of the proposed activities because all potential 

disturbances and effects to sensitive plants would occur within this boundary. Any predictable effects 

to vegetation would remain within this area. For sensitive plants, the project area also serves as the 

area of analysis for cumulative effects because effects of other past, present, and foreseeable activities 

would interact with effects of the proposed project only within the project area. 

The time frame considered for future effects is 10 years after implementation.

Affected Environment

Existing Habitat Conditions

The geology of the project area, as it relates to sensitive plant habitat, is quite varied. Bedrock and 

soil parent material are composed of granite, especially on the eastern half of the project, 

metasedimentary rock primarily on the western half of the project, or volcanically derived andesitic 

tuff (Mehrten Formation) which is isolated on some of the ridge tops and surrounding slopes. Soils in 

the project area are diverse, running the full range from deep sandy or loamy granitics to rocky clays 

of metasedimentary origin. The andesitic tuff breccia tends to be shallow, coarse and fast draining. 

This variety of soils and parent material allows for the establishment of rare plants, many of which 

have affinities for very specific types of soils or parent material. Lava caps were disturbed by the Rim 

Fire and some were also impacted during suppression activities. Before the fire, some of the lava caps 

were impacted by off-trail OHV driving causing localized disturbance.

Before the Rim Fire, plant communities within the project boundaries included Westside Ponderosa 

Pine Forest, Sierran Mixed Conifer Forest, several different chaparral communities such as Montane 

Manzanita Chaparral and Northern Mixed Chaparral, Montane Meadow, White Alder Riparian 

Forest, Aspen Riparian Forest, Blue Oak Woodland, and other oak woodland communities (Holland 

1986). Among these were mixed conifer stands which had not burned in wildfires in more than 100 

years and provided excellent habitat for occurrences of Cypripedium montanum, and small, low

gradient perennial streams which provided excellent habitat for Peltigera gowardii. These high 

functioning ecosystems were relatively free of noxious weeds. Many of them burned with a moderate 

to high intensity in the Rim Fire where the conifer overstory was completely killed. 

Wildfire has been an important component driving plant community composition within the analysis 

area during the past 100 years. Dating back as far as 1908, 124 wildfires occurred within the Rim Fire 

boundary (USDA 2010d). Some of the past fires overlapped with each other, burning some areas 

three, four or even five times prior to the Rim Fire. Other drivers of the pre-Rim Fire mix of plant 

communities include past logging, reforestation activities, cattle grazing and effective fire 

suppression. 

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Many of the Westside Ponderosa Pine Forest areas were conifer plantations 10 to 40 years of age. 

Some of the plantations were isolated and the result of old clear-cut timber harvests. However, most 

of the plantations were planted as part of the recovery from the1973 Granite Fire, the 1987 Stanislaus 

Complex fires and the 1996 Ackerson Complex or Rogge Complex fires. The Wrights Creek 

plantations dated from the 1950s and the Sawmill plantations dated from the 1960s and were also the 

result of post-fire recovery. The past wildfires and subsequent salvage logging and reforestation 

activities created thousands of acres of disturbed habitat. These plantations were in various phases of 

growth and many had been thinned in the past 15 years. Due to their mostly early seral nature, the 

understories had low native plant diversity and were primarily composed of disturbance followers 

such as non-native annual grasses and native shrubs like deer brush (Ceanothus integerrimus), 

manzanita (Arctostaphylos sp.), bear clover (Chamaebatia foliolosa) and Sierra gooseberry (Ribes 

roezlii). 

Sensitive Species

As described in the Sensitive Plant BE and Botany Report, rarity in plants can be the result of a 

number of things. Loss of habitat is a key factor for some species. Reproductive isolation through loss 

of populations is another factor. In many cases, the scarcity of the habitat in which the species 

evolved is the limiting factor which makes the species rare. Many of the sensitive plants considered in 

the Rim Reforestation project are limited to specialized or scarce habitats such as cliffs, vernal pools, 

fens (spring-fed seep or meadow areas containing 16 inches or more of peat), or “lava caps” 

(prehistoric volcanic ash mud flows also known as lahars and composed of andesitic tuff). 

Within the Rim Reforestation project, the majority of the treatment units have been surveyed for all 

sensitive species based on the unit’s habitat attributes and the current Sensitive Plant List. 

Approximately 2% of the project area remains unsurveyed. 

The following Sensitive Plant species are known to occur within the project area: Balsamorhiza 

macrolepis, Clarkia australis, Clarkia biloba ssp. australis, Cypripedium montanum, Erythronium 

taylori, Mimulus filicaulis, Mimulus pulchellus, and Peltigera gowardii.

In addition, suitable habitat within the appropriate geographic and elevational ranges exists within the 

project area for the following species: Allium tribracteatum, Allium yosemitense, Arctostaphylos 

nissenana, Botrychium ascendens, Botrychium crenulatum, Botrychium lineare, Botrychium lunaria,

Botrychium minganense, Botrychium montanum, Botrychium pedunculosum, Botrychium pinnatum, 

Bruchia bolanderi, Cinna bolanderi, Dendrocollybia racemosa, Eriastrum tracyi, Eriogonum 

luteolum var. saltuarium, Eriophyllum congdonii, Eriophyllum nubigenum, Erythronium 

tuolumnense, Fissidens aphelotaxifolius, Helodium blandowii, Horkelia parryi, Hulsea brevifolia, 

Lewisia kelloggii ssp. hutchisonii, Lewisia kelloggii ssp. kelloggii, Lomatium stebbinsii, Meesia 

uliginosa, Mielichhoferia elongata, Mielichhoferia shevockii and Tauschia howellii. 

The following plant profiles are for species which are known from the project area. 

Balsamorhiza macrolepis (big-scale balsamroot) is a perennial herb in the sunflower family, 

Asteraceae. It reproduces by seed. Balsamorhiza macrolepis begins growing in late winter or early 

spring and blooms in mid-spring. The plant goes dormant during the summer, after seeds are 

produced. The range of Balsamorhiza macrolepis is the Sierra Nevada Foothills from Tehama County

south to Mariposa County, and the interior Coast Range from Tehama County (Mendocino National 

Forest) south to Santa Clara County. Balsamorhiza macrolepis inhabits a variety of soil and plant 

community habitats. It has been reported from ponderosa pine forest, chaparral, vernally moist 

meadows and grasslands or grassland within oak woodland. Most of the occurrences are found in 

serpentine substrates, but it is also known to grow in soils derived from sandstone, basalt, and rocky 

clays of metasedimentary origin. The known occurrences in the Rim Fire burned area and the 

Yosemite occurrence are on granitic soils. Balsamorhiza macrolepis is usually found in openings or 

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under an open brush cover. The elevation range is listed as below 4,600 feet (Jepson Flora Project

2014). It occurs as high as 4,700 feet elevation in the STF. 

Clarkia australis (Small's southern clarkia) is an annual herb which grows in openings in ponderosa 

pine and mixed-conifer stands often in association with bear clover. Clarkia australis prefers sites 

with little or no competition from aggressive weedy species. When not associated with bear clover, 

the species is usually observed growing in bare mineral soil or with a very light layer of leaf litter. 

Clarkia australis has a very narrow range in Tuolumne and northern Mariposa Counties. The Rim 

Fire burned through a large portion of the known occurrences of this species. 

Clarkia biloba ssp. australis is an annual herb which usually grows under light shade in oak 

woodland, chaparral and conifer forests. Like Clarkia australis, it prefers to grow where there is little 

competition from weedy species.

Cypripedium montanum (mountain ladyslipper orchid) is a perennial herb in the orchid family, 

Orchidaceae. It arises in early spring from shallow rhizomes and dies back by late summer. The 

appropriate identification period for this species is mid-spring, approximately early May to mid or 

late June. In the STFt, Cypripedium montanum inhabits sites which are relatively undisturbed with a 

moderate to dense overstory, usually containing Douglas-fir or white fir. These sites are typically 

west or north-facing with fairly damp, deep loamy soils and a welldeveloped duff layer. In the STF, 

Cypripedium montanum ranges in elevation from 3,500 to 6,500 feet. The elevation range for 

California is listed as 650 to 7200 feet (Jepson Flora Project 2014). 

Erythronium taylori (Taylor's fawn lily) is a perennial herb in the lily family, Liliaceae. It was

discovered by Dean Taylor, Ph.D. in 1996 in the Groveland Ranger District and described by James 

R. Shevock and Geraldine A. Allen (1997). It emerges from a corm in early spring and withers by 

mid-June. The appropriate identification period for this species is early spring, approximately the 

month of April. Erythronium taylori is found in habitat that is shaded, northfacing cliffs. Because 

other species of Erythronium can inhabit a variety of north-facing habitats, it's possible that 

Erythronium taylori might occur on sites, which are not cliff-like. The elevation is approximately 

4,200 feet. 

Mimulus filicaulis (the slender-stemmed or Hetch-Hetchy monkey flower) and Mimulus pulchellus

(the pansy monkey flower) are annual herbs which occur in seasonally damp soils, seeps, springs, 

meadows and drainages in openings in forests or chaparral. Mimulus pulchellus is often found 

growing in “lava cap” soils. Mimulus filicaulis has a very narrow range from the Tuolumne River 

south to Mariposa County. Most of the occurrences are centered on the area east of Cherry Lake Road 

and north of Highway 120 and west of the boundary with Yosemite National Park. The range of 

Mimulus pulchellus is Calaveras, Tuolumne and Mariposa Counties. Both Mimulus filicaulis and 

Mimulus pulchellus prefer to grow in areas with little competition. Both tolerate low levels of soil 

disturbance, such as caused by gophers after the plants have gone to seed.

Peltigera gowardii (Goward’s waterfan) is a lichen which grows submerged or within spray zones of 

perennial streams. The streams are shallow and often fed by cold water springs. The water is very 

clear and peak flows are not of the intensity that would lead to scouring. The range of this species is 

from southern Alaska to Fresno County in California. 

In addition to Sensitive Plants, the Botany Report (project record) analyzed Forest Watchlist and 

Botanical Interest species. Forest Watchlist species include those which are locally rare (as opposed 

to declining throughout their range), are of public concern, occur as disjunct populations, are newly 

described taxa, or lack sufficient information on population size, threats, trend, or distribution. 

Botanical interest species are those which are protected or enhanced for the purpose of conserving 

botanical richness or diversity within the National Forest. These are typically species which are 

uncommon in the Forest, but not necessarily uncommon at a regional or global scale. They are 

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Draft Environmental Impact Statement and Environmental Consequences

sometimes species at the extent of their geographic ranges, disjunct from areas where they are 

common, or are limited by habitats which are uncommon in the Forest, but more numerous 

elsewhere.

Environmental Consequences

Alternative 1 (Proposed Action)

DIRECT AND INDIRECT EFFECTS

Sensitive Plant occurrences will be avoided during implementation. Additionally, sun-loving species 

of sensitive plants would be provided with a buffer to remove the indirect effects of shading from 

replanting. No occurrences are expected to be eliminated as a result of these situations. Table 3.09-1 

shows the number of known occurrences and their acreage overlapping proposed treatments. 

Table 3.09-1 Alternatives 1, 3 and 5: Sensitive Plant Occurences Overlapping Treatment Areas

Sensitive Plant Species Occurrences in units

(number)

Occurrences in units

(acres)

Balsamorhiza macrolepis 4 0.21

Clarkia australis 170 154.85

Clarkia biloba ssp. australis 45 105.11

Cypripedium montanum 21 3.08

Erythronium taylori 1 11.53

Mimulus filicaulis 88 66.93

Mimulus pulchellu 15 27

Peltigera gowardii 6 7.41

With avoidance of most sensitive plant occurrences, only Clarkia australis, Clarkia biloba ssp. 

australis, Mimulus filicaulis and Mimulus pulchellus would possibly be directly affected by the 

proposed activities. In some of these occurrences, manual site preparation would be allowed during 

the dry non-growing period when the species are present as seed, not living plants. Conducting 

manual site preparation within these occurrences poses a low to moderate risk of damage or death of 

some of the seeds even when implemented during the dry, non-growing period. The risk would come 

from trampling by workers. The amount of seed damaged or lost is expected to be minimal. 

Effects to Clarkia australis are reduced by not allowing equipment to track through occurrences 

smaller than 0.25 acre and to minimize tracking through occurrences larger than 0.25 acre. Rather 

than impacting growing plants, activities in Clarkia australis occurrences would be restricted to the 

dry, non-growing period, when they would have less impact by allowing annual seed set and 

conserving seed in the soil. These standard management requirements greatly reduce the risk that 

occurrences of Clarkia australis would be eliminated. The benefit of conducting mastication within 

occurrences of Clarkia australis is the reduction of fuels (trees and brush) and inter-tree competition 

which would contribute to fuel loading and thereby lower the risk of losing occurrences during the 

next wildfire. Additionally, mastication might help prevent or diminish the establishment of dense 

brush which might otherwise dramatically reduce the quality of the habitat for Clarkia which prefers 

to grow in forest openings with little or no competition. The benefit of subsoiling in Clarkia australis

occurrences is the enhancement of habitat.

Conducting manual site preparation within occurrences of Clarkia australis, Clarkia biloba ssp. 

australis, Mimulus filicaulis or Mimulus pulchellus poses a low to moderate risk of damage or death 

of some of the seeds even when implemented during the dry, non-growing period. The risk would 

come from trampling by workers. The amount of seed damaged or lost is expected to be minimal. 

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Table 3.09-2 details the number of occurrences affected by manual treatment. The acres presented are 

the amount of treatment that intersects with sensitive plant occurrences rather than the acres of 

sensitive plants affected. As a result, the number of acres for each species is likely inflated. Most of 

the percentages are low with Clarkia biloba ssp. australis being the most affected with 53% of the 

occurrences impacted, but only 5% of the total acreage. Clarkia australis is moderately affected in 

terms of occurrences affected (17%), but only has 7% of the total acreage in the project area affected. 

Mimulus fillicaulis has a negligible amount affected while mimulus pulchellus is not affected by hand 

treatments.

Table 3.09-2 Alternative 1: Occurrences Intersecting Manual Treatments 

Sensitive Plant Species Number of Occurrences in 

units (percent of total)

Acres of Occurrences 

in units (percent of total)

Clarkia australis 29 (17%) 11.3 (7%)

Clarkia biloba ssp. australis 24 (53%) 5.3 (5%)

Mimulus filicaulis 2 (2%) 0.24 (less than1%)

Mimulus pulchellus 0 0

The Sensitive aquatic lichen Peltigera gowardii may be affected indirectly by project activities. It is 

expected that activities which change these habitat characteristics – increase sedimentation, scour or 

sun exposure – would likely lead to a reduction or loss of individuals, and depending on the degree of 

impact, perhaps loss of the occurrence. Sedimentation or scouring could damage the thin, gelatinous 

thallus of Peltigera gowardii by abrading it, leading to death of the organisms (USDA 2010c). 

Sedimentation could also cover the organisms, blocking their ability to photosynthesize (USDA 

2010c). The soil and watershed BMPs would prevent direct impacts to the species, and would reduce 

the amount of activity-created sediment in these occurrences. Planting trees will have the long term 

benefit of producing shade by returning the canopy back to previous conditions. 

Noxious weed eradication has the potential to indirectly affect rare plant species through accidental 

spills, spray drift, surface runoff, or a combination of these factors. These potential effects would be 

greatly limited by implementing BMPs and management requirements. Noxious weed invasion can 

result in negative impacts to all habitat types, although different habitats may be invaded by different 

suites of noxious weed species. Noxious weed infestations can lead to changes in habitat 

characteristics that are detrimental to sensitive plant species. Once weeds have become established 

they can indirectly impact sensitive species through allelopathy (the production and release of 

chemical compounds that inhibit the growth of other plants), altering fire regimes, and competing for 

nutrients, light, and water. Treatment of known noxious weed sites reduces the risk of the impacts, 

while also potentially opening up suitable habitat for colonization for sensitive plant populations near 

infested areas.

Thinning existing plantations to an ICO structure would likely benefit species found within thinning 

units, Balsamorhiza macrolepis, Clarkia australis, Clarkia biloba ssp. australis, Mimulus filicaulis 

and Mimulus pulchellus, if the occurrences are in close proximity to open patches to potentially 

colonize. One occurrence of Cypripedium montanum has less than 0.01 acre within thinning units. 

This species would benefit by maintaining clumps on its edge. 

CUMULATIVE EFFECTS

Present and future projects planned within the Rim Reforestation project area (Appendix B) 

incorporate management requirements which reduce the risk of loss of occurrences. The combined 

effects of the proposed activities in Alternative 1 with other present and foreseeable future actions, 

shown in Table 3.09-3, are not expected to result in adverse cumulative effects to sensitive plants, 

mainly due to flagging and avoiding known sites. Individuals may be adversely affected by proposed 

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Draft Environmental Impact Statement and Environmental Consequences

project activities. However, these impacts are not expected to be so great in intensity or duration that 

any of these occurrences would be eliminated, even when combined with other Forest activities.

Table 3.09-3 Alternatives 1, 3, 4 and 5: Sensitive Plants Overlapping Cumulative Effects Activities

Sensitive Plant Species Project Activity Type ALT 1

(acres)

ALT 3 

(acres)

ALT 4 

(acres)

ALT 5 

(acres)

Balsamorhiza macrolepis Grazing 0.21 0.21 0.09 0.21

Balsamorhiza macrolepis Rim Hazard Tree EA: MP 0.09 0.09 0.09 0.09

Balsamorhiza macrolepis Rim Recovery EIS: HP, MP, JP, Burn 0.10 0.10 0 0.10

Clarkia australis Grazing 154.85 154.85 72.58 154.85

Clarkia australis Rim Hazard Tree EA: MP 16.12 16.12 8.50 16.12

Clarkia australis Rim Recovery EIS: HP, MP, JP, Burn 84.23 84.23 66.22 84.23

Clarkia australis Wildlife Habitat Enhancement: Encroaching conifers 0.15 0.15 0.15 0.15

Clarkia biloba ssp. Australis Grazing 105.11 105.11 0.76 105.11

Clarkia biloba ssp. Australis Rim Hazard Tree EA: MP 50.92 50.92 0.45 50.92

Clarkia biloba ssp. Australis Rim Recovery EIS: HP, MP, JP, Burn 21.00 21.00 0.30 21.00

Cypripedium montanum Grazing 3.08 3.08 1.48 3.08

Cypripedium montanum Rim Hazard Tree EA: MP 0.47 0.47 0.47 0.47

Cypripedium montanum Rim Recovery EIS: HP, MP, JP, Burn 1.21 1.21 0.96 1.21

Cypripedium montanum Rim Fire Rehabilitation: Great Gray Owl: Ackerson 0.30 0.30 0 0.30

Erythronium taylori Grazing 11.53 11.53 11.53 11.53

Erythronium taylori Rim Recovery EIS: LS, JP, Burn 11.53 11.53 11.53 11.53

Mimulus filicaulis Grazing 66.93 66.93 2.26 66.93

Mimulus filicaulis Carlon Trailhead: Recreation 0.07 0.07 0 0.07

Mimulus filicaulis Dimond “O” Campground: Recreation 0.07 0.07 0 0.07

Mimulus filicaulis Middle Fork Picnic Site: Recreation 0.18 0.18 0 0.18

Mimulus filicaulis Rim Hazard Tree EA: MP 9.13 9.13 0.64 9.13

Mimulus filicaulis Rim Recovery EIS: HP, MP, JP, Burn 10.39 10.39 1.29 10.39

Mimulus filicaulis Rim Fire Rehabilitation: Meadow-Stream/meadow North Sawmill 0.33 0.33 0 0.33

Mimulus filicaulis Soldier Timber Sale 0.20 0.20 0 0.20

Mimulus pulchellus Grazing 27.00 27.00 1.22 27.00

Mimulus pulchellus Rim Hazard Tree EA: MP 1.07 1.07 0 1.07

Mimulus pulchellus Rim Recovery EIS: HP, MP, JP, Burn 16.08 16.08 1.22 16.08

Mimulus pulchellus Jawbone - Granite Stewardship: Fence Repair: Lower Femmons 4.7 0.08 0.08 0.08

Mimulus pulchellus Wildlife Enhancement: Meadow handwork Lower Femmons 0.08 3.64 0.72 3.64

Peltigera gowardii Grazing 7.41 7.41 5.17 7.41

Peltigera gowardii Rim Hazard Tree EA: MP 3.48 3.48 3.28 3.48

Peltigera gowardii Rim Recovery Project: HP, MP, JP, Burn 3.08 3.08 1.67 3.08

Peltigera gowardii Rim Recovery Project: LS, JP, Burn 0.10 0.10 0.10 0.10

HC=Hand Cut; HP=Hand Pile; JP=Jackpot Burn; LS=Lop and Scatter; MP=Machine Pile (with dozer)

Alternative 2 (No Action)

DIRECT AND INDIRECT EFFECTS

Alternative 2 has no direct effects to Sensitive Plants. Indirect effects could occur from increased 

invasion of existing noxious weed populations, potential increase in the risk of future high severity 

wildfire due to not removing standing biomass and woody fuels. In some cases dense brush is likely 

to take over some habitat, overtopping rare plant species and effectively shading them out of former 

habitat. The potential benefits to annual species and Balsamorhiza macrolepis would not be realized 

as existing plantations would not be thinned and denser canopies over a larger area would be 

maintained.

CUMULATIVE EFFECTS

Projects that occur within the cumulative effects area (such as Rim Recovery and Rim HT) utilized 

flag and avoid to minimize effects to sensitive species. As a result, these actions are not expected to 

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contribute to adverse cumulative effects. Peltigera gowardii occurrences are at a high risk of loss to 

sedimentation in Alternative 2 since no reforestation activities would contribute to soil stabilization to 

prevent sedimentation.

Alternative 3

DIRECT AND INDIRECT EFFECTS

Table 3.09-1 shows the number of occurrences potentially affected in Alternative 3 are the same as 

Alternative 1; however, two of those occurrences of Clarkia australis could be affected by subsoiling. 

Alternative 3 also proposes 2,565 fewer acres of noxious weed treatments than Alternative 1, while 

also proposing the opening of more bare mineral soil through hand grubbing. Additionally, weed 

treatment does not include herbicides, which would make the treatments less effective and noxious 

weeds would persist at sites within the project longer. The risk of noxious weed invasion is high in 

Alternative 3 compared to moderate in Alternative 1. The potential effects to Sensitive plants are also 

comparatively higher. 

CUMULATIVE EFFECTS

Same as Alternative 1 (Table 3.09-3). 

Alternative 4

DIRECT AND INDIRECT EFFECTS

The direct and indirect effects of this alternative would be similar to those described in Alternative 1. 

However, as Table 3.09-4 shows, Alternative 4 has fewer activities that would not be flagged for 

avoidance, so less occurrences of most of the species would be affected. A greater percentage of 

occurrences fall within hand treatments in Alternative 4 compared to Alternative 1 and Alternative 4 

would create more ground disturbance through prescribed burning than the rest of the action 

alternatives.

Alternative 4 has a greater risk of weed spread since no herbicides are proposed for use in weed 

eradication and fewer weed populations and species would be targeted. Therefore, even though this 

alternative proposes treatment in fewer rare plant occurrences the overall risk of noxious weed

invasion into these areas is greater.

Table 3.09-4 Alternative 4: Sensitive Plants Overlapping Proposed Reforestation Activities

Sensitive Plant Species Occurrences in units

(number)

Occurrences in units

(acres)

Balsamorhiza macrolepis 1 0.09

Clarkia australis 62 75.28

Clarkia biloba ssp. australis 5 0.76

Cypripedium montanum 10 1.48

Erythronium taylori 1 11.53

Mimulus filicaulis 12 2.26

Mimulus pulchellus 2 1.22

Peltigera gowardii 2 5.17

CUMULATIVE EFFECTS

Table 3.09-3 shows fewer occurrences would be cumulatively affected in Alternative 4 as compared 

to Alternative 1. The effects are expected to be similar to those described in Alternative 1, but the 

magnitude of the effects would be smaller since less occurrences of annual species would potentially 

be treated.

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Alternative 5

DIRECT AND INDIRECT EFFECTS

Same as Alternative 1 (Table 3.09-1). 

CUMULATIVE EFFECTS

Same as Alternative 1 (Table 3.09-3). 

Summary of Effects Analysis across All Alternatives

For all action alternatives, the Rim Reforestation project will not impact Allium tribracteatum, Allium 

yosemitense, Arctostaphylos nissenana, Eriastrum tracyi, Helodium blandowii, Meesia uliginosa, 

Mielichhoferia elongata, and Mielichhoferia shevockii because activities are not proposed in their 

habitats. 

For all action alternatives, the Rim Reforestation project may affect individuals, but are not likely to 

result in a trend toward federal listing or loss of species viability for Balsamorhiza macrolepis, 

Botrychium ascendens, Botrychium crenulatum, Botrychium lineare, Botrychium lunaria, Botrychium 

minganense, Botrychium montanum, Botrychium pedunculosum, Botrychium pinnatum, Bruchia 

bolanderi, Cinna bolanderi, Cypripedium montanum, Dendrocollybia racemose, Eriogonum luteolum 

var. saltuarium, Eriophyllum congdonii, Eriophyllum nubigenum, Erythronium taylori, Erythronium 

tuolumnense, Fissidens aphelotaxifolius, Horkelia parryi, Hulsea brevifolia, Lewisia kelloggii ssp.

hutchisonii, Lewisia kelloggii ssp. kelloggii, Lomatium stebbinsii, Peltigera gowardii.and Tauschia 

howellii because even though flagging and avoiding will be in place or known locations do not exist, 

some undiscovered populations may be affected within suitable habitat that will be treated.

For Clarkia australis, Clarkia biloba ssp. australis, Mimulus filicaulis, and Mimulus pulchellus, all 

action alternatives of the Rim Reforestation project may affect individuals, but are not likely to result 

in a trend toward federal listing or loss of species viability because portions of their occurrences 

would likely receive adverse effects, but populations are not expected to be eliminated within the 

project area.

Even though the no action alternative does not manage for the increased risk of weed spread in the 

project area the effects to sensitive plants is minor because no disturbance activities would be 

implemented. The consequences are that it may affect individuals, but is not likely to result in a trend 

toward federal listing or loss of species viability for all sensitive species with suitable habitat in the 

project area.

The comparison of effects between alternatives concentrates on three main factors. The first factor is 

the amount of annual species (Clarkia australis, Clarkia biloba ssp. australis, Mimulus filicaulis, and 

Mimulus pulchellus) affected by treatments. This impact corresponds to the Sensitive Plant indicators: 

Sensitive Plant occurrences; and number of sensitive plants impacted by the project, the intensity of 

the impacts and the duration of the impacts. The second factor is the risk of weed spread inherent in 

each alternative. This impact corresponds to the Sensitive Plant indicators: suitable habitat for 

sensitive plants and the condition of those habitats; and the number of sensitive plants impacted by 

the project, the intensity of the impacts and the duration of the impacts. The third factor is the amount 

of habitat rehabilitated to pre-fire conditions. This impact corresponds to the Sensitive Plant indicator: 

suitable habitat for sensitive plants and the condition of those habitats.

Table 3.09-8 presents the comparison of effects between alternatives by assigning a value of 1 

through five for each impact factor. A one indicates the lowest level of impact while a five indicates 

the highest level of impact. In the case of identical effects, each alternative was given the same value 

while the next highest impact was given the next available value. For example, in Table 3.09-8 for the 

amount of habitat restored to pre-fire conditions impact, alternatives 1, 3 and 5 were given a value of 

1 while the next alternative was given a value of 4. All four of the impacts were weighted equally.

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This comparison of impacts between alternatives indicates that Alternative 1 and 5 have the least 

impact followed by Alternatives 3, 4 and 2 in order of higher impact.

Table 3.09-8 Comparison of Alternatives: Impacts to Sensitive Plants 

Impact Factor Alternative 

1

Alternative 

2

Alternative 

3

Alternative 

4

Alternative 

5

Amount of annual species affected 5 1 5 2 5

Risk of noxious weed spread 1 5 3 4 1

Amount of habitat restored to pre-fire 

conditions

1 5 1 4 1

Aggregate impact score 7 11 9 10 7

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3.10 SOCIETY,CULTURE AND ECONOMY

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction

Multiple statutes, regulations and executive orders identify the general requirement for the application 

of economic and social evaluation in support of Forest Service planning and decision making. These 

include, but are not limited to, the Multiple-Use Sustained Yield Act of 1960 (74 Stat. 215: 16 USC 

528-531), National Environmental Policy Act of 1969 (83 Stat. 852; 42 USC 4321, 4331-4335, 4341-

4347), and the Planning Act of 1974. In addition, the following guidance also applies. 

Executive Order 12898 issued in 1994 orders federal agencies to identify and address any adverse 

human health and environmental effects of agency programs that disproportionately impact minority 

and low-income populations. The Order also directs agencies to consider patterns of subsistence 

hunting and fishing when an agency action may affect fish or wildlife. 

The Civil Rights Act of 1964 provides for nondiscrimination in voting, public accommodations, 

public facilities, public education, federally assisted programs, and equal employment opportunity. 

Title VI of the Act, Nondiscrimination in Federally Assisted Programs, as amended (42 U.S.C. 2000d 

through 2000d-6) prohibits discrimination based on race, color, or national origin. 

Office of Management and Budget Circular A-94 “Guidelines and Discount Rates for Benefit-Cost 

analysis of Federal Programs,” (Revised October 29, 1992), and including Appendix C Revised 

December 2014 presents discount rates to be used for economic analyses conducted in calendar year 

2015. This circular provides guidelines for evaluating the economic efficiency of Federal agency 

programs and projects that take place over a number of years. 

The Forest Plan Compliance (project record) document identifies the Forest Plan S&Gs that

specifically apply to this project and related information about compliance with the Forest Plan.

Effects Analysis Methodology

Assumptions Specific to Society, Culture and Economy

 The majority of the Rim Fire burned within Tuolumne County, but the southern portion of the fire 

also burned into Mariposa County. The primary socioeconomic impacts would occur within a 

geographic region of impact defined by these two counties. Some secondary impacts would be 

felt in other counties as noted in the analysis below.

 The Environmental Justice analysis reports what effects might occur to minority and low-income 

populations. Of particular concern is whether job or income discrimination might occur to these 

groups in the area during, or resulting from, the proposed project. 

Data Sources

 California Department of Finance 

 California Employment Development Department

 IMPLAN Group, LLC

 United States Census Bureau

 USDA Forest Service

Society, Culture and Economy Indicators

Indicators used in the analysis of economic and social effects may be grouped into three categories as 

directed by Forest Service Manual (FSM) Chapter 1970 - “Economic and Social Evaluation.” The 

three categories are:

 Economic Efficiency

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 Economic Impact 

 Social Analysis

ECONOMIC EFFICIENCY

Undertaking the proposed actions, a long-term investment, would have immediate costs during 

implementation over the next 10 to 15 years, but the value in forest products will not be fully realized 

until trees mature 60 years or more in the future. As directed by FSM and Forest Service Handbook 

1909.17, the primary indicators of economic efficiency in this type of long-term situation should be: 

 Present Net Cost (PNC)

 Present Net Benefit (PNB)

 Present Net Value (PNV)

Estimates are made for these indicators in order to make comparisons between alternatives, and not to 

attempt to measure absolute numbers for outputs. Also, no attempt has been made to assign monetary 

values to resource outputs such as wildlife, watershed, soils, or fisheries.

ECONOMIC IMPACT

Within the two-county region of impact, jobs were selected as the single best indicator of economic

health because jobs are intuitively understandable and easily observed by the communities affected, 

but it should be noted that beneficial or adverse economic impacts on jobs are highly correlated with 

such other measures of economic health as gross regional product, economic output, personal income, 

and the portion of gross regional product that ultimately finds its way into local and state taxes. The 

key indicators are:

 Employment information at the county level for context

 Jobs supported by Rim Reforestation project activities

SOCIAL ANALYSIS

Non-market values, such as the value of recreation experiences or stability in rural lifestyles, by their 

nature are difficult to quantify. Direction provided in 40 CFR 1502.23 and Forest Service Handbook 

1909.15, (7/6/04) and 22.35 (01/14/05) provides for the use of qualitative analysis to evaluate the 

effects of these non-market values. The non-market aspects of each proposed activity will be 

described in other resource sections and specialist reports. Key indicators include:

 Local population trends and community demographic statistics

 Recreation patterns within the region of impact (qualitative)

 Potential for differential impacts on low income, minority, and other disadvantaged population 

groups (qualitative) 

 Social/cultural impacts to American Indians, ranching, regional business owners and summer 

camps (qualitative)

Society, Culture and Economy Methodology by Action

Actions, or the lack thereof, would have an effect on the society, culture and economy of Tuolumne 

and Mariposa Counties. Although not all of the socio-economic effects can be quantified, the 

methodology at least describes the mechanisms through which effects may be felt and characterizes 

their relative magnitude and direction (i.e., beneficial or adverse). Actions through which socioeconomic effects may be generated can be clustered into activity groups and include:

 Reforestation, the activity group with the highest costs to the government and highest economic 

impact, includes a more detailed sequence of possible activities including: site preparation, 

planting of conifers, release, and prescribed fire. 

 Noxious Weed Eradication, which includes such weed removal methods as burning, grazing, 

grubbing, herbicides and hand pulling. 

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 Deer Habitat Enhancement, which is essentially a special type of reforestation designed to 

benefit the deer population and includes the same detailed sequence of possible activities.

 Natural Regeneration, where initial activities are limited to fuels reduction. If after five years 

natural regeneration is not adequate, more traditional reforestation activities may be applied.

 Thin for ICO Structure within Existing Plantations, where the activities are designed to 

remove selected trees and understory through such methods as mechanical harvesting, hand 

cutting, mastication, and prescribed burns. 

METHODOLOGY FOR ASSESSING ECONOMIC EFFICIENCY

Most of the actions would require the government to incur near-term costs to implement them. Some 

of the actions would create the potential for the government to receive revenue over the long term 

through sales of timber and other forest products. Some of the actions would also create 

environmental benefits such as enhanced habitat for deer and other animals, or reduction of noxious 

weeds and other invasive species, which are noted as beneficial or adverse, but are not quantified in 

dollar terms for purposes of assessing the differences in economic efficiency between alternatives.

The near term costs to the government will be estimated by applying per-acre costs based on recent 

experience of the Stanislaus NF for paying qualified contractors to perform similar actions to the 

number of acres to be treated according to each alternative, with costs spread out over the next few 

years as implementation proceeds. Per-acre cost estimates of actions expressed in 2015 dollars are 

presented in Table 3.10-1. Most of the expenditures of public funds would go to private contractors to 

perform the bulk of the work, but the Forest Service would conduct all burning actions and the 

survival exam surveys and certifications.

Table 3.10-1 Average Estimated Cost of Treatment Actions per Acre

Treatment Action Contract Cost 

per Acre

Agency Workforce 

Cost per Acre

Deep till and forest cultivate $450 $0

Feller buncher $450 $0

Mastication $650 $0

Hand cut $750 $0

Machine pile and burn $430 $200

Hand pile $400 $0

Burn piles $0 $200

Jackpot burn $0 $650

Hand herbicide application (site preparation and release) $450 $0

Plant 7 feet x 14 feet $350 $0

Plant ICO Structure $425 $0

Survival exams (1st, 3rd and 5th year) $0 $100

Release by hand grubbing, once during the year $800 $0

Release by hand grubbing, two times during the same year $1,600 $0

Agency costs for monitoring Natural Regeneration units $0 $100

Prescribed fire - low complexity (plantations/treated areas) $0 $650

Prescribed fire - high complexity (complex early seral) $0 $1,000

Burning through aerial ignition $0 $1,000

Source: Stanislaus National Forest recent historical contracting.

For each alternative with its unique mix of treatments to be conducted on a number of acres, the 

Present Net Cost (PNC) is estimated by multiplying by the cost factors above to acres treated each 

year, and then by discounting near-term future costs using guidance from OMB Circular A-94 which 

specifies rates to be used for economic analysis of federal decisions considered in calendar year 2015. 

The near-term discount rates are presented in Table 3.10-2 for analyses conducted in real dollars (i.e., 

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where the effects of future inflation have been taken out by using constant 2015 dollars). The discount 

rates shown are those specified in Appendix C of OMB Circular A-94, and as directed by the 

instructions, discount rates for the intervening years may be estimated through linear interpolation. 

Federal actions with durations longer than 30 years may use the 30-year interest rate.

Table 3.10-2 Real Discount Rates to be Used in Federal Decisions Considered in 2015

Item Year 3 Year 5 Year 7 Year 10 Year 20 Year 30

Discount Rate 0.1% 0.4% 0.7% 0.9% 1.2% 1.4%

Source: OMB Circular A-94, Appendix C (Revised December 2014)

The Present Net Benefit (PNB) of each alternative is estimated by multiplying the possible revenue 

the government could generate decades into the future through thinning of trees, and ultimately 

through green timber sales once forests have matured sufficiently to yield sustainable harvests of 

timber. These distant future positive values also are discounted back to the present, and OMB 

Circular A-94 specifies an annual discount rate of 1.4% for cash flows that occur 30 or more years 

into the future. For example, the value of $100 earned through timber sales that take place 60 years 

from now, would only be worth $43 today: 

PNB = $100 x ____1______ 

(1 + 1.4%)60

PNB = $100 x 43% 

PNB = $43 

Estimating the value of green timber harvested far into the future clearly requires speculation. To 

remove the influences of possible future inflation, current values can be used, but even those fluctuate 

dramatically. For example, in the local market due in part to the large volume of salvaged trees 

recently available from the Rim Fire, and due in part to the national recession the U.S. building 

industry is only now recovering from, the demand for saw logs is currently at a historic low in 

Tuolumne County. From a much larger perspective, looking at the value of timber sold Forest Service 

wide over the last 30 years as reported to Congress, values have ranged from as low as $50 to over 

$170 per thousand board feet (MBF). The average revenue to the government has been approximately 

$100 per MBF, and this statistic will be used as a reasonable estimate of future timber sales potential 

as measured in today’s dollars. Again, future sales will be discounted depending on how far in the 

future they are expected to take place to reach the Present Net Benefit to the government.

The single best estimate of the economic efficiency of an alternative is the PNV, which is the sum of 

PNC and PNB. 

METHODOLOGY FOR ESTIMATING ECONOMIC IMPACT

Paying contractors to perform treatments in Rim Fire units would create temporary direct 

employment in Tuolumne and Mariposa counties. Although many of the laborers and skilled 

equipment operators directly employed are likely to be residents of other counties, or even other 

states, drawn to the STF to perform temporary jobs, the expenditures of contractors and their 

employees while in Tuolumne and Mariposa counties would also generate some modest indirect and 

induced employment through multiplier effects in the two-county region of impact.

The estimate of direct employment generated in each year is based on the total budget to be spent on 

contractors in that year across all units and all activities. Approximately half of the total budget is 

expected to go to the labor providing the work in the forest, with the other half including such uses as 

costs of equipment and supplies, transportation, payroll taxes, insurance, contractor overhead and 

profit and a small portion to Forest Service overhead costs of administering the contracts. 

Employment generation, measured in full-time-equivalent jobs is estimated by dividing labor costs by 

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a mean annual wage of $44,000, corresponding to a mean hourly wage of $21.15. The mean hourly 

wage is derived from the Occupational Employment Statistics and Wages (OES) survey conducted by 

the California Employment Development Department (EDD) for the “Mother Lode Region,” which 

includes the counties of Amador, Calaveras, Mariposa and Tuolumne. In the most recent OES data, 

released July 2015, the mean hourly wage for Farming, Fishing, and Forestry Occupations was 

$16.36, but half of those workers were relatively low-paid farm laborers (earning a mean of $10.84 

per hour). Logging Equipment Operators in the Mother Lode Region are earning a mean of $20.81 

per hour, First-Line Forestry Supervisors $23.73 and Fallers $29.35 on average. EDD uses 2,080 

hours per year to estimate mean annual wages for someone employed full time, and thus a $21.15 

hourly wage would create a full-time-equivalent wage income of $44,000 for the worker. 

Additional jobs would be indirectly supported in the region of economic impact as a result of the 

activities described above. Economic models based on input-output analysis are used to generate 

“multipliers” which estimate the “indirect” and “induced” economic effects associated with “direct” 

impacts. For example, if the operator of a feller buncher is the direct job supported, an indirect job 

would be held by the mechanic in Tuolumne County that services the equipment. Part of an induced 

job is supported in the local grocery store where both of the previous employees shop after work. In 

the methodology used for alternatives analysis, multipliers are derived from the IMPLAN system, 

developed by the Minnesota IMPLAN Group, Inc. (MIG) and now being vended by IMPLAN Group, 

LLC. Multipliers are lower for small economic areas than they are for the state as a whole, and the 

relevant multipliers for the direct industries affected average 1.5, indicating that for every job directly 

generated by the treatment activities, another half a full-time-equivalent job would be supported in 

Tuolumne or Mariposa Counties through indirect or induced mechanisms. Again, the goal is to create 

employment indicators that may be evaluated consistently across all alternatives, and not necessarily 

to estimate absolute numbers of jobs created in any given year. Also note that because annual average 

wages and full-time-equivalent statistics are used in the estimates, many more people would likely 

experience some additional employment than is indicated, because most of the direct jobs in the forest 

and the indirect and induced jobs in the service industries of Tuolumne and Mariposa counties are 

part-time in nature.

METHODOLOGY FOR ANALYZING SOCIAL ANALYSIS

Social effects are primarily discussed and analyzed in qualitative terms addressing:

 Recreation patterns of residents of Tuolumne and Mariposa counties. 

 Recreation that draws visitors from beyond the two-county area, and contributes to the local 

tourism industry and the rural Sierra lifestyles it supports.

 Rural mountain lifestyles supported by the forest products industry. 

 Rural lifestyles based on ranching, including reliance on grazing allotments in the Rim Fire area.

 Pressures on population growth in Mariposa and Tuolumne counties. 

 Potential for any effects involving environmental justice concerns.

Affected Environment

For socio-economic analysis, the primary environment impacted by the Rim Reforestation project 

actions is defined by the two counties that contained the fire: Tuolumne and Mariposa. The resident 

populations have lived in a culture that has a long history of forest products industries. Over time the 

counties have built up an infrastructure supporting the forest industries including lumber mills, energy 

co-generation plants, contractor companies, and an inventory of mechanical equipment that is used 

within the forests. This infrastructure relies on a long-term steady supply of growing trees and 

merchantable timber that requires periodic reforestation activities and decades of maintenance and 

care.

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In addition to forest products, Tuolumne and Mariposa counties have also fostered a culture including 

ranching and grazing, and other resource-based economic activities, such as mining. Residents also 

value the recreational opportunities provided by the NFS lands close to home.

In addition, the affected counties have a long history of serving a tourism industry that has Yosemite 

National Park as the largest attraction in the vicinity. The industry also relies on recreational 

opportunities in the National Forest, including many within the Rim Fire burn area. The area includes 

a special type of tourism associated with a collection of summer camps and private resorts that were 

impacted by the Rim Fire.

Existing Conditions

POPULATION

Table 3.10-3 shows rapid growth in the affected environment during the 1970s and 1980s. The 

population of Tuolumne and Mariposa Counties grew much faster than the state as a whole during 

those decades. The relative growth rate slowed during the 1990s, however, and since 2000 the 

counties have grown much slower than the state. 

Table 3.10-3 Historical Population by County for U.S. Census Years: 1970 – 2010

County or Region 1970 1980 1990 2000 2010

Mariposa 6,015 11,108 14,302 17,130 18,251

Tuolumne 22,169 33,928 48,456 54,504 55,365

Total 2-Co. Region 28,184 45,036 62,758 71,634 73,616

10-Year Growth 60% 39% 14% 3%

California 19,971,069 23,667,764 29,760,021 33,871,653 37,253,956

10-Year Growth 19% 26% 14% 10%

Source: California State Data Center, Demographic Research Unit, Department of Finance

Table 3.10-4 shows growth is expected to occur at a slower rate than the state average in coming 

decades as well. Today Tuolumne is by far the larger of the two counties, and coupled with the 

location of the majority of the Rim Fire area, the majority of the primary socio-economic impacts 

from reforestation activities would be felt in Tuolumne County. 

Table 3.10-4 Projected Population by County for 10-Year Periods: 2015 – 2055

County or Region 2015 2025 2035 2045 2055

Mariposa 18,147 20,520 21,288 20,949 20,334

Tuolumne 54,628 57,278 59,560 59,767 59,966

Total 2 Co. Region 72,775 77,798 80,848 80,716 80,300

10-Year Growth 7% 4% 0% -1%

California 38,896,969 42,373,301 45,747,645 48,574,095 50,817,750

10-Year Growth 9% 8% 6% 5%

Source: California State Data Center, Demographic Research Unit, Department of Finance

ENVIRONMENTAL JUSTICE CONCERNS

Some demographic data for the affected environment describe the context for evaluating 

environmental justice concerns. Executive order 12898, “Federal Actions to Address Environmental 

Justice in Minority Populations and Low-Income Populations,” signed February 11, 1994 by 

President Clinton states (Section 1-101), “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 in the United States.”

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For environmental justice analysis, Table 3.10-5 presents the ethnic distribution of the two-county 

population that defines the region of socioeconomic impact. The ethnic distribution of the California 

state population is also presented for comparison purposes. Tuolumne and Mariposa counties have 

very similar ethnic profiles, and both contain distinctly fewer minorities than the state as a whole, 

with the one exception that Native Americans are slightly more heavily represented locally than 

statewide.

Table 3.10-5 Ethnic Minority Populations in the Region of Impact

Ethnic Identity Tuolumne

County

Mariposa

County California

White alone, percent, 2013 (a) 91.1% 90.2% 73.5%

Black or African American alone, percent, 2013 (a) 2.1% 1.1% 6.6%

American Indian and Alaska Native alone, percent, 2013 (a) 2.2% 3.3% 1.7%

Asian alone, percent, 2013 (a) 1.3% 1.4% 14.1%

Native Hawaiian and Other Pacific Islander alone, percent, 2013 (a) 0.2% 0.2% 0.5%

Two or More Races, percent, 2013 3.2% 3.8% 3.7%

Hispanic or Latino, percent, 2013 (b) 11.2% 10.0% 38.4%

White alone, not Hispanic or Latino, percent, 2013 81.6% 81.8% 39.0%

(a) Includes persons reporting only one race.

(b) Hispanics may be of any race, so also are included in applicable race categories. Source: U.S. Census Bureau

Environmental justice concerns can also focus on low-income populations. Similarly, age 

discrimination can be an issue for the Civil Rights Act. Table 3.10-6 presents the key age and income 

characteristics. The two-county region has fewer families with young children than the state average, 

and has dramatically more people of retirement age than the state average. Incomes by all measures 

are lower in Tuolumne and Mariposa Counties than for similar measures statewide. In spite of that, 

proportionately fewer people are living below the poverty line in the more populous Tuolumne 

County than the statewide average. The poverty percentage in Mariposa County, however, has 

recently exceeded that of the state average.

Table 3.10-6 Age, Income and Poverty Characteristics in the Region of Impact

Key Age and Income Characteristics Tuolumne

County

Mariposa

County California

Population, 2014 estimate 53,831 17,682 38,802,500

Persons under 5 years, percent, 2013 4.1% 4.2% 6.5%

Persons under 18 years, percent, 2013 16.9% 16.9% 23.9%

Persons 65 years and over, percent, 2013 22.8% 23.7% 12.5%

Per capita money income in past 12 months (2013 dollars), 2009-2013 $25,943 $26,988 $29,527

Median household income, 2009-2013 $48,426 $49,820 $61,094

Persons below poverty level, percent, 2009-2013 14.5% 16.1% 15.9%

Source: US Census Bureau

INDUSTRIAL PROFILE OF THE REGIONAL ECONOMY

Table 3.10-7 (Tuolumne County) and Table 3.10-8 (Mariposa County) present the historical 

perspective, and the most recent available profile, of the structure of the regional economy. The 

industry sector for “Mining and Logging” is much larger in Tuolumne County, and almost nonexistent in Mariposa County. The dramatic decline in employment in the Mining and Logging sector 

from 1990 through 2010 can also be seen in Tuolumne. In recent years, however, it appears the 

industry has stabilized. Employment in sawmills is included in the “Manufacturing” sector of the 

economy. 

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It does not appear from these tables that there are large pools of labor in either county that are 

dedicated to the type of treatments proposed to be performed on forest lands. A search of data 

collected by the U.S. Census Bureau for their data series County Business Patterns reveals that in the 

entire state of California, there are only 80 business providing “Support activities for forestry” 

(NAICS Code 115310), and in the most recent count had only approximately 500 people employed in 

those activities. In contrast, in spite of having a much smaller population and economy, the state of 

Oregon has an industrial cluster of over 200 such contractor businesses, with closer to 3,000 forest 

labor employees. This corroborates anecdotal evidence that many of the experienced contractors 

available to conduct forest work in Tuolumne and Mariposa counties are actually based in Southern 

Oregon. 

Table 3.10-7 Tuolumne County Industry Employment and Labor Force by Annual Average

Industry Title 1990 2000 2010 2011 2012 2013 2014

Civilian Labor Force 19,870 22,910 22,600 22,720 22,360 21,680 21,640

Civilian Employment 18,530 21,560 19,160 19,430 19,450 19,330 19,750

Civilian Unemployment 1,340 1,350 3,440 3,280 2,900 2,350 1,890

Civilian Unemployment Rate 6.7% 5.9% 15.2% 14.5% 13.0% 10.8% 8.7%

Total, All Industries 14,200 15,990 15,940 16,200 16,240 16,350 16,840

Total Farm 90 180 60 60 50 50 60

Total Nonfarm 14,120 15,800 15,880 16,140 16,190 16,300 16,780

Total Private 10,210 11,270 10,570 10,970 10,960 11,070 11,440

Goods Producing 2,320 2,250 1,340 1,490 1,450 1,460 1,470

Mining and Logging 400 200 130 160 110 120 130

Construction 1,080 920 540 510 510 490 510

Manufacturing 850 1,130 680 830 830 850 830

Durable Goods 730 890 490 630 660 680 670

Nondurable Goods 110 240 190 200 170 170 160

Service Providing 11,800 13,550 14,540 14,650 14,730 14,830 15,320

Private Service Providing 7,890 9,010 9,220 9,480 9,500 9,610 9,980

Trade, Transportation and Utilities 2,380 2,840 2,330 2,420 2,480 2,510 2,670

Wholesale Trade 190 150 190 120 140 140 140

Retail Trade 2,020 2,490 1,970 2,110 2,140 2,160 2,300

Transportation, Warehousing and Utilities 170 200 180 190 210 220 230

Information 200 230 240 210 210 210 230

Financial Activities 790 550 520 510 520 550 560

Professional & Business Services 880 890 930 930 930 920 910

Educational & Health Services 1,130 1,740 2,780 2,930 2,910 2,820 2,910

Leisure & Hospitality 1,960 2,130 2,040 2,060 1,980 2,130 2,210

Other Services 550 630 380 430 470 480 500

Government 3,910 4,540 5,310 5,170 5,230 5,220 5,340

Federal Government 560 370 440 420 480 480 520

State and Local Government 3,350 4,170 4,870 4,750 4,750 4,740 4,820

State Government 1,160 1,110 1,260 1,190 1,130 1,080 1,140

Local Government 2,190 3,060 3,610 3,560 3,630 3,660 3,680

Source: California Employment Development Department, Labor Market Information Division

The relative health of the regional economy can also be inferred from comparisons with the state 

average for unemployment rate. Using the same data sources and methods as shown in Table 3.10-7 

and Table 3.10-8, the State of California had an unemployment rate of 7.5% last year in 2014. With 

2014 unemployment rates of 8.7% and 8.8% respectively, somewhat more distress currently exists in 

the economies of both counties according to the most recent data available. Since the turn of the 

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century in 2000, both counties have consistently experienced somewhat higher unemployment rates 

than the average for the state as a whole.

Table 3.10-8 Mariposa County Industry Employment and Labor Force by Annual Average

Industry Title 1990 2000 2010 2011 2012 2013 2014

Civilian Labor Force 6,780 7,980 8,740 8,690 8,410 8,200 8,130

Civilian Employment 6,390 7,490 7,610 7,550 7,390 7,330 7,410

Civilian Unemployment 380 490 1,130 1,140 1,030 860 710

Civilian Unemployment Rate 5.7% 6.2% 12.9% 13.1% 12.2% 10.5% 8.8%

Total, All Industries 4,790 4,930 5,430 5,390 5,250 5,280 5,370

Total Farm 30 10 20 20 20 20 20

Total Nonfarm 4,760 4,920 5,420 5,380 5,230 5,260 5,350

Total Private 3,330 3,190 3,230 3,230 3,180 3,310 3,410

Goods Producing 430 300 240 240 250 250 280

Private Service Providing 2,910 2,890 2,990 2,990 2,930 3,050 3,130

Mining and Logging 10 20 10 10 10 20 20

Construction 250 160 110 110 120 130 150

Manufacturing 160 120 120 120 120 100 110

Service Providing 4,340 4,620 5,180 5,130 4,980 5,010 5,080

Trade, Transportation and Utilities 370 340 330 330 330 350 400

Wholesale Trade 20 10 10 10 20 20 20

Retail Trade 340 320 270 280 270 290 330

Transportation, Warehousing and Utilities 10 10 50 40 40 40 40

Professional and Business Services 100 250 170 170 160 140 120

Educational and Health Services 230 190 250 260 280 330 380

Leisure and Hospitality 1,920 1,930 2,130 2,080 1,990 2,010 1,990

Private Service Providing - Residual 290 180 120 140 170 220 240

Government 1,430 1,730 2,190 2,140 2,060 1,960 1,940

Federal Government 570 620 850 830 800 730 710

State and Local Government 860 1,110 1,340 1,320 1,260 1,230 1,240

State Government 150 170 180 170 160 160 190

Local Government 710 940 1,160 1,150 1,090 1,070 1,050

Source: California Employment Development Department, Labor Market Information Division

RESOURCE BASED INDUSTRIES AND LIFESTYLES IN THE REGION OF IMPACT

The lumber industry has historically been one of the main resource based sources of employment in 

Tuolumne and Mariposa Counties, and has contributed to the rural lifestyles available there. It has 

been in a long-term decline in recent decades, however. California’s timber harvest peaked in 1955 at 

6 billion board feet. The trend in total industry volume statewide has been down ever since, although 

it was still almost 5 billion board feet in the late 1980s, just 25 years ago. The number of sawmills in 

the state was over 100 at that time, but has declined dramatically to 25 with a smattering of other 

wood product plants that utilize a small percentage of logs from the forest. This has reduced the 

number of mills within the local region around the Rim Fire burn area as well. On the other hand, the 

reduction in milling capacity in California has not declined as rapidly as the number of mills, because

it has been the smaller, less efficient mills that have ceased operations. Even so, the bottleneck in the 

industrial process for turning standing trees in Tuolumne and Mariposa Counties into lumber remains 

due to the combined capacities of the sawmills within reach. Other steps in the industrial process are 

more scalable and flexible. For example, more logging and trucking contractors can be brought into 

the region from further away if needed. 

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A more recent resource based economic activity is the innovation of the biomass power generation 

industry. Conceived as a more environmentally sensitive way to reduce unwanted fuel loads in the 

forests, biomass is burned within contained plants and used to generate electrical power. At this time, 

the biomass industry has a significant infrastructure of existing plants within 90 to 120 miles of the 

Rim Fire burn area. Future power generation, and the future health of the biomass industry, relies in 

part on the continued supply of fuel from the forest. From the perspective of reduction of excess fuels 

from the forest, there are also clearly ecosystem value benefits to be gained by hauling and burning 

biomass in power plants that can contain a majority of the particulates and greenhouse gases, rather 

than burning the material in open piles on site. 

Ranching and livestock grazing has also been a traditional component in the local economy, and has 

contributed to the rural culture and lifestyle of Tuolumne and Mariposa counties. 

Native American people have gathered plant materials and visited specific areas within the burn zone. 

Their use of the area may have been affected by the impacts of the Rim Fire on the resources.

RECREATION/TOURISM INDUSTRY IN THE REGION OF IMPACT

The portion of the Stanislaus National Forest affected by the Rim Fire, has a long history of 

recreational use. One of the social and cultural attractions for living in Tuolumne and Mariposa

Counties has been the presence of recreational opportunities on the National Forest close to home. 

The Rim Fire area has also historically been used extensively by non-locals. One of the reasons for 

this is that Highway 120, passing through the burn area, is one of the major gateways to Yosemite 

National Park, which has generated recreation related tourism and economic impacts in multiple 

ways. Some people have spent a portion of their money in the area as they passed through to their 

primary destination in Yosemite. Others were not able to secure overnight accommodations in the 

park, and instead stayed in other accommodations within the burn area, such as camping on the 

National Forest, and made day trips into Yosemite. Yet others found that Tuolumne river rafting (a 

Class 5 experience) or other recreational offerings in the burn area were sufficiently attractive to 

warrant extending their visit to Yosemite by one or more days in the Stanislaus. The Stanislaus has 

also been the primary destination for many non-locals who were motivated by the recreational 

activities to be had there, without visiting Yosemite at all during the same trip.

Examples of the activities historically available within the Rim Fire burn area that have drawn both 

locals and non-locals, in roughly descending order of participation in each activity include: 

 Viewing natural features 

 Hiking / walking

 Viewing wildlife

 Picnicking

 Driving for pleasure

 Fishing

 Developed camping 

 Motorized trail activity

 OHV use

 Hunting 

 River rafting (non-motorized water sports) 

 Resort use 

 Primitive camping

The environment within the burn area has changed dramatically since the fire. Recreation patterns 

have been affected. For some, the aftermath of the Rim Fire and the flora and fauna that are emerging 

may be a new draw and increase their interest in visiting the area. For example, a new attraction being 

marketed in the Bay Area is the 42-mile driving tour of the Rim Fire area, complete with 

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downloadable map and 11 audio files. For many other recreationists, however, the loss of their 

favorite spot in the forest and the changes to their favored recreational use may have diminished their 

incentive to visit.

The Rim Fire also affected a variety of summer camps, private resorts, and other recreational facilities 

operated by other public agencies, private non-profit groups, and private for-profit entities including:

 City of Berkeley Tuolumne Camp

 San Francisco Camp Mather

 The City of San Jose Camp

 Camp Tawonga 

 Evergreen Lodge

 Other facilities

A majority of the Berkeley-Tuolumne Camp was destroyed by the Rim Fire and is currently not 

available for use pending permits and reconstruction. To the extent the visitor accommodating 

capacity or recreational attractiveness of the area has been diminished, there has been a proportionate 

decrease in the size of the visitor-serving economy in Tuolumne County, and there have also been 

social and cultural impacts on the groups that have traditionally visited the area.

FOREST SERVICE FISCAL ENVIRONMENT

Economic efficiency is important for all federal expenditures of taxpayer dollars, but recent trends in 

the costs of fighting wildfires have focused federal attention on the allocation of fiscal resources 

within the Department of Agriculture, and within the Forest Service specifically. As highlighted in a 

USDA report “The Rising Cost of Fire Operations: Effects on the Forest Service’s Non-Fire Work” 

issued on August 5, 2015, for the first time in its history the Forest Service is spending more than half 

of its $5 billion annual budget battling wildfires, including preparedness, suppression, FLAME, and 

related programs. As stated in the report:

“In 1995, fire made up 16% of the Forest Service’s annual appropriated budget—this year, for the 

first time, more than 50% of the Forest Service’s annual budget will be dedicated to wildfire. 

Along with this shift in resources, there has also been a corresponding shift in staff, with a 39% 

reduction in all non-fire personnel. Left unchecked, the share of the budget devoted to fire in 2025 

could exceed 67%, equating to reductions of nearly $700 million from non-fire programs 

compared to today’s funding levels. That means that in just 10 years, two out of every three 

dollars the Forest Service gets from Congress as part of its appropriated budget will be spent on 

fire programs.”

“As more and more of the agency’s resources are spent each year to provide the firefighters, 

aircraft, and other assets necessary to protect lives, property, and natural resources from 

catastrophic wildfires, fewer and fewer funds and resources are available to support other agency 

work—including the very programs and restoration projects that reduce the fire threat.”

Environmental Consequences

Alternative 1 (Proposed Action)

DIRECT AND INDIRECT EFFECTS

The proposed action addresses all the purposes and needs and is composed of the full set of activity 

groups, the largest of which is focused on reforestation, but also includes deer habitat enhancement, 

thinning existing plantations for ICO structure and fuels reduction, and noxious weed eradication. 

Some of the specific treatments are capital intensive such as use of feller bunchers for cutting dead 

and live trees and heavy equipment tractors for deep tilling, and others are labor intensive such as 

hand cutting and piling of fuels and hand spraying of herbicides. 

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Economic Efficiency

The estimated costs per acre of each type of treatment (presented above in Table 3.10-1) have been 

multiplied by the number of acres subject to each treatment as they are scheduled to occur over the 

coming 10 to 15 years, in accordance with the schedule tables presented in Appendix F for each of the 

action alternatives. For each of the first 14 years under Alternative 1, the Forest Service would incur 

the majority of its costs to hire contractors to perform treatments and have additional in-house agency 

costs to conduct burns, perform survival exams, and other monitoring of the contractors. The resulting 

total costs of treatment performed by contractors and by Forest Service staff by year are presented in 

the second and third columns of Table 3.10-9. The total cost to the government to be incurred each 

year is presented in the fourth column. 

To accurately compare costs that occur over a number of future years with benefits derived from the 

proposed action, however, the PNC must be calculated. Using the discount rates specified for use 

during 2015 for federal decisions, the PNC for Alternative 1 is calculated in the last column of Table 

3.10-10. The total PNC of performing scheduled treatments under Alternative 1 over the next decade 

and a half is approximately $83 million. 

Table 3.10-9 Alternative 1: Present Net Cost of Treatments

Year Contractor Costs 

(2015 $1,000s)

Agency Costs 

(2015 $1,000s)

Total 

Costs

Discount 

Rate1 Discount Factor2 Present Net Cost (PNC)

1 $732 $59 $790 0.00% 100.00% $790

2 $3,916 $2,153 $6,069 0.05% 99.90% $6,063

3 $8,595 $2,071 $10,666 0.10% 99.70% $10,634

4 $9,200 $3,508 $12,708 0.25% 99.01% $12,582

5 $9,874 $2,648 $12,523 0.40% 98.02% $12,275

6 $9,758 $1,193 $10,951 0.55% 96.76% $10,596

7 $8,643 $1,246 $9,889 0.70% 95.23% $9,417

8 $6,421 $1,246 $7,666 0.77% 94.05% $7,210

9 $3,894 $677 $4,571 0.83% 92.83% $4,243

10 $3,508 $634 $4,141 0.90% 91.43% $3,786

11 $1,968 $437 $2,405 0.93% 90.32% $2,172

12 $2,127 $473 $2,600 0.96% 89.17% $2,318

13 $159 $35 $195 0.99% 87.98% $171

14 $696 $155 $850 1.02% 86.76% $738

Totals $69,489 $16,534 $86,024 $82,997

1 Discount rates for federal analyses are presented in Appendix C of OMB Circular A-94 for key years, and discount rates for intervening 

years are estimated through linear interpolation.

2 The Discount Factor is equal to 1/(1 + i)t where i is the interest rate and t is the number of years from the date of initiation for the 

program or policy until the given future year. Source: Land Economics Consultants analysis

The PNB from Alternative 1 that can be realized in dollars paid to the government is derived from the 

ultimate sale of forest products to private industry, either during thinning operations over the coming 

decade or from commercial timber sales once the desired sustainable forest conditions are achieved 

50 to 60 years from now. The volumes of timber likely to be produced by the treatment regimen, and 

the point in the future when such products might be available are estimated in Table 3.10-10. For 

purposes of developing a standard methodology for comparing alternatives, the future projections 

stop after the first round of commercial harvests, conducted in 50 to 60 years, but it should be noted 

that the mature stand of trees created by that point in time would continue to grow and add biomass, 

and that on a sustainable basis additional commercial timber harvests would occur far into the future, 

perhaps occurring next around year 100, and then again in year 150. The longer the time horizon, the 

more the PNB will grow due to the repeat entries to harvest larger and larger trees.

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Table 3.10-10 Alternative 1: Present Net Benefits Derived from Thinning or Harvesting Timber

Years Thin/Harvest

(acres)

Estimated Yield 

(board feet/acre)

Produced 

(MBF)

Value Sold 

(in $1,000s)

Discount 

Rate

Discount 

Factor

Present Net Benefit 

(PNB in $1,000s)

1 6 305 2 $0.2 0.00% 100.00% $0.2

2 33 305 10 $1 0.05% 99.90% $1

3 1,164 305 355 $36 0.10% 99.70% $35

4 2,561 305 781 $78 0.25% 99.01% $77

5 5,911 305 1,803 $180 0.40% 98.02% $177

6 4,136 305 1,261 $126 0.55% 96.76% $122

7 123 305 38 $4 0.70% 95.23% $4

50 10,786 4,998 53,907 $5,391 1.40% 49.90% $2,690

60 12,644 8,664 109,546 $10,955 1.40% 43.42% $4,757

Totals 37,365 15,796 590,223 $16,770 $7,863

Source: Land Economics Consultants analysis

The PNV is the single best statistic for quantifying the economic efficiency of the proposed action, 

including both the discounted benefits received in the future from the action and the discounted costs 

of treatments that produce the desired future forest conditions. For the alternatives calling for 

dramatic action on the part of the government to replant and manage the forest over the next decade 

or so, it should be expected that dollar costs would be larger than dollar benefits recouped by the 

federal government in selling forest products to private industry. This is because the desired forest 

conditions are designed to also generate many other benefits that are not captured in the dollar 

exchanges between the government and the private sector economy, such as enhanced habitat quality, 

carbon sequestration, reduced risk of wildfires, recreational opportunities, and other ecosystem 

values.

Given the PNB of $7.9 million estimated above, less the PNC of negative $83.0 million, the PNV for 

Alternative 1 is negative $75.1 million. The larger the PNV, the more beneficial it is to the federal 

goal of economic efficiency. In the case of expensive action alternatives, the larger PNV is the one 

that is “less negative.”

Economic Impact

The funds the federal government would pay private contractors to conduct forest treatments within 

the Rim Fire burn area would temporarily expand the two-county regional economy. Given that there 

are few contractor businesses within Tuolumne or Mariposa counties set up to perform the required 

treatment activities, it is likely that many of the contracts would be awarded to firms from outside the 

area. While some may be from other California counties, others would likely come out of the 

industrial cluster resident in Oregon. More of the money paid to contractors would “leak out” of the 

regional economy immediately if they are not based locally, but nevertheless some would remain in 

the two-county region, and direct jobs within the counties would be created for the duration of the 

contract work. 

In addition, contractors from outside the area would need to rent motel rooms or otherwise house their 

workforce locally while the work is being performed, employees would buy meals and other sundry 

retail goods, and contractor firms would buy gas, oil, parts, supplies, and other inputs from local 

businesses. All of this activity would create business volume, personal income, gross regional 

product, and local tax revenue within Tuolumne and Mariposa Counties. 

The best single indicator of this general economic expansion for comparing between alternatives is 

job creation, which is highly correlated with all of the other measures of economic health. In Table 

3.10-11 the consistent methodology is applied, where half the contract cost is assumed to go to wages 

for workers, and wages are projected to average $44,000 per year to equal full-time-equivalent jobs. 

Half again as many indirect and induced jobs are then created locally through multiplier effects. 

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Alternative 1 is estimated to support 200 to 300 jobs per year in the two-county area in the coming 

half dozen or so years, tapering off a decade from now, but totaling over $2,350 throughout the 

treatment period. Job creation is a beneficial impact on the two-county regional economy.

Table 3.10-11 Alternative 1: Jobs Created in Tuolumne and Mariposa Counties

Year Contractor Costs 

(2015 $1,000s)

Direct Jobs 

(FTEs) 1

Indirect and Induced 

Jobs (FTEs) 2 Total Jobs Supported (FTEs)

1 $732 17 8 25

2 $3,916 89 44 133

3 $8,595 195 98 293

4 $9,200 209 105 314

5 $9,874 224 112 337

6 $9,758 222 111 333

7 $8,643 196 98 295

8 $6,421 146 73 219

9 $3,894 88 44 133

10 $3,508 80 40 120

11 $1,968 45 22 67

12 $2,127 48 24 73

13 $159 4 2 5

14 $696 16 8 24

Totals $69,489 1,579 790 2,369

1 Assuming 50% of contractor costs go to labor, and mean annual wages are $44,000. 2 Given an employment multiplier of 1.5, another half an FTE job is created in the 2-county region for every direct FTE job created. 

Source: Land Economics Consultants analysis

The costs of Agency activities (e.g., conducting prescribed burns and surveying forests) would 

support jobs within the Forest Service, but the conservative assumption is made here that none of 

these are net new jobs, but rather reflect Agency priorities and the allocation of time for people that 

would be on staff regardless. In an ideal outcome, federal appropriations or other monies such as 

grants and sponsorships would be forthcoming allowing the STF to add 10 or more new people 

dedicated to Rim Reforestation activities.

Social Analysis

The proposed action (Alternative 1) would restore a mixed conifer forest far more rapidly than taking 

no action (Alternative 2). Forest resource based economic activities and the rural lifestyles that are 

supported by them would be enhanced by Alternative 1. The ranching lifestyle for families, that have 

grazing allotments within the burn area, would be enhanced somewhat by proposed site preparation

and tree thinning treatments that impede range stock movement, and by reducing noxious weeds. The 

treatments and the more rapid return of a mixed conifer forest would help maintain the industrial 

capacity of the forest products and biomass energy industries and the rural lifestyles they support in 

the two-county area.

Recreation within the Rim Fire area, although perhaps in differing forms, would likely take place with 

or without the Forest Service taking action. To the extent that return of a mixed conifer forest would 

have greater appeal to a wider range of traditional recreational pursuits and draw more tourists back 

to the forest, residents of the region who own businesses or work in the tourism industry would see 

some restoration of lifestyles that have been diminished by the reduced volumes of visitors resulting 

from the Rim Fire.

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CUMULATIVE EFFECTS

Past actions in the region of impact, and throughout California, have led to a reduction in the size of 

the forest products industry with a specific capacity bottleneck in number of sawmills available to 

process logs into lumber. The mills that remain today tend to be the larger and more efficient ones. 

Even so, the capacity of the existing private industry infrastructure to mill lumber is far below 

historical highs.

The Rim Fire burned over a quarter million acres including private forest lands and forest inside 

Yosemite National Park. Recent actions contributing to cumulative effects included the emergency 

salvage logging of over 18,000 acres of private timber land, and over 28 miles of roadside hazard tree 

removal in Yosemite (over 800 acres). In addition, three National Forest timber sales were in progress 

on over 2,000 acres when the fire broke out, and have been continued, although at reduced scales in 

some instances. With a surge in available supply and limits to processing capacity, the prices private 

industry has been prepared to pay for salvaged or green trees have dropped to very low levels. Forest 

Service sales of timber salvaged from the Rim Fire area generated a fraction of the revenue seen after 

other large scale fires on the Forest from 1987 through 2007. 

Ongoing activities include continued treatments to reduce fuels on over 25,000 acres in the Rim 

Recovery area and several thousand acres of green tree thinning in other project areas. Foreseeable 

future actions include over 4,000 acres of green tree thinning in the Twomile Ecological Restoration 

area, the Reynolds Creek Stewardship area and other project areas.

All of these contribute demand on private industry infrastructure available to conduct treatments in 

the forests, thin green trees, haul raw materials, and produce lumber, energy and other forest products. 

There are several cumulative economic effects that would likely be produced by this situation: 

 In the short-term, capacity is limited. Given the recent surge in raw materials available from 

salvage logging combined with new green tree thinning and fuels reductions, downward pressure 

will continue to be maintained on the prices for raw materials. This can be seen as a beneficial 

economic impact by buyers, such as sawmills and power plants, and an adverse economic impact 

by sellers, such as the Forest Service.

 With continued softness in demand and low prices paid, it is possible that the Forest Service 

would not be able to sell as many green trees as they are hoping for to offset costs of thinning in 

some units. Although the overall impact of conducting the treatments proposed in Alternative 1 

would be beneficial to the local economy regardless of the source of funding to pay for 

treatments, if the Forest Service is unable to offset some of the costs of thinning through sale of 

green trees it would represent higher cost to taxpayers and lower economic efficiency. 

 Another possible outcome is that thinning would be deferred until the demand and prices for 

green trees have recovered sufficiently to fund the activities. While that may make economic

sense, in the interim the forest will be more vulnerable to fire and infestation. 

 In the long run, implementing Alternative 1 in conjunction with other present and foreseeable 

actions would serve as a stimulus to expand the capacity of the industry, potentially including 

forming new businesses to conduct labor intensive treatments, hiring of work crews, and 

investing in new equipment. Additional hiring and business formation would be seen as a 

beneficial impact on the local economy. For significant industry expansion to take place, 

however, the perception would have to be that there is some assurance that sufficient funding will 

be available in future years to continue with the scheduled treatments and programs.

Reasonably foreseeable future actions include replanting in campgrounds, reconstruction of the City 

of Berkeley Tuolumne Camp, improvements to the San Jose Camp, enhancement of trails networks 

for both OHV and non-motorized uses, and other environmental improvements that enhance the 

attractiveness and capacity of the area for recreation. In combination with foreseeable actions, 

Alternative 1 would further expand the capacity of the tourism industry based along Highway 120, 

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and incomes and jobs in visitor serving businesses in Tuolumne County would increase as a result. 

Because the Highway 120 corridor also serves as one of the major gateways to Yosemite National 

Park, Alternative 1 could also expand visitation to Yosemite somewhat, for example by encouraging 

people to stay overnight in campsites in the Rim Fire area and become day visitors to Yosemite 

Valley. From a cumulative perspective, this could have a beneficial impact on direct tourism 

employment gains in Tuolumne and Mariposa Counties, as well as additional beneficial indirect 

economic impacts through multiplier mechanisms.

Continuation of the 14 existing grazing allotments is included in the ongoing and foreseeable future 

actions, and the rural ranching lifestyle it supports should be maintained among the cumulative 

effects.

Economic efficiency will continue to be a high priority for the Forest Service. A USDA August 4, 

2015 report states: 

“Climate change has led to fire seasons that are now on average 78 days longer than in 1970. The 

U.S. burns twice as many acres as three decades ago and Forest Service scientists believe the 

acreage burned may double again by mid-century. Increasing development in fire-prone areas also 

puts more stress on the Forest Service’s suppression efforts.”

“While the Forest Service and its firefighting partners are able to suppress or manage 98% of fires, 

catastrophic mega-fires burn through the agencies resources: 1% to 2% of fires consume 30% or 

more of annual costs. Last year, the Forest Service’s 10 largest fires cost more than $320 million 

dollars. The cost of fire suppression is predicted to increase to nearly $1.8 billion by 2025. This 

trend of rising fire suppression costs is predicted to continue as long as the 10-year average serves 

as the funding model and presents a significant threat to the viability of all other services that 

support our national forests.”

“This unsustainable problem is made worse because in many years, fighting fires costs more than 

was planned for that year, requiring mid-season transfers of additional dollars from already 

depleted accounts to pay for firefighting: a practice referred to as ‘fire transfer.’ In some cases, the 

agency is forced to divert money away from the same forest restoration projects that prevent or 

lessen the impacts of future wildfire. While Congress typically provides supplemental resources to 

replenish the Forest Service budget after fire transfers, transfers remain extremely problematic as 

they disrupt seasonal work, frustrate partners, and delay vital work.”

The increase in employment opportunities, both from conducting treatments to forest units and from 

restoration of some of the tourism industry, would place upward pressure on populations in Tuolumne 

and Mariposa Counties. Given that some unemployment and underemployment already exists in the 

area, and that some of the jobs may be taken by seasonal or temporary workers, the growth in 

permanent population of the two-county area due to any of the action alternatives is likely to be minor 

and indistinguishable from organic growth. 

Alternative 2 (No Action)

DIRECT AND INDIRECT EFFECTS

Under Alternative 2 no treatments would be performed within the Rim Fire area beyond management 

as guided by current decisions and plans. The return of a mixed conifer forest would be delayed the 

longest under Alternative 2. Only natural regeneration would return forests to the landscape, taking 

hundreds of years to reach maturity in some areas, especially where mature green conifers are nonexistent. Fuels reduction treatments beyond those planned under other analysis would not be 

performed, no thinning would occur in older plantations to remove standing biomass and saw logs, 

and noxious weeds would persist and spread throughout the area. 

Economic Efficiency

No action means no revenue would be generated to the government from sale of trees removed during 

thinning operations within existing plantations over the next decade. With natural regeneration alone 

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it would also take longer to produce merchantable timber in the areas proposed for planting, and 

would likely be at lower volumes per acre. The PNB of selling timber under the no action alternative 

is estimated in Table 3.10-12. The same format as Table 3.10-10 for Alternative 1 is used for 

comparability, and it can be seen that no government income occurs in years 1 through 7, but there 

still would be some revenue from timber sales occurring 50 or 60 years from now, estimated to be 

worth approximately $1.9 million when expressed as PNB. 

Table 3.10-12 Alternative 2: Present Net Benefits Derived from Thinning or Harvesting Timber

Years Thin/Harvest

(acres)

Estimated Yield 

(board feet/acre)

Produced 

(MBF)

Value Sold 

(in $1,000s)

Discount 

Rate

Discount 

Factor

Present Net Benefit 

(PNB in $1,000s)

1 0 0 0 $0 0.00% 100.00% $0

2 0 0 0 $0 0.05% 99.90% $0

3 0 0 0 $0 0.10% 99.70% $0

4 0 0 0 $0 0.25% 99.01% $0

5 0 0 0 $0 0.40% 98.02% $0

6 0 0 0 $0 0.55% 96.76% $0

7 0 0 0 $0 0.70% 95.23% $0

50 1,504 4,451 6,693 $669 1.40% 49.90% $334

60 6,062 5,840 35,405 $3,540 1.40% 43.42% $1,537

Totals 7,566 10,291 77,862 $4,210 $1,871

Source: Land Economics Consultants analysis

Although the Forest Service would not have to incur the direct costs of having contractors and agency 

staff perform treatments under Alternative 2, the Forest Service would also have a higher cost of 

fighting future fires in the Rim Fire area. None of the standing biomass and dead woody fuels would 

be removed from the thinning units leaving extra fuel in these stands, hindering firefighting and 

future fire control. With unmanaged fuel loads, the costs of suppressing a fire in such conditions 

would likely be higher than fighting a wildfire in a managed forest. The PNC of Alternative 2 could 

be lower than for the action alternatives with luck during fire seasons, but could also be much higher 

due to unpredictable fires. 

Adhering strictly to the standard methodology adopted for comparing the economic efficiency of each 

alternative, the positive PNV of Alternative 2 is $1.9 million; i.e., a PNB of $1.9 million with a PNC 

reflecting zero costs of prescribed treatments. This could be seen as a beneficial effect for the federal 

government, although it ignores any differences in values that are not captured in dollar terms, such 

as enhanced habitat quality, carbon sequestration, and other ecosystem values.

It is possible that the PNC for Alternative 2 could be significantly negative due to the higher costs of 

fighting a wild fire in areas with large amount of standing dead trees. The cost of fighting the last fire 

in the Rim Fire burn area was estimated to be over $125 million. This would be an adverse effect.

Economic Impact

Under Alternative 2, no contracts would be forthcoming for private firms to conduct treatment 

actions. No direct new job support would be created, and no indirect and induced jobs would be 

created in the two-county area. Compared with action alternatives, this would be perceived as an 

adverse economic impact.

Social Analysis

For some people a forest that develops through natural regeneration may be a more desirable option 

because it costs less, minimizes human interference, does not require herbicides, benefits some 

species of wildlife, or enhances recreational wildlife watching for the specific species benefited. The 

difficulty would be moving through or even seeing through heavy brush areas that may be 

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impenetrable due to the density of the returning vegetation (e.g. the 1987 Larson Fire on the 

Groveland Ranger District). In addition, natural regeneration could take centuries to reforest parts of 

the Rim Fire where few live overstory conifers survive post fire. For others, the naturally regenerating 

recreational environment may be less attractive than a more rapidly returning mixed conifer forest. 

From the perspective of visitors and residents who were used to the way the forest looked and 

functioned before, the natural regeneration environment will certainly be different. Historical 

recreational patterns and traditional resident social life have already been disrupted by the Rim Fire. 

Depending on one’s recreational preferences and expectations for the forest, Alternative 2 could be 

seen as either beneficial or adverse.

CUMULATIVE EFFECTS

Present and reasonably foreseeable actions include treatments in other parts of the forest and on 

private lands in Tuolumne and Mariposa counties that are similar to what are proposed under action 

alternatives for the Rim Fire area. Without the Rim Reforestation treatments adding additional work, 

the forestry products industry will still continue to exist in Tuolumne and Mariposa counties, but it 

would be smaller. There would be fewer direct jobs, and fewer indirect and induced jobs in the 

region, which would constitute an adverse economic effect.

In the longer run, by producing lower volumes of merchantable timber within the Rim Fire zone and 

delaying maturity until further into the future, there could be additional pressure to close down 

sawmills, biomass energy plants, or other components of the forest products industry infrastructure 

within Tuolumne and Mariposa counties, which would also be seen as a long-term adverse effect on 

the regional economy. 

With no related increase in employment opportunities under the no action alternative, there would be 

no additional pressure on population growth. Tuolumne and Mariposa Counties are likely to continue 

to grow slowly as they have recently with additional retirees moving in and with other organic growth 

as households form and people find jobs in other local industries.

Alternative 3

DIRECT AND INDIRECT EFFECTS

Alternative 3 is an attempt to achieve the same desired forest conditions, but without the use of 

herbicides. From an economic and socio-cultural perspective, this requires much more labor intensive 

treatments than with the other action alternatives. For example, it takes more time to hand grub

unwanted undergrowth around planted tree seedlings than it takes to spray the area with herbicides. 

Furthermore, it takes multiple repeat grubbings to achieve the same results as a single herbicide

application and is less effective at controlling brush even with two treatments a year. As a result, 

more person-hours of time would be expended in Alternative 3 and costs of hiring contractors to 

perform these activities would be substantially higher that with other action alternatives.

Economic Efficiency

The same methodology was used to analyze economic efficiency as Alternative 1.

Using the appropriate discount rates, the PNC for Alternative 3 is calculated in the last column of 

Table 3.10-13. The total PNC of performing scheduled treatments under Alternative 3 over the next 

decade and a half is approximately $232 million. 

As with Alternative 1, the PNB from Alternative 3 that can be realized in dollars paid to the 

government is derived from the ultimate sale of forest products to private industry, either during 

thinning operations over the coming decade or from commercial timber sales once the desired 

sustainable forest conditions are achieved 50 to 60 years from now.

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Table 3.10-13 Alternative 3: Present Net Cost of Treatments

Year Contractor Costs 

(2015 $1,000s)

Agency Costs 

(2015 $1,000s)

Total 

Costs

Discount 

Rate1 Discount Factor 2 Present Net Cost (PNC)

1 $959 $59 $1,018 0.00% 100.00% $1,018

2 $10,597 $2,041 $12,638 0.05% 99.90% $12,626

3 $19,293 $1,503 $20,795 0.10% 99.70% $20,733

4 $25,044 $3,311 $28,355 0.25% 99.01% $28,073

5 $31,856 $2,347 $34,203 0.40% 98.02% $33,527

6 $37,928 $1,236 $39,164 0.55% 96.76% $37,896

7 $30,533 $793 $31,325 0.70% 95.23% $29,832

8 $22,654 $926 $23,579 0.77% 94.05% $22,176

9 $19,347 $574 $19,921 0.83% 92.83% $18,492

10 $14,693 $440 $15,132 0.90% 91.43% $13,836

11 $8,774 $479 $9,253 0.93% 90.32% $8,357

12 $3,589 $70 $3,659 0.96% 89.17% $3,262

13 $2,474 $155 $2,628 0.99% 87.98% $2,312

14 $0 $0 $0 1.02% 86.76% $0

Totals $227,739 $13,930 $241,670 $232,140

1 Discount rates for federal analyses are presented in Appendix C of OMB Circular A-94 for key years, and discount rates for intervening 

years are estimated through linear interpolation.

2 The Discount Factor is equal to 1/(1 + i)t where i is the interest rate and t is the number of years from the date of initiation for the 

program or policy until the given future year. Source: Land Economics Consultants analysis

As in Alternative 1, the PNV is the single best statistic for quantifying the economic efficiency of the 

proposed action. Given the PNB of $2.5 million estimated above, less the PNC of negative $232.1 

million, the PNV for Alternative 3 is negative $229.6 million. The larger the PNV, the more 

beneficial it is to the federal goal of economic efficiency. In the case of expensive action alternatives, 

the larger PNV would be the one that is “less negative,” and as discussed below in the comparison, 

Alternative 3 is the most negative of all alternatives, and by an order of magnitude. 

Table 3.10-14 Alternative 3: Present Net Benefits Derived from Thinning or Harvesting Timber

Years Thin/Harvest

(acres)

Estimated Yield 

(board feet/acre)

Produced 

(MBF)

Value Sold 

(in $1,000s)

Discount 

Rate

Discount 

Factor

Present Net Benefit 

(PNB in $1,000s)

1 6 305 2 $0 0.00% 100.00% $0

2 33 305 10 $1 0.05% 99.90% $1

3 1,164 305 355 $36 0.10% 99.70% $35

4 2,561 305 781 $78 0.25% 99.01% $77

5 5,911 305 1,803 $180 0.40% 98.02% $177

6 4,136 305 1,261 $126 0.55% 96.76% $122

7 123 305 38 $4 0.70% 95.23% $4

50 0 0 0 $0 1.40% 49.90% $0

60 8,136 5,937 48,303 $4,830 1.40% 43.42% $2,097

Totals 22,070 8,072 178,149 $5,255 $2,514

Source: Land Economics Consultants analysis

Economic Impact

Similar to Alternative 1, but as Table 3.10-15 shows, far more jobs would be created because of the 

increased amount of manual labor needed to accomplish the hand grubbing portion of this 

Alternative. Alternative 3 is estimated to support over 1,000 full-time-equivalent (FTE) jobs per year 

in the two-county area during periods of peak activity, totaling over 7,700 throughout the treatment 

period. 

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Job creation is a beneficial impact on the two-county regional economy, but it could also come with 

some “growing pains.” Because the work is seasonal, 1,000 jobs expressed as full-time-equivalents 

could mean that substantially more people than that are required at any one time. Tuolumne and 

Mariposa Counties are relatively small, and housing and serving a couple thousand workers could 

impact motel room availability. The surge in occupancy rates would likely be seen as beneficial by 

motel owners and operators, but to the extent that housing temporary forest workers displaces people 

who would otherwise have been in the area for recreational/tourism purposes, it could adversely 

impact the owners and operators of attractions, tour operators, and other segments of the gateway 

community economies that serve tourists and not workers.

Table 3.10-15 Alternative 3: Jobs Created in Tuolumne and Mariposa Counties

Year Contractor Costs 

(2015 $1,000s)

Direct Jobs 

(FTEs)1

Indirect & Induced 

Jobs (FTEs)2 Total Jobs Supported (FTEs)

1 $959 22 11 33

2 $10,597 241 120 361

3 $19,293 438 219 658

4 $25,044 569 285 854

5 $31,856 724 362 1,086

6 $37,928 862 431 1,293

7 $30,533 694 347 1,041

8 $22,654 515 257 772

9 $19,347 440 220 660

10 $14,693 334 167 501

11 $8,774 199 100 299

12 $3,589 82 41 122

13 $2,474 56 28 84

14 $0 0 0 0

Totals $227,739 5,176 2,588 7,764

1 Assuming 50% of contractor costs go to labor, and mean annual wages are $44,000. 2 Given an employment multiplier of 1.5, another half an FTE job is created in the 2-county region for every direct FTE job created. 

Source: Land Economics Consultants analysis

The need for in-house Forest Service staff time would be roughly similar in Alternative 3 as for 

Alternative 1, and it would be preferable to have additional staff. 

Social Analysis

Same as Alternative 1 except that replacing herbicides with hand grubbing eliminates the need for 

grazing restrictions designed to keep livestock away from treated forage.

CUMULATIVE EFFECTS

Same as Alternative 1.

Alternative 4

DIRECT AND INDIRECT EFFECTS

In terms of human intervention, and its economic repercussions, Alternative 4 falls between the 

proposed action (Alternative 1) and no action (Alternative 2). Reforestation would occur on less than 

3,000 acres, and over 17,000 acres characterized as complex early seral forest would be allowed to 

develop unassisted except for the use of prescribed fire. In all, prescribed fire would be returned to 

15,932 acres over the first decade, with fire reintroduced to a similar acreage in the second decade 

and then repeated through time. To keep the indicators consistent across all alternatives, only the 

prescribed fire treatments over the coming 14 years are accounted for in the analyses below.

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Economic Efficiency

The same methodology was used to analyze economic efficiency as Alternative 1 Using the 

appropriate discount rates, the PNC for Alternative 4 is calculated in the last column of Table 3.10-

16. The total PNC of performing scheduled treatments under Alternative 4 over the next decade and a 

half is approximately $30 million.

Table 3.10-16 Alternative 4: Present Net Cost of Treatments

Year Contractor Costs 

(2015 $1,000s)

Agency Costs 

(2015 $1,000s)

Total 

Costs

Discount 

Rate1 Discount Factor2 Present Net 

Cost (PNC)

1 $155 $1,642 $1,796 0.00% 100.00% $1,796

2 $918 $1,593 $2,512 0.05% 99.90% $2,509

3 $2,217 $1,739 $3,956 0.10% 99.70% $3,944

4 $1,306 $1,743 $3,049 0.25% 99.01% $3,019

5 $918 $1,797 $2,716 0.40% 98.02% $2,662

6 $941 $1,802 $2,743 0.55% 96.76% $2,654

7 $918 $1,797 $2,716 0.70% 95.23% $2,586

8 $941 $1,802 $2,743 0.77% 94.05% $2,580

9 $0 $1,593 $1,593 0.83% 92.83% $1,479

10 $0 $1,593 $1,593 0.90% 91.43% $1,457

11 $0 $1,593 $1,593 0.93% 90.32% $1,439

12 $0 $1,593 $1,593 0.96% 89.17% $1,421

13 $0 $1,593 $1,593 0.99% 87.98% $1,402

14 $0 $1,593 $1,593 1.02% 86.76% $1,382

Totals $8,315 $23,475 $31,790 $30,330

1 Discount rates for federal analyses are presented in Appendix C of OMB Circular A-94 for key years, and discount rates for intervening 

years are estimated through linear interpolation.

2 The Discount Factor is equal to 1/(1 + i)t where i is the interest rate and t is the number of years from the date of initiation for the 

program or policy until the given future year. Source: Land Economics Consultants analysis

Table 3.10-17 shows the PNB for Alternative 4 and was calculated the same as Alternative 1.

Given the PNB of $2.3 million estimated above, less the negative PNC of $30.3 million, the PNV for 

Alternative 1 is negative $28.0 million. The larger the PNV, the more beneficial it is to the federal 

goal of economic efficiency. In the case of expensive action alternatives, the larger PNV is the one 

that is “less negative.” It is important to remember that only 20% of the area would be reforested 

under Alternative 4, leaving about 80% to come back naturally over decades and centuries. 

Table 3.10-17 Alternative 4: Present Net Benefits Derived from Thinning or Harvesting Timber

Years Thin/Harvest

(acres)

Estimated Yield 

(board feet/acre)

Produced 

(MBF)

Value Sold 

(in $1,000s)

Discount 

Rate

Discount 

Factor

Present Net Benefit 

(PNB in $1,000s)

1 6 305 2 $0 0.00% 100.00% $0

2 33 305 10 $1 0.05% 99.90% $1

3 1,164 305 355 $36 0.10% 99.70% $35

4 2,561 305 781 $78 0.25% 99.01% $77

5 5,911 305 1,803 $180 0.40% 98.02% $177

6 4,136 305 1,261 $126 0.55% 96.76% $122

7 123 305 38 $4 0.70% 95.23% $4

50 1,504 4,451 6,693 $669 1.40% 49.90% $334

60 6,062 5,840 35,405 $3,540 1.40% 43.42% $1,537

Totals 21,500 12,426 267,162 $4,635 $2,288

Source: Land Economics Consultants analysis

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Economic Impact

Although Alternative 4 calls for only minimal human intervention in the forest, the federal 

government would still pay private contractors to conduct some forest treatments, temporarily 

expanding the two-county regional economy. Direct jobs within the counties would be created for the 

duration of the contract work.

As under the other action alternatives, contractors from outside the area would need to rent living 

space, buy meals and other sundry retail goods, and purchase gas, oil, parts, supplies, and other inputs 

from local businesses. 

In Table 3.10-18, Alternative 4 is estimated to support a total of only about 280 jobs, amounting to a 

peak of roughly 75 FTE jobs in the most active year of treatments. Job creation is a beneficial impact 

on the two-county regional economy. 

Table 3.10-18 Alternative 4: Jobs Created in Tuolumne and Mariposa Counties

Year Contractor Costs 

(2015 $1,000s)

Direct Jobs 

(FTEs)1

Indirect & Induced 

Jobs (FTEs)2 Total Jobs Supported (FTEs)

1 $155 4 2 5

2 $918 21 10 31

3 $2,217 50 25 76

4 $1,306 30 15 45

5 $918 21 10 31

6 $941 21 11 32

7 $918 21 10 31

8 $941 21 11 32

9 $0 0 0 0

10 $0 0 0 0

11 $0 0 0 0

12 $0 0 0 0

13 $0 0 0 0

14 $0 0 0 0

Totals $8,315 189 94 283

1 Assuming 50% of contractor costs go to labor, and mean annual wages are $44,000. 2 Given an employment multiplier of 1.5, another half an FTE job is created in the 2-county region for every direct FTE job created. 

Source: Land Economics Consultants analysis

The costs of Agency activities (e.g., conducting prescribed burns and surveying forests for survival 

rates) will support jobs within the Forest Service, but the conservative assumption is made here that 

none of these are net new jobs, but rather reflect Agency priorities and the allocation of time for 

people that would be on staff regardless. Given the regimen of prescribed burns, it would be 

advantageous to have more staff to conduct this ongoing activity. 

Social Analysis

Same as Alternative 2.

CUMULATIVE EFFECTS

Same as Alternative 1. 

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Alternative 5

DIRECT AND INDIRECT EFFECTS

The prescribed treatments in Alternative 5 are very similar to those in Alternative 1, with the 

exception that the number and density of trees planted would be higher under Alternative 5. From an 

economic perspective, the large costs of equipment and manpower to remove fuels, prepare soils, 

release, and monitor progress dwarf the marginal costs of time and materials for planting additional 

trees to produce a higher initial density. In addition, because of the more complex planting design in 

alternatives 1, 3, and 4, the actual per acre cost of tree planting is likely to be less for Alternative 5 

than it would be for those other alternatives. As a result, costs to the government and job creation are 

almost the same for alternatives 1 and 5.

Economic Efficiency

Following the same methodology as was used to analyze economic efficiency for Alternative 1 

estimates for Alternative 5 are shown in Table 3.10-19. Agency costs for Alternative 5 are slightly 

less than what was shown for Alternative 1 because the costs of monitoring natural regeneration areas 

would not be required under Alternative 5. Contractor costs are slightly less under Alternative 5 due 

to less complicated planting. The total cost to the government to be incurred each year is presented in 

the fourth column.

Using the appropriate discount rates, the PNC for Alternative 5 is calculated in the last column of 

Table 3.10-19. The total PNC of performing scheduled treatments under Alternative 5 over the next 

decade and a half is approximately $81 million. 

Table 3.10-19 Alternative 5: Present Net Cost of Treatments to be Performed

Year Contractor Costs 

(2015 $1,000s)

Agency Costs 

(2015 $1,000s)

Total 

Costs

Discount 

Rate1 Discount Factor2 Present Net Cost (PNC)

1 $732 $59 $790 0.00% 100.00% $790

2 $3,832 $2,153 $5,985 0.05% 99.90% $5,979

3 $8,168 $2,071 $10,239 0.10% 99.70% $10,209

4 $8,741 $3,508 $12,249 0.25% 99.01% $12,127

5 $9,694 $2,516 $12,211 0.40% 98.02% $11,969

6 $9,637 $1,111 $10,749 0.55% 96.76% $10,401

7 $8,341 $1,211 $9,552 0.70% 95.23% $9,097

8 $6,182 $1,091 $7,273 0.77% 94.05% $6,840

9 $3,867 $677 $4,544 0.83% 92.83% $4,218

10 $3,392 $634 $4,025 0.90% 91.43% $3,680

11 $1,968 $437 $2,405 0.93% 90.32% $2,172

12 $2,127 $473 $2,600 0.96% 89.17% $2,318

13 $159 $35 $195 0.99% 87.98% $171

14 $696 $155 $850 1.02% 86.76% $738

Totals $67,537 $16,131 $83,668 $80,711

1 Discount rates for federal analyses are presented in Appendix C of OMB Circular A-94 for key years, and discount rates for intervening 

years are estimated through linear interpolation.

2 The Discount Factor is equal to 1/(1 + i)t where i is the interest rate and t is the number of years from the date of initiation for the 

program or policy until the given future year. Source: Land Economics Consultants analysis

Table 3.10-20 shows the PNB for Alternative 5, which was calculated the same as the other 

alternatives. The PNV was also calculated the same as for the other alternatives. Given the PNB of 

$8.4 million estimated above, less the PNC of negative $80.7 million, the PNV for Alternative 5 is 

negative $72.3 million. The larger the PNV, the more beneficial it is to the federal goal of economic

efficiency. In the case of expensive action alternatives, the larger PNV would be the one that is “less 

negative.”

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Table 3.10-20 Alternative 5: Present Net Benefits Derived from Thinning or Harvesting Timber

Year Thin/Harvest

(acres)

Estimated Yield 

(board feet/acre)

Produced 

(MBF)

Value Sold 

(in $1,000s)

Discount 

Rate

Discount 

Factor

Present Net Benefit 

(PNB in $1,000s)

1 6 305 2 $0 0.00% 100.00% $0

2 33 305 10 $1 0.05% 99.90% $1

3 1,164 305 355 $36 0.10% 99.70% $35

4 2,561 305 781 $78 0.25% 99.01% $77

5 5,911 305 1,803 $180 0.40% 98.02% $177

6 4,136 305 1,261 $126 0.55% 96.76% $122

7 123 305 38 $4 0.70% 95.23% $4

50 26,009 6,165 160,338 $13,570 1.40% 49.90% $8,001

60 0 0 0 $0 1.40% 43.42% $0

Totals 39,943 8,300 331,515 $13,995 $8,417

Source: Land Economics Consultants analysis

Economic Impact

Table 3.10-21 Alternative 5: Jobs Created in Tuolumne and Mariposa Counties

Year Contractor Costs 

(2015 $1,000s)

Direct Jobs 

(FTEs)1

Indirect and Induced 

Jobs (FTEs)2 Total Jobs Supported (FTEs)

1 $732 17 8 25

2 $3,832 87 44 131

3 $8,168 186 93 278

4 $8,741 199 99 298

5 $9,694 220 110 330

6 $9,637 219 110 329

7 $8,341 190 95 284

8 $6,182 141 70 211

9 $3,867 88 44 132

10 $3,392 77 39 116

11 $1,968 45 22 67

12 $2,127 48 24 73

13 $159 4 2 5

14 $696 16 8 24

Totals $67,537 1,535 767 2,302

1 Assuming 50% of contractor costs go to labor, and mean annual wages are $44,000. 2 Given an employment multiplier of 1.5, another half an FTE job is created in the 2-county region for every direct FTE job created. 

Source: Land Economics Consultants analysis

Economic impacts for Alternative 5 are similar to Alternative 1. Table 3.10-21 displays the applied 

consistent methodology to estimate direct, indirect and induced jobs created. Alternative 5 is 

estimated to support over 300 full-time-equivalent (FTE) jobs per year in the two-county area during 

periods of peak activity, totaling just over 2,300 throughout the treatment period. The burden on 

Forest Service staff time would be roughly similar to Alternative 1.

Social Analysis

Same as Alternative 1.

CUMULATIVE EFFECTS

Same as Alternative 1.

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Draft Environmental Impact Statement and Environmental Consequences

Summary of Effects Analysis across All Alternatives

Economic Efficiency

Economic efficiency focuses on the human economy and what can be quantified in dollar terms. It is 

a useful tool for federal decision making when choosing among alternatives, but it is limited in that it 

ignores substantial values that are not quantified in dollars, such as enhanced habitat quality, carbon 

sequestration, reduced risk of wildfires, and other ecosystem values. When comparing the economic 

efficiency of alternatives in Table 3.10-22, the only benefit shown is the value of forest products that 

generate revenue to the government as they are sold to private industry in future years. All of the 

action alternatives are expected to produce a little revenue from thinning activities over the next 

decade or so to help offset costs, and all alternatives, including the no action alternative, are expected 

to produce some merchantable timber for sale in 50 or 60 years. The end results differ significantly, 

however, and Alternatives 1 and 5 produce the highest PNB, three to four times as much as the other 

three alternatives, derived primarily from healthy timber sales in years 50 and 60. 

Table 3.10-22 Summary of Economic Efficiency by Alternative (in $1,000s)

Discounted Values Alternative 1

(Proposed Action)

Alternative 2

(No Action)

Alternative 3 Alternative 4 Alternative 5

Present Net Benefit $7,863 $1,871 $2,514 $2,288 $8,417 

Present Net Costs ($82,997) $0 ($232,140) ($30,330) ($80,711)

Present Net Value ($75,134) $1,871 ($229,626) ($28,042) ($72,294)

Source: Land Economics Consultants analysis

Present Net Costs also vary significantly between alternatives, with Alternative 3 creating the most 

adverse situation for the federal government, due to the high cost of hand grubbing to replace the 

need for use of herbicides. At roughly one-third the cost of Alternative 3, alternatives 1 and 5 are 

essentially the same, and require approximately $80 to $83 million in expenditures over the next 

decade and a half to implement. Alternative 4 represents a low-cost alternative with only minimal 

human intervention in the forest’s regeneration, most of which is in the form of prescribed fire. The 

no action alternative implies no costs of government actions, but that is a misleading indicator when 

the government recognizes that it is liable for costs of fire suppression and that Alternative 2 leaves 

more dead woody fuels and greatly increases government firefighting costs.

Present Net Value is the sum of properly discounted benefits and costs. By showing the highest value 

for this indicator, Alternative 2 suggests no action should be taken. When one includes the risk of 

uncontrolled fires and their costs, however, it can be seen that this is a false conclusion. Alternative 3 

has by far the lowest value, and reflects the high costs of replacing herbicide use with manual labor. 

Among the other action alternatives, Alternative 4 creates the highest PNV in spite of having low 

benefits, because it is also low-cost. Alternatives 1 and 5 are essentially the same from an economic

efficiency standpoint.

Economic Impact

With a focus on jobs created, the labor-intensive effort in Alternative 3 to produce the desired forest 

conditions without using herbicides generates by far the greatest number of jobs in Tuolumne and 

Mariposa Counties. Given the small size of the workforce devoted to forest work in the host counties, 

however, it is likely that the majority of the direct jobs supported would be taken by people who live 

outside the two counties, and who would be housed temporarily in Tuolumne and Mariposa motels 

while grubbing out the forest. During peak activity periods, this could put pressure on the motel 

inventory and distort revenue flows in other tourism supported businesses.

Alternatives 1 and 5 would require a more manageable demand on motel rooms, and would generate 

very similar levels of jobs. Alternatives 1 and 5 would likely be seen as equally beneficial by most 

participants in the local economy. 

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With minimal human intervention in the forest, Alternative 4 would also have a minimal beneficial 

impact on the economy. The no action alternative would be exactly that, and would generate no new 

jobs in Tuolumne or Mariposa counties. Table 3.10-23 summarizes jobs created by alternative.

Table 3.10-23 Summary of Jobs Created by Alternative (in FTEs)

Full-Time-Equivalent Jobs Alternative 1

(Proposed Action)

Alternative 2

(No Action)

Alternative 3 Alternative 4 Alternative 5

Direct Jobs Supported 1,579 0 5,176 189 1,535

Indirect & Induced Jobs 790 0 2,588 97 767

Total Jobs Supported 2,369 0 7,764 283 2,302

Source: Land Economics Consultants analysis

Social Analysis

In terms of the quality of life for residents of Tuolumne and Mariposa counties and their traditional 

social and cultural patterns, it is likely that most residents liked the conditions in the Rim Fire area as 

they were before the fire better than they are now. The action alternatives are designed to return the 

forest to similar conditions faster than the no action alternative. Due to their reliance on more active 

intervention, Alternatives 1, 3 and 5 would likely return pre-fire forest conditions faster than 

Alternative 4. Although not necessarily better or worse, the forest conditions under Alternative 4 

would be “different” from prior conditions for decades to come, and resident opinions may vary as to 

the desirability of each outcome.

The perceived aesthetics of the forest (i.e., “beauty is in the eye of the beholder”) and the recreational 

opportunities that are available within it would be a driver of tourism in Tuolumne and Mariposa 

counties. Visitation and recreation within the Rim Fire area will likely take place with or without the 

Forest Service taking action, or under any of the action alternatives, but the forms of recreation and 

the volumes of tourists may differ. Conditions that attract bird watchers may be different than those 

that attract fishermen and hunters. Conditions that maximize hiking may be different from those that 

maximize motorized trail activity. To the extent that return of a mixed conifer forest would have 

greater appeal to a wider range of traditional recreational pursuits and draw more tourists back to the 

forest, residents of the region who own businesses or work in the tourism industry would see some 

restoration of lifestyles that have been diminished by the reduced volumes of visitors by the Rim Fire. 

Environmental Justice

Environmental Justice (EJ) is an executive order (EO 12898) which requires, in brief, 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. 

USDA Civil Rights policy requires each agency to analyze the civil rights impact(s) of policies, 

actions, or decisions that will affect federally conducted and federally assisted programs and 

activities. A civil rights impact analysis (CRIA) facilitates the identification of the effects of 

eligibility criteria, methods of administration, or other agency-imposed requirements that may 

adversely and disproportionately impact employees or program beneficiaries based on their 

membership in a protected group. Protected groups include multiples of similarly situated persons 

who may be distinguished by their common race, color, national origin, age, disability, and where 

applicable, sex, marital status, familial status, parental status, religion, sexual orientation, genetics, 

political beliefs, or receipt of income from any public assistance program. 

Actions including treatments to units within the Rim Fire area or deciding not to conduct any 

treatments and actions that are applied consistently to everyone are not discriminatory. Economically 

beneficial support for additional employment, generated by action alternatives, is not specific to any 

ethnic group or income segment of the population. No evidence suggests that considered actions (in 

their entirety) have disproportionately high and adverse impact on minority and low-income 

populations. 

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3.11 SOILS

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction

National Forest Management Act (NFMA) of 1976 as amended and the Forest and Rangeland 

Renewable Resources Planning Act of 1974) require the maintenance of productivity and protection 

of the land and, where appropriate, the improvement of the quality of soil and water resources. 

NFMA specifies that substantial and permanent impairment of productivity must be avoided. 

Forest Service Manual (FSM) 2550 (USDA 2010c) establishes the management framework for 

sustaining soil quality and hydrologic function while providing goods and services outlined in the 

Forest Plan. Primary objectives of this framework are to inform managers of the effects of land 

management activities on soil quality and to determine if adjustments to activities and practices are 

necessary to sustain and restore soil quality. Soil quality analysis and monitoring processes are used 

to determine if soil quality conditions and objectives have been achieved.

Pacific Southwest Region (Region 5) FSM 2500 Chapter 2550 Supplement (USDA 2012a) 

establishes soil functions (support for plant growth (productivity) function, soil hydrologic function, 

and filtering and buffering function) that the Region uses to assess soil conditions and determine if 

the national soil quality objectives are being met. Each soil function has a set of indicators that frame 

the desired condition for soil resources. The analysis standards are used for areas dedicated to 

growing vegetation. They are not applied to lands with other dedicated uses, such as system roads and 

trails or developed campgrounds. 

Forest Service Handbook (FSH) 2509.22, Chapter 10 (Water Quality Management Handbook) 

(USDA 2011b) improves and replaces the Best Management Practices (BMPs) presented in Water 

Quality Management for NFS lands in California. The Forest Service water quality protection 

program relies on implementation of prescribed BMPs. These BMPs are procedures and techniques 

that are incorporated in project actions and determined by the State of California to be the most 

effective, practicable means of preventing or reducing the amount of pollution generated by nonpoint 

sources to a level compatible with water quality goals. Additionally, the 2011 Handbook amendment 

establishes an expanded water quality management monitoring program (section 16). 

National Best Management Practices for Water Quality Management on National Forest 

System Lands (USDA 2012) that apply to the proposed activities are included in Chapter 2. 

The Forest Plan Compliance (project record) document identifies the Forest Plan Standards and 

Guidelines that specifically apply to this project and related information about compliance with the 

Forest Plan.

Effects Analysis Methodology

Soil effects are determined and predicted based on a review of relevant literature and from monitoring 

reports and observations of soils where similar actions have occurred in the past. While the physical 

actions may be similar, the impact to soils depends on the soil properties at that location, which can 

be highly variable. The analysis area for this report consists of soil that supports vegetation growth 

within the project area boundary. Soils under roads, trails, and recreation sites are not directly 

considered when addressing soil impacts from the project, but their indirect effects on soils 

supporting vegetation are considered where necessary (e.g. runoff from roads that leads to erosion in 

a treatment unit).

The soil effects analysis is bounded in time by the foreseeable future period during which detectable 

effects on the soil resource could persist in this project area. Some soil features, such as ground cover, 

can recover quite quickly. Effects on other features, such as compaction and soil organic matter, can 

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persist for decades or centuries. Because soil effects can be persistent, the current soil conditions 

reflect the cumulative effects of past activities, regardless of when they took place. In general, effects 

are discussed as short-term (less than 5 years) or long-term effects (longer than 5 years). For 

cumulative effects, the analysis is bounded in time by past, present and reasonably foreseeable future 

projects.

Assumptions Specific to Soils

 Activities detailed in the Rim Fire Recovery EIS (USDA 2014) are still in progress. However, for 

soil effects analysis, the baseline condition will assume that all activities in both the Rim 

Recovery and Rim Fire Hazard Trees EA (USDA 2014h) projects have already taken place.

 All treatments prescribed under the natural regeneration units were assumed to be implemented in 

order to analyze for the most potential impacts. 

 The condition of ground cover will be determined by currently proposed mechanical site 

preparation or prescribed burn treatments. In alternatives that contain units with only herbicide 

proposed for site preparation, past actions such as machine piling in combination with herbicide 

site preparation will determine future soil cover.

 Assumptions for Erosion Hazard Rating (EHR) analysis include:

- All slopes are uniform and were generalized by soil type. 

- For EHRs, a single “climate” was used for the whole project area. The precipitation values 

were based on a weather station close to Corral Creek, near the middle of the Rim Fire. 

- Soil Cover inputs to the EHR analysis are estimates of percent ground cover that would be 

remaining after proposed treatment activities (e.g. site preparation) are complete. Estimated 

cover values were based on field surveys, ground cover data, and photographs of similar 

treatment types that have occurred on the Stanislaus in the past.

- The EHRs include a factor to increase water infiltration for units that could receive deep till

and forest cultivation (DTFC) treatments.

Data Sources

 Soil survey data including maps and soil properties from the Stanislaus National Forest Soil 

Survey (USDA 1981), and more detailed soil surveys covering portions of the project area 

(Norgren et al. 1990). 

 Soil interpretations provided by the Region 5 Soil Interpretation Guide (USDA 1999).

 The Rim Fire Soil Burn Severity map and soils BAER report (Flores et al. 2013). 

 Remote sensing data including the LiDAR DEM, and high resolution multi-spectral imagery 

acquired and processed in 2013 by the Forest Service Remote Sensing Lab based in McClellan, 

California.

 Geologic map of Tuolumne and Mariposa counties, and associated GIS layers.

 Soil pit descriptions, and additional field observations about soil disturbance and soil physical 

properties made by the soil scientist and field crews.

Soils Indicators

The Region 5 supplement (USDA 2012a) to the national soil management chapter provides direction 

for soil assessment procedures and defines the soil functions and indicators that were used to frame 

soil condition assessments. Three soil functions (environmental functions of soil) were used for 

assessment and analysis to determine if the national soil quality objectives were being met: support 

for plant growth function (soil productivity); soil hydrologic function; and filtering-buffering 

function. Each of these 3 functions has a set of indicators, listed below, that were used to determine if 

existing conditions meet the desired soil conditions in the project area. Full analysis of these 

indicators can be found in the Soils Report (project record). 

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SOIL STABILITY

 Amount of unit with EHR higher than moderate 

 Amount of soil cover removed by project activities 

SURFACE AND SOIL ORGANIC MATTER

 Percent organic mulch cover remaining after site preparation (Criteria greater than 50% area 

covered)

 Area of productivity loss due to displacement of topsoil

SOIL STRENGTH AND STRUCTURE

 Area of productivity loss due to compaction or loss of soil porosity 

 Area with reduced infiltration due to change in soil structure 

SOIL MOISTURE REGIME

 Soil moisture regime in meadows and fens is retained

FILTERING BUFFERING FUNCTION

 Soil microorganism populations 

 Leaching potential of applied herbicides 

 Risk of off-site movement of applied herbicides 

The indicators above include the following specific measures. Soil stability refers to a soil’s ability to 

resist erosion. Soil cover protects a soil from water and wind erosion, and slope, vegetation type and 

infiltration rates all affect the overall risk of erosion. The EHR method incorporates all these factors 

to show relative differences in soil stability. To preserve soil stability, soil cover should be managed 

to avoid a high EHR (USDA 1999) after project activities are complete. For surface organic matter, 

an organic mulch consisting of duff and small woody debris should cover approximately 50% of the 

soil surface after site preparation, and 85% of soil organic matter should be preserved in the top 12 

inches of soil (USDA 2010a). Soil porosity and soil structure should be maintained similar to the 

natural condition to maintain a favorable rooting environment for plants and to ensure sufficient 

infiltration rates to accommodate precipitation inputs (USDA 2012a). Soil moisture regimes should 

not be altered from their natural state, especially in wet meadows and fens (USDA 2012a). Lastly, no 

specific measures for soil filtering buffering function have been developed. Instead, the Region 5 Soil 

Management Handbook Amendment (USDA 2012a) states: for projects that involve the application 

of chemicals, such as herbicides, analyze the effects to soil micro-organisms, post-project erosion 

risk, leaching potential and risk of off-site movement of the chemicals.

Soils Methodologyby Action

There are various types of activity groups proposed in this project that are performed with mechanical 

equipment or prescribed burning that have similar effects on soil: deer habitat enhancement, natural 

regeneration, reforestation (non-mechanical site preparation, plant conifers, prescribed fire, 

grubbing), and thin existing plantations. Tree thinning and prescribed burn actions for the purpose of 

deer habitat enhancement or for plantation thinning occur in different locations across the landscape, 

but have similar effects on soil; thus they were analyzed together in this section. Effects from 

mechanical site preparation, herbicide site preparation, and herbicide use for noxious weed 

eradication are all discussed separately.

SOIL DESCRIPTION AND INTERPRETATION

Soils information for this analysis was derived from the Stanislaus National Forest Soil Survey, the 

Natural Resources Conservation Service (NRCS) Soil Data Viewer (SDV), and from more detailed 

soil surveys covering portions of the project area (USDA 2008a; Norgren et al. 1990). The SDV was 

used to review distribution of specific soil properties potentially affected by mechanical equipment 

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operations on a unit-by-unit basis. Specific interpretations and soil data properties from the SDV

include soil texture, depth, rock content, soil taxonomy, infiltration and permeability, soil water 

holding capacity, soil composition within a unit, acceptable soil loss, slope percent, and soil 

productivity information such as soil survey site class or Net Primary Productivity. The analysis of 

these data was used, partly, to determine where various mechanical site preparation techniques would 

occur. The Soils Report (project record) includes a soil map.

SITE OBSERVATIONS

Field observations identified soil properties useful in confirming the accuracy of the soil survey, 

existing soil conditions, and soil response to management activities. Sampling in 2015 focused on 

important soil variables to determine how soils would respond to site preparation and herbicide 

treatments; variables sampled include soil depth, rock content, slope, surface rock outcrop, soil 

texture, ground cover, and soil hydrologic group. The predicted level of treatment impact, focusing on 

units with tractor piling and DTFC treatments first, was used to prioritize unit sampling. Twenty-five

units proposed for DTFC treatments were visited and more than 250 plots and soil pits were recorded. 

Additionally, site observations from 2013, acquired after the Rim Fire, supplemented the 2015 

sampling. Because of ongoing salvage logging activities, some properties have changed since the 

sampling occurred (such as ground cover), and do not represent the existing condition; however, soil 

properties such as depth, hydrologic group, slope, texture, and rock content are still useful. Ninetyseven plots from 2013 were used. 

Pre-harvest soil disturbance data were collected in areas covered by the Rim HT project using the 

protocol described by Page-Dumroese et al. (2009). Only limited data about soil disturbance after 

completion of the Hazard Tree project are available, including 11 transects. No soil disturbance data 

have been collected yet in the Rim Recovery salvage logged areas.

SOIL EROSION HAZARD RATING

The Region 5 Soil EHR System (USDA 1999) was used to rate the risk of erosion for all soils in the 

project area after implementation of project activities. This system uses various physical soil 

properties along with climate and site-specific conditions to rate sheet and rill erosion soil hazards. 

Inputs to the EHR system were adapted to best fit the predicted conditions after project activities were 

implemented. Soil cover inputs were derived from observed field data for Alternative 2. For action 

alternatives, monitoring data from similar past treatments was used to predict soil cover posttreatment. 

LIDARDATAANALYSIS

A digital elevation model (DEM) derived from LiDAR data was used to create 1-meter slope layers, 

aspect and a hill shade layer that was used to visually inspect units for rock outcrops. These data were 

used in the unit-by-unit assessment of suitability for site preparation techniques, and as inputs to the 

EHR analysis.

Affected Environment

Soil Properties

The geology within the Rim Fire includes variable metamorphic rocks in foothill formations, volcanic 

mudflows and conglomerates on ridge locations, and young glaciated or old deeply-weathered 

granitic rocks throughout the area. Project area soils are primarily derived from metamorphic rock in 

the lower elevations and granitic rock at mid and higher elevations. Table 3.11-1 displays the general 

soil groups in the project area and the corresponding soil properties used in the analysis (Soils 

Report). Most soils within the analysis area have surface textures of loam or sandy loam with gravelly 

texture modifiers, and the most abundant soils have clay loam subsurface textures. This indicates soils 

with high natural infiltration rates at the surface, but only moderate permeability or ability to transmit 

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water below ground. These soils range from shallow to deep, reflecting a wide range of soil 

productivity and soil hydrologic groups. Specific dominant soils include Holland, Josephine, 

Wintoner and Fiddletown. Rock outcrop is also common, even dominant, in several map units. 

Although rock outcrop does not produce sediment, it commonly produces runoff which accelerates 

erosion on soils downslope. The majority of soils (about 75%) within the proposed action have a 

severe compaction rating (high probability to be compacted by activities when moist). These tend to 

be the most productive soils in the project area, particularly the Holland and Josephine soils. 

Table 3.11-1 Soil Families and Associated Properties Used in Analysis

Family MAE 

(%) T-FAC Surface Texture Subsurface Texture DEPTH (inches)

COMP 

Hazard

ROCK 

(%)

Dystric Lithic Xerochrepts 2.00 1 Cobbly loam Cobbly loam 20-40 Moderate 10-50

Dystric Xerochrepts 0.50 1 Cobbly loam Coarse sandy loam 20-40 Moderate 0-25

Fiddletown 8.30 2 Gravelly to Bouldery sandy loam Gravelly sandy loam 20-60 Slight 35-60

Gerle 4.00 4 Gravelly sandy loam Sandy loam 40-60+ Slight 5-30

Holland 32.40 4 Loam Clay loam 40-80+ Severe 5-20

Josephine 29.10 4 Gravelly loam Clay loam 20-60+ Severe 10-30

Lithic Xerumbrepts 5.10 1 Loamy sand Sandy loam 0-20 Slight 10-50

McCarthy 5.20 3 Gravelly sandy loam Sandy loam 20-60 Slight 35-60

Pinole 0.40 4 Gravelly loam Clay loam 60-80+ Severe 5-35

Rock Outcrop 0.28 1 Unweathered bedrock NA 0-10 Slight

Sites 4.54 2 Gravelly loam Gravelly clay loam 20-80+ Severe 0-25

Typic Dystroxerepts 0.20

Ultic Haploxeralfs 0.50 1 Sandy loam Loam Severe 0-10

Wintoner 7.60 4 Gravelly loam Clay loam 40-60+ Severe 0-30

Xerolls 0.10 5 Loam Loam 40-60+ Severe 0-15

COMP=Compaction; DEPTH=Soil Depth; MAE= Maximum Extent of Activities (% total acres); ROCK=Rock Content; T-FAC=T-Factor

Existing Conditions

The project area occurs entirely within the footprint of the 2013 Rim Fire. The soil burn severity 

within the Rim Fire was approximately 44% high and moderate soil burn severity, and the rest at low 

or very low burn severity. Immediately after the fire, the high and moderate burn severity areas had a 

deficiency of both soil cover and surface organic matter. Two years after the fire, substantial 

vegetation regrowth occurred in many locations, but the regrowth is variable. In some locations, 

native shrub species including some nitrogen-fixing species have produced significant ground and 

canopy cover. Some areas with high soil burn severity have less vegetation growth or have a cover of 

invasive species that are not providing the same protective soil cover. In short, recovery of vegetation 

is variable, leaving some locations vulnerable to erosion. The amount of soil organic matter lost in the 

fire has not recovered in two years, and any pre-fire soil disturbance causing compaction or 

displacement on major skid trails has not changed. In locations where no management actions have 

occurred in the last 2 years, the fire is still one of the dominant features controlling surface soil 

conditions. Existing conditions immediately post-fire were described in further detail in the Rim 

Recovery EIS, Chapter 3.11 (USDA 2014). 

The Rim Fire hazard tree removal and salvage logging activities affected multiple soil indicators. The 

EHR method reflects changes made to soil cover and stability. Project-wide, EHR conditions range 

from low to moderate with 41% of the project area predicted to have a low EHR and 59% predicted to 

be moderate. This is an improvement in EHR conditions as described in the BAER report and Rim 

Recovery EIS. The improvement is primarily due to increases in ground cover since the fire. Data 

from 2014 soil disturbance monitoring at 11 Rim HT sites showed ground cover ranged from 62 to 

87% with an average of 78%. Sampling in 2015 showed ground cover ranged from 35 to 85%, and 

averaged 60%. In short, ground cover within salvaged logged areas varies widely and is difficult to 

rate for the whole project, but it is currently sufficient in most areas to prevent a high EHR. 

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Results of soil disturbance monitoring reflect changes in other soil indicators including surface and 

soil organic matter (SOM), and soil strength and structure. In 2013, remote sensing analysis and field 

validation was done to identify legacy, or historic evidence of soil disturbance. While the skid trail 

footprint and levels of compaction have likely changed since 2013 due to salvage logging, the SOM 

lost due to displacement on those trails or combustion during the fire remains the same (in other 

words, the SOM has not recovered in 2 years). The most severe legacy compaction was found on 

benched skid trails or temporary roads on Josephine and Holland soils where clay subsoils were 

exposed and vegetation was stunted or non-existent. This reflects a reduction of soil porosity and 

displacement of the soil organic material. This, combined with SOM lost in combustion during the 

Rim Fire led to approximately 6,000 acres with reduced levels of SOM (USDA 2014 Soils Chapter 

3.11). In 2014, sampling showed that 3 of the 11 units sampled, or 27%, exceeded disturbance 

thresholds and are expected to have a loss of soil productivity. Units typically exceeded thresholds as 

a result of excessive displacement and loss of SOM, or had excessive compaction. Sampling in 2015 

showed that 9 out of 24 units sampled showed some sign of erosion evidence, and 7 units (or 29%) 

showed evidence of rill or gully erosion sufficient to have a loss of productivity. 

Disturbance sampling in 2014 was only done in Rim HT project areas, and no data were collected in 

Rim Recovery salvage logged areas as methods for hazard tree removal are very similar to salvage 

logging. Although the sample sites were well-distributed throughout the project area, the sample size 

was small. The 2014 disturbance data are assumed to reasonably represent the conditions found in 

Rim Recovery treatment areas, but not enough data are available to rate the existing condition of soil 

indicators on a unit basis, or by activity groups. Instead, existing indicator ratings are provided below 

in Table 3.11-2 for the whole project area based on the best available data. More information about 

the predicted effects of Rim Recovery treatments can be found in the Rim Recovery EIS, Soils 

Chapter 3.11. 

Table 3.11-2 Summary of Existing Condition of Indicators

Soil Function Indicator Rating 

Range Metric1 Area

Soil Productivity and 

Hydrologic Function

Soil Stability Good EHR greater than moderate 0 units (0 acres)

Soil Productivity and 

Hydrologic Function

Soil Stability Poor-Good Presence of rill and gully erosion 7 units (29% of units)

Soil Productivity Surface and Soil 

Organic Matter

Fair-Good Percent ground cover, average projectwide69%

Soil Productivity Surface and Soil 

Organic Matter

Fair-Good Percent of units sampled not meeting 

organic mulch cover requirement

17% of units

Soil Productivity Soil Strength and 

Structure

Poor-Fair Area with soil productivity loss due to 

compaction or displacement

27% of units

Soil Productivity Soil Strength and 

Structure

Poor-Fair Acres of productivity loss (legacy 

disturbance) post-fire

6,062 acres

1 Source: Rim Recovery EIS, Chapter 3.11 Soils

Environmental Consequences

Environmental consequences are discussed by the proposed treatment types. The action categories of 

deer habitat enhancement, natural regeneration, thin existing plantations, and reforestation in some 

cases use similar treatment types to achieve the objectives described, so discussions are grouped 

together by treatment type. As stated above, all treatments under the natural regeneration units were 

assumed to be implemented, so analysis related to all reforestation treatment types also applies to 

natural regeneration units. Discussions for each soil indicator include assessments for: mechanical 

and hand thinning of trees (including initial site preparation), prescribed fire (including pile burning), 

mechanical site preparation (machine pile, DTFC, etc.), manual release, and chemical site preparation 

and release. The act of conifer planting has minimal direct effects on all soil indicators, and is not 

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Draft Environmental Impact Statement and Environmental Consequences

discussed further. However, the density of planted trees and their contributions to soil moisture, cover 

and organic matter over time are important, and are discussed where appropriate. Noxious weed 

eradication treatments and chemical site preparation or release are discussed together.

Alternative 1 (Proposed Action)

DIRECT AND INDIRECTEFFECTS

Soil Stability

In existing plantations proposed for tree thinning, soil cover would be reduced, especially on landings 

and main skid trails. In past monitoring of thinning-only treatments in a similar environmental setting, 

total soil cover typically remained high enough to meet forest standards and prevent a high EHR 

(Soils Report). In Alternative 1, most thinning units would also have prescribed understory burning 

implemented before thinning. Burning in combination with thinning would cause an initial reduction 

in soil cover due to organic horizon combustion. However, with typical spring or fall burning and 

associated high fuel moistures, this reduction would likely be within forest soil quality guidelines for 

cover. EHR analysis shows that in thin or thin and burn units, no areas would result in a high EHR. 

Figure 3.11-1 Surface Organic Mulch after Different Treatments

Mechanical site preparation done with feller bunchers, mastication, or grapple piling would have 

effects similar to those of thinning alone, except most units would not have prescribed burning done 

first. Mastication treatments would increase soil cover through additions of shredded tree and shrub 

material. Burning of any piles created would reduce soil cover immediately under the piles, but the 

area would likely be small relative to the unit size. Mechanical site preparation could also be done 

A - Glyphosate release spray B - Hand grubbing, only 2.5 foot radius

C - Dozer piling only D - Dozer piling, followed by DTFC

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with dozers or tractors with brush rakes used to push material into piles for burning. Dozer piling is 

not intended to reduce the fine fuels in contact with the ground, but because of “sweeping” of the 

surface by the larger targeted material, some surface cover would be displaced to piles. Recent and 

past monitoring of dozer piling shows that it can reduce soil cover well below forest standards in the 

short-term, making sites more susceptible to erosion, but the result is highly dependent on vegetation 

type and ground cover. In a recently monitored tractor piled unit, a young plantation burned in the 

Rim Fire, ground cover averaged only 36%. But two other units with a heavy component of 

manzanita (one burned, and one unburned) both had ground cover above 60% after treatment (Figure 

3.11-1, C). EHR analysis shows only 6 units, or about 94 acres would be moved to a high EHR as a 

result of tractor piling.

The final mechanical site preparation method is deep tilling followed by forest cultivation. 

Monitoring of this treatment on the Stanislaus done in the 1990s and in 2015 show that ground cover 

is typically reduced considerably, sometimes below 20% (Soils Report). Cover is not typically moved 

off site, but is incorporated into below ground soil layers so it has less benefit to preventing erosion 

and stabilizing soil (Figure 3.11-1, D); this condition would remain until vegetation and planted trees 

produce ground cover sufficient to prevent erosion. Monitoring in 1993 (Soils Report) stated 62% of 

the sampled units showed “localized sheet and rill erosion characterized by gravel pavements, 

sediment basins, puddles and rill channels.” In this monitoring, the majority of the erosion occurred 

on soils with higher clay content. More rarely, severe rilling or gullying has been recorded on DTFC 

units, usually below road drainages that concentrate water onto loosened soil.

The monitoring of DTFC units in the 1990s recommended practices to limit or prevent erosion on this 

treatment, and many of these recommendations are included as management requirements in

Alternative 1. Two soil types that most commonly showed severe erosion after DTFC treatments were

Mariposa and Bandarita soils. In Alternative 1, these soils were avoided as much as possible when 

assigning DTFC as a site preparation treatment. On steeper slopes, the untilled vegetated buffer strips 

left below road drainage outlets and every 100 feet along the slope would provide material to capture 

and keep eroded soil on site and would help break up rill networks, if they were to form. With the soil

management requirements, 116 units in Alternative 1 would have their EHR increased to high. This is 

a large increase in high EHR ratings compared to the existing condition and Alternative 2 (No 

Action), but compared to other action alternatives with DTFC treatments it represents the lowest 

number of high EHR ratings, and the lowest overall risk of erosion. 

Herbicide applications targeting noxious weed species would create an initial pulse of ground cover 

as dead vegetation falls to the ground. While some of the noxious weed species provide ground cover 

for soil stabilization, they can also out-compete a diverse range of native vegetation that may produce 

better quality ground cover for soil stabilization. Less vegetative cover would be present 1 to 3 years 

after treatment, but if native species reestablish, the benefits for soil stability would outweigh the 

temporary reduction in vegetative cover. Manual pulling or grubbing weeds in Alternative 1 is 

expected to occur in small areas, having minimal effects on soil cover and stability.

Herbicide applications for site preparation and release have similar effects as noxious weed 

treatments, but on more acres. Leaves and woody material from treated shrubs and competing 

vegetation would die and fall to the ground within the first few years after treatment (Figure 3.11-1, 

A). In release treatments, this could occur in a large proportion of a unit. Ground cover is expected to 

increase initially, for 2 or 3 years after a site preparation treatment. During this time, a unit could 

receive additional release treatments, up to 3 times over a 5-year span. Release treatments would 

increase ground cover underneath targeted plants, similar to site preparation spray. Since the objective 

of release treatments is to control and reduce competition to planted trees, less vegetative cover would 

occur on a site with multiple release sprays. Overall, ground cover is expected to decrease somewhat 

between year 2 and year 10 after the initial herbicide treatment, and return to normal levels as planted 

trees drop needles and vegetation returns to the site. Total ground cover is difficult to predict in 

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herbicide treated units, but in units not having tractor piling or DTFC treatments, it is expected to 

meet forest standards at all times through the final release treatment. In herbicide units without tractor 

piling or DTFC treatments, no areas are expected to have high EHR, and a majority of the units 

would have low EHR, and low expected erosion rates. When used in combination with mechanical 

site preparation treatments, ground cover conditions are determined by the mechanical methods with 

likely higher EHR values.

Surface and Soil Organic Matter

Surface organic matter refers to organic material on top of the mineral soil surface, including coarse 

woody debris (CWD), fine wood, and forest floor layers (O soil horizon). This material (especially 

finer sizes) is important for nutrient cycling and support of soil microorganisms. Soil organic matter 

(SOM) refers to organic matter that is a component of mineral soil horizons (mainly A horizons). In 

soils without high clay content, most nutrient exchange occurs in surface soil horizons where SOM is 

highest. Because of this, it is important to protect SOM, especially on soils with thin A horizons, such 

as Lithic Xerumbrepts and other shallow soils listed in Table 3.11-1. 

Thinning units would generally have surface organic matter redistributed, but not moved off site. 

Where trees are felled and skidded, small limbs and needles are likely to break off, causing a 

moderate increase in fine woody debris. The O horizon would be displaced and mixed in areas where 

feller bunchers walk and on light skid trails. On heavy skid trails, surface organic matter would be 

buried and mixed in with surface soil horizons and would be scraped away close to landings. 

Displacement results in the removal of nutrient rich loamy material exposing the high clay content 

subsurface. This subsurface is deficient in soil nutrients, reduces infiltration, and has higher natural 

soil strength impeding root penetration. Fox et al. (1989) found displacement caused by windrowing 

decreased forest productivity. Displacement can also lead to channelized flow from entrainment 

between berms, reduced infiltration, and reduced surface roughness. Prescribed burning done before 

thinning would reduce surface organic matter through combustion, but relatively moist fuels in spring 

or fall burns should prevent large continuous losses of surface organic matter. This combination of 

activities would likely cause a reduction in, or possibly a neutral effect on, total nutrient pools in the 

forest floor. Many remaining nutrients, especially nitrogen, would mineralize or be released into 

mineral soil and would be more available to plants and soil biota (Moghaddas 2007; St. John 1976). 

Areas with high soil burn severity would result in a net loss of SOM as a result of combustion and 

volatilization of nutrients. This higher loss of SOM is more likely under pile burning, where fuels are 

concentrated and are expected to create enough heat to combust SOM immediately under piles.

Effects of mechanical site preparation done with feller bunchers or grapple piling would have effects 

similar to those described for thinning treatments. Mastication treatments would cause a direct 

increase in surface organic material. Masticated material acts as good soil cover, but in the short-term 

it does not have the same nutrient exchange properties as SOM or forest floor material. In the longterm as masticated material breaks down, it would provide nutrient exchange benefits. Site 

preparation with tractor piling could remove surface and SOM, as discussed above, via sweeping of 

topsoil into machine piles. Management requirements would limit the amount of soil that ends up in 

machine piles, protecting SOM, and the requirement for a brush rake should reduce the amount of 

surface organic matter that is removed. Depending on pre-piling site condition, soil cover (including 

surface organic matter) could still be reduced below 40%. 

DTFC treatments mix surface soil layers, and can bring rocks or subsoil to the surface, especially in 

thin soils or those with higher clay content. This has effects similar to soil displacement when subsoil 

layers are brought to the surface. This displacement would occur unit-wide, except in buffer strips and 

untreatable areas such as rock outcrops. The forest cultivation treatment is designed to uproot and 

bring to the surface competing vegetation species, especially bear clover. This treatment would 

remove some surface organic material by mixing it into deeper soil layers, and would remove 

subsurface organic material such as roots by bringing them to the surface. When done in combination 

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with tractor piling, large woody debris and fine woody debris would be almost completely removed 

from a site, with the exception of down log management requirements. Forest monitoring completed 

in 1993 showed all measured units failed to meet soil quality standards for small and large woody 

material (Soils Report). Management requirements retaining a buffer strip for every 100 feet of 

contour DTFC would mean a minimum of 8% of a unit would not receive DTFC, and should retain 

sufficient levels of surface and SOM. Outside these areas, surface organic mulch would remain below 

forest standards in the short-term, at least 2 years, until vegetation and planted trees produce sufficient 

surface organic material. The effect on SOM in the short-term would mean surface organics would be 

incorporated into the soil, and would increase organic carbon below ground. This result was shown in 

monitoring done on a Josephine soil on the Stanislaus where 3 of 4 sampled plots had a decrease in 

organic carbon at the soil surface (0 to 6 inches), and an increase of organic carbon in deeper soil 

layers (Soils Report). In the long-term (more than 5 years) it is unclear what would happen to SOM 

following DTFC. Mixing of soil may cause similar effects as soil displacement by exposing less 

productive subsoil layers, and increasing organic matter decomposition by increasing oxygen 

presence. Surface organics incorporated deeper into the soil may compensate for this loss somewhat, 

but overall SOM levels are predicted to decrease in the long-term. Visual inspections of DTFC units 

from the 1990s consistently display a lack of dark soil colors that are typically associated with high 

organic matter content in the A horizon, and often show noticeably slow organic matter 

decomposition at the surface, and little incorporation of new litter into the soil. However, no sampling 

has been done to show if levels of organic carbon are reduced in the long-term compared to units that 

did not have DTFC treatment. 

Noxious weed eradication treatments would temporarily increase surface organic matter from dead 

vegetation accumulating on the soil surface, but are not expected to affect SOM levels. Herbicide site 

preparation treatments would also increase surface organic material in the short-term (Figure 3.11-1, 

A) as killed vegetation falls to the surface and decomposes. The effect to SOM in the long-term is 

unclear. Site preparation and release treatments would specifically target species like bear clover and 

deer brush that have underground root networks that contribute to increases in SOM and fix nitrogen 

(deer brush). These species would be reduced in herbicide treated areas for at least 5 years over the 

length of possible release treatments, but the rate they would recover is variable, and the long-term

effect on SOM is unknown.

Soil Strength and Structure

Changes in soil porosity can affect water holding capacity, air and water movement, and the ability of 

roots to penetrate the soil (Alexander and Poff 1985; Williamson and Neilson 2000). A majority of 

actions are taking place on soils with a high compaction hazard (Table 3.11-1) 

Soil compaction by mechanical equipment would reduce total porosity in thinning units. Feller 

bunchers are considered low ground-pressure equipment and are not expected to cause widespread 

compaction. Skidding operations, however, would detrimentally compact the soil. Williamson and 

Neilson (2000) found that most compaction occurs after 3 passes of log-laden equipment. Landings 

are areas of high compaction because they support skidding equipment, processors, and biomass 

trucks The reduction of porosity would be greatest on landings and segments of main skid trails; 

however, compaction monitoring on the Stanislaus National Forest has shown that the footprint of the 

severely compacted areas is typically less than 15%, which meets the Forest standard (Soils Report). 

Additionally, smaller trees would be removed in existing plantation thinning, creating lower ground 

pressure and weight of skidding equipment compared to thinning larger trees and fewer passes along 

each skid trail would be needed. 

Hand thinning and prescribed burn activities would have little to no effect on soil porosity or 

compaction. However, prescribed fire activities could alter soil structure at the surface of the soil. 

Organic matter can combust in surface layers of the A horizon (top 2 to 3 cm) if fire resides in one 

location long enough to heat soil to that depth. This could change the soil structure from granular to 

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single-grain. However, with spring or fall burning and relatively high soil moisture content, this effect 

should be minimal compared to dry-season wildfires.

Effects of mechanical site preparation done with feller bunchers, mastication, or grapple piling would 

have effects similar to those described for thinning treatments. Slight reductions in soil porosity may 

occur, but should not reduce soil productivity. Tractor piling would cause similar levels of 

compaction when compared to thinning treatments, but the distribution would be different. Instead of 

compacted skid trails, compacted areas would be concentrated around machine piles where the dozer 

made multiple passes. However, if any of these thinning or site preparation treatments are followed 

by DTFC, the effects of compaction would be reduced. Deep tilling loosens soil and is often used as a 

treatment to alleviate compaction. The 1993 monitoring showed that 88% of DTFC units met the 

forest standard for maintaining porosity and preventing compaction (Soils Report). In coarse-textured 

soils, DTFC is not expected to drastically alter soil structure that is important for soil hydrologic 

function, and macroporosity levels would be maintained. In denser clay soils such as Sites and 

Josephine (Table 3.11-1), DTFC would increase macroporisity in the short term (1 to 3 years) by 

loosening dense clay subsoil, but after the soil settles, macroporosity may actually be reduced because 

of the destruction of soil structure, and the reduction in root channels and other large pores in clay 

soils. This alteration of coarse soil structure may be one of the factors that led to the increased erosion 

recorded in past monitoring (Soils Report). Infiltration is increased in the short-term because of soil 

loosening, but after about 3 years the benefits are lost as infiltration rates slow.

Noxious weed eradication and herbicide site preparation or release treatments are not expected to 

have a noticeable effect on soil strength, porosity, or soil structure because they do not require heavy 

equipment operation. 

Soil Moisture Regime

Most proposed treatments (thinning, prescribed fire, noxious weed eradication, mechanical site 

preparation or herbicide site preparation and release) are unlikely to affect soil moisture regime on 

uplands. Where these treatments occur, soils don’t typically have a hydric, or moisture-dependent, 

soil moisture regime. Thus, these activities are not discussed for this soil indicator in any of the 

remaining alternatives.

Low density conifer planting around meadow perimeters and removing live trees around meadows 

would help maintain water-dependent moisture regimes in meadows by reducing water uptake by 

planted trees in the long-term. 

DTFC treatments may alter the surface and subsurface water flow patterns within a unit by changing 

infiltration rates and water permeability, but the effect this would have on soil moisture regime is 

unknown. Increased infiltration for up to 3 years could reduce surface flow of water, or at least alter 

its course across a unit. Many water-dependent moisture regimes are influenced more by ground 

water than surface water.

Filtering Buffering Function

The only actions that could affect filtering-buffering function of soil are herbicide applications. The 

other treatments are not evaluated for this indicator.

Glyphosate is the only herbicide proposed for use in site preparation or in release treatments for the 

purposes of reforestation. According to the SERA report (2011), there is very little information 

suggesting glyphosate will be harmful to soil microorganisms under field conditions. Other research 

indicates that glyphosate can harm soil microorganisms under lab conditions, but it is likely to 

enhance or have no effect on soil microorganisms in field conditions or in soil (Busse et al. 2001; 

Wardle and Parkinson 1992). From examination of the effects of glyphosate on microorganisms in 

numerous forest soils throughout northern California, Busse (2001) failed to detect any changes in 

microbial population size, diversity, or function due to the herbicide applied at the field rate. When 

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applied at concentrations well above the recommended rate, soil microbial growth was stimulated. 

Additionally, glyphosate does not appear to reduce the beneficial effect of mycorrhizal fungi (Busse 

2001; Chakravarty and Chatarpaul 1990). Ratcliff et al. (2006) concluded that glyphosate has a 

benign effect on both soil bacterial and fungal community structure when applied at the 

recommended field rate to organisms in their native soil habitat.

The fate of herbicides in soil is determined by their chemical structure and reactivity or how they 

interact with the soil environment. Substances that are soluble in water and do not adsorb readily to 

soil particles or organic matter can be leached through the soil. Such substances have the potential to 

reach water when precipitation amounts exceed the water infiltration rates of the soil. Substances that 

are adsorbed (roughly, bonded to) soil particles are mostly degraded in place and resist leaching. 

Adsorption of chemicals to soil particles depends primarily on soil clay and organic matter content, 

temperature, and pH.

Glyphosate tends to readily adsorb to soil particles, and is degraded by microbial action. This gives 

Glyphosate a relatively low mobility in soil, rarely penetrating below 12 inches depth. Its persistence 

in soil is typically less than 3 months and can be less depending on the soil conditions (SERA 2011). 

Past monitoring on the Groveland Ranger District has showed with typical application rates used for 

site preparation and release, glyphosate was not detected in soil after treatment (Soils Report).

Relatively little information is available on the toxicity of clopyralid to soil microorganisms. At 

concentrations of 10 parts per million (ppm) in soil, clopyralid had no effect on nitrification, nitrogen 

fixation, or degradation of carbonaceous material (SERA 2004). The USFS uses the 10 ppm value as 

a no observed effect concentration (NOEC) for soil microorganisms. Use rates for noxious weed 

eradication would be approximately 0.1 milligram clopyralid per kilogram of soil, which is far below 

the known value for potentially toxic levels for soil organisms.

Clopyralid is degraded primarily by microbes in soils and aquatic sediments. No metabolites 

accumulate during the degradation process and therefore, no additional contamination of the 

environment occurs (Pik et al. 1977). The half-life in soil can range from 15 to 287 days, depending 

on soil temperature and moisture conditions (SERA 2004). The half-life for clopyralid is expected to 

be approximately 25 days for soils in areas treated for noxious weeds. Clopyralid does not bind 

tightly to soil particles; however, the potential for leaching or runoff is functionally reduced by the 

relatively rapid degradation of clopyralid in soil. Recent monitoring on the Groveland Ranger District 

showed no evidence of clopyralid entering water after it was sprayed on noxious weeds adjacent to a 

stream (Peterson 2012a, 2012b).

Aminopyralid is a relatively persistent substance in soil, and the half-life in a field setting in soil can 

range from 25 to 74 days. Longer times of persistence (over 300) days have been observed in a 

laboratory setting where degradation of aminopyralid was the only means of dissipation (SERA 

2007a). Soil invertebrates, including earthworms, appear to be relatively unaffected by aminopyralid 

and show no observable effects when exposed to 5,000 milligrams active ingredient per kilogram of 

soil (SERA 2007a). Similarly, soil microorganisms do not have adverse effects observed at 

concentrations up to 8 milligrams per kilogram of soil. In fact, the only observed effect was an 

increase in nitrate and total mineral nitrogen on the day aminopyralid was applied (SERA 2007a). 

Because of the application rates for this herbicide are very low, concentrations are expected to be well 

below the no effect concentrations given for soil microorganisms and invertebrates. Thus, even 

though aminopyralid is relatively persistent in soil, it is not expected to cause any negative effects to 

soil microorganisms.

There are very little data available about the effect of clethodim on soil microorganisms, or other soil 

biota. The only terrestrial invertebrate that has toxicity information available is the honey bee, which 

has a No Observable Adverse Effect Level of 860 milligrams per kilogram of body weight. With 

normal application rates, it appears clethodim is unlikely to negatively affect bees and aquatic 

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invertebrates (SERA 2014). Clethodim is not readily adsorbed by soil or organic matter particles, so, 

in a laboratory environment, it has been shown to be moderately mobile in soil. However, its expected 

half-life in a field environment is the shortest of any herbicide proposed for use in this project at only 

3 days. With the proposed application methods and management requirements to limit timing of 

application there is a low probability that clethodim would be leached out of the soil profile or be 

moved off site through sediment losses because most of the substance it is likely to break down in a 

few days.

CUMULATIVE EFFECTS

Units that are proposed for DTFC site preparation would mitigate any compaction that resulted from 

Rim Recovery salvage logging treatments. This would be a beneficial effect, especially in units that 

were salvaged logged during the wet season.

There are several scenarios where the combined effect of past actions and currently proposed actions 

may create cumulative negative effects to the soil resource, or specific soil indicators. Those 

scenarios are where currently proposed actions overlap with: high soil burn severity from the Rim 

Fire, dozer piling proposed in the Rim Recovery, and in some cases salvage logging proposed in the 

Rim Recovery. Tractor piling that was proposed in the Rim Recovery would occur in many units with 

the same footprint as Rim Reforestation units. The combined effect of tractor piling and thinning or 

prescribed burning treatments in Reforestation would reduce ground cover sufficiently to create a 

high EHR condition. This would create a cumulative negative effect on soil stability and surface 

organic matter, and 1,260 acres would be moved to a high EHR category. 

The combination of prescribed burning and thinning in existing plantations and deer habitat 

enhancement units is not likely to cause a cumulative negative effect in areas where the Rim Fire 

burned with low or moderate soil burn severity. However, where high soil burn severity occurred, 

there may be a cumulative negative effect to surface and soil organic material and total soil nutrient 

pools. The overlapping area of high burn severity and prescribed burning is smaller than the overlap 

with Recovery tractor piling which would have a more direct and predictable negative effect on 

surface and SOM. 

Finally, locations with high soil burn severity in the Rim Fire, followed by salvage logging 

(excluding Watershed Sensitive Areas), followed by mechanical site preparation (especially dozer 

piling or DTFC) are the most susceptible to negative cumulative effects to soil resources. For EHR 

analysis, tractor piling treatments proposed in the Rim Recovery were used to determine the existing 

condition for ground cover, so the cumulative effect of that treatment would be captured. Areas with 

high soil burn severity that receive tractor piling treatments are the least likely to have sufficient 

surface organic matter to meet forest plan standards of 50% organic mulch after site preparation. It is 

expected that most of these areas will not meet forest plan standards after treatment.

Alternative 2 (No Action)

DIRECT AND INDIRECTEFFECTS

Soil Stability

Under Alternative 2, no project activities would occur, so there would be no direct effects on the soil 

resource. Other actions described under the Rim Recovery and other projects would continue. 

Because of the Rim Fire and Rim Recovery project activities, EHRs would be slightly elevated over 

their natural (unburned) condition, but no areas in the project area would have a high EHR. In most 

cases, soil cover for erosion protection would be limited to natural rates of accumulation, based on the 

vegetation types present post-fire. If there are locations that were under a forested vegetation type 

before the Rim Fire that are now chaparral vegetation, natural levels of ground cover could be 

reduced below their pre-fire condition. This could contribute to higher rates of erosion in the longterm (greater than 10 years), if forest vegetation is not re-established. This condition would mostly be 

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expected in areas that are currently manzanita or chamise chaparral. Bear clover and other vegetation 

types that produce nearly 100 % ground cover would have similar erosion rates in the long-term as a 

forested site.

Noxious weed populations would remain and continue to displace native vegetation. In some cases,

such as with non-native annual grasses, this could lead to a long-term reduction in soil stability. 

Native bunch grasses evolved under the area’s historic fire regime, and the soils that formed under 

these native species are a product of that long-term relationship. Non-native species may cause a 

long-term reduction in stability of soil, leading to a reduction in soil productivity. 

Surface and Soil Organic Matter

The vegetation type and amount of vegetation recovery would determine the levels of surface organic 

matter that accumulate in the short-term under Alternative 2. Monitoring shows that units receiving

dozer piling in the Rim Recovery may have reduced surface organic matter levels for several years 

until new vegetation restores ground cover and litter layers. In most parts of the project area, 

vegetation that has become established since the Rim Fire would dominate SOM processes. Soil 

cover would continually be added by litter accumulation, and nutrient cycling processes would be 

dominated by natural processes. 

In existing plantations, no thinning or removal of standing small trees would occur; this material 

would fall over the next several years and accumulate fine and coarse woody material on the soil 

surface. In existing plantations that experienced high vegetation burn severity, fuel loadings in the 

next 5 to 10 years could reach levels that cause severe soil heating in a fire, if they were to re-burn 

(Brown et al. 2003). One study, in adjacent Yosemite National Park, examined the effects of multiple 

fires on vegetation in unlogged areas. Areas of high soil and vegetation burn severity were more 

likely to burn at high severity again in future fires (van Wagtendonk et al. 2012). However, areas that 

burned at low or moderate burn severity initially and had maintained forest conditions were more 

likely to burn at low or moderate burn severity in later fires. Fuel loading in contact with the soil 

surface is likely the most important variable in determining risk of fire damage to the soil during a 

possible reburn. Since a large part of the project area would be treated for fuel loadings in other 

projects, under Alternative 2 only unthinned plantations are at risk of fire damage to the soil. 

Soil Strength and Structure

Existing levels of compaction under Alternative 2 would not be altered. Any existing compaction 

from legacy treatments or from Rim Recovery salvage logging would remain until natural processes 

restore soil porosity. Conversely, no additional compaction would be created from dozer piling, 

thinning, or other mechanical site preparation treatments.

Soil Moisture Regime

Thinning of live conifers around meadows would not occur under Alternative 2. In a few cases where 

there is conifer encroachment threatening the moisture regime, this could impact the meadow’s 

available water and moisture regime. In a majority of the project area, however, no actions would take 

place that affect soil moisture regime and existing conditions would continue to determine available 

water for soils in water-dependent systems.

Filtering Buffering Function

No herbicide applications would occur under Alternative 2. Soil microorganism populations would 

continue to cycle under normal post-fire conditions, and there would be no risk of herbicide 

substances leaching or movement within the project area.

CUMULATIVE EFFECTS

In the short-term, stabilizing vegetation that has grown since the Rim Fire would continue to expand 

and produce soil cover at natural rates and would not be altered by site preparation actions. Any 

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existing compaction in DTFC areas would remain and slowly recover with natural processes. Erosion 

hazard would remain at moderate levels or below in all parts of the project area. In the long-term, in 

areas that transitioned from a forest-dominated to a chaparral-dominated environment, natural ground 

cover levels could be reduced and annual erosion rates could increase. To have a severe negative 

effect on soil productivity this vegetation type change and increased erosion rate would have to 

persist for a long period of time. 

Alternative 3

Alternative 3 differs from Alternative 1 where changes affecting soils include: elimination of the use 

of herbicides, additional amounts of DTFC and hand grubbing. Management requirements affecting 

DTFC also differ from Alternative 1. Alternative 3 proposes additional DTFC site preparation

treatments on 646 acres of proposed deer habitat enhancement areas, and on 3,809 acres of the 

proposed reforestation treatment areas. The additional areas of DTFC would be on sites that were 

proposed for herbicide site preparation in Alternative 1. The slope limitation for DTFC would be 

increased to 35%, and untilled buffer strips on steep slopes (over 20%) or below roads would not be 

required. 

DIRECT AND INDIRECTEFFECTS

Soil Stability

All thinning and pre-thinning prescribed burning would be the same as described in Alternative 1. 

Initial site preparation using prescribed burning or mechanical and hand treatments would also be the 

same as described in Alternative 1. The described effects, and the acres treated would be the same as 

Alternative 1.

The additional DTFC treatments would increase the risk of erosion on nearly all of the newly 

proposed acres. The removal of buffer strips and increase of suitable slope for this treatment increases 

the likelihood of concentrated water flow coming off of a road and initiating rill erosion, and would 

increase rill energy on slopes above 30%. Soil properties in each additional DTFC unit were reviewed 

by the soil scientist before being proposed for this treatment. In most of the additional units there are 

portions within them that had thin soils, steep slopes, or rock outcrops that would not be desirable to 

subsoil. Additionally, when units met criteria for slope steepness and rock content, some areas were 

proposed for DTFC on soil types that were said to be unfavorable for this treatment in past 

monitoring (Soils Report). This increases the risk of erosion compared to DTFC units in Alternative 

1. As mentioned under Alternative 1, DTFC would increase macroporosity (and possibly infiltration) 

on dense clay soils in the short-term. With low intensity rainfall, this effect may prevent rill erosion 

from initiating in large areas in DTFC treatments, but in the event of large rainstorms with high 

intensity rainfall that exceeds infiltration rates, resulting in surface flow of water, the risk of rill or 

gully erosion rates goes up. The likelihood of large, intense rain events cannot be predicted, so there 

is not a guarantee of more erosion with additional DTFC acres, it simply increases the risk in the 

event of a large storm. The analysis predicts Alternative 3 would have the most number of units (170) 

and 22% of the total treated area with a high EHR. This is an increase of 54 additional units and 8% 

over Alternative 1.

In lieu of site preparation applications of herbicides, manual grubbing would be used after planting to 

remove competing vegetation. DTFC units would also receive hand grubbing as a release treatment. 

This action would remove soil cover and expose bare soil around planted trees (Figure 3.11-1, B). 

The area of a unit affected by grubbing would vary with the number of planted trees, and could range 

from approximately 45% to 89%. Compared to the herbicide site preparation in Alternative 1, manual 

grubbing would result in lower ground cover and a slightly elevated risk of erosion in the short-term. 

Areas between planted trees would not be grubbed, leaving ground cover intact over the remainder of 

the unit. The additional grubbing has partly contributed to the increased acres of high EHR, but 

sprouting vegetation is expected to recover much more quickly than Alternative 1 in units that receive 

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herbicide site preparation and release treatments. Thus, in hand grubbed areas the long-term effect of 

erosion could be increased or decreased compared to Alternative 1, and would be dependent on 

ground cover levels after the final release treatment is complete.

Noxious weed eradication would be done with one or more of the following methods: grubbing, hand 

pulling, prescribed fire, grazing and seeding with native species. Seeding with native species would 

increase ground cover and soil stability, a beneficial effect, as native plants are established. All other 

manual methods would reduce ground cover in some way. The Jawbone Lava Flat area contains the 

largest contiguous patch of noxious weeds and would have the most area that could have reduced 

ground cover. After treatment, the EHR within this unit would mostly be moderate, with some areas 

classified as low.

Although assumptions are factored into all modeling, the increased erosion risk and EHR is 

substantial enough to conclude that Alternative 3 would have the highest risk of reducing soil 

productivity as a result of erosion.

Surface and Soil Organic Matter

All thinning and pre-thinning prescribed burning would have the same effects as described in 

Alternative 1. Initial site preparation using prescribed burning, mechanical and hand equipment 

would also be the same as described in Alternative 1. The described effects, and the acres treated 

would be the same in Alternative 3 as in Alternative 1.

The additional DTFC treatments in Alternative 3 would have similar effects to surface and soil 

organic material as described in Alternative 1. Over the additional areas treated with DTFC, surface 

organic mulch would be reduced below forest standards in the short-term, subsurface organic carbon 

levels would slightly increase in the short-term and overall SOM levels are likely to decline in the 

long-term. 

By not implementing buffer strips in Alternative 3, the amount of surface organic mulch would 

decrease further when compared to Alternative 1. In most DTFC units, small untreated areas, such as 

rock outcrops, would likely remain, leaving surface organic matter intact; however, no minimum 

amount of surface organic mulch is guaranteed to remain as refugia for normal nutrient cycling 

processes of forest floor layers. Displacement of SOM, as described in Alternative 1, would occur on 

the additional DTFC treated areas. 

Alternative 3 manual noxious weed eradication treatments would reduce surface organic matter levels 

below what is described in Alternative 1, but the treatments are not expected to affect SOM levels. 

Similarly, hand grubbing for vegetation control after planting would displace and reduce surface 

organic mulch and SOM around planted trees. This would reduce the quality and quantity of organic 

mulch around trees until vegetation recovers and the trees grow large enough to produce litter. Shrub 

species such as bear clover and deer brush are expected to recover more quickly than in Alternative 1, 

but the effect this would have on SOM levels is unknown. In areas without sprouting vegetation, 

grubbed sites would have reduced SOM levels compared to herbicide release units in Alternative 1.

Soil Strength and Structure

The effects to soil strength and structure in the Alternative 3 DTFC treatments would be the same as 

described in Alternative 1, but the effects would occur over larger areas. DTFC treatments would 

reduce compaction, where it exists, on the additional areas and buffer strips as stated in Alternative 1. 

Soil structure changes would be the same as described in Alternative 1. 

Soil Moisture Regime

The meadow prescriptions and effects to soil moisture regime in meadows for Alternative 3 are the 

same as in Alternative 1. Alternative 3 includes a management requirement to avoid specific areas 

within the project that may be dependent on delivery of surface water to maintain soil moisture 

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regime. As discussed for Alternative 1, the overall effect of DTFC on soil moisture regime is 

unknown, but avoiding areas with plants that are sensitive to changes in soil moisture would maintain 

the existing condition for water flow, and could potentially preserve the desired soil moisture 

conditions. 

Filtering Buffering Function

No herbicide applications are proposed in Alternative 3, so the effects to soil filtering buffering 

function would be the same as described in Alternative 2 (No Action). Soil microorganism 

populations would continue to cycle under normal post-fire conditions without the risk of herbicide 

substances leaching or moving within the project area.

CUMULATIVE EFFECTS

The additional area of DTFC treatments would create more area at risk of negative cumulative effects 

to surface organic matter and soil stability, and the effects would be the same as described in 

Alternative 1. Similar to the cumulative effects described for DTFC, hand grubbing could create a 

cumulative negative effect to surface organic matter where it overlaps with Rim Fire high soil burn 

severity and Rim Recovery salvage logged areas. The combination of these past actions and hand 

grubbing, especially at the highest tree planting densities, could create a long-term deficit of surface 

organic mulch that would affect nutrient cycling around planted trees. A cumulative effect is less 

likely where high surface organic mulch cover or sprouting vegetation exists. Other cumulative 

effects, outside of DTFC and hand-grubbed areas would be the same as described under Alternative 1. 

Alternative 4

The changes in Alternative 4 affecting soils, when compared to Alternative 1, include: eliminate 

DTFC treatments, reduce the number of reforestation units and acres of site preparation and release 

treatments, eliminate herbicide use for noxious weed treatments and add prescribed fire treatments. 

All thinning in deer habitat enhancement and existing plantations would have the same acres and 

effects for all soil indicators as described in Alternative 1. Noxious weed treatment acres and soil 

indicator effects would be the same as described in Alternative 3. 

DIRECT AND INDIRECTEFFECTS

Soil Stability

Alternative 4 site preparation actions would occur over far fewer acres than in Alternative 1; no more 

than 20% of a unit area in Alternative 4 would receive mechanical or herbicide treatments. This 

means a larger area within reforestation unit boundaries would maintain existing soil cover for 

erosion protection. Where site preparation treatments do occur, they would be similar to those 

described for Alternative 1, but over fewer acres. Prescribed fire would occur in 50% of the 

reforestation areas and 50% of the complex early seral forest within the first 10 years. For EHR

analysis, it was assumed that the whole unit footprint would receive prescribed fire, because the 

portions that would be burned are unknown at this time. Even with this over-assumption of treatment 

area, EHR ratings are reduced compared to Alternative 1. Approximately 2% of the area in 

Alternative 4, or portions of 12 units, would be elevated to a high EHR. This is a reduction in EHR 

rating compared to Alternative 1, but EHR levels would still be elevated above the existing condition. 

Surface and Soil Organic Matter

The reduced area of dozer piling for site preparation treatments in Alternative 4 would ensure surface 

organic material remains intact over larger proportions of each unit treated, and compared to 

alternatives with DTFC treatments, surface organic mulch cover would be much higher. This means a 

larger area would have surface organic mulch available for nutrient cycling. The prescribed burning 

in reforested areas of Alternative 4 would have effects similar to those described in Alternative 1. 

Most complex early seral prescribed burning would occur outside the Alternative 1 treatment area, 

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where surface fuel conditions could differ from most of the prescribed burn areas in Alternative 1. 

The location and timing of complex early seral prescribed fire is not well defined, so there is 

uncertainty about the level of effects to surface and SOM. Standing dead trees would fall at varying 

rates over the proposed timeline for prescribed burning, which would change surface fuel loading and 

how fire affects surface and SOM. However, all prescribed burning would need to retain more than 

50% surface organic mulch cover to meet soil management requirements. Overall, surface organic 

mulch cover is expected to be sufficient in more areas, and SOM would be displaced over a smaller 

area compared to Alternative 1. In mechanical site preparation areas, improvements in these 

indicators would be proportional to the difference in acres treated between Alternatives 1 and 4. 

Soil Strength and Structure

The nature of effects from mechanical site preparation and prescribed burning in Alternative 4 would 

be the same as described for Alternative 1, but would occur over a different area. The effects of 

mechanical site preparation would occur over a smaller area, and prescribed burning would occur 

outside unit boundaries described in Alternative 1. A major difference would be that DTFC 

treatments would not occur, so there would be no mitigation of compaction where it is created by 

thinning or site preparation activities.

Soil Moisture Regime

The Alternative 4 prescription for thinning of existing plantations around meadows is the same as in 

Alternative 1, so effects to soil moisture regime would be the same as Alternative 1. There is no 

specific planting prescription for meadows in Alternative 4, but the overall area planted is much 

smaller than in Alternative 1. Planting areas could be selected anywhere within the footprint of units; 

as long as planting does not occur next to meadows, then the effects to soil moisture regime in planted 

areas would also be the same as described in Alternative 1.

Filtering Buffering Function

Glyphosate is the only herbicide proposed for use in Alternative 4, as no herbicides are proposed to 

treat noxious weeds. Where it is applied, glyphosate, used only for reforestation treatments, would 

have similar effects to soil microorganisms as described in Alternative 1. A low risk of off-site 

movement or leaching of glyphosate could occur, as similarly described in Alternative 1, but the 

potential affected area would be smaller.

CUMULATIVE EFFECTS

The reduced area of site preparation treatments would reduce the area of negative cumulative soil 

effects to surface and SOM and to soil stability in Alternative 4. The reduced area of cumulative 

effects is partly captured in the EHR analysis because Rim Recovery tractor piling was considered 

when assigning ground cover values. Only 12 units showed high EHR values, a large reduction 

compared to Alternative 1. Areas of overlap with Rim Fire high soil burn severity are not directly 

captured in the EHR analysis, but again, the area of overlap between these areas and Alternative 4 

treatments would be smaller than in Alternative 1, leading to less area with potential cumulative 

negative soil effects.

Alternative 5

DIRECT AND INDIRECT EFFECTS

The changes in Alternative 5 affecting soils, when compared to Alternative 1, include: thin new 

plantations (replacing post-planting prescribed fire with tree thinning) and increase the slope limit for 

DTFC to 35%. 

Alternative 5 replaces the natural regeneration treatments found in Alternative 1 with reforestation 

treatments. In Alternative 1, natural regeneration treatments would be monitored first, before 

implementing reforestation actions, so there is no guarantee reforestation actions would take place if 

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Draft Environmental Impact Statement and Environmental Consequences

they are not needed. However, in the effects analysis for Alternative 1, all natural regeneration units 

were assumed to receive all proposed reforestation actions, to analyze for the most potential impacts. 

In reality, the total treated area in Alternative 1 could be smaller than Alternative 5, even though the 

effects described are very similar. In short, Alternative 5 would have the largest “guaranteed” 

footprint of proposed activities. 

Soil Stability

The proposed hand thinning after planting in Alternative 5 would, by itself, have little or no impact to 

soil cover and stability; however, burning the piled cut material would reduce ground cover 

underneath the piles and the effects would be similar to those described for pile burning in Alternative 

1.If the material is lopped and scattered instead, it would provide additional ground cover for erosion 

protection. 

The increased slope limit for DTFC treatments would lead to slightly more acres within a unit being 

treated; small pieces of a unit that would have been excluded from DTFC treatment in Alternative 1 

would be treated in Alternative 5. This would slightly increase the risk of rill and gully erosion over 

the whole unit. If rill erosion initiates, it would have slightly more erosive power on slopes above 

30%. The EHR tool is a relatively coarse model, and does not capture this small difference in 

proposed treatments. Thus, EHRs are the same in both Alternative 1 and Alternative 5 with 116 units 

and 14% of the treated area in a High EHR. 

Surface and Soil Organic Matter

The additional area treated with DTFC in Alternative 5 would remove surface organic mulch causing 

a slight reduction in overall mulch cover in each treated unit with steeper slopes. All DTFC units are 

expected to be deficient in surface organic mulch. So, while the larger area of removal is a negative 

effect, it would not change the overall unit rating. SOM would be affected by displacement in the 

same area.

Soil Strength and Structure

Thinning new plantations in Alternative 5 would only be done by hand, so no additional compaction 

is expected when compared to Alternative 1. The additional pile burning would affect soil structure 

underneath piles as described in Alternative 1. The additional loss of soil structure under burned piles 

would be of relatively small extent, because only small trees (less than 10 years old) would be burned. 

If the material is lopped and scattered instead, it would not negatively affect soil structure. Compared 

to Alternative 1, no additional negative effects to soil hydrologic function are expected from this 

treatment.

Soil Moisture Regime

The application of a 25-foot buffer around all meadows adjacent to reforestation units in Alternative 5

and thinning new plantations to have minimal tree structure adjacent to meadows may lead to slightly 

higher tree densities around meadows than Alternative 1, but the intent is similar. In the long-term, 

this would help maintain water-dependent moisture regimes in meadows by reducing water uptake by 

planted trees, similar to Alternative 1.

Filtering Buffering Function

With the stated assumption that natural regeneration units in Alternative 1 would be analyzed for all 

reforestation activities, then Alternative 5 has the same proposed herbicide use, and the same effects 

to soil filtering buffering function as Alternative 1. The “guaranteed” area impacted by herbicide 

treatments would be larger in Alternative 5, but the effects would be the same as in Alternative 1.

CUMULATIVE EFFECTS

Same as Alternative 1.

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Summary of Effects Analysis across All Alternatives

Table 3.11-3 provides a summary of the EHRs across all alternatives, a quantitative prediction of soil 

stability after treatment for each alternative. The effects on other soil indicators are qualitative 

summarizations of the previous effects analysis.

Soil Stability

Alternative 3 creates the highest risk of soil erosion, and reduces ground cover below forest standards 

over the largest area, because of additional DTFC units, large areas of hand grubbing and fewer soil 

management requirements. Alternative 5 has a slightly elevated risk of erosion over Alternative 1, but 

less than Alternative 3. Alternative 4 would leave the most soil cover overall in the project area, but 

treated areas would have the same level of erosion risk as Alternative 1, and erosion risk with 

Alternative 4 is higher than Alternative 2. 

Surface and Soil Organic Matter

Alternative 3 creates the largest area with surface organic mulch below forest standards, due to

additional DTFC units and hand grubbing. Alternative 4 would leave the highest percent surface 

organic mulch on soil surfaces, and would have the lowest impact to SOM. Alternative 5 would have 

slightly less surface organic mulch than Alternative 1 in added DTFC areas, but more mulch cover 

elsewhere because of the removal of post-planting prescribed fire. 

Soil Strength and Structure

Alternative 3 would have the largest benefit to soil strength by reducing compaction in added DTFC 

units. Levels of compaction would be similar between Alternatives 1 and 5. Alternative 4 would have 

the most legacy compaction persisting because of a lack of DTFC treatments; however, it would also 

create the least amount of compaction because of the smallest mechanical treatment footprint.

Alternative 3 would alter soil structure over the largest area, but severity of effects on soil structure 

are mixed, with improvement in the short-term, but a loss in structure and reduced infiltration after 

year 3 over the largest area.

Soil Moisture Regime

Effects between all action alternatives are relatively similar, and would provide a slight improvement 

in soil moisture regime in meadows that are water-dependent. 

Filtering Buffering Function

Alternative 3 would have the lowest probability for off-site movement of herbicides, with no leaching 

of herbicide substances, and effects to soil microorganisms closest to Alternative 2. Alternative 4 has 

the lowest probability of off-site movement or leaching of herbicides due to glyphosate’s high 

adsorption and relatively low mobility in soil. Alternatives 1 and 5 would have the same risk of offsite movement and leaching, due to the inclusion of more soil-mobile herbicides. All alternatives with 

herbicide treatments would have similar effects to soil microorganisms; evidence suggests none of the 

herbicides proposed would have strong negative impacts to soil organisms.

Table 3.11-3 Comparison of Alternatives: Summary of Erosion Hazard Rating (EHR)

Indicators1 Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5

High EHR 14% 0% 22% 2% 14%

Moderate EHR 70% 59% 63% 89% 70%

Low EHR 16% 41% 15% 9% 16%

Total units with area exceeding high EHR 116 0 170 12 116

1 Percent of alternative area

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3.12 SPECIAL AREAS

This section describes the affected environment and the environmental consequences for Special 

Areas. For the purposes of this project, Special Areas are Forest Plan management area land 

allocations within or adjacent to the Rim Fire perimeter that include: Special Interest Areas (SIAs); 

Wild and Scenic Rivers and Proposed Wild and Scenic Rivers (Wild and Scenic Rivers); and, 

Wilderness (USDA 2010a). 

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction

Special Interest Areas

Three SIAs are located within the Rim Fire perimeter: Bourland Creek Trestle Historic Area; Pacific 

Madrone Botanic Area; and, Jawbone Falls Heritage Area. The Rim Recovery project does not 

include treatment units within or adjacent to the Bourland Creek Trestle SIA; therefore, that SIA is 

excluded from further analysis. Forest Plan direction for SIAs is to protect values, make educational 

opportunities available and preserve the integrity of the special interest feature for which the areas 

were established (USDA 2010a, p. 129). Special cutting methods will be used to salvage mortality or 

improve the quality of resources other than the timber resource (p. 133).

Wild and Scenic Rivers

The Wild and Scenic Rivers Act (82 Stat. 906, as amended; (16 U.S.C. 1271-1287) establishes the 

National Wild and Scenic River System and establishes policy for managing designated rivers. Under 

the Act, designated rivers “shall be preserved in free-flowing condition, and that they and their 

immediate environments shall be protected for the benefit and enjoyment of present and future 

generations” (16 USC 1271). Section 10(a) states: each component of the national wild and scenic 

rivers system shall be administered in such manner as to protect and enhance7

 the values which 

caused it to be included in said system without, insofar as is consistent therewith, limiting other uses 

that do not substantially interfere with public use and enjoyment of these values. Section 12(a) states: 

particular attention shall be given to scheduled timber harvesting, road construction, and similar 

activities which might be contrary to the purposes of this Act.

FSH 1909.12, Chapter 8 includes direction to manage selected river corridors to preserve their 

notable values or features as part of, or for eventual inclusion in, the National Wild and Scenic River 

System.

Forest Plan direction for Wild and Scenic Rivers is to protect and enhance Proposed Wild and Scenic 

River characteristics and manage the same as designated Wild and Scenic Rivers (USDA 2010a, p. 

117). Designated and proposed Wild and Scenic Rivers, along with immediate environments, will be 

managed to preserve their free flowing condition and protect their outstandingly remarkable values 

(p. 111). The Forest Plan allocates Wild classification river segments to Primitive or Semi-Primitive 

Non-Motorized ROS; and, Scenic and Recreational classification river segments to Roaded Natural 

ROS (p. 114). Special cutting methods will be used to improve the quality of Wild and Scenic River 

resources (p. 116). 

The Tuolumne Wild and Scenic River Plan (USDA 1988a) provides additional direction for that 

congressionally designated river. Timber management objectives include the following:

 Manage vegetation to protect and enhance Wild and Scenic River values, placing special 

emphasis on protecting streamside vegetation.

1 The Interagency Wild and Scenic Rivers Coordinating Council interprets Protect as elimination of adverse impacts and Enhance as 

improvement in conditions (IWSRCC 2002)

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Chapter 3.12 Stanislaus

Special Areas National Forest

Wilderness

The Wilderness Act of 1964 (Public Law 88-577) and the 132 subsequent laws designating 

Wilderness contain numerous statutory provisions addressing management of Wilderness. It 

establishes a National Wilderness Preservation System of federal lands where the earth and its 

community of life are untrammeled by man, where man himself is a visitor who does not remain.

Several sections of FSM 2320 provide management direction for Wilderness:

 Wilderness values shall dominate over all other considerations except where limited by the 

Wilderness Act, subsequent legislation, or regulations (FSM 2320.3). 

 Do not maintain buffer strips of undeveloped wild land to provide an informal extension of 

Wilderness. Do not maintain internal buffer zones that degrade Wilderness values (FSM 2320.5). 

 Manage each Wilderness as a total unit and coordinate management direction when they cross 

other administrative boundaries (FSM 2320.5). 

 Where a choice must be made between Wilderness values and visitor or any other activity, 

preserving the Wilderness resource is the overriding activity (FSM 2320.6). 

 Display the relationship and coordination between the Wilderness and activities present in the 

Wilderness, as well as activities outside of the Wilderness that affect the management of 

Wilderness (FSM 2322.03). 

 Protect air quality and related values, including visibility, on Wilderness land designated class I 

by the Clean Air Act as amended in 1977 (FSM 2323.61). 

Forest Plan direction for Wilderness is to: maximize the quality and naturalness of the Wilderness 

environment; minimize impacts to the Wilderness resource while allowing it to be used for primitive 

recreation and preserving scenic, scientific, educational and historical values; all NFS lands within 

Congressionally designated Wilderness and areas recommended for Wilderness will be managed in 

accordance with the Wilderness Act of 1964 (16 USC 1131-1136) as amended (USDA 2010a). 

The Forest Plan Compliance (project record) document identifies the Forest Plan Standards and 

Guidelines that specifically apply to this project and related information about compliance with the 

Forest Plan.

Effects Analysis Methodology

Assumptions Specific to Special Areas

SPECIAL INTEREST AREAS

 Site preparation and reforestation in the Pacific Madrone SIA would be conducted in such a way 

that project activities would not damage the integrity of the unique botanical features, the 

madrone trees, including seedlings and saplings that are coming up post fire. 

 Site preparation including deep tilling, forest cultivation, mastication (shredding) and machine 

piling and burning will occur outside of cultural resource boundaries thereby having no adverse 

effect to cultural resources within the SIA. 

 Use of existing breaches within linear sites such as historic railroad grades, trails, and will cause 

no adverse effect the SIA. 

 Hand or direct localized application of herbicides to noxious weeds within cultural resource site 

boundaries are not anticipated to have any adverse effects on cultural values, particularly plant 

species important to California Indian Basketweavers or other Native American gatherers within 

the SIA. 

 Removal of smaller diameter non-commercial timber (biomass) and standing dead trees within 

and adjacent to cultural resources through limited mechanical and hand cutting methods will have 

no adverse effect to cultural resources.

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 All slash, brush and other vegetation removed from within and outside of cultural resource site 

boundaries will be piled and burned outside of site boundaries thereby having no adverse effect to 

cultural resources.

 Use of existing and development of new water sources are not anticipated to affect the SIA. 

WILD AND SCENIC RIVERS

 No treatment actions will occur in Wild and Scenic Rivers or proposed Wild and Scenic River 

corridors. 

 Proposed treatments would not affect the free-flowing condition of any Wild and Scenic River.

 About 98% of the Rim Fire burned within the Tuolumne River watershed. 

 All proposed treatments are several miles from the main fork of the Merced Wild and Scenic 

River corridor and none are visible from anywhere along the river. 

 The remaining 2% of the Rim Fire burned in the North Fork Merced River watershed along the 

southern edge of the fire. The North Fork Merced is a main tributary to the Merced Wild and 

Scenic River. All proposed treatments are several miles from the Merced Wild and Scenic River 

corridor and none are visible from anywhere along the river. The limited amount of treatments in 

the North Fork Merced watershed will not affect the Merced Wild and Scenic River.

WILDERNESS

 For the purposes of this project, the generic term Wilderness includes the Emigrant Wilderness

and the Yosemite Wilderness. 

 No treatment actions will occur in designated Wilderness.

 Action alternatives will not cause long-term changes to Wilderness character, recreation 

opportunities or access.

Data Sources

SPECIAL INTEREST AREAS

 GIS shapefiles with the location of the Pacific Madrone SIA. 

 GIS Layers of the Stanislaus National Forest Basemap 2014.

 2009 GIS Ortho Photo layers. 

 Existing information from consultation with Indian Tribes, cultural resource records, historic 

archives, maps, and GIS spatial layers were used.

WILD AND SCENIC RIVERS

 Stanislaus National Forest GIS library

 Stanislaus National Forest: Forest Plan Wild and Scenic River Study (USDA 1991a) 

 Tuolumne Wild and Scenic River Plan (USDA 1988a) 

 Project GIS maps

WILDERNESS

 Stanislaus National Forest GIS Library

 National Visitor Use Monitoring (NVUM) data (USDA 2014c) 

 Project GIS maps

Special Areas Indicators

SPECIAL INTEREST AREAS

 SIA values are specific to each SIA and may include unique botanic, cultural, geologic, scenic, 

historic and memorial features. Pacific Madrone Botanic Area has unique botanic features and the 

Jawbone Falls Heritage Area has unique cultural features.

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WILD AND SCENIC RIVERS

 Wild and Scenic River Values: For a river to be eligible for Wild and Scenic River designation 

it must be free-flowing and, with its adjacent land area, must possess one or more outstandingly 

remarkable values (47 Federal Register 173, September 7, 1982; p. 39454-39461). ORVs are 

specific to each river segment and may include cultural, ecologic, fish, geologic, historic, scenic, 

recreation, wildlife or other. Table 3.12-1 shows the specific ORVs for the segments within the 

Rim Reforestation project.

Table 3.12-1 Outstandingly Remarkable Values and River Classifications for Wild and Scenic Rivers

River/Stream Segment Miles SCEN 

ORV

RECR 

ORV

GEOL 

ORV

FISH 

ORV

WDLF 

ORV

H/CR 

ORV

OTHR 

ORV

WILD 

CLASS

SCEN 

CLASS

REC 

CLASS

Tuolumne Yosemite - Early Intake 5 SCEN RECR GEOL WDLF H/CR S/E W 5

Tuolumne Early Intake - Cherry Creek 1 RECR WDLF H/CR S/E 1

Tuolumne Cherry Creek - Lumsden 4 SCEN RECR GEOL FISH WDLF H/CR S/E 4

Tuolumne Lumsden Area 4 SCEN RECR GEOL FISH WDLF H/CR S/E 4

Tuolumne Lumsden - Terminus 15 SCEN RECR GEOL FISH WDLF H/CR S/E W 15

Total Designated 29 24 4 1

Clavey 1 Bell Creek 7 SCEN H/CR ECOL 6 1

Clavey 2 Lily Creek 11 ECOL 9 2

Clavey 3 Bell/Lily - 3N01 5 FISH ECOL 5

Clavey 4 3N01 - Cottonwood Road 8 FISH WDLF ECOL 4 4

Clavey 5 Cottonwood Road - Tuolumne 16 SCEN RECR FISH WDLF ECOL 14 2

SF Tuolumne 2 MF Tuolumne - Tuolumne 2 SCEN OTHR 2

Total Proposed 49 33 16 0

Total 78 57 20 1

CLASS=Classification; FISH=Fish; ECOL= Ecologic; GEOL=Geologic; H/CR=Historic/Cultural; ORV=Outstandingly Remarkable Value; SCEN=Scenic; 

REC=Recreational; RECR=Recreation; S/E=Scientific/Educational; WDLF=Wildlife; WILD=Wild

WILDERNESS

 Wilderness Character: the degree to which the untrammeled, natural, undeveloped, and 

opportunities for solitude or primitive and unconfined recreation qualities of Wilderness are 

diminished. 

Special Areas Methodology by Action

SPECIAL INTEREST AREAS

 Pacific Madrone Botanic Area: A field visit revealed that Pacific madrone trees in the SIA

survived the Rim Fire. Analysis of effects to Pacific madrone trees from activities proposed in the 

Rim Reforestation project utilized existing data acquired primarily through past site monitoring 

and anecdotal information from botanists from other Forests. 

 Jawbone Falls Heritage Area: Utilizing previous archaeological inventories from past projects 

that meet current survey standards (1986 to present) nearly 78% of the proposed treatment areas 

were eliminated from further inventory. A strategy was developed to intensively survey (50 to 

100-foot interval spacing) the remaining treatment areas. The strategy is consistent with the 

Regional PA 2013 and the Rim PA 2014 (project record). 

WILD AND SCENIC RIVERS

 The geographic extent of this analysis for direct and indirect effects is river corridor boundary, 

one quarter-mile on either side of the high water mark of the rivers.

 The analysis for cumulative effects includes those effects within the river corridor and, given that 

nearly the entire project area drains to these rivers, cumulative effects of this project occur at the 

watershed scale. Chapter 3.15 (Watershed) displays potential cumulative watershed effects (e.g., 

sedimentation and other impacts to water quality).

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 The analysis of each alternative considers whether the activities would alter ORVs of the 

associated river segments. The short-term timeframe for this analysis is three to five years.

 The long-term timeframe for this analysis is ten years. 

 The temporal bounds of the analysis are generally dependent on the lasting effects of project 

activities. Short-term effects are impacts from project activities that are expected to last up to 5 

years. These would include disturbances associated with implementation of the proposed 

activities as well as impacts that would endure beyond implementation, up to 5 years. Long-term 

effects are those projected to endure beyond 5 years. 

WILDERNESS

 The geographic extent of this analysis is the area of the Wilderness that falls within 0.5 mile of 

project activities. Rim Reforestation project activities would occur on NFS land adjacent to the 

Wilderness. No project activities are planned in the Wilderness.

 The temporal bounds of the analysis are generally dependent on the lasting effects of project 

activities. Short-term effects are impacts from project activities that are expected to last up to 5

years. These would include disturbances associated with implementation of the proposed 

activities as well as impacts that would endure beyond implementation, up to five years. Longterm effects are those projected to endure beyond 5 years. 

Special Interest Areas: Affected Environment

Existing Conditions

JAWBONE FALLS HERITAGE AREA

The Jawbone Falls SIA was established in 2000. Consisting of 47 acres, the area was identified by the 

Tuolumne Band of Me-Wuk Indians as sacred and one of the most significant traditional cultural 

properties of the Central Sierra Me-Wuk people. At the time it was established, significant cultural 

values were identified through field surveys and consultation with Indian Tribes and other interested 

parties. The specific nature of the cultural resources is administratively confidential, under the 

provisions of the Archaeological Resource Protection Act of 1974, as amended (43 CFR 7). 

From the onset of the Rim Fire incident and continuing through the Rim Fire Recovery and Rim 

Reforestation efforts, the Forest Archaeologist consulted with the Tuolumne Band of Me-Wuk 

Indians regarding protection of traditional collection areas and sites significant to the Miwok people. 

Native peoples continue to utilize the Jawbone Falls SIA area for traditional gathering and will 

continue to do so. 

Historic records, maps and oral accounts encompassing the Jawbone Falls SIA boundary indicate 

moderate land use since the 1880s in the form of ranching/cattle grazing and railroad logging. Earliest 

records indicate a number of homesteads were patented near the area of Jawbone Falls mainly for 

acquiring title to valuable timber. However, as noted in the 1920 Stanislaus Land Classification Atlas, 

although timber “will be removed in time”, grazing would continue to be “the chief industry for some 

time to come.” Some of the existing trail/road system is likely connected to moving livestock to 

summer pasturage. Associated features affected by the fire include, fences, wooden troughs and 

collapsed wooden structures (range cabins). 

The West Side Lumber Company founded in 1899 did not reach the area of the SIA until the 1940s. 

As the company expanded to its easternmost timber tracts during this time period, timber in and 

around Jawbone Falls was harvested. Associated features affected by the Rim Fire event include 

railroad grades, cut and fill structures, donkey sets and associated equipment.

PACIFIC MADRONE BOTANIC AREA

The Pacific Madrone SIA consists of two small groves of Pacific madrone trees covering 15 acres. 

These are located along Road 1S13C in Packard Canyon and about 5 acres overlap a reforestation 

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Chapter 3.12 Stanislaus

Special Areas National Forest

unit. The management emphasis of this SIA is to protect and manage the unique botanical features for 

which it was designated, namely the southern-most groves of Pacific madrone in the Sierra Nevada. 

Resource activities such as fuels reduction and reforestation are allowed within the SIA provided the 

integrity of the SIA is protected (USDA 2010a). In recent years, discovery of young Pacific madrone 

trees and saplings outside of the SIA indicates madrone trees have been successfully reproducing and 

expanding their distribution in the vicinity.

The Pacific Madrone SIA occurs within an area which had not burned for more than 100 years. In the 

past, timber harvest occurred in the SIA, but more recently management activities have not taken

place. As a result, the understory became overgrown with regenerating conifers. The habitat within 

the SIA tends to be comparatively cool and damp owing to the northeast aspect and position in the 

bottom of a perennial stream drainage. Madrone trees in the SIA survived the Rim Fire likely due to 

the microclimate of the site. Additionally, it is possible fire burned through this area at night when 

fire activity was lower. Madrone trees outside the SIA did not fare as well; most reportedly sustained 

canopy mortality. Pacific madrone is known to resprout from the root crown after fire so many trees 

with canopy mortality will likely survive.

Special Interest Areas: Environmental Consequences

Alternative 1 (Proposed Action)

DIRECT AND INDIRECT EFFECTS

Jawbone Falls Heritage Area

Under Alternative 1, the potential direct and indirect effects to the Jawbone Falls SIA are minimal as 

proposed treatments within the SIA would be limited to small diameter non-commercial timber 

(biomass) and hazard trees approved by the Tribe that would enhance or protect those cultural values 

that make the SIA significant and unique. 

Additionally, Alternative 1 includes extensive use of herbicides within a variety of proposed 

treatments (i.e. reforestation site preparation, noxious weed eradication, and deer habitat 

enhancement). In all treatment areas application of herbicides would be accomplished through the use 

of backpack sprayers for direct localized application. In cases where noxious weeds are within 

cultural resource site boundaries the use of herbicides will only be allowed as long as it does not 

affect plant species important to California Indian Basketweavers or other Native American gatherers 

or cultural values contained within the SIA. In each case a Forest heritage specialist will be consulted 

prior to treatment within sites.

Cultural resource sites located within the boundaries of the SIA will be delineated with coded 

flagging and/or other effective marking i.e. “flag and avoid” for protection prior to project 

implementation as stipulated in the Program of Rim Fire Emergency Recovery Undertakings, 

Tuolumne County, California Programmatic Agreement (Rim PA, project record). 

Pacific Madrone Botanic Area

The existing madrone trees, saplings, and seedlings would be avoided during all implementation and 

no planting would be done adjacent to these trees. Forest Plan direction is to protect and promote 

these trees within this SIA. Reforestation work would only be done where activities could avoid these 

trees, and each tree or seedling would have a 25-foot no-planting buffer. Providing forest canopy 

would benefit the madrones in the long-term as providing adjacent forest would contribute to the 

cooler climate madrones thrive in. Additionally, establishing a conifer forest would minimize brush 

fields that would carry fire more readily. Therefore, minimal, to no, direct or indirect effects would 

occur to the Pacific Madrone SIA.

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Draft Environmental Impact Statement and Environmental Consequences

CUMULATIVE EFFECTS

Jawbone Falls Heritage Area

All projects listed in Cumulative Effects Analysis (Appendix B) have been or will be subject to 

NHPA Section 106 compliance and potential effects to cultural resources would be identified at that 

time following stipulations in the Rim PA (project record).

Alternative 1, when combined with the past, present and foreseeable future actions and events, shown 

in Appendix B, is not expected to cumulatively lead to increased impacts to the cultural values or 

cultural resources that make Jawbone Falls an SIA. 

Pacific Madrone Botanic Area

The direct and indirect effects of Alternative 1 are minimal and would not degrade the integrity of this 

SIA. Appendix B shows no other present or foreseeable future projects are planned for the SIA 

location. With minimal to no direct or indirect effects to the Pacific Madrone SIA and no foreseeable 

future actions, no cumulative effects occur under Alternative 1.

Alternative 2 (No Action)

DIRECT AND INDIRECT EFFECTS

Jawbone Falls Heritage Area

Under Alternative 2, the potential direct effects of the proposed treatments to the SIA are minimal. 

There would be no new or increased ground-disturbing activities in the areas of known cultural 

resource sites nor would the cultural values contained within the SIA be affected, therefore no direct 

effects occur with this alternative.

However, this alternative may have indirect effects to the cultural values and resources through 

inaction. The existing threat of fire-weakened non-commercial and smaller diameter trees falling 

naturally, and potentially damaging already fragile cultural resources, would continue. The actions 

presented in Alternatives 1, 3, 4 and 5 would further remove dense vegetation, biomass and hazard 

trees preventing damage to archaeological resources and therefore reduce the potential for ground 

disturbance to sites and associated cultural values within the SIA. 

Pacific Madrone Botanic Area

Alternative 2 has no direct effects; indirect effects may occur in untreated areas where falling dead 

trees damage madrone trees and saplings, or kill madrone seedlings. Once the trees fall they could 

block germinating madrone seeds, cause excess ground level shading for madrone seedlings and 

create high fuel accumulations, which could burn at high intensity causing madrone crown mortality 

and possibly killing madrone trees, saplings or seedlings. Non-reforested areas would initially come 

back to brush fields and be more susceptible to fire in the short term and not provide forest canopy for 

shade and cooling in the long term. 

CUMULATIVE EFFECTS

Jawbone Falls Heritage Area

This alternative, when combined with the past, present and foreseeable future actions are expected to 

cumulatively lead to a minimal increase of impacts to cultural values and resources. As stated above, 

Alternative 2 may have an indirect effect to these values where lack of treatments within and around 

cultural resource sites may increase the potential for ground disturbance and damage to site features 

and cultural values contained within the SIA. 

Pacific Madrone Botanic Area

Alternative 2 poses indirect effects to this SIA. Appendix B shows no other present or foreseeable 

future projects are planned for the SIA location. With indirect effects to the Pacific Madrone SIA and 

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no foreseeable future actions, the indirect effects described under Alternative 2 are the cumulative 

effects of Alternative 2.

Alternative 3

DIRECT AND INDIRECT EFFECTS

Jawbone Falls Heritage Area

The potential effects in Alternative 3 are similar to Alternative 1. As in Alternative 1, the potential 

direct and indirect effects to the Jawbone Falls SIA are minimal as proposed treatments within the 

SIA would be limited to those small diameter non-commercial timber (biomass) and hazard trees 

approved by the Tribe that would enhance or protect those cultural values that make the SIA 

significant and unique. Unlike Alternative 1, ground disturbing activity would substantially increase 

in Alternative 3 due to the absence of herbicide treatments. Increased ground disturbance through 

deep tilling, forest cultivation and hand grubbing, increases the chance to uncover previously 

unknown cultural resources where deposits are largely subsurface. As with any project, should 

heritage properties be located during implementation, activities will cease in the area and the District 

Archaeologist or designated individual will be notified immediately, which would lessen the 

likelihood of additional damage. 

Pacific Madrone Botanic Area

Same as Alternative 1.

CUMULATIVE EFFECTS

Jawbone Falls Heritage Area

All projects listed in Appendix B are subject to NHPA Section 106 compliance and potential effects 

to cultural resources would be identified at that time following stipulations in the Rim PA.

Alternative 3, when combined with the past, present and reasonably foreseeable future actions and 

events are not expected to cumulatively lead to increased impacts to cultural resources.

Alternative 3 would continue the recovery efforts started with the Rim Recovery project. The 

reforestation plan would lessen the effects of future wildfire on these sites, protect fragile resources 

and return the ecological setting or appearance to the time of the Native American presence, thus 

preserving those values that would make these sites significant and allow for future studies.

Pacific Madrone Botanic Area

Same as Alternative 1.

Alternative 4

DIRECT AND INDIRECT EFFECTS

Same as Alternative 1.

CUMULATIVE EFFECTS

Same as Alternative 1.

Alternative 5

DIRECT AND INDIRECT EFFECTS

Same as Alternative 1.

CUMULATIVE EFFECTS

Same as Alternative 1.

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Wild and Scenic Rivers: Affected Environment

One congressionally designated and two proposed Wild and Scenic Rivers lie within the Rim Fire 

perimeter. This includes all 29 miles of the designated Tuolumne Wild and Scenic River on NFS 

lands; the lower half of the Clavey Proposed Wild and Scenic River (24 miles); and, all of the South 

Fork Tuolumne Proposed Wild and Scenic River (2 miles). 

About 98% of the Rim Fire burned within the Tuolumne River watershed. The remaining 2% burned 

in the North Fork Merced River watershed along the southern edge of the fire. Table 3.12-2 displays 

the river segments affected by the Rim Fire.

Table 3.12-2 Wild and Scenic River Corridors Affected by the Rim Fire

Wild and Scenic River Classification Segments Total 

Miles1 Miles within Project Area

Total 

Acres1 Acres within Project Area

Clavey River Wild 3 33.0 16.2 10,560 4,822

Scenic 3 14.0 7.3 4,480 2,377

Tuolumne River Wild 3 24.0 21.5 7,680 6,050

Scenic 1 4.7 4.7 1,381 1,381

Recreational 1 1.0 0.6 320 96

South Fork Tuolumne River Scenic 1 2.5 2.5 681 681

1 Within NFS lands

Clavey Proposed Wild and Scenic River

The Clavey Proposed Wild and Scenic River includes 33 miles of Wild and 14 miles of Scenic 

segments, including its tributaries Bell Creek and Lily Creek. It was proposed for its free-flowing 

characteristics, abundance and quality of life zones and vegetation, elevation range, and relative 

remoteness and lack of development. The Rim Fire affected half (23.5 miles) of the 47 mile river 

corridor: 7.3 miles of Scenic classification and 16.2 miles of Wild classification are within the 

analysis area. The 5 miles of Wild segments within Wilderness were not affected by the Rim Fire. 

The primary ORVs of the Clavey River inside the Rim Fire perimeter include ecological, fish, scenic, 

wildlife, and recreation (USDA 1991a, p. 46-50) as described below. 

ECOLOGICAL

The Clavey River (including Bell and Lily Creeks) has a combination of landscape ecology features 

making it distinct within the Sierra Nevada Mountains: 1) free-flowing characteristics; 2) abundance 

and quality of life zones and vegetation; 3) elevation range; and, 4) relative remoteness and lack of 

development. 

The Clavey River is one of the longest remaining free-flowing streams in the Sierra Nevada. It is 47 

miles from source to mouth, including both headwater forks, Bell and Lily Creeks. Free-flowing 

condition is an important value because little remains in the Sierra Nevada. From the Feather River on 

the north to the Kern River on the south, all but one (the Consumnes) of the 15 major rivers in the 

Sierra, are impounded. Of 90 major tributaries, only four streams greater than 40 miles are freeflowing with no impoundments or diversions from headwaters to mouth. The Clavey River contains 

all but one Sierra Nevada life zone within its watershed. Elevation ranges from 1,200 feet at its mouth 

to 9,200 feet at its headwaters, allowing for all life zones except true alpine. At its headwaters, subalpine forests of red fir, lodgepole, western white pine and mountain hemlock combine with mountain 

meadows and granite-bound lakes. All forest habitats are found as elevation decreases, ending with 

the California chaparral type at the mouth of the river. Within the wide variety of high to low 

elevation vegetative types in the Clavey, one is truly unique: Bell Meadow, at 6,500 feet along Bell 

Creek, contains the largest stand of quaking aspen (110 acres) in the southern half of the Sierra.

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Another feature of the Clavey River is its minimal development. It is almost entirely under federal 

ownership; even the portions outside of Wilderness are relatively undisturbed and remote. Private 

lands and developments such as towns and roads line portions of most other rivers in the Sierra. The 

Clavey, although crossed by several roads, has remained relatively undisturbed because of its 

remoteness, rugged nature and its north-south geographic orientation. For much of its length, the 

Clavey runs perpendicular to the east-west trend of major roadways in its watershed.

FISH

The Clavey was one of the first streams in California to be designated as a Wild Trout Stream, 

representing a mid to low elevation trout stream in a remote location. It is also now designated as a 

state Heritage Trout Water (Watershed Report). 

Wild Trout streams provide self-sustaining trout fisheries which are not supplemented by hatchery 

stocking. It is believed that almost the entire basin contains only fish native to this portion of the 

Sierra Nevada. About 95 percent of the basin has an original fish assemblage. Rainbow trout is the 

only trout species in the basin (Lily Creek is reported to have some non-native brook trout and nonnative brown trout may spawn at the confluence with the Tuolumne River). Rainbow trout are found 

in all of the Clavey and its tributaries capable of supporting coldwater fish. 

The lower portion of the Clavey also contains a native assemblage of warm water fish including 

Sacramento suckers, Sacramento squawfish and hardhead. Due to extensive planting of non-native 

trout species and the illegal introductions of non-native warm water fish species, few other streams in 

the Sierra contain the original assemblage of fish species. The Clavey River may be the only 

"rainbow trout" river left, in the Sierra Nevada, with its original fish assemblage still intact and 

relatively unaffected by introduced species.

SCENIC

Outstanding Variety Class A landscape includes a deep, V-shaped, river-cut canyon through 

metasedimentary rock. The river provides a variety of water forms including rapids, cascades and 

pools. Vegetation patterns are varied, including scattered ponderosa pine and oak-grass woodland. 

The scenic values of the lower Clavey are similar to those of the lower Tuolumne Wild and Scenic 

River.

WILDLIFE

The intensity of the Rim Fire changed the structure and type of vegetation in the WSR corridor, 

which has likely changed wildlife presence there. Prior to the fire, fisher and spotted owl habitat 

existed within or adjacent to the northern portion of the WSR corridor, but much of it was burned in 

the Rim Fire and is no longer suitable. Peregrine falcon habitat, due to the rugged limestone cliffs, 

exists in the lower portion. Goshawk territories were present along the WSR corridor prior to the Rim 

Fire.

RECREATION

Hiking and fishing are the popular dispersed activities. Access is limited and portions are remote and 

wild, resulting in a rare opportunity for solitude and non-motorized recreation experiences, below the 

snow and available all year.

This portion of the Clavey has been traversed by expert kayakers. It is a native trout fishery, and a 

State designated Wild Trout Stream which is significant to anglers. Hiking and swimming are the 

popular activities near the Clavey confluence with the Tuolumne Wild and Scenic River. 

The Rim Fire burned with varying intensity along the one-half mile wide river corridor, consuming 

vegetation with a basal area loss of less than 50% in 17 miles of the corridor, and a basal area loss of 

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greater than 50% in the other 12 miles. Loss of vegetation has seriously altered the Scenic ORV of the 

river corridor and resulted in reduced visual diversity and wildlife habitat.

South Fork Tuolumne Proposed Wild and Scenic River

The South Fork Tuolumne Proposed Wild and Scenic River, located in the south-central portion of 

the Forest, includes the 2 mile Scenic segment from the Middle Fork Tuolumne River to the 

Tuolumne River. ORVs include scenic quality and other. There are no water-related ORVs for the 

South Fork (USDA 1991a, p. 51). 

SCENIC

Outstanding Variety Class A landscape includes a deep, rugged canyon. The river provides a variety 

of water forms including rapids, cascades, waterfalls, and pools. Rim of the World Vista, located 

above the river area on Highway 120 (Big Oak Flat route to Yosemite National Park), provides 

outstanding scenic views of the deep river canyon, all the way to its confluence with the Tuolumne 

Wild and Scenic River.

OTHER

“Other” areas are considered sensitive because they are fragile or nonrenewable. About 65% of the 

viewshed in the one-half mile wide river corridor is affected with a basal area loss of over 75% due to 

the Rim Fire. The remaining 35% of the river corridor viewshed sustained 25 to 75% basal area loss. 

Some randomly scattered and small (less than 1 acre) patches of less than 25% basal area loss exist 

along the corridor. Loss of vegetation severely compromised the scenic ORV for this river.

One electricity transmission line crosses over the river corridor and an aqueduct (tunnel) crosses 

under and parallel to the river corridor. Two un-numbered roads totaling about one-half mile access 

the transmission line in the river corridor.

Tuolumne Wild and Scenic River

The Stanislaus National Forest portion of the Tuolumne Wild and Scenic River includes 24 miles of 

Wild, 4 miles of Scenic, and 1 mile of Recreational segments. The river is located in the south-central 

part of the Forest. ORVs include fish, geologic, historic and cultural, recreation, scenic, scientific and 

educational, whitewater boating and Wilderness characteristics. These ORVs were listed in the 1979 

Tuolumne River Study EIS (USDA 1979). The study took place prior to the more detailed ORV 

descriptions that are used now for this type of assessment. However, the study described the reason 

behind choosing these ORVs as diverse habitat, several vegetation zones, steep-walled canyons, a 

significant variety of fisheries, remoteness, recreation opportunities, one of the finest whitewater 

boating opportunities in the nation, and many prehistoric and historic sites, including Miwok sites and 

evidence of gold rush history. 

Lumsden Road (1N10) runs 5.9 miles along the south and west sides of the river within the scenic 

corridor, crossing once at the Lumsden Bridge. Routes off the Lumsden road within the river corridor 

include the 0.1 mile 1S52, 0.1 mile 1N10A, and 0.2 mile 1N10E. Two hiking trails, 17E40 and 

17E56, run parallel to the river on the south side and are in a Wild classification segment of the river. 

One trailhead, one put-in for boating, 3 camping sites, and one gaging station are the only facilities 

within the Scenic segment of the river. Dispersed camping associated with boating occurs along the 

river west of Merals Pool.

The Rim Fire burned with varying intensity along the one-half mile wide river corridor, mostly 

consuming vegetation greater than 50% of the basal area. Because of steep canyon walls, an estimated 

10 to15 miles has a view from the river corridor where over 75% of the vegetation has been 

consumed. This is at both the west end of the river and the easterly end of the river. In areas where the 

corridor is flatter, about 19 miles have basal area consumption of 0 to 50%. Loss of vegetation has 

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seriously compromised the Scenic ORV of the river corridor, reduced visual diversity and wildlife 

habitat, and created an increased risk of soil erosion within the steep slopes of the canyon. 

The Tuolumne Wild and Scenic River was divided into eight segments for planning purposes, with 

boundaries between segments based on the types and levels of existing development, access, 

recreation opportunity, and the potential for classification as a unit separate from adjacent segments. 

Table 3.12-3 shows the eight segments, their length and classification.

Table 3.12-3 Tuolumne Wild and Scenic River Classifications

Segment Classification Length

(miles)

Yosemite to Early Intake Wild 5

Early Intake to Cherry Creek Recreational 1

Cherry Creek to Lumsden Area Wild 4

Lumsden Area Scenic 4

Lumsden Area to Clavey River Wild 4

Clavey River to Indian Creek Wild 3

Indian Creek to Mohican Mine Wild 6

Mohican Mine to Terminus Wild 2

Total 29

RECREATION USE(ALL RIVERS) 

Hiking and fishing are popular dispersed activities in all three river corridors. Access is limited due to 

topography and lack of roads. Rainbow Pool, just upstream of Highway 120, is a popular picnic and 

swimming area for day use visitors and the City of Berkeley Family Camp located upstream. The 

pool was also the location of an historic stagecoach stop and former resort. Whitewater boating 

(rafting and kayaking) is popular on the Tuolumne River. Expert kayakers have floated the Clavey.

At the confluence of the Tuolumne and South Fork are the popular Lumsden and South Fork 

campgrounds, which are accessed via the visually bracing and not-for-the-driving-challenged 

Lumsden Road. This area is also the put-in for the world famous class IV whitewater run on the 

Tuolumne. The Rim of World Vista on Highway 120 provides outstanding views of the precipitous 

drop of the South Fork all the way down to the main stem of the Tuolumne. 

Wild and Scenic Rivers: Environmental Consequences

Alternative 1 (Proposed Action)

DIRECT AND INDIRECT EFFECTS

Clavey Proposed Wild and Scenic River

Proposed actions adjacent to the proposed Wild and Scenic River boundary include a variety of 

treatments, including thinning existing plantations, understory burning, and reforestation. The vast 

majority of treatments near the Wild and Scenic River corridor are reforestation units. None of the 

ORVs are expected to be permanently affected by the proposed treatments, although smoke from 

burning could linger over the area for several days, potentially affecting Scenery in the short-term.

Scenic ORVs would improve over time as the reforested trees grow and add diversity to the 

landscape. The Wildlife ORV would be indirectly enhanced due to the beneficial effects of activities 

that target deer habitat enhancement, although the treatments would occur outside of the Wild and 

Scenic River corridor.

Though treatments would not occur within the corridor, there could be slight indirect impacts to 

aquatic biota in tributaries of the proposed Wild and Scenic River due to sedimentation and herbicide 

use, thus affecting the Fish ORV. Due to the spatial distribution of project units, measurable impacts 

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Draft Environmental Impact Statement and Environmental Consequences

in the Clavey River would likely be minimal; tributaries in those watersheds are more likely to be 

measurably affected

The other ORVs, Ecological and Recreation, would not be affected. The free flowing characteristic of 

the river would be maintained. Where project activities are proposed within sight distance of the 

proposed Wild and Scenic River, distance and geographic features would obscure most treatments 

from the casual observer or users of those areas.

South Fork Tuolumne Proposed Wild and Scenic River

Two treatment units are proposed immediately adjacent to the south of the proposed Wild and Scenic 

River boundary. The two units, a reforestation and a reforestation and thinning unit near Rim of the 

World and Colfax Spring, are located well above the river. Additional units proposed for thinning are 

located near the high point of the boundary to the south. As these are located well above the river and 

outside the boundary, impacts are not expected to occur to the scenic ORV of this river. Where 

project activities are proposed within sight distance of the proposed Wild and Scenic River, distance 

and geographic features would obscure most treatments from the casual observer or users of those 

areas. Scenic ORVs would improve over time as the reforested trees grow and add diversity to the 

landscape.

Tuolumne Wild and Scenic River

No treatment units are proposed immediately adjacent to the Wild and Scenic River boundary. A 

cluster of units are located to the south, approximately half a mile from the southern boundary and to 

the north of Highway 120. These units are proposed for reforestation and thinning. Due to their 

location, the ORVs of geologic, historic and cultural, recreation, scenic, scientific and educational, 

whitewater boating and Wilderness characteristics would not be affected. Due to the spatial 

distribution of project units, measurable impacts in the Tuolumne to the fish ORV would likely be 

minimal. Tributaries in those watersheds are more likely to be measurably affected.

CUMULATIVE EFFECTS

Ongoing or recent past actions within Wild and Scenic River corridors include salvage harvest, road 

maintenance and removal of hazard trees. Vegetation management is proposed to occur along 

powerlines in the Tuolumne Wild and Scenic River corridor. The scenic quality of the Clavey has 

been degraded due to the fire intensity in that area and temporary drift smoke from burning could 

contribute to short term degradation of the scenery ORV in site specific areas. However, effects from 

drift smoke would be minor and not long-lasting. No cumulative effects are expected to the other 

ORVs of the designated or proposed Wild and Scenic Rivers. 

Alternative 2 (No Action)

DIRECT AND INDIRECT EFFECTS

Since no actions are proposed, Alternative 2 would not affect ORVs for any of the proposed or 

designated Wild and Scenic Rivers. 

CUMULATIVE EFFECTS

There are no direct or indirect effects, so there are no cumulative effects.

Alternative 3

DIRECT AND INDIRECT EFFECTS

Same as Alternative 1.

CUMULATIVE EFFECTS

Same as Alternative 1.

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Alternative 4

DIRECT AND INDIRECT EFFECTS

Clavey Proposed Wild and Scenic River

The units adjacent to the proposed Wild and Scenic River boundary are composed mainly of early 

seral forest treatment units. The presence of smoke from burning could temporarily affect scenery in 

these locations, but would not permanently alter this ORV. Only 50% of the complex early seral 

forest units would be burned within a moderately long fire return interval (10 years), so effects would 

be minor. No long term effects are expected.

A few natural regeneration units and potential founder stand planting units are proposed to the east of 

the proposed Wild and Scenic River corridor. Site preparation and plant and release treatments could 

be used in the natural regeneration units if results are not achieved in five years. Proposed founder 

stands are small in nature. These units are outside of the proposed Wild and Scenic River boundary 

and treatments would not affect scenery. 

The other ORVs for this proposed Wild and Scenic River are not expected to be affected by treatment 

actions (refer to 3.15 Watershed for effects to tributaries). Although early seral forest exists within the 

corridor, no treatments to these units are proposed during the life of this project. 

South Fork Tuolumne Proposed Wild and Scenic River

Less than ten treatment units are located near or adjacent to the proposed Wild and Scenic River 

boundary, and are composed of early seral forest treatment units. The ORV of scenery could be 

temporarily affected by smoke but would not permanently alter this ORV. Only 50% of the complex 

early seral forest units would be burned within a moderately long fire return interval (10 years), so 

effects would be minor. No long term effects are expected. 

Tuolumne Wild and Scenic River

Treatment units adjacent to the Wild and Scenic River are early seral forest units. Effects to the 

scenery ORV are similar to the Clavey Proposed Wild and Scenic River. The ORVs of geologic, 

historic and cultural, recreation, scientific and educational, whitewater boating, fish and Wilderness 

characteristics would not be affected. 

CUMULATIVE EFFECTS

Effects to scenery due to smoke would be similar to Alternative 1, but less since there are few units 

located adjacent to WSR boundaries, and because the fire interval would be so long in nature. There 

would be no cumulative effects to the other ORVs. 

Alternative 5 

DIRECT AND INDIRECT EFFECTS

Effects to scenery on all designated and proposed WSRs due to smoke would be similar to 

Alternative 1, although since fire would only be used in existing plantations, smoke would be less 

than in the other action alternatives. The differences in spacing prescriptions would not affect the 

ORVs.

CUMULATIVE EFFECTS

Same as Alternative 1.

Wilderness: Affected Environment

The Emigrant Wilderness is located in Tuolumne County. It is characterized by large expanses of 

bare, glaciated granite and sub-alpine vegetation types, numerous glacial lakes, high quality scenery 

and Wilderness recreation opportunities. It is bordered on the east by Toiyabe National Forest and 

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Draft Environmental Impact Statement and Environmental Consequences

Yosemite National Park. The Emigrant Wilderness became part of the National Wilderness 

Preservation System in 1975. The California Wilderness Act of 1984 added 5,855 acres to the original 

area, bringing it to its current size of 113,000 acres. Most of the recreation use in the Emigrant 

Wilderness Area is for hiking, camping, backpacking, and horse-back riding; pack-stock are also 

commonly used. Fishing is popular at most lakes, but hunting use is light. 

Commercial livestock grazing occurs in some areas. Tungsten mining in the Snow Lake area has 

occurred in the past. Portions of several streams which are eligible for Wild and Scenic River 

designation and include Kennedy Creek (proposed Wild and Scenic River), Relief Creek South Fork 

Stanislaus River, Buck Meadow Creek, Summit Creek, and the Cherry Creek system.

A majority of Wilderness recreation use occurs from early July through early September. Kibbie 

Ridge Trail can be an exception because of exposure to summer sun and heat. Recreation use does 

occur outside of the peak times, but visitation is considerably lower due to weather, access, school 

schedules, and deer hunting season. Because of the popularity of equestrian activities the Aspen 

Meadow and Kennedy Pack Stations operate under Outfitter and Guide Special Use Permits to 

provide horseback riding and pack and saddle service to Wilderness visitors.

The Emigrant Wilderness is contiguous with Yosemite Wilderness to its south. Most recreation 

within the area originates from the Kibbie Ridge and Lake Eleanor Trail Heads. Popular destinations 

from these trail heads include Eleanor and Kibbie Lakes in Yosemite National Park (Wilderness). 

(USDA 2014) 

Wilderness: Environmental Consequences

Alternative 1 (Proposed Action)

DIRECT AND INDIRECT EFFECTS

Alternative 1 proposed treatment units do not occur within the Wilderness. Actions within a mile of 

the Wilderness boundary include thinning and reforestation to the south and southwest. A 

reforestation unit is located within 0.5 mile of the Wilderness boundary, and the nearest deer 

broadcast burn is over 2 miles to the southwest.

Herbicides and Noxious Weed Eradication

Herbicide use and noxious weed eradication activities would not affect Wilderness character.

Reforestation

Reforestation units are located within a mile of the Wilderness boundary. Planting work would be 

done by hand and on foot, and is not expected to affect Wilderness character. Some mechanical 

preparation work would occur, including the use of feller bunchers, excavators, and saws. Visitors 

near the Wilderness boundary would be able to hear the sights and sounds of these activities. 

However, as they travel farther into the Wilderness the noise would become reduced.

Thinning

In the geographic extent, visuals (project activity), noise and dust produced during ground based 

activities may negatively disrupt the solitude qualities of Wilderness character. The sounds of 

chainsaws may be audible until visitors travel further into the interior. These effects are expected to 

be short term and only persist near the Wilderness boundary. Some visitors may temporarily change 

their activities and destination, particularly those who want to camp near the boundary. The 

untrammeled, natural and undeveloped qualities of Wilderness character would not be affected. 

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Understory Burning

Wilderness visitors may be able to see and smell smoke from high points or vistas within the 

Wilderness. However, due to the distance from the proposed units, this is not anticipated to negatively 

affect Wilderness character.

CUMULATIVE EFFECTS

Anticipated and reasonably foreseeable activities occurring in the Wilderness and near the boundary 

include road and trail maintenance, visitor use monitoring, campsite rehabilitation and fire 

suppression. The Reynolds Creek Ecological Restoration project, occurring to the east, includes 

thinning and burning. Most visitors expect to see increased presence of humans near boundary and 

transition areas. When considered with other activities occurring in the area, implementation of 

Alternative 1 activities are not expected to have a cumulative long term effect on Wilderness

character. 

Alternative 2 (No Action)

DIRECT AND INDIRECT EFFECTS

Under Alternative 2, no treatments would occur. Choosing Alternative 2 would not impact the 

outstanding opportunities for solitude, untrammeled, natural and undeveloped or primitive and 

unconfined qualities of Wilderness character.

CUMULATIVE EFFECTS

There are no direct or indirect effects, so there are no cumulative effects.

Alternative 3

DIRECT AND INDIRECT EFFECTS

Same as Alternative 1.

CUMULATIVE EFFECTS

Same as Alternative 1.

Alternative 4 

DIRECT AND INDIRECT EFFECTS

Alternative 4 would propose no other treatment units except for several complex early-seral forest 

units (prescribed burning) directly adjacent to the Wilderness boundary on the southern end. The 

presence of smoke could temporarily bother Wilderness visitors depending on prevailing winds. 

Depending on the length of time for burning, presence of large fuels smoldering, and atmospheric 

stability, smoke could linger for a few days. Some visitors may alter their plans and choose different 

routes of travel. However, since only 50% of the complex early-seral forest units would be burned in 

a moderately long fire return interval (10 years), smoke effects would be minor. No long term effects 

are expected.

CUMULATIVE EFFECTS

Same as Alternative 1.

Alternative 5

DIRECT AND INDIRECT EFFECTS

Same as Alternative 1.

CUMULATIVE EFFECTS

Same as Alternative 1.

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Draft Environmental Impact Statement and Environmental Consequences

Summary of Effects Analysis across All Alternatives

Special Interest Areas

JAWBONE FALLS HERITAGE AREA

For all action alternatives, any proposed treatment measures within the Jawbone Falls SIA would be 

limited to those trees approved by the Tribe that would enhance or protect those cultural values that 

make it significant and unique. Anticipated effects for Alternatives 3, 4 and 5 are the same as 

Alternative 1. There are no anticipated direct effects and minimal indirect and cumulative effects to 

cultural resources under Alternative 2 (No Action), as no project activity would occur. 

PACIFIC MADRONE BOTANIC AREA

Under Alternatives 1, 3, 4 and 5, no direct, indirect or cumulative effects are expected in the Pacific 

Madrone SIA. Indirect effects under Alternative 2 include damage from falling trees.

Wild and Scenic Rivers

With the exception of minor, short-term impacts to the scenic quality from drift smoke, none of the 

alternatives are expected to change the free-flowing quality of any of the designated or proposed Wild 

and Scenic Rivers. Maintaining high water quality is also needed to maintain Wild and Scenic values. 

Management requirements minimize water quality impacts in all of the action alternatives. ORVs of 

each river are expected to be unchanged in each alternative.

Wilderness

Wilderness character is not expected to change or diminish from project activities. Short-term, minor 

effects to solitude could occur from the sights and sounds of workers or equipment; however, this 

would be limited to the areas near the Wilderness boundary where most visitors have expectations of 

encountering people and activity. The presence of drift smoke could obscure views and temporarily 

change the unconfined nature of the Wilderness experience, but this is expected to be minor and not 

cause long-term effects. Most activities would take place outside the regular Wilderness use season.

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Draft Environmental Impact Statement and Environmental Consequences

3.13 VEGETATION

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction

The National Forest Management Act of 1976, Sec. 4. (d)(1), states that “It is the policy of 

Congress that all forested lands in the National Forest System shall be maintained in appropriate 

forest cover with species of trees, degree of stocking, rate of growth and conditions of stands 

designed to secure the maximum benefits of multiple use sustained yield management in accordance 

with land management plans.” Furthermore, the Act requires that “All national forest lands treated 

from year to year shall be examined after the first and third growing seasons and certified ... as to 

stocking rate, growth rate...Any lands not certified as satisfactory shall be returned to the backlog and 

scheduled for prompt treatment” (NFMA 1976). 

The Forest Service Land Management Planning Handbook (FSH 1909.12) shows the vision for 

ecosystems is to have ecological integrity and adaptive capacity. The handbook states: “Ecosystems 

have integrity when their composition, structure, function, and connectivity are operating normally 

over multiple spatial and temporal scales” (USDA 2015b, p. 58). The handbook provides the 

following definitions, which are provided here for reference and clarification (USDA 2015c). 

 Adaptive capacity: The ability of ecosystems to respond, cope, or adapt to disturbances and 

stressors, including environmental change, to maintain options for future generations. As applied 

to ecological systems, adaptive capacity is determined by genetic diversity of species, 

biodiversity within a particular ecosystem, and heterogeneous ecosystem mosaics as applied to 

specific landscapes or biome regions.

 Ecological integrity: The quality or condition of an ecosystem when its dominant ecological 

characteristics (for example, composition, structure, function, connectivity, and species 

composition and diversity) occur within the natural range of variation and can withstand and 

recover from most perturbations imposed by natural environmental dynamics or human influence. 

Forest Service Region 5 developed guidelines for ecological restoration to help retain and restore 

forest resilience and provide a sustainable ecosystem from a broad range of services to humans and 

other organisms (USDA 2011a). Within the Region 5, three major drivers of change have been 

identified: climate change, shifting hydrologic patterns, and increasingly dense unhealthy forest 

coupled with rapidly growing human populations. Ecological restoration will be the core objective 

used to promote an all lands approach to restoration. Vegetation and fire management will support the 

development of biodiversity and ecological processes before and after fire disturbance, and ensure the 

retention of forest resources over the long term. This approach will promote activities that include the 

following: 

 Reforesting after wildfire and implementing suitable stand maintenance activities that meet 

project goals and site conditions. 

 Forest thinning and prescribed fire to decrease fuel loading and increase forest heterogeneity. 

 Providing wildlife and plant habitat for threatened and endangered species.

Forest Plan Direction (USDA 2010a) provides broad management goals and strategies that address 

problems related to old forest ecosystems and associated species (p. 11). These goals and strategies 

include: 

 Increasing the frequency of large trees, increasing structural diversity, and improving the 

continuity and distribution of old forests across the landscape. 

 Restoring forest species composition and structure following large scale, stand-replacing 

disturbance events.

 Restoring ecosystems across all land allocations following large-scale catastrophic disturbance 

events.

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Forest Plan Direction (USDA 2010a) outlines management practices that are actions that achieve the 

goals and objectives of the Forest Plan (p. 17-32). Actions applicable to the Rim Reforestation project 

include: 

 All activities necessary to reestablish desirable tree species by artificial methods on deforested 

areas. Minimum standards for reestablishment are contained in the Regional Standards. Activities 

included in this practice are: preparation of the seed bed or planting site; planting seedlings or 

direct seeding; saving natural regeneration; animal, insect, and disease control when necessary; 

and examinations, evaluation, certification, and monitoring of stands to achieve the 

reestablishment objectives.

 Activities necessary to reduce the effect of competing vegetation, animals, insects, and disease on 

the growth and development of desired tree species. 

 Removal of surplus trees in areas with excess stocking by cutting, mowing, or herbicide injection 

to favor potential crop tree growth and development. Excess trees thinned do not have a 

commercial value because of tree size, species comparison, or access to available markets.

 Removal of trees in stands of less than rotation age to periodically reduce the stocking level to a 

point where the stand will grow back to 90% of normal stocking as indicated in-yield tables 

within a specified time period. There are no minimum or maximum treatment area sizes. This 

cutting method applies to stands on all forest types which carry stocking in excess of desired 

amounts. 

Forest Plan Direction (2010a) outlines forestwide standards and guidelines that provide management 

direction applying to all Forest lands (p. 33-64). Specific standards and guidelines that are applicable 

to the Rim Reforestation project include: 

 Maintain the species composition of the major forest types existing where projects occur.

 Promote shade intolerant pines (sugar and ponderosa) and hardwoods. 

 Where possible, create openings around existing California black oak and canyon live oak to 

stimulate natural regeneration. 

 Retain the mix of mast-producing species where they exist within a stand. 

Forest Plan Direction (2010a) outlines direction and standards and guidelines that apply to specific 

management areas (p. 65-164). Management areas applicable to the Rim Reforestation project 

include: Wildlife (p. 123-127) and General Forest (p. 161-164). Direction and standard and guidelines 

for these management areas are the same:

 Reforest all openings in available, capable, and suitable lands for timber production created by 

timber harvest, wind, fire, or insect and disease pests.

 Preparation of sites for artificial or natural stand reestablishment will be completed sufficiently in 

advance of planting or natural seeding to provide control of competing vegetation. Normally 

control of competing vegetation will be designed to ensure prescribed first year survival of 

planted or natural seedlings. This will often involve more than one treatment on more than one 

competing species prior to planting. It may involve a variety of techniques including fire, 

mechanical bunching and shredding, discing, and pesticides. Pest management will be considered 

as necessary.

 Natural seeding or planting will be done with tree species, seed zones, and elevations determined 

to be appropriate through a silvicultural examination and prescription. 

 Reduce the effect of competing vegetation on the growth and development of desired species on 

lands available, capable, and suitable for timber production. 

 Release efforts will only be done after appropriate stand examination and prescription. The 

objective will be to treat stands before brush or undesired hardwood densities reach 10,000 cubic 

feet per acre. Ideally competing vegetation will be treated while seedlings and sprouts from this 

vegetation are small and easily treated by a variety of techniques. Often this will be within two or 

three years after site preparation. On plantations five years or older where conifers are established 

over most of the site, the objective will be to treat competing vegetation based on the actual 

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growth and development of the tree stand. Brush and undesired vegetation will be treated where 

the conifer stand is not meeting site objectives for growth and it is apparent that competing 

vegetation is the cause. A variety of techniques including mechanical piling, and shredding, hand 

grubbing and herbicides may be used.

 Remove surplus trees on available, capable, and suitable lands with excess stocking. This will be 

done to favor growth and development of potential crop trees, prevent disease and insect 

outbreaks, or meet other resource objectives.

 Pre-commercial thinning is a tool that will be used to maintain diversity by improving species 

composition in many stands. A variety of techniques may be used including mechanical, 

crushing, piling, shredding, hand cutting, and pesticides. 

 Design cutting methods to obtain specific management objectives for late successional 

Management Indicator Species (MIS habitat)

Effects Analysis Methodology

Assumptions Specific to Vegetation

 Plot data, field observations, and severity mapping are representative of the project area. Severity 

mapping measures the fire severity present at about 30 days after fire containment; however, it 

does not measure the effects of drought and insects that can occur after images are processed.

 Region 5 CALVEG cover types conifer (CON) and mixed hardwood-conifer (MIX) represent 

suitable and productive forestland.

 Post-fire conditions assume the Rim Fire Recovery project and Rim Fire Hazard Tree project are 

fully completed or will be completed prior to Rim Reforestation treatment activities.

 Examples of post-fire reforestation and secondary succession are representative of the Rim 

Reforestation project area. Most of the examples are taken from neighboring projects or other 

areas of the Sierra Nevada; therefore, this is a reasonable assumption. 

 Current and recent climate conditions provide a reasonable baseline for this analysis time frame 

(about 60 years). Temperatures in the Sierra Nevada have become incrementally warmer since the 

1960s (Thorne et al. 2008) and are expected to continue warming (Safford et al. 2012). This 

analysis assumes this trend will continue, but not to an extent that loss of habitat suitability over 

the next 50 to 60 years would be significant. In other words, no dramatic shifts in vegetation 

would occur beyond what has or is currently being observed. Tree competition-related thresholds

of stand density are still applicable as they relate to insect, disease and drought.

Data Sources

 Survival exams from the Mi-Wok and Groveland Ranger Districts covering 4,966 acres of 

plantations established in the 1980s and 1990s. 

 Field observations and plot data. Two datasets were developed to assess post-fire conditions. 

From 2014 to 2015 field crews conducted walkthroughs of each proposed unit noting operability; 

need for reforestation, thinning, and fuels reduction; and, post-fire response of shrubs and other 

herbaceous vegetation. Fixed area circular plots (50th-acre), distributed on a systematic random 

grid (656 feet by 656 feet) were used to collect information about : natural regeneration, 

competing vegetation cover, distance to potential seed source, and whether or not the plot had 

been impacted by post-fire mechanical operations. Complete details about the plot sampling 

protocol are available in the project record.

 Common stand exam (CSE) data collected in the Rim Fire perimeter. Data downloaded from the 

Natural Resources Management Natural Resource Information System (NRM NRIS) Field 

Sampled Vegetation Database (FSVeg). A total of 843 CSE plots were collected between 2005 

and 2013 (prior to the 2013 Rim Fire). 

 California Wildlife Habitat Relationships (CWHR, CDFW 2014b) and CALVEG cover types

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 GIS data including: Rapid Assessment of Vegetation Condition (RAVG) analysis mapping, 

Worldview Imagery, Soil Survey Geographic (SSURGO) database for the STF, land allocations, 

project unit boundaries and road treatments

Vegetation Indicators

Indicators provide a relative measure of the direct and indirect effects to changes in forest vegetation 

due to project alternatives. They are intended to respond to the agency vision of promoting ecological 

integrity and adaptive capacity (USDA 2015b; USDA 2015c). 

TREE SIZE AND SPECIES COMPOSITION

 Average tree diameter at breast height (dbh) at years 10, 20 and 60.

 Average tree height at years 10, 20 and 60.

 Percent trees per acre by species, in particular shade-intolerant pine (sugar and ponderosa) and 

hardwoods. 

 Relative change in abundance of understory vegetation (shrubs, grasses and forbs). 

Tree size influences many different aspects of forest ecosystems. This is especially true for large 

trees, which contribute disproportionately to reproduction (van Wagtendonk and Moore 2010), are 

critical wildlife habitat features (North et al. 2000; Zielinski et al. 2004), and contribute to fire 

resiliency (Agee and Skinner 2005; Brown et al. 2004; van Mantgem et al. 2011). The number of 

trees per acre is used to describe the recovery of tree density, forest structure and habitat. It provides a 

basis for comparing the direct and indirect effects to species composition, which is important in 

assessing forest health and resiliency. Species composition is also an important component of wildlife 

habitat and strongly influences ecosystem processes and functions (Tilman et al. 1997; CREP 2008). 

STAND DENSITY INDEX

 Years until tree densities reach or exceed the stand density index (SDI) zone of increased bark 

beetle-related mortality (SDI of about 230 or about 45% of maximum SDI) and the bark beetle 

induced maximum SDI of 365. 

Tree density influences the dynamics of vegetation competition, tree growth and forest health. SDI is 

an age and site productivity-independent measure of density. SDI is used to evaluate forest health and 

vigor in terms of resiliency of trees to drought, insects and disease. In general, higher stand densities 

predispose trees to damage or mortality. Bark beetles and disease agents are often more damaging at 

high densities and also limit diameter growth. Densities below 55 to 60% of the maximum SDI level 

provide for reduced density-related mortality and relatively high vigor (Oliver 1995; Long and Shaw 

2012). According to Oliver (1995) and Oliver and Uzoh (1997) ponderosa pine stands, especially 

plantations, start to show increased bark beetle-related mortality at SDIs above 230 (about 45% of 

maximum SDI). They also suggest the possibility of a bark beetle induced maximum SDI of 365, 

though they state that outbreaks often reduce stand density to levels well below that SDI.

FUTURE MANAGEMENT FEASIBILITY

 Years until stand densities near or exceed the threshold of imminent competition-related mortality 

(SDI of about 260 or 50% of maximum; Long and Shaw 2012) and can produce at least 2,000 

board feet per acre if thinned to SDI 170 (about 35% of maximum). 

An obvious effect of regenerating conifer forests is the future ingrowth of small trees and 

accumulation of surface fuels (e.g., tree litter and shrub cover). Even in the absence of coniferous 

trees, vegetative biomass will accumulate over the next several decades and contribute to fuel loading 

in the absence of fire. This is evident in historical records, which indicate that fire played an essential 

role in moderating shrubs, tree regeneration and tree development even with low overstory tree 

densities (Collins et al. 2015; Show and Kotok 1924; Sudworth 1900). Furthermore, shrub cover is a 

good predictor of fire behavior (Lydersen and North 2012; van Wagtendonk et al. 2012), and can 

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contribute to high-severity fire (Harris and Taylor 2015; Lydersen et al. 2014). Today, prescribed 

burning and managed wildfire are faced with numerous operational and social constraints that limit 

their use in effectively reducing hazardous fuels and maintaining natural processes (Quinn-Davidson 

and Vaner 2012). An important alternative to fire has been the use of mechanical thinning to reduce 

ladder and canopy fuels through the removal of trees and other vegetation (Graham et al. 1999; 2004). 

To create resilient stands, however, mechanical thinning is more effective when accompanied by 

reduction in surface fuels either by prescribed surface fire or piling and burning (Agee and Skinner 

2005; Reinhardt et al. 2008). Therefore, we are faced with the reality that effective suppression and 

containment of wildfire is more likely with the complementary use of both mechanical thinning and 

prescribed fire (North et al. 2015). Although the focus is often set on the costly removal of smalldiameter trees and surface fuels, such costs can be offset through the necessary removal of some 

merchantable intermediate sized trees to maintain low canopy bulk density and open stand conditions, 

as well as accelerate development of large trees (Moghaddas and Craggs 2007; North et al. 2009). It 

stands to reason then that management feasibility would improve if increasing fuel loads and stand 

densities are balanced with larger trees that can at least partially offset operational costs when 

thinned. 

CHANGE IN FOREST STRUCTURE

 Change in the proportion of forest successional classes.

The Rim Fire changed vegetation conditions across the project area. The fire killed and injured trees 

and shrubs, which changed forest structure and habitat. Treatments have the potential to change postfire forest structure and resulting habitat. This analysis uses the Region 5 CALVEG classification 

system to evaluate changes in forest successional stages.

The CALVEG system conforms to the upper levels of the National Vegetation Classification 

standards hierarchy. This analysis used the CALVEG vegetation cover type to identify a general 

distinction between broad vegetation types: conifer (including mixed hardwood and conifer), 

hardwood, shrub, grass, barren and other life form classifications. The primary focus of this analysis 

is the conifer and mixed hardwood-conifer cover types. Within these two conifer-dominated cover 

types, CWHR vegetation type, size class and density were used to describe forest structure. Table 

3.13-1 shows size classes 0 to 2 are usually indicative of young trees, habitat best described as 

dominated by seedlings and saplings. Larger size classes are often interpreted as “old” or “mature” 

forest. Large size classes can take 40 to 150 years to develop. Multilayered forest provides a variable 

tree structure; both large and medium trees are present with saplings or small trees. These multistory 

forests develop in a variety of ways; however, the large tree component takes the longest to develop.

Table 3.13-1 California Wildlife Habitat Relationship (CWHR) size classes

CWHR Size Description Diameter at Breast Height

1 Seedling Less than 1 inch

2 Sapling 1 to 6 inches

3 Pole 6 to 11 inches

4 Small tree 11 to 24 inches

5 Medium/Large Tree Greater than 24 inches

6 Multilayered Size 5 over size 4 or 3; total tree crown closure greater than 60%

Table 3.13-2 shows density of forest cover is expressed in terms of tree canopy cover. Dense forest 

cover can develop in as little as 10 years when dominated by small trees; or take hundreds of years 

when dominated by large trees. 

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Table 3.13-2 California Wildlife Habitat Relationship (CWHR) density classes

CWHR Density Description Canopy Cover

blank or X No cover, definite forest habitat Less than 10%

S Sparse cover 10% to 24%

P Open cover 25% to 39%

M Moderate cover 40% to 59%

D Dense cover Greater than 60%

In a bioregional assessment for natural range of variability, Safford (2013) provides an estimate of 

historic landscape variability based on LANDFIRE biophysical settings (BpS) state and transition 

models. The BpS represent the vegetation that may have been dominant on the landscape prior to 

Euro-American settlement and is based on the current biophysical environment and an approximation 

of the historical disturbance regime, but with the current climatic conditions (LANDFIRE 2009). 

Reference landscape forest structure is described using five successional classes (seral stage) for 

yellow pine and mixed conifer (YPMC) forests in the Sierra Nevada: early successional, mid 

successional (open and closed canopy and late successional (open and closed canopy). Early 

successional is described as vegetation not dominated by trees greater than 4 inches dbh, which

includes areas dominated by herbaceous plants, shrubs, seedlings and saplings. Open canopy for mid 

and late successional stages is defined as less than 40 to 50% canopy cover and closed canopy is 

greater than 40 to 50% canopy cover. Mid successional stages are defined by trees 5 to 21 inches dbh 

and late successional stages are defined by trees greater than 21 inches dbh. These definitions are 

quite similar to the CWHR size and density classes; therefore, this analysis adapted the CWHR size 

and density classes shown in Table 3.13-3 to these successional classes for comparison to reference 

forest landscape structure. 

Table 3.13-3 Adaption of CALVEG and CWHR to Forest Successional Classes

Forest Successional Class1 CALVEG Cover Type CWHR 

Size

CWHR 

Density

Historic Forest 

Landscape

Early Conifer and mixed hardwood-conifer 2 or less ALL 15 to 20% 

Mid seral open canopy (mid-open) Conifer and mixed hardwood-conifer 3 and 4 S, P 20 to 30%

Mid seral closed canopy (mid-closed) Conifer and mixed hardwood-conifer 3 and 4 M, D 5 to 15%

Late seral open canopy (late-open) Conifer and mixed hardwood-conifer 5 and 6 S, P 25 to 45%

Late seral closed canopy (late-closed) Conifer and mixed hardwood-conifer 5 and 6 M, D 5 to 20%

1 As defined by Safford (2013)

VegetationMethodology by Action

The methodology for evaluating effects on vegetation is based upon assessing changes to vegetation 

following the Rim Fire and the associated timber salvage, hazard tree abatement and fuels reduction 

work. The analysis evaluates cumulative changes in vegetation composition, growth and structure 

caused by the project activities as well as the Rim Reforestation project. Changes in vegetation are 

assessed post treatment and over a 60-year time frame. This temporal scope was selected because the 

impacts to seedling survival and growth, species composition and forest structure at a given location 

can accumulate over time from different activities or events. The analysis compares effects found in 

scientific literature to the effects experienced with similar treatments on the STF. 

DIRECT AND INDIRECT EFFECTS

Unless otherwise specified, the analysis area used to analyze the direct and indirect effects on forest 

vegetation is 41,933 acres and includes only NFS lands within the Rim Fire perimeter. The analysis 

area is based on the Rim Reforestation project treatment unit area where project activities would 

impact forest vegetation. It includes 26,009 acres of reforestation activities (including natural 

regeneration and deer habitat enhancement with reforestation), 13,934 acres of prescribed fire with 

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thinning and 1,990 acres of prescribed fire only for deer habitat enhancement. The analysis 

encompasses hardwood forest, chaparral, grasslands and riparian vegetation; however, given the 

administrative and ecological setting of the affected environment, as well as the purpose and need of 

the project, the analysis primarily focuses on coniferous forest.

CUMULATIVE EFFECTS

Cumulative effects on vegetation are analyzed at the project scale. Vegetative cumulative effects are 

additive. That is they are the total of changes of proposed treatments to vegetative structure. The 

project scale analysis allows for comparison of changes that are occurring as a result of the past, 

present, and reasonable foreseeable projects across several large watersheds. Changes in coniferous 

forest have the greatest potential for cumulative effects on conifer establishment, species composition 

and forest structure. Although the cumulative effects analysis focuses on the project scale, the effects 

of the project on landscape forest structure are sometimes discussed inside of the larger Rim Fire 

landscape (257,314 acres); however, evaluation of vegetation change beyond the project scale is 

limited and outside the scope of this analysis.

ANALYSIS

Natural regeneration is proposed in some treatment units. Natural regeneration in these units would be 

monitored to assess the need to for release, alter species composition, or if necessary, conduct site 

preparation and planting. Although field assessments of these units suggest that natural regeneration 

is likely and reforestation treatments will not be needed, this analysis assumes all reforestation actions 

would be completed in natural regeneration units; therefore, analysis of all natural regeneration units 

are included in the analysis of other reforestation units to address all potential effects. No further 

distinctions between natural regeneration units and reforestation units are made in this analysis. Also, 

no special distinction is made for reforestation activities proposed for deer habitat improvement other 

than differences in planting density.

Assessment of Existing Conditions

Given the large number of treatment units and limited available resources, it was impractical to 

collect enough plot-level data within each unit to accurately assess conifer regeneration and 

vegetation composition on a per unit basis. Instead, this analysis first vetted the data using methods 

similar to Crotteau et al. (2013), stratifying plots across a gradient of four fire burn severities. Fire 

severity was determined remotely using Relative differenced Normalized Burn Ratio (RdNBR) 

derived from pre- and post-fire LANDSAT Thematic Mapper images, which are subsequently 

transformed to four nominal Composite Burn Index (CBI) categories: unchanged (minimal or no 

visible effect of fire), low-severity, medium-severity and high-severity. RdNBR has been tested in 

similar conifer dominated vegetation types and proven to produce fire severity classifications with 

similar accuracy as other fire mapping processes (Miller et al. 2009a).

Reforestation

The analysis of conifer forest establishment and growth required a synthesis of local reforestation 

records, scientific literature and plot data. This synthesis helped parameterize two forest growth 

models used to evaluate the short- and long-term changes in vegetation: CONIFERS in R 

(RCONIFERS) and the Forest Vegetation Simulator (FVS).

Growth Models

RCONIFERS was used to predict growth and development of trees and competing vegetation in the 

project area to age 20. RCONIFERS is a model for young stand growth developed by the Forest 

Service Pacific Southwest Research Station (Ritchie and Hamann 2015). In general, most forest 

growth and yield simulators are ineffective at simulating the growth of very young stands, especially 

any stand in which non-tree vegetation contributes significantly to the level of competitive stress to 

which trees are exposed (Ibid). The Southwest Oregon (SWO) variant of RCONIFERS was 

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developed using data from mixed-conifer stands heavy to Douglas-fir in southern Oregon and heavy 

to ponderosa pine in northern California. The SWO variant is based on a limited list of conifer, 

hardwood and shrub species. The list includes all major conifer tree species found in the project area 

and the majority of the dominate hardwood and shrub species. With the exception of bearclover 

(Chamaebatia foliolosa), the SWO variant is the most appropriate model available to forecast the 

dynamic effect of competing vegetation on young forest growth in the project area. Although 

bearclover is not included in RCONIFERS, its effects on young conifer establishment and growth 

have been studied for several decades (McDonald et al. 2004). To account for the effect of bearclover 

competition, conifer growth in RCONIFERS was projected in the absence of competing vegetation 

(free-to-grow). Findings from scientific literature were then used to adjust conifer height and diameter 

growth accordingly.

The FVS Western Sierra Nevada Variant was used to simulate tree growth and summarize forest 

structure beyond age 20. The FVS projections use the default growth rates, which are calibrated to 

reflect inter-tree competition of established stands that have developed to a point where non-tree 

vegetation plays a minimal role in tree growth. This distinction between FVS and RCONIFERS is 

important to note for this analysis because growth projections are transitioned between the two 

models at age 20 despite tree size. This could affect long-term growth projections by essentially 

eliminating the variable of competitive stress caused by non-tree vegetation from the growth models 

at year 20. The effect is likely most pronounced in alternatives where early conifer growth has been 

reduced the most, resulting in the smallest tree heights and diameters at year 20. The aboveground 

photosynthetic potential of young trees is balanced by belowground root development and the ability 

to effectively compete for limited water and nutrients (Grossnicle 2005); therefore, these smaller trees 

are still aggressively competing with other vegetation and growing at a reduced potential compared to 

trees that have benefited from about two decades of greater root development and height growth. 

Removing the effect of non-tree competition at year 20 artificially provides these smaller trees a 

window of relatively free-to-grow conditions until they reach a size where inter-tree competition 

becomes a factor. During this period, trees that were larger at age 20 would experience a potentially 

smaller window of free-to-grow conditions before the onset of inter-tree competition. Scenarios 

where tree size is greatly reduced by competing vegetation would experience a longer period of freeto-grow conditions before the onset of inter-tree competition. 

While computer models attempt to display the complex reality of vegetation; modeling results fall 

short of a precise (perfect) depiction of the variability of real forest vegetation. This short-coming is 

due to the variability associated with measuring vegetation, the variability in locating plots, the errors 

associated with drawing boundaries around vegetation, and the ability of algorithms used in the 

computer models to effectively emulate natural variability. Despite these short comings, computer 

models do provide a means for relative comparison. 

Model Parameterization

Given the large scale of this project, a variety of model states, or scenarios, representing common 

conditions were identified and analyzed rather than simulating forest growth of every treatment unit 

for each alternative. This approach was used partly because plot data was limited on a per unit basis. 

While a robust dataset was created by collecting data from numerous plots across the project area, 

there was only a subset of units that had more than a few plots. Having a small sample within a unit 

increased the likelihood of outlier plots having undue effects on describing existing conditions. For 

example, a unit might have abundant conifer regeneration and little competing vegetation. If only one 

plot was completed in that unit and it happened to land in a patch of shrubs with no conifer 

regeneration, then the data would misrepresent the broader existing conditions across the unit.

The modeling scenarios were based on the five alternatives and their associated planting patterns, 

which are determined by slope position (Alternatives Considered in Detail, Chapter 2.02). Like FVS, 

RCONIFERS is a semi-distance-independent individual tree growth model. In general, this means it 

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does not readily account for the distance between individual trees and how the proximity and 

arrangement of neighboring trees might influence individual tree development. Rather, tree growth 

and development is determined by stand-level conditions (e.g., trees per acre), thereby, inferring 

distance to neighboring trees given that conditions in a stand are consistent. Basing stand-level 

conditions on plot-level data, however, does provide some ability to model localized competition and 

site variables within a stand (Dixon 2002). Attempting to model the fine-scale nuances of the various 

proposed planting patterns would have resulted in a tenuous and overwhelmingly complex analysis 

with numerous scenarios (greater than 100) after factoring in biophysical variables. Instead, a 

simplified approach was used that based the modeling scenarios on slope position and planting 

density, assuming this would provide an adequate representation of the predominant conditions and 

vegetation dynamics germane to this analysis. Effects of fine-scale planting patterns on individual 

trees are left to qualitative discussion. Both RCONIFERS and FVS structure input data by stands and 

plots within stands. Therefore, each scenario was treated as a stand. To account for the range of 

biophysical factors, mock plots were developed within each scenario’s stand (i.e., topographic slope 

position) based on environmental factors, density of hardwoods, competing vegetation and natural 

conifer regeneration as summarized from plot data.

Environmental Factors

The following environmental factors were incorporated into RCONIFERS: elevation, aspect, percent 

slope, water holding capacity, annual precipitation and growing season precipitation. Water holding 

capacity was determined using the available water supply (AWS) from the Soil Survey Geographic 

database (USDA 2008a). The available water supply is defined as the total volume of water available 

to plants when soil is at field capacity (USDA 1999). Mean annual precipitation (36.8 inches) and 

mean growing season precipitation (3.2 inches) were calculated based on precipitation records from 

the last 15 years (WRCC 2015). 

Competing Vegetation

Variability within each slope position was addressed by identifying dominant shrub types based on 

plot data. After categorizing plots into dominate shrub types, the proportion of plots within each slope 

position by shrub type were calculated. Overall, bearclover and deerbrush (Ceanothus integerrimus) 

were disproportionately the dominate shrub species on the most plots (greater than 72% of all plots). 

Manzanita (Arctostaphylos spp.) was the third most common dominant shrub in the project area, but 

on a much smaller proportion of the plots (8.5%). Given the large number of the plots dominated by 

deerbrush and bearclover, these shrub types were used to represent competing vegetation in 

RCONIFERS. That is, within each slope position all the deerbrush plots were averaged to estimate 

the species composition, cover and height of deerbrush and associated vegetation (i.e., other shrubs, 

grasses and forbs). This approach accounted for both the abundance of deerbrush and other shrub 

species, grasses and forbs. As mentioned previously, RCONIFERS does not include bearclover, so 

conifer growth adjustments were made based on scientific literature. Details on methodology and 

growth adjustments associated with bearclover are discussed in the following sections.

Natural Conifer and Hardwood Regeneration

Natural conifer regeneration was only used to model Alternative 2 and areas in Alternative 4 that 

would not undergo artificial reforestation. For the action alternatives and in areas proposed for 

reforestation under Alternative 4, planting or control of natural conifer regeneration was assumed to 

only occur in areas where natural regeneration was not meeting desired conditions; therefore, desired 

conifer stocking and species composition would always occur under these scenarios whether it be 

natural or artificial.

Density of natural conifer and hardwood regeneration was estimated using plot data stratified across 

the slope positions. Salvage and fuels reduction operations can reduce survival of naturally 

regenerating conifer seedlings through soil disturbance and physically burying seedlings in woody 

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material (Donato et al. 2006). Although each plot was not sampled twice to explicitly assess pre- and 

post-logging conditions, data was collected in recently logged areas and in areas scheduled for 

salvage operations, but had not yet been logged. Assuming natural regeneration in these areas were

relatively similar prior to mechanical operations, natural regeneration in logged and unlogged areas 

was compared. While both hardwood and conifer regeneration was lower in areas that had been 

logged, hardwood densities were impacted less. The majority of the oak and hardwood regeneration 

occurred in the form of stump sprouts, which are less vulnerable to damage by mechanical operations 

than small seedlings germinated from seed. For example, plots with top-killed oaks were likely less

impacted by mechanical equipment given presence of standing dead oak and not conifers. Conifer 

regeneration, however, is more vulnerable to mechanical operations because it only regenerates from 

seed within close proximity to species typically targeted for salvage. Plot data suggests that salvage 

and fuels reduction operations that have occurred in the project area have reduced conifer 

regeneration by 74% and oak regeneration by about 39%. 

Survival of Natural Regeneration

Aside from effects of salvage and hazard tree abatement operations, all hardwood regeneration is 

expected to initially survive and only experience mortality related to SDI thresholds built into default 

model settings. As already noted, the majority of hardwood regeneration is from root and stump 

sprouts, which afford these species ready-access to water and nutrients. Conifers, however, are 

expected to experience some levels of mortality as they must expend resources toward root 

development before they can invest in aboveground growth (Grossnicle 2005). Research that tracks 

both natural conifer establishment and survival over time is somewhat limited; however, findings 

from Shatford et al. (2007) do indicate that conifer seedling density does decline over time, but the 

only decline shown is over the course of almost 20 years and does not speak to initial conifer survival. 

However, Figure 5 from Shatford et al. (2007) does show relatively low initial densities, which then 

increase during the first few years before they precipitously fall over the next 10-plus years. This 

pulse of regeneration is likely a result of both conifer establishment near surviving mature conifers 

and dispersal and establishment of conifer seedlings that occurs during a short period of time when 

shrub and hardwood species are still responding to the fire; and therefore, have not yet dominated the 

site. Once all available growing space is occupied, then stem densities decline. Saigo (1969) found 

that pine would initially establish in high numbers, but quickly decline due to various factors such as 

predation, competition and poor microsite conditions. The results from these two studies suggest that 

conifer seedling survival is probably highly diverse and influenced by numerous factors including the 

species, competing vegetation, site conditions and climate.

This analysis based survival of naturally regenerating conifers on research conducted on planted 

conifers. This was approach taken because it helped control for the two very distinct shrub types 

being modeled for this analysis (deerbrush dominated and bearclover dominated), which would 

provide some diversity of results that are likely to occur. McDonald and Abbott (1997) reported 

between 99 and 81% survival of planted conifers over the course of an 18-year study on the effects of 

competing vegetation and young conifer growth. The study included a variety of shrub, grass and forb 

species common in Sierra Nevada mixed conifer forests, but did not include bearclover. Conifer 

survival rates were lowest in the high shrub cover plots and highest in the no shrub cover plots. 

Average survival rates of these low and high shrub plots (90%) was assumed to reflect the variation 

of potential natural seedling survival in areas dominated by deerbrush. 

High initial bearclover cover (20 to 40%) can substantially decrease initial conifer survival by as 

much 80% or more (Tappeiner and Radosevich 1982; McDonald and Fiddler 1999). Tappeiner and 

Radosevich (1982) reported only 13% conifer survival after 19 years in study plots with 20 to 40% 

bearclover cover. Reducing initial bearclover cover increased conifer survival to 71% (Tappeiner and 

Radosevich 1982). Other studies reported similar conifer survival (69-73%) in study plots that had 20 

to 30% bearclover cover present in the first few growing seasons (McDonald and Everest 1996; 

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McDonald and Fiddler 1999). Therefore, it was assumed that 71% of the natural conifer regeneration 

would survive in bearclover-dominated shrub types that had less than 30% bearclover cover and 13% 

of the natural conifer regeneration would survive in bearclover-dominated shrub types that had 

greater than 30% bearclover cover.

Research investigating effects of bearclover on growth of young ponderosa pine suggests that the 

majority of mortality occurs in the first few years after seedling establishment (Tappeiner and 

Radosevich 1982); therefore, natural regeneration mortality was incorporated into all model scenarios 

during the first projected growing season. Any additional mortality during the first 20 years was 

accounted for using default settings in RCONIFERS for SDI-related mortality. Default FVS mortality 

settings were used for projections beyond year 20. 

Future Conifer Dispersal and Establishment

Conifer dispersal was not modeled in this analysis. The CWHR definition of shrub-dominated 

vegetation types require at least 10% shrub cover and less than10% cover of tree species. The 

definition for the mixed hardwood-conifer forest type requires at least 25% cover of conifer species 

when there is greater than 50% cover of hardwood species. Therefore, at least 10 to 25% conifer 

cover is required to be classified as a conifer vegetation type. Post-fire conifer dispersal, 

establishment and growth are influenced by shrub and hardwood vegetation. Shatford et al. (2007) 

evaluated conifer establishment after 8 wildfires and noted that dispersal of conifer stocking gradually 

increased over the study period; however, this increase in presence of established conifer seedlings 

did not necessarily indicate conifer dominance. Similar to plot data in the Rim Fire, high burn 

severity areas studied by Shatford et al. (2007) had much lower densities of pine regeneration 

compared to Douglas-fir or true firs, which comprised greater than 50 to 80% of the conifer 

regeneration. Shatford et al. (2007) found that distance to seed trees did not appear to be a major 

limiting factor in conifer seed dispersal; however, no indication is made as to how far specific conifer 

species were dispersing. Given the disproportionate abundance of Douglas-fir and true firs, these 

species likely accounted for the majority of longer dispersal distances. Despite gradual increases in 

establishment, Shatford et al. (2007) notes that even after 19 years “conifer seedlings were frequently 

overtopped by shrubs and hardwoods” (p. 144). Other studies have observed dominance of non-pine 

regeneration in areas of high burn severity that is also commonly overtopped by other vegetation 

(Crotteau et al. 2013; Nagel and Taylor 2005; SNRC 2012). Additionally, other studies have 

demonstrated that large areas dominated by shrubs can considerably slow or inhibit the development 

of dry conifer forests (Barton 2002; Goforth and Minnich 2008; Roccaforte et al. 2012; Collins and 

Roller 2013).

Despite the presence of some conifers, their contribution to vegetative cover may not warrant 

reclassification from a CWHR shrub or hardwood dominated vegetation type to a conifer vegetation 

type. Although Douglas-fir and true firs are able to slowly disperse into large severely burned areas 

and persist among dense shrubs and hardwood vegetation even when overtopped for extended periods 

of time, their growth is greatly diminished (Conard and Radosevich 1982a; Conard and Radosevich 

1982b; Nagel and Taylor 2005; Shatford et al. 2007). Shatford et al. (2007) noted that in addition to 

the sporadic nature of dispersal, conifer growth would be delayed for about 20 years until shrub 

growth slows, but beyond that “successional development cannot be precisely predicted for specific 

locations” (p. 145). Nagel and Taylor (2005) observed even longer periods of significantly stunted 

growth in white fir, noting that on average it took about 30 years for a white fir seedling to grow one 

foot in height and about 120 years of fire suppression for white fir to establish and overtake chaparral 

vegetation.

The long time frame required for recovery of conifer forest cover is also attributable to the time 

required for conifers to produce viable cone crops that allow for increased expansion. For example, 

immature white fir and ponderosa pine can produce seed crops, but their performance is more erratic 

than that of mature trees, which typically do not produce dependable cone crops until 40 to 60 years 

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of age (Laacke 1990; Oliver and Ryker 1990). In California, ponderosa pine trees more than 25 

inches dbh were the best producers (Oliver and Ryker 1990). The best seed producing size for white 

fir is between 12 and 30 inches dbh. Similarly, Douglas-fir seed production increases with age. Oldgrowth Douglas-fir may produce 20 to 30 times the number of cones than younger trees that are 50 to 

100 years old (Hermann and Lavender 1990). 

Based on the very slow dispersal and growth of conifers among shrubs and hardwoods, conifer 

expansion beyond the proportion of the analysis area already regenerating with conifers was not 

modeled during the analysis time frame of 60 years. During the analysis time frame, it is unlikely that 

significant acreage would experience an increase in conifer cover of more than the 10 to 25% 

required to qualify as a CWHR conifer forest type or mixed hardwood-conifer type. Nor would 

seedlings that might establish after the fire grow to an age or size that would result in significant 

additional seed fall within the next 60 years. Therefore, the proportions of plots with and without 

conifer regeneration were used to determine the acres that would reliably regenerate as conifer forest 

during the analysis time frame. All other acres were treated as chaparral or hardwood vegetation 

types.

Conifer Planting Density and Survival

Conifer planting was based on densities identified for each alternative and topographic position 

(Alternatives Considered in Detail, Chapter 2.02). For each scenario, the 25-foot planting buffers on 5 

oaks per acre were used to adjust the number of conifers planted per acre. Conifer planting densities 

were also adjusted to account for potential initial mortality that commonly occurs shortly after being 

planted. Local reforestation records from the 1990s covering 4,966 acres on the Mi-Wok and 

Groveland Ranger Districts were evaluated to determine the effects of different site preparation and 

release treatments on planted conifer seedling survival. Records were categorized into different site 

preparation and release categories according to the different action alternatives proposed under the 

Rim Reforestation project. As Table 3.13-4 shows for each category, results from third-year survival 

exams were used to calculate an average percent survival, which was weighted based on plantation 

acres. Survival exam records distinguish between naturally regenerating conifers and planted conifers. 

The results presented here lump natural and artificial regeneration; thereby, incorporating potential 

natural regeneration that may occur within the Rim Reforestation project area.

Table 3.13-4 Third-Year Seedling Survival: Weighted Average Estimates Based on Local Records

Site Preparation and Release Treatments Planted in 1990s

(acres)

Initial Planted 

(acres)

Survived 

(acres)

Percent 

Survival1

Site preparation with herbicides or deep tilling with forest 

cultivation followed by herbicide release treatments

1,767 453 330 73

Deep till site preparation followed by manual releases 2,304 420 201 48

No site preparation followed by manual releases 895 390 110 28

1 Seedling survival assumptions are based on these values rounded up to the nearest multiple of 5.

Of the 4,966 acres evaluated, 1,767 acres were treated with herbicides as shown in Table 3.13-4. 

While herbicides were used for release treatments on all of these acres, site preparation treatments 

included different combinations of herbicides and deep tilling with forest cultivation. Effects on 

seedling survival of site preparation with either deep tilling or herbicides were assumed to be similar; 

and therefore, lumped together. This assumption was made for two reasons. First, records for a large 

portion of the acres (732 acres) in one of the timber compartments evaluated (Walton Cabin) were 

incomplete; however, multiple Forest employees (both retired and still working for the Forest 

Service) that assisted with reforestation efforts in the 1990s confirmed that both deep tilling and 

herbicides were widely used in this compartment. Second, records from the other 1,035 acres indicate 

that when followed by herbicide release treatments, site preparation with deep tilling versus 

herbicides resulted in similar survival rates. On average, 73% of seedlings survived when prepped 

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with herbicides versus 67% when prepped with deep tilling. Similarly, areas that were not site 

prepped, but were released using herbicides were included in this category based on the assumption 

that no site preparation was deemed necessary at the time. While all units under Alternatives 1, 4 and 

5 are prescribed either herbicides or deep tilling for site preparation, as described in Chapter 2 these 

treatments would only be used if still deemed necessary at the time of implementation.

The remaining 3,199 acres were reforested without herbicides. Treatment and survival details for 

these acres are described in USDA (1995). About 2,300 acres were site prepped with deep tilling and 

released using manual grubbing. The other 895 acres were planted the first spring after the 1987 

Stanislaus Complex Fire before competing vegetation had begun to respond. 

Conifer Growth and Competing Vegetation

The Forest Service in Region 5 has extensive experience and a large body of research including longterm studies that clearly establish the effect of competing vegetation on the growth of young conifer 

trees. For example, in a 31-year study McDonald and Abbott (1997) evaluated the effect of multiple 

shrub densities on the growth of ponderosa pine seedlings. Four shrub densities ranging from none to 

heavy were maintained for the first few years and pine growth was documented periodically for 26 

additional years. At the end of the study, tree heights ranged from about 9 in the heavy shrub plots 

and just over 30 feet in plots with no shrubs. RCONIFERS was built using extensive study plots 

documenting the dynamics of young conifers and shrubs (Ritchie and Hamonn 2015); therefore, this 

analysis uses RCONIFERS to simulate the effect of competing vegetation on young conifers. As 

mentioned earlier, however, RCONIFERS does not include bearclover, so the effect of bearclover 

was analyzed based on relevant research.

Herbicide Control of Bearclover – Alternatives 1, 4 and 5

Multiple studies have shown that in the first few growing seasons, bearclover reduces conifer height 

growth by about 50% (Tappeiner and Radosevitch 1982; McDonald and Everest 1996; McDonald and 

Fiddler 1999). During these first years of growth, the ability of confer seedlings to grow in height and 

diameter is greatly dependent on root development and the ability of the seedling to access soil 

moisture (Grossnicle 2005). Lack of water stresses conifer seedlings by causing decreased root 

expansion, which reduces resource collection and causes losses in growth that are seldom made up 

(McDonald and Fiddler 2010). It has been well substantiated that suppressing competing vegetation 

during the first few years of tree development has the greatest impact on the survival and growth of 

conifer seedlings (Balandier et al. 2006; McDonald and Fiddler 2010). In a study near Mount Shasta, 

white fir seedlings were released with herbicides every year for the first 3 years and for the first 6 

years after planting; however, treating for the first 6 years provided no significant gain over treating 

for the first 3 years (McDonald and Fiddler 2001). Conversely, when competing vegetation was not 

controlled during the first 3 years, but each year 4 to 6 years after planting, seedlings had statistically 

smaller average diameters than if released each year for only the first 3 years. In another study, 

excavation of 5-year old Douglas-fir seedlings grown with and without competition showed that the 

root biomass of seedlings in a free-to-grow environment was 9 to 22 times larger than those grown 

amongst sprouting shrubs because seedlings exposed to competition produced virtually no new root 

biomass (McDonald and Fiddler 2010). This critical period of early competition control has also been 

demonstrated in a study with northern conifers, which showed that the vegetation community and 

growth patterns established during the first 3 to 5 years after planting were relatively consistent 

through the subsequent 5 years (Wagner and Robinson 2006).

Although herbicide release treatments would not permanently eliminate bearclover or other 

competing vegetation (Tappeiner and Radosevitch 1982; Tesch and Hobbs 1989; McDonald and 

Fiddler 2010), herbicide release treatments would provide several years of free-to-grow conditions 

that would allow conifer seedlings to develop robust root systems that can effectively compete with 

other vegetation as it reestablishes following cessation of herbicide applications. Tappeiner and 

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Radosevitch (1982) found that bearclover aggressively recovered after a single herbicide application, 

but this short-term setback still resulted in increased conifer growth. Multiple herbicide applications 

following planting will likely cause greater dieback of bearclover roots and rhizomes, which will 

increase the time necessary for bearclover to recover and afford conifer seedlings a longer period of 

reduced competition. After multiple applications of herbicides, it will likely take several years for 

most other competing vegetation to regain densities similar to current levels. By that time, however, 

conifers will be able to effectively compete for soil resources as well as slow shrub expansion with 

shade. Based on this critical period, herbicide release treatments in bearclover shrub types were 

modeled using free-to-grow conditions for the first 5 years. After 5 years, other competing vegetation 

was introduced back into the model to simulate some level of competition after release treatments 

stop. 

No Control of Bearclover – Alternatives 2 and 4

While initial lower bearclover cover substantially increases conifer seedling survival; competition 

from bearclover can greatly reduce young conifer growth. After 3 growing seasons, plots that had 

lower initial bearclover cover versus plots with higher initial bearclover cover experienced 50% and 

56% lower tree heights compared to a free-to-grow plot (Tappeiner and Radosevich 1982). After 19 

years, the effect of bearclover on tree heights amounted to 67% and 72%, respectively. Although 

McDonald and Fiddler (1999) reported taller average tree heights at age 11 than that reported by 

Tappeiner and Radosvich (1982), they did not have a free-to-grow study plot to compare the effect of 

bearclover on conifer growth; therefore, this study could not be used to deduce the percent reduction 

in conifer growth that might have resulted from bearclover competition during the first several years 

of conifer development. The taller tree heights may have been a result of site conditions or other 

environmental factors. After modeling the natural conifer regeneration in a free-to-grow scenario, tree 

heights were adjusted according to bearclover abundance to reflect the findings of Tappeiner and 

Radosevich (1982). That is, all conifers in bearclover shrub types were modeled in RCONIFER 

without competing vegetation. Tree heights were then adjusted according to the abundance of 

bearclover. In bearclover shrub types with greater than 30% bearclover cover, free-to-grow tree 

heights were reduced by 72% after 20 years. In bearclover shrub types with less than 30% bearclover 

cover, tree heights were reduced by 67% after 20 years. Tree diameters were adjusted using species 

specific regressions of tree height-diameter relationships based on model outputs. 

Partial Control of Bearclover – Alternative 3

While hand grubbing will kill above ground portions of bearclover, belowground rhizomes will 

readily sprout and conifer seedlings will still experience some level of competition. Bearclover has 

been documented to aggressively recover following a single application of a single herbicide 

application (Tappeiner and Radosevich 1982). This is likely because a single herbicide application 

may reduce live root and rhizome biomass, but not completely kill the plant. Prescribed fire has 

resulted in similar effects by killing the aboveground portions of the plant, but the following spring it 

vigorously resprouts (McDonald and Everest 1996; McDonald et al. 2004). The same would be true 

for hand-grubbing bearclover, but manual treatment would likely be even less effective. To 

effectively control bearclover, you must repeatedly disrupt both the below-ground and above-ground 

portions of the plant (McDonald et al. 2004). For example, repeated herbicide applications reduce

both the photosynthetic tissues and root biomass. Hand grubbing, even multiple times would only kill 

the top portions of the plant. 

Although manual treatments would not directly kill bearclover roots, it would reduce root vigor as the 

plant would repeatedly experience reduced photosynthetic function and need to invest belowground 

resources into growing aboveground portions of the plant. Therefore, killing the aboveground 

portions of bearclover does provide some relief from soil moisture depletion that gives conifer 

seedlings an opportunity to make gains in root and shoot growth (Tappeiner and Radosevich 1982). 

Because the growth model RCONIFERS does not include bearclover, the effect of manual release

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Draft Environmental Impact Statement and Environmental Consequences

treatments were based on the findings of Tappeiner and Radosevich (1982) for a single herbicide

treatment. This study observed a small increase in conifer growth over the control study plots. These 

effects were compounded 5 times to account for 5 years of reduced competition from bearclover. A 

single herbicide treatment increased conifer mean annual height growth 0.056 feet between years 3 

and 19 compared to the control (Tappeiner and Radosevich 1982). Assuming each additional year of 

release would increase mean annual height growth the same amount, 5 years of release would result 

in conifer heights of about 10 feet at age 19 as opposed to 6.2 feet with a single release. If free-togrow conifers grew to 18.7 feet by age 19, then the effect of bearclover even with 5 releases that kill 

only the aboveground portions of the plant would result in a 46.5% reduction in height growth. 

Diameter growth was adjusted using the same height-diameter growth relationship described 

previously. 

Prescribed Fire in New Plantations

Prescribed fire would only be introduced to new plantations after about 10 years if fuels conditions 

meet specific criteria (Fuels, Chapter 3.05). As a result, it is likely that some new plantations would 

not meet these criteria. In the case that prescribed fire is introduced, conifer mortality would likely 

vary considerably, but burning would not proceed if conifer mortality is expected to exceed 20%. 

Given the potential for some plantations to not meet suitable burning criteria and the potential for 

minimal conifer mortality, conifer densities were not adjusted for prescribed fire; therefore, 

projections of stand density are representative of higher potential conifer densities.

Stand Attributes

Species composition, trees per acre and volume were calculated based on either RCONIFERS outputs 

or using FVS default equations. Pre-Rim Fire CWHR type, size and density within the project area 

were determined using CWHR spatial data (CDFW 2014b). The Rim Fire caused significant changes 

to CWHR classifications, which have not been remapped. Expected changes described in Table 4 of 

the Rim Recovery Vegetation Report provided the basis for the Rim Recovery project analysis 

(USDA 2014). For consistency, this analysis is based on the same expected changes. During this 

analysis, however, some errors in the CWHR pre-fire data were discovered. The errors occurred 

primarily in the plantations created in the 1990s after the 1987 Stanislaus Complex Fire. Many of the 

plantations were incorrectly coded as grass or shrub vegetation types because they were either in the 

process of being prepared for planting or were recently planted when the imagery used for creating 

the CWHR dataset was created. The differences in the acreages between this analysis and the Rim 

Recovery analyses are based on corrections by the Forest GIS staff on the CWHR classifications in 

areas with recently discovered errors. Post-fire CWHR vegetation types were assumed to remain 

unchanged unless active reforestation or natural regeneration occurs. If converted to conifer forest, 

then it is assumed to be either ponderosa pine (PPN) or Sierran mixed conifer (SMC). CWHR size 

and density was projected for all analyses in FVS using an AddFile developed by FVS staff (Rebain 

2005). 

Changes in SDI are evaluated for existing plantations, new plantations, and in areas with natural 

conifer regeneration. SDI for all cases was calculated using the equation developed by Reineke 

(1933) for trees greater than or equal to 1 inch dbh. Long and Shaw (2012) recommend this SDI 

calculation for mixed conifer stands that are not compositionally “pure” (i.e., greater than 80% of 

basal area composed of either true firs and Douglas-fir or ponderosa pine and Jeffrey pine).

Depending on stand attributes and age, other methods of calculating SDI may be more appropriate; 

Values of SDI produced using the Reineke (1933) equation are essentially equal to other equations for 

younger even age-aged stands, but increasingly diverges with increasing skewness of the diameter 

distribution (Long and Shaw 2012). Therefore, the Reineke (1933) equation is appropriate for 

calculating SDI for this analysis because plantations and natural regeneration is generally going to be 

even-aged during the analysis period and basal area rarely composed of a single species.

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Thin Existing Plantations

Common stand exam (CSE) data for this analysis was downloaded from the Natural Resources 

Management Natural Resource Information System (NRM NRIS) Field Sampled Vegetation 

Database (FSVeg). All data was collected between 2005 and 2013 (prior to the 2013 Rim Fire). Only 

plots representing conifer or mixed hardwood-conifer types were used to simulate effects of thinning 

and growth in existing plantations. All other CWHR vegetation types were assumed unchanged 

throughout the analysis time frame. CWHR size and density in non-conifer vegetation types are 

expected to increase over time, but proposed treatments in these types will primarily focus on fuels 

reduction and not significantly alter tree structure if trees are present. A total of 843 plots located 

within the Rim Fire perimeter were processed using the Western Sierras variant of FVS (Dixon 

2002). Each plot was categorized by CWHR vegetation type based on the relative proportion of 

conifer and hardwood canopy cover (CDFG 2005). FVS was used to classify each plot according to 

size and density (Rebain 2005). Plots were then processed together as stands depending on CWHR 

size and density to represent CWHR classifications that occur in proposed thinning units. 

Thinning was simulated in FVS based on the ICO thinning guidelines (How the Alternatives Were 

Developed, Chapter 2.01) and CWHR size and density classifications. For size classes 3 and less the 

ICO thinning guidelines would likely result in an average residual tree density of about 128 trees per 

acre. Residual tree densities in larger CWHR size classes would be about 105 trees per acre. These 

distinctions were made based on the assumed current spacing relative to size. For example, the 

majority of the larger size classes are located in the Granite plantations, which are older than the 1987 

Stanislaus Complex plantations. Many of the Granite plantations were thinned prior to the Rim Fire. 

Target tree spacing was typically about 18 to 20 feet between trees. Conversely, the younger Complex 

plantations have experienced only minimal pre-commercial thinning and some have never been 

thinned. Stand exams prior to the Rim Fire showed that tree densities ranged between 200 and 350 

trees per acre in these plantations, suggesting that tree spacing was between about 7 by 14 feet to 14 

by 14 feet. The ICO thinning guidelines call for creating 6 small clumps and 2 large clumps per acre 

with individual trees spaced about 25 feet apart. Prescribing these tree spacing guidelines to 

plantations that have different distances between trees would result in a range of clump footprint sizes 

despite the clumps having about the same number of trees. For example, if trees are about 20 feet 

apart, then a clump of 6 trees would have a footprint of about 2,600 square feet. If the trees were 

closer, then a smaller area would be required to achieve a clump with the same number of trees. If 

clumps tend to be small in area, then more space would be available for individual trees and result in 

higher residual tree densities. Based on these guidelines then, smaller CWHR size classes were 

estimated to have more residual trees per acre after thinning. While existing plantations are prescribed 

fire prior to mechanical operations, burning would not occur unless conditions would allow for target 

tree densities to be achieved. Follow-up mechanical treatments may be necessary to further reduce 

tree densities where needed and to reduce densities of small standing dead trees; therefore, thinning to 

target residual tree densities was simulated in all existing plantations one year after prescribed fire.

Affected Environment

The project area encompasses 41,933 acres within the Rim Fire perimeter where elevation ranges 

from about 3,000 to 7,000 feet. Predominant topographic features include steep river canyons, 

intermittent tributary drainages and broad sloping benches. Elevational differences in river canyons 

can range from 800 to 1300 feet in less than half a mile, but such topographic features occur primarily 

outside project treatment units. Prior to the Rim Fire, vegetation within the project area consisted of 

Sierran mixed-conifer forest, mixed hardwood-conifer and conifer plantations. Other vegetation 

occurring within the Rim Fire perimeter includes annual and perennial grasslands, chaparral and 

hardwood types.

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Historic Forest Structure

Historic forest structure provides a baseline that can be used to help inform forest management 

decisions regarding reforestation, density management and how forest structure is expected to change 

over time. While variables such as climate change introduce uncertainty, the past can provide some 

insight into how forest structure, function and processes might respond to changing environmental 

conditions. There are several historical accounts and reconstructions of historic structure and 

composition of Sierran mixed-conifer forests. These sources describe a wide range of conditions. This 

variation is evident in the accounts of Sudworth (1900). Sudworth described distinct forest structures 

within the low to middle elevations on the Stanislaus National Forest. Within this elevation range, 

ponderosa pine was the most abundant comprising 45 to 55% of most stands and up to 90% of stands 

at lower elevations. Sugar pine was less common, but still comprised 5 to 25% of the species 

composition. Incense cedar and white fir typically comprised 20 to 30% and 30 to 40%, respectively. 

White fir densities were typically highest at elevations between 4,000 to 5,000 feet and much lower 

and inconsistent at lower elevations. California black oak comprised a much smaller amount in most 

stands, with the highest proportions (5 to 10% of stands) occurring at low to mid elevations. 

Sudworth (1900) noted that there were some areas dominated by open conditions with very large 

(greater than 30 inches dbh), old-growth pine. In contrast, he also noted abundant dense patches of 

pine regeneration and dense stands of yellow pine 25 to 50 years old; however, frequent fire was 

noted as continually thinning such stands and often killing most of the regeneration. Lydersen et al. 

(2013) reconstructed reference forest conditions on the Stanislaus-Tuolumne Experimental Forest. 

Fire records indicated that the mean fire return interval was about 5 years; however, the last fire 

recorded occurred 40 years prior to the 1929 forest mapping data that they studied, so fire exclusion 

may have already become a factor. Lydersen et al. (2013) estimated that 40 years without fire resulted 

in an increase of tree densities from about 54 to 133 trees per acre. This ingrowth of smaller trees was 

possible given the presence of mature trees as seed sources and the absence of fire; however, 

Lydersen et al. (2013) warn caution because they likely underestimated historic small tree densities 

due to limitations related to their dataset.

In contemporary mixed-conifer forests that have relatively intact fire regimes, Lydersen and North 

(2012) found high levels of conifer seedlings and saplings (486 to 4,087 per acre). While seedling and 

sapling density was very high, densities of larger trees ranged from 45 to 134 trees per acre depending 

on topographic slope position. Collins et al. (2015) evaluated timber transects conducted in 1911 that 

were located within the Rim Fire perimeter (in the vicinity of Evergreen Road and Peach Growers). 

These records suggest that there were areas with even lower tree densities (11-32 trees per acre). 

Seedlings and saplings (trees less than 6 inches dbh) were also recorded along these transects, and 

similar to the findings of Lydersen and North (2012), occurred at significantly higher densities than 

larger trees (369-637 seedlings/saplings per acre, personal communication, Brandon Collins). The 

large difference in densities of conifer regeneration and established trees suggests that fire, other 

disturbances, and competition significantly regulated the number of small trees that grew to maturity. 

In a Jeffery pine mixed-conifer forest with a relatively intact fire regime, Minnich et al. (2000) found 

that 30 to 60% of pole sized trees survived wildfire. Another study found that about 50% of trees less 

than 8 inches dbh survived fire (Stephens et al. 2008). 

While frequent fire likely killed large portions of conifer regeneration, historic accounts of dense 20 

to 50 year old pine stands suggest that a fair amount of conifer regeneration likely escaped wildfire 

during early stand development (Sudworth 1900). In contrast to studies that attribute increases in 

small and intermediate sized trees to the introduction of fire exclusion (Collins et al. 2015; Lydersen 

and North 2012; Lydersen et al. 2013; Minnich et al. 2000), others argue that a dominance of youngand intermediate-aged stands prior to fire exclusion were actually common because they would 

regenerate following periodic disturbances that caused significant tree mortality (Odion et al. 2014). 

Baker (2014) asserts that while there were open, park like stands, Sierran mixed-conifer forests were 

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generally dense and prone to high-severity fire. His results suggest that forest openings and areas with 

relatively low tree density accounted for about 17 to 30% of the area. He contends that these sparsely 

forested areas are evidence of high-severity fire that occurred because of dense forest conditions. 

Although his estimate of mean historic tree density (about 119 trees per acre) is within the range 

suggested by Lydersen and North (2012), Baker (2014) notes that about 16% of the forested area 

exceeded 162 trees per acre and about 3% had 405 to 3,642 trees per acres, which suggests that there 

were areas of relatively dense mixed-conifer forest.

In terms of landscape forest structure, there is no clear answer to the question of how much fireinitiated early seral vegetation is desirable or what proportion of the landscape should be in the early 

seral stage and how large the patches should be (Coppoletta et al. 2015). Some studies have 

concluded that the effects of long-term fire exclusion, railroad logging, and other past management 

actions are now contributing to an increasing trend in high-severity fire and area burned in forests of 

the western United States (Miller et al. 2009; Miller and Safford 2012). As a result, it has been

suggested that management needs to focus on replacing high-severity fire acres by increasing the 

acres of low- and moderate-severity fire in low and middle elevation forests like yellow pine and 

mixed-conifer (Mallek et al. 2013). Additionally, mounting evidence is showing that climate change

exacerbates the negative correlation between increasing acres of high-severity fire and decreasing 

acres of low- and moderate-severity fire (Westerling et al. 2006; Lenihan et al. 2008; Westerling and 

Bryant 2008; Littell et al. 2009; Lutz et al. 2009). Under the current and predicted climate scenarios, 

early seral conditions have been predicted to increase on the landscape (Lenihan et al. 2008). Despite 

this body of evidence, some assert that there is still a large deficit of high-severity fire in Sierran 

mixed-conifer forests and because of fire suppression, “even doubling of fire would still be far lower 

than the historic levels” (Odion and Hanson 2013, p. 20). This school of thought views the lack of 

high-severity fire as a threat to Sierra Nevada forests (Baker 2014; Hanson and Odion 2014; William 

and Baker 2012). As a result of this deficit, they argue that post-fire vegetation, not impacted by 

activities such as salvage logging and reforestation, has become increasingly rare and should be 

protected (DellaSala et al. 2014; Odion and Hanson 2013). 

Some methodologies used to reconstruct historic forest structure and how they relate to fire severity 

have been called into question. Baker (2014) used similar data and methodology as William and 

Baker (2012) to determine historical forest structure and fire severity extent. Fulé et al. (2014) 

identified important errors in basic assumptions and methods in William and Baker (2012): the use of 

tree size distributions to reconstruct past fire severity and extent is not supported by empirical agesize relationships or by studies that directly quantified disturbance history in dry western forests. Fulé 

et al. (2013) also note that while William and Baker (2012) asserted surprising levels of heterogeneity 

in their reconstructions of stand density and species composition, their data are not substantially 

different from many previous studies which reached very different conclusions about subsequent 

forest structure and fire behavior changes. In response to Fulé et al. (2014), William and Baker (2014) 

defend their methodologies and findings, entrenching the scientific disconnect in conclusions 

regarding historic forest structure and high-severity fire in western dry forests.

As noted by Fulé et al. (2014), despite reaching very different conclusions about fire behavior and 

subsequent forest structure, the results of William and Baker (2012) are not substantially different 

from other studies with regard to forest structure. The same can be said with regard to results of 

Safford (2013) and Baker (2014). LANDFIRE BpS models provide an estimate of course landscape 

forest structure that may have occurred historically and is based on both biophysical conditions and 

current climatic conditions (LANDFIRE 2009). Safford (2013) used the BpS models to estimate 

landscape forest structure for Sierran mixed-conifer forests. He estimated that 5 to 15% of the 

landscape was in a mid-seral closed canopy structural class as shown in Table 3.13-3. This range is 

similar to the estimate made by Baker (2014) for relatively dense conditions (16%) – assuming values 

presented by Baker (2014) would classify as mid seral. Safford (2013) also estimated 15 to 20% of 

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the landscape was in an early seral condition, which overlaps with the Baker (2014) estimate of 17 to 

30% for forest openings and scattered trees. This difference in the early seral successional class is 

likely a result of methodologies and interpretations regarding the historic occurrence of high-severity 

fire. The LANDFIRE BpS models used by Safford (2013) provide a general range of conditions that 

are within range or close to estimates made in other studies of reference conditions and historical 

accounts (Franklin and Fites-Kaufman 1996; Bonnicksen and Stone 1982; Show and Kotok 1924).

Pre-Fire Vegetation

LANDSCAPE FOREST STRUCTURE

Table 3.13-5 shows the following CALVEG cover types comprised the majority of the vegetation 

impacted by the Rim Fire: conifer and mixed hardwood-conifer. Other vegetation cover types 

included hardwood, shrub, herbaceous, barren and other non-vegetation types. 

Table 3.13-5 Acres of CALVEG Cover Types within the Rim Fire Perimeter, STF and Project Area

CALVEG Cover Type Rim Fire Perimeter Stanislaus National Forest Rim Reforestation Project

CON - conifer 138,249 75,042 29,179

MIX - mixed hardwood-conifer 44,078 27,576 7,466

HDW - hardwood 30,756 22,055 1,473

SHB - shrub 27,448 22,724 3,260

HEB - herbaceous 14,267 6,141 533

OTHER - barren, urban, water 2,515 991 22

Total Acres 257,314 154,530 41,933

Table 3.13-5 shows hardwood, shrub and herbaceous types accounted for about 30% of vegetation 

depending on the scale. Barren and non-vegetation types accounted for less than 1% of the total Rim 

Fire footprint. Although the Rim Fire impacted non-conifer cover types, they are expected to maintain 

relatively the same CWHR type despite fire severity and changes that might occur in CWHR size and 

density. 

Figure 3.13-1 Average Landscape Forest Structure before Rim Fire Compared to Historic Conditions

CALVEG cover types provide a general classification of what the dominate vegetation is. Within 

each cover type, some portions of non-conifer CWHR vegetation types may exist. For example, a 

conifer cover type might encompass both CWHR conifer types as well as CWHR shrub and 

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hardwood types. As noted by Safford (2013), shrub cover occurring within the conifer biophysical 

setting is considered an early seral structure. Therefore, pre-fire landscape forest structure was 

estimated for CALVEG conifer and mixed hardwood-conifer cover types because they most closely 

resemble the LANDFIRE biophysical settings used by Safford (2013) to classify landscape structure 

of Sierran mixed-conifer forests. Within these two cover types, CWHR vegetation type, size and 

density was used to classify seral structural classes in Table 3.13-3. Compared to Safford’s (2013) 

estimates of landscape forest structure, Figure 3.13-1 shows a deficit of the following structural 

classes prior to the Rim Fire, regardless of land ownership: early, mid seral open canopy and late seral 

open canopy. As a result, there was an excess of mid and late seral closed canopy. The majority of the 

excess closed canopy was in the mid-seral size class with more than 3 times the historic estimate 

across all lands and just over 2 times the historic estimate on NFS lands.

CALIFORNIA WILDLIFE HABITAT RELATIONSHIPS

Vegetation within the Rim Reforestation project area was primarily conifer or mixed hardwoodconifer (36,645 acres). Other general cover types (e.g., shrub, hardwood and herbaceous) were 

omitted as to not overestimate the proportion of early seral conditions within the conifer and mixedhardwood conifer cover types. Table 3.13-6 summarizes the CWHR vegetation type, size and density 

within these two conifer cover types. Tables 3.13-1 and 3.13-2 previously showed the size and 

density class definitions. Ponderosa pine and Sierran mixed conifer were the dominant vegetation 

types, comprising just over 78% of the vegetation within the project area. The majority of the forest 

structure was also closed canopy (73%) with only 3.8% in a mid-seral open canopy condition. About 

23% was dominated by early seral conditions: shrub (2,336 acres), grass (1,856 acres), and tree 

seedlings and saplings (4,333 acres). This proportion of early seral conditions slightly exceeded the 

estimated historic proportion for early seral conditions (15 to 20%, Safford 2013). 

Table 3.13-6 Acres by Pre-Rim Fire CWHR Vegetation Type, Tree Size, Canopy and Seral Stage

Successional Class 

(Seral Stage)

Size and Density Shrub and 

Grass

MHW1 BOP MHC JPN LPN PPN SMC WFR Total

Early 1 and 2, all densities 4,192 52 3 118 5 3,607 548 8,525

Mid-Open 3S 3 8 91 48 150

Mid-Open 3P 3 2 43 4 413 431 898

Mid-Open 4S 1 2 20 31 53

Mid-Open 4P 6 2 6 113 188 5 320

Mid-Closed 3M 10 163 21 1,095 666 1,954

Mid-Closed 3D 70 3 155 8 41 1,130 328 1,735

Mid-Closed 4M 24 214 26 1,209 1,445 3 2,922

Mid-Closed 4D 61 35 2,193 3 33 4,788 9,172 11 16,296

Late-Closed 5M 15 15

Late-Closed 5D 53 217 129 313 3,065 3,777

Total 4,195 239 77 3,117 14 266 12,778 15,938 19 36,645

Percent of Total 11.4 0.7 0.2 8.5 0.04 0.7 34.9 43.5 0.1 100.0

1 MHW=montane hardwood; BOP=blue oak-foothill pine; MHC=montane hardwood-conifer; JPN=Jeffrey pine; LPN=lodgepole pine; 

PPN=ponderosa pine; SMC=Sierran mixed conifer; WFR=white fir. All within CALVEG cover types conifer and mixed-hardwood conifer

Areas Proposed for Reforestation

At most, the total area proposed for reforestation is 26,009 acres (includes natural regeneration and 

deer habitat enhancement units). Dispersed throughout the proposed reforestation units were patches 

of the following general CALVEG cover types: hardwood (691 acres), shrub (1,722 acres), 

herbaceous (85 acres) and other non-vegetation cover types (19 acres) that add up to 2,517 acres. 

About 90% of the area proposed for reforestation was classified as CALVEG cover types conifer or 

mixed hardwood-conifer. Of the conifer and mixed hardwood-conifer cover types, 81% was classified 

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as CWHR type ponderosa pine or Sierran mixed-conifer and 12% was classified as other conifer or 

montane hardwood-conifer types. Less than 1% was classified as montane hardwood and about 6% 

was classified as shrub or grass CWHR grass types. In total, there was 2,705 acres (12% of the 

conifer and mixed-hardwood CALVEG cover types) of early seral structure.

Existing PlantationsProposed for Thinning

Within the Rim Fire perimeter an estimated 17,773 acres of plantations were predominately planted 

after the 1973 Granite Fire, 1987 Stanislaus Complex Fire and 1996 Rogge Fire. All of these 

plantations are included in the Rim Reforestation project. A portion of these plantations were 

classified as hardwood (664 acres), shrub (1,880 acres), herbaceous (144 acres) and other nonvegetation (3 acres) CALVEG cover types. These non-conifer cover types are primarily small patches 

of distinct vegetation dispersed throughout the plantations. Of the 15,082 acres of conifer and mixed 

hardwood-conifer cover types, 134 acres were classified as late seral ponderosa pine and Sierra 

mixed-conifer forest (CWHR size class 5). These late seral conditions were also scattered throughout 

the existing plantations and were likely small remnant patches that escaped the previous fires.

Rim Fire

The Rim Fire caused extensive vegetative changes. High severity patches were uncharacteristically 

large and accounted for a larger proportion (35%) of the burned area than historically occurred 

(Miller et al. 2009). Other areas of low or very low severity continue to have intact forest tree cover, 

but are experiencing increasing levels of insect- and drought-related tree mortality due to sustained 

drought conditions (USDA 2015d).

Several factors contributed to the pattern of severity and fire effects: extreme drought, fire weather, 

years since last fire, elevation and topography, shrub cover, tree species composition and surface fuels 

(Harris and Taylor 2015; Lydersen et al. 2014; Kane et al. 2015). Historically, these same factors, 

with the exception of extreme drought, are believed to have resulted in a self-regulating system of 

interactions between vegetation characteristics and disturbance (North et al. 2009; Lydersen et al. 

2012; Harris and Taylor 2015). However, the effects of fire exclusion and drought have altered forest 

structure and created burn conditions that resulted in historically novel fire effects during the Rim 

Fire. Both Harris and Taylor (2015) and Lydersen et al. (2014) found that study plots with a greater 

proportion of shade-tolerant tree species and higher densities of small and intermediate sized trees 

(conditions often associated with high fire severity), generally burned with lower fire severity. 

Lydersen et al. (2014) found that elevation and shrub cover contributed the most to high-severity fire. 

Their study plots with higher shrub cover were primarily those at lower elevations with lower tree 

densities, whereas the plots with less shrub cover were those at higher elevations with higher tree 

densities and more white fir. The plots at higher elevations were cooler and moister, which 

contributed to greater tree canopy cover. Harris and Taylor (2015) reported similar results, finding 

that fire severity was associated with shrub cover and topographic position. Shrub cover was 

associated with pine on dry upper slopes and ridges, whereas lower slopes and valley bottoms 

supported higher densities of trees with cooler temperatures and higher moisture levels. Given the 

relatively mild fire weather, Harris and Taylor (2015) conclude that cool, moist areas escaped highseverity fire despite higher densities of shade-tolerant species.

Kane et al. (2015) also conducted a study that evaluated biophysical factors of the Rim area. Unlike 

Lydersen et al. (2014) and Harris and Taylor (2015), this study found that areas associated with 

greater moisture and productivity actually contributed to the uncharacteristically large high severity 

burn patches of the Rim Fire. These contrasting findings are likely a result of scale. Kane et al. (2015) 

explain that larger scales represented by their biophysical predictors “may simply better match the 

scales at which fire behavior, the biophysical environment, and fuel variations correlate” (p. 70). 

Kane et al. (2015) compared the fire effects of the Rim Fire to previous fires in the study area using 

actual evapotranspiration, which is an indicator of productivity. Greater evapotranspiration infers 

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greater productivity, which is associated with moist conditions. Compared to the Rim Fire, previous 

fires in the study area experienced significantly lower proportions of high severity fire. For pre-Rim 

fires, actual evapotranspiration was negatively correlated with burn severity. That is, moist and 

productive sites experienced lower burn severities. In the Rim Fire, however, this trend reversed and 

actual evapotranspiration correlated with higher burn severities. Kane et al. (2015) attribute this “flip” 

to the drought drying locations that usually had higher fuel moistures, and the Rim Fire then burned 

the fuel accumulations that had built up in these areas. An example of such an area is Corral Creek, 

which is a highly productive site that had a high proportion of mature Douglas-fir, incense cedar and 

white fir prior to the fire. The most productive areas of Corral Creek were the lower slopes and valley 

bottoms. Tree heights approached and exceeded 200 feet. Numerous trees exceeded 30 inches dbh 

and the largest trees exceeded 50 inches dbh. Both the 1987 Stanislaus Complex Fire and the 1996 

Rogge Fire burned near this area. The cool moist conditions likely contributed to the area 

experiencing little disturbance during previous fires; however, Corral Creek experienced 100% tree 

mortality during the Rim Fire.

Existing Conditions

LANDSCAPE FOREST STRUCTURE

After the Rim Fire, RAVG analysis mapping was completed to assess burn severity and change in 

vegetation. CWHR habitat classifications were adjusted based on the RAVG burn severity mapping. 

Figure 3.13-2 summarizes the post-fire landscape forest structure for the entire Rim Fire footprint 

compared to historic reference conditions (Safford 2013). Both the mid and late seral open canopy 

successional classes slightly increased, but are still far less than historic ranges. Mid and late seral 

closed canopy successional classes experienced large decreases. Late seral closed canopy was 

reduced to just within the historic range across all lands. When considering only NFS lands, late seral 

closed canopy conditions are slightly greater than the historic minimum; however, there is still an 

excess of mid seral closed canopy conditions on NFS lands. 

Figure 3.13-2 Average Landscape Forest Structure after Rim Fire Compared to Historic Conditions

Across the entire Rim Fire landscape, almost twice as many acres of mid seral closed canopy 

conditions exist than the historic range. Given the uncharacteristically large proportion of the 

landscape that experienced high severity fire, a large portion of the closed canopy conditions were 

shifted to the early seral successional class. Across all lands, an excess of nearly twice as much early 

seral conditions, almost 40% or 71,552 acres, now exists compared to the historic maximum of 20%, 

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which would amount to 36,466 acres of the conifer and mixed hardwood-cover cover types. The 

majority of the early seral successional structure is on NFS lands. There is now enough structure on 

just NFS lands (almost 25%) to exceed the historic range of 15 to 20%. If only considering other nonNFS lands, the proportion of early successional structure (about 15%) is just within the historic range.

COMPLEX EARLY SERAL FOREST

Immediately after the Rim Fire, timber salvage was conducted primarily in large patches of severely 

burned areas (USDA 2014). In many of these areas salvage operations have either been completed or 

are currently underway. Hazard tree removal has also been conducted along many forest roads and 

near structures. However, a considerable amount of acres were moderately or severely burned during 

the Rim Fire that have not been impacted by salvage or hazard tree operations. The term complex 

early seral has been defined by some as early seral conditions created by stand replacing disturbances 

that have not otherwise been altered by humans (DellaSala et al. 2014; Odion and Hanson 2014). That 

is, no standing dead trees are removed and post-fire vegetation is allowed to develop without human 

intervention. Stand-replacing events that kill all or most of the dominant trees therein, typically leave 

behind many biological legacies (e.g., standing dead trees and large down woody debris) that create 

distinct differences compared to pre-disturbance conditions (Swanson et al. 2011).

Figure 3.13-3 Retention of Standing Dead Trees during Salvage in Femmons Meadow Area

For this analysis, complex early seral forest was defined as conifer and mixed hardwood-conifer 

cover types that experienced at least 50% basal area mortality and were not impacted by the Rim 

Recovery project, Rim HT project, or were not located on private lands (i.e., assumed salvage 

operations conducted on all private lands). Based on this definition, currently 41,875 acres of 

complex early seral forest exist within the Rim Fire perimeter. Based on the definition of seral 

structural classes defined by Safford (2013), a portion of these complex early seral acres (7,376 acres) 

could be considered mid or late seral open canopy structure because they experienced moderateseverity fire and still have low densities of surviving trees; however, the vast majority of these acres 

(34,499 acres) resulted from high-severity fire that killed virtually all trees and now make up 48% of 

the current early seral structure across the Rim Fire landscape (Figure 3.13-2). In other words, almost 

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half of the 71,552 acres of early seral conifer and mixed hardwood-conifer structure within the Rim 

Fire landscape has not been altered by humans. Based on Safford’s (2013) estimate of the proportion 

of early seral structure, the current amount of complex early seral forest (34,499 acres) nearly equals 

the historic maximum of 20% of the conifer and mixed-conifer forest within the Rim Fire landscape.

Although salvage and hazard tree operations removed standing dead trees, the Rim Recovery project 

(USDA 2014) required that 4 to 6 trees per acre with a dbh of at least 24 inches be retained for 

wildlife purposes. When considering the diversity of historic tree density and the range of fire 

severities, an equivalent range of standing dead tree densities likely occurred historically. Dense 

forest conditions likely resulted in larger numbers of standing dead trees following high severity fire. 

Conversely, areas with lower tree densities may have resulted in lower numbers of dead standing 

trees. Collins et al. (2015) determined that large tracks of very low overstory tree densities (11 to 32 

trees per acre) existed on the STF. With such low tree densities, it was likely that areas with only 

small patches of standing dead trees existed, especially following mixed severity fire conditions. 

Therefore, the areas that were salvage logged after the Rim Fire still provide some elements of 

structural complexity despite the effects of mechanical operations. Figure 3.13-3 shows retention of 

standing dead trees in an area recently salvaged near Femmons Meadow. 

CALIFORNIA WILDLIFE HABITAT RELATIONSHIPS

Table 3.13-7 summarizes the post-Rim Fire CWHR vegetation type, size and density classifications 

within CALVEG conifer and mixed hardwood-conifer cover types. Large wildfires that have high 

proportions of high severity fire can convert large areas of conifer forest to shrub vegetation (Collins 

and Roller 2013; Crotteau et al. 2013; Coppeletta et al. 2015; Nagel and Taylor 2005). The Rim Fire 

shifted a large portion of the project area into an early seral structure, increasing the abundance of 

grass and shrub vegetation types from about 11% to over 62% of the project area. Early seral 

conditions now comprise a significantly larger proportion of the project area compared to historic 

Sierran mixed-conifer landscapes (15 to 20%, Safford 2013). As a result, the proportion of ponderosa 

pine and Sierran mixed-conifer vegetation types was significantly reduced from 78% to less than 35% 

of the project area. Areas of low- to moderate-burn severity slightly increased the proportion of mid 

and late seral open canopy conditions. 

Table 3.13-7 Acres by Post-Rim Fire CWHR Vegetation Type, Tree Size, Canopy and Seral Stage

Successional Class 

(Seral Stage)

Size and Density Shrub and 

Grass

MHW1 BOP MHC JPN LPN PPN SMC WFR Total

Early 1 and 2, all densities 22,819 226 61 64 2,253 402 25,826

Mid-Open 3S 3 1 3 38 6 270 243 563

Mid-Open 3P 4 1 39 1 3 306 299 652

Mid-Open 4S 1 151 7 407 917 3 1,486

Mid-Open 4P 7 8 142 3 480 952 5 1,597

Mid-Closed 3M 18 6 299 192 516

Mid-Closed 3D 1 19 2 2 326 60 410

Mid-Closed 4M 42 2 511 465 2 1,023

Mid-Closed 4D 3 4 263 1,450 1,670 3 3,392

Late-Open 5S 14 9 18 237 277

Late-Open 5P 13 5 22 242 281

Late-Closed 5M 1 1

Late-Closed 5D 19 4 36 562 621

Total 22,822 241 77 822 3 48 6,375 6,242 13 36,645

Percent of total 62.3 0.7 0.2 2.2 0.01 0.1 17.4 17.0 0.04 100.0

1 MHW=montane hardwood; BOP=blue oak-foothill pine; MHC=montane hardwood-conifer; JPN=Jeffrey pine; LPN=lodgepole pine; 

PPN=ponderosa pine; SMC=Sierran mixed conifer; WFR=white fir. All within CALVEG cover types of conifer and mixed-hardwood conifer

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Areas Proposed for Reforestation

The 2,517 acres of non-conifer CALVEG cover types did not significantly change despite highseverity effects during the Rim Fire. The hardwood types likely experienced high tree mortality in 

some areas, but hardwood species in the project area readily sprout after fire and quickly regain 

dominance over the site. Within CALVEG cover types conifer and mixed hardwood-conifer (23,492 

acres), the Rim Fire significantly reduced the proportion of conifer-dominated CWHR vegetation 

types. Prior to the fire, conifer types comprised 93% of the vegetation, but now comprise about 20%. 

Much of the conifer vegetation was shifted to an early seral structure that is now dominated by shrubs 

and hardwoods. Patches of mid and late seral conifer forest totaling 5,013 acres are distributed 

throughout the areas proposed for reforestation. Just over half of these acres (2,857 acres) 

experienced moderate burn severity and are now in an open canopy condition with scattered conifers. 

The majority of these patches were incidentally included in units when drawing boundaries using GIS 

and account for small portions of units. They are also typically located within close proximity to the 

edge of high-severity burn patches. Stress caused by the Rim Fire (e.g., crown scorch and severe 

cambium heating) in addition to extended drought conditions and increased bark beetle activity has 

increased levels of tree mortality; therefore, many of these residual patches have experienced reduced 

tree densities or in some cases 100% mortality. The majority of natural conifer regeneration, as 

discussed in the following sections, has been observed within close proximity of residual live trees 

and high-severity patch edges. These areas within proposed reforestation units primarily account for 

the areas proposed for natural regeneration described in Chapter 2.02. For the purpose of this 

analysis, natural regeneration units are analyzed for active reforestation to account for the scenario of 

greatest potential impact. The 2,517 acres classified as non-conifer vegetation are areas that would be 

excluded from reforestation activities (e.g., dense oak patches, stringer meadows, lava caps and 

roads). These areas contribute to the diversity of vegetation across the landscape, but are not included 

in calculations of landscape forest structure classes (seral stages) within conifer and mixed hardwoodconifer cover types. While discussions of effects may refer to all 26,009 acres proposed for 

reforestation, it is with the understanding that these non-conifer cover types would not be planted. 

Existing Plantations Proposed for Thinning and Prescribed Fire

Overall, the Rim Fire burned with high burn severity across 98,049 acres (USDA 2014e). Despite the 

uncharacteristically large area of high burn severity, only a small portion of these acres can be 

attributed to plantations. Of the 17,773 acres of existing plantations, 9,919 acres (56%) experienced 

less than 50% basal area mortality. An additional 4,015 acres of plantations experienced a mix of 

burn severities, which left patches of dense plantations among patches of moderate to high burn 

severity patches. Together, these plantations compose the 13,934 acres (78% of existing plantations) 

that are proposed for thinning under the Rim Reforestation project.

Several factors likely contributed to the variation of burn severities in the existing plantations. 

Plantations are often considered to be vulnerable to wildfire because young conifers have thin bark 

and low branches that are sensitive to scorching (McGinnis 2010). Studies of the Rim Fire, however, 

have also shown that biophysical conditions and shrub cover seemed to play an important role in fire 

severity, more so than tree size and density (Lydersen et al. 2014; Harris and Taylor 2015). Similarly, 

an evaluation of the Granite plantations determined that the biggest risk to plantations are surface and 

ladder fuels; and therefore, plantations that have an overall continuity of surface fuels are more likely 

to support large severe fires as opposed to well established plantations with trees that have grown to 

heights providing distinct separation of surface litter fuels and the canopy, as well as successfully 

shading the forest floor and minimizing shrub cover continuity (Sapsis and Brandow 1997). 

About one third of the plantations proposed for thinning were planted after the 1996 Rogge Fire. Tree 

sizes in these plantations currently range between 3 and 6 inches dbh with heights between 15 and 20 

feet. These plantations were predominately planted at a density of 444 trees per acre. As previously 

noted, third year survival exams indicate that deep tilling and herbicide treatments result in about 

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25% mortality during the first few years of tree establishment. As a result, current tree density in 

these plantations averaged about 325 trees per acre prior to the fire; however, post-fire live tree 

density is somewhat lower in areas that experienced low- to moderate-severity fire (220 to 300 trees 

per acre). While some areas experienced higher severity fire, there are still patches with tree densities 

exceeding 300 trees per acre.

The next oldest plantations were established after the 1987 Stanislaus Complex Fire during the 1990s 

and also account for about one third of the plantations proposed for thinning. These plantations were 

planted using similar methods and planting densities as the Rogge plantations; therefore, post-fire tree 

densities are similar. Because these plantations are almost 10 years older, however, diameters and 

heights are larger on average. Tree diameters typically range from about 6 to 12 inches dbh with 

heights of 25 to 35 feet. 

The oldest plantations were planted after the Granite fire in the 1970s. Many of these plantations had 

been thinned prior to the Rim Fire. On average, tree spacing ranges from 16 to 22 feet (about 135 

trees per acre post-fire). Tree diameters are considerably larger than many of the Rogge or Complex 

plantations, ranging from 12 to 18 inches on average with heights of 50 to 70 feet. 

Deer habitat enhancement using prescribed fire only is proposed on 1,990 acres. The Jawbone lava 

cap comprises the majority of these acres (50%). The remainder is a mix of Rogge plantations and 

hardwood vegetation that experienced a mix of low-, moderate-, and high-severity fire.

NATURAL REGENERATION

The pattern of correlation between natural conifer regeneration and the Composite Burn Index (CBI) 

within areas proposed for reforestation is similar to the findings of Crotteau et al. (2013). The highest 

seedling densities of conifer regeneration are in the low- and moderate-severity burn patches. 

Seedling density in high-severity burn areas is the lowest and most inconsistent as shown in Table 

3.13-8. The proportion of plots without conifer regeneration in high-severity burn areas is 70%, which 

is about twice as much as the low- and moderate-burn severities. Other studies of conifer regeneration 

and burn severity have observed a similar trend in conifer regeneration and burn severity (Collins and 

Roller 2013). When extrapolated to acres, the total area within proposed reforestation units, with and 

without natural conifer regeneration, is 9,825 acres and 16,184 acres, respectively. Although the 

majority of the areas proposed for reforestation experienced high-severity fire, there are small patches 

distributed throughout treatment units that experienced low-severity fire. Many of these patches were 

included incidentally when delineating unit boundaries in ArcMap and would obviously not require 

reforestation. White fir is more abundant than any other species; likely because it is a prolific seeder 

(Zald et al. 2008). It comprises about 50% of the natural conifer regeneration across most burn 

severities. Douglas-fir is the second most abundant and comprises about 25% of the conifer 

regeneration consistently across all burn severities. Pine species are the most abundant in unchanged 

areas and overall much lower in density compared to white fir and Douglas-fir. All pine species 

combined only account for about 13% of all natural conifer regeneration. Ponderosa pine is the most 

common pine species, accounting for 11% of all conifer regeneration. Sugar pine contributes only 

about 1% and other pine species (grey pine, knobcone and Jeffrey pine) account for less than 1% 

overall. Some seedlings were unable to be identified, but only amounted to about 4% of all conifer 

regeneration.

Although plots were not visited both pre- and post-salvage logging, a large portion of the plots were 

completed in areas that were expected to be salvaged. This plot data suggests that salvage and fuels 

reduction operations that have occurred in the project area have reduced conifer regeneration by about 

74% and oak regeneration by about 39%. Although oak and other hardwood regeneration has been 

impacted by mechanical operations, it is still quite abundant across all burn severities because of its 

ability to sprout from stumps and roots. Hardwood regeneration density across the areas proposed for 

reforestation averages about 185 seedlings or sprouts per acre. About 78% of hardwood regeneration 

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is from stump and root sprouts. There is a disproportionate abundance of California black oak (80%) 

regenerating compared to other hardwood species. Canyon live oak is the second most abundant 

(17%), while other hardwood species (interior live oak, blue oak, big leaf maple, dogwood, willow 

and alder) account for only about 3% of regenerating hardwoods. 

Table 3.13-8 Natural Conifer Regeneration within Areas Proposed for Reforestation

Burn Severity 

(CBI)

Total 

Plots

Null Plots Total 

Acres1

Stocked 

Acres2

Seedlings 

Per Acre3

WF 

(%)

IC 

(%)

DF 

(%)

PINE 

(%)

UNK 

(%)

Unchanged 16 3 239 195 2,365 20 24 27 28 0

Low 57 9 1,371 1,155 5,705 52 6 17 12 13

Moderate 320 124 5,662 3,468 4,167 54 5 29 9 2

High 1,280 905 18,736 5,489 870 48 1 25 22 4

Total 1,673 1,041 26,009 9,825 2,291 52 5 25 13 5

1 Acres include all natural regeneration unit acres

2 Calculated based on proportion of null plots (plots without natural conifer regeneration) and plots with conifer regeneration

3 Seedling density in areas with natural regeneration; excludes null acres; CBI=Composite Burn Index; WF=white fir; IC=incense cedar; 

DF=Douglas-fir; PINE=ponderosa pine, Jeffrey pine, sugar pine, grey pine and knobcone pine; UNK=unknown conifer

Many factors, such as available moisture, soil insolation and rodent herbivory, influence post-fire 

seedling establishment (Crotteau et al. 2013; Nathan et al. 2002; Saigo 1969; Vander Wall et al. 

2005). The foremost requirement for natural conifer regeneration is seed source (Bonnet et al. 2005). 

Shatford et al. (2007) found that distance to seed source for Douglas-fir and white fir was not 

necessarily a limiting factor; however, pine species have heavier seed (Laacke 1990; Oliver and 

Ryker 1990), which likely decreases the rate of long-distance seed dispersal. While regeneration tends 

to be highest in low to moderate severity patches (Crotteau et al. 2013), Bonnet et al. (2005) found 

that seedling establishment was very successful in patches of high-severity that were within about 40 

feet of unburned forest canopy, but decreased exponentially toward the center of burn patches. During 

plot surveys in the Rim Fire area, distance to nearest potential seed source was recorded. 

Figure 3.13-4 Distribution of Natural Conifer Regeneration within Areas Proposed for Reforestation

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Figure 3.13-4 summarizes density of natural conifer regeneration within units proposed for 

reforestation. The largest proportion of seedlings is within 50 feet of live mature conifer trees. The 

proportion of natural conifer regeneration sharply declines as the distance to live mature conifers 

increases. This trend is true for all conifer species. White fir, Douglas-fir and incense cedar together 

comprise 70% and 68% of the conifer regeneration occurring at distances of 250 to 500 feet and 

greater than 500 feet from live trees, respectively.

UNDERSTORY VEGETATION

The relationship between shrub cover and burn severity followed general trends observed after other 

large wildfires (Collins and Roller 2013; Coppoletta et al. 2015; Crotteau et al. 2013). Overall cover 

of shrubs, grasses and forbs has a positive correlation with burn severity. Within unchanged, low-, 

moderate- and high-severity areas vegetation cover averages 4%, 23%, 50% and 61%, respectively. 

Grasses and forbs make up about 25% of the vegetative cover in both moderate- and high-burn 

severity. Bearclover and deerbrush are disproportionately more abundant than any other shrub species 

across all burn severities; however, there is a more even distribution of species in moderate-severity 

than in high-severity. In moderate-severity, both bearclover and deerbrush each comprise about one 

fifth of the vegetation (on average about 9% cover each). In high-severity, bearclover accounts for 

about one third (20%) of the vegetative cover on average and deerbrush one sixth (10%). Bearclover 

has an extensive system of below-ground rhizomes and tap roots that aggressively responds to above 

ground disturbances such as fire (McDonald et al. 2004). In addition to effectively sprouting after 

disturbances, Ceanothus species (such as deerbrush, whitethorn, and buckbrush) commonly store 

more seed in the soil than other shrub species (Knapp et al. 2012), which has likely contributed to the 

high abundance of deerbrush in the project area. The majority of the plots that were dominated by 

deerbrush occurred in drainages, while mid-slopes, ridges and emergency travel routes were typically 

dominated by bearclover. 

Manzanita species are the third most abundant shrub species. Knapp et al. (2012) found that after 

ceanothus species, manzanita was the next most abundant shrub seed stored in mixed-conifer forest 

soil. Numerous other shrub species exist throughout the project area including, but not limited to 

cherry, ribes, toyon and poison oak. Manzanita and these species individually account for less than 

1% of the total vegetative cover, but where present species like manzanita or buckbrush can occur in 

large dense patches. Overall, however, other shrub species account for a much smaller portion of the 

total vegetative cover compared to bearclover or deerbrush.

Environmental Consequences

Alternative 1 (Proposed Action)

DIRECT AND INDIRECT EFFECTS

Tree Size and Species Composition

Reforestation

Reforestation efforts, including site preparation and release, plant new trees and take advantage of 

natural regeneration resulting in predictable conifer survival and growth (Fiske 1981). Artificial 

regeneration allows for more control over competing vegetation and tree species composition. Ground 

disturbing activities (such as fire, tractor piling, hand cutting and shredding) during site preparation 

can stimulate sprouting of several shrub species (e.g., bearclover, Ceanothus species and some 

species of manzanita). Similarly, these activities can stimulate germination of shrub seeds stored in 

the soil, making control of competing vegetation challenging (Knapp et al. 2012). 

Deep Tilling and Forest Cultivation

Areas site prepped with deep tilling would have better survival than areas that did not. Deep tilling 

kills above-ground portions of shrubs and breaks-up below-ground roots and rhizomes (McDonald et 

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al. 2004), which reduces initial competition for water during the first growing season after planting. 

As displayed in Table 3.13-4, initial conifer survival is estimated at about 75% of the initial planting 

density in areas prepped with both deep tilling and herbicide releases. Reduced competition would

also increase conifer growth.

Herbicides

Herbicide site preparation and release treatments would effectively reduce shrub and grass 

competition for the first five years allowing for establishment and development of conifers in a free to 

grow environment. Initial herbicide release treatments would require the most widespread application 

because shrubs and other herbaceous vegetation would have relatively high cover. These first 

treatments would kill both above- and below-ground portions of shrubs and other understory 

vegetation, reducing their abundance. Therefore, each subsequent treatment would likely require less 

herbicide be dispensed to achieve desired levels of competing vegetation (i.e., less than 10,000 cubic 

feet per acre, USDA 2010a). Areas that are deep tilled would also require less herbicides be applied to 

effectively control competing vegetation.

Figure 3.13-5 Understory Vegetation in 15-Year Old Walton Cabin Plantations Prior to the Rim Fire

The beneficial effects of herbicide release treatments on understory vegetation would likely last 

several years after release treatments stop, resulting in reduced abundance of shrubs, grasses and 

forbs. Experience on the STF, as well as research, has demonstrated that understory vegetation does 

recover even after multiple herbicide applications (DiTomaso et al. 1997; McDonald and Fiddler 

2010; Sapsis and Brandow 1997). Given the abundance of seed stored in the soil and numerous areas 

excluded from herbicide application (e.g., oak buffers, sensitive areas, riparian buffers, heritage 

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exclusions), the diversity of understory plant communities are not at risk of being lost from the 

project area and can effectively recover and spread throughout treatment areas over time. Figure 3.13-

5 shows bearclover and manzanita growing in 15-year old plantations where both deep tilling and 

herbicides were used after the 1996 Rogge Fire. Increases in herbaceous species richness have been 

observed following cessation of herbicide treatments (DiTomaso et al. 1997). The use of herbicides 

effectively reduces shrub cover, which increases solar radiation to the forest floor. As a result, grasses 

and forbs that would normally be outcompeted by the aggressive post-fire response of shrubs are able 

to persist in larger proportions (McDonald and Abbott 1997); however, such increases may result 

from invasion by undesirable species such as cheat grass (McGinnis et al. 2010). Herbicide treatments 

for noxious weeds, as well as subsequent reforestation release treatments, would help to minimize 

spread and establishment of invasive exotic plant species.

Prescribed Fire

Introducing prescribed fire while plantations are still fairly young (about 10 years old) would also 

facilitate reestablishment of native shrub species. Prescribed fire stimulates germination of Ceanothus

species that require fire for seed scarification, promoting recovery of the herbaceous understory 

(Kauffman and Martin 1991). Prescribed fire, which would also slow development of large decadent 

shrubs after herbicide release treatments stop, would maintain small openings in shrub canopies and 

allow a greater abundance of grasses and forbs to persist within plantations for a longer period of 

time.

Tree Development and Densities

Tree crown characteristics are influenced by shrub competition and tree density. As trees grow and 

expand lateral branches, they must physically compete with neighboring trees and other vegetation 

for growing space as well as water and nutrients belowground. Higher stand densities reduce the 

amount of time before trees grow large enough to begin competing with each other for physical 

growing space. Like shrubs, higher tree densities can also reduce diameter and height growth, but 

depending on tree spacing this effect may not occur for 10 to 30 years depending on how closely trees 

are spaced. The effect of shrub competition is more pronounced in earlier years before inter-tree 

competition begins. Oliver (1979) evaluated the effect of different tree spacings with and without 

shrub removal. Trees spaced greater than 12 feet apart that were free of shrub competition did not 

experience reduced height or diameter growth during the 12 year study period; however, shrub 

competition significantly reduced diameter, height, crown width and branch diameter. Tree spacing 

alone did not affect tree growth during the 12-year study period except at the smallest spacing 

evaluated (6 feet). At this spacing, inter-tree competition for light and belowground resources 

occurred during the 12-year study period. Similarly, trees grown close together are more likely to 

shed portions of their crown that are shaded by neighboring trees and vegetation. As a result, trees in 

tightly spaced clumps may shed portions of their crowns sooner than trees that are open grown. For 

the most part, however, tree spacing proposed under the Alternative 1 planting patterns is large 

enough that most trees would not experience significant declines in growth or self-pruning during the 

first 10 to 30 years.

Table 3.13-9 summarizes tree development and densities for Alternative 1. Growth simulations 

estimate that conifer diameters would average just over 4 inches at breast height at year 20 and almost 

14 inches by year 60. Average conifer heights at years 20 and 60 would be about 23 feet and 75 feet, 

respectively. Conifer heights are similar to heights observed by McDonald and Abbott (1997) in study 

plots with low competing vegetation. As shown in Table 3.13-9, tree heights at year 10 in their study 

were slightly taller on average (10.6 feet and 8.7 feet in plots with low and moderate abundance of 

competing vegetation) compared to estimates made using RCONIFERS. Table 3.13-9 shows at year 

18, McDonald and Abbott (1997) observed slightly shorter tree heights (14.9 to 20.9 feet) compared 

to 20-year estimates made using RCONIFERS. The RCONIFER estimates of dbh and height are also 

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comparable to other plantation growth models produced for northern California (Oliver and Powers 

1978). 

Table 3.13-9 Alternative 1 Tree Density and Characteristics at Years 10, 20 and 60

Species Year PCR1

Mean

CBH1

Mean

DBH1

Mean

DBH 

Minimum

DBH 

Maximum

Height

Mean

Height 

Minimum

Height

Maximum

TPA1

Mean

TPA 

Minimum

TPA 

Maximum

Conifers 10 93 1 0.7 0.0 1.4 7.3 2.7 10.7 176 104 207

Conifers 20 70 7 4.3 0.4 6.8 23.2 6.7 34.0 175 104 207

Conifers 60 61 29 13.9 4.8 24.1 74.8 23.6 111.1 157 98 179

Hardwoods 10 78 2 1.0 0.0 3.0 9.6 4.6 22.5 50 38 63

Hardwoods 20 44 13 4.0 2.6 5.9 23.9 16.1 37.3 20 15 25

Hardwoods 60 29 27 6.1 4.0 10.6 38.3 23.0 53.8 16 10 22

1 PCR=percent crown ratio; CBH=canopy base height in feet; DBH=diameter at breast height in inches; TPA=trees per acre.

Tree density would vary by slope position because of the different planting patterns that are 

summarized in Table 2.02-2 (Alternatives Considered in Detail, Chapter 2). Lower tree densities 

would occur on fuelbreaks and primary ridges, while the highest densities would be planted in 

drainages where conditions are cooler, moister and better suited for denser forest. After accounting 

for initial mortality and oak buffers, tree densities would range from 104 to 207 trees per acre during 

the first 10 years. Overall, the average tree density at year 10 is estimated at 176 trees per acre. 

Assuming no major disturbances occur (e.g., stand replacing fire, mechanical thinning, insect 

outbreak), background or normal mortality rates would reduce conifer density to 157 trees per acre on 

average and range from about 98 to 179 trees per acre by year 60. Areas with lower tree density or 

larger spacing between clumps would likely develop higher shrub cover in the long-term. Lydersen 

and North et al. (2012) found that tree densities on ridges and mid-slopes were often associated with 

greater shrub cover.

Pine species would comprise a greater proportion of the plantations. Over the next 60 years, pine 

would comprise about 70% of the density, of which, 15 to 20% would be sugar pine. Oak and other 

hardwoods would initially comprise about 22% of overall tree density. Hardwood species generally 

never exceed heights of more than 60 to 80 feet, but conifer species commonly reach heights of 100 

to 200 feet. Growth simulations predict that conifers would begin to overtop oak and other hardwoods 

after 15 to 20 years. As the conifers increase in size and can more effectively compete for water and 

light, hardwood density will decrease. Competition between hardwoods would also contribute to 

declining hardwood densities as more dominate individuals expand into the growing space of 

neighbors. By year 60, hardwoods are projected to comprise about 8-10% of the tree density, which is 

comparable to historic accounts of oak density at about the same elevation. On the STF, Sudworth 

(1900) estimated that the highest densities of California black oak occurred between 3,500 and 4,500 

feet elevation, comprising 5 to 10% of most stands. The majority of the Rim Reforestation project 

area is less than 5,000 feet.

Various planting patterns are proposed based on slope position. The distribution of planting patterns 

reflects patterns observed by Lydersen and North (2012), with higher tree densities and larger treeclumps located on lower slopes and lower tree densities and smaller tree-clumps located on upper 

slopes and ridges. Planting seedlings in clumps also reflects natural patterns of regeneration to an 

extent. For example, Sudworth (1900) described conifer regeneration as being patchy, but the patches 

of regeneration were growing among intact forest and not within large patches of severely burned 

forest. While planting patterns would promote a clumpy distribution of seedlings and saplings in the 

short-term, key structural components would be absent until the development of large trees, which 

with their presence, create conditions suitable for natural conifer regeneration. Based on an extensive 

review of research related to tree spatial patterns, Larson and Churchill (2012) describe the common 

driving mechanisms of tree spatial patterns in dry conifer forest of the western U.S. Key components 

include clumps of trees across a range of sizes and ages (e.g., patches of old large trees to patches of 

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regeneration), widely spaced individual trees and openings. The process of frequent fire maintains 

this heterogenic structure by creating new openings, which then naturally regenerate from seed 

produced by nearby patches of mature trees. This vegetation-disturbance dynamic is reflected in other 

research in Sierran mixed-conifer forests. Lydersen and North (2012) note that areas burned at lower 

intensity promoted tree regeneration and areas burned at higher intensity created shrub habitat. 

Crotteau et al. (2013) observed greater conifer regeneration in areas with low to moderate burn 

severity, while areas that burned with high-severity had lower conifer regeneration and high shrub 

cover. Crotteau et al. (2013) contribute the lower shrub cover in areas that burned with low severity to 

high shade provided by residual mature trees. Lower shrub abundance and nearby seed sources then 

produce greater amounts of patchy conifer regeneration. The uncharacteristically large high-severity 

patches created by the Rim Fire left few if any remaining large trees and an abundance of shrub 

cover; therefore, restoration of the vegetation-disturbance dynamic described by Larson and Churchill 

(2012) would not occur until a diversity of tree ages and sizes have developed. Planting patterns may 

result in a more patchy structure of seedlings and saplings in the short-term, but would not accelerate 

the development of large trees compared to simpler planting patterns such as in Alternative 5 as 

shown in Table 3.13-9 and Table 3.13-13. As the trees develop over the next 50-60 years, it is the 

future disturbances (e.g., fire, mechanical thinning, insects and diseases), future natural regeneration, 

and variation in microsite productivity that will promote development of fine-scale heterogeneity in 

tree age, size, densities, and spatial arrangements.

Nutrients and Water Availability to Trees

The effectiveness of site preparation and release treatments (especially herbicide treatments) strongly 

correlates with increased water availability to trees. Competition with dense shrubs slows the initial 

growth of conifer seedlings (Conard and Radosevich 1982a; Lanini and Radosevich 1986; McDonald 

and Fiddler 2001; Oliver 1990; Stuart et al. 1993). Although shrubs have been shown to improve 

nitrogen fixing and soil fertility (Conard et al. 1985; Busse 2000; Busse et al. 1996), water availability 

has been shown to override the beneficial effects of improved nutrient availability on tree growth. 

Powers and Ferrell (1996) concluded that on droughty sites, vegetation control plus fertilizer did not 

improve tree growth beyond vegetation control alone. Powers and Ferrell (1996) also found that on 

more productive sites, fertilizer application without vegetation control boosted shrub growth and 

blocked trees from the beneficial effects of increased nutrient availability. Similarly, Powers and 

Reynolds (1999) found that on sites that were both droughty and infertile, trees responded to 

increased water availability before increased nutrient availability. Others have affirmed the benefits to 

tree growth resulting from early shrub control and increased water availability (McDonald and 

Fiddler 2010; Stephenson 1990; Zhang et al. 2006). Reforestation treatments increase water 

availability to conifer seedlings; thereby, setting stands on a trajectory to conifer dominance and the 

creation of structures (e.g., large trees) more like those that existed pre-fire. Reforestation treatments 

also provide opportunities to restore forest structure consistent with historic conditions (Sensenig et 

al. 2013).

Climate Change Influences

Concern has been raised over whether or not it is appropriate to conduct reforestation throughout the 

project area given changes in site suitability and potential vegetation shifts resulting from warming 

climate trends. All tree species have a threshold for drought, beyond which no growth occurs 

(Hinckley and Scott 1971; Royce and Barbour 2001; Waring and Cleary 1967). With trends of 

increasing temperatures and decreasing snow packs in the Sierra Nevada (Lutz et al. 2010; Safford et 

al. 2012; Thorne et al. 2008), understanding the drought-related thresholds of tree species can help us 

understand the potential extent of vegetation change that may occur because of changing climate, and 

assess the sensitivity of individual species within a particular location (Hannah et al. 2002). Species 

that are currently close to their drought threshold or water-balance range limit may be affected by 

increasing water deficits (Breshears et al. 2009). Lutz et al. (2010) evaluated the effect of increasing 

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summer water deficit on individual tree species found in Yosemite National Park. The metric used by 

Lutz et al. (2010) for measuring water balance was the predicted ratio between actual 

evapotranspiration and potential evapotranspiration as affected by warming climate trends. They 

compared the water balance where each tree species is found within Yosemite to the North American 

range of each species to determine which species might be close to their drought threshold. Of all the 

species evaluated, western white pine and mountain hemlock were the only two species with study 

plots clustered around the lower North American threshold for water balance; and therefore, are the 

most at risk. Lutz et al. (2010) concluded that most of the same species found in the Rim 

Reforestation project (i.e., California black oak, Douglas-fir, incense cedar, ponderosa pine, red fir, 

sugar pine and white fir) may occur in locations that will put them at increasing risk of water deficitrelated mortality. That is, the study plots where these species were located were clustered toward the 

arid end of their North American range; however, within the North American range each species was 

found on sites with a lower water balance than that observed in Yosemite. For example, Lutz et al. 

(2010) estimated the North American water balance range for ponderosa pine to be about 0.32 to 

0.99, with a mean of about 0.6. The majority of the areas where ponderosa pine is located in 

Yosemite occurred between 0.42 and 0.63, with an average of about 0.53. While the average in 

Yosemite is lower than the average of the North American range, the majority of ponderosa pine sites 

are still well above the lower threshold. Therefore, there may be some sites where ponderosa pine 

reaches its drought threshold as temperatures increase, but these would likely be areas with the lowest 

site productivity. Based on this information, reforestation in some areas under Alternative 1 may 

experience future water deficit-related mortality. As noted by Lutz et al. (2010), however, the scale 

used for modeling climate is still fairly coarse and underpinned by uncertainty. Topography in the 

project area is highly variable, and like most areas in the Sierra Nevada range, results in highly 

variable microclimatic conditions that drive vegetation structure and composition (Lydersen and 

North 2012); therefore, future climate related mortality is likely to reflect the fine-scale heterogeneity 

of the biophysical landscape. While conifer species may eventually die-off in isolated areas that are 

planted, many areas dispersed across the project area would likely remain habitable to conifers and 

persist despite warming temperatures. Furthermore, areas of poor site quality would likely be dropped 

during unit layout or skipped during site preparation and planting.

In light of potential future water deficit-related mortality caused by climate change, the concept of 

focusing reforestation efforts within climatic refugia, or envelopes, has been raised. Loarie et al. 

(2008) explain that climate trends in California will likely result in shifts in vegetation diversity and 

distribution. From a conservation perspective, species that are able to expand their ranges should 

garner the least concern; however, species with shrinking ranges will likely require the most attention 

and human assistance. As exemplified by Lutz et al. (2010), mountainous areas are expected to harbor 

species with shrinking ranges and may provide future refugia that act as a life boats for biodiversity 

into the next century (Loarie et al. 2008). Groves et al. (2012) argues for a broader approach to 

incorporating climate change into conservation planning because conserving climate refugia 

represents only a partial solution to climate change adaptation and relies largely on climate 

projections and all their associated uncertainties. Additionally, coarse-scale climate envelope models 

may overestimate or misrepresent the projected extinction rates for a given area because they often 

fail to capture topographic or microclimatic buffering (Groves et al. 2012; Willis and Bhagwat 2009). 

Millar et al. (2007) suggest that redundant planting across a range of environments may capture finescale microclimates, increase diversity and provide an ecological buffer that spreads risk rather than 

concentrates it. Furthermore, mixed-conifer refugia are often characterized as cool, moist sites that 

are relatively productive. Productive sites with infrequent fire will tend to burn at higher severities

(Lutz et al. 2012). Kane et al. (2015) demonstrated that this was the case with the Rim Fire. Because 

fire responds rapidly to climate, effects of fire will likely overshadow the direct effects of climate on 

tree species distributions and migrations (Dale et al. 2001; Flannigan et al. 2000). Therefore, 

Alternative 1 would help spread the risk that fire poses to declining conifer species in lower 

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Chapter 3.13 Stanislaus

Vegetation National Forest

elevations (especially sugar pine) across a greater proportion of the Rim Fire landscape; capturing a 

higher frequency of suitable microclimates that may otherwise remain dominated by shrubs and 

hardwoods for decades or centuries. It would also increase connectivity of conifer forest, which 

would enhance ecosystem integrity by increasing the ability of tree species to move and adjust to 

future climate conditions and disturbances (Groves et al. 2012). 

Genetic Diversity

Some literature has raised concerns over genetic diversity being low in plantations due to planting 

commercial species and using nursery genomes (DellaSala et al. 2014). Region 5 currently does not 

use seed orchards, but instead depends solely on collection of wild seed grown in nurseries. Isozyme 

analyses comparing naturally established conifer seedlings and nursery-grown seedlings have found 

no difference in genetic diversity (Shimizu and Adams 1993). Genetic variation would be 

reintroduced from seed collections within the local seed zone. This would be especially beneficial for 

promoting rust-resistant sugar pine within the project area. The trend of declining sugar pine has 

raised significant concern over maintaining genetic diversity in this species to ensure its long-term 

capacity to adapt and survive future natural disturbances and large scale threats to sustainability 

(Burns et al. 2008; Zeglan et al. 2010). Natural regeneration of sugar pine currently makes up only 

1% of all natural conifer regeneration within the 26,009 acres proposed for reforestation. In addition 

to sugar pine, species composition would include a mix of planted conifers (Jeffrey pine, ponderosa 

pine, white fir, incense cedar, Douglas-fir and giant sequoia) and natural regeneration. The proportion 

of species planted would be tailored to fit the site. For example, white fir and Douglas-fir would be 

favored on northern aspects and drainages as opposed to a heavier mix of pine on southern aspects 

and ridges. Overall, however, a greater proportion of pine (about 50% ponderosa pine and 20% sugar 

pine) would be planted to reflect historic species composition (CREP 2008; Sudworth 1900) and 

because pine is less sensitive to drought than other conifer species (Ferrell et al. 1994; Hurteau et al. 

2007). 

Existing Plantations

Prescribed fire and mechanical thinning in existing plantations would remove small, excess standing 

dead and live trees to reduce stand densities and move plantations toward the desired ICO structure. 

Prescribed fire is the initial method for thinning the plantations. Follow-up mechanical treatments 

would remove excess fire killed trees to achieve desired surface and ladder fuel loading, as well as 

further reduce live tree density if necessary. If burn conditions do not permit safe use of prescribed 

fire, mechanical thinning may precede prescribed fire to ensure treatment of plantations in the next 

ten years before excess mortality occurs. Tree species diversity would be promoted by removing 

ponderosa pine and by leaving sugar pine, white fir and incense cedar and thinning around oak. On 

average, only about 300 board feet per acre would be removed because the majority of the trees that 

are currently of merchantable size would be retained. Although the majority of these plantations have 

relatively small trees (less than 15 inches dbh), prescriptions would retain a portion of the largest 

standing dead trees to provide wildlife structures and future large down woody material. Treatments 

would create more openings in the tree canopy and allow more sunlight to reach the forest floor. 

Prescribed fire and mechanical operations would initially kill aboveground portions of shrubs, grasses 

and forbs; however, reduced shading of the forest floor combined with prescribed fire and soil 

disturbance would stimulate sprouting and seed germination of understory vegetation. Treatments 

would also stimulate conifer regeneration (Zhang et al. 2013) and promote fine-scale structural 

complexity as new cohorts of conifers establish over time.

Thinning would improve residual tree health and vigor by removing mostly small, suppressed and 

intermediate sized trees that would otherwise compete for water and growing space. Reducing the 

number of smaller trees would initially increase the average tree diameter and height of the 

plantations and increase the growth of the remaining trees. Over the next 20 years, tree diameter 

would increase across all thinned plantations, with stand averages ranging from about 12 to almost 28 

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inches dbh in the youngest and oldest plantations. Average tree heights would range from about 40 to 

70 feet, respectively. After 60 years, average stand diameters would range from 18 to 31 inches and 

height would range from 60 to 105 feet. As shown in Table 3.13-15, the density of large trees (greater 

than 24 inches dbh) across all thinned plantations would average about 21 trees per acre, which is 

about 15% more large trees than would occur if no action is taken. 

Alternative 1 would treat about 1,990 acres, with prescribed burning only, to enhance deer habitat. 

Prescribed burning would cause low levels of tree mortality and potentially increase vigor of residual 

trees. Large areas with no conifers dominated by oak, shrubs and grasses would experience short-term 

effects such as aboveground mortality, but would readily sprout during subsequent growing seasons. 

Burning would break up the horizontal continuity of shrubs, providing more light, soil moisture and 

growing space for grasses and forbs. Reductions in shrub and oak cover would occur in the shortterm. Over the next decade, however, sprouting shrubs and oaks, as well as new germinates 

stimulated during burning, would expand their crowns and reoccupy growing space. 

Stand Density Index

Reforestation

Reforestation accelerates the establishment of conifer forest. Once trees have reached a size where 

shrub competition no longer significantly influences diameter and height growth, competition among 

trees for water, light and physical growing space becomes an important factor in forest development. 

Reforestation treatments decrease the time until inter-tree competition becomes a factor. SDI is used 

to evaluate the effect of inter-tree competition on forest health and vigor. Alternative 1 proposes 

higher planting densities based on topographic slope positions. The slope positions proposed for the 

highest tree densities are in drainages and on mid-slopes in areas with an old forest mosaic desired 

condition. These areas of higher planting densities (303 trees per acre) would require less time until 

the onset of inter-tree competition. Drainages and old forest mosaic mid-slopes would just reach a 

SDI of about 200 by year 40. By year 50 drainages and old forest mosaic mid-slopes would have a 

SDI of 275 and 267, respectively. Other mid-slope positions (open canopy mosaic outside SFMAs 

and old forest mosaic inside SFMAs) would also exceed a SDI of 230 by year 50 (SDI 244). In total, 

about 17,960 acres would exceed a SDI of 230 within 50 years. Therefore, it would take about 40 to 

50 years before 70% of the project area would start to show increased bark beetle-related mortality 

(Oliver 1995; Oliver and Uzoh 1997). After 60 years, the remaining mid-slope positions (5,471 acres) 

exceed a SDI of 230; however, some slope positions that are planted with lower tree densities 

(fuelbreaks, primary ridges and emergency travel routes) would not reach a SDI of 230 within 60 

years. Even in the absence of thinning or other major disturbances, none of the slope positions reach 

the bark beetle induced maximum SDI of 365 within the 60-year analysis timeframe.

Although primary ridges do not reach a SDI of 230 within the next 60 years, ridges typically have 

shallow soils, lower soil moisture availability, and are more exposed to solar radiation. As 

temperatures and summer water deficits increase with changing climate, these areas are the most 

vulnerable to drought-induced mortality. Having lower SDI levels would improve tree resilience 

during periods of extended drought. Lower SDI levels, however, suggest lower tree canopy cover and 

increased shrub cover would occur, which would increase the risk of high-severity fire in these areas 

during extreme drought (Harris and Taylor 2015; Lydersen et al. 2014). 

Existing Plantations

After prescribed burning and thinning, a total of 2,868 acres of plantation (about 20% of thinned 

plantation acres) would still exceed a SDI of 230. A portion of these acres (105 acres) are small 

patches of late seral closed canopy forest that would exceed a SDI 365 and eventually reach a SDI of 

528 during the 60 year analysis time frame. These patches of older remnant forest are relatively small, 

distributed throughout the existing plantations, and would experience minimal effects from 

treatments. The remaining acres that exceed a SDI of 230 are primarily the older Granite plantations 

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that also have relatively larger trees. Because thinning would focus on reducing biomass sized trees, 

SDI would not significantly change on these acres, but would be reduced below the insect-induced 

maximum SDI of 365. These plantations would remain below a SDI of 365 for about 20 years and 

reach a SDI of 419 during the 60 year analysis time frame. By year 20, an additional 916 acres (7% of 

thinned plantation acres) would increase in SDI and exceed the threshold of 230. In the absence of 

major disturbances, an additional 4,213 acres would not reach a SDI of 230 until sometime between 

year 20 and 60 years after thinning. The remaining plantations would remain in a relatively open 

canopy structure with low conifer densities over the next 60 years. By year 60, a range of stand 

densities, ages and structures would exist. Some openings created during prescribed fire would likely 

remain open and dominated by shrubs and hardwoods. Other openings would begin to regenerate with 

young conifers, promoting uneven-aged structures. Aside from the 105 acres of late seral closed 

canopy forest, an additional 1,894 acres would exceed a SDI of 365, but no other thinned plantations 

would exceed the SDI threshold of 365 during the analysis period of 60 years. 

During the first 10 to 20 years after thinning, residual trees would benefit from reduced stand 

densities, which would increase water and nutrient availability. Residual trees would increase in 

growth and vigor, which would accelerate development of larger trees during the analysis time frame. 

Reduced competition would ease water stress during dry summers and reduce tree mortality during 

periods of more severe drought (D'Amato et al. 2013). Although a large portion of these thinned 

plantations (about 6,000 acres) would not exceed a stand-level SDI of 230 during the analysis time 

frame, as the residual trees increase in size and occupy more growing space over the next 20 years, 

SDI levels would increase. Subsequently, inter-tree competition would slowly intensify and some 

stands would begin to show more evidence of insect-related mortality as they approach SDI levels of 

230 (Oliver 1995; Oliver and Uzoh 1997). Mortality would be more severe during periods of drought 

when trees are water-stressed. If insects and drought are not a factor, SDI levels would continue to 

approach 260 to 280 (50 to 60% of maximum SDI) in some plantations. At these densities 

competition-related mortality would increase and result in “self-thinning” (Long and Shaw 2012). 

Mortality would typically occur in denser patches and on poorer sites where competition is more 

intense between trees, which will further promote structural heterogeneity and uneven-aged 

structures. As trees succumb to insect and competition, SDI levels would decrease and surviving trees 

would benefit from reduced live tree densities. 

Future conifer regeneration was not included in these projections; therefore, SDI values are based on 

existing tree densities. Thinning and prescribed fire would likely stimulate some level of conifer 

regeneration that would eventually contribute to higher SDI levels. Future management decisions 

would need to assess the need for long-term management (e.g., mastication or additional prescribed 

fire) to address changing circumstances that are outside the scope of this analysis and project decision 

space.

Future Management Feasibility

Reforestation

Conifer forest that is stocked with high densities of small trees can result in high SDI levels. 

Conversely, high SDI levels can result from low densities of large trees because large trees require 

more growing space and resources for maintaining health and vigor. For this reason, conifer forests 

inevitably experience SDI increases, especially in the absence of significant disturbances. For this 

reason, thinning intermediate sized trees has been noted as sometimes being necessary to reduce 

competition, accelerate large tree development, and create desired fine-scale heterogeneity in Sierran 

mixed-conifer forests (North et al. 2009). Assuming repeated prescribed burning over the next several 

decades does not significantly reduce tree density, plantations would eventually reach SDI levels that 

induce competition-related mortality. Ideally then, a scenario that balances the culmination of 

increasing SDI levels with the development of merchantable sized trees would provide future 

generations opportunities for offsetting management costs. Such a situation would avoid development 

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of plantations with submerchantable trees that require thinning before undesirable SDI thresholds are 

exceeded.

Stand densities under Alternative 1 would begin to reach suitable SDI levels for requiring thinning at 

about the same time that merchantable sized trees have developed. Long and Shaw (2012) 

recommend thinning when SDI reaches 50 to 60% of maximum SDI. Assuming maximum SDI for 

ponderosa pine dominated mixed-conifer stands is 524, thinning should occur around the time they 

reach a SDI of 260. At this SDI, stands would show an increase in bark beetle-related mortality and 

also begin self-thinning; therefore, thinning would capture some of the potential timber volume while 

still maintaining desirable tree densities and sizes, as well as creating canopy openings that provide 

suitable conditions for pine regeneration. Drainages and old forest mosaic mid-slope plantations 

would be the first to reach a SDI of 260. This would occur by year 50 on 10,786 acres. At that time, 

thinning from below to an SDI of 170 (about 30% of maximum SDI) would remove 4,998 board feet 

per acre and leave 139-149 trees per acre. By year 60, an additional 12,644 acres of mid-slope 

plantations would meet thinning criteria; however, given the lower tree densities in these plantations, 

trees must grow larger to achieve a SDI of 260. Therefore, thinning to the same SDI target requires 

removing larger trees with more volume (8,664 board feet per acre) and thinning to a lower residual 

tree density (107 to 110 trees per acre). As noted previously, some plantations (2,578 acres of 

fuelbreaks and primary ridges) under Alternative 1 would not reach a SDI of 230 within the next 60 

years; and therefore, would not meet thinning criteria. Maintaining these strategically placed fire 

management areas would not produce cost offsets from removal of merchantable timber because 

existing tree densities would be too low. Future maintenance of ladder fuels and shrub cover in these 

areas could be completed at cost using prescribed fire and mechanical operations. 

Existing Plantations

Prescribed fire and thinning the existing plantations today would improve opportunities for future 

management. Reductions in tree density would increase growth and vigor of residual trees and result 

in 15% more large trees per acre greater than 24 inches dbh compared to no treatment as shown in 

Table 3.13-15. In general, a greater number of trees of commercial size would exist in the future 

compared to Alternative 2. As stands continue to increase in density and accumulate ladder and 

surface fuels, removing some of the merchantable intermediate sized conifers would help offset costs 

associated with future fuels reduction operations and wildlife habitat improvement projects. 

Change in Forest Structure

Reforestation

Reforestation treatments would accelerate the establishment of conifer forest in uncharacteristically 

large patches of high-severity fire within a matter of years as opposed to decades or potentially 

longer. Once conifers are established, mid and late seral successional structures would begin to 

develop. Alternative 1 would reforest 16,184 acres more than are currently regenerating naturally. In 

areas that are regenerating naturally (9,825 acres), treatments would help favor a desirable mix and 

density of conifer species. Of the 26,009 acres proposed for reforestation, 3,324 acres are currently 

considered complex early seral forest because they were severely burned and have not been altered by 

humans (DellaSala et al. 2014; Odion and Hanson 2014). Reforestation activities would reduce the 

“complexity” of these areas by removing standing dead trees and controlling understory vegetation, 

but accelerate the development of conifer forest. The other areas proposed for reforestation are 

primarily severely-burned forest that have been impacted by salvage logging or hazard tree removal 

under other Rim Recovery and Rim HT projects and would otherwise remain dominated by dense 

shrub thickets with scattered patches of dense white fir and Douglas-fir.

Over the next 30 years, all plantations would progress from early seral successional classes into mid 

seral successional classes as the average tree size increases. On average, canopy cover would range 

between 10% and 39%, which is still an open canopy condition. By year 40, most of the plantations 

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(90%) would reach canopy covers of greater than 40%. Given the variation of planting densities and 

topographic positions, less than 3,000 acres would remain in a mid-seral open canopy condition with 

25 to 39% canopy cover after 40 years. These open canopies would occur on the fuelbreaks, primary 

ridges and emergency travel routes. In the absence of major disturbance, all plantations would reach a 

mid-seral closed canopy condition by year 50 with canopy covers of 40 to 69%. 

In the long-term, future management and disturbances would transition plantations into various 

successional classes. As exemplified by the Rim Fire, a portion (22%) of the existing plantations 

experienced high severity fire and were reset to an early successional stage; however, the majority of 

the plantations within the Rim Fire experienced a range of burn severities. About 22% experienced 

moderate burn severity, shifting them from a mid-seral closed canopy condition to an open canopy 

condition. About 56% experienced low burn severity. Although the canopy condition of these 

plantations did not significantly change, low levels of mortality would increase the health and vigor 

of residual trees, accelerating development of late seral conditions. Had these plantations not existed 

prior to the Rim Fire, they would likely have been dominated by shrub and hardwood vegetation as a 

result of slow conifer succession following past fires; however, they are now contributing to structural 

diversity across the landscape.

Existing Plantations

Prescribed burning and thinning treatments in existing plantations would increase the diversity of 

forest structure across the landscape. The transition between different structural classes is not static; 

rather, it is a dynamic process driven by tree competition, development and disturbance. Thinning and 

prescribed fire would accelerate transition between structural classes. Some structural classes such as 

open canopy conditions would not occur in the absence of thinning, prescribed fire, or some other 

disturbance. Treatments proposed in the younger Rogge plantations would reduce tree competition 

and accelerate the transition from an early seral structure (average dbh 1 to 6 inches) to a mid-seral 

structure (average dbh 6 to 11 inches). Similarly, thinning older plantations that are currently in a 

mid-seral closed canopy structure would transition them into an open canopy structure and accelerate 

the transition of some plantations into a late seral structure. After 20 years, a portion of the mid seral 

open canopy conditions would transition into a late seral open canopy condition, which is currently 

the rarest structural class on the Rim Fire landscape (Figure 3.13-2). Over the course of the next 60 

years as trees continue to increase in size, all the plantations would eventually return to a closed 

canopy condition (greater than 40% canopy cover), but this would not occur until sometime between 

years 50 and 60. During the next 50 to 60 years, Alternative 1 would provide a greater range of both 

open and closed canopy conditions compared to Alternative 2. 

A total of 2,187 acres of high-severity patches are distributed throughout existing plantations. 

Although relatively small, these patches would fit the definition of complex early seral forest 

(DellaSala et al. 2014; Odion and Hanson 2014). About 1,530 of these acres experienced highseverity fire, which occurred in small patches scattered throughout the 13,934 acres proposed for 

thinning. The remaining 687 acres resulted from moderate-severity fire and are also relatively small 

patches scattered throughout existing plantations. Trees in these patches are relatively small (less than 

15 inches dbh), so thinning would remove some of the dead trees to reduce fuel loading; however, a 

portion of the largest dead trees would be retained.

To enhance deer habitat, an additional 1,990 acres are proposed for prescribed burning only. Areas 

that do not currently have trees would not contribute to changes in landscape forest structure. 

Prescribed fire may decrease tree canopy cover a small amount depending on fire-caused mortality. 

This effect would be minimal on a landscape scale and last for relatively short time (less than 20 

years).

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CUMULATIVE EFFECTS

Cumulative effects are those activities that additively contribute to the direct and indirect effects 

discussed under Alternative 1. Cumulative effects include past, present and reasonably foreseeable 

activities. A list of past, present and reasonably foreseeable activities within the vicinity of the Rim 

Fire landscape are summarized in Appendix B. The temporal boundary of this analysis is limited to 

the time frame in which future management activities are completed.

Past management activities have shaped the existing condition and are not considered further. 

Activities that occur outside of the project area may affect vegetation, but would have no influence on 

vegetation growth, composition, or structure within the project area. Therefore, all ongoing, present, 

and foreseeable activities that occur outside of Rim Reforestation project area do not additively 

contribute to the direct and indirect effects discussed under Alternative 1 for the following indicators: 

tree size and composition, stand density index, and future management feasibility.

The following list describes ongoing and present and reasonably foreseeable future actions within the 

project area that do not cumulatively affect vegetation.

 Ongoing livestock grazing may affect vegetation locally where cattle gather. Cattle do not 

typically eat shrubs or trees. Cattle can trample or crush young seedlings; however, management 

requirements are in place to reduce conflicts between range and reforestation activities. Range 

activities would have no detectable effect on shrubs or conifer growth. As a result there is no 

potential for cumulative effects.

 Present and future transportation-related treatments (maintenance, construction, rerouting, culvert 

replacement/repair, gate installations, and designation changes to roads or trails) do not affect 

sufficient vegetation to create a detectable change in vegetation from existing conditions.

 Ongoing, present and future recreation-related activities are primarily concentrated in areas that 

would not pose conflicts with reforestation and thinning activities. Any potential changes to 

vegetation caused by recreation would not be detectible at a significant scale and would not 

contribute to cumulative effects. Travel by recreationists on designated travel routes does not 

change vegetation; therefore, 4 by 4, OHV and snowmobile travel has no potential for a 

cumulative effect on vegetation.

 Present Rim Fire Habitat Improvement projects, including botany restoration areas, weed 

treatments and meadow work could potentially impact a small number of shrubs and trees; 

however, the effect would not be detectible. 

 Future Rim Fire Rehabilitation work including fence repair, great Grey Owl habitat improvement, 

weed treatments, installation of water troughs and guzzlers and meadow restoration do not affect 

sufficient shrub and tree vegetation to create a detectable change from existing conditions.

Present activities within the project area that do contribute to cumulative effects include the Rim 

Recovery and Rim HT projects which include various mechanical operations that would reduce 

natural conifer regeneration and understory vegetation. These effects are accounted for in the affected 

environment and direct and indirect effects under Alternative 1.

Change in Forest Structure

The present and foreseeable actions discussed here primarily occur outside of Rim Reforestation 

project area (private lands, Yosemite National Park, and other lands within the Rim Fire perimeter), 

but may contribute to changes in landscape forest structure. Present and future management activities 

not included here would not cumulatively contribute to detectible changes in landscape forest 

structure.

Present actions:

 The Rim Fire Habitat Improvement project would remove encroaching conifers to improve 

meadow habitat. This project would reduce tree cover on 397 acres. This amounts to less than 1% 

of the entire Rim Reforestation project area and less than 0.2% of the Rim Fire landscape.

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 The Funky and Groovy Stewardship projects would primarily affect 2,392 acres of mid to late 

seral closed canopy forest. Treatments would decrease tree density and move stands into an open 

canopy forest structure.

Foreseeable future actions:

 Reynolds Creek Ecological Restoration Aspen Release would reduce conifer density on 2 acres. 

Tree cover would remain and have minimal effects on landscape forest structure.

 Reynolds Creek Ecological Restoration Meadow Restoration would remove conifer tree cover 

from meadows on no more than 14 acres. 

 The Reynolds Creek Fuels project would prescribe burn 2,323 acres in recently thinned stands. 

Prescribed fire would reduce shrub cover, conifer regeneration and small tree density, but likely 

have little effect on large tree density. By reducing conifer regeneration and small tree density, it 

would maintain 2,323 acres in an open canopy condition. 

 Rim Fire Rehabilitation work including aspen release and campground planting would reduce 

conifer density on 32 acres and increase conifer density and cover within two developed 

campgrounds (less than 5 acres total). Although the aspen release work would reduce conifer 

cover on in vary small area, tree cover would remain.

 The Reliable Power Project would treat 134 acres of vegetation using a mix of herbicide, hand 

and mastication treatments. Treatments would primarily reduce cover of shrubs and small trees; 

thus, maintaining open canopy conditions. 

 The Reynolds Creek Stewardship, Soldier Creek Timber Sale and the Twomile Ecological 

Restoration Timber Sales (Campy, Looney and Thommy) would primarily affect 4,156 acres of 

mid to late seral closed canopy forest. Treatments would decrease tree density and move stands 

into an open canopy forest structure. 

Most of the present and future management activities (e.g., aspen release and campground planting) 

affect a small area and would not significantly contribute to cumulative changes in landscape forest 

structure. Projects that affect a larger area, such as green thinning and prescribed fire would 

contribute a more significant cumulative change to landscape forest structure. Currently, there is a 

deficit of mid and late seral open canopy structure (Figure 3.13-2). Green thinning projects would 

move 6,548 acres of closed canopy forest into an open canopy condition, which would increase the 

proportion of open canopy structure by about a 4% within the entire Rim Fire landscape. Currently, 

mid and late seral open canopy structure accounts for only 17% of the Rim Fire landscape, so these 

green thinning projects would increase by almost a quarter. These projects would move the landscape 

closer to a more natural range of variability by increasing forest structures that the landscape is 

lacking. Similarly, prescribed fire and treatments that reduce small tree density (e.g., prescribed fire in 

recently thinned stands) would maintain acres already in an open canopy structure for a longer period 

of time.

On private land, 15,479 acres have already been salvage logged, site prepped and planted. Present and 

future actions include herbicide release treatments to accelerate growth of conifers. Release 

treatments would reduce the cover of understory vegetation over the next few years. Because these 

acres have been salvage logged, they are not counted as complex early seral forest. These plantations 

would not impact the remaining 34,449 acres of complex early seral acres created by high-severity 

fire in the Rim Fire, but would accelerate the transition from early seral structure to mid and late seral 

structures. This would reduce the proportion of early seral structure within the Rim Fire landscape by 

about 8%. Within the next 20 to 40 years, plantations on private land would develop into mid seral 

forest. Transition into open or closed canopy conditions would be subject to land owner decisions and 

outside the scope of this analysis.

In total, Alternative 1 would contribute to the following cumulative changes to landscape forest 

structure:

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 Post-Rim Fire early-seral conifer forest would be reduced from 71,552 acres to 32,581 acres. This 

includes 15,479 acres of reforestation on private lands and the 23,492 acres of reforestation on 

NFS lands (26,009 acres minus 2,517 acres of non-conifer cover types). The remaining earlyseral forest makes up about 18% of the Rim Fire landscape (including private land, Yosemite 

National Park and other public lands), which is within the 15 to 20% historic range for early-seral 

structure (Safford 2013).

 Complex early seral forest created by high-severity fire (not including areas of moderate burn 

severity) would be reduced from 36,171 acres to 29,645 acres. These remaining 29,645 acres of 

severely burned conifer forest have not been impacted by salvage, hazard tree, or reforestation 

activities and are not expected to be impacted in the foreseeable future. These acres make up 

about 16% of the Rim Fire landscape (including private land, Yosemite National Park and other 

public lands), which is within the 15 to 20% historic range for early-seral structure (Safford 

2013). 

 Future mid seral closed canopy conditions would increase up to 38,971 acres. This includes 

plantations on both private and NFS lands. Eventually these plantations would make up about 

21% of the future Rim Fire landscape, which is 6% greater than the historic estimate of 5 to 15% 

(Safford 2013). This is assuming no thinning or stand replacing disturbance occurs within the 

next 60 years. Future thinning could transition these plantations into open canopy structures and 

accelerate the development of late seral open canopy forest. Historically, there was 1.5 to 2 times 

the amount of mid seral open forest than there is now. Late seral open canopy currently has the 

greatest deficit; historically, there were about 6 to 11 times more than currently exists. Combined, 

the new plantations on private and NFS lands could someday make up just under half of the 45 to 

75% of the Rim Fire landscape that should be in a mid to late seral open canopy condition (Figure 

3.13-2). 

 Mid and late seral open canopy structure would increase up to 20,482 acres resulting from 

thinning existing plantations and other green thinning. The cumulative effect of these treatments 

will vary considerably over the next 60 years because forests are dynamic and transition into 

various states of open canopy and seral structures depend on future climate conditions and 

disturbances. In general, however, thinning accelerates development of open canopy conditions, 

which are lacking across the Rim Fire landscape. Thinning could increase the open canopy 

structure across the Rim Fire landscape by up to about 11%.

Alternative 2 (No Action)

DIRECT AND INDIRECT EFFECTS

Tree Size and Species Composition

Reforestation

High- and moderate-severity patches are not reforested under Alternative 2. Immediately after the 

Rim Fire, vegetation (including shrubs, grasses, forbs and noxious weeds) rapidly responded and 

began increasing in abundance in moderate- and high-severity burn areas. During the first few years 

after a wildfire, turnover in species composition is considerable, as species that favor young burns 

give way to other species that favor older burns (Siegel et al. 2011). Although grasses, forbs and 

noxious weeds increase in abundance after wildfires, in a matter of years shrubs will overtop them 

and increase in dominance. For example, equations developed by Kie (1985) indicate that deerbrush 

and whitethorn shrub growth will increase 35 to 50% following reductions in canopy cover of 35 to 

65%; similar to those found in moderate- and high-severity burn patches. During these first years 

after a wildfire, conifer regeneration also occurs; however, episodic events and conditions such as 

seed dispersal, bare soil, soil moisture and low shrub competition must coincide to result in continued 

conifer establishment and survival (Bonnet et al. 2005). As a result, conifer regeneration immediately 

after the Rim Fire was patchy, limited in extent (9,825 acres out of 26,009 acres), and mostly 

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occurred within close proximity to mature conifers that survived the fire as displayed in Table 3.13-8 

and Figure 3.13-4. 

Additional reforestation would rely on secondary succession to reforest following the Rim Fire. 

Secondary succession is a plant-by-plant replacement process that occurs following a disturbance, 

where one plant species invades and replaces another (Horn 1974). Reinvasion of severely-disturbed 

forests often is very slow and unpredictable because of complex interactions among propagules as 

well as site and climatic conditions (Kozlowski 2002). While conifer seed dispersal is possible for 

longer distances (Shatford et al. 2007), the proportion of seed produced and dispersed is typically low 

at 1 to 5% (Nathan et al. 2002). Furthermore, seeds dispersed longer distances are less likely to 

successfully germinate and persist (Lesser and Jackson 2013; Nathan et al. 2002; Saigo 1969), which 

slows succession from shrub dominance to conifer forest. High and moderate severity areas would 

likely continue being dominated by shrubs similar to untreated control stands examined in research 

(McDonald and Fiddler 1995). In mixed-conifer forest types, Crotteau et al. (2013) found that shrubs 

continued to dominate high-severity patches 10 years after a wildfire, overtopping more than 60% of 

natural conifer regeneration in high-severity patches. McDonald and Fiddler (1995) found that forest 

areas in the Sierra Nevada that were dominated by shrubs required treatment to return conifer 

dominance. McDonald and Abbott (1997) found that areas not treated to reduce ceanothus and 

manzanita experienced changes in dominance of shrub species through time, but shrubs continued to 

dominate and increase in dominance over the next 31 years.

Figure 3.13-6 Forest Regeneration Comparison near Crane Meadow Following 1973 Granite Fire

Slow secondary succession from shrubs to conifer forest has been observed within the Rim Fire 

perimeter. Figure 3.13-6 displays aerial photographs of the Crane Meadow vicinity, which burned in 

the 1973 Granite Fire. The photographs were taken in 1944 (prior to the fire) and 1998 (25 years after 

the fire). Following the Granite Fire, the Forest Service artificially regenerated the areas surrounding 

the private parcel, outlined in the center of the photographs. As shown on the 1998 photo, the 

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Draft Environmental Impact Statement and Environmental Consequences

regenerated areas grew; however, the private land was never planted and exemplifies the lack of 

natural regeneration and the potential long-term impacts of high-severity fire in Sierran mixed-conifer 

forests.

Competition with dense shrubs has been shown to slow the initial growth of tree seedlings (Conard 

and Radosevich 1982a; Lanini and Radosevich 1986; McDonald and Fiddler 2001; Oliver 1990; 

Stuart et al. 1993). Therefore, natural conifer regeneration would likely experience the slowest growth 

of all the alternatives. Table 3.13-10 summarizes conifer and hardwood growth at years 10, 20 and 

60. It also shows estimated tree densities throughout the 60-year analysis time frame. Compared to

the other alternatives, the effects of no release treatments become evident by year 10. The average 

height of conifers is only 3.6 feet compared to 7.3 feet under Alternative 1. By year 20, average 

height under Alternative 2 is about half as much as Alternative 1. Competition also significantly 

slows tree diameter growth. The average conifer dbh under Alternative 2 at years 10 and 20 are about 

3.5 times less than Alternative 1. The size of hardwoods would not be that different from Alternative 

1. Height growth projected by RCONIFERS was similar to findings of McDonald and Abbott (1997) 

in study plots with medium to high levels of shrub cover. Slower conifer growth would also prolong 

the time before conifers begin to overtop hardwoods. As a result, hardwoods would experience 

slightly lower levels of competition related mortality in the first 10 to -20 years; however, this effect 

would be small because inter-tree competition would still occur between hardwoods, which would 

also decrease hardwood densities over time.

Table 3.13-10 Alternative 2 Tree Density and Characteristics at Years 10, 20 and 60

Species Year PCR1

Mean

CBH1

Mean

DBH1

Mean

DBH 

Minimum

DBH 

Maximum

Height

Mean

Height

Minimum

Height

Maximum

TPA1

Mean

TPA 

Minimum

TPA 

Maximum

Conifers 10 87.8 0.4 0.2 0.0 0.8 3.6 1.4 7.9 571 279 6,506

Conifers 20 61.0 4.8 1.7 0.0 5.1 12.4 3.4 27.6 482 254 2,373

Conifers 60 48.0 29.5 9.0 3.3 25.5 56.7 17.6 110.2 344 236 814

Hardwoods 10 83.3 2.0 1.8 0.5 3.7 12.1 6.9 23.7 53 38 104

Hardwoods 20 58.6 10.5 4.2 2.1 6.0 25.5 17.7 32.0 20 14 37

Hardwoods 60 39.7 26.0 6.8 3.5 11.4 43.2 27.3 53.6 15 5 24

1 Trees per acre is based acres with natural conifer regeneration and does not include acres without conifer regeneration

PCR=percent crown ratio; CBH=canopy base height in feet; DBH=diameter at breast height in inches; TPA=trees per acre.

By year 60, the difference between conifer tree size under Alternative 2 and the other alternatives 

tends to decrease. For example, dbh at year 60 under Alternative 2 is about 1.5 times smaller than 

Alternative 1, compared to about 3.5 times smaller than at year 20. This trend is likely caused by two 

factors: effects of tree competition and abrupt changes in competition derived from the modeling 

methodology. Although only a portion of the project area has conifer regeneration (9,825 acres out of 

26,009 acres), where it does occur, it is patchy and typically very dense. On average there are over 

500 seedlings per acre, but in many cases conifer seedling density exceeds 1,000 per acre. As Table 

3.13-10 displays, high tree densities would cause intense competition between young trees and over 

time cause tree densities to sharply decline, but still remain relatively high (Table 3.13-10). As tree 

densities decline, residual trees would experience increases in growth rate and the difference in dbh 

and heights compared to the other alternatives would slowly shrink with time. Beginning at year 20, 

FVS was used to model growth instead of RCONIFERS. Unlike RCONIFERS, FVS assumes trees 

are well-established and relatively free from competition-related growth effects from understory 

vegetation. Therefore, transferring to FVS would effectively emulate a release treatment at year 20. 

While all alternatives would experience some level of the same release, this effect is likely more 

exaggerated under Alternative 2 than any other alternative because the trees are smaller and the 

average tree height (about 12 feet) is small enough to suggest that trees are still competing with 

shrubs. For instance, Shatford et al. (2007) noted that during the first 10 to 20 years the majority of 

conifers they observed were overtopped by competing vegetation because shrub growth remains

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relatively vigorous during this time after fire. Although shrubs tend to slow in growth after this time 

period, they are fully developed and still sequestering a substantial amount of water and light 

resources to maintain respiration of living tissues. Despite this plateau in shrub growth rates, conifers 

must still compete for water and light, which results in sustained slow tree growth that is not 

accounted for in FVS. 

Research in Sierran mixed-conifer forests suggests that, in addition to large patches of moderate- and 

high-severity fire being dominated by a mix of shrub species, tree species dominance typically shifts 

from ponderosa pine, sugar pine and Jeffrey pine to fir species (Collins and Roller 2013; Crotteau et 

al. 2013; Nagel and Taylor 2005). There have been some instances of relatively high densities of 

ponderosa pine regenerating after wildfires. After the Freds Fire on the El Dorado National Forest, 

Bohlman (2012) observed high levels of natural ponderosa pine regeneration; however, they note that 

the relatively high abundance of ponderosa pine was somewhat unique in their experience compared 

to regeneration inventories they had conducted on 15 other fires. Table 3.13-8, showing plot data in 

the Rim Reforestation project area, confirms that a trend of shrub and fir dominance is likely to occur. 

This table also shows the proportion of all pine species combined (ponderosa pine, sugar pine, 

knobcone pine, grey pine and Jeffrey pine), currently accounts for 13% of all conifer regeneration 

within the project area and is not expected to naturally shift to pine dominance within the next 60 

years. Areas of very high seedling densities tend to be dominated by white fir or Douglas-fir. During 

the first 10 years, these conifer thickets would experience intense competition and self-thin; therefore, 

a larger proportion of conifer mortality would occur in white fir and Douglas-fir during these early 

years, increasing the proportion of pine species from about 13% to 21% by year 10. This proportional 

shift to pine would significantly slow as trees increase in size and inter-tree competition begins. 

White fir and Douglas-fir can tolerate growing in denser stand conditions than pine, so the rate of 

pine mortality would likely increase as the rate of white fir and Douglas-fir mortality decreases. 

However, given the disproportionate densities of white fir and Douglas-fir compared to pine species, 

a greater number of white fir and Douglas-fir trees would still likely die despite the increasing rate of 

pine mortality. Therefore, the proportion of pine species would continue to increase between years 10 

and 60, but only an additional 5%. By year 60, pine species would make up 26% of the species 

composition on average. This is much lower than historically occurred in most stands, with ponderosa 

pine alone accounting for typically greater than 50% of most stands in the lower to middle elevations 

on the STF (CREP 2008; Sudworth 1900). 

Slower tree growth during the first 10 to 20 years would also prolong the time until dependable and 

abundant conifer seed production occurs. Conifers can produce seed as young as 7-10 years old; 

however, their performance is more erratic than that of mature trees (Laacke 1990; Oliver and Ryker 

1990). White fir does not produce dependable cone crops until about age 40 (Laacke 1990). This is 

about 20 years before ponderosa produces dependable cone crops (Oliver and Ryker 1990). The best 

seed producers for white fir are trees between 12 and 30 inches dbh, which is smaller than the best 

producers for ponderosa pine (Laacke 1990; Oliver and Ryker 1990). In California, the best seed 

producing size for ponderosa pine is greater than 25 inches dbh (Oliver and Ryker 1990). Based on 

tree age and growth model projections, white fir would likely reach necessary tree sizes for 

dependable seed production before ponderosa pine. Given the already high proportions of white fir 

and its ability to more dependably reproduce sooner than ponderosa pine, white fir would likely 

remain the dominant trees species.

Research suggests that low- and high-severity fire begets more of the same severity (van Wagtendonk 

et al. 2012). Shrub cover is a good predictor of fire behavior (Lydersen and North 2012; van 

Wagtendonk et al. 2012). Under low live fuel moisture conditions, shrub patches can burn at higher 

intensity than fuels in surrounding forest vegetation (Knapp et al. 2012; Skinner and Taylor 2006). 

High shrub cover and a shift toward fir dominance is likely to promote high-severity fire, especially 

when combined with current climate trends that are resulting in more frequent wildfire and extreme 

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drought conditions (Coppoletta et al. 2015; Crotteau et al. 2013). The likelihood of future highseverity fire would further reduce conifer forest cover and result in expansion of shrub and chaparral 

vegetation. The Rim Fire is an indication that a shift in vegetation-disturbance dynamics is transpiring 

(Harris and Taylor 2015). This shift has precipitated as a result of forest densification (driven by fire 

suppression and other land management practices) and appears to be accelerated by drought 

conditions that are resulting from changing climate (Crotteau et al. 2013; Miller et al. 2012). If 

patterns of high-severity fire become entrenched, large portions of forests may become locked into 

cycles of repeat high-severity fires (Kane et al. 2015). Large fire-created openings in the project area 

are likely to remain filled with dense thickets of shrubs and scattered thickets of conifer regeneration. 

If a cycle of high-severity fire continues, these shrub-dominated patches would persist and expand. 

Alternative 2 would provide no intervention in current departure of climate- and vegetationdisturbance dynamics compared to historic dynamics. Effects of fire will likely overshadow the direct 

effects of climate on tree species distributions and migrations because fire responds rapidly to climate 

(Dale et al. 2001; Flannigan et al. 2000). The Rim Fire has exemplified how fire might accelerate 

vegetation shifts by killing all or most conifer trees within uncharacteristically large high-severity 

patches (Harris and Taylor 2015; Miller et al. 2009). Although patches of conifer regeneration exist, 

they are dominated by white fir and Douglas-fir as opposed to pine. Pine is less sensitive to drought 

than other conifer species (Ferrell et al. 1994; Hurteau et al. 2007); therefore, these conifer patches 

are more likely to be negatively affected by warmer and longer periods of summer drought. Lydersen 

et al. (2014) and Harris and Taylor (2015) found that cool, moist areas experienced lower fire 

severities during the Rim Fire. These areas may act as climate refugia that provide forest cover in 

light of changing climate; however, Kane et al. (2015) demonstrated that during periods of extreme 

drought, more productive sites that have higher densities of trees and surface fuels will likely 

contribute to creation of large high-severity patches. In light of climate change, areas within the Rim 

Reforestation project area that are regenerating with high densities of white fir and Douglas-fir may 

be less affected by wildfire during years of normal precipitation, but prone to high-severity fire during 

extreme droughts. Therefore, the small proportion of the project area that does have natural conifer 

regeneration is at a greater risk of being lost if severe droughts are likely to increase in frequency. The 

risk of losing declining pine species in lower elevations (especially sugar pine) is greater in 

Alternative 2, due to the likelihood of high-severity wildfire removing the remaining conifer 

diversity. Microclimates that are well suited for conifers and are distributed throughout the severely 

burned project area, would not reforest naturally or be planted within the project time frame. Conifer 

forest connectivity would not be enhanced or accelerated, which would reduce the ability of pine 

(especially sugar pine) to move and adjust to future climate conditions and disturbances.

Existing Plantations

Without thinning, smaller suppressed and intermediate sized trees would continue to compete for 

water and growing space, slowing the growth of individual trees. Over the next 20 years, average tree 

diameters would range from about 6 to almost 12 inches dbh in the youngest and oldest plantations. 

Average tree heights would range from about 20 to 45 feet. After 60 years, diameters would range 

from 9 to 17 inches and height would range from 33 to 75 feet. After 60 years, large tree density 

(greater than 24 inches dbh) would average 18 trees per acre, which is 15% less than Alternative 1. 

As the trees continue to grow, canopy openings created by the Rim Fire would shrink, and in many 

cases, disappear as trees mature; therefore, fewer opportunities for conifer regeneration and 

development of understory vegetation would exist. As a result, horizontal and vertical forest structure 

would become more homogenized over time. Tree species composition would not significantly 

change in the absence of disturbance or thinning. 

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Stand Density Index

Reforestation

No reforestation activities would occur under Alternative 2, so discussion of SDI is limited to only 

portions of the project area that currently have natural conifer regeneration (9,825 acres out of 26,009 

acres). While there may be low levels of natural conifer regeneration outside these areas, expansion of 

dry conifer forest into shrub dominated vegetation is slow (Barton 2002; Collins and Roller 2013; 

Goforth and Minnich 2008; Nagel and Taylor 2005; Roccaforte et al. 2012; Shatford et al. 2007), and 

would likely not qualify as conifer forest cover (greater than 10 to 25% conifer cover) according to 

CWHR criteria during the 60-year analysis time frame.

Overall, areas that are naturally regenerating within the project area increase in SDI rapidly because 

of the high densities of conifer seedlings. The highest densities are located in drainages and 

emergency travel routes. This is likely because these areas tend to be located in cooler, moister areas 

compared to mid-slopes and ridges; therefore, higher densities of white fir and Douglas-fir occurred 

in these areas prior to the Rim Fire. As a result, patches of conifer regeneration reach high SDI levels 

quickly in these areas. Within 20 to 30 years 385 acres of unsalvaged drainages and 31 acres of 

unsalvaged emergency travel routes would exceed a SDI of 300 and 365, respectively. After 40 years, 

a total of 2,940 acres would reach or exceed a SDI of 230 and 823 acres would exceed a SDI of 365. 

By year 60, all areas of natural regeneration would exceed a SDI of 230, of which, 38% would exceed 

a SDI of 365 and 23% would reach or exceed a SDI of 450. 

The majority of the natural regeneration is white fir and Douglas-fir. These species tend to have a 

larger maximum SDI. Maximum SDI for ponderosa pine, white fir and Douglas-fir in Sierran mixedconifer forests is 446, 634 and 570, respectively (Dunning and Reineke 1933). When factored 

together, maximum SDI for mixed species stands generally range from 524 to 533 for pine dominated 

stands and 584 to 592 for fir dominated stands (Long and Shaw 2012). Lower maximum SDI levels 

induced by bark beetles (Oliver 1995) are typically associated with even-aged pine dominated stands. 

Therefore, patches of fir-dominated natural regeneration should be able to tolerate higher SDI levels. 

Increased competition-, insect- and drought-related mortality would become more prevalent as SDI 

levels reached and exceeded 365 to 400 (i.e., about 60% of maximum SDI, Long and Shaw 2012), 

which would occur between years 30 and 40. Although white fir and Douglas-fir would tolerate 

higher SDI levels, ponderosa pine would not. The maximum SDI for ponderosa pine is 446 (Dunning 

and Reineke 1933); therefore, it would experience increasing rates of mortality over time. Ponderosa 

pine mortality would likely begin as early as 20 to 30 years from now when SDI levels near and 

exceed 60% of its maximum SDI. As a result, white fir and Douglas-fir would maintain a greater 

proportion of the conifer forest within the project area over the next 60 years; further departing from 

desired species composition and ecological integrity.

Existing Plantations

Of the existing plantations proposed for thinning, 3,904 acres currently exceed a SDI of 230 and 

about half of these acres exceed a SDI of 365. Without thinning, the existing plantations would 

exceed SDI levels of 230, about 20 years faster than compared to the other alternatives. By year 20, 

an additional 2,821 acres would exceed a SDI of 230. By year 40, a total of 7,997 acres would exceed 

SDI levels of 230. Thinning under the other alternatives would prevent most of these plantations from 

exceeding a SDI of 365. Without thinning, however, 7,596 acres would exceed SDI of 365 by year 

60. That is, almost four times as many acres would exceed a SDI of 365 by year 60 compared to the 

other alternatives.

Without thinning, trees would not benefit from reduced stand densities, which would decrease water 

and nutrient availability to individual trees. Trees would experience slowed growth and reduced 

vigor, which would slow development of larger trees during the analysis time frame. Water stress 

during dry summers would intensify and tree mortality during periods of more severe drought would 

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increase. As the trees increase in size and occupy more growing space over the next 20 to 60 years, 

SDI levels would increase to levels well beyond 365; the insect-induced SDI maximum (Oliver 1995; 

Oliver and Uzoh 1997). Subsequently, inter-tree competition would severely intensify and stands 

would likely show widespread evidence of insect-related mortality. Mortality would be more severe 

during periods of drought when trees are water-stressed. If insects and drought were not a factor, SDI 

levels would still be well beyond the threshold for self-thinning (50 to 60% of maximum SDI). At 

these densities competition-related mortality would be inevitable and result in “self-thinning” (Long 

and Shaw 2012). Like the other alternatives, mortality would typically occur in denser patches and on 

poorer sites where competition is more intense between trees; however, given the homogenous 

structure of such high tree densities, patches of mortality would likely be larger. Large patches of 

mortality would promote homogeneity of species composition and structure. 

Future Management Feasibility

Reforestation

Overall, Alternative 2 would provide the fewest acres that might someday provide merchantable 

wood products for offsetting future management costs. Like Alternative 1, thinning criteria would not 

be met until about 50 years from now. Within the 9,825 acres that are expected to successfully 

regenerate with conifers, 1,504 acres would satisfy thinning criteria by year 50. Thinning would 

remove 4,451 board feet per acre. By year 60, an additional 6,062 acres would satisfy thinning criteria 

and remove 5,840 board feet per acre. After thinning to a SDI of 170, residual tree densities would 

range from 157 to 235 trees per acre. During the first 60 years, 2,259 acres never satisfy the thinning 

criteria despite most of these areas exceeding SDI levels of 400. Therefore, thinning to the target SDI 

of 170 would yield less than 2,000 board feet per acre, suggesting that small trees would still 

dominate these areas after 60 years. In total, Alternative 2 would result in 18,443 acres of suitable 

forest land that would not provide any cost offsets for future management.

Existing Plantations

As existing plantations increase in density, individual tree growth slows. Forgoing thinning would 

result in 15% fewer large trees (greater than 24 inches dbh) per acre. Similarly, fewer trees would 

reach merchantable sawtimber sizes during the next several decades and reduce potential 

opportunities to offset future costs associated with fuels reduction and wildlife habitat management.

Change in Forest Structure

Reforestation

Alternative 2 would rely on natural secondary succession to transition the excess of more than 30,000 

early seral acres within the Rim Fire landscape into mid and late seral structures. Research suggests 

that high-severity fire creates vegetation conditions that promote more high-severity fire (van 

Wagtendonk et al. 2012). Patterns of shrub dominance and abundant white fir regeneration indicate a 

shift away from a pine-dominated, frequent lower-severity fire system (Coppoletta et al. 2015; 

Crotteau et al. 2013). Given the uncharacteristically large patches burned by high-severity fire during 

the Rim Fire (Miller et al. 2009), transition into forest cover would be unpredictable and slow 

(Crotteau et al. 2013; Kozlowski 2002; Nagel and Taylor 2005). Intervention is required to help 

restore both pine composition and frequent fire as an ecological process (Crotteau et al. 2013; Harris 

and Taylor 2015). Without reforestation, substantial expansion of conifer forest beyond areas already 

regenerating would likely not occur until trees reach a size or age that can produce dependable cone 

crops. For white fir, which is the most abundant natural regeneration in the project area, this would 

likely not occur until 40 to 60 years from now (Laake 1990); at which time, newly established trees 

would likely experience slow growth and remain in an early seral structure well beyond the 60-year 

analysis timeframe. Additionally, conifer regeneration would mostly occur near existing seed sources 

(Bonnet et al. 2005), but some small numbers of seedlings could establish farther away in severely 

burn areas (Shatford et al. 2007). Considering the slow growth of seedlings once established among 

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dense shrubs, however, these trees would likely require several decades to overtop shrubs and 

establish conifer forest (Nagel and Taylor 2005; Shatford et al. 2007). As a result, about 58% of the 

23,492 acres (26,009 acres minus 2,517 acres of non-conifer cover types) proposed for reforestation 

would remain in an early seral structure dominated by shrubs and hardwoods during the next 60 

years. This is about three times the proportion of the project area that would have historically 

occurred in an early seral structure (Safford 2013). 

The naturally regenerating areas would experience slow tree growth due to competition with shrubs 

or high densities of other trees. Development of mid-seral conditions in these patches would also be 

slow and not emerge until sometime between 40 and 60 years from now. In the absence of 

disturbance, tree densities in patches of regeneration would remain high, so no open canopy condition 

would occur during the analysis time frame. 

Existing Plantations

No thinning or prescribed fire in existing plantations would result in lower diversity of landscape 

forest structure during the next 60 years. Without treatment, closed canopy conditions would persist 

in the absence of disturbances. Areas that currently have open canopy structure because of the Rim 

Fire would eventually return to closed canopy conditions. Within 10 years all but about 750 acres is 

estimated to return to closed canopy conditions. Within the next 30 to 40 years no mid- or late-seral 

open canopy structure would exist. 

CUMULATIVE EFFECTS

Cumulative effects are those activities that additively contribute to the direct and indirect effects 

discussed under Alternative 2. Cumulative effects include past, present and reasonably foreseeable 

activities. A list of past, present and reasonably foreseeable activities within the vicinity of the Rim 

Fire landscape are summarized in Appendix B. The temporal boundary of this analysis is limited to 

the time frame in which future management activities are completed.

Past management activities have shaped the existing condition and are not considered further. 

Activities that occur outside of the project area may affect vegetation, but would have no influence on 

vegetation growth, composition, or structure within the project area. Therefore, all ongoing, present, 

and foreseeable activities that occur outside of Rim Reforestation treatment units do not additively 

contribute to the direct and indirect effects discussed under Alternative 2 for the following indicators: 

tree size and composition, stand density index, and future management feasibility. 

The ongoing, present and reasonably foreseeable future actions within the analysis area that do not 

cumulatively affect vegetation are the same as discussed under Alternative 1.

Present activities occurring within the project area that do contribute to cumulative effects include the 

Rim Fire Recovery and Rim Hazard Tree projects. These projects include various types of mechanical 

operations that would reduce natural conifer regeneration and understory vegetation. These effects 

have already been accounted for in the description of the affected environment and discussion of 

direct and indirect effects under Alternative 2.

Change in Forest Structure

The present and foreseeable actions that may contribute to a cumulative effect to landscape forest 

structure are the same as discussed under Alternative 1; therefore, the following list discusses only the 

cumulative effects resulting from Alternative 2 in the context of the Rim Fire landscape. In total, 

Alternative 2 would contribute to the following cumulative changes to landscape forest structure:

 Post-Rim Fire early-seral conifer forest would be reduced from 71,552 acres to 46,248 acres. This 

includes 15,479 acres of reforestation on private lands and the 9,825 acres of natural conifer 

regeneration on NFS lands. The remaining early-seral forest makes up just over 25% of the Rim 

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Draft Environmental Impact Statement and Environmental Consequences

Fire landscape (including private land, Yosemite National Park and other public lands), which is 

greater than the 15 to 20% historic range for early-seral structure (Safford 2013). 

 Complex early seral forest created by high-severity fire (not including areas of moderate burn 

severity) would remain at 34,499 acres, which makes up about 19% of the Rim Fire landscape 

(including private land, Yosemite National Park and other public lands). This is almost equal to 

the maximum of the 15 to 20% historic range for early-seral structure (Safford 2013).

 Future mid-seral closed canopy conditions would increase up to 25,304 acres. This includes the 

plantations on private land and natural regeneration on NFS lands. Eventually these plantations 

and patches of conifer regeneration would make up about 14% of the future Rim Fire landscape, 

which is within the historic estimate of 5 to 15% (Safford 2013). This is assuming no thinning or 

stand replacing disturbance occurs within the next 60 years. Future thinning could transition these 

areas into open canopy structures and accelerate the development of late-seral open canopy forest. 

Historically, 1.5 to 2 times the amount of mid seral open forest existed than is present now. Late 

seral open canopy currently has the greatest deficit; historically, there were about 6 to 11 times 

more than currently exists. Without planting on NFS lands, development of future mid and late 

seral structures would be limited to the new plantations on private lands and natural regeneration 

on NFS lands. Assuming no stand-replacing events, these plantations and patches of forest would 

make up at most one third of the 45 to 75% of the Rim Fire landscape that should be in a mid to 

late seral open canopy condition (Figure 3.13-2). 

 Mid and late seral open canopy structure would increase up to 6,548 acres resulting from other 

green thinning. Thinning accelerates development of open canopy conditions, which are lacking 

across the Rim Fire landscape. Thinning projects would increase the open canopy structure across 

the Rim Fire landscape by up to about 4%, which is less than Alternative 1. 

Alternative 3

DIRECT AND INDIRECT EFFECTS

Tree Size and Species Composition

Reforestation

Alternative 3 would reforest the same number of acres as Alternative 1, but planting patterns and 

densities would differ as described in Chapter 2.02 Although Alternative 3 has fewer planting patterns 

than Alternative 1, it has a larger range of conifer planting densities. Alternative 3 would plant more 

acres at higher initial densities than Alternative 1; however, no herbicides would be used. Only 

manual release treatments are proposed under this alternative. Despite a greater number of acres being 

site prepped with deep tilling and forest cultivation, planted conifers under Alternative 3 would likely 

experience higher rates of initial mortality. Based on survival exams from the Mi-Wok and Groveland 

Ranger Districts, areas site prepped with deep tilling would have better survival than areas that did 

not. Deep tilling kills above-ground portions of shrubs and breaks-up below-ground roots and 

rhizomes (McDonald et al. 2004), reducing initial competition for water during the first growing 

season after planting. Based on past experience on the STF, initial conifer survival is estimated at 

50% of the initial planting density in areas prepped with deep tilling and cultivation when followed 

by manual releases as shown in Table 3.13-4. Experience on the STF has also shown that manual 

releases without deep tilling result in much lower initial survival rates of about 30%, as shown in 

Table 3.13-4. After accounting for initial seedling mortality and oak buffers, conifer density during 

the first decade would range between 41 and 172 trees per acre and decline to 38 to 162 trees per acre 

over the next 60 years as displayed in Table 3.13-11. Alternative 3 would have similar oak and 

hardwood sizes and densities as Alternative 1. The effect of planting pattern on the development of 

fine-scale heterogeneity is similar to Alternative 1. Planting patterns would create open stand 

structures with small clumps of seedlings and saplings in the short-term; however, variation in tree 

sizes, ages, and spatial distribution would require several decades at minimum to develop.

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Table 3.13-11 Alternative 3 Tree Density and Characteristics at Years 10, 20 and 60

Species Year PCR1

Mean

CBH1

Mean

DBH1

Mean

DBH 

Minimum

DBH 

Maximum

Height

Mean

Height

Minimum

Height

Maximum

TPA1

Mean

TPA 

Minimum

TPA 

Maximum

Conifers 10 92.3 0.4 0.4 0.0 0.8 5.3 1.7 7.5 120 41 172

Conifers 20 67.0 5.4 2.8 0.1 4.8 16.3 4.7 24.2 120 40 172

Conifers 60 63.8 24.5 13.6 5.1 26.8 67.6 25.0 102.2 112 38 162

Hardwoods 10 82.7 1.9 1.3 0.6 2.9 10.7 7.8 21.0 50 38 63

Hardwoods 20 64.9 9.1 4.4 3.0 6.2 26.0 19.1 32.9 19 14 25

Hardwoods 60 42.7 25.2 7.2 4.2 11.5 44.0 27.3 61.1 17 13 23

1 PCR=percent crown ratio; CBH=canopy base height in feet; DBH=diameter at breast height in inches; TPA=trees per acre.

Deep tilling and forest cultivation (DTFC) would primarily be completed in the fall, so conifers 

planted in the following spring would benefit from reduced competition until shrubs, grasses and 

forbs recover. Areas that are not suitable for deep tilling and forest cultivation would be manually 

released either during planting or shortly thereafter. Water availability to young trees would be 

effectively diminished in areas that are not deep tilled as compared to areas that are deep tilled 

because the available water would be more easily consumed by shrubs with intact below-ground roots 

and rhizomes. Although not as effective as herbicide releases, repeated annual manual releases have 

proven fairly effective on most shrubs, grasses and forbs. McDonald and Fiddler (1997) evaluated 

different manual release treatments and determined that grubbing a radius of less than 5 feet around 

conifer seedlings significantly decreased conifer growth; however, multiple manual releases that 

removed vegetation within a 5-foot radius around conifer seedlings increased tree heights by about 

1.5 times compared to a control. Creating only a 2-foot radius had no effect on tree growth. Growth 

projections made using RCONIFERS resulted in similar results. Conifer heights at year 10 under 

Alternative 3 are about 1.5 times the heights estimated for Alternative 2. It should be noted, however, 

that tree heights in the McDonald and Fiddler (1997) study were about 14 feet after 10 years, which is 

considerably taller than the average height estimated for this analysis. This difference is likely a result 

of both site conditions and the large presence of bearclover cover within the Rim Reforestation 

project area. Bearclover was not present in the study conducted by McDonald and Fiddler (1997). 

Mechanical and manual releases have proven ineffective with bearclover (McDonald et al. 2004). 

Tappeiner and Radosevich (1982) found that trees grown in bearclover only achieved heights of about 

6 feet after 19 years following a single herbicide application. While this was a slight increase over the 

control, multiple treatments are necessary to effectively control bearclover (McDonald et al. 2004). 

Tree heights estimated under Alternative 3, however, would average just over 16 feet after 20 years, 

which is similar to study plots with low shrub cover observed by McDonald and Abbott (1997). 

While not as tall as trees in Alternative 1, this is a large increase over Alternative 2 because handgrubbing would provide some increases in water availability, albeit not as much as would occur with 

repeated herbicide applications. Taller average tree heights would also likely result from conifers 

growing in other shrub types where hand-grubbing would more effectively increase conifer growth 

compared to areas dominated by bearclover. Noxious weeds could rapidly establish in recently deep 

tilled or hand grubbed areas when mineral soil is exposed; therefore, conifer growth responses could 

be diminished if noxious weeds are present or if manual grubbing and pulling of known noxious weed 

treatments prove ineffective.

At year 20 when modeling is switched from RCONIFERS to FVS, tree growth rates artificially begin 

to match or even surpass rates in Alternative 1 because FVS does not account for shrub competition; 

however, shrubs would likely still impact tree growth beyond this age because shrubs would continue 

competing for water. Furthermore, by year 20 the average canopy base height under Alternative 1 is 

about 2 feet greater than Alternative 3. The average crown ratio is also less under Alternative 3. This 

suggests that trees under Alternative 1 are both taller and have larger crowns at year 20. Larger 

crowns indicate more needles (leaves) available for photosynthesis, which promotes faster height and 

diameter growth; yet, by year 60 the average dbh in Alternative 3 is almost the same as Alternative 1, 

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suggesting that the sudden artificial release from shrub competition at year 20 (i.e., switching to FVS) 

contributed to sudden increases in height and diameter growth. 

A hurdle related to Alternative 3 worth noting is the high cost and difficulty associated with 

effectively completing manual releases. The Society chapter (Chapter 3.10) displays the cost analysis. 

Manual release is difficult work and labor intensive, making it expensive, especially given the large 

number of acres that would require manual release under Alternative 3. Past experience on the STF 

has demonstrated the difficulties involved with manual release. Many contracts went into default 

during the 1990s and volunteer groups were only able to complete small areas, resulting in much of 

the work never being completed (USDA 1995). 

Although Alternative 3 would result in lower conifer densities compared to Alternative 1, it would 

help increase conifer forest connectivity across a greater area than Alternatives 2 and 4. Alternative 3 

would ensure that shade-intolerant species such as ponderosa pine, Jeffrey pine and sugar pine make 

up a larger proportion of tree composition. Planting would increase the likelihood of suitable 

microsites across the project area being occupied by conifers rather than by indefinitely persisting 

shrubs and hardwoods. Establishing conifers, especially pine species, across a wider area, would 

increase the likelihood of more forest patches escaping future stand-replacing events, such as wildfire. 

As a result, conifers would be positioned to move and adapt to future changing climate conditions and 

disturbances as discussed under Alternative 1. 

Effects of prescribed burning in young plantations would be the same as Alternative 1. 

Existing Plantations

Same as Alternative 1.

Stand Density Index

Reforestation

Variable density planting is proposed on all mid-slopes and drainages outside SFMAs. Initial 

densities of variable density planting are higher than within SFMAs and features. Additionally, areas 

that are deep tilled are expected to have higher initial seedling survival. Although Alternative 3 would 

plant higher tree densities initially than Alternative 1, initial seedling mortality is expected to be much 

higher without the use of herbicides; therefore, tree densities on average would be lower than 

Alternative 1 and take longer to reach SDI levels of 230 and greater. Areas of higher planting 

densities and survival would require less time until the onset of inter-tree competition. These areas 

include drainages and mid-slopes that are deep tilled; however, no plantations would reach or exceed 

a SDI of 230 until sometime between years 50 and 60. After 60 years, 8,159 acres would exceed a 

SDI 230. The highest SDI at year 60 would be 272. Although the majority of the project area would 

not exceed a SDI of 230 within the next 40 to 50 years, low SDI levels suggest lower tree canopy 

cover and increased shrub cover. As temperatures and summer water deficits increase with changing 

climate, risk of insect-, competition-, and drought-related mortality would be slightly lower than 

Alternative 1 overall. Having lower SDI levels would improve tree resilience during periods of 

extended drought; however, increased shrub cover would increase the risk of high-severity fire during 

extreme drought (Harris and Taylor 2015; Lydersen et al. 2014). 

Existing Plantations

Same as Alternative 1.

Future Management Feasibility

Reforestation

Low initial survival and initial planting densities would require longer periods of time for plantations 

to reach and exceed a SDI of 260. With lower tree densities, Alternative 3 would require larger trees 

to satisfy thinning criteria for SDI. While manual release treatments would improve tree growth 

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compared to Alternative 2, they are not as effective as the herbicide release treatments used in 

Alternative 1. Therefore, slower initial tree growth would further prolong the development of larger 

trees. Unlike the other alternatives, no plantations would satisfy the thinning criteria within the next 

50 years. By year 60, a total of 8,136 acres would satisfy the thinning criteria. Thinning could remove 

5,937 board feet per acre, which is more than could be removed under Alternative 2 and less than 

Alternative 1 in year 60. Residual tree densities in these areas would range from 115 to 123 trees per 

acre. Like Alternative 1, areas that satisfy the thinning criteria are those that initially have higher tree 

densities. These areas are the drainages and mid-slopes that are deep tilled during site preparation. 

The fuelbreaks, primary ridges, emergency travel routes and all areas that are not site prepped with 

deep tilling never satisfy the thinning criteria within the next 60 years because tree densities are too 

low. Alternative 3 would result in 17,873 acres of forest land that would not provide any cost offsets 

for future management.

Existing Plantations

Same as Alternative 1.

Change in Forest Structure

Reforestation

Alternative 3 would reforest the same number of acres as Alternative 1; however, the development of 

different forest structures would be different because of the different planting patterns, lower initial 

seedling survival and slower tree growth. Over the course of the next 30 years, not all plantations 

would progress from early seral successional classes into mid seral successional classes. About 58% 

would qualify as mid seral open canopy, while 42% would remain in an early seral structure. By year 

40, fuelbreaks and primary ridges (1,146 acres total) would remain in an early seral condition with 

average tree sizes of 1-6 inches dbh and low tree densities. The other plantations would have reached 

a mid-seral condition with 10 to 39% canopy cover. After 50 years all of the plantations would reach 

a mid-seral condition. About one third would develop closed canopies and the other two thirds would 

have open canopy conditions (less than 40% canopy cover). Between years 50 and 60 additional 

plantations would develop closed canopy conditions, but a small portion (2,702 acres) would retain 

open conditions with less than 40% canopy cover. Compared to Alternative 1, a greater proportion of 

the project area would maintain in an open canopy condition throughout the next 60 years and have 

smaller tree sizes on average. As described under Alternative 1, future management and disturbances 

would transition plantations into various successional classes.

Existing Plantations

Same as Alternative 1.

CUMULATIVE EFFECTS

The cumulative effects to vegetation under Alternative 3 are the same as Alternative 1, with the 

following differences: 

 Manual release treatments are proposed instead of herbicide applications and more acres of deep 

tilling with forest cultivation are proposed. These differences would not contribute to a 

cumulative effect to vegetation outside of the project area. Present activities occurring within the 

project area that do contribute to cumulative effects include the Rim Fire Recovery and Rim 

Hazard Tree projects. These projects include various types of mechanical operations that would 

reduce natural conifer regeneration and understory vegetation. These effects have already been 

accounted for in the description of the affected environment and discussion of direct and indirect 

effects under Alternative 3. 

 Differences in planting density and conifer growth would result in slower development of midseral structures as well as closed canopy structures; however, proportional changes in early-seral 

and complex early seral structures would be the same as discussed in Alternative 1.

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Draft Environmental Impact Statement and Environmental Consequences

Alternative 4

DIRECT AND INDIRECT EFFECTS

Tree Size and Species Composition

Reforestation

In addition to the estimated 9,825 acres that are expected to naturally regenerate with conifers, 

Alternative 4 would reforest 2,954 acres using a founder stand planting design. Planting founder 

stands would allow control of competing vegetation and species composition. Trees planted in 

founder stands would grow faster than naturally regenerating conifers and increase the proportion of 

pine across the project area to 24%, 27% and 30% over the next 10, 20 and 60 years, respectively. 

Outside of areas proposed for planting founder stands, effects to tree size and species composition 

would be similar to those described under Alternative 2. Founder stands would occur only on midslopes and consist of 2 to 10 acre patches of planted conifers. Planting would not affect oak and 

hardwoods because founder stands would only be planted in areas with no hardwoods. Similarly, 

planting would not occur if natural conifer regeneration is present. Table 3.13-12 summarizes tree 

characteristics and densities at years 10, 20 and 60. The use of herbicides would reduce competition 

in founder stands and result in similar average conifer dbh and heights as expected under Alternative 

1. Outside of founder stands, however, competing vegetation would slow tree growth. When averaged 

together, the overall average tree size of Alternative 4 would be considerably smaller than Alternative 

1. 

Table 3.13-12 Alternative 4 Tree Density and Characteristics at Years 10, 20 and 60

Species Year PCR1

Mean

CBH1

Mean

DBH1

Mean

DBH 

Minimum

DBH 

Maximum

Height

Mean

Height

Minimum

Height

Maximum

TPA1

Mean

TPA 

Minimum

TPA 

Maximum

Conifers 10 88.2 0.5 0.2 0.0 1.1 3.8 1.4 9.1 469 131 6,506

Conifers 20 61.8 5.0 1.9 0.0 7.0 13.1 3.4 32.6 401 131 2,373

Conifers 60 49.3 29.6 9.6 3.3 25.5 58.5 17.6 110.4 293 122 814

Hardwoods 10 83.3 2.0 1.8 0.5 3.7 12.1 6.9 23.7 53 38 104

Hardwoods 20 58.6 10.5 4.2 2.1 6.0 25.5 17.7 32.0 20 14 37

Hardwoods 60 39.7 26.0 6.8 3.5 11.4 43.2 27.3 53.6 15 5 24

1 Trees per acre is based acres with natural conifer regeneration and founder stands, and does not include acres without conifer 

regeneration. PCR=percent crown ratio; CBH=canopy base height in feet; DBH=diameter at breast height in inches; TPA=trees per acre.

Prescribed fire is proposed on a large scale under Alternative 4, within and outside of founder stands. 

At the earliest, prescribed fire would occur about 5 to 7 years after the Rim Fire. Although prescribed 

fire would reduce shrub cover, tree growth during these early years would have already been 

negatively impacted by competing vegetation. It has been well substantiated that suppressing 

competing vegetation during the first few years of tree development has the greatest impact on the 

survival and growth of conifer seedlings (Balandier et al. 2006; McDonald and Fiddler 2010). Growth 

lost during the first few years of seedling development will likely never be made up because seedlings 

do not respond as vigorously to delayed release treatments (McDonald and Fiddler 2001). Large-scale 

prescribed fire would, however, reduce surface fuels and tree densities where conifers are 

regenerating. Lower fuel loads and tree densities would help prolong the probability of another highintensity fire, providing a longer window of opportunity for conifers to develop fire resilient 

characteristics such as thick bark and high canopy base heights. Trees growing in founder stands 

would develop these characteristics faster than trees outside founder stands. The early slow growth of 

trees outside founder stands would result in substantially smaller trees after 20 years than in founder 

stands. However, the area planted as founder stands is considerably smaller than the area naturally 

regenerating. Therefore, the overall averages for tree size and other characteristics increase very little 

compared to Alternative 2. As a result, the overall average canopy base height under Alternative 4 is 

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still about 2 feet less than Alternative 1. The overall averages for dbh and height under Alternative 4 

are also significantly less than Alternative 1.

Creation of founder stands throughout the project area would eventually lead to broader expansion of 

conifer forest throughout large severely burned areas. Based on tree age and growth model 

projections, white fir would likely reach necessary tree sizes for dependable seed production before 

ponderosa pine. Within about 40 to 60 years, founder stands would likely have trees that are 

producing large, dependable cone crops that could then result in accelerated seed dispersal into 

adjacent areas. Although founder stands would have higher proportions of pine compared to naturally 

regenerating areas, white fir would still start producing more viable seed before any pine species; and 

therefore, would likely maintain dominance beyond the next 60 years. 

Within founder stands, the effect of planting pattern on the development of fine-scale heterogeneity is 

similar to Alternative 1. Planting patterns would create open stand structures with small clumps of 

seedlings and saplings in the short-term; however, variation in tree sizes, ages and spatial distribution 

would require several decades at minimum to develop. A key difference, however, is the small size of 

founder stands. The concept of a founder stands is to provide a seed source from which conifer forest 

can grow and expand from. Founder stands are expected to require at least 40-60 years before 

substantial seed production begins and forest expansion is possible; therefore, Alternative 4 would 

likely require a longer period of time to establish conifer vegetation-disturbance dynamics, such as 

the ICO structures maintained by frequent fire, on a scale greater than 2 to 10 acres (i.e., the size of a 

founder stand). 

Like Alternatives 1 and 3, the distribution of founder stands across the landscape would provide for a 

small level of ecological buffering that increases the probability of all conifer stands in the project 

area being lost to future disturbance (Millar et al. 2007). Planting small stands with ponderosa pine 

and sugar pine will provide a small level of planting redundancy that will disperse these species 

across a wider area than Alternative 2, and provide future seed sources. The founder stands would 

provide opportunities for these species to move and adapt to future changing climate conditions and 

disturbances, but to a lesser extent than Alternatives 1 and 3. The founder stands only increase the 

forested area by 2,954 acres compared to Alternative 2. Therefore, the founder stands would be 

dispersed throughout 13,230 acres of predominantly shrub and hardwood vegetation. Shrub cover is a 

good predictor of fire behavior (Lydersen and North 2012; van Wagtendonk et al. 2012). Under low 

live fuel moisture conditions, shrub patches can burn at higher intensity than fuels in surrounding 

forest vegetation (Knapp et al. 2012; Skinner and Taylor 2006). Today, prescribed burning and 

managed wildfire are faced with numerous operational and social constraints that limit their use in 

effectively reducing hazardous fuels and maintaining natural processes (Quinn-Davidson and Vaner 

2012). If prescribed fire is not repeatedly used across the landscape to maintain low shrub levels, then 

the risk of high-severity fire killing founder stands would increase over time and limit their ability to 

function as sources for conifer dispersal in the long-term.

Existing Plantations

Same as Alternative 1.

Stand Density Index

Reforestation

Outside of founder stands, the direct and indirect effects related to SDI are the same as described for 

Alternative 2. Founder stands would only account for 2,954 acres of small plantations distributed 

across the project area. Planting density within founder stands would range between 100 and 200 

trees per acre. At tree densities this low it would require almost 60 years to exceed a SDI of 230. As 

temperatures and summer water deficits increase with changing climate, risk of insect-, competition-, 

and drought-related mortality would be low within founder stands during the first 50 years. Having 

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lower SDI levels would improve tree resilience during periods of extended drought; however, lower 

tree densities would increase the abundance of shrub cover within founder stands. Given the small 

size of founder stands, they would likely be adjacent to shrub dominated patches that have not been 

reforested. In the absence of frequent prescribed fire, shrubs would likely reach decadent structures 

after 10 to 20 years (Shatford et al. 2007). Saspis and Brandow (1997) concluded that one of the 

factors contributing to high-severity fire risk in Granite plantations was the juxtaposition of different 

fuel types and ladder fuels. Therefore, increased shrub cover would increase the risk losing founder 

stands to high-severity fire during extreme drought (Harris and Taylor 2015; Lydersen et al. 2014). 

Existing Plantations

Same as Alternative 1.

Future Management Feasibility

Reforestation

The effects of Alternative 4 are the same as Alternative 2. Although founder stands would increase 

the acres of reforested land by 2,954 acres, SDI levels would not reach a SDI of 260 within the next 

60 years; therefore, no additional acres would satisfy the thinning criteria and no additional cost 

offsets would be realized for future management.

Existing Plantations

Same as Alternative 1.

Change in Forest Structure

Reforestation

With the exception of prescribed fire and creating founder stands, Alternative 4 would have similar 

effects on landscape forest structure as Alternative 2. Widespread use of prescribed fire could 

promote establishment of conifer regeneration in large areas that would otherwise remain dominated 

by shrubs and hardwoods. Prescribed fire would create openings in the shrub canopy where conifer 

seedlings could establish; however, reinvasion of conifers would still rely on complex interactions 

between seed supply, suitable medium for seed germination, and favorable climatic conditions 

(Bonnet et al. 2005; Kozlowski 2002). A high abundance of white fir and Douglas-fir regeneration 

after the Rim Fire suggests that these species would have the highest probability of establishing after 

prescribe fires, so a desirable species composition would likely not be achieved within the next 60 

years. Furthermore, high shade provided by residual mature conifers in a low- to moderate-severity 

fire system reduces shrub cover, limiting competition with conifer seedlings (Crotteau et al. 2013). 

While prescribed fire in large severely burned areas would create openings in shrub cover, most of 

these areas would have no conifer canopy to slow the response of shrub growth following prescribed 

fire. Consequently, shrub cover would quickly recover and suppress any newly established conifers; 

thus, prolonging succession from shrub to conifer cover (Crotteau et al. 2013; Nagel and Taylor 2005; 

Shatford et al. 2007). While succession from early seral to mid-seral conditions would still likely 

occur on the order of multiple decades, frequent prescribed fire could accelerate transition from shrub 

cover to conifer cover quicker than Alternative 2, but the difference is difficult to quantify. 

Founder stands would not affect the 3,325 acres of complex early seral forest within the project area. 

Herbicide use in founder stands would reduce competition with understory vegetation and promote 

faster conifer growth. Founder stands would reach a mid-seral open canopy condition by year 30, 

which would likely be the only mid seral conditions within the project area (2,954 acres). After 40 

years an additional 7,087 acres that naturally regenerated would reach mid seral tree sizes. Given the 

low initial tree densities in founder stands, they would require about 50 years before trees reach a size 

that created a closed canopy (greater than 40% canopy cover). By year 60 all founder stands and all 

patches of white fir and Douglas-fir dominated natural regeneration would reach a mid-seral closed 

canopy condition. In total, 54% of the 23,492 acres (26,009 acres minus 2,517 acres of non-conifer 

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cover types) proposed for reforestation under the other action alternatives would remain primarily 

dominated by shrubs and hardwoods after 60 years. This is more than twice the proportion of the 

project area that would have historically occurred in an early seral structure (Safford 2013).

Existing Plantations

Same as Alternative 1.

CUMULATIVE EFFECTS

The cumulative effects to vegetation caused by thinning existing plantations are the same as described 

under Alternative 1.The cumulative effects to vegetation caused by reforestation activities are the 

same as Alternative 2, with the following difference:

 Creating founder stands would increase the proportion of early seral forest that is transitioned to a 

mid-seral structure within the 60-year analysis time frame. In total, Alternative 4 would 

contribute to a cumulative reduction of early seral forest from 71,552 to 43,294 acres. This 

includes 15,479 acres of reforestation on private lands, 9,825 acres of natural conifer 

regeneration, and 2,954 acres of founder stands. The remaining early seral forest makes up about 

24% of the Rim Fire landscape, which is greater than the 15 to 20% historic range for early seral 

structure (Safford 2013).

 Once founder stands develop into a mid-seral size, they would remain in an open canopy structure 

until year 50. Until that time, they would increase the proportion of open canopy structure across 

the Rim Fire landscape by 1.6% 

Alternative 5

DIRECT AND INDIRECT EFFECTS

Tree Size and Species Composition

Reforestation

Alternative 5 would have similar tree sizes and species composition as Alternative 1 as shown in 

Table 3.13-13 and Table 3.13-9. Oliver (1979) found that seedlings spaced greater than 6 feet apart 

did not experience slowed growth during the first 12 years after planting. Although Alternative 5 has 

a higher initial planting density than Alternative 1, hand thinning would occur by year 7, reducing 

tree densities to about 220 to 240 trees per acre (about 14-foot spacing). Planting higher densities 

would initially ensure greater tree cover, which would increase the likelihood of trees being planted in 

favorable microsites (e.g., pockets of deep soil and high moisture availability), that might otherwise 

be passed over when planting seedlings farther apart. 

Table 3.13-13 Alternative 5 Tree Density and Characteristics at Years 10, 20 and 60

Species Year PCR1

Mean

CBH1

Mean

DBH1

Mean

DBH 

Minimum

DBH 

Maximum

Height

Mean

Height

Minimum

Height

Maximum

TPA1

Mean

TPA 

Minimum

TPA 

Maximum

Conifers 10 94.4 0.4 0.7 0.0 1.4 7.4 2.9 10.7 231 211 236

Conifers 20 70.5 7.0 4.3 0.1 7.2 23.6 5.1 38.1 232 211 236

Conifers 60 58.8 31.0 13.5 4.2 24.6 75.2 24.0 121.3 192 179 201

Hardwoods 10 79.8 2.1 1.2 0.1 2.5 10.2 5.5 20.3 50 38 63

Hardwoods 20 44.2 13.0 3.9 2.0 6.2 23.3 14.1 35.8 20 15 25

Hardwoods 60 29.3 26.9 6.0 3.4 10.2 38.1 20.9 53.8 12 10 18

1 PCR=percent crown ratio; CBH=canopy base height in feet; DBH=diameter at breast height in inches; TPA=trees per acre.

Within the first several years, trees growing in more favorable conditions would have larger diameters 

and be taller. Thinning would favor the most vigorous trees, removing trees growing in less 

productive pockets. Thinning the slower growing trees would avoid a systematic thinning and begin 

moving the plantations toward a more random spatial distribution that is expressed through microsite 

productivity. Like all the other action alternatives, young plantations would still have a homogeneous 

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Draft Environmental Impact Statement and Environmental Consequences

vertical structure. Vertical structure would not begin to express itself until trees reach an age or size 

when natural regeneration begins and new cohorts are established. This would be the case for all 

alternatives, whether vegetation is dominated by shrubs or conifers. Alternative 5 would also have 

relatively the same effects as Alternative 1 in terms of future ecological resiliency, adaptation and 

diversity. Effects of herbicide applications for conifer release and noxious weed treatments would be 

the same as Alternative 1.

Existing Plantations

Same as Alternative 1.

Stand Density Index

Reforestation

Only one planting pattern is proposed under Alternative 5, but thinning, occurring at about age 7, 

would begin introducing horizontal complexity. After accounting for initial mortality, oak buffers and 

thinning, tree densities would average about 230 trees per acre. This is somewhat higher compared to 

Alternative 1, so SDI levels would increase faster. By year 40, the majority of the project area would 

near a SDI of 230, but not exceed it. By year 50, however, all plantations would exceed a SDI of 230. 

At this point, plantations would show an increase in insect-, competition- and drought-related 

mortality. Assuming no thinning or other disturbances occur, all plantations would exceed a SDI of 

300 by year 60, but not 365. The highest SDI achieved by year 60 would be 337 (about 64% of 

maximum SDI). Because all of the plantations would exceed a SDI of 230 by year 50, a greater 

number of acres would experience increased stress during periods of extreme drought compared to 

the other alternatives. As plantations approach and exceed SDI levels of 300, self-thinning would 

occur and SDI would decrease; however, higher tree densities would shade the forest floor and 

decrease shrub cover continuity. Lower shrub abundance would potentially result in more patches of 

conifers escaping high-severity fire, especially in cool and moist areas (Harris and Taylor 2015; 

Lydersen et al. 2014). 

Existing Plantations

Same as Alternative 1.

Future Management Feasibility

Reforestation

Higher tree densities under Alternative 5 would result in all plantations meeting thinning criteria by 

year 50. Although tree densities are slightly higher than Alternative 1, both alternatives have about 

the same average tree sizes throughout the 60-year analysis time frame. Therefore, Alternative 5 

would have more merchantable sized trees in year 50 and remove more board feet per acre sooner 

than all the alternatives. Residual tree densities would still be somewhat higher than Alternative 1, 

ranging from 136 to 164 trees per acre. A larger per acre volume is removed under Alternative 1 in 

year 60. This is partially a result of the 10-year cycles that FVS is based on. A large portion of the 

acres thinned under Alternative 1 in year 60 are close to a SDI of 260 in year 50 and would likely 

exceed this threshold well before 60 years. Because FVS works on 10-year cycles, these acres would 

continue to grow and accumulate volume over the course of several years despite exceeding a SDI of 

260; therefore, more volume would be removed per acre in year 60. Similarly, waiting to thin until 

year 60 under Alternative 5 would result in larger per acre volume removed than Alternative 1, just as 

it did at year 50. Waiting until year 60 would also result in lower residual tree densities as it did with 

Alternative 1. While greater risk would be taken on if thinning were postponed 10 more years, SDI 

levels would still be well below the bark beetle induced maximum of 365 (Oliver 1995; Oliver and 

Uzoh 1997). As a result, Alternative 5 provides future generations more management options earlier 

across more acres.

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Existing Plantations

Same as Alternative 1.

Change in Forest Structure

Reforestation

Alternative 5 would have similar effects as Alternative 1 on forest landscape structure over the next 

60 years. Key differences would include less variation in canopy cover compared to Alternative 1. All 

plantations under both alternatives would reach mid seral structures within the next 30 years. Unlike 

Alternative 1, however, canopy cover would only vary between 40% and 59% as opposed to 20% to 

59%. By year 50, canopy cover would increase in all plantations to greater than 60%. Under 

Alternative 1, the first, but not all, plantations would reach a canopy cover of greater than 60% by 

year 60. Canopy closure is accelerated under Alternative 5 because of higher initial planting densities. 

As described under Alternative 1, future management and disturbances would transition plantations 

into various successional classes.

Existing Plantations

Same as Alternative 1.

CUMULATIVE EFFECTS

The cumulative effects to vegetation caused by Alternative 5 are the same as Alternative 1, with the 

following difference: 

 Differences in planting density would result faster development of closed canopy structures in 

some areas; however, proportional changes in early seral and complex early seral structures 

would be the same as discussed in Alternative 1.

Summary of Effects Analysis across All Alternatives

Tree Size and Species Composition

Alternatives 1 and 5 would have higher conifer survival and faster growth because herbicide

applications would more effectively control competing vegetation compared to other alternatives. As 

a result, they would have the largest average conifer dbh after 20 years as well as throughout the next 

60 years. Herbicides are proposed under Alternative 4 for use in founder stands, which would 

experience similar dbh and height growth as plantations in Alternatives 1 and 5; however, when 

averaged with tree growth outside founder stands, average growth is less. Manual release treatments 

in Alternative 3 would not control competing vegetation as effectively as herbicides; therefore, 

Alternative 3 would experience higher initial mortality rates and slower conifer growth compared to 

Alternatives 1 and 5. Alternative 2 would not control competing vegetation and would experience the 

slowest conifer growth. 

Alternatives 1, 3 and 5 would have more control over tree species composition. As Table 3.13-14 and 

Table 3.13-15 show, these alternatives would promote a higher proportion of ponderosa pine, sugar 

pine and Jeffrey pine across the landscape. Alterative 2 would rely on natural regeneration; and 

therefore, white fir and Douglas-fir would comprise the largest proportion of future stands in the 

project area. Founder stands in Alternative 4 would increase the proportion of pine species across the 

project area, but the increase would be marginal given the small number of acres planted and the 

abundance of white fir and Douglas-fir outside founder stands. 

Herbicide and manual release treatments would decrease the abundance of shrub cover throughout the 

project area. Reductions in shrub cover are expected to last for about 5 years at which time they 

would begin to recover and increase in abundance over the next 15 to 20 years until conifer canopies 

begin to close and shade the forest floor. 

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Thinning existing plantations would decrease tree density and increase health and vigor of residual 

trees. By year 60, thinned plantations would increase the number of large trees (trees greater than 24 

inches dbh) by about 15%. Over the next 60 years, tree diameter would increase across all thinned 

plantations, with averages ranging from about 18 to almost 31 inches dbh in the youngest and oldest 

plantations. Average tree heights would range from about 60 to 105 feet. Alternative 2 would not thin 

existing plantations; therefore, higher tree densities would slow tree growth. After 60 years, average 

tree diameter would increase by about 50% less than if thinned. Average tree height heights would 

also increase by 30 to 50% less than if thinned. 

Stand Density Index

Areas that initially have the highest tree densities would develop higher levels of SDI sooner than 

areas with lower initial tree densities. Although Alternatives 2 and 4 would have fewer acres of 

conifer forest, patches of unmanaged natural conifer regeneration would exceed SDI levels of 230 and 

365 much faster than would occur under the other alternatives. About 30% of conifer forest under 

Alternatives 2 and 4 would exceed a SDI of 230 by year 40 and about 6 to 8% would exceed a SDI of 

365 by year 40. No plantations under the other alternatives would exceed a SDI of 230 within 40 

years. Therefore, conifer forest under Alternatives 2 and 4 would likely begin experiencing effects of 

insects, competition and drought before plantations in the other alternatives. Prescribed fire in 

Alternative 4 could slow the increase of SDI, but it is difficult to quantify the effect of fire given the 

high shrub cover expected under this alternative. Founder stands in Alternative 4 and plantations in 

Alternatives 1, 3 and 5 never reach a SDI of 365 or more. As Table 3.13-14 and Table 3.13-15 show, 

by year 60, most of the plantations in Alternative 1 and all of the plantations in Alternative 5 exceed a 

SDI of 230. Low initial survival and tree densities in Alternative 3 reduce the number of acres that 

reach a SDI of 230. By year 60 only 31% of Alternative 3 plantations exceed a SDI of 230. 

Thinning existing plantations would reduce SDI levels and increase resiliency to insect-, drought-, 

and competition -related mortality. The plantations would benefit from reduced competition for a 

period of 20 to 40 years. During this time, residual trees would increase in size and SDI would slowly 

increase again. No thinning would occur under Alternative 2 and the existing plantations would 

experience higher levels of insect-, drought-, and competition-related mortality sooner.

Future Management Feasibility

Alternatives 1 and 5 would provide the most potential for offsetting future management costs by 

harvesting intermediate sized trees. As Table 3.13-14 shows, reforestation activities under 

Alternatives 1 and 5 result in the most merchantable sized trees within the next 50 years, without first 

exceeding SDI levels that would result in wide spread insect-, drought-, and competition-related 

mortality. 

Slightly higher tree densities in Alternative 5 results in all plantations reaching a SDI that requires 

thinning by year 50, while some plantations in Alternative 1 would not reach as high of SDI levels in 

this time frame. Therefore, all plantations could be commercially thinned by year 50 under 

Alternative 5. Sometime between years 50 and 60, the remaining plantations in Alternative 1 would 

need to be thinned. Allowing the trees to accumulate volume for an additional 10 years would result 

in more volume being removed per acre. Low initial seedling survival and low planting densities in 

some areas would result in far fewer acres requiring thinning within the next 50 to 60 years; therefore, 

while trees would grow to a merchantable size, too few would exist to warrant harvesting and less 

cost offsets for future management. Very high tree densities in Alternative 2 would result in slow tree 

growth over the next 60 years. Some areas would eventually have trees that are of merchantable size; 

however, many trees would be too small to be commercially harvested even 60 years from now. 

Although founder stands in Alternative 4 would grow to commercial size, tree densities would be too 

low to commercially harvest and provide no cost offset for future fuels reduction and wildlife habitat 

management.

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Table 3.13-14 Comparison of Alternatives: Summary of Effects for Reforestation

Indicator Alternative 1

(Proposed Action)

Alternative 2

(No Action)

Alternative 

3

Alternative 

4

Alternative 

5

Average conifer dbh at year 20 (inches) 4.3 1.7 2.8 1.9 4.3

Average conifer height at year 20 (feet) 23.2 12.4 16.3 13.1 23.6

Percent conifer in pine 70 23 70 27 75

Percent conifer forest exceeding stand density 

index of 230 at year 60

90 100 31 100 100

Percent conifer forest exceeding stand density 

index of 365 at year 60

0 38 0 29 0

Future potential timber yield (million board feet) 163 42 48 42 160

Acres reforested 26,009 9,825 26,009 12,779 26,009

Acres not reforested 0 16,184 0 13,230 0

As Table 3.13-15 shows, thinning existing plantations would result in larger trees over the next 60 

years compared to not thinning. Therefore, more merchantable intermediate-sized trees would exist in 

the future that could be harvested to offset future management costs. 

Table 3.13-15 Comparison of Alternatives: Summary of Effects for Existing Plantations

Indicator Alternative 1 (Proposed Action) Alternative 2 (No Action) Alternative 

3

Alternative 

4

Alternative 

5

Average conifer 

dbh at year 20

18-31 inches with 15% more large 

trees (greater than 24) than 

Alternative 2

9-17 inches with 15% fewer 

large trees (greater than 24) 

than Alternative 1

Same as 1 Same as 1 Same as 1

Average conifer 

height at year 20

60-105 feet 33-75 feet Same as 1 Same as 1 Same as 1

Tree species 

composition

Increase in sugar pine, white fir, 

Douglas-fir and incense cedar

Unchanged Same as 1 Same as 1 Same as 1

Stand density 

index

Majority of acres reduced well below 

230 for 20 to 40 years

Majority of acres maintained 

high levels well over 230

Same as 1 Same as 1 Same as 1

Forest structure Heterogeneous open canopy Homogeneous closed 

canopy

Same as 1 Same as 1 Same as 1

Change in Forest Structure

Alternatives 1, 3 and 5 would reforest 23,492 acres (26,009 acres minus 2,517 acres on non-conifer 

cover types). While not every acre or even 100% of each acre would be reforested (e.g., oak patches, 

rock outcrops, sensitive areas), these alternatives would provide a relatively broad distribution of tree 

regeneration across more acres than Alternatives 2 and 4. In the long-term, it would promote greater 

species diversity in large areas that currently have little or no natural conifer regeneration. Large 

patches of shrubs and hardwood vegetation slow establishment of conifers and can require decades to 

centuries to convert from shrub-dominance to conifer forest (Collins and Roller 2013; Conard and 

Radosevich 1982a; Nagel and Taylor 2005; Wilken 1967). Planting conifers in areas that lack natural 

conifer regeneration would accelerate the development of conifer canopy and promote structural 

diversity in areas that would otherwise remain dominated by shrubs or hardwoods in the long-term.

While Alternative 4 would provide opportunities for planting desirable conifer species, the total acres 

planted are far less than under Alternatives 1, 3 and 5. Currently there is an excess of early seral 

structure across the Rim Fire landscape. Alternatives 1, 3 and 5 would accelerate the establishment of 

conifer forest on more acres, which would move more of the Rim Fire landscape toward mid and late 

seral forest structures that are currently lacking.

Thinning existing plantations would increase the acres of mid seral open canopy forest within the Rim 

Fire landscape. Thinning will also promote fine-scale heterogeneity by creating a range of canopy 

openings, tree clumps and individual trees. Not thinning the existing plantations would maintain 

closed canopy conditions, which are currently in excess across the landscape. Alternative 2 would 

also maintain homogeneous structures. 

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3.14 VISUAL RESOURCES

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction

FSM 2380 includes direction on application of the principles of landscape aesthetics, scenery 

management and environmental design in project-level planning. The Scenery Management System 

(SMS); Landscape Aesthetics, A Handbook for Scenery Management, Agriculture Handbook 701 

(USDA 1995a) provides guidance on the scenery management system. The USDA Forest Service 

Landscape Management Series Volume 2, Chapter 1, The Visual Management System (VMS) 

provides guidance for development and application of Visual Quality Objectives (VQOs). 

The Forest Plan goal for Visual Resources includes: Meet adopted VQOs on all projects. Maintain 

high visual quality in areas of concentrated public use and in areas seen from major travel routes. 

Allow management activities in certain areas to dominate the surrounding characteristic landscape, 

but they should borrow from natural forms and appear as natural occurrences when viewed from 

background distances. Consider private land concerns during the evaluation of proposed management 

activities adjacent to privately developed subdivisions and recreation areas. Particular attention will 

be given to visual quality in the foreground view areas of these private developments as well as any 

other values relating to their attendant use and enjoyment of the National Forest. (USDA 2010a, p. 7)

The Forest Plan Compliance (project record) document identifies the Forest Plan Standards and 

Guidelines that specifically apply to this project and related information about compliance with the 

Forest Plan.

Effects Analysis Methodology

Assumptions Specific to Visual Resources

 Forest lands within the project area met the VQOs prior to the Rim Fire, but burned areas may not 

currently meet the VQOs.

 Reforestation will improve the landscape aesthetics in the long-term, moving conditions towards 

meeting VQOs. This is compatible with the Forest Plan objective for Visual Resource

Improvement (USDA 2010a, p. 63), commonly referred to as the Rehabilitation VQO. 

 The terms visual/scenery resources and landscape characteristics all refer to visual resources.

Data Sources

 Forest Plan VQO maps

 GIS layers for Management Areas and VQOs) 

Visual Resources Indicators

 VQOs Achieved

 Degree of Natural Appearance 

Visual Resources Methodology by Action

Although the Forest Plan direction for visual resources was developed using the VMS, the current 

direction is to apply the SMS. Therefore this analysis combines concepts from both systems. During 

field observations, a variety of photos were taken from various viewpoints. The photos of the existing 

condition were used in conjunction with descriptions of proposed activities to determine the extent 

and duration of potential impacts to scenic/visual resources.

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This is a qualitative analysis that does not include acres of proposed activity by VQO. Proposed 

activities were analyzed based on their potential impacts to visual resources including the duration of 

impact, and the degree of natural appearance.

DIRECT AND INDIRECT EFFECTS

 The analysis area is the Rim Fire perimeter.

 Duration of short-term effects is 20 years; duration of long-term effects is 40 years.

CUMULATIVE EFFECTS

 The cumulative effects analysis area is the entire Rim Fire area including NFS lands and those 

under other ownership.

 The timeframe for the cumulative effects analysis is 40 years.

Affected Environment

Existing Conditions

The 2013 Rim Fire, the dominant visual impact within the project area, burned extremely hot, killing 

thousands of acres of conifer forest and leaving large expanses with little to no live vegetation. Resprouting and natural seeding is occurring, but the primary species returning to the landscape are 

sprouting shrubs such as bear clover, manzanita and ceanothus as well as oaks and other sprouting 

hardwoods. Historically, the Rim Fire landscape was railroad logged from the 1920s to 1940s and the 

forest was primarily composed of second growth pine and mixed conifer forest. Other past 

management activities within this landscape include timber harvesting/vegetation management, 

mining, grazing, transportation system construction, fire suppression, prescribed burning and fuels 

reduction. In addition, insect and disease occurrences along with drought related mortality occurred. 

These actions and events created a mosaic of forested areas interspersed with meadows and some 

pockets of hardwoods and conifers providing contrast and diversity to the dominant burned 

landscape.

The Forest has the highest recreation visitation rate of National Forests on the Sierra Nevada western 

slope (3.08 Recreation). Viewing natural features, and driving for pleasure were listed among the top 

five recreation activities visitors participated in on the Forest based on results of the 2012 National 

Visitor use Monitoring (NVUM) survey. Forest visitors typically are interested in or concerned about 

how the forest looks when viewed from developed recreation sites. Many popular developed 

recreation sites are located along the Evergreen Road where scenery is viewed from by visitors 

driving for pleasure and recreating. Forest Service developed day use sites include Carlon, Merals 

Pool, Middle Fork, Rim of the World and Rainbow Pool. Developed Campgrounds include Carlon, 

Cherry Valley, Dimond O, Lost Claim, Lumsden, Lumsden Bridge, Middle Fork, South Fork and 

Sweetwater. The Peach Growers Recreation Residence Tract, City of Berkeley Tuolumne Camp and 

San Jose Camp, operated under Special Use Permit (SUP), are also within the Rim Fire where users 

view the Forest. Evergreen Lodge and Camp Mather are private land recreation developed sites. 

Dispersed recreation users on non-motorized or motorized system trails also view the landscapes 

within the Rim Fire.

The Rim Fire resulted in a mosaic or patchwork of burned trees and shrubs with islands of green 

surviving trees and shrubs. Figure 3.14-1 shows the vast amount of burned landscape viewed 

immediately after the Rim Fire from the Rim of the World Vista looking north across the Tuolumne 

River canyon to Jawbone Ridge. In contrast, Figure 3.14-2 shows the majority of vegetation north of 

Rainbow Pool Day Use Area remained intact, but scattered dead trees are visible.

Regeneration of shrubs occurred quickly in most of the project area. Figure 3.14-3 displays the 

returning vegetation 2 growing seasons after the Rim Fire. Figure 3.14-4 shows lupine “meadows” 

quickly regenerating after the Rim Fire.

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Figure 3.14-1 View from the Highway 120 Rim of the World Vista (October 2013)

Figure 3.14-2 Lightly Burned Landscape Surrounding Rainbow Pool Day Use Area (May 2015)

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Figure 3.14-3 Shrub Regeneration After Two Growing Seasons (May 2015)

Figure 3.14-4 Lupine in Foreground with burned Oaks and Conifers in the Background (May 2015)

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Environmental Consequences

Proposed activities may take approximately 10 years to implement and another decade for the planted 

trees to dominate the landscape. During implementation the Rehabilitation VQO applies to the project 

area. The proposed activities may be visible in all distance zones from popular developed recreation 

sites or roads and trails in the project area. Proposed activities that occur in the foreground and middle 

ground views would be most noticeable. Some of the proposed activities vary based on the scale or 

scope of the specific management activity; however effects to visual resources would be similar.

Over time as reforestation is accomplished, the modification VQO could be achieved. As the trees 

continue to grow, the VQOs Partial Retention and eventually Retention could be met. 

Alternative 1 (Proposed Action)

DIRECT EFFECTS

Plantations

Short-term direct effects of plantations (the first 5 years) including within deer habitat enhancement 

areas would occur when most trees are less than 10 feet tall and not very apparent in middle ground 

views. In foreground views the individual trees would be noticeable. Individual trees and plantations 

would not be noticeable in the background distance zone in this timeframe. 

As the trees mature and become more obvious in the middle ground the plantations would be more 

apparent and may look unnatural when viewed for a long duration of time. The homogeneous size of 

the trees when the plantations are between 15 to 20 years old and trees are 12 to 30 feet tall would 

look unnatural. Oak buffers, mortality and clumpy and varied planting patterns throughout the units 

would reduce this effect. Areas which could provide long duration views include developed 

recreation sites and trails and roads where visitors move slowly through the landscape. Plantation 

areas would appear natural when viewed from the background distance zone. Plantation patterns 

would be less noticeable the more undulating the topography is in all distance zones and over time. 

Effects to visual resources include enhancing the meadow component of the vegetative mosaic by 

decreasing conifer encroachment in the long-term, retention of small clumps of conifers near the 

meadow and further away from the core of the meadow retaining larger clumps of conifers. This 

special meadow planting design would also add spatial variety into the stands while emphasizing oaks 

and other hardwoods. All VQOs would be met with implementation of this pattern. 

Seedlings in fuelbreaks would be planted to approximately 13 to 17 foot-initial spacing for 150 feet 

on either side of the ridge with a 30 foot “no plant” strip along the ridge top. In middle ground and 

background views primary ridge and fuelbreak treatments would be similar in appearance to a ski 

area run or utility corridor if the 30 foot width is consistent and the edges do not vary. The inclusion 

of the 75 foot clearance for helispots would create diversity regarding the forms and lines of the 

vegetative mosaic. “To meet visual quality objectives successfully, fuelbreak design must subdue 

unnatural contrasts and borrow from natural form, lie, color and texture” (USDA 1985). In the longterm the maximum modification and potentially the modification VQOs would be met. 

Long-term visual effects of plantations, after 20 years, would have diminished in the middle ground 

views and appear natural to forest visitors. Planting patterns would be less noticeable the more 

undulating the topography is in all distance zones and over time. 

Natural regeneration typically occurs in random spacing with a natural diversity of species. This 

would result in naturally appearing forms, colors, textures, and stands free of unnatural linear 

features. All VQOs would be met in the long-term if natural regeneration occurs. Planting conifers 

would accelerate the recovery of these species and ensure their existence in the short and long-term 

which is consistent with the Rehabilitation VQO.

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The proposed management activities to restore the vegetative mosaic within the Rim Fire are 

compatible with the interim Rehabilitation VQO. In the long-term implementation of the activities 

would appear natural eventually meet the forest plan VQOs.

As plantations mature and over time ecological processes including natural regeneration and mortality 

would occur and these areas would appear more natural. Commercial thinning could also create the 

desired ICO structure. Figure 3.14-6 displays a 50 year old plantation thinned from below without an 

ICO design, but different sized trees, species and an abundance of brush are still present in these 

stands.

Figure 3.14-6 Fifty Year Old Pine Plantation (Wrights Creek Fire) Near the Rim Fire (May 2015) 

Deer Habitat Enhancement and Thin Existing Plantations

Direct effects of thinning and removal of conifers near oaks include creating a more open park-like 

vegetative mosaic and enhance species diversity, tree sizes and heterogenity across the landscape. 

These activities are compatible with the Rehabilitation VQO and would aid in the progression of 

restoring the landscape characteristics and enhancing the visual quality. “The amount of visual access, 

or how far one can see into a forest, also has been found to be a significant predictor of landscape 

preference... As the density of smaller trees increases, visibility and scenic beauty decrease.” (Ryan 

2005). Clumping of conifers to increase hiding cover and creating larger openings for deer forage also 

creates additional visual variety in the stands, which would assist in meeting long-term VQOs. 

Thinning densely stocked stands improves and rehabilitates the scenic character of the forest and 

thinning to the ICO structure would create a naturally appearing stand. 

Noxious Weed Eradication

Noxious weed eradication would decrease competition for native vegetation to naturally reclaim the 

landscape. All noxious weed treatments including application of herbicides would assist in the 

rehabilitation of the landscape to eventually meet the forest plan VQOs.

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Reforestation

Site preparation including feller bunchers or other mechanical equipment would create visual 

resource effects including visible evidence of slash on the ground, soil disturbance and other signs of 

disturbance associated with use of machinery. This short-term effect would be visible for one or two 

growing seasons. “Residual woody debris is one of the most significant predictors of negative 

perception of scenic beauty.” (Ryan 2005) Indirect effects forest visitors would experience from 

mechanical equipment include the sights, sounds, and smells of equipment operating in the Forest for 

several years. This work would be dispersed throughout the 25,000 acre area and be limited to 

specific units each season.

Deep tilling and forest cultivating (subsoiling) would be noticeable when viewed from all foreground 

and middle ground distance zones. With the re-growth of shrubs, grasses, wildflowers and other 

herbaceous plants the effects of deep tilling and forest cultivation would last about 2 growing seasons. 

Hand cutting, hand piling and prescribed burning would directly affect visual resources temporarily 

through evidence of slash on the ground and burned ground. The effects of pile burning would be less 

noticeable than broadcast or jackpot burning since piles would produce a more discreet foot print and 

area of smoke dispersion. 

Mastication would remove most of the shrub component in these areas, creating a strong contrast 

between soil colors and herbaceous plants in the landscape immediately after mastication has 

occurred. Within one to two growing seasons, the cut shrubs would re-sprout. The cut sprouting

shrubs would return after 1 to 2 growing seasons to provide diversity and heterogeneity in these 

stands. This site preparation treatment would assist in meeting the long-term VQOs.

Broadcast hand application of herbicides for site preparation and release would kill competing 

vegetation, but would leave it in place and intact on the site. Although this treatment is different than 

mastication the resulting effects to visual resources is essentially the same.

Prescribed Fire

Prescribed fire (broadcast burning and jackpot burning) would have short-term direct effects 

including the presence of black and charred vegetation and sometimes soils. “While prescribed 

burning can mimic natural disturbance, like a wildland fire it can leave a forest blackened and charred 

and is perceived negatively by the public.” (Ryan 2005) This effect is overcome within one year, and 

would only be short-term as seen by the average forest visitor. Multiple prescribed burns may be 

ignited each season, but individual burns would not last more than several days. Long-term direct 

effects from broad scale, low to moderate intensity under burning in thinning units and surrounding 

locations would reduce fuel loading and promote regeneration of trees, shrubs, wildflowers and other 

herbaceous plants. This activity would diversify the vegetative mosaic in regards to vegetative forms, 

natural appearing lines, and additional colors and textures in the forest stands. Short-term indirect 

effects from prescribed burning include views of the fire and smoke, and forest visitors may smell the 

smoke.

Prescribed burns would be ignited during the spring and fall to re-introduce fire back into the 

plantations around age 10 as well as to underburn within the existing plantations prior to ICO 

thinning. The individual burns would not last long, however burning in the project area could occur 

for 10 consecutive years. The effects of burning are described above. Since fire is a natural part of 

this landscape and these burns would be very low intensity, the visual effects would be minimal. In 

addition, this activity would diversify the vegetative mosaic in regards to vegetative forms, natural 

appearing lines, and additional colors and textures in the forest stands. 

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CUMULATIVEEFFECTS

Ongoing and reasonably foreseeable activities that would occur within the analysis area are listed in 

Appendix B. When considered with the recent Rim Recovery project, portions of the vegetative 

mosaic across the landscape within the project area would be in a state of transition from salvage 

logging, hazard tree removal and restoration activities over the next decade.

Since there are no regulations for scenic resource management on private lands, the effects of 

ongoing private development adjacent to Forest lands can sometimes have negative effects on scenic 

resources of the continuous landscape. When activities on private land are designed to limit impacts 

to scenic resources, the differences between private lands and Forest lands are less noticeable. The 

private timber industry lands that were salvage logged, deep tilled, sprayed and planted immediately 

after the Rim Fire are noticeably distinct from NFS lands and should return to a forested condition far 

sooner. Currently, they are a very open landscape. These lands were planted on a 10 to 14 foot grid 

and seedling survival is much higher than typically found on NFS lands. This geometrical/line pattern 

would be noticeable for many years on this production forest land. In the long-term, forest structure, 

bigger trees, would return to these areas sooner.

Alternative 2 (No Action)

DIRECT AND INDIRECT EFFECTS

No treatments would occur in Alternative 2. It would take a lot more time to achieve desired scenic 

character across the landscape since reforestation would depend on natural regeneration to take place. 

The landscape would be dominated by continuous woody shrubs and forbs precluding the possible 

establishment of diverse forest habitat (species, density, sizes).

The landscape within the Rim Fire would be dominated by a mix of shrub species. A landscape 

dominated by the shrubs would be outside of the historical range of variation for vegetation. It may 

take decades to meet the desired landscape character and visual quality objectives for the project area 

under this alternative. The scenic attractiveness component of the landscape character may change if 

the vegetative composition is dominated by shrub species.

CUMULATIVE EFFECTS

Ongoing and reasonably foreseeable activities that would occur within the analysis area are listed in 

Appendix B. When considered with the recent Rim Recovery project, portions of the vegetative 

mosaic across the landscape within the project area would be in a state of transition from salvage 

logging, hazard tree removal and the restoration activities over the next decade.

Without reforestation, the vegetation that colonizes the fire area could cause long-term changes in 

how visitors distribute themselves across the landscape and change the way people experience the 

Forest.

The private timber industry land planted immediately after the Rim Fire is noticeably distinct from 

NFS lands and would continue to be so in the long-term. Currently, they are a very open landscape, 

but in the long-term would provide some forest structure to the north end of the project area.

Alternative 3

DIRECT AND INDIRECT EFFECTS

Similar to Alternative 1, with the differences described below.

Plantations

Fuelbreaks are 250 feet wide with one row of 4-tree micro-clusters spaced 26 feet apart within a 90 

foot wide strip across the top of the ridge, bordered by 80 feet of trees planted at 15 by 15 foot 

spacing. The linear edges of the 90 foot fuelbreak would appear un-natural as the trees matured 

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starting between 7 to 10 years when the trees would be at least 5 feet tall. Around half of the trees 

planted are expected to have survived within 5 years of planting. As the number of live trees decline, 

the linear features of the fuelbreak would become less apparent including the linear feature of the 

micro-clumps down the center of the fuelbreak. The 90 foot wide middle of brush would remain 

intact with few trees for decades. The fuelbreaks could be easily noticed in all distance zones, but 

would be more dominant in foreground and middle ground views of developed recreation sites and 

popular roads and trails. In middle ground and background views the fuelbreak treatments could 

dominate the landscape for decades if the fuelbreaks are maintained. If so, this could potentially meet 

the modification VQO in the long-term. “To meet visual quality objectives successfully, fuelbreak 

design must subdue unnatural contrasts and borrow from natural form, lie, color and texture” (USDA 

1985). 

Alternative 3 would result in more natural appearing landscape characteristics than Alternative 1 due 

to the increased variability of tree spacing from mortality. Alternative 3 would appear less natural 

than Alternatives 1 and 5 where fuel breaks exist.

Reforestation

In areas with deep tilling, forest cultivation and hand grubbing release treatments about 50% seedling 

survival is expected after 5 years. As the amount of surviving seedlings decreases and more brush 

moves into the landscape the short-term effect would be a more diverse appearance.

Release consists of hand grubbing to remove the vegetation in a 5 foot radius circle around each 

seedling. This activity would be done two times each year, likely in early spring and late spring to 

ensure competing vegetation is set back enough to support seedling survival. Grasses and shrubs 

would cover these areas treated for release within 1 to 2 growing seasons, but hand release is 

expected to be needed for 5 years post planting. Although only 45% or less of the area would have 

this treatment, concentric rings (a distinct and unusual pattern in nature) would be visible from most 

distances. The area would recover quickly once treatments stop and this treatment assists in meeting 

the long-term VQOs.

CUMULATIVE EFFECTS

Same as Alternative 1.

Alternative 4

DIRECT AND INDIRECT EFFECTS

Similar to Alternative 1, with the differences described below.

Potential effects to visual resources from proposed activities such as mastication and prescribed 

burning are the same as Alternative 1. The differences between the alternatives are stated below.

Plantations

In the short-term, Alternative 4 only reforests 20% of the proposed planting areas in the other action 

alternatives. The limited amount of planting would result in about four times as much of the 

landscape within the Rim Fire to be dominated by early seral structure including shrubs. This 

landscape composition would be outside the historic vegetation range of variability and therefore 

would not appear natural. This departure from historical range of variation may not be noticeable by 

Forest visitors.

Prescribed Fire

The additional areas treated with prescribed fire and the use of a tractor line around founder stands to 

protect them during burning would be noticeable in all distance zones until the end of the first 

growing season after the fire lines are created. Because the amount of burning is thousands of acres 

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more under this alternative, 34,000 acres in every 20 years, the effects to visitors would last far longer 

than under the other action alternatives.

CUMULATIVE EFFECTS

Same as Alternative 1.

Alternative 5

DIRECT AND INDIRECT EFFECTS

Same as Alternative 1.

CUMULATIVE EFFECTS

Same as Alternative 1.

Summary of Effects Analysis across All Alternatives

VQOs AchievedIndicator

The proposed treatments and activities under Alternatives 1, 3, 4 and 5 that would restore the 

vegetative mosaic within the Rim Fire area are compatible with the Rehabilitation VQO. In the longterm the Retention, Partial Retention and Modification VQOs could be achieved.

Under Alternative 2 (No Action), the scenic attractiveness component of the landscape character may 

change if the vegetative composition were dominated by shrub species which would be outside of the 

historical range of variation for vegetation in this area. It may take decades to meet the desired 

landscape character and VQOs under Alternative 2. 

Degree of Natural Appearance Indicator

The degree of natural appearance of the management activities varies by alternative: 

 Alternatives 1 and 5 would appear more natural than Alternatives 2, 3 and 4 in the long-term

because of the more forested landscape and eventually meet the VQOs. 

 Alternative 2 would not appear natural in the long-term since a shrub dominated landscape 

would be outside the historical range of variation for vegetation landscape characteristics

 Alternative 3 would result in more natural appearing landscape than Alternatives 1 and 5 due to 

hand grubbing and the subsequent increased variability of tree spacing from mortality and 

planting design with a less noticeable pattern; however, Alternative 3 would appear less natural 

than Alternatives 1 and 5 due to implementation of the strategic fire management fuel breaks.

 Alternative 4 would create landscape characteristics in unplanted areas that would not appear 

natural in the long-term since a shrub dominated landscape would be outside the historic range of 

variation for vegetation.

 Alternative 5 would result in less natural appearing landscape than all the action alternatives in 

the short-term due to the 7 foot by 14 foot initial planting pattern, but after PCT would be similar 

to Alternative 1. 

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3.15 WATERSHED

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction

Protection of water quantity and quality is an important part of the mission of the Forest Service 

(USDA 2007a). Management activities on NFS lands must be planned and implemented to protect the 

hydrologic functions of forest watersheds, including the volume, timing, and quality of streamflow. 

The following direction is relevant to the action alternatives as they affect water resources.

The Clean Water Act of 1948 (as amended in 1972 and 1987) establishes as federal policy for the 

control of point and non-point pollution, and assigns the states the primary responsibility for control 

of water pollution. Compliance with the Clean Water Act by national forests in California is achieved 

under state law (below). 

Non-point source pollution on national forests is managed through the Regional Water Quality 

Management Handbook (USDA 2011b), which relies on implementation of 35 prescribed regional 

best management practices (BMPs), as well as 23 national BMPs (USDA 2012) relevant to this 

project. Appendix B in the Watershed Report (project record) lists these BMPs and their associated 

management requirements. One of the Regional BMPs (BMP 2.13) requires the development of an 

Erosion Control Plan for projects with ground-disturbing activities. A plan was developed for this 

project and is included in the project record. 

The California Water Code consists of a comprehensive body of law that incorporates all state laws 

related to water, including water rights, water developments, and water quality. The laws related to 

water quality (sections 13000 to 13485) apply to waters on the national forests and are directed at 

protecting the beneficial uses of water. Of particular relevance for the Proposed Action is section 

13369, which deals with non-point-source pollution and best management practices.

The Porter-Cologne Water-Quality Act, as amended in 2006, is included in the California Water 

Code. This act provides for the protection of water quality by the state Water Resources Control 

Board and the regional water quality control boards, which are authorized by the U.S. Environmental 

Protection Agency to enforce the Clean Water Act in California.

EO 11988 Floodplain Management (1977) and 11990 Protection of Wetlands direct federal agencies 

to avoid to the extent possible the impacts associated with the destruction or modification of 

floodplains and wetlands. 

A Conditional Waiver of Waste Discharge Requirements for Discharges Relating to Timber Harvest 

Activities is issued to the Forest Service by the Central Valley Regional Water Quality Control Board

(Water Board). These waivers are required for all timber harvest activities that will or will likely 

discharge waste that could affect the quality of the waters of the State.

The Forest Plan Compliance (project record) document identifies the Forest Plan Standards and 

Guidelines that specifically apply to this project and related information about compliance with the 

Forest Plan.

Effects Analysis Methodology

The five project alternatives were analyzed at three watershed scales to determine direct, indirect and 

cumulative watershed effects of the Rim Reforestation project. These included large scale watersheds 

(40,000 to 250,000 acres) and two nesting smaller scales: 10,000 to 40,000 acres and 2,000 to 10,000 

acres. 

Beneficial uses of water and water quality objectives in the California Water Quality Control Plan 

(Basin Plan) of the Water Board (CVRWQCB 2011) were utilized as a regulatory benchmark 

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regarding the existing condition and to assess the effects of the proposed action and its alternatives on 

water quality. The water quality parameters considered in the watershed analysis were water 

temperature, sediment related parameters, and herbicides. These are the pollutants with the potential 

of being affected by project management activities.

Assumptions Specific to Watershed

 Watershed condition from the Rim Fire will recover, as will effects of the Rim Reforestation 

project.

 Water quality effects will occur at a magnitude below adversely affecting beneficial uses of water 

unless uncontrollable events occur. These include an abnormally high amount and/or intensity of 

precipitation or the occurrence of another fire in the project area as the watersheds recover from 

the effects of the Rim Fire.

 Water Quality Best Management Practices will be implemented and effective unless 

uncontrollable factors occur. These include an abnormally high amount and/or intensity of 

precipitation or the occurrence of another fire in the project area as the watersheds recover from 

the effects of the Rim Fire.

 Appendix A in the Watershed Report (project record) provides assumptions associated with 

Equivalent Roaded Acres (ERA) modeling for cumulative watershed effects.

Data Sources

 Satellite Imagery: Worldview, Landsat, and Light Detection and Ranging (LiDAR) 

 Forest Land Management Databases and planning documents: Forest Service Activity Tracking 

System (FACTS) and the Schedule of Proposed Actions (SOPA)

 Stanislaus StreamScape Inventory (SSI): Stream Survey Data from 2005-2012 

 Benthic Macroinvertebrate Inventory, Clavey River Ecosystem Project (CREP 2008)

 Burned Area Emergency Response Program: Past Fire information; Rim Fire watershed data

 Geographic Information Systems (GIS)

 Stanislaus National Forest Wild and Scenic River Study (1991) 

 Tuolumne River Wild and Scenic Management Plan 1988 (reprint 2002) 

 CalFire: Timber Harvest Plans (THPs), Non-Industrial Timber Management Plans (NTMPs) and 

Notices of Emergency Timber Operations (Frese 2013-2014) 

 Yosemite National Park: GIS shapefile with past and future activities within Park boundaries 

Watershed Indicators

 Water Quality Parameters: temperature, sediment, herbicides (measure: meet water quality

objectives)

 Stream Condition: channel form, streambank stability, pool sediment (measure: SSI protocol) 

 Riparian Vegetation: recovery (measures: no damage from project activities; recruitment 

unimpeded) 

 Ground Cover: riparian areas (measures: retention of existing; addition in riparian areas and 

watershed sensitive areas (WSA) (acres))

 Cumulative watershed effects (measure: ERA)

Watershed Methodology by Action

The direct, indirect and cumulative effects of the five project alternatives were evaluated using the 

following methods. 

DIRECT AND INDIRECT EFFECTS

 Literature Review. A thorough review of the literature was conducted related to the direct and 

indirect effects of actions that affect the watershed resource as proposed in this project. 

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 Monitoring. A review of Water Quality Best Management Practices Evaluation Program 

(BMPEP) results on the STF for activities related to the project was conducted. BMPEP 

monitoring results over the past decade were useful for predicting outcomes of the management 

activities proposed in this project.

 Field Evaluation. Field review of proposed treatment units and watershed conditions within the 

project area was conducted.

 GIS. GIS was used for analyzing data collected from fieldwork, satellite imagery products and 

forest databases related to the project.

CUMULATIVE WATERSHED EFFECTS

A Cumulative Watershed Effects analysis was conducted using the CWE model adopted by the 

Pacific Southwest Region of the Forest Service as a method of addressing cumulative watershed 

effects (USDA 1990). The model is referred to as Equivalent Roaded Acre (ERA). ERA values are 

calculated using a computer model developed on the STF (Rutten and Grant 2008). Appendix A of 

the Watershed Report (project record) provides further details.

Affected Environment

Watershed Setting

The Rim Fire burned through numerous watersheds in the central and southern portions of the 

Stanislaus National Forest, and some overlap eastward into Yosemite National Park where the 

remainder of the fire occurred. These watersheds are an important component of the water supply, 

fish and wildlife habitat, recreation, timber production and other values of the Sierra Nevada 

mountain range. Portions of the watersheds within the Rim Fire perimeter burned in several fires 

during the 20th century, while some areas have not burned in over 100 years. About 98% of the Rim 

Fire burned within the Tuolumne River watershed. The remaining 2% burned in the North Fork 

Merced River watershed along the southern edge of the fire.

Watersheds in the Rim Fire are delineated in accordance with the national watershed classification 

system (USGS 2013). This system is a spatial hierarchy of eight nesting watershed size classes 

ranging from very large (greater than 250,000 acres) to very small (less than 2,000 acres). This 

classification system uses the term Hydrologic Unit Code (HUC), as shown in Table 3.15-1, to 

describe all watershed size classes. They are called HUC levels and are numbered in order from 1 to 8 

in descending size class. Each HUC level code is a two digit number that ties to a watershed size and 

name. For example, HUC Level 1 is a two digit code whereas as HUC Level 5 is a 10 digit code. 

Table 3.15-1 shows an example of how this nesting system applies to the Rim Fire watersheds. 

Table 3.15-1 Hydrologic Unit Code System (HUC)

HUC Level HUC Name HUC Size 

(average acres) Rim Fire Examples

1 Region 100,000,000 NA

2 Sub-region 10,000,000 NA

3 Basin 7,000,000 San Joaquin River

4 Sub-basin 450,000 Tuolumne River

5 Watershed 40,000 to 250,000 Clavey River

6 Sub-watershed 10,000 to 40-000 Reed Creek

7 Drainage 2,000 to 10,000 Reynolds Creek

8 Sub-drainage less than 2,000 Lost Creek

The STF includes HUC Level 4 through 8 watersheds. (The term watershed is often used generically 

even though each HUC level has a unique name). The HUC Level 4 watersheds on the Forest are the 

headwaters of large rivers that continue downstream off the Forest (e.g., Tuolumne River).

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Nine HUC 5 Level watersheds are within the Rim Fire; within those, are 18 HUC Level 6 watersheds. 

Table 3.15-2 displays the HUC Level 5 and HUC Level 6 watersheds relevant to the fire area, 

including total HUC Level 5 and HUC Level 6 watershed acreage. Note that the HUC Level 6 

watershed acreage does not add up to that of 7 of the 9 HUC Level 5 watersheds. This is because in 

those watersheds additional HUC Level 6 watersheds are fully outside the fire perimeter. Watershed 

acreage within the STF boundary is less in some watersheds and will be described in the existing 

condition and environmental consequences sections of this report. The HUC Level 5 watersheds in 

Table 3.15-2 are listed clockwise around the fire area beginning where the main channel of the 

Tuolumne River exits the Rim Fire perimeter.

Table 3.15-2 Rim Fire Area Principal Watersheds and Condition Overview

HUC Level and Name Size

(acres)

In RIM

(%)

In NF

(%)

SBS 

HIGH

SBS 

MOD

SBS 

LOW

5. Big Creek-Tuolumne River 81,721 56 70 5 27 68

6. Big Creek 18,734 1 52 0 1 99

6. Grapevine Creek-Tuolumne River 23,817 77 82 1 26 73

6. Jawbone Creek-Tuolumne River 27,629 99 100 14 56 30

7. Corral Creek 4,581 100 100 31 58 11

7. Lower Jawbone Creek 5,670 100 100 10 75 15

5. North Fork Tuolumne River 63,849 9 92 0 3 97

6. Lower North Fork Tuolumne River 34,210 17 89 1 6 93

5. Clavey River 100,645 52 100 3 15 82

6. Lower Clavey River 17,871 100 100 4 45 51

7. Bear Springs Creek-Lower Clavey River 7,090 100 100 7 43 50

6. Middle Clavey River 26,912 69 100 2 11 87

6. Reed Creek 24,527 66 100 7 16 77

7. Lower Reed Creek 7,495 100 100 21 41 38

5. Cherry Creek 90,892 24 93 3 12 85

6. Lower Cherry Creek 24,383 84 98 10 43 47

7. Granite Creek 4,126 100 100 30 62 8

6. Upper Cherry Creek 16,344 7 100 0 1 99

6. West Fork Cherry Creek 26,149 1 100 0 1 99

5. Eleanor Creek1 59,906 28 2 1 9 90

6. Miguel Creek-Eleanor Creek 15,798 76 6 4 31 65

5. Falls Creek-Tuolumne River1 124,244 19 4 1 5 94

6. Poopenaut Valley-Tuolumne River 18,232 99 30 6 33 61

5. Middle Fork Tuolumne River1 46,635 68 34 7 32 61

6. Lower Middle Fork Tuolumne River 14,928 100 100 6 57 37

6. Upper Middle Fork Tuolumne River 31,707 53 3 8 21 71

5. South Fork Tuolumne River1 57,855 88 41 4 29 67

6. Lower South Fork Tuolumne River 19,988 100 100 4 43 53

6. Upper South Fork Tuolumne River 37,866 83 9 3 22 75

5. North Fork Merced River 79,110 8 81 0 3 97

6. Bull Creek 21,064 6 100 0 2 98

6. Bean Creek-North Fork Merced River 36,739 14 92 0 4 96

Rim Fire Summary1 69 7 37 56

LOW=Low and Unburned; MOD=Moderate; NF=National Forest; RIM=Rim Fire; SBS=Soil Burn Severity (percent of Fire area) 1 Substantial portion of the Rim Fire extends east into Yosemite National Park.

Given the large size of the fire, the HUC Level 6 watersheds are the most appropriate scale for 

watershed description and analysis of the effects of the Rim Reforestation project. HUC Level 5 

watersheds will be described for spatial context and broad scale analysis, and selected HUC Level 7 

watersheds will be discussed where more detailed analysis is indicated. Figure 3.15-1 displays the 

HUC Level 6 watersheds relevant to the Rim Fire. 

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Figure 3.15-1 HUC Level 6 Watersheds in the Rim Fire Area

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Existing Conditions

Several factors that affect watershed condition have occurred in the Rim Reforestation project area. 

These include natural events and management activities that create ground disturbance and alter 

natural hydrologic processes. The effects of the Rim Fire have a strong influence on existing 

conditions, and will be discussed further below. The Rim HT project and the Rim Recovery project, 

which began the Rim Fire restoration process, are the most recent projects within the analysis area. 

Rim HT is essentially completed and Rim Recovery is about 70% complete and implementation will 

continue regardless of the decision that is made for the Rim Reforestation project. This watershed 

analysis considers the effects of the initial two projects as part of the existing condition in the 

cumulative effects analysis (Appendix B). 

WILDFIRE EFFECTS

The Rim Fire, like almost all wildfires, is a mosaic of high, moderate and low soil burn severity plus 

unburned areas within its perimeter. Many past fires occurring within the Rim Fire perimeter have 

nearly half or more of their total acreage in the low and unburned categories that resulted in minimal 

to negligible watershed impact. Most watershed damage occurs from high soil burn severity, and 

lesser from moderate soil burn severity.

The principal effects of soil burn severity are the reduction of ground cover and infiltration capacity. 

High soil burn severity has the most watershed effect since it usually results in very low remaining 

ground cover, ranging from 0 to 20%, and the most increase in water repellency. These factors make 

it insufficient to adequately prevent accelerated soil erosion and, where eroded soil can reach 

waterways, cause stream sedimentation. Moderate soil burn severity is usually less damaging since 

the soil is not as impacted and the singed conifer needles fall to the forest floor initiating replacement 

of burned ground cover. Low soil burn severity is usually an insignificant factor since most pre-fire 

cover remains and infiltration is mostly retained. 

High soil burn severity usually chars the soil crust, damaging soil structure, killing plant roots, 

removing all, or mostly all, ground cover (litter and duff) and often results in strongly water repellent 

soil. Moderate soil burn severity does less damage since its soil structure effect and degree of water 

repellency is usually lower. Low soil burn severity has minimal soil impact, usually scorching ground 

and portions of tree trunks and bases of tree crowns; few trees are killed. The combination of high and 

moderate soil burn severity usually represents what is known as a stand replacing fire since nearly all 

trees are killed. Often in forested areas, post-fire vegetation condition acts as a visual indicator of soil 

burn severity. High soil burn severity is indicated by fully killed trees with all needles and often many 

branches consumed. Moderate soil burn severity is viewed as killed trees with browned needles 

remaining (most fall before winter, providing natural ground cover). Low soil burn severity usually 

results in patchy ground fire with lower portions of trunks blackened and some lower crowns singed. 

Soil burn severity is a measure of the effect of ground heat as a fire burns across a landscape, and is 

not the same as fire intensity or vegetation burn severity. Fire intensity is a measure of heat produced 

by a fire (BTUs). Vegetation burn severity measures both vegetation canopy mortality and vegetation 

basal area mortality resulting from wildfire. For the remainder of this report reference to burn severity 

will mean soil burn severity unless otherwise noted.

While the Rim Fire area is the largest of the fires within the forest to date, it does not have the highest 

soil burn severity. Its high soil burn severity is the second lowest of the principal fires within its 

perimeter since 1973. Though its high soil burn severity is much less than its next largest predecessor, 

the Stanislaus Complex Fire of 1987, the Rim Fire has resulted in about 10,000 acres of very low 

ground cover distributed in various sized large to small patches across the 154,530 acres of NFS land 

it burned. Table 3.15-3 displays soil burn severity for the six largest fires within the Rim Fire 

perimeter that have soil burn severity information.

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Table 3.15-3 Soil Burn Severity for Selected Fires in Relation to the Rim Fire

Fire Year NFS

(acres)

SBS 

HIGH

SBS 

MOD

SBS 

LOW Notes

Rim 2013 154,530 7 37 56

Stanislaus Complex 1987 147,100 36 20 44

Rogge 1996 19,400 0 41 59 No high soil burn severity due to low fuel loading over much 

of the area because of new plantations after the Stanislaus 

Complex fire.

Granite 1973 17,100 55 30 15

Ackerson 1996 11,300 19 14 67 This fire was much larger overall with most acreage in 

Yosemite National Park.

Pilot 1999 4,000 46 25 29

LOW=Low and Unburned; MOD=Moderate; SBS=Soil Burn Severity (percent of Fire area)

Distribution of soil burn severity within a fire area is also important. A spatial mosaic of all severities 

can reduce on and off-site soil and water effects while concentrations of high soil burn severity can 

cumulatively increase effects. The largest concentrations of high soil burn severity in the Rim Fire 

occurred in Granite Creek, within the 1973 Granite Fire, and in the Corral Creek and Reed Creek 

areas, both believed unburned in about 100 years. Other lesser high soil burn severity concentrations 

are scattered throughout the fire area, surrounded by moderate and/or low soil burn severity areas as 

well as unburned areas. 

These concentration areas, and other smaller severely burned sites in the fire, were identified by the 

Rim Fire BAER team as a watershed value at risk for loss of soil productivity and delivery of stream 

sedimentation. As a result, action to minimize the risk was taken in November, 2013. Helicopters 

applied weed free rice straw mulch to 4,300 acres of the highest priority portions of these locations 

(i.e., steep slopes, high erosion risk, and stream proximity). Helicopter mulching produces a uniform 

layer of straw, about 1 to 1.5 inches deep that provides 80 to 100% ground cover. An additional 

BAER action, mastication, was conducted on 40 acres of high soil burn severity area to increase 

ground cover. Mastication is mechanical chipping of small trees. Low-ground-pressure tracked 

equipment with an articulated arm and a chipping head provides immediate cover to bare areas.

The Tuolumne River canyon is another burn concentration area in the Rim Fire. The fire began near 

the Clavey River confluence, continued upstream to Cherry Creek, then up Cherry Creek to Eleanor 

Creek in Yosemite National Park. Much of the canyon vegetation is dominated by chaparral and other 

flashy fuels which burned hot and fast up canyon, where the fire then spread northward and led to the 

conifer dominated high soil burn severity concentrations mentioned above. The canyon soil burn 

severity is classed as moderate, even though vegetation was well consumed, since the fire here had 

little residence time and thus, minimally degraded soil properties or increased watershed runoff 

response. This concentration area is a near repeat of the 1987 Stanislaus Complex Fire. The 

Tuolumne River canyon burns easily, and the mature 26-year-old vegetation was ready to burn again.

Overall in the Rim Fire, effective watershed cover exists on about 56% of the land within the fire 

perimeter (the total of the low soil burn severity and the unburned portion within the fire perimeter). 

This cover consists of living vegetation which primarily includes conifer trees with forest floor litter 

and duff, plus brush and smaller woody shrubs. This ground cover has been supplemented in much of 

the moderately burned conifer areas due to needle cast. While this is not as effective as living cover it 

does provide a measure of effectiveness compared to high burn severity areas since it resists initiation 

of rainsplash erosion. Helicopter mulching and mastication mitigated some of the worst high soil burn 

severity areas, but other locations of high soil burn severity areas remained with inadequate cover 

soon after the fire. However, it is worth to note that natural recovery of live vegetation has been 

happening at a fast pace throughout the project area.

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In summary, the Rim Fire was a mixed severity fire, not only across the entire fire, but at all 

watershed scales. Patch size of each soil burn severity class in this mosaic was also mixed with some 

patches hundreds to several hundreds of acres, others tens to hundreds, and yet others where all three 

classes occurred within ten acres. Mixed severity was also distributed similarly from stream to ridge 

within most watersheds. Riparian areas burned in a mosaic as did the hillslopes above them. The 

largest high soil burn severity patches occurred in the uplands, mostly on south-facing slopes where 

the fire could easily pre-heat fuels.

At the Rim Fire scale, the amount of soil burn severity varies widely among and within all HUC level 

watersheds. In general it is least for the HUC 5 watersheds, more for the HUC 6 watersheds and 

greatest for the HUC 7 watersheds. Many HUC 5 watersheds, being the largest, have substantial 

portions outside the Rim Fire perimeter. The HUC 6 watersheds, though generally having more 

acreage within the fire, also have a highly variable amount of soil burn severity based on fire location 

and watershed acreage within the fire perimeter. The HUC 7 watersheds, that have the highest burn 

severity, have been selected as watershed analysis emphasis areas due to severe burn and/or 

concentrated post-fire management activities.

Table 3.15-2 provides an overview of the three watershed scales and the portion each occupies within 

the Rim Fire and the STF. It also shows the soil burn severity of each watershed as an indicator of 

existing condition relative to ground cover and vegetation alteration by the fire. Rim Fire information 

is provided at the top of the table for comparison with the HUC Level 5, 6, and 7 watersheds. Refer to 

Figure 3.15-1 for the locations of the HUC 6 watersheds as well as to gain an understanding of the 

locations of their HUC 5 and 7 counterparts. 

Table 3.15-2 shows the similarities and variations among watersheds. Watershed area within the fire 

perimeter ranges from 1 to 100% among the HUC 5 and 6 watersheds, and all the HUC 7 watersheds 

are 100% within the perimeter. The percentage of watershed area within the STF is high for all 

watersheds except for portions of the 4 HUC 5 watersheds that extend east of the Forest into 

Yosemite National Park.

The amount of soil burn severity across the fire also exhibits similarities and variations by watershed. 

Moderate soil burn severity is greater than high severity in every watershed, ranging from2 to 10 

times as much. High soil burn severity is similar in almost all HUC 5 and HUC 6 watersheds; all 9 

HUC 5s are less than 10% as are 16 of the 18 HUC 6s. HUC 7 watersheds are dissimilar to their 

larger counterparts in that they almost all have greater high and moderate soil burn severity.

Table 3.15-2 also shows that 25 of the 32 watersheds have more than 50% acreage in the low soil 

burn severity and unburned class. Half of those watersheds have greater than 75% in this same class. 

The remaining 7 watersheds include all 5 HUC 7s and 2 of the more heavily burned HUC 6s: Lower 

Cherry Creek and the Lower Middle Fork of the Tuolumne River. The fire wide average of 56% in 

the low and unburned class is made up of a high percentage of predominantly low and unburned 

watersheds punctuated by several highly burned ones. 

The most visible watershed impact of the fire was in the high soil burn severity areas since it reduced 

ground cover to less than 20%, often near zero. Ground cover in the moderate soil burn severity areas 

was also substantially reduced as nearly all trees were killed by the fire, though needle cast 

replacement cover of 50% or more occurred in many of the conifer forested areas before winter. 

However, a vegetation monitoring was conducted this field season 2015 by Forest Service personnel 

on units proposed for reforestation (approximately 26,009 acres, including deer and natural 

regeneration units). Within the Composite Burn Index (CBI) of high, moderate, low, and unchanged 

severity areas, vegetation cover averaged 61%, 50%, 23% and 4%, respectively. Overall cover of 

shrubs, grasses, and forbs have a positive correlation with burn severity, increasing on average from 

4% cover in unchanged areas to greater than 60% cover in high-severity burn areas. Vegetation 

(Chapter 3.13) provides additional information on post-fire vegetation monitoring. 

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VEGETATION CONDITION

Hillslopes

The remaining live vegetation within the Rim Fire perimeter consists largely of second growth forest 

stands from legacy logging as well as more recent various aged timber plantations. It also consists of 

unlogged natural stands, some of which are very old. Despite the diversity of this vegetation, it almost 

all currently shares a common trait: high stand density. An excessive number of tree stems per acre 

creates closed canopies and an undesirable fuel ladder. This dense condition leaves unburned forest 

vegetation elsewhere as vulnerable to future high severity wildfires as has recently occurred. At the 

scale of the Rim Fire about 44% of live vegetative canopy was lost, in various mosaic patterns, and 

about 56% remained largely unaffected. As Table 3.15-2 showed, the amount of soil burn severity 

and vegetation burn severity varied substantially among the watersheds in the fire area.

Riparian Conservation Areas

Riparian Conservation Areas (RCAs) are corridors along stream channels and surrounding meadows, 

springs and other wetland areas that provide habitat for plants that thrive on a high water table. These 

riparian obligate species include resprouting trees such as alders, big leaf maples, dogwoods, 

cottonwoods and aspens, shrubs such as willows, and a variety of streamside and meadow herbaceous 

plants. Conifers also coexist in RCAs with obligate species, often growing well near streams.

Table 3.15-4 shows the watershed effect of the Rim Fire on vegetation condition in RCAs by 

watershed. A 100-foot zone along all perennial and intermittent streams (100 feet on each side for a 

total width of 200 feet) was selected to focus on the immediate near-stream complex of obligate and 

non-obligate vegetation in the cooler, moister microclimate along streams, often referred to as the 

“riparian bubble.” These RCAs often includes the immediate channel and its flood prone areas and or 

adjacent terrace. The upslope remainder of the 300 or 150-foot RCA widths are usually dominated by 

hillslope vegetation and warmer air temperatures. Both soil and vegetation burn severity measures 

were assessed for validation of comparability. This 100-foot buffer represents an average of about 7% 

of the total area in the Rim Fire watersheds, with a range of 5 to 9% among all watersheds.

The RCA columns in Table 3.15-4, display soil and vegetation burn severity for all HUC 6 and HUC 

7 watersheds in the Rim Fire. The RCA H + M column is the sum of high and moderate soil burn 

severity in the 100-foot stream buffer. The Watershed column displays the sum of the high and 

moderate burn severity for the entire watershed. The RCA H + M column is the key information for 

comparing soil to vegetation burn severity and RCA-to-watershed soil burn severity. 

Table 3.15-4 shows that RCA soil and vegetation burn severity match closely in almost all 

watersheds. In 21 of 23 watersheds soil and vegetation burn severity are within 5% of one another, 

and the remaining two are 7% and 8%. In most cases the vegetation burn severity is equal to or 

slightly less than the soil burn severity. The two measures validate they are comparable for estimating 

vegetation loss. Soil burn severity has the added advantage of also being able to indicate ground cover 

condition. 

Comparing RCA to watershed, Table 3.15-4 shows that RCA soil burn severity is in most cases less 

than for the watershed as a whole. RCA soil burn severity is not higher than watershed soil burn 

severity in 19 of the 23 watersheds in Table 3.15-4. The 4 that are higher are barely so, and many of 

the watershed soil burn severity percentages are much higher than the RCA. 

The Rim Fire burned less severely near the streams than in the uplands in almost all watersheds, and 

substantially less in many. And though it burned less in RCA there was still a notable loss of the 

stream shade capacity of conifers and riparian obligate trees and shrubs in many watersheds. But 

while the conifers will be long in returning to replace shade, the riparian trees will fill the void in the 

short run and also provide biodiversity along stream reaches burned in the Rim Fire.

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Table 3.15-4 Riparian Conservation Area Soil and Vegetation Burn Severity

HUC Level and Name % RCA

SBS HIGH

% RCA

SBS MOD

% RCA

SBS LOW

% RCA

SBS H+M

% RCA

VBS HIGH

% WAT 

SBS H+M

5. Big Creek-Tuolumne River

6. Big Creek 0 0 100 0 0 0

6. Grapevine Creek-Tuolumne River 0 11 89 11 15 27

6. Jawbone Creek-Tuolumne River 11 38 51 49 50 70

7. Corral Creek 41 51 9 92 88 89

7. Lower Jawbone Creek 3 42 55 45 49 85

5. North Fork Tuolumne River

6. Lower North Fork Tuolumne River 1 8 91 9 6 7

5. Clavey River

6. Lower Clavey River 1 19 80 20 19 49

7. Bear Springs Creek-Lower Clavey River 2 17 81 19 14 50

6. Middle Clavey River 1 7 92 8 7 13

6. Reed Creek 3 10 87 13 11 23

7. Lower Reed Creek 12 31 56 43 41 62

5. Cherry Creek

6. Lower Cherry Creek 13 34 53 47 45 53

7. Granite Creek 35 59 6 94 91 92

6. Upper Cherry Creek 0 0 100 0 0 1

6. West Fork Cherry Creek 0 0 100 0 0 0

5. Eleanor Creek1

6. Miguel Creek-Eleanor Creek 4 34 62 38 41 35

5. Falls Creek-Tuolumne River1

6. Poopenaut Valley-Tuolumne River 5 27 68 32 32 39

5. Middle Fork Tuolumne River1

6. Lower Middle Fork Tuolumne River 5 50 45 55 50 63

6. Upper Middle Fork Tuolumne River 3 22 75 25 17 29

5. South Fork Tuolumne River1

6. Lower South Fork Tuolumne River 2 23 75 25 18 46 

6. Upper South Fork Tuolumne River 4 19 77 22 17 25

5. North Fork Merced River

6. Bull Creek 0 2 98 2 2 2

6. Bean Creek-North Fork Merced River 0 2 98 2 2 4

H+M=High plus Moderate; LOW=Low and Unburned; MOD=Moderate; SBS=Soil Burn Severity (percent of Fire area); VBS

HIGH=Vegetation Burn Severity High (Canopy Mortality 75 to 100%); WAT=Watershed (total acres) 1 Substantial portion of the Rim Fire extends east into Yosemite National Park.

TRANSPORTATION SYSTEM CONDITION

Road density in the Rim Fire area ranges from 1 to 6 miles of road per square mile, with an average 

of about 4 miles per square mile. This is similar to other roaded multiple-use areas within the forest. 

Prior to the Rim Fire, the existing road network within its perimeter was adequate to serve the needs 

of forest management activities. As part of the post-fire salvage harvest, minimal road construction 

had a negligible change in road density. 

Road sediment discharge increases are expected as a result of the Rim Fire. Most increases are likely 

to occur in high soil burn severity areas within the Rim Fire, and to a lesser extent in moderate soil 

burn severity areas. Problems include locations of improper road drainage function and culverts at 

road-stream crossings. The undersized culverts cannot handle post-fire flow volume and the 

additional woody debris and sediment it carries. The quantity and effect of fire-related sedimentdelivery increase is uncertain, due to variability in winter weather prior to the implementation of the 

Rim Reforestation. Forest roads cause hydrological effects by concentrating and channelizing surface 

and subsurface flow. Following wildfire, the ability of the landscape to filter runoff from roads can be 

reduced due to a decrease in ground cover (Peterson 2009).

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STREAM CONDITION

Stream condition inventories were conducted along portions of 23 streams within the Rim Fire area 

between 2005 and 2012. These are part of the forestwide Stanislaus StreamScape Inventory (SSI) 

program to determine stream condition prior to management activities or for baseline watershed 

information (Frazier et al. 2008). SSI consists of 21 attributes of stream condition measured 

continuously along wadeable stream channels in lengths that have ranged from about 1 to nearly 10 

miles. Some larger streams become wadeable by late summer, such as the Middle and South Forks of 

the Tuolumne River, the Clavey River and Reed Creek. They, among many of their tributaries, 

comprise the streams represented here. The main channel of the Tuolumne River has not been 

inventoried due to its size and regulated flow regime which create unsafe SSI working conditions. 

Table 3.15-5 summarizes the existing condition of these streams based on key indicators.

Table 3.15-5 Rim Fire Stream Condition Summary for Stream Channel and Stream Habitat Indicators

Indicator Measure Streams Conditions

Stream Channel Streambank Stability 21 over 75%

Stream Channel Streambank Stability 1 50 to 75%

Stream Channel Streambank Stability 1 less than 50%

Stream Channel Channel Form 16 over 75% normal or rejuvenating

Stream Channel Channel Form 4 50 to 75% normal or rejuvenating

Stream Channel Channel Form 3 less than 50% normal or rejuvenating

Stream Habitat Pool Tail Fine Sediment 16 less than 10%

Stream Habitat Pool Tail Fine Sediment 3 10 to 20%

Stream Habitat Pool Tail Fine Sediment 4 over 20%

Stream Habitat Pool Bed Fine Sediment 18 less than 10%

Stream Habitat Pool Bed Fine Sediment 3 10 to 20%

Stream Habitat Pool Bed Fine Sediment 2 over 20%

Stream Habitat Water Temperature Maximum 10 less than 59 degrees F

Stream Habitat Water Temperature Maximum 9 59 to 68 degrees F

Stream Habitat Water Temperature Maximum 4 over 68 degrees F

Stream Channels

Streambank stability is assessed in quartile percentage classes at 328-foot (100-meter) increments. 

The summary above represents the percentage of streambank stability on all streams inventoried. 

Twenty-one of the 23 streams have a majority of their stream length in the greater than 75% stability 

quartile with no 328-foot increments less than 50% stable. This indicates the streambank stability for 

the surveyed stream is either fully or highly likely to be greater than 75%, which represents a very 

stable stream system. Numerous streams have over 90% of their length fully classified in the upper 

quartile. 

Channel form, or cross-sectional shape, is assessed in SSI in four classes which depict excellent to 

poor condition. The Normal class is one whose channel fits proper morphological features for its 

stream type. These factors include width-to-depth and entrenchment ratios, streambank angle, and 

other measures of channel shape (Rosgen 1996). The Rejuvenating class is a channel form that shows 

evidence of legacy disturbance but is recovering or has recovered to good condition. These classes are 

combined to assess condition of the channel form. For example, a stream with more than 75% of its 

length in these classes, provided the Normal class is greater, is in very good condition. Sixteen of the 

inventoried streams are in this condition, while the remaining streams have some portions with 

evidence of accelerated incision or widening. 

Overall, the two stream channel indicators show a high percentage of the inventoried streams were in 

very good condition prior to the Rim Fire. Stream condition is expected to be affected by post-fire 

erosion and sedimentation though the magnitude is uncertain, and is largely reliant upon winter 

weather events. Effects may be mitigated in areas that received BAER hillslope and road treatments 

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Chapter 3.15 Stanislaus

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in the fall of 2013 as well as in areas where effective and adequate natural re-growth has taken place 

to a level that can minimize surface erosion and sedimentation. 

Stream Habitat

SSI quantitatively measures stream pool sediment serving as indicators of stream habitat quality and 

sedimentation. Pools are the sediment reservoirs in streams. Sediment in stream pools is an indicator 

of erosion from the upstream watershed, and thus shows whether excessive input is present. 

Excessive sedimentation can arise from ground disturbing management activities such as timber 

harvest or roads, or from fires, floods or mass wasting (e.g., landslides, debris flows). Fine sediment 

is measured since it represents the smallest soil particles, which are the key components of aquatic 

habitat. Excessive fine sediment in stream pool tails can reduce fish spawning success. Excess pool 

bed sediment reduces pool area that can be used for fish rearing and productivity. Pool tail fine 

sediment is calculated at pool outlets, and pool bed fine sediment is measured throughout the full 

length of stream pools. Pool tail sediment less than 20% is usually considered suitable for fish 

spawning. Pool bed sediment, measured as the length of fine sediment deposition in a pool, 

characterizes the amount of settleable material (material heavy enough to sink to the bottom of a 

pool) sourced from the watershed. The same percentage threshold is used for pool bed sediment as for 

pool tails.

As shown in Table 3.15-5, pool tail and pool bed sediment were very low in the inventoried streams. 

It is not excessive since presence of native fish of all age classes are common or abundant in these 

streams. The amount of pool sediment in these streams is an indicator of a very stable watershed 

landscape, including recovery from past disturbances by wildfire and ground-disturbing management 

activities.

Water temperature was also excellent in these streams. The SSI data in Table 3.15-5 are the 

maximum daily temperatures and all are suitable for the native aquatic organism communities. Even 

the streams with maximum temperatures exceeding 68 degrees Fahrenheit, a threshold of concern for 

cold water fish, were only slightly higher and their minimum daily temperatures are well below the 

threshold. 

Benthic macroinvertebrates (BMI) are another indicator of stream health. They were sampled in the 

Clavey River in 2007 as well as several of its tributaries within the Rim Fire perimeter as part of the 

stream condition inventory for the Clavey River Ecosystem Project (CREP 2008). The BMI data were 

evaluated using the River Invertebrate Prediction and Classification System (RIVPACS) (Hawkins et 

al. 2000). Numeric values very close to 1 indicate reference condition, meaning streams are in as 

good of condition as naturally occurs. Numbers exceeding 1 are better than what is expected. A score 

of 0.9 or 90% means the stream health is in excellent condition. Streams and their BMI scores are as 

follows: Two Mile Creek (0.991), Hull Creek (1.106), Clavey River (0.927), Reed Creek (1.021), 

Bourland Creek (1.166), Cottonwood Creek (1.166) and Bear Springs Creek (0.932). No impairment 

of stream habitat or water quality was evident.

Between the time of collection of the stream condition data and the Rim Fire there were no significant 

management activity disturbances or natural events that would have been likely to substantially alter 

stream conditions.

WATER QUALITY CONDITION

Prior to the Rim Fire, water quality within the fire perimeter was considered excellent at all the 

watershed scales previously described. Throughout the main Tuolumne River and its tributaries there 

is substantial evidence of high quality water. The EPA maintains a list of waters with impaired water 

quality under Section 303(d) of the Federal Clean Water Act (CVRWQCB 2010). The Tuolumne 

River is not listed as an impaired stream, nor is the Merced River. At the smaller scale, SSI and BMI 

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data collected in the Rim Fire area have shown evidence of excellent water quality where sampled in 

the watersheds across the fire area. 

Water quality degradation resulting from erosion and stream sedimentation following the Rim Fire 

occurred as expected for a winter (2013/2014) that turned out to be only about 50% of average 

precipitation with few storms exceeding a 1 to 2 year return interval. Early winter rainfall began to 

mobilize easily dislodged ash and streamside sediment in highly burned areas with little ground 

cover. Streams and rivers ran variably turbid, some very much so, during and after succeeding storms 

depending on rainfall intensity, soil type and other factors. Decreases in turbidity and sediment 

transport occurred between storms. This process of storm driven sediment delivery and transport 

repeated itself over the low-rainfall winter of 2014/2015. Sediment mobilization, transport and 

deposition were minor to moderate, without major degradation. 

Environmental Consequences

Alternative 1 (Proposed Action)

DIRECT AND INDIRECT EFFECTS

Direct and indirect effects of proposed activities are described below for 13 of 18 HUC 6 watersheds 

and 5 HUC 7 watersheds. Five HUC 6 watersheds (Big Creek, Upper Cherry Creek, Bull Creek, Bean 

Creek-North Fork Merced River, and West Fork Cherry Creek) are not assessed below due to the 

negligible amount of high and moderate soil burn severity (Table 3.15-2) and proposed project 

activities in their watersheds. Proposed treatments within these watersheds cover a relatively low 

percentage of the total watershed acres and therefore are too small for consideration in this analysis.

Project consequences in these watersheds would be negligible and not likely detectable. The selection 

of 5 HUC 7 watersheds is described in Appendix A of the Watershed Report: Cumulative Watershed 

Effects Analysis Methodology. 

Erosion and Sedimentation

Soil Compaction

Compaction of soil from mechanized equipment can lead to hydrologic effects such as lower 

infiltration rates and increased runoff. These effects are anticipated to occur in the portion of the 

project area where thinning in existing plantations and mechanical site preparation are proposed. The 

effects would be minimized on those areas where deep tilling and forest cultivation would be 

combined as a follow-up site preparation activity. Conversely, equipment tracking could break down 

the hydrophobic layer, providing a positive effect. 

Soil Displacement

In existing plantation thinning units, feller-bunchers “bunch” the logs into a pile for the skidder to 

move. Minor displacement of soil may occur in the feller-buncher tracks, particularly where the 

equipment has turned.

Management requirements of mechanical impacts (e.g., slope and wet season limitations) are

anticipated to minimize or prevent erosion and sedimentation. Mastication, while potentially causing 

some on-site soil displacement, also provides a mulch cover to mitigate erosion risk.

Ground Cover

Management requirements were designed to maintain or increase ground cover in near-stream areas. 

Within RCAs, ground cover is expected to increase under the proposed action as a result of 

maintaining post-fire conifer needle cast, application of ground cover by leaving dead plant material 

and limbs, or by mastication, along with the natural recovery of live vegetation. A maximum of 20 

tons per acre of fuel loading would remain. 

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BMP monitoring is completed annually on the STF to assess the effectiveness of BMPs. The 

Watershed Report in the project record gives a description of BMP effectiveness in preventing and 

minimizing erosion and sedimentation on past projects. 

Mechanized Equipment Activities

Effects of site preparation with tractors and thinning existing plantations with feller bunchers on 

water quality could include increases in sedimentation caused either by the transport of eroded 

material out of treated areas into stream channels, or by increased flows that result in channel erosion 

that in turn increases sedimentation. Best Management Practices (BMPs) are applied to minimize 

erosion and sediment delivery to streams. MacDonald and Stednick (2003) note that fuels treatments 

should have little effect on water quality if they are well-planned and BMPs are implemented. 

Mastication has the potential to disturb or compact soil but has not been widely studied (Robichaud et 

al. 2010). Hatchett et al. (2006) concluded that erosion and compaction on their study area’s coarse 

sandy loam were minimal, but that their findings were probably the result of the equipment being 

operated on masticated material rather than on bare ground. The precipitation simulations in their 

study did not produce runoff on the plots with masticated material for groundcover. Moghaddas and 

Stephens (2007a) found that commercial thinning of a mixed conifer forest followed by mastication 

did not increase compaction of the Holland and Musick series soils in their study area. Based on these 

studies and previous experience with the treatment on the STF, mastication is expected to increase 

soil cover and organic matter and cause slight or minimal decrease in porosity. The treatment leaves 

good groundcover and does not significantly increase erosion, so increases in runoff or erosion are 

not expected to occur. 

Despite the variability in research results, some key points are brought up repeatedly in the literature 

including: 1) Minimize compaction to the extent possible; 2) Minimize soil displacement; 3) Maintain 

or increase ground cover to filter sediment. Management requirements and BMPs were designed to 

accomplish these three tasks. 

Table 3.15-6 Alternative 1: Mechanical Activities by Soil Burn Severity

HUC Level and Name SBS 

HIGH

SBS 

MOD

SBS 

LOW

6. Grapevine Creek-Tuolumne River 0 26 46

6. Jawbone Creek-Tuolumne River 68 96 94

7. Corral Creek 32 46 7

7. Lower Jawbone Creek 0 0 1

6. Lower North Fork Tuolumne River 0 19 20

6. Lower Clavey River 1 47 30

7. Bear Springs Creek 0 3 1

6. Middle Clavey River 0 6 4

6. Reed Creek 11 12 16

7. Lower Reed Creek 11 10 6

6. Lower Cherry Creek 66 135 44

7. Granite Creek 54 76 2

6. Miguel Creek-Eleanor Creek 0 0 2

6. Poopenaut Valley-Tuolumne River 4 4 0

6. Lower Middle Fork Tuolumne River 16 101 43

6. Upper Middle Fork Tuolumne River 0 6 6

6. Lower South Fork Tuolumne River 5 38 37

6. Upper South Fork Tuolumne River 0 1 3

LOW=Low and Unburned; MOD=Moderate; SBS=Soil Burn Severity (percent of Fire area)

From a hydrologic standpoint, increased compaction, increased soil displacement, and changes in 

ground cover are most critical in the near stream areas where stream sedimentation is most likely. 

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Knowledge of soil burn severity in these areas is important because areas of low soil burn severity 

have much greater potential to filter sediment than areas of high soil burn severity. Table 3.15-6 

describes mechanical activities acres (thin/biomass, machine piling, mastication, deep tilling and 

forest cultivation) within 100 feet of perennial or intermittent streams and special aquatic features 

(SAFs) by soil burn severity.

Despite implementation of BMPs and management requirements, increased stream sedimentation is 

anticipated as a result of the proposed action, particularly in areas where mechanical activities create 

more effective sediment transport networks to stream channels. This is more likely to occur in the 

Jawbone Creek-Tuolumne River, Corral Creek, Lower Cherry Creek, and Granite Creek watersheds 

than in other HUC 6 or HUC 7 watersheds due to the larger acreages of near-stream high soil burn 

severity.

Piling and Burning

Jackpot burning and hand piling and burning would result in reduced fuel loading with very little 

ground disturbance. Although some soil movement could occur following these activities, it is 

anticipated to be minor and short term. Pile burning essentially results in small isolated areas of highseverity burn spots located beneath the piles. High-severity impacts include increased runoff and 

erosion (MacDonald et al. 2004). The associated effects on runoff and erosion would be mitigated by 

the small size of the burned patches, the unburned areas between them, and buffers along streams 

where piles will not be burned to ensure a filter strip between these areas and streams (Chapter 2.03). 

A recent study (Hubbert et al. 2013) found that burning piles within 23 feet of streams did not affect 

water quality. Hand cut and pile treatments have not been shown to cause ground disturbance that 

would lead to erosion and sediment delivery. These treatments are considered to have minimal 

potential to impact water quality.

Machine piling could be implemented using either a dozer (dozer piling) or an excavator or other 

similar piece of equipment (grapple piling). Tractors with brush rakes cause more direct soil 

disturbance than the other proposed methods. The possible effects of this treatment include reduced 

soil cover, decreased infiltration capacity, increased runoff, and increased erosion that could result in 

rilling or gullying, especially on steeper slopes or soils that are sensitive to disturbance. Increased 

sediment delivery that exceeds the streams’ capacity to transport it could result in increased 

sedimentation. Water quality could also be affected if equipment leaks fuel or other fluids into a 

stream. The disturbance caused by dozer piling is expected to be greater than that caused by grapple 

piling. That is because the dozer would push the fuels into a pile, whereas an excavator would pick up 

and place fuels into a pile. 

In areas of low soil burn severity, riparian buffers are anticipated to be largely intact and have ground 

cover capable of filtering sediment movement resulting from machine piling. In areas of moderate 

soil burn severity, riparian buffers may be variable. However, ground cover in the form of needle cast 

and resprouting vegetation can help filter runoff caused by machine piling disturbance. In areas of 

high soil burn severity little, if any, ground cover remained after the Rim Fire. However, two years 

post fire these areas have shown a dramatic increase in the amount of vegetation returning to these 

areas (Vegetation Chapter 3.13). This new vegetation can help filter sediment laden runoff resulting 

from the impacts of machine piling. In addition, management requirements state a minimum of 60% 

of well distributed ground cover should be left within 100 feet and to exclude dozer operations within 

50 feet of a perennial streams, intermittent streams or SAF. Although it is anticipated that some 

sediment could reach streams as a result of machine piling, streamside buffers, needle cast, new and 

resprouting vegetation or placed ground cover should minimize this. 

According to Reid (2010), the impacts of mechanical fuel treatments (similar to the site preparation

activities proposed here), on erosion and sediment yield are likely to result from direct soil 

disturbance where these activities affect swales and low-order stream channels. In this project, swales 

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have no riparian buffers since mechanized access is not prohibited. Ephemeral channels have a 15-

foot buffer where equipment is excluded. 

Roads

Forest roads cause hydrological effects by concentrating and channelizing surface and subsurface 

flow. Following wildfire, the ability of the landscape to filter runoff from roads can be reduced due to 

a decrease in ground cover (Peterson 2009). 

In this project area, road work was recently completed under previous projects and the effects are 

reflected in the existing condition of the project area. On road surfaces that are draining well, 

maintenance is important because a lack of road maintenance can result in progressive degradation of 

road-drainage structures and functions (USDA 2013a). This is particularly important with increased 

runoff from hillslopes following fire. In these situations, reconstruction is required to adequately 

improve drainage features and minimize impacts.

Erosion and sedimentation is anticipated along maintained and reconstructed roads. However, 

implementation of BMPs and management requirements are expected to minimize these effects. Road 

reconstruction may actually reduce erosion and sedimentation as this treatment would involve 

improving road drainage features. 

Fuel Loading

Site preparation and thinning existing plantations would reduce the fuel loading in project area 

watersheds. Coarse woody debris would be reduced to about 20 tons per acre. This would result in 

lower flame lengths and fireline intensities, allowing for direct attack of future wildfires. Increased 

erosion following prescribed fire is related to the amount of vegetation removed. Prescribed burns, by 

design, do not consume extensive areas of organic matter (Baker 1990). Therefore, prescribed fires 

have little impact on erosion and sedimentation, whereas intense wildfires may have substantial 

impacts (Brooks et al. 1997). Reducing fuel loading and then maintaining this with prescribed fire has 

less potential for erosion and sedimentation than allowing fuel loading to increase as snags fall and 

having another large stand-replacing wildfire in the future. The Fuels Chapter 3.05 has more 

information on fuel loading. 

Riparian Vegetation

Riparian vegetation may be beneficially affected by the proposed action where thinning of trees in 

riparian areas are prescribed. Increasing sunlight in streamside areas provides an energy input that 

often stimulates regrowth of the riparian plant community. Riparian vegetation is often resilient even 

following wildfires (Ellis 2001, Dwire and Kauffman 2003, Beschta et al. 2004) and resprouting 

riparian vegetation such as willows and sedges is often observed quickly after the fire (note that in the 

Rim Fire, resprouting vegetation was observed in less than two weeks of actively burning at multiple 

riparian zones that burned at high intensity). Though this effect is largely a result of the fire removing 

stream shade cover and moisture competition, removal of tree boles may have a slight incremental 

effect. Another variable affecting riparian plant growth is the short-term increase in streamflow and 

near-stream ground water following a fire as a result of a reduction in plant transpiration due to tree 

mortality.

No fens are within treatment areas and would therefore not be affected. 

Project activities along meadow edges are not expected to affect the 100 acres of meadows identified 

within the proposed action treatment units, as management requirements would be implemented.

This project identified the need to eradicate noxious weeds and invasive non-native pest plants in and 

adjacent to project units. Methods for removing noxious weeds include burning, grazing, grubbing, 

herbicides and hand pulling. Weed infestations near streams could potentially spread by wind, water, 

birds and other animals to new sites downstream. Once population of weeds and pest plants expand 

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into riparian areas their potential to overtake desirable riparian species is high. This can lead to 

impairment of riparian function, increased sediment delivery, reduced quality of aquatic habitat, 

reduced flood control function and reduced function of soil water delivery to streams. 

Stream Condition

Stream Flow

Water yield typically increases in the first year following wildfire due to a reduction in soil water 

storage, interception, and evapotranspiration when vegetation is killed. This change decreases with 

time as vegetation reoccupies a watershed (Peterson et al. 2009). Under Alternative 1, small and 

immeasurable hydrologic changes in canopy throughfall, plant transpiration and uptake processes 

would occur from removing, shredding and burning vegetation. Canopy openings and reduced fuel 

loading are expected to occur in SMZs as allowed under the mechanized equipment constraints of the 

BMP’s in RCAs. The creation of canopy openings in SMZs may favor riparian vegetative species and 

potentially increase available soil moisture, during otherwise high transpiration periods.

Thinning activities will remove forest cover decreasing interception and transpiration and in wetter 

areas, increase annual water yields. The increases in annual water yield are proportional to the amount 

of forest cover removed, but at least 15 to 20% of the trees must be removed to produce a statistically 

detectable effect (MacDonald and Stednick 2003), and this project would remove at least that amount. 

The reduction in forest canopy also increases the amount of solar radiation that reaches the surface of 

the snow pack and the transfer of advective heat. These changes increase the rate of snowmelt and 

may alter the timing of peak runoff (MacDonald and Stednick 2003). 

Planting seedlings would serve to improve the long-term watershed and riparian stability and function 

by enhancing and restoring the species diversity and structural composition of the forest surrounding 

riparian communities. Alternative 1 would restore or improve riparian RCA functions such as surface 

and subsurface filtering mechanisms. Planting trees would also increase live vegetation helping 

restore post-fire natural water storage, another positive watershed effect.

Modeling has indicated that increased surface roughness promotes infiltration and reduces overland 

flows, leading to reduced storm peak events and total flows (Smith et al. 2011). BMPs and 

management requirements under the proposed action would involve maintaining ground cover and 

minimizing compaction. Therefore, measurable changes in stream flow are not anticipated to result 

under the proposed action beyond the changes that already occurred as a result of the fire. 

Stream Morphology

Prior to the Rim Fire, stream surveys throughout the project area indicated that most stream banks 

were stable and that channel form was predominately either normal (no active downcutting or 

evidence of accelerated past incision) or rejuvenating (evidence of legacy disturbance, but channel 

has recovered or is recovering to good condition). 

Increased high peak flows following the Rim Fire have the potential to cause channel incision and 

stream bank erosion, primarily in low-gradient stream reaches with small, mobile substrate. However, 

measureable changes in flow are not anticipated as a result of the proposed action. Therefore, if 

channel incision does occur within the project area, it is likely the result of the fire or from large 

storms, not the proposed action. 

Streambanks that were stable pre-fire may no longer have adequate cover to maintain their stability. 

This is particularly true in areas of high soil burn severity. As discussed above, riparian vegetation is 

resilient following fires and is expected to flourish in the post-fire conditions of increased sunlight 

and water. This would allow for natural recovery of bank stability. The effect of the proposed action 

on streambank stability is expected to be minimal. Mechanized equipment exclusion zones are 

applied to all streams so that equipment is only allowed on streambanks at designated crossing 

locations. Skid trail stream crossings are limited to two per mile on perennial and intermittent streams 

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and three per mile on ephemeral streams. Management requirements to maintain or provide ground 

cover within 100 feet of perennial and intermittent streams would provide for stability while riparian 

vegetation continues recovering. Indirect effects that could occur in the case of increased flow or 

sediment delivery from adjacent hillslopes are also not expected, since hillslope effects would also be 

minimized by the implementation of project management requirements. 

Large Woody Debris

Following wildfire, snags falling into streams may be the main source of wood to streams until trees 

in the post-fire riparian areas are large enough to fall into streams and create habitat (Reeves 2006). 

Large woody debris (LWD) in and across channels typically helps to maintain channel stability, 

decrease flow velocity, trap sediment, and protect banks from erosion. The proposed thinning would 

not remove large existing snags and would primarily harvest smaller diameter trees (very few trees 

over 20 inches dbh exist within these stands). LWD recruitment would not be effected and the 

remaining trees would actually grow faster and become larger sooner. Given the quantity of large 

fire-killed trees that currently exist along streams in the project area, future recruitment is high and 

little potential for modification of its role in any subdrainage is likely. The role of LWD is less 

important in steep bedrock dominated systems such as these, where the wood does not form stable 

jams capable of trapping sediment for long periods of time (Berg et al. 1998). LWD recruitment in 

streams would increase in the long-term following project implementation.

Water Quality

Uses of water for the Tuolumne River from its source to New Don Pedro Reservoir are municipal and 

domestic supply, irrigation, stock watering, power, contact and non-contact recreation, warm and cold 

water freshwater habitat, and wildlife habitat. Existing uses of water for the Merced River from its 

source to McClure Lake are irrigation, power, contact and non-contact recreation, warm and cold 

water freshwater habitat, and wildlife habitat. A potential use for the Merced River is municipal and 

domestic water supply (CVRWQCB 2011). Beneficial uses are maintained when their related water 

quality objectives are met. Water quality objectives that could be affected by the proposed action are 

water temperature, sediment related parameters (sediment, settleable material, suspended material, 

and turbidity), and pesticides. There are no 303(d) listed impaired waterbodies within the project 

analysis area. This indicates that water quality is excellent at this large scale.

Water Temperature

Stream channel shade is highly influential in regulating water temperatures (Rutherford et al. 2004). 

Channel shade was reduced in portions of the project area where near-stream trees were killed by the 

fire. Elevated stream temperatures occur most frequently in mid- to late summer and early fall, when 

stream flows are at their lowest. Channel shading in seasonal channels has little influence on water 

temperature further downstream during these late season periods, because the seasonal streams are 

generally not flowing. Removal of the near-stream dead or live conifer trees on existing plantations is 

anticipated to have very little effect on stream shading. Even in drainages that could have an increase 

in water temperature (Corral Creek and Granite Creek), when the water reaches the Tuolumne River, 

it will mix with cooler water and the effect will be diluted. These small and localized effects would 

not affect beneficial uses in these drainages or downstream. Therefore, warm and cold water 

freshwater habitat would not be affected by the proposed action. In the long-term, planting conifer 

seedlings within riparian corridors would help to restore the shading component that was lost after the 

Rim Fire.

Sediment-Related Parameters

Ground-based treatments in RCAs would cause ground disturbance, due to tractor / heavy equipment 

use, skidding, and development and use of skid trails, and landings. Disturbed ground could result in 

increased erosion (erosion rates above pre-project levels). If project-generated erosion is delivered to 

a stream channel, that sedimentation could result in a water quality impact that would affect 

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beneficial uses. For example, delivery of fine sediments from the project could decrease the quality of 

cold water fish habitat by filling pools and embedding spawning gravels. Some effects to water 

quality could result from ground disturbance associated with mechanical equipment treatments in 

unscoured swales that receive no SMZ buffers. These effects would consist of small, short-term (1-3 

years) increases in sediment delivery to streams, which are not expected to be measurable. The 

project was designed to minimize or avoid these impacts, though management requirements including 

BMPs. Piling and burning of material near stream courses could contribute ash or sediment to 

streams. Ash can change the chemical properties of water if contributed in sufficient quantity. Water 

quality would be protected from potential effects of pile burning by locating burn piles outside of 

SMZs, which reduces the risk of ash from pile burning reaching the channels. 

None of the sediment related beneficial uses of water should be impaired as a result of the proposed 

action. Minor, short-term increases in sediment related parameters are expected but not to the extent 

of adversely affecting beneficial uses. Anticipated sediment increases vary by watershed based on 

amount of project activity and watershed effects of the Rim Fire. None of the streams with special 

designations such as Wild and Scenic Rivers or Heritage Trout Waters are expected to be adversely 

affected. No known impairment of beneficial uses has occurred as a result of other past fire salvage 

harvesting on the STF in settings where the percentage of high soil burn severity was greater than the 

Rim Fire.

Herbicides

The risk of petrochemicals reaching streams would be reduced by implementing BMP 2.11, which 

requires that equipment servicing and refueling activities occur outside of RCAs. Suitable locations 

for such activities would be designated prior to project implementation.

Alternative 1 uses Glyphosate (trade name Accord® or equivalent) for reforestation treatments where 

competing vegetation cannot be effectively controlled by other means. The proposed action also 

includes a combination of hand pulling, digging, grazing, prescribed fire and herbicide applications of 

Glyphosate, Clopyralid, Aminopyralid and Clethodim to target noxious weeds. 

Use of herbicides has the potential to expose areas of bare soil. In addition, manual treatments such as 

weed eating, pulling, and digging up weeds or competing vegetation may occur within buffers where 

herbicides are not allowed.

Potential water quality impacts are assessed based on the probable or reasonably expected 

concentrations that might be encountered in water following herbicide application as well as a worst 

case or spill scenario. Potential herbicide impacts include: 1) Herbicides directly entering water 

bodies by heavy storm runoff; 2) Accidental spill or fugitive drift from spray applications; 3) 

Localized erosion and transport of soil to water bodies due to loss of vegetation cover; and 4) 

Leaching of herbicides through specific soil types. These potential impacts are compared to State 

Water Quality Objectives and Federal Objectives. 

Applicable objectives in the Water Board Basin Plan include:

1. No individual pesticide or combination of pesticides shall be present in concentrations that 

adversely affect beneficial uses.

2. Discharges shall not result in pesticide concentrations in bottom sediments or aquatic life that 

adversely affect beneficial uses.

3. Pesticide concentrations shall not exceed those allowable by applicable anti-degradation policies. 

4. Pesticide concentrations shall not exceed the lowest levels technically and economically 

achievable.

5. Waters designated for domestic or municipal supplies shall not contain concentrations of 

pesticides in excess of the Maximum Contaminant Levels (MCL) set forth in California Code of 

Regulations, Title 22 Division 4 Chapter 15. 

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Where more than one objective may be applicable, the most stringent objective applies (CVRWQCB, 

2011). The most stringent numerical objective is to not exceed Maximum Contaminant Levels 

(MCL). The MCL for glyphosate is 0.7 mg/l or 700 ppb. MCLs have not been set in the California 

Code of Regulations for aminopyralid, clopyralid, and clethodim. The most stringent narrative 

objective is to “not exceed the lowest levels technically and economically achievable.”

The Safe Drinking Water Act requires the EPA to determine safe levels of contaminants in drinking 

water which do or may cause health problems. EPA has set the MCL for glyphosate at 0.7 mg/l or 

700 ppb (EPA 2010). MCLs have not been set for aminopyralid, clopyralid, and clethodim. 

Management requirements, including buffer widths, were developed for herbicide use to protect water 

resources from contamination (Chapter 2.02).

Glyphosate

Glyphosate is a broad-spectrum foliar herbicide. It is proposed for use via a backpack sprayer and a 1-

qt pressurized handheld sprayer. Glyphosate is relatively immobile in most soil environments as a 

result of its strong adsorption to soil particles. It also has low leaching potential. Glyphosate is 

inactivated in soil and water by microbial degradation. Soil studies have determined glyphosate halflives ranging from 3-130 days (Schuette 1998). According to the specimen label, heavy rainfall soon 

after application may wash the product off of the foliage (Dow AgroSciences 2014). 

Glyphosate Risk Assessment

A Human Health and Ecological Risk Assessment (worksheet version 6.00.13) was conducted for 

glyphosate (Human Health and Ecological Risk Report). Glyphosate for site preparation and release 

purposes is proposed in this project on approximately 26,036 acres. A total of approximately 1,739 

acres of chemical treatment areas, or 6.7% of the total acres, are located within 100 feet of a 

perennial, intermittent or SAF. The values range from approximately 0.3 acres in the RCAs of the 

Miguel Creek-Eleanor Creek watershed to a maximum of 444 acres on the Jawbone Creek-Tuolumne 

River watershed. The project also proposed the use of glyphosate for weed eradication purposes on 

about 5,042 acres within the project area. This number is an overestimation since this does not take 

into consideration areas that would be treated with glyphosate for site preparation and release overlap 

with areas of noxious weeds species. A total of approximately 436 acres to be treated with glyphosate 

for weeds, or 9% of the total acres, are located within 100 feet of a perennial, intermittent or SAF. 

The values range from approximately 0.1 acres in the RCAs of the Upper South Fork-Tuolumne 

River to a maximum of 107 acres on the Lower Cherry Creek HUC 6 watersheds. With ground-based 

application and the use of buffers around drainages, these herbicides are not expected to enter surface 

water.

The risk assessment estimates the peak Expected Environmental Concentration (EEC) of glyphosate 

in water. Estimated concentrations range from 0.0065 mg/L to 0.415 mg/L. In addition, the peak EEC 

does not account for the dilution that would occur should the glyphosate reach a flowing stream, 

particularly one the size of, for example, Reed Creek, Clavey River, and the Tuolumne River. 

Therefore, even the lower end of the peak EEC range may overestimate concentrations in water. 

The risk assessment also estimated concentrations in water at distances downwind after direct spray 

or after drift from backpack sprayers. A 10-foot buffer is proposed for the Rim Reforestation project 

when using Glyphosate near perennial waters, ephemeral streams, springs, seeps, or wet areas as well 

as near obligate riparian vegetation. Although a 10-foot distance is not modeled in the risk assessment 

for direct spray or after drift from backpack sprayers, direct spray into streams (0-foot buffer) and a 

25-foot buffer are modeled. The proposed 10-foot buffer would have concentrations within this range. 

Direct spray into a stream was estimated to have a concentration of 457 μg/L of glyphosate and a 25-

foot buffer would have a concentration of 3.8 μg/L of glyphosate. The direct spray does not account 

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for dilution in a stream, and therefore likely is an overestimate. Project management requirements 

limit wind speeds during spraying to 5 miles per hour.

Under both the peak EEC and direct spray or drift scenarios, concentrations of glyphosate in water 

would remain below the 0.7 mg/L MCL. In addition, toxicity values for tolerant cold water fish and 

amphibians would not be exceeded (Human Health and Ecological Risk Report, Worksheet G03). 

This means that even under the case of the accidental spill, glyphosate concentrations in water would 

be so low that no effect to aquatic species would be observed. This finding has been supported by 

monitoring data as described in the Watershed Report. 

The Human Health and Ecological Risk Assessment estimated concentrations of glyphosate in pond 

water from an accidental spill (20 gallons) (worksheet B04b). Under this spill scenario, the 

concentration of glyphosate in water would be 1.14 mg/L. Although under this spill scenario the state 

and federal MCLs of 0.7 mg/L is somewhat exceeded, this is an overestimation because management 

requirements would prohibit the storage of herbicides on RCAs and require that mixing and loading 

be performed as far from water and on ground level as possible and on areas predetermined by the 

Contracting Officer Representative (Management Requirements, Chapter 2). In addition, the amount 

that a single backpack sprayer can handle is from 3 to 5 gallons. This means that even under the case 

of the accidental spill, glyphosate concentrations in water would be so low that no effect to water 

quality and aquatic species would be observed. Management requirements, such as buffer zones, were 

developed to further minimize the risk of and impact from a spill. 

Clopyralid

Clopyralid is a selective (narrow-spectrum) foliar herbicide proposed for use via a backpack sprayer. 

It is effective in killing plants in the sunflower family and some legumes and buckwheat family 

plants. . Clopyralid has a low soil adsorption coefficient and a very high movement rating. The very 

high movement ratings of clopyralid do not necessarily imply delivery to ground or surface waters in 

detectable amounts. The amount applied, the breakdown of the herbicide between application and 

precipitation, and streamside buffers ameliorate the potential for delivery. California’s dry summer 

climate means significant breakdown of the chemicals occurs in the time between spring application 

and fall rains. Persistence of clopyralid in soil is variable with documented half-lives ranging from 10 

days to 10 months depending on soil type and climate. Although clopyralid does not bind readily to 

soil, it dissipates rapidly in some common soil conditions and typically is not expected to leach 

appreciably in non-sandy, low-to-moderate rainfall conditions. According to the specimen label, 

applications of Transline are rainfast within two hours after application (Dow AgroSciences 2011). 

Clopyralid Risk Assessment

A Human Health and Ecological Risk Assessment (worksheet version 6.00.13) was conducted for 

clopyralid (Human Health and Ecological Risk Report). Clopyralid is proposed for noxious weeds 

eradication on 528 acres within the project area. This number is an overestimation since this does not 

take in consideration species overlaps that could be treated in the same area with other herbicides (i.e. 

glyphosate). A total of approximately 66.4 acres of chemical treatment areas, or 13% of the total 

acres, are located within a 100 feet of a perennial, intermittent or SAF. The values range from about 

0.2 acres in the RCAs of the Upper Middle-Tuolumne River watershed to a maximum of 59 acres on 

the Lower Cheery Creek watershed. With ground-based application, the use of buffers around 

drainages and all other applicable BMPs (Chapter 2.02), this herbicide is not expected to enter surface 

water.

The risk assessment estimated the peak expected environmental concentration (EEC) of clopyralid in 

water. Estimated concentrations range from 0.005 mg/L to 0.07 mg/L. In addition, the peak EEC does 

not account for the dilution that would occur should the clopyralid reach a flowing stream, 

particularly one the size of, for example, the Clavey River and the Tuolumne River. Therefore, even 

the lower end of the peak EEC range may overestimate concentrations in water. 

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The risk assessment estimated concentrations in water downwind after direct spray or after drift from 

backpack sprayers by modeling at 0-foot buffer (direct spray into streams) and at 50-foot buffer. 

Under the 50 foot-buffer scenario, as proposed in this project near perennial waters, ephemeral 

streams, springs, seeps, or wet areas that have standing water at the time of application, the estimated 

concentration of clopyralid is 0.121 μg/L in pond water and 0.0989 μg/L in stream water (assuming 

the water was downwind of treatment site). This is a conservative estimate, and actual concentrations 

would be less. Direct spray into water with a 50-foot buffer is highly unlikely as the spray from the 

backpack sprayer would not reach that far. Project management requirements limit wind speeds 

during spraying to 5 miles per hour. In addition, vegetation within the 50-foot buffer would intercept 

drift spray, further reducing the likelihood of clopyralid reaching surface water. 

The State and EPA have not established MCLs for clopyralid with which to compare the risk 

assessment values. However, project management requirements would reduce the risk of clopyralid 

reaching surface water.

The Human Health and Ecological Risk Assessment estimated concentrations of clopyralid in pond 

water under three different volumes of accidental spill ranging from 20 gallons to 200 gallons. Under 

these spill scenarios, concentrations of clopyralid in water would range from 0.056775 mg/L to 

1.1355 mg/L. This exceeds the NOEC for aquatic macrophytes. However, these concentrations are 

higher than what would be expected should an accidental spill occur on the Rim Reforestation 

project. The accidental spill scenario is based off of spill into a pond, and there are no ponds in the 

project area that are near weed treatment sites. The highest risk site is a yellow star-thistle and 

tocalote site near Granite Creek within the Lower Cherry Creek HUC6 watershed. In the case of an 

accidental spill into the river, dilution would greatly reduce the concentrations of clopyralid in water. 

In addition, vegetation within the 50-foot no-spray would intercept the spill. 

Runoff of clopyralid is most likely to occur as a result of heavy rainfall immediately after application. 

The likelihood of this occurring on the Rim Reforestation project is reduced due to the fact that 

application is not allowed when rain is forecast in the next 24 hours. In addition, clopyralid is 

considered rainfast after 2 hours (Dow AgroSciences 2011). Over 100 years of precipitation in 

Sonora, CA indicates that the likelihood of heavy precipitation decreases throughout the spring. 

Average precipitation in April, May, and June is 2.70, 1.24, and 0.30 inches respectively. The 

region’s dry summer climate means that little, if any, precipitation would occur during the summer 

months, allowing for breakdown of clopyralid in the time between spring application and fall rains. 

According to the SERA report, “clopyralid does not bind tightly to soil and thus would seem to have 

a high potential for leaching. While there is little doubt that clopyralid will leach under conditions that 

favor leaching – sandy soil, a sparse microbial population, and high rainfall – the potential for 

leaching or runoff is functionally reduced by the relatively rapid degradation of clopyralid in soil. A 

number of field lysimeter studies and a long-term field study indicate that leaching and subsequent 

contamination of ground water is likely to be minimal. “This conclusion is also consistent with a 

monitoring study of clopyralid in surface water after aerial application” (SERA 2004). BMPs were 

also designed to minimize the risk of leaching. This includes not applying clopyralid when soils are 

saturated and monitoring weather forecasts prior to application. Leaching is therefore unlikely to be a 

factor affecting water quality in this project.

The small amount of acreage proposed for treatment within 100 feet of a stream or SAF as well as the 

implementation of BMPs, including the use of buffers, limits on wind speed during application, and 

monitoring of weather and soil conditions prior to application, would minimize potential 

contamination of water. Therefore, the proposed application of clopyralid meets the State’s narrative 

objective to “not exceed the lowest levels technically and economically achievable” in all instances 

except that of an accidental spill.

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Aminopyralid

Aminopyralid is a new herbicide that has been registered provisionally as a reduced risk pesticide for 

the control of broadleaf weeds. It is proposed for use via a backpack sprayer. Aminopyralid is more 

mobile in soil than glyphosate, leading to a greater risk of this compound being translocated in the 

soil profile and possibly entering groundwater. Aminopyralid is likely to be non-persistent and 

relatively immobile in the soil profile (EPA 2005). Leaching below 6 to 12 inches (15 to 30 cm) is 

minimal (EPA 2005). The use of this chemical in areas where soils are permeable, particularly where 

the water table is shallow, may result in ground water contamination.

Aminopyralid Risk Assessment

A Human Health and Ecological Risk Assessment (worksheet version 6.00.13) was conducted for 

aminopyralid (Human Health and Ecological Risk Report). The Rim Reforestation project is 

proposing the use of aminopyralid for noxious weeds eradication purposes on approximately 458 

acres within the project area. This number is an overestimation since this does not take in 

consideration species overlaps that could be treated in the same area with other herbicides (i.e. 

glyphosate). A total of about 64.8 acres of chemical treatment areas, or 12% of the total acres, are 

located within a 100 feet of a perennial, intermittent, or SAF. The values range from approximately 

3.2 acres in the RCAs of the Lower North Fork-Tuolumne River watershed to a maximum of 37.5 

acres on the Grapevine Creek-Tuolumne River watershed. With ground-based application, the use of 

buffers around drainages and all other applicable BMPs (Management Requirements, Chapter 2), this 

herbicide is not expected to enter surface water.

The risk assessment estimated the peak expected environmental concentration (EEC) of aminopyralid 

in water. Estimated concentrations range from 0.00022 mg/L to 0.066 mg/L. In addition, the peak 

EEC does not account for the dilution that would occur should the aminopyralid reach a flowing 

stream, particularly one the size of, for example, Lower North Fork-Tuolumne River and Lower 

South Fork-Tuolumne River. Therefore, even the lower end of the peak EEC range may overestimate 

concentrations in water. 

The risk assessment estimated concentrations in water downwind after direct spray or after drift from 

backpack sprayers by modeling at 0-foot buffer (direct spray into streams) and at 50-foot buffer. 

Under the 50 foot-buffer scenario, as proposed in this project, the estimated concentration of

aminopyralid is 0.0534 μg/L in pond water and 0.0435 μg/L in stream water (assuming the water was 

downwind of treatment site). This is a conservative estimate, and actual concentrations would be less. 

Direct spray into water with a 50-foot buffer is highly unlikely as the spray from the backpack sprayer 

would not reach that far. Project management requirements limit wind speeds during spraying to 5 

miles per hour. In addition, vegetation within the 50-foot buffer would intercept drift spray, further 

reducing the likelihood of aminopyralid reaching surface water. 

The State and EPA have not established MCLs for aminopyralid with which to compare the risk 

assessment values. However, the modeled concentrations of aminopyralid in water should not affect 

aquatic life.

The Human Health and Ecological Risk Assessment estimated concentrations of aminopyralid in 

pond water under three different volumes of accidental spill ranging from 20 gallons to 200 gallons. 

Under these spill scenarios, concentrations of aminopyralid in water would range from 0.024981 

mg/L to 0.49962 mg/L. These concentrations remain below the NOEC for aquatic macrophytes. 

However, these concentrations are higher than what would be expected should an accidental spill 

occur. The accidental spill scenario is based off of spill into a pond, and there are no ponds in the 

project area that are near weed treatment sites. The highest risk areas are an Italian thistle, star-thistle 

and tocalote site near intermittent tributaries of Grapevine Creek within the Grapevine CreekTuolumne River HUC6 watershed. In the case of an accidental spill into the river, dilution would 

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greatly reduce the concentrations of aminopyralid in water. In addition, vegetation within the 50-foot 

no-spray buffer would intercept the spill. 

Clethodim

Clethodim is a selective postemergence herbicide used for the control of annual or perennial grass 

weeds proposed for use via a backpack sprayer. Clethodim is of low persistence in most soils with a 

reported half-life of approximately 3 days (SERA 2014). Breakdown is mainly by aerobic processes, 

although photolysis may make some contribution. Volatilization loss and hydrolysis are probably not 

important processes in the soil breakdown of clethodim. The main breakdown products in soils under 

aerobic conditions are sulfoxide, sulfone and oxazole sulfone. Clethodim and these degradates are 

weakly bound to soils. Thus, while it may be somewhat mobile in the soil environment, it is very 

short-lived.

Clethodim Risk Assessment 

A Human Health and Ecological Risk Assessment (worksheet version 6.00.13) was conducted for 

clethodim (Human Health and Ecological Risk Report). Clethodim is proposed for noxious weeds 

eradication on 3,002 acres within the project area. A total of 117 acres of chemical treatment areas, or 

4% of the total acres, are located within a 100 feet of a perennial, intermittent, or SAF. The values 

range from 1.4 acres in the RCAs of the Grapevine-Tuolumne River watershed to a maximum of 

1,253 acres in the Jawbone Creek-Tuolumne River watershed. With ground-based application, the use 

of buffers and all other applicable BMPs, this herbicide is not expected to enter surface water.

The risk assessment estimated the peak expected environmental concentration (EEC) of clethodim in 

water. Estimated concentrations range from 0.00000375 mg/L to 0.1325 mg/L. In addition, the peak 

EEC does not account for the dilution that would occur should the clethodim reach a flowing stream, 

particularly one the size of, for example, the Clavey River. Therefore, even the lower end of the peak 

EEC range may overestimate concentrations in water. 

The risk assessment estimated concentrations in water downwind after direct spray or after drift from 

backpack sprayers by modeling at 0-foot buffer (direct spray into streams) and at 50-foot buffer. 

Under the 50 foot-buffer scenario, as proposed in this project near perennial waters, ephemeral 

streams, springs, seeps, or wet areas that have standing water at the time of application, the estimated 

concentration of clethodim is 0.121 μg/L in pond water and 0.0989 μg/L in stream water (assuming 

the water was downwind of treatment site). This is a conservative estimate, and actual concentrations 

would be less. Direct spray into water with a 50-foot buffer is highly unlikely as the spray from the 

backpack sprayer would not reach that far. Project management requirements limit wind speeds 

during spraying to 5 miles per hour. In addition, vegetation within the 50-foot buffer would intercept 

drift spray, further reducing the likelihood of clethodim reaching surface water. 

The State and EPA have not established MCLs for clethodim with which to compare the risk 

assessment values. However, aquatic macrophytes are the most sensitive of all aquatic species 

analyzed. For aquatic macrophytes, data was only available for Lemna gibba on the risk assessment, 

and an NOEC of 0.3 mg/L was used for risk characterization. Because Lemna are monocots, this 

NOEC is presumed to apply to sensitive species of aquatic macrophytes. The risk assessment for 

clethodim estimated hazard quotients for the central and upper values as 1.3 and 4, respectively, 

indicating an elevated toxicological risk to aquatic macrophyte individuals under the accidental acute 

exposure scenario. However, project management requirements, would reduce the risk of clethodim 

reaching surface water.

The Human Health and Ecological Risk Assessment estimated concentrations of clethodim in pond 

water under three different volumes of accidental spill ranging from 20 gallons to 200 gallons. Under 

these spill scenarios, concentrations of clethodim in water would range from 0.056775 mg/L to 

1.1355 mg/L. However, these concentrations are higher than what would be expected should an 

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Draft Environmental Impact Statement and Environmental Consequences

accidental spill occur on the Rim Reforestation project. The accidental spill scenario is based off of 

spill into a pond, and there are no ponds in the project area that are near weed treatment sites. The 

highest risk sites are medusahead sites near the intermittent Bull Meadow Creek and Alder Creek 

streams within the Lower Clavey River and the Jawbone Creek-Tuolumne River HUC6 watersheds, 

respectively. In the case of an accidental spill into the river, dilution would greatly reduce the 

concentrations of clethodim once it gets into the Tuolumne River, if not before. In addition, 

vegetation within the 50-foot no-spray would intercept the spill. 

Clethodim Monitoring Data

There is a general lack of monitoring data on clethodim in surface water and groundwater. This is a 

limitation in the risk assessment and a source of uncertainty. The lack of monitoring data reflects the 

fact that clethodim is a relatively new herbicide. But, based on literature review, there is very little 

risk posed to water quality from this herbicide application in the Rim Reforestation project. In order 

to ensure compliance with the Forest Plan monitoring would be done when herbicide applications 

occur within RCAs and SMZs (USDA 2002). 

Herbicide Surfactants

Syl-tacTM

According to the Syl-tacTM label, the product should not exceed 5% of the finished spray volume. The 

project is proposing to use for Syl-tac (0.4%). Due to the small amount of surfactant being used and 

stream buffers being applied, it is unlikely that the toxicity levels would be exceeded. 

ColorfastTM Purple

ColorfastTM Purple dye is not required to be registered as a pesticide and contains no toxic chemicals 

(USDA 1997). Due to the small amount of dye being used and stream buffers being applied, it is 

unlikely to get in the water.

CUMULATIVE EFFECTS

The process for analyzing cumulative watershed effects (CWE) consists of two steps: 1) An office 

evaluation to determine the risk of cumulative effects using a predictive model and researching 

watershed history and 2) Field evaluation of stream course indicators of cumulative effects.

Step 1, the risk of cumulative effects, is evaluated using the Forest Service equivalent roaded acreage 

(ERA) methodology, adopted by Region 5 as a method of addressing cumulative watershed effects 

(USDA 1990). A description of the ERA methodology can be found in Appendix A: Cumulative 

Watershed Effects Analysis Methodology of the Watershed Report. 

Step 2, field evaluation, is necessary for comparing the modeled ERA prediction with actual and 

expected future field conditions. Project-related water quality parameters and watershed condition are 

evaluated via in-stream and near-stream indicators of condition. This evaluation is essential to help 

interpret cumulative effects of past projects and potential cumulative effects given proposed activities 

and other reasonably foreseeable future activities. Field review was used to verify that the geographic 

and temporal extent of analysis was adequate for evaluation of cumulative watershed effects 

(Connaughton 2005). 

Equivalent Roaded Acres (ERAs)

The CWE ERA analysis was conducted on all lands (public and private) using the activities listed in 

Appendix B within 13 HUC 6 and 5 HUC 7 level watersheds. GIS analysis was used to calculate 

acreages of activities in the watersheds. ERA values for these activities were summed and then were 

compared to a Threshold of Concern (TOC). The TOC range for all HUC 6 and HUC 7 watersheds 

analyzed was 12 to 14%. Table 3.15-7 gives a summary of ERA values by watershed.

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Table 3.15-7 Alternative 1: Annual Percent ERA for HUC 6 and HUC 7 Analysis Watersheds 

HUC Level and Name 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

6. Grapevine Creek-Tuolumne River 2.63 2.46 2.34 2.27 2.24 2.02 1.84 1.63 1.48 1.42

6. Jawbone Creek-Tuolumne River 13.411 12.321 11.38 9.44 7.53 6.62 5.32 4.08 2.87 2.32

7. Corral Creek 22.371 23.031 23.011 19.361 15.271 12.991 10.63 8.27 5.59 4.01

7. Lower Jawbone Creek 10.65 9.35 8.64 7.43 5.83 5.14 4.20 3.52 2.78 1.95

6. Lower North Fork Tuolumne River 3.19 2.94 2.79 2.60 2.36 2.17 1.98 1.79 1.66 1.64

6. Lower Clavey River 8.41 7.92 7.26 6.15 5.52 4.73 3.93 2.97 2.16 1.75

7. Bear Springs Creek 12.091 11.76 10.93 9.76 8.86 8.12 7.48 6.82 6.23 1.62

6. Middle Clavey River 5.29 4.88 5.22 5.47 4.78 4.20 3.63 3.08 2.55 2.15

6. Reed Creek 8.12 7.51 6.90 6.06 5.07 4.52 3.95 3.23 2.56 2.20

7. Lower Reed Creek 14.551 12.951 11.17 8.88 6.99 6.25 5.54 4.35 3.33 2.92

6. Lower Cherry Creek 7.71 6.79 6.09 5.05 4.00 4.05 3.35 2.71 2.08 1.82

7. Granite Creek 18.851 16.451 15.401 12.721 9.66 8.45 6.71 5.30 4.04 3.47

6. Miguel Creek-Eleanor Creek 1.25 1.03 0.80 0.55 0.31 0.29 0.25 0.22 0.18 0.16

6. Poopenaut Valley-Tuolumne River 2.04 1.73 1.40 1.05 0.70 0.63 0.57 0.51 0.46 0.42

6. Lower Middle Fork Tuolumne River 13.231 12.471 11.67 10.68 9.29 7.95 6.72 5.27 4.04 3.05

6. Upper Middle Fork Tuolumne River 1.76 1.38 1.01 0.63 0.25 0.22 0.19 0.16 0.14 0.12

6. Lower South Fork Tuolumne River 8.40 7.84 7.47 6.72 6.13 5.40 4.62 3.84 3.14 2.66

6. Upper South Fork Tuolumne River 1.54 1.35 1.15 0.97 0.81 0.76 0.73 0.69 0.66 0.64

1 Denotes watersheds over the TOC

Previous analyses on the Forest indicate the effects of livestock grazing at the watershed scale are 

very low. Ground disturbance from livestock grazing is essentially a site issue rather than a watershed 

scale issue. This is because the spatial impacts of livestock grazing are much higher in low gradient 

stream channels through meadows than in upland areas, and low gradient stream areas make up an 

extremely small percentage of the watershed acreage in this project. This results in negligible change 

to ERA values. Because of this, cumulative impacts of grazing are described narratively for this 

project.

HUC 6 and 7 Watersheds

Management requirements and BMPs were proposed to maintain or improve current conditions in the 

watersheds. This includes maintenance of a minimum of 60% well distributed ground cover within a 

100 feet of a perennial stream, intermittent stream, or SAF and exclusion zones for ground-based 

equipment. Effectiveness monitoring is done annually on projects throughout the forest at randomly 

selected sites to determine if BMPs were effective. The Water Board requires that additional 

monitoring beyond effectiveness monitoring be conducted on watersheds (both HUC 6 and HUC 7) 

over the TOC with commercial timber related activities. Forensic monitoring inspections are 

conducted during the winter period. These inspections are designed to detect potentially significant 

sources of pollution such as failed management measures or natural sources. The goal of winter 

forensic monitoring is to locate sources of sediment production in a timely manner so that rapid 

corrective action may be taken where feasible and appropriate (CVRWQCB 2005). Under this 

project, the majority of the thinning units within the watersheds over the TOC are located on areas 

that may be inaccessible during the winter. In such situations, forensic monitoring would be 

conducted during spring runoff, as this is the time when erosion is most likely. 

The Rim Recovery EIS project was also required to conduct forensic monitoring on the watersheds 

that exceeded the TOC and would continue doing it until all the activities and waiver conditions have 

been met under that project. Under this project 2 HUC 6 and 4 HUC 7 watersheds exceeded the TOC. 

These watersheds are the same watersheds that exceeded the TOC under Rim Recovery with the 

exception of the Lower Jawbone Creek HUC7 watershed that remained under TOC under this project. 

All of the rest of the analysis watersheds under this project were well below the TOC (see Table 3.15-

7). 

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A project specific monitoring plan will be developed to ensure compliance with the State Water 

Board timber waiver and the Region 5 Forest Service Water Quality Management Handbook. 

Stream condition in the project area watersheds was evaluated to identify indications of past or 

present cumulative effects, and the potential for adverse impacts from future cumulative effects. The 

evaluation of stream condition included pre-fire stream surveys in most watersheds following the 

StreamScape Inventory (SSI) Protocol, which included observations of streambed sediment, 

streambank stability, and attributes of stream morphology (Frazier et al. 2008). 

All watersheds which exceeded the TOC are discussed in detail below.

Jawbone Creek-Tuolumne River (HUC 6) and Corral Creek (HUC 7)

ERA Summary

Under Alternative 1, the ERA in the Jawbone Creek-Tuolumne River watershed would increase from 

its current 13.24% (no action) to 13.41%, its maximum ERA, in the first year of implementation, 

2016. The ERA falls back below the TOC by 2018 and by 2025 is down to 2.32%. The previous 

activities in the watershed, which have an ERA value of 10.64% in 2016, are large contributors to the 

high ERA values. These activities include the fire itself, fire suppression, timber harvest on private 

and NFS lands before the fire and salvage activities on private and NFS lands after the fire. 

The ERA in the Corral Creek HUC 7 watershed would increase from its current 22.04% (no action) to 

22.37% in the first year of implementation, 2016. This would further increase in 2017, with a 

maximum ERA of 23.03%. The ERA falls back below the TOC by 2022 and by 2025 is down to 

4.01%. The ERA is over the 12 to 14% threshold of concern for this watershed. This is due mainly to 

the previous activities in the watershed, which have an ERA value of 17.26%. Land management 

activities in the watershed include salvage activities post fire (Rim HT and Rim Recovery projects) 

and private salvage activities. However, the main reason the previous ERA was so high was because 

89% of the watershed burned at high or moderate soil burn severity. 

Stream Condition Summary

Pre-fire stream surveys in the Jawbone Creek-Tuolumne River watershed were conducted in Drew 

Creek and Corral Creek. Surveys indicated that the condition of Drew Creek was good overall (i.e., 

stable banks, normal channel morphology, and low pool bed sediment). The RCA surrounding Drew 

Creek burned at low severity, so stream condition post-fire is likely the same as pre-fire. Very little 

treatment is proposed under Alternative 1 in the southern part of the Jawbone Creek-Tuolumne River 

watershed near Drew Creek, so stream condition is anticipated to remain good. 

Pre-fire stream surveys in Corral Creek, on the other hand, showed much of the channel to be 

rejuvenating from past disturbance. Pre-fire bank stability was moderate, and was substantially 

reduced by the fire. This stream is still sensitive to further disturbance. Due to this sensitivity, 

additional management requirements were put in place for Corral Creek. A large equipment exclusion 

zone prohibits mechanized equipment between Corral Creek and its near-stream roads. Ground cover 

will be maintained or provided along its banks to minimize erosion and increase stability. This is in 

addition to 700 acres of straw mulch that was applied to the watershed as part of BAER treatments. 

Despite these treatments, Corral Creek is one of the areas which have the greatest potential for stream 

sedimentation following treatment.

The proposed action is anticipated to result in increased sedimentation in the Jawbone CreekTuolumne River watershed, particularly in the Corral Creek HUC 7 watershed. However, 

management requirements and BMPs are anticipated to minimize these effects to the extent feasible. 

Monitoring is anticipated to identify any problem areas so that corrective action could be taken 

quickly. Due to these measures, the proposed action is not anticipated to result in adverse off-site 

cumulative effects to sediment-related water quality parameters or to watershed condition (i.e. 

degradation of stream channel morphology, accelerated erosion or loss of soil productivity). 

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Bear Springs Creek (HUC 7)

ERA Summary

The ERA in the Bear Springs Creek HUC 7 watershed would increase from its current 11.79% (no 

action) to 12.09% in the first year of implementation, 2016. This is the maximum ERA. The ERA 

falls back below the TOC the following year 2017 and by 2025 is down to 1.62%. The ERA is 

slightly over the 12 to 14% threshold of concern for this watershed. This is due mainly to the previous 

activities in the watershed, which have an ERA value of 9.89%. These previous activities include the 

fire itself, in which 50% of the watershed burned at moderate or high soil burn severity, as well as 

salvage activities on NFS land and timber activities (both green tree sales and salvage) on private 

lands.

Stream Condition Summary

Pre-fire stream surveys were not conducted in the Bear Springs Creek HUC 7 watershed. However, 

the acreage of high soil burn severity in this watershed was low (7%). Only 2% high soil burn 

severity occurred within 100 feet of streams, meaning that most of the high soil burn severity was on 

the hillslopes. In the Bear Springs Creek watershed, mechanical activities are not proposed in a high 

soil burn severity area within 100 feet of a perennial stream, intermittent stream, or SAF, but are 

proposed on only 3 acres within moderate soil burn severity. Due to low acreage of treatment 

proposed within moderate soil burn severity and zero acreage within the highest risk area, the creation 

of effective sediment transport networks to stream channels are not expected. Due to implementation 

of management requirements and BMPs, as well as monitoring to identify problem areas, the 

proposed action is not anticipated to result in adverse off-site cumulative effects to sediment-related 

water quality parameters or to watershed condition (i.e. degradation of stream channel morphology, 

accelerated erosion or loss of soil productivity). 

Lower Reed Creek (HUC 7)

ERA Summary

The ERA in the Lower Reed Creek HUC 7 watershed would increase from its current 14.46% (no 

action) to a maximum 14.55% in the first year of implementation, 2016. The ERA falls back below 

the TOC by 2018 and by 2025 goes down to 2.92%. The ERA is over the 12 to 14% threshold of 

concern for this watershed. This is due mainly to the previous activities in the watershed, which have 

an ERA value of 11.71% in 2016. These previous activities include the fire itself, in which 62% of the 

watershed burned at moderate or high soil burn severity, as well as timber activities (both green tree 

sales and salvage) on private and NFS lands. 

Stream Condition Summary

Reed Creek and Niagara Creek are the main channels in the Lower Reed Creek watershed. Reed 

Creek had high bank stability pre-fire and had 99% of its length in a normal channel form. Niagara 

Creek had more evidence of past instability, with sections of low bank stability (6% of surveyed 

length) and almost half its length incised, incised and widened, or rejuvenating. Despite this, both 

streams had low pool bed and pool tail sediment. 

In the Lower Reed Creek watershed, 11 acres of mechanical activities are proposed in high soil burn 

severity areas within 100 feet of a perennial stream, intermittent stream, or SAF. Reed Creek is 

bedrock controlled and highly erosion resistant, so changes in stream channel form are unlikely. 

Niagara Creek is more sensitive to disturbance, as its dominant substrate is gravel which is much 

more easily mobilized in high flows. Management requirements and BMPs were designed to address 

this sensitivity. This includes equipment exclusion zones and ground cover requirements. In addition, 

about 1,900 acres of straw mulch was applied to this watershed as part of BAER treatments. Despite 

these treatments, the Lower Reed Creek HUC 7 watershed is one of the areas which have the greatest 

potential for stream sedimentation following treatment.

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The proposed action is anticipated to result in a slightly increased sedimentation in the Lower Reed 

Creek watershed. However, management requirements and BMPs are anticipated to minimize these 

effects to the extent feasible. Monitoring is anticipated to identify any problem areas so that 

corrective action could be taken quickly. Due to these measures, the proposed action is not anticipated 

to result in adverse off-site cumulative effects to sediment-related water quality parameters or to 

watershed condition (i.e. degradation of stream channel morphology, accelerated erosion or loss of 

soil productivity). 

Granite Creek (HUC 7)

ERA Summary

The ERA in the Granite Creek HUC 7 watershed would stay on its current 18.85% (no action) to the 

maximum 18.85% in the first year of implementation, 2016. The ERA falls back below the TOC by 

2020 and by 2025 is down to 3.47%. The ERA is over the 12 to 14% threshold of concern for this 

watershed. This is due primarily to the previous activities in the watershed, which have an ERA value 

of 15.42% in 2016. These previous activities include the fire itself, in which 92% of the watershed 

burned at moderate or high soil burn severity, as well as timber activities (both green tree sales and 

salvage) on private and NFS lands. 

Stream Condition Summary

No pre-fire SSI data was collected for the Granite Creek watershed. In this watershed, 54 acres of 

mechanical activities are proposed in high soil burn severity area within 100 feet of a perennial 

stream, intermittent stream, or SAF. The granitic soil prevalent in this watershed is highly erodible. 

About 30% of the watershed burned at high soil burn severity, and an additional 62% burned at 

moderate soil burn severity. Because of this sensitivity, about 750 acres of straw mulch was applied 

to the Granite Creek watershed as part of BAER treatments. 

The proposed action is anticipated to result in increased sedimentation in the Granite Creek 

watershed. This watershed experienced the greatest burn severity of any of the HUC 7 watersheds. 

However, management requirements and BMPs are anticipated to minimize these effects to the extent 

feasible. Monitoring is anticipated to identify any problem areas so that corrective action could be 

taken quickly. Due to these measures, the proposed action is not anticipated to result in adverse offsite cumulative effects to sediment-related water quality parameters or to watershed condition (i.e. 

degradation of stream channel morphology, accelerated erosion or loss of soil productivity). 

Lower Middle Fork Tuolumne River (HUC 6)

ERA Summary

The ERA in the Lower Middle Fork Tuolumne River watershed would increase from its current 

12.57% (no action) to the maximum 13.23% in the first year of implementation, 2016. The ERA falls 

back below the TOC by 2018 and by 2025 is down to 3.05%. The ERA is over the 12 to 14% 

threshold of concern for this watershed. This is due mainly to the previous activities in the watershed, 

which have an ERA value of 9.53% in 2016. These previous activities include the fire itself, of which 

63% of the watershed burned at moderate or high soil burn severity, as well as timber activities on 

private and NFS lands. 

Stream Condition Summary

Nearly 10 miles of pre-fire stream survey data was collected on the main channel of the Middle Fork 

Tuolumne River. Bank stability was very high and channel form was normal for its entire length, 

indicating no evidence of past channel incision. Pool tail and pool bed fine sediment was also low. In 

this watershed, 16 acres of mechanical activities are proposed in high soil burn severity area within 

100 feet of a perennial stream, intermittent stream, or SAF. Part of this watershed was burned 

previously in the Pilot Fire, and good pre-Rim Fire condition indicates that impacts of past wildfire 

have not affected stream channel stability. The areas of high soil burn severity in the Lower Middle 

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Fork Tuolumne River watershed were relatively small patches well distributed throughout the 

watershed. The spatial mosaic of severity classes can reduce on and off site soil and water effects by 

interrupting erosion pathways and reducing sediment delivery to streams.

The proposed action is anticipated to result in increased sedimentation in the Lower Middle Fork 

Tuolumne River watershed. However, management requirements and BMPs are anticipated to 

minimize these effects to the extent feasible. Monitoring is anticipated to identify any problem areas 

so that corrective action could be taken quickly. Due to these measures, the proposed action is not 

anticipated to result in adverse off-site cumulative effects to sediment-related water quality 

parameters or to watershed condition (i.e. degradation of stream channel morphology, accelerated 

erosion or loss of soil productivity). 

Grazing

Active grazing allotments are located in all of the analysis HUC 6 and HUC 7 watersheds except 

Miguel Creek-Eleanor Creek. Grazing on these allotments has the potential to slow recovery of 

riparian vegetation and increase ground disturbance, particularly along streambanks. However, Forest 

Plan Standards and Guidelines require the prevention of disturbance from livestock from exceeding 

20% of stream reach or 20% of natural lake and pond shorelines. It also limits browse to no more than 

20% of the annual leader growth on mature riparian shrubs and no more than 20% of individual 

seedlings. In this project area the browse limit would apply to streamside areas where riparian 

obligate trees and shrubs are naturally resprouting and reseeding after the fire. Although continuing of 

grazing is anticipated to result in ground disturbance and a reduction in riparian vegetation, these 

effects are anticipated to be localized and adherence to Standards and Guidelines should allow for 

riparian vegetation recovery to progress naturally. 

Alternative 2 (No Action)

DIRECT AND INDIRECT EFFECTS

Under the no action alternative, current management plans would continue to guide management of 

the project area and all conditions would remain the same as those shown in the Affected 

Environment. Hydrologic and erosional responses to the fire would continue to occur. No 

reforestation, deer habitat enhancement or noxious weed eradication would be implemented to 

accomplish the purpose and need of the Rim Reforestation Project.

Large areas of the fire where all or most of the conifers were killed would be left to recover naturally, 

which could take many decades.

Alternative 2 does not serve to improve the long-term watershed and riparian stability and function by 

enhancing and restoring the species diversity and structural composition of the forest surrounding 

riparian communities and adjacent hillslopes. Alternative 2 does not help restore or improve RCAs 

and adjacent hillslopes functions as a filtering or shading mechanism.

Erosion and Sedimentation

Soil Compaction

Under the Alternative 2, no additional soil compaction would occur. However, activities under the 

action alternatives designed to reduce soil compaction would also not occur. Field review and LiDAR 

imagery indicates an extensive skid trail network within the project area. Many of these pre-existing 

skid trails were not properly decommissioned in the past and thus are concentrating runoff and 

causing erosion and sedimentation. Under the action alternatives, existing skid trails would be re-used 

to the extent practicable, and then subsoiled and waterbarred, reducing compaction and the risk of 

erosion and sedimentation. This would not occur under Alternative 2. 

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Draft Environmental Impact Statement and Environmental Consequences

Soil Displacement

Soil displacement would not be increased by proposed activities under Alternative 2.

Ground Cover

Erosion resulting from the winter of 2015/16 will be a small increment over that from the Rim Fire 

following the winter of 2013/14. Post-fire observations on past fires on the STF show that the most 

substantial amount of erosion usually occurs during the first winter after the fire. The erosion rates 

will continue decreasing as a result of additional needle cast and growth of live cover. Over time, 

trees falling would increase ground cover in many areas. Live vegetative recovery would increase 

over time under the no action alternative. This recovery is anticipated to be faster than under the 

action alternatives because disturbance by heavy equipment would not occur. Groundcover would 

recover the most slowly in High SBS areas, with erosion the most likely in these areas.

Mechanized Equipment Activities

Thinning and mechanical site preparation activities as proposed in the action alternatives have the 

potential to create more sediment transport networks to stream channels. These transport networks 

would not be created under Alternative 2. However, existing sediment transport networks would also 

not be mitigated by subsoiling under Alternative 2, as they would be under the action alternatives.

Piling and Burning

No piling and burning would occur under Alternative 2, so there is no risk of further erosion and 

sedimentation from these activities. 

Roads

Forest roads cause hydrological effects by concentrating and channelizing surface and subsurface 

flow. Following wildfire, the ability of the landscape to filter runoff from roads can be reduced due to 

a decrease in ground cover (Peterson 2009). Any existing issues would continue to occur under 

Alternative 2.

The increased overland flow rates and sediment yields associated with road reconstruction and 

maintenance would not occur under Alternative 2. In addition, no roads would be improved through 

these activities, allowing existing problems to persist.

Fuel Loading

The no action alternative would allow for fuel loading to increase in the project area. Nearly all snags 

would be expected to fall by 20 years post-fire. The limbs and boles from these fallen trees would 

accumulate as surface fuels. This fuel is expected to increase each decade as trees fall over.

Increased erosion following fire is related to the amount of vegetation removed. Prescribed fires, by 

design, do not consume extensive areas of organic matter (Baker 1990). Therefore, they have little 

impact on erosion and sedimentation, whereas intense wildfires may have substantial impacts (Brooks 

et al. 1997). Higher fuel loadings, projected to occur under Alternative 2, would not be maintained 

with prescribed fire. A future reburn under higher fuel loadings would likely lead to soil erosion and 

sedimentation more severely than that caused by the reduction of fuel loading during site preparation 

activities under the action alternatives and maintaining these reduced loadings in the future by 

utilizing prescribed fire.

Riparian Vegetation

Under Alternative 2, riparian vegetation would not be disturbed. However, the thinning of trees in

riparian areas would increase sunlight to these species, and this would not occur under Alternative 2. 

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Stream Condition

Stream Flow

Under Alternative 2, there would be no measurable changes in stream flow. Soil compaction from 

management activities, which can reduce infiltration and increase runoff to streams, would not occur. 

However, activities under the action alternatives designed to reduce soil compaction would not occur 

either. There would be no hydrologic changes in canopy throughfall, plant transpiration and uptake 

processes from removing, shredding and burning vegetation. 

Stream Morphology

No changes in stream morphology are anticipated. Bank stability would increase over time as live 

vegetation continued to recover.

Large Woody Debris

Levels of large woody debris (LWD) in streams would be high under Alternative 2 as existing snags 

and dying trees would be retained and over time many near-stream snags would fall into streams. The 

effect of this high level of LWD on stream condition is uncertain. In streams with low levels of LWD 

this extra loading may be beneficial in storing stream sediment. In streams with high levels of LWD, 

this extra loading may be excessive. Larger rivers should be capable of transporting these high loads 

of LWD to downstream reservoirs. 

Water Quality

Water Temperature

Under Alternative 2, thinning would not occur allowing stream shading to increase, maintaining cool 

water temperatures over time.

Sediment-Related Parameters

Ground disturbance from mechanized equipment that could lead to stream sedimentation would not 

occur under Alternative 2. However, activities that could reduce stream sedimentation, such as 

mastication and subsoiling of existing skid trails, would not occur. 

Chemicals

Herbicides would not be used under Alternative 2. 

Summary

Beneficial uses of water would continue to be met.

CUMULATIVE EFFECTS

Equivalent Roaded Acres (ERAs)

Table 3.15-8 shows ERAs calculated for 13 HUC 6 and 5 HUC 7 watersheds.

HUC 6 and 7 Watersheds

ERAs exceed the threshold of concern in 2 HUC 6 and 3 HUC 7 watersheds under the no action 

alternative. These high values can be attributed to the fire itself as well as past and future 

management activities on private and NFS lands. 

Grazing

Same as Alternative 1.

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Draft Environmental Impact Statement and Environmental Consequences

Table 3.15-8 Alternative 2: Annual Percent ERA for HUC 6 and HUC 7 Analysis Watershed

HUC Level and Name 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

6. Grapevine Creek-Tuolumne River 2.63 2.46 2.27 2.07 1.88 1.73 1.59 1.44 1.30 1.28

6. Jawbone Creek-Tuolumne River 13.241 11.51 9.84 7.97 6.21 5.11 4.02 2.93 2.02 1.67

7. Corral Creek 22.041 19.621 17.031 13.731 10.42 8.59 6.78 4.97 3.16 2.29

7. Lower Jawbone Creek 10.65 9.18 8.11 6.79 5.47 4.66 3.87 3.08 2.50 1.83

6. Lower North Fork Tuolumne River 3.19 2.94 2.71 2.48 2.27 2.10 1.93 1.75 1.62 1.61

6. Lower Clavey River 8.29 7.48 6.61 5.58 4.60 3.81 3.03 2.29 1.58 1.24

7. Bear Springs Creek 11.79 11.06 10.19 9.13 8.19 7.56 6.93 6.41 5.93 1.39

6. Middle Clavey River 5.29 4.87 5.19 5.40 4.73 4.15 3.58 3.03 2.50 2.11

6. Reed Creek 8.09 7.34 6.65 5.87 4.84 4.16 3.49 2.82 2.25 1.89

7. Lower Reed Creek 14.461 12.381 10.36 8.26 6.25 5.21 4.18 3.15 2.45 2.05

6. Lower Cherry Creek 7.71 6.70 5.66 4.59 3.54 2.98 2.42 1.87 1.41 1.26

7. Granite Creek 18.851 15.911 13.021 10.17 7.44 6.14 4.83 3.52 2.67 2.48

6. Miguel Creek-Eleanor Creek 1.25 1.03 0.80 0.55 0.31 0.28 0.24 0.20 0.17 0.15

6. Poopenaut Valley-Tuolumne River 1.92 1.62 1.29 0.96 0.62 0.56 0.51 0.47 0.43 0.41

6. Lower Middle Fork Tuolumne River 12.571 11.54 10.32 8.81 7.36 6.23 5.11 4.02 2.99 2.32

6. Upper Middle Fork Tuolumne River 1.73 1.35 0.98 0.59 0.21 0.19 0.17 0.15 0.13 0.11

6. Lower South Fork Tuolumne River 8.37 7.78 7.23 6.26 5.37 4.68 3.99 3.31 2.65 2.21

6. Upper South Fork Tuolumne River 1.53 1.33 1.13 0.93 0.74 0.71 0.68 0.64 0.62 0.60

Alternative 3

Alternative 3 would not include use of herbicides. Instead, site preparation, treatment of noxious 

weeds and release of planted seedlings would be accomplished using manual treatments or heavy 

equipment. 

DIRECT AND INDIRECT EFFECTS

Erosion and Sedimentation

Direct and indirect effects from all of the treatments described in Alternative 1 would be the same for 

Alternative 3, with the differences described below. 

The effects described for the use of glyphosate, aminopyralid, clopyralid, and clethodim do not apply 

to Alternative 3. 

Additional mechanical site preparation would increase ground disturbance and the risk of erosion and 

sediment delivery to streams slightly; however, because these activities would comply with all 

specified management requirements including BMPs, any additional impacts are expected to be 

minimal. Additional hand release would have no effects on watershed resources due to the localized 

and minor disturbance that results from this treatment. Overall effects of the array of mechanical 

treatments would be the same as described under Alternative 1.

Treating noxious weeds with mechanical methods would produce different effects than the use of 

herbicides. As part of the Integrated Pest Management Approach (IPM), 1,127 and 1,173 acres of 

prescribed fire would treat medusahead grass and other weed species on the Jawbone CreekTuolumne River and Lower Clavey River watersheds, respectively. Prescribed fire would also require 

fire line construction. The burn would be followed by targeted grazing or additional grubbing. The 

management requirements developed for these actions would minimize effects. While tilling has a 

greater risk of causing erosion than other mechanical treatments; however, assuming that BMPs and 

other management requirements are implemented, potential impacts to water quality would be minor 

and localized to the adjacent stream reach.

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Mechanized Equipment Activities

Table 3.15-9 shows mechanical activities acres (thin/biomass, machine piling, mastication, deep 

tilling and forest cultivation) within 100 feet of perennial or intermittent streams and SAFs by soil 

burn severity.

Table 3.15-9 Alternative 3: Mechanical Activities by Soil Burn Severity

HUC Level and Name SBS 

HIGH

SBS 

MOD

SBS 

LOW

6. Grapevine Creek-Tuolumne River 0 26 46

6. Jawbone Creek-Tuolumne River 69 125 99

7. Corral Creek 33 47 7

7. Lower Jawbone Creek 1 27 3

6. Lower North Fork Tuolumne River 0 19 20

6. Lower Clavey River 3 59 34

7. Bear Springs Creek 3 12 5

6. Middle Clavey River 0 11 11

6. Reed Creek 13 20 16

7. Lower Reed Creek 13 18 6

6. Lower Cherry Creek 70 148 45

7. Granite Creek 56 84 3

6. Miguel Creek-Eleanor Creek 0 0 2

6. Poopenaut Valley-Tuolumne River 4 4 0

6. Lower Middle Fork Tuolumne River 26 143 53

6. Upper Middle Fork Tuolumne River 0 6 6

6. Lower South Fork Tuolumne River 5 48 48

6. Upper South Fork Tuolumne River 0 0 3

LOW=Low and Unburned; MOD=Moderate; SBS=Soil Burn Severity (percent of Fire area)

Despite implementation of BMPs and management requirements, increased stream sedimentation is 

anticipated as a result of Alternative 3, particularly in areas where mechanical activities create more 

effective sediment transport networks to stream channels. This is more likely to occur in the Jawbone 

Creek-Tuolumne River, Corral Creek, Lower Cherry Creek, and Granite Creek watersheds than in 

other HUC 6 or HUC 7 watersheds due to the larger acreages of high soil burn severity areas near 

streams proposed for treatment. Under these 4 watersheds and this Alternative 3, mechanical 

activities acres on high soil burn severity would increment slightly when compared with Alternative 

1. Jawbone Creek-Tuolumne River goes from 68 to 69 acres, Corral Creek from 32 to 33 acres, 

Lower Cherry Creek from 66 to 70 acres, and Granite Creek from 54 to 56 acres. 

CUMULATIVE EFFECTS

Equivalent Roaded Acres (ERAs)

ERAs were calculated for 13 HUC 6 and 5 HUC 7 watersheds. Results of these analyses vary from 

that found under Alternative 1 since increases in mechanical treatment would create higher ERAs. 

Table 3.15-10 shows the ERA values for Alternative 3.

HUC 6 and 7 Watersheds

ERA values for 7 of the 13 HUC 6 watersheds were equal or slightly higher for Alternative 3 than 

Alternative 1. These are Grapevine Creek-Tuolumne River, Lower North Fork-Tuolumne River, 

Middle Clavey River, Miguel Creek-Eleanor Creek, Poopenaut Valley-Tuolumne River, Upper 

Middle Fork-Tuolumne River and Upper South Fork-Tuolumne River watersheds. Of those 7 

watersheds, Grapevine Creek-Tuolumne River would have the higher increase with up to 0.17% in 

2023 for Alternative 3. Eleven HUC 6 and HUC 7 watersheds had higher ERA values than 

Alternative 1. The largest increase would occur in 2021 with up to 4.61 in the Corral Creek watershed 

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Draft Environmental Impact Statement and Environmental Consequences

under Alternative 3. ERA increases were attributed primarily to the additional deep tilling and forest 

cultivation and manual grubbing treatments added under this Alternative 3. 

Although there are differences in ERA values between Alternative 1 and Alternative 3, the 

watersheds that exceeded the TOC were the same. Therefore, cumulative effects for Alternative 3 are 

anticipated to be the same as described for Alternative 1.

Table 3.15-10 Alternative 3: Annual Percent ERA for HUC 6 and HUC 7 Analysis Watershed

HUC Level and Name 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

6. Grapevine Creek-Tuolumne River 2.63 2.46 2.34 2.27 2.24 2.12 1.99 1.80 1.64 1.59

6. Jawbone Creek-Tuolumne River 13.411 12.521 12.431 10.92 9.40 8.49 7.29 5.32 3.48 2.69

7. Corral Creek 22.371 23.251 25.021 22.871 19.811 17.601 15.211 10.45 5.93 4.02

7. Lower Jawbone Creek 10.65 9.96 11.30 10.63 9.52 8.65 7.71 5.55 3.68 2.55

6. Lower North Fork Tuolumne River 3.19 2.94 2.79 2.60 2.36 2.19 2.02 1.84 1.71 1.69

6. Lower Clavey River 8.46 8.17 7.67 6.79 6.20 5.68 4.84 3.91 3.04 2.48

7. Bear Springs Creek 12.231 12.371 11.86 10.99 10.08 9.44 8.36 7.41 6.69 1.95

6. Middle Clavey River 5.29 4.95 5.30 5.56 4.90 4.32 3.75 3.20 2.71 2.31

6. Reed Creek 8.12 7.75 7.25 6.48 5.46 5.06 4.34 3.54 3.00 2.63

7. Lower Reed Creek 14.551 13.741 12.331 10.24 8.26 8.00 6.79 5.36 4.64 4.15

6. Lower Cherry Creek 7.71 6.92 6.37 5.43 4.50 4.66 4.19 3.35 2.57 2.25

7. Granite Creek 18.851 17.201 16.991 14.931 12.491 11.20 9.58 6.51 4.11 3.37

6. Miguel Creek-Eleanor Creek 1.25 1.03 0.80 0.55 0.31 0.34 0.30 0.27 0.23 0.21

6. Poopenaut Valley-Tuolumne River 2.04 1.77 1.49 1.16 0.81 0.74 0.62 0.52 0.46 0.43

6. Lower Middle Fork Tuolumne River 13.781 13.571 13.741 13.481 12.401 11.57 9.60 7.63 5.59 4.02

6. Upper Middle Fork Tuolumne River 1.76 1.40 1.03 0.66 0.28 0.26 0.22 0.18 0.15 0.14

6. Lower South Fork Tuolumne River 8.47 8.04 7.84 7.28 7.22 6.98 6.14 5.29 4.69 3.75

6. Upper South Fork Tuolumne River 1.54 1.35 1.15 0.98 0.82 0.78 0.75 0.72 0.69 0.66

1 Denotes watersheds over the TOC

Grazing

Same as Alternative 1.

Alternative 4

Under Alternative 4, considerably fewer planted acres and trees are proposed in comparison with 

Alternative 1. Alternative 4 would reforest no more than 20% of each unit proposed in Alternative 1. 

Site preparation treatments would be the same as in Alternative 1, but on only 2,867 acres. 

Alternative 4 includes similar noxious weed eradication as Alternative 3 on 3,350 acres. 

DIRECT AND INDIRECT EFFECTS

The direct and indirect effects of Alternative 4 are the same as those for Alternative 1 with the 

exception of those described below. 

Erosion and Sedimentation

Ground disturbance from mechanized equipment would be reduced dramatically under Alternative 4 

due to the reduction of treated areas in comparison to Alternative 1. Thousands of acres would not 

have initial mechanical site preparation treatments which would result in increased fuel loading. 

Alternative 4 proposes the reintroduction of early and frequent use of prescribed fire within the 

stands. Increased erosion following fire is related to the amount of vegetation removed. Prescribed 

burns, by design, do not consume extensive areas of organic matter (Baker 1990). Therefore, 

prescribed fires would have little impact on erosion and sedimentation, whereas intense wildfires may 

have substantial impacts (Brooks et al. 1997). Reducing fuel loading through site preparation and 

thinning followed by maintenance with prescribed fire has less potential for erosion and 

sedimentation than allowing fuel loading to increase as snags fall and having another large stand333
Chapter 3.15 Stanislaus

Watershed National Forest

replacing wildfire in the future. Although BMPs are expected to protect stream channels and water 

quality from treatment actions, there would be less overall impact with fewer treated acres.

The effects described for the use of aminopyralid, clopyralid, and clethodim for noxious weed 

eradication do not apply to Alternative 4. Instead the effects of manual noxious weed eradication are 

the same as Alternative 3.

The effects of glyphosate for site preparation and release of planted seedlings on 2,867 acres are 

similar to those described under Alternative 1, but on fewer acres. 

Mechanized Equipment Activities

Table 3.15-11 describes mechanical activity acres (feller buncher and mastication) within 100 feet of 

perennial or intermittent streams and special aquatic features (SAFs) by soil burn severity. No 

machine pilling treatments falls within the 100 feet buffer of any hydrological feature. Under 

Alternative 4, no deep tilling and forest cultivation is proposed for site preparation purposes on any of 

the units. The potential to create more effective sediment trasnport networks to stream channels is 

reduced dramatically under Alternative 4. Table 3.15-11 shows that almost all of the watersheds have 

zero mechanical treatment acres within the high soil burn severity areas with the exception of the 

Lower Cherry Creek and Granite Creek watersheds having 6 and 2 acres respectively. This is a 

reduction of mechanical activities on 91% and 96%, respectively, of these two watersheds’ acres 

when compared to Alternative 1. 

Table 3.15-11 Alternative 4: Mechanical Activities by Soil Burn Severity

HUC Level and Name SBS 

HIGH

SBS 

MOD

SBS 

LOW

6. Grapevine Creek-Tuolumne River 0 13 44

6. Jawbone Creek-Tuolumne River 0 16 82

7. Corral Creek 0 0 1

7. Lower Jawbone Creek 0 0 1

6. Lower North Fork Tuolumne River 0 8 12

6. Lower Clavey River 0 16 29

7. Bear Springs Creek 0 0 1

6. Middle Clavey River 0 6 4

6. Reed Creek 0 9 11

7. Lower Reed Creek 0 7 6

6. Lower Cherry Creek 6 59 39

7. Granite Creek 2 22 2

6. Miguel Creek-Eleanor Creek 0 0 0

6. Poopenaut Valley-Tuolumne River 0 0 0

6. Lower Middle Fork Tuolumne River 0 5 10

6. Upper Middle Fork Tuolumne River 0 0 0

6. Lower South Fork Tuolumne River 0 7 14

6. Upper South Fork Tuolumne River 0 0 3

LOW=Low and Unburned; MOD=Moderate; SBS=Soil Burn Severity (percent of Fire area)

CUMULATIVE EFFECTS

Equivalent Roaded Acres (ERAs)

ERAs were calculated for 13 HUC 6 and 5 HUC 7 watersheds. Table 3.15-12 shows the ERA values 

for Alternative 4.

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Draft Environmental Impact Statement and Environmental Consequences

Table 3.15-12 Alternative 4: Annual Percent ERA for HUC 6 and HUC 7 Analysis Watershed

HUC Level and Name 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

6. Grapevine Creek-Tuolumne River 2.63 2.46 2.34 2.27 2.20 1.95 1.76 1.58 1.42 1.38

6. Jawbone Creek-Tuolumne River 13.251 11.57 10.02 8.12 6.40 5.53 4.40 3.26 2.28 1.88

7. Corral Creek 22.051 19.901 17.741 14.291 10.89 9.07 7.37 5.45 3.48 2.59

7. Lower Jawbone Creek 10.66 9.21 8.18 6.87 5.51 4.75 3.92 3.16 2.55 1.84

6. Lower North Fork Tuolumne River 3.19 2.94 2.79 2.60 2.35 2.15 1.96 1.78 1.65 1.63

6. Lower Clavey River 8.30 7.70 7.10 6.11 5.35 4.41 3.61 2.85 2.08 1.63

7. Bear Springs Creek 11.84 11.20 10.41 9.35 8.46 7.77 7.14 6.60 6.09 1.51

6. Middle Clavey River 5.29 4.87 5.21 5.46 4.78 4.20 3.62 3.06 2.53 2.13

6. Reed Creek 8.09 7.34 6.67 5.89 4.87 4.28 3.60 2.92 2.33 1.95

7. Lower Reed Creek 14.461 12.391 10.41 8.32 6.32 5.48 4.43 3.38 2.62 2.18

6. Lower Cherry Creek 7.71 6.71 5.67 4.60 3.62 3.47 2.82 2.21 1.69 1.50

7. Granite Creek 18.881 15.951 13.081 10.24 7.59 6.48 5.07 3.76 2.86 2.62

6. Miguel Creek-Eleanor Creek 1.25 1.03 0.80 0.55 0.31 0.28 0.24 0.21 0.17 0.15

6. Poopenaut Valley-Tuolumne River 1.92 1.62 1.30 0.96 0.63 0.57 0.52 0.47 0.43 0.41

6. Lower Middle Fork Tuolumne River 12.581 11.60 10.42 8.92 7.66 6.43 5.32 4.17 3.09 2.39

6. Upper Middle Fork Tuolumne River 1.73 1.35 0.98 0.60 0.23 0.20 0.17 0.15 0.13 0.11

6. Lower South Fork Tuolumne River 8.39 7.81 7.28 6.36 5.59 4.88 4.16 3.46 2.75 2.28

6. Upper South Fork Tuolumne River 1.53 1.33 1.13 0.96 0.79 0.74 0.71 0.67 0.64 0.62

HUC 6 and 7 Watersheds

ERA values for 6 of the 13 HUC 6 watersheds were equal or slightly lower for Alternative 4 than 

Alternative 1. These are Grapevine Creek-Tuolumne River, Lower North Fork-Tuolumne River, 

Middle Clavey River, Miguel Creek-Eleanor Creek, Upper Middle Fork-Tuolumne River, and Upper 

South Fork-Tuolumne River watersheds. The remaining 12 HUC 6 and HUC 7 watersheds had lower 

ERA values than Alternative 1. The largest decrease would occur in 2018 with up to a 5.27% 

decrease in ERA in the Corral Creek watershed under Alternative 4. ERA decreases were attributed 

primarily due to the large reduction of treated areas under Alternative 4. The contribution on ERAs 

under Alternative 4 is very small ranging from 0 to 0.75%. Less disturbance is beneficial to 

watersheds. However, the post-fire response would still dominate at all scales (project area, HUC 7, 

and HUC 6). 

Although there are differences in ERA values between Alternative 1 and Alternative 4, the 

watersheds that exceeded the TOC were the same with the exception of Bear Springs Creek that fell 

back below TOC in year 2016. Therefore, cumulative effects for Alternative 4 are anticipated to be 

slightly less than Alternative 1 and Alternative 3.

Grazing

Same as Alternative 1.

Alternative 5

Alternative 5 is the same as Alternative 1 except for the deletion of prescribed fire in new plantations 

and it includes thinning at age 7 to create the desired ICO and fuel structure. This PCT would be 

accomplished using hand cutting, piling and burning treatments or lop and scatter if fuels are not an 

issue.

DIRECT AND INDIRECT EFFECTS

Same as Alternative 1.

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CUMULATIVE EFFECTS

Equivalent Roaded Acres (ERAs)

ERAs were calculated for 13 HUC 6 and 5 HUC 7 watersheds. Results of these analyses were similar 

to that found under Alternative 1. Table 3.15-13 shows the ERA values for Alternative 5. 

Table 3.15-13 Alternative 5: Annual Percent ERA for HUC 6 and HUC 7 Analysis Watershed

HUC Level and Name 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

6. Grapevine Creek-Tuolumne River 2.63 2.46 2.34 2.27 2.24 2.02 1.84 1.63 1.48 1.42

6. Jawbone Creek-Tuolumne River 13.411 12.321 11.38 9.44 7.53 6.62 5.32 4.08 2.87 2.36

7. Corral Creek 22.371 23.031 23.011 19.361 15.271 12.991 10.63 8.27 5.61 4.19

7. Lower Jawbone Creek 10.65 9.35 8.64 7.43 5.83 5.14 4.20 3.52 2.78 1.96

6. Lower North Fork Tuolumne River 3.19 2.94 2.79 2.60 2.36 2.17 1.98 1.79 1.66 1.64

6. Lower Clavey River 8.41 7.92 7.26 6.15 5.52 4.73 3.93 2.97 2.17 1.79

7. Bear Springs Creek 12.091 11.76 10.93 9.76 8.86 8.12 7.48 6.82 6.25 1.72

6. Middle Clavey River 5.29 4.88 5.22 5.47 4.78 4.20 3.63 3.08 2.55 2.16

6. Reed Creek 8.12 7.51 6.90 6.06 5.07 4.52 3.95 3.23 2.56 2.26

7. Lower Reed Creek 14.551 12.951 11.17 8.88 6.99 6.25 5.54 4.35 3.33 3.12

6. Lower Cherry Creek 7.71 6.79 6.09 5.05 4.00 4.05 3.35 2.71 2.08 1.82

7. Granite Creek 18.851 16.451 15.401 12.721 9.66 8.45 6.71 5.30 4.04 3.48

6. Miguel Creek-Eleanor Creek 1.25 1.03 0.80 0.55 0.31 0.29 0.25 0.22 0.18 0.16

6. Poopenaut Valley-Tuolumne River 2.04 1.73 1.40 1.05 0.70 0.63 0.57 0.51 0.46 0.43

6. Lower Middle Fork Tuolumne River 13.231 12.471 11.67 10.68 9.29 7.95 6.72 5.27 4.08 3.17

6. Upper Middle Fork Tuolumne River 1.76 1.38 1.01 0.63 0.25 0.22 0.19 0.16 0.14 0.12

6. Lower South Fork Tuolumne River 8.40 7.84 7.47 6.72 6.13 5.40 4.62 3.84 3.14 2.69

6. Upper South Fork Tuolumne River 1.54 1.35 1.15 0.97 0.81 0.76 0.73 0.69 0.66 0.64

1 Denotes watersheds over the TOC

Grazing

Same as Alternative 1.

Summary of Effects Analysis across All Alternatives

Beneficial Uses of Water

All alternatives are expected to result in maintenance of the applicable beneficial uses of water in the 

Water Quality Control Plan (Basin Plan) for the California Central Valley Water Quality Control 

Board (CVRWQCB 2011). Water temperature, sediment, and water quality following herbicide use 

are not expected to be adversely altered. Domestic and municipal water supplies and power are not 

adversely affected by the proposed action or alternatives. Recreational contact and non-contact waters 

are suitable for human use. Warm and cold freshwater habitat and wildlife habitat are not adversely 

affected by the proposed action or alternatives.

Erosion and Sedimentation

Under Alternatives 1, 3, and 5 sedimentation increases, due to mechanical activities, are anticipated to 

be highest in 2 HUC 6 and 2 HUC 7 watersheds with treatments proposed within 100 feet of streams 

in high soil burn severity areas (Jawbone Creek-Tuolumne River, Corral Creek, Lower Cherry Creek, 

and Granite Creek). Of the piling and burning activities, dozer piling has the highest potential for 

sedimentation and could occur in any of the treatment units. Under this project, the management 

requirement is to maintain a minimum of 60% well distributed ground cover within the 100 feet and 

to exclude dozer operations within 50 feet of a perennial stream, intermittent stream, or SAF. 

Although it is anticipated that some sediment could reach streams as a result of machine piling, 

streamside buffers, needle cast and/or resprouting vegetation should minimize this. Although minimal 

road work is proposed (just associated with thinning of the existing plantations), some erosion and 

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sedimentation is anticipated along maintained and reconstructed roads. Implementation of BMPs and 

management requirements are expected to minimize these effects. Road reconstruction and 

maintenance may reduce erosion and sedimentation that is currently occurring as these treatments 

would involve improving road drainage features. 

Under Alternative 2, new sediment transport networks would not be created. However, reductions in 

soil compaction on existing skid trails would also not occur. With no piling and burning, no risk of 

erosion and sedimentation would occur. Road reconstruction and maintenance would not occur, so 

hydrologic connectivity of roads and streams currently occurring would remain. 

Under Alternative 4, ground disturbance from mechanized equipment would be reduced dramatically 

in comparison to Alternative 1, due to the reduction of treated areas and no deep tilling and forest 

cultivation for site preparation. No machine piling treatment falls within the 100 feet buffer of any 

hydrological feature. Effective sediment trasnport networks to stream channels is reduced 

dramatically under Alternative 4. 

In summary, the Rim Fire Reforestation project will not cause significant impacts to Forest soil and 

water resources. In the short-term project work would involve negligible and very localized soil 

disturbance due to planting and the release of young conifers. In the long-term (decades) the project 

would accelerate a return to conifer forest, stabilizing soils and improving water quality.

Fuel Loading

Alternatives 1, 3 and 5 site preparation activities would reduce fuel loading to 20 tons per acre of 

surface fuels, allowing for direct attack of future wildfires and maintenance of reduced fuel loading 

with prescribed fire. 

Under Alternative 4, thousands of acres proposed in Alternative 1 would not have initial mechanical 

site preparation which could result in a higher risk of increased fuel loading through time. Alternative 

4 proposes the reintroduction of early and frequent use of prescribed fire within the stands. Reducing 

fuel loading through site preparation and thinning followed by maintenance with prescribed fire has 

less potential for erosion and sedimentation than allowing fuel loading to increase as snags fall and 

having another large stand-replacing wildfire in the future.

Under Alternative 2, fuel loading is expected to increase over time. This would not allow for direct 

attack of wildfires or use of prescribed fire. A future reburn under higher fuel loadings would likely 

lead to soil erosion and sedimentation more severely than that caused by the reduction of fuel loading 

during site preparation activities under the action alternatives and maintaining these reduced loadings 

in the future by utilizing prescribed fire.

Riparian Vegetation

Under Alternatives 1, 3, 4 and 5, thinning of trees in riparian areas (where prescribed) may provide 

slight increases in sunlight, benefitting regrowth of riparian obligate trees and shrubs. Management 

requirements would prevent disturbance to riparian vegetation and the numerous meadows. 

Under Alternative 2, no thinning of trees would occur, so no beneficial increase in sunlight would 

occur. There would be no disturbance to riparian vegetation. 

Stream Condition

Under the action alternatives, measurable changes in stream flow or channel incision are not 

anticipated. BMPs and management requirements under all alternatives would involve maintaining 

ground cover and minimizing compaction. Therefore, measurable changes in stream flow are not 

anticipated to change beyond what already occurred as a result of the fire.

Under Alternative 2, no changes in stream flow or channel incision are anticipated. The erosion rates 

will continue decreasing as a result of additional needle cast and growth of live cover. Over time, 

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trees falling would increase ground cover in many areas. Live vegetative recovery would increase 

over time under the no action alternative. This recovery is anticipated to be faster than under the 

action alternatives because disturbance by heavy equipment would not occur. Groundcover would 

recover the most slowly in High SBS areas, with erosion the most likely in these areas. The burned 

riparian areas would be left to recover naturally. Alternative 2 does not serve to improve the longterm watershed and riparian stability and function by enhancing and restoring the species diversity 

and structural composition of the forest surrounding riparian communities. Alternative 2 does not 

serve to restore or improve riparian RCA functions as a filtering or shading mechanism. 

Water Quality

Under the action alternatives, water temperature is not expected to be affected. Under Alternatives 1, 

3 and 5, some sedimentation would likely occur, particularly in areas having high soil burn severity 

adjacent to streams. That sedimentation potential would be reduced dramatically under Alternative 4. 

The potential for herbicides to contaminate surface water under Alternatives 1, 4 and 5 is limited. 

Adverse effects to beneficial uses of water are not anticipated.

Under Alternative 2, no changes to water temperature, stream sedimentation or water quality related 

to herbicide applications are anticipated. Adverse effects to beneficial uses are not anticipated.

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3.16 WILDLIFE

Analysis Framework: Statute, Regulation, Forest Plan and Other Direction

The Endangered Species Act of 1973 (16 USC 1531 et seq.) requires that any action authorized by a 

federal agency not be likely to jeopardize the continued existence of a TE species, or result in the 

destruction or adverse modification of habitat of such species that is determined to be critical. Section 

7 of the ESA, as amended, requires the responsible federal agency to consult the United States Fish 

and Wildlife Service (USFWS) and the National Marine Fisheries Service concerning TE species 

under their jurisdiction. It is Forest Service policy to analyze impacts to TE species to ensure 

management activities are not be likely to jeopardize the continued existence of a TE species, or 

result in the destruction or adverse modification of habitat of such species that is determined to be 

critical. This assessment is documented in a Biological Assessment (BA) and is summarized and 

referenced in this Chapter.

USDA Departmental Regulation 9500-004 provides the following direction to USDA agencies. 

Regional Forester Sensitive Species

1. Assure that the values of fish and wildlife are recognized, and that their habitats, both terrestrial 

and aquatic, including wetlands, are recognized and enhanced where possible as the Department 

carries out its overall missions.

2. Consider fish and wildlife and their habitats in developing programs for these lands. Alternatives 

that maintain or enhance fish and wildlife habitat should be promoted. When compatible with 

objectives for the area, management alternatives that improve habitat will be selected.

3. Balance the competing uses for habitat supporting fish and wildlife through strong, clear policies, 

relevant programs, and effective actions to sustain and enhance fish and wildlife in desired 

locations and numbers. 

4. Recognize that fish and wildlife have inherent values as components and indicators of healthy 

ecosystems, and that they often demonstrate how altered environments may affect changes in 

quality of life for humans.

5. Avoid actions “which may cause a species to become threatened or endangered”.

Threatened, Endangered, Candidate and Proposed Species

1. Conduct activities and programs “to assist in the identification and recovery of threatened and 

endangered plant and animal species.”

2. Avoid actions “which may cause a species to become threatened or endangered.”

3. Consult “as necessary with the Departments of the Interior and/or Commerce on activities that 

may affect threatened and endangered species.” 

4. Not “approve, fund or take any action that is likely to jeopardize the continued existence of 

threatened and endangered species or destroy any habitat necessary for their conservation unless 

exemption is granted pursuant to subsection 7(h) of the Endangered Species Act of 1973, as 

amended.” 

Threatened and Endangered species are those Federally listed by the USFWS; Candidate species are 

candidates to become Proposed species but issuance of a proposed rule is currently precluded by 

higher priority listing actions (USFWS 1998). Sensitive species are those designated by the Regional 

Forester with the goal of proactively developing and implementing management practices to ensure 

that those species do not become Threatened or Endangered, and therefore require protection under 

the Endangered Species Act because of Forest Service actions (Departmental Regulation 9500-004). 

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The Forest Plan Compliance (project record) document identifies the Forest Plan Standards and 

Guidelines that specifically apply to this project and related information about compliance with the

Forest Plan. 

Other species of particular conservation concern were also identified during the planning process for 

this project, mule deer and black-backed woodpeckers, and they are also analyzed in this document. 

Table 3.16-1 shows the wildlife species considered for this project. The Wildlife BE provides the 

rationale for why a species is not addressed in this Chapter.

Table 3.16-1 Endangered, Threatened, Candidate, Sensitive and Species of Conservation Concern

Common Name Scientific Name Type Status1

Valley Elderberry Longhorn Beetle Desmocerus californicus dimorphus Invertebrate T

Bald Eagle Haliaeetus leucocephalus Bird S

California Spotted Owl Strix occidentalis occidentalis Bird S, MIS

Great Gray Owl Strix nebulosa Bird S

Northern Goshawk Accipiter gentilis Bird S

Willow Flycatcher2 Empidonax traillii Bird S

Pacific Marten Martes caurina Mammal S, MIS

Fisher Pekania pennant (formerly Martes pennanti pacifica) Mammal S, P (T)

California Wolverine2 Gulo gulo luteus Mammal S

Sierra Nevada Red Fox2 Vulpes vulpes necator Mammal S

Fringed Myotis Myotis thysanodes Mammal S

Pallid Bat Antrozous pallidus Mammal S

Townsend's Big-Eared Bat Corynorhinus townsendii Mammal S

Western Bumble Bee Bombus occidentalis Invertebrate S

Black-Backed Woodpecker Picoides arcticus Bird MIS, SCC

Mule Deer Odocoileus hemionus Mammal MIS, SCC

1 T=Threatened, C=Candidate, S=Sensitive, SCC=Species of Conservation Concern, MIS=Management Indicator Species. 2.Species not analyzed in detail.

Effects Analysis Methodology

Assumptions Specific to Wildlife

While some of these assumptions may be debatable, the comparison of alternatives using these 

assumptions is valid because the same assumptions are applied to all alternatives.

 All standards and guidelines, standard operating procedures, project design features, management 

requirements and mitigations would be fully adhered to and implemented. 

 Implementation of project activities would generally occur in the following timeframes: fuels 

treatments (initial site preparation), reforestation and release treatments and prescribed burning 

2017 to 2029. 

 For the snag retention management requirement in Old Forest Emphasis Area (OFEA) and Home 

Range Core Area (HRCA) units, the intent is to retain legacy structure where it exists for longterm resource recovery needs (i.e. the development of future old forest habitat with higher than 

average levels of large conifer snags and down woody material). Retention of all hardwood snags 

outside Strategic Fire Management Areas and up to six hardwood snags inside Strategic Fire 

Management Areas greater than or equal to 12 inches dbh. This requirement applies to all action 

Alternatives.

 Unit boundaries were developed using GIS data at various scales. The level of inaccuracy of a 

line on a map at most scales used was approximately 20 feet. When utilizing these data on the 

ground, some variation in unit boundaries may occur. The scope of these variations was 

considered in the effects analysis.

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 Suitable habitat acres were generated using ArcGIS and several data sources. At the scale of this

analysis, up to 257,000 acres, rounding errors are likely to cause slight variation in acres when 

presented under different species sections. These slight variations are considered minimal and 

have no measureable effect on the accuracy of this analysis.

 All mechanical treatment methods and equipment used for project activities, as described in the 

EIS, would have similar impacts to wildlife resources.

Data Sources

 California Wildlife Habitat Relationships (CWHR).

 California Natural Diversity Database (CNDDB).

 Natural Resource Information System (NRIS Wildlife).

 Black-backed woodpecker occupancy model by Tingley et al. (2014a). 

 GIS layers including: RAVG database, Worldview Imagery, Stanislaus vegetation database, land 

allocations, project unit boundaries and road treatments.

 Project survey reports and incidental detection records.

 Scientific literature, internal and draft reports.

Wildlife Indicators

Wildlife Indicators vary by species and are stated under the environmental consequences for each 

species.

Wildlife Methodology by Action

PROJECT ACTION AREA

Unless otherwise specified, the analysis area used to analyze the direct and indirect effects on wildlife 

and wildlife habitat is about 155,000 acres and includes Stanislaus NFS lands within the Rim Fire 

perimeter. The analysis area is based on; 1) Acres burned in a distinct geographic area and 

administrative setting that influences the purpose and need of proposed activities; 2) Area of impact 

to forest vegetation from the wildfire and subsequent proposed project activities; 3) Furthest 

measurable extent of changes to disturbance levels and habitat modification that would occur as a 

result of implementing any of the proposed alternatives; and 4) Consistency with the analysis area 

described in the Rim Fire Reforestation EIS reports for fire and fuels, soils and vegetation because 

ecologically, the dynamics among these elements are inherently linked with terrestrial wildlife 

habitat. This analysis is bounded in time for short-term effects (up to 20 years) and long-term effects 

(up to 80 years). Eighty years was chosen for the long-term analysis because that is when the 

modeling shows forested habitat reaching moderate to high capability for the majority of species 

considered in this report. This timeframe is used to serve for relative analysis comparisons between 

the alternatives.

CUMULATIVE EFFECTS

According to CEQ NEPA regulations, “cumulative impact” is the impact on the environment which 

results from the incremental impact of the action when added to other past, present, and reasonably 

foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes 

such actions (40 CFR 1508.7). 

The analysis area used to analyze the cumulative effects on wildlife and wildlife habitat is about 

257,000 acres and includes all lands within the Rim Fire perimeter. The analysis area is based on: 1) 

Treatments are proposed in and would modify burned areas within the Rim Fire area only; 2) This 

area provides an appropriate context for the reasonable determination of effects to species considered 

and their habitat; and 3) Relevant cumulative effects, particularly other projects that have or will treat 

areas within the fire perimeter, can be effectively and meaningfully addressed. This analysis is 

bounded in time for short-term effects (up to 20 years) and long-term effects (up to 80 years). This

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analysis relies on current environmental conditions as a proxy for the impacts of past actions. Existing 

conditions reflect the aggregate impact of all prior human actions and natural events that affected the 

environment and might contribute to cumulative effects. All activities listed and described in 

Appendix B are not expected to affect all species considered in this document. See individual species 

analysis sections for further discussion of relevant present and reasonably foreseeable future actions.

Terrestrial Wildlife: Herbicide Risk Assessment (toxicological effects)

Under Alternatives 1 and 5, an Integrated Pest Management (IPM) approach is proposed for weed 

eradication, which includes the use of herbicides. Herbicide use is also proposed in reforestation units 

for site preparation and release. Under Alternative 4, herbicides are proposed for reforestation areas 

only, not weed eradication. See Chapter 2.02 for additional details. This analysis covers the worst 

case scenario, or application of herbicides on the maximum number of acres. While spraying every 

acre is unlikely and would vary across the project area depending on vegetation composition and 

response, this analysis will inform the reader of the maximum effects possible to terrestrial wildlife. 

Under Alternatives 1 and 5, four herbicides are proposed for use to control noxious weeds and reduce 

competing vegetation for newly planted conifers. Most treatment areas for weeds and conifer planting 

overlap, thus acres may be double counted in some instances. The herbicides proposed for use under 

Alternatives 1 and 5 are glyphosate, clopyralid, clethodim and aminopyralid. The herbicide proposed 

for use under Alternative 4 is glyphosate. Herbicides would be applied using low pressure backpack 

sprayers with a psi of about 15. 

Reforestation

Under Alternatives 1 and 5, up to about 25,000 acres would be sprayed with glyphosate for either site 

preparation or release treatments (Chapter 2.02). It is important to note that not every part of any 

given acre would actually be sprayed. Several management requirements and topographical 

constraints would reduce the amount of acres sprayed including; oak buffers, sensitive plant and 

cultural sites, retention of up to 20% vegetation on an acre before spraying would be triggered and 

inoperable areas. Treatments would be spread across the project area, with different units being 

treated over multiple years. The treatments would be phased in; meaning only a portion of the total 

acreage would be treated any given year. See Appendices N an R for the noxious weed and 

reforestation implementation schedules and associated acres. The maximum number of herbicide 

treatments would be three if deep tilling is used for site preparation and four if deep tilling is not used. 

The first year of spraying is considered the worst case scenario as subsequent years would likely 

require less intensive treatment based on the first year’s application results. 

Under Alternative 4, up to about 4,130 acres would be sprayed with glyphosate for either site 

preparation or release treatments (Chapter 2.02). Treatments would be spread across the project area, 

with different units being treated over a few years. See Appendix R for the implementation schedule 

and associated acres.

Noxious Weeds

The chemicals proposed for noxious weed treatments are glyphosate, chlopyralid, aminopyralid and 

clethodim. Treatments would be conducted over multiple years, see Appendix N for the 

implementation schedule and associated acres. The first year of treatments is considered the worst 

case scenario and follow up treatments are expected to be less intensive as infestations are reduced. 

The majority of the noxious weed treatments are within reforestation units. Under Alternative 4, no 

herbicides are proposed for noxious weed treatments.

Risk assessments were completed for all herbicides proposed for use in this project. The SERA risk 

assessments (SERA 2004, 2011, 2014) and associated worksheets are hereby incorporated by 

reference and provide more detailed discussion, assumptions and validation of this risk assessment. 

Risk assessments can be used to determine the ecological risk to individuals exposed to 

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concentrations of chemicals in the open environment, aquatically or terrestrially. Exposure risk is, in 

part, determined by comparing estimates of expected environmental concentrations (EEC) derived 

from modeled outputs to toxicity values established for the species or a surrogate for the species of 

concern. These EECs for acute and chronic scenarios are then compared to available toxicity data for 

terrestrial species, producing a hazard quotient (HQ, HQ = EEC/toxicity). These models consider 

typical (center), low and high values for exposure and the resulting hazard quotient. The smaller the 

HQ, the lower the risk is to individuals. Conversely, as the HQ approaches or exceeds equity (i.e., a 

value of one (1)), there is a greater risk that there could be a toxicological effect to an individual. For 

acute and chronic exposures, the Forest Service has adopted a toxicity threshold of NOAEL (the no 

observable adverse effect level). NOAEL values are based on longer-term studies of organisms 

exposed to low concentrations of chemicals that are used to determine whether physiological or 

generational effects exist.

Chemical Descriptions

GLYPHOSATE

Glyphosate is a broad-spectrum foliar herbicide and could be used on several noxious weeds and 

competing vegetation types effectively. Glyphosate is relatively immobile in most soil environments 

as a result of its strong adsorption to soil particles with a low leaching potential. Glyphosate on 

vegetation has a half-life estimated at 10 days. Glyphosate is rapidly metabolized by an animal’s 

kidneys and excreted in waste products (SERA 2011). It is not known to bioaccumulate in animal fat 

or other body tissues; therefore, the risk to predators, such as fisher or spotted owls, of consuming 

herbivores is very low.

CLOPYRALID

Clopyralid is a selective herbicide used primarily in the control of broadleaf weeds, mainly thistles. It 

is most effectively used as a post emergent because it is rapidly absorbed across leaf surfaces. It does 

not bind tightly with soil and there is risk of leaching. However, this potential risk is reduced by the 

relatively rapid degradation of clopyralid in soil. The half- life of clopyralid on vegetation is about 8 

days and in soil about 10 to 19 days (SERA 2004). Toxicity has been relatively well characterized in 

experimental animals, and some additional studies on birds, bees, spiders and earthworms generally 

support the characterization of clopyralid as relatively non-toxic. No adverse effects are anticipated or 

even considered plausible in terrestrial animals from the use of clopyralid at the typical application 

rate of 0.35 lb a.e. per acre (Ibid). It is important to note that the typical application rate is 0.10 lb ae. 

per acre higher than is proposed in this project.

AMINOPYRALID

Aminopyralid is a selective herbicide used primarily in the control of broadleaf weeds, mainly thistles 

SERA 2004). Very little information is available regarding aminopyralid in open literature because it 

is a new herbicide. It is in the same class of herbicides as and on some occasions used as an 

alternative for clopyralid. It is most often applied to the vegetation as a post emergent. Aminopyralid 

on vegetation has a half-life estimated at 10 to 16 days and in soil an estimated half-life of 25-35 days 

(Ibid). There is no indication that mammals, birds, or terrestrial invertebrates would be adversely 

affected by aminopyralid (Ibid). 

CLETHODIM

Clethodim is a selective postemergence herbicide used for the control of annual or perennial grass 

weeds, such as medusahead and barbed goatgrass (SERA 2014). Risks to mammals can be well 

characterized, but it is more difficult to characterize risks to other groups of terrestrial animals 

because of limitations in the available data on birds and terrestrial insects (Ibid). Serious effects to 

mammals do not seem likely and the potential for direct effects to birds associated with acute 

exposures appears to be low. Limitations with the risk assessment on clethodim involves the small 

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number of species on which toxicity data are available relative to the large number of species that 

may be exposed. This limitation is exacerbated by the lack of field studies relevant to the assessment 

of the effects of clethodim applications on most groups of non-target species.

Based on acute toxicity, US EPA/OPP classify clethodim as practically non-toxic to mammals, birds 

and honeybees. Field studies to investigate the impact of clethodim on mammalian wildlife were not 

found in the literature; however, body weight loss or decreased body weight gain is the most 

consistent effect observed in experimental mammals exposed to clethodim in acute, sub chronic and 

chronic studies (Ibid). In one reproductive study in quail, clethodim did not have an impact on the 

body weights of adults or offspring. Based on the LC50 of >100 μg/bee (Lethal Concentration when 

50% of the test population is killed) for technical grade clethodim, US EPA/OPP/EFED classifies 

clethodim as practically nontoxic to honeybees and is considered a functional NOAEL (Ibid). 

Surrogate Species

Toxicological effects studies of herbicide use on wild animals are almost non-existent. Specifically, 

TES species are not tested directly, thus the need for surrogate species to represent others for 

herbicide risk assessments and the application of chemicals. It is important to note a surrogate species 

may not accurately represent the species of concern, thus caution should be applied to the results of 

ecological risk assessments and the use of surrogate species. A large number of tests have been 

conducted using more readily available animals exposed to chemicals using standardized methods, 

which serve as surrogate species. Some surrogate species included in the risk assessment scenarios 

include honey bees, goats, rats, rabbits and bobwhite quail. 

Types of Exposure

Herbicides have the potential to directly and indirectly affect terrestrial wildlife species and habitats 

through exposure and contamination resulting from direct spraying of an individual, ingestion of 

contaminated media (e.g., vegetation, prey species or water), grooming activities or indirect contact 

with contaminated vegetation (SERA 2004, 2011, 2014). Direct and indirect effects to individuals in 

either aquatic or terrestrial habitats are dependent upon the toxicity of the chemicals being used, the 

exposure levels to which the individuals are likely to be subjected and the likelihood that an 

individual would be exposed to the chemicals. Further, to fully evaluate the risk and potential effects, 

the dose and exposure information (toxicity and EEC values, respectively) must be related to the life 

history characteristics of the animal to estimate the likelihood that an animal would be exposed to the 

chemicals.

Complete exposure assessments, toxicity values, toxicological thresholds and hazard quotients for all 

chemicals proposed in this project are available in the project record and are hereby incorporated by 

reference. Summary tables for scenarios considered in this assessment are provided for easy 

reference.

For this assessment, the following species are considered: bald eagle, black-backed woodpecker, 

California spotted owl, great gray owl, fringed myotis, pallid bat, Townsend’s big-eared bat, fisher, 

marten, mule deer and western bumblebee. Because we would employ a 100 foot buffer with no 

herbicide application around any elderberry shrub, no toxicological effects to VELB or elderberry 

shrubs from herbicide application are expected; therefore, no further analysis is warranted. 

Scenarios

The following species life histories, existing habitat conditions, and likely types of exposure were 

used to choose appropriate scenarios considered in this analysis for glyphosate, clopyralid, 

aminopyralid and clethodim. All scenarios were considered and analyzed under all chemicals unless 

noted otherwise.

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FISHER AND MARTEN

Fisher and marten are wide ranging meso-carnivores with large home ranges and a preference for late 

seral forested habitats. Fishers have been documented to move up to 3 miles per day and are active 

day or night. Marten exhibit similar habits, traveling long distances and being active day or night. 

They forage opportunistically on a diet that varies both seasonally and geographically which includes 

small mammals, birds, insects, fruits, berries, fungi and reptiles. Fisher and marten are uncommon 

and sensitive to human disturbance. Neither species has been documented in the project area. 

The areas proposed for herbicide treatments include potential foraging and dispersal habitat for 

marten and fisher. 

Reforestation

After the initial herbicide treatment, understory vegetation is expected to be much reduced, thus these

areas would be of much less utility as foraging habitat because prey such as small mammals and birds 

rely on understory vegetation for cover and food. It is plausible that the remaining root systems of 

treated shrubs would still provide subnivean habitat for mice or ground squirrels; however, the 

temperature regime just below the surface would be changed because of the reduction of foliar cover 

above ground and may become unsuitable for animals using the upper soil profile for burrows. It is 

likely that any individual fisher or marten in this area would be traveling in adjacent green forest not 

proposed for treatments in this project. Because of their avoidance of open areas, it is unlikely that 

they would spend much time in the affected area, especially after the first year of treatment other than 

to inspect the now readily visible burrow holes or pockets of untreated vegetation within treated units. 

Weeds

Chemicals would be applied to each specific weed type, not broadcast sprayed, so the number of nontargeted plants being killed would be minimal.

The likely types of exposure considered in this assessment for marten and fisher would be ingestion 

of contaminated prey (small mammals), fruit or contaminated water (non-accidental acute and 

chronic). Because of their sensitivity to disturbance and human presence, any individuals in the 

treatment area would likely be flushed and displaced during implementation. Thus, the scenario 

describing direct spraying of an individual is discountable and is not evaluated in this assessment. 

MULE DEER

Mule deer are wide ranging herbivores that utilize a variety of vegetation types including oak 

woodlands, coniferous forest, meadows and grasslands, chaparral and riparian corridors. They browse 

or graze, showing preferences for forbs and grasses, as well as tender new shoots of various shrub 

species including mazanita, ceanothus, mountain mahogany and bitterbrush. 

Reforestation and weeds

The areas proposed for herbicide treatments include suitable transition and concentration habitat, as 

well as critical winter range. The most likely exposure for deer is when foraging during early spring 

and summer, which would encompass critical winter range and migratory or transition range. The 

likely types of exposure considered in this analysis for mule deer would be ingestion of contaminated 

fruit, vegetation and water. Because of their sensitivity to disturbance and human presence, any 

individuals in the treatment area would likely be flushed and displaced during implementation. Thus, 

the scenario describing direct spraying of an individual is discountable and is not evaluated in this 

assessment.

PALLID,BIG-EARED AND FRINGED MYOTIS BATS

Bats are found in various habitat types such as forests, woodlands, grasslands, meadows and riparian 

corridors. They roost in buildings, under bridges, in rock crevices, foliage and trees. Day roosts are 

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usually enclosed locations such as rock crevices or hollowed out snags where they can remain 

undetected by potential predators. Most bats are sensitive to disturbance at roost sites. Bats can travel 

over a mile to favorite foraging locations. They forage at night exclusively on insects, using open 

habitats such as meadows, forest edges, or riparian corridors. See species account section in this 

document for more life history information for these species. 

Reforestation and weeds

The areas proposed for herbicide treatments include suitable foraging and travelling habitat for 

fringed myotis, pallid bats and big-eared bats. The most likely exposure for these species is during 

foraging bouts along forest edges or while traveling on their way to a suitable foraging location. Thus, 

the likely types of exposure considered in this assessment for bats would be ingestion of contaminated 

prey (insects) and ingestion of contaminated water (non-accidental-acute and chronic). Because they 

are nocturnal, foraging at night, the scenario describing direct spraying of an individual is 

discountable and is not evaluated in this assessment. 

BALD EAGLE,GREAT GRAY OWL,GOSHAWK AND SPOTTED OWL

Great gray owls, goshawks and spotted owls are found in late seral forested habitats, great gray owls 

are closely associated with meadows. Bald eagles are closely associated with lake areas. Eagles rely 

on prey that are; dead, dying or otherwise vulnerable. They eat fish, rabbits, waterfowl, and 

mammals. Owls and goshawks are carnivorous predators that forage over large areas consuming prey 

items such as squirrels, small birds, woodrats, mice, gophers and voles. They typically hunt from 

perches and on the wing. All these species are sensitive to disturbance and human presence. Several 

great gray owl, spotted owl and goshawk territories exist throughout the project area and in close 

proximity to treatment units. One bald eagle breeding territory exists at Cherry Lake. See species 

account sections in this document for more life history information for these species.

Reforestation

The areas proposed for herbicide treatments include potential foraging habitat for bald eagles, great 

gray owls, goshawks and spotted owls. It is likely that any individual eagles, owls or goshawks near 

treatment areas would be utilizing adjacent green forest and edge habitat not proposed for treatments 

in this project.

Weeds

Chemicals would be applied to each specific weed type, not broadcast sprayed, so the number of nontargeted plants being killed would be minimal. The likely types of exposure considered in this 

assessment for bald eagles, owls and goshawks would be ingestion of contaminated prey (small 

mammals or fish) or contaminated water (non-accidental acute and chronic). Because these species 

are highly mobile and sensitive to human disturbance, the scenario describing direct spraying of an 

individual is discountable and is not evaluated in this assessment. 

BLACK-BACKED WOODPECKERS

Black-backed woodpeckers are closely associated with burned forest, although they do use green 

forest as well. Black-backed woodpeckers readily forage on larvae of wood-boring beetles, engraver 

beetles, and mountain pine beetles found in the trunks of burned conifers (Dixon and Saab 2000). 

Very low numbers of black-backed woodpeckers have been documented in the project area. See 

species account section in this document for more life history information for this species.

Reforestation and weeds

Snags in the proposed treatment areas would provide only small areas in which black-backed 

woodpeckers would forage. Individual woodpeckers would more likely utilize adjacent burned forest 

that was not salvage logged or snags in green forest. The likely types of exposure considered in this 

assessment for black-backed woodpeckers would be ingestion of contaminated prey (insects), fruit or 

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water (non-accidental acute and chronic). Because these species are highly mobile, the scenario 

describing direct spraying of an individual is discountable and is not evaluated in this assessment. 

The scenario representing the ingestion of contaminated insects is that of a bird eating insects that 

have just been sprayed with chemical. Individuals would be at greatest risk of being exposed if they 

were foraging through the area either immediately or within a few days after spraying occurred. 

Insects sought by black-backed woodpeckers reside under the bark and in the trunks of burned trees 

and are much less likely to be exposed because understory plants and weeds would be targeted, 

standing burned trees would not be sprayed. 

The scenario representing the ingestion of contaminated fruit is a small bird or large bird consuming 

fruit that has been directly sprayed with chemical. The small bird used in this scenario weighs 0.1kg 

and the large bird weighs 4kg, neither of which is close to the weight of black-backed woodpeckers 

(0.07kg), thus both scenarios are shown which represent animals smaller and larger than the species 

of concern. This species are considered bounded by these scenarios. It is assumed that black-backed 

woodpeckers would fall somewhere between the values for the birds in these scenarios.

Exposure to contaminated water is modeled to estimate glyphosate concentrations in water using a 

Gleams-Driver model. This model estimates peak and longer-term pesticide concentrations in surface 

water. HQs for birds are derived when modeled concentration rates are combined with the bird’s 

weight and amount of water consumed. The small bird used in this scenario weighs 0.1kg and the 

large bird weighs 4kg, neither of which is close to the weight of black-backed woodpeckers (0.07kg), 

thus both scenarios are shown which represent animals smaller and larger than the species of concern. 

This species are considered bounded by these scenarios. It is assumed that black-backed woodpeckers 

would fall somewhere between the values for the birds in these scenarios.

WESTERN BUMBLE BEE

No records exist of western bumble bee on the STF. Bumble bees forage, collecting nectar and pollen 

on many different flowering plants including; lupine, penstemon, asters, clovers, etc.

Reforestation

The areas proposed for herbicide treatments may provide suitable foraging, nesting and overwintering 

habitat to bumble bees. It is likely that after the first year of treatment, understory vegetation would 

be much reduced in treated areas and would be unsuitable for foraging. Untreated areas within and 

adjacent to treated areas would continue to provide suitable foraging habitat.

Weeds

Chemicals would be applied by targeting each plant, not broadcast spraying, so the number of nontargeted plants being sprayed would be minimal. The weeds would be sprayed prior to flowering, 

which reduces the potential for exposure to bees.

The likely types of exposure considered in this assessment for bumble bees would be the direct 

contact honeybee scenario and ingestion of contaminated vegetation. 

The scenarios representing the ingestion of contaminated vegetation is an invertebrate consuming 

short grass or broadleaf vegetation that has been directly sprayed with chemical. This scenario is run 

for acute exposure, use residue rates, related to the amount of contaminated food eaten per day. The 

scenario for direct spray involves a honey bee that is directly sprayed with chemical and assumes 

complete absorption over the first day of exposure. This scenario is run for acute exposure only. 

GlyphosateAnalysis

Under Alternatives 1 and 5, up to about 25,000 acres are proposed for glyphosate treatments 

associated with reforestation and eradication of noxious weeds. Treatment areas are spread across the 

entire project area. Under Alternative 4, up to 4,145 acres are proposed for glyphosate treatments in 

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reforestation areas only. Glyphosate would be applied via backpack sprayer in a broadcast manner. 

Reference Table 3.16-2 for all scenarios and associated HQ values cited below.

MAMMALS

Toxicity values for mammals are based on an NOAEL of 500 mg a.e./kg/bw/day for acute and 

chronic exposure scenarios (SERA 2011). Decreases in food consumption and reduced body weight 

gain are commonly observed in mammals exposed to glyphosate (Ibid). However, most field studies 

provide no suggestion of adverse effects on mammalian populations or reproductive capacity, other 

than secondary effects which can be attributed to changes in vegetation (Ibid). All but one of the HQs 

reported for glyphosate application under Alternatives 1, 4 and 5 are below the NOAEL or No 

Observable Adverse Effect Level for the mammals considered. The upper limit for bats consuming 

contaminated insects is 1.0, which is just at the threshold of NOAEL. 

Fisher and Marten

For the scenario representing ingestion of a contaminated small mammal, a significant reduction in 

the risk of exposure is expected within a few days of the small mammal being sprayed. A small 

mammal, if sprayed, would be expected to immediately start grooming its fur, which is a normal 

behavioral response when foreign objects are introduced to its fur. Once ingested by the small 

mammal through grooming its fur, the chemical would be quickly metabolized and excreted by the 

kidneys in the animal’s waste products. Data from Brewster et al (1991) shows that after 28 hours, 

only 0.06% of an administered dose of 10 mg/kg bw remained in the blood of rats. (cited in SERA 

2007). 

All of the associated upper level (worst case scenario) HQ values for acute and chronic/longer-term 

exposure to glyphosate are well below 1, many are several orders of magnitude below the NOAEL 

threshold HQ value of one (1). 

In summary, Alternatives 1, 4 and 5 have an extremely low potential for direct or indirect individual 

effects from the proposed application of glyphosate as described above. The proposed application of 

herbicides poses very limited toxicological risk to marten and fisher, especially considering they have 

not been documented in the project area. Because all HQs are well below the threshold of NOAEL an 

adequate margin of safety exists in the unlikely or limited exposure of fisher or marten to 

contaminated prey, fruit or water. 

Mule Deer

Based on acute lethality data for glyphosate, there appear to be no remarkable differences in 

sensitivity among mammals; however, there is limited data that indicate larger mammals such as deer

are somewhat more sensitive than smaller mammals to sub-lethal doses of glyphosate (SERA 2011). 

It is possible that individual deer could forage on berries, leaves or grasses that have been sprayed. 

The associated HQ values for non-accidental acute exposure at the upper limit (worst case scenario) 

for ingestion of contaminated broadleaf, tall, and short grass are 0.5, 0.4 and 0.9 respectively, 

approaching the threshold value of one (1) and warrants further discussion. The scenario for 

consumption of contaminated short grass (HQ equals 0.9) is based on the large mammal eating 5 

pounds of contaminated short grass per day. It is expected that the treated vegetation would quickly 

die becoming less desirable and the toxicity of the herbicide would result in taste aversion, resulting 

in reduced consumption of treated vegetation. It is unlikely that a deer would eat 5 pounds of 

contaminated short grass a day when untreated more palatable vegetation would be available near 

treated areas.

The associated HQ values for non-accidental acute and chronic/longer-term exposure at the upper 

limit (worst case scenario) for a large mammal ingesting contaminated water are several orders of 

magnitude less than the threshold value of 1. 

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In summary, Alternatives 1, 4 and 5 have limited potential for direct or indirect individual effects 

from the proposed application of glyphosate as described above. The proposed application of 

herbicides poses some toxicological risk to deer because of the amount of area to be treated over 

multiple years. However, it is important to note that the exposure based on this risk assessment shows 

that all HQs are below the threshold of NOAEL providing mule deer an adequate margin of safety in 

the event that they are exposed to contaminated vegetation or water. 

Pallid, Big-Eared and Fringed Myotis Bats

The associated HQ value for non-accidental acute exposure at the upper limit (worst case scenario) 

for ingestion of contaminated insects is 1.0. This HQ value is at the threshold value of one (1) and 

warrants further discussion. This upper limit is based on the assumption that 100% of the insects 

being consumed have been contaminated and the amount of prey consumed accounts for about half of 

the body weight of the animal (0.02kg). The weight of the small mammal in this scenario a bit larger 

than the weight of a pallid bat, but 3 to 4 times that of the weight of fringed myotis and big-eared 

bats. Bats can eat up to their body weight in insects each night. Bats tend to follow “foraging routes” 

and may target several foraging areas in one night or feeding bout; therefore, the likelihood that an 

individual would consume half its body weight in contaminated insects at the spray location is low. It 

is more likely that they would receive a lesser exposure, perhaps better estimated by the central or 

lower limit exposure which has associated HQ values of 0.2 and 0.02 respectively, far below the 

threshold value of one (1). The duration for upper limit (worst case scenario) would last less than a 

few days in any one location. Insects would disperse from the immediate area naturally or as 

conditions such as the wind blew them elsewhere diluting the concentration of contaminated 

individuals available for consumption. The upper level model is an extremely conservative estimate 

based on the potential exposure of individual bats to contaminated insects and is at the threshold 

value of one (1) which indicates a slightly increased risk for toxic effects to individual bats. 

The associated HQ values for non-accidental acute and chronic/longer-term exposure at the upper 

limit (worst case scenario) for a small mammal ingesting contaminated water are several orders of 

magnitude less than the threshold value of 1. 

In summary, Alternatives 1,4 and 5 have limited potential for direct or indirect individual effects from 

the proposed application of glyphosate as described above. The proposed application of herbicides 

poses some toxicological risk to bats because of the amount of area to be treated over multiple years. 

However, it is important to note that the exposure based on this risk assessment shows that all but one 

HQ are several orders of magnitude less than the NOAEL . The HQ value for ingestion of 

contaminated insects has an HQ value of 1, which just reaches the threshold. Therefore, these species 

are provided an adequate margin of safety in the event that they are exposed to contaminated prey or 

water.

BIRDS

Toxicity values for birds are based on an NOAEL of 1,500 or 58 mg a.e./kg/bw/day for acute and 

chronic exposure scenarios respectively (SERA 2011). As with mammals, decreases in food 

consumption and reduced body weight gain are commonly observed in birds exposed to glyphosate 

(Ibid). While no specific studies have been conducted on birds, two studies involving the immersion 

of eggs in a solution of Roundup suggest that it is not likely to cause developmental effects in birds. 

No field studies report adverse effects in birds and effects on bird populations appear to be secondary 

effects which can be attributed to changes in vegetation (Ibid). All but one Hazard Quotient reported 

for proposed glyphosate application under Alternatives 1, 4 and 5 are below the NOAEL for the birds 

considered. One HQ value related to the scenario of black-backed woodpeckers exposed to 

contaminated fruit was 1.7. 

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Bald Eagle, Great Gray Owl, Goshawk and Spotted Owl

For the scenario representing ingestion of a contaminated small mammal, a significant reduction in 

the risk of exposure is expected within a few days of the small mammal being sprayed. A small 

mammal, if sprayed, would be expected to immediately start grooming its fur, which is a normal 

behavioral response when foreign objects are introduced to its fur. Once ingested by the small 

mammal through grooming its fur, the chemical would be quickly metabolized and excreted by the 

kidneys in the animals’ waste products. Data from Brewster et al (1991) shows that after 28 hours, 

only 0.06% of an administered dose of 10 mg/kg bw remained in the blood of rats. 

All of the associated upper level (worst case scenario) HQ values for acute and chronic/longer-term 

exposure to glyphosate are several orders of magnitude below the NOAEL threshold value of one (1). 

In summary, Alternatives 1, 4 and have limited potential for direct or indirect individual effects from 

the proposed application of glyphosate as described above. The proposed application of herbicides 

poses some toxicological risk to bald eagles, great gray owls, goshawks and spotted owls, because of 

the amount of area to be treated over multiple years. However, it is important to note that the toxicity 

exposure scenarios analyzed in the risk assessment show that all HQs are several orders of magnitude 

less than the NOAEL; therefore, these species are provided an adequate margin of safety in the event 

that they are exposed to contaminated prey or water.

Black-backed Woodpecker

The associated HQ value for non-accidental acute exposure at the upper limit (worst case scenario) 

for ingestion of contaminated insects is 0.7. This HQ value is approaching the threshold value of one 

(1) and warrants further discussion. This upper limit is based on the assumption that 100% of the 

insects being consumed have been contaminated. Because the insects consumed by black-back 

woodpeckers are not typically associated with the target vegetation, it is highly unlikely that they 

would consume only contaminated insects. It is more likely that would receive a lesser exposure, 

perhaps better estimated by the central or lower limit exposure which has associated HQ values of 0.1 

and 0.01 respectively, which are far below the threshold value of one (1). 

The associated HQ values for non-accidental acute and chronic exposure at the upper limit (worst 

case scenario) for ingestion of contaminated fruit is 0.4 to 0.05 and 1.7 to 0.2. The HQ value for

chronic exposure is greater than the threshold value of one (1) and warrants further discussion. 

Treatments would be applied during the early spring months before many plants have gone to fruit. It 

is expected that sprayed plants would be damaged or killed such that they would not produce fruit 

after treatment. Additionally, untreated areas would provide foraging opportunities to individuals 

adjacent to and in treated areas. However, the potential for increased exposure of black-backed 

woodpeckers to toxic chemicals occurs under this scenario.

The associated HQ values for non-accidental acute and chronic/longer-term exposure at the upper 

limit (worst case scenario) for a small or large bird ingesting contaminated water are several orders of 

magnitude less than the threshold value of 1. 

In summary, Alternatives 1, 4 and 5 have moderate potential for direct or indirect individual effects 

from the proposed application of glyphosate as described above. The proposed application of 

glyphosate poses some toxicological risk to black-backed woodpeckers because of the amount of area 

to be treated over multiple years. However, it is important to note that the exposure based on the risk 

assessment shows that most HQs are less than NOAEL; therefore, these species are provided an 

adequate margin of safety in the event that they are exposed to contaminated prey, vegetation or 

water. There is a slightly elevated risk associated with exposure to contaminated fruit.

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INVERTEBRATES

Toxicity values for insects are based on an NOAEL of 860 mg a.e./kg/bw/day for acute and chronic 

exposure scenarios respectively (SERA 2011). Hazard Quotients reported for proposed glyphosate 

application under Alternatives 1, 4 and 5 indicate a toxicological risk for invertebrates. 

Western Bumble Bee

A study of the application of very high water volumes and surfactant concentrations to honeybees 

found lethal effects, but this was suspected to have been the result of drowning rather than toxicity of 

surfactants (Bakke 2003). Regardless, insects are sensitive to physical impacts of liquids, including 

drowning. Palmer and Krueger (2001a in SERA 2001) report mortality of 5% (3 of 60) of honeybees 

directly sprayed with a dose of 100 μg/bee. This type of exposure corresponds to an HQ of 2.0. This 

dose is classified as an NOEC (No Observable Effect Concentration) because it was not significantly 

different from mortality in the matched solvent control (SERA 2011). It was significant when 

combining the matched solvent (0 of 60) with the negative control (0 of 60) to reach a control of (0 of 

120). The direct contact honeybee acute exposure was not included because contact toxicity data, 

nectar residue data and oral toxicity data is not available for honeybees.

The associated HQ values for acute exposure at the upper limit (worst case scenario) for ingestion of 

contaminated short grass and broadleaf vegetation are 3.0 and 1.7 respectively, above the threshold 

value of one (1) and warrants further discussion. Vegetation would be treated in the early spring 

before the flowering period for most plants and are expected to die back within a week or two. 

Because the sprayed plants are not likely to provide suitable forage for bumble bees, they would 

likely travel past treated areas. Untreated vegetation would be available within treatment units and 

adjacent to treated areas throughout implementation.

In summary, Alternatives 1, 4 and 5 have moderate potential for direct or indirect toxicological 

effects to individuals from the proposed application of glyphosate as described above. The proposed 

application of herbicides poses toxicological risk to bumble bees because of the amount of area to be 

treated over multiple years. Table 3.16-2 summarizes the HQs for the terrestrial wildlife species 

discussed above.

Clopyralid Analysis

Under Alternatives 1 and 5, about 705 acres are proposed for treatment of noxious weeds with 

clopyralid. These treatment areas are spread across 72,000 acres within the project area. Thistles, 

woolly mullein, spotted knapweed and tocalote would be the targeted species sprayed with 

Clopyralid. Clopyralid applications would target each individual plant, not broadcast sprayed, so the 

number of non-target plants sprayed is assumed to be very few. Spraying would occur in the early to 

mid-spring before most if not all target weeds and surrounding vegetation were flowering. There is 

limited potential for terrestrial animal exposure throughout the project area. Reference Table 3.16-3 

for all scenarios and associated HQ values cited below.

ALL SPECIES

Toxicity values for mammals are based on an NOAEL of 75 or 15 mg a.e./kg/bw/day for acute and 

chronic exposure scenarios respectively (SERA 2004). Toxicity values for birds are based on an 

NOAEL of 670 or 15 mg a.e./kg/bw/day for acute and chronic exposure scenarios respectively (Ibid). 

No chronic toxicity studies in birds have been encountered so the chronic NOAEL for mammals is 

used in this assessment. Toxicity values for honey bees are based on an NOAEL of 909 mg/kg/bw. 

While the plausibility of exposure is limited, all scenarios listed under the scenario section are 

considered here, except consumption of contaminated fish. No treatments are proposed in close 

proximity to Cherry Lake; therefore the scenario representing a bird eating a contaminated fish is not 

considered here. 

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There were no non-accidental acute exposure scenarios resulting in a Hazard Quotient that exceeds 

the designated NOAEL. In fact, all acute exposure HQs were several orders of magnitude below the 

threshold of 1. All but one chronic/longer-term exposure scenario resulted in Hazard Quotients 

several orders of magnitude below the threshold of NOAEL. The scenario considered for blackbacked woodpeckers as chronic exposure and ingestion of contaminated fruit by a small bird had an 

HQ of 1.1, just above the threshold of concern, indicating the potential toxicological risk to individual 

woodpeckers. The small bird scenario represents a bird several times smaller than a black-backed 

woodpecker and thus is an extremely conservation assessment of potential risk. Additionally, because 

of the targeted spray application and the limited amount of acreage being sprayed across the 

landscape, it is unlikely that vegetation in close proximity to the weeds producing fruit eaten by 

woodpeckers would actually be sprayed.

In summary, Alternatives 1 and 5 have limited potential for direct or indirect individual effects from 

the proposed application of clopyralid as described above. The proposed application of clopyralid

poses limited toxicological risk to terrestrial wildlife based on the limited area to be treated. It is also 

important to note that the exposure based on the risk assessment shows that all but one HQ is less 

than the NOAEL, most of them several orders of magnitude below the threshold of concern; therefore

these species are provided an adequate margin of safety in the event that they are exposed to 

contaminated prey, vegetation or water.

Aminopyralid Analysis

Under Alternatives 1 and 5, about 670 acres are proposed for treatment of noxious weeds with 

aminopyralid. Treatment sites, the location of the target weeds, are spread across about 30,000 acres 

within the project area. Thistles, spotted knapweed, oxeye daisy, sulfer cinquefoil and tocalote would 

be the targeted species sprayed with aminopyralid. Aminopyralid would target each individual plant, 

not broadcast sprayed, so the number of non-target plants sprayed is assumed to be very few. 

Spraying would occur in the early to mid-spring before most if not all target weeds and surrounding 

vegetation were flowering. There is limited potential for terrestrial animal exposure throughout the 

project area. Reference Table 3.16-4 for all scenarios and associated HQ values cited below.

ALL SPECIES

Toxicity values for mammals are based on an NOAEL of 104 or 50 mg a.e./kg/bw/day for acute and 

chronic exposure scenarios respectively (SERA 2007). Toxicity values for birds are based on an 

NOAEL of 14 or 184 mg a.e./kg/bw/day for acute and chronic exposure scenarios respectively (Ibid). 

For honeybees, no mortality would be expected following acute exposure to doses up to 1,075 mg/kg 

based on direct spray studies and is considered a functional NOAEL (Ibid). 

While the plausibility of exposure to wildlife is limited, all scenarios listed under the scenario section

are considered here, except consumption of contaminated fish. No treatments are proposed in close 

proximity to Cherry Lake; therefore the bald eagle scenario representing a bird eating a contaminated 

fish is not considered here.

There were no chronic/longer-term exposure scenarios resulting in a Hazard Quotient that exceeds the 

designated NOAEL. In fact, all chronic HQs were several orders of magnitude below NOAEL. All 

but one non-accidental acute exposure scenario resulted in Hazard Quotients at or below NOAEL.

The scenario considered for black-backed woodpeckers as non-accidental exposure and ingestion of 

contaminated insects by a small bird had an HQ of 1.8. The HQ value is slightly above the threshold 

of concern, indicating the potential for toxicological risk to individual woodpeckers. The small bird 

scenario represents a bird several times smaller than a black-backed woodpecker and thus is an 

extremely conservation assessment of potential risk. Additionally, because the insects black-backed 

woodpeckers prey upon are located under the bark of burned trees, it is unlikely that individuals 

would be exposed to aminopyralid at the level considered in this scenario. 

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In summary, Alternatives 1 and 5 have limited potential for direct or indirect individual effects from 

the proposed application of aminopyralid as described above. The proposed application of 

aminopyralid poses limited toxicological risk to terrestrial wildlife based on the limited area to be 

treated. However, it is important to note that the exposure based on the risk assessment shows that all 

but one HQ are well below the threshold of concern or No Observable Adverse Effect Level, most of 

them several orders of magnitude below this threshold; therefore, these species are provided an 

adequate margin of safety in the event that they are exposed to contaminated prey, vegetation, or 

water.

Clethodim Analysis

Under Alternatives 1 and 5, about 3,100 acres are proposed for treatment of noxious weeds. 

Treatment areas, the location of the target weeds, are spread across an area of about 45,000 acres 

within the project area. Medusahead and barbed goatgrass would be the targeted species sprayed with 

clethodim. Two of the largest areas, comprising about 80 percent of the treatment proposed for 

medusahead are in critical winter deer range and near Ackerson meadow, an important area for great 

gray owls. Implementing these treatments would improve habitat conditions in the short and long 

term for these and many other species. Reference Table 3.16-5 for all scenarios and associated HQ 

values cited below. 

Clethodim would be applied by directed foliar spraying, not broadcast spraying. Spraying would 

occur in the early spring before the target weeds and most surrounding vegetation were flowering. 

There is potential for terrestrial animal exposure within the project area.

ALL SPECIES

Toxicity values for mammals are based on an NOAEL of 100 or 19 mg a.e./kg/bw/day for acute and 

chronic exposure scenarios respectively (SERA 2014). Toxicity values for birds are based on an 

NOAEL of 950 or 20 mg a.e./kg/bw/day for acute and chronic exposure scenarios respectively (Ibid). 

For honeybees, a functional NOAEL is 860 mg/kg based on acute contact bioassays (Ibid). 

While the plausibility of exposure to wildlife is limited, all scenarios listed under the scenario section

are considered here, except consumption of contaminated fish. No treatments are proposed in close 

proximity to Cherry Lake; therefore the scenario representing a bird eating a contaminated fish is not 

considered here. No oral studies were available for honeybees; therefore, the scenario of invertebrates 

ingesting contaminated vegetation is not available for consideration in this analysis. 

There were no chronic/longer-term exposure scenarios resulting in a Hazard Quotient that exceeds the 

designated NOAEL. In fact, all upper level (worst case scenario) HQs were well below 1.0, most of 

them several orders of magnitude below the threshold of 1. 

In summary, there is a limited potential for direct or indirect individual effects from the proposed 

application of clethodim under Alternatives 1 and 5 as described above. The proposed application of 

clethodim poses some toxicological risk to terrestrial wildlife based on the limited area to be treated. 

It is also important to note that the exposure based on the risk assessment shows that all HQs are less 

than the threshold of concern, most of them several orders of magnitude below; therefore, these 

species are provided an adequate margin of safety in the event that they are exposed to contaminated 

prey, vegetation, or water.

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Table 3.16-2 Summary of Hazard Quotients for Terrestrial Wildlife – Glyphosate

Receptor CEN 

HQ1

LOW 

HQ1

UP 

HQ1

TOX 

VAL

TOX 

END

Non-Accidental Acute Exposures

Contaminated Fruit [Lowest Residue Rates]

Larger Mammal (400g) 4E-02 5E-03 0.1 500 NOAEL

Large Mammal (70 kg) 2E-02 3E-03 8E-02 500 NOAEL

Small bird (10g) 1E-01 2E-02 4E-01 1500 NOAEL

Large Bird (4 kg) 1E-02 2E-03 5E-02 1500 NOAEL

Contaminated Broadleaf Foliage

Large Mammal (70 kg) 1E-01 1E-02 0.5 500 NOAEL

Insect 3E-01 5E-02 1.7 860 NOAEL

Contaminated Tall Grass

Large Mammal (70 kg) 8E-02 8E-03 0.4 500 NOAEL

Contaminated Short Grass [Highest Residue Rate]

Large Mammal (70 kg) 0.2 2E-02 0.9 500 NOAEL

Insect 6E-01 1E-01 3.0 860 NOAEL

Contaminated Water

Small mammal (20g) 2E-05 2E-06 1E-04 500 NOAEL

Canid (5 kg) 9E-06 1E-06 7E-05 500 NOAEL

Large Mammal (70 kg) 7E-06 8E-07 5E-05 500 NOAEL

Small bird (10g) 1E-05 1E-06 7E-05 1500 NOAEL

Large Bird (4 kg) 1E-06 2E-07 1E-05 1500 NOAEL

Contaminated Insects

Small mammal (20g) 0.2 2E-02 1.0 500 NOAEL

Small bird (10g) 0.1 1E-02 0.7 1500 NOAEL

Consumption of small mammal (after direct spray) by predator

Canid (5 kg) 3E-02 8E-03 5E-02 500 NOAEL

Carnivorous bird (640 g) 1E-02 3E-03 2E-02 1500 NOAEL

Consumption of contaminated Fish

Fish-eating bird (2.4 kg) 9E-07 1E-08 4E-05 1500 NOAEL

Chronic/Longer-Term Exposures

Contaminated Fruit [Lowest Residue Rates]

Larger Mammal (400g) 6E-03 8E-04 2E-02 500 NOAEL

Large Mammal (70 kg) 3E-03 5E-04 1E-02 500 NOAEL

Small bird (10g) 5E-01 7E-02 1.7 58 NOAEL

Large Bird (4 kg) 5E-02 7E-03 2E-01 58 NOAEL

Contaminated Broadleaf Foliage

Large Mammal (70 kg) 2E-02 2E-03 8E-02 500 NOAEL

Contaminated Tall Grass

Large Mammal (70 kg) 1E-02 1E-03 7E-02 500 NOAEL

Contaminated Short Grass [Highest Residue Rate]

Large Mammal (70 kg) 3E-02 3E-03 0.1 500 NOAEL

Contaminated Water

Small mammal (20g) 3E-07 1E-07 8E-06 500 NOAEL

Canid (5 kg) 2E-07 7E-08 5E-06 500 NOAEL

Large Mammal (70 kg) 1E-07 6E-08 4E-06 500 NOAEL

Small bird (10g) 4E-06 2E-06 1E-04 58 NOAEL

Large Bird (4 kg) 6E-07 3E-07 2E-05 58 NOAEL

Consumption of contaminated Fish

Fish-eating bird (2.4 kg) 4E-07 2E-08 7E-05 58 NOAEL

1 Application rate: 5 lb a.e./acre. 

CEN=Central; END=Endpoint; HQ=Hazard Quotient; LOW=Lower; TOX=Toxicity; UP=Upper; VAL=Value

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Table 3.16-3 Summary of Hazard Quotients for Terrestrial Wildlife – Clopyralid

Receptor CEN 

HQ1

LOW 

HQ1

UP 

HQ1

TOX 

VAL

TOX 

END

Accidental Acute Exposures

Direct Spray 100% absorption

Honey Bee 4E-02 4E-02 4E-02 909 NOEC

Non-Accidental Acute Exposures

Contaminated Fruit [Lowest Residue Rates]

Larger Mammal (400g) 1E-03 2E-04 5E-03 75 NOAEL

Large Mammal (70 kg) 7E-03 9E-04 3E-02 75 NOAEL

Small bird (10g) 1E-02 2E-03 5E-02 670 NOAEL

Large Bird (4 kg) 1E-03 2E-04 5E-03 670 NOAEL

Contaminated Broadleaf Foliage

Large Mammal (70 kg) 2E-01 2E-02 0.8 75 NOAEL

Contaminated Tall Grass

Large Mammal (70 kg) 3E-02 3E-03 0.1 75 NOAEL

Contaminated Short Grass [Highest Residue Rate]

Large Mammal (70 kg) 0.1 7E-03 0.3 75 NOAEL

Contaminated Water

Small mammal (20g) 1E-05 2E-06 3E-05 75 NOAEL

Canid (5 kg) 6E-06 1E-06 2E-05 75 NOAEL

Large Mammal (70 kg) 4E-06 1E-06 2E-05 75 NOAEL

Small bird (10g) 2E-06 5E-07 7E-06 670 NOAEL

Large Bird (4 kg) 3E-07 7E-08 1E-06 670 NOAEL

Contaminated Insects

Small mammal (20g) 0.1 6E-03 0.3 75 NOAEL

Small bird (10g) 2E-02 2E-03 0.1 670 NOAEL

Consumption of small mammal (after direct spray) by predator

Canid (5 kg) 9E-03 3E-03 2E-02 75 NOAEL

Carnivorous bird (640 g) 1E-03 4E-04 2E-03 670 NOAEL

Chronic/Longer-Term Exposures

Contaminated Fruit [Lowest Residue Rates]

Larger Mammal (400g) 2E-02 3E-03 1E-01 15 NOAEL

Large Mammal (70 kg) 1E-02 2E-03 7E-02 15 NOAEL

Small bird (10g) 2E-01 3E-02 1.1 15 NOAEL

Large Bird (4 kg) 3E-02 3E-03 1E-01 15 NOAEL

Contaminated Broadleaf Foliage

Large Mammal (70 kg) 7E-02 5E-03 4E-01 15 NOAEL

Contaminated Tall Grass

Large Mammal (70 kg) 5E-02 4E-03 4E-01 15 NOAEL

Contaminated Short Grass [Highest Residue Rate]

Large Mammal (70 kg) 1E-01 1E-02 0.8 15 NOAEL

Contaminated Water

Small mammal (20g) 2E-05 2E-06 3E-05 15 NOAEL

Canid (5 kg) 1E-05 1E-06 2E-05 15 NOAEL

Large Mammal (70 kg) 8E-06 1E-06 1E-05 15 NOAEL

Small bird (10g) 3E-05 4E-06 6E-05 15 NOAEL

Large Bird (4 kg) 4E-06 6E-07 8E-06 15 NOAEL

1 Application rate: .25 lb a.e./acre. 

CEN=Central; END=Endpoint; HQ=Hazard Quotient; LOW=Lower; TOX=Toxicity; UP=Upper; VAL=Value

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Table 3.16-4 Summary of Hazard Quotients for Terrestrial Wildlife – Aminopyralid

Receptor CEN 

HQ1

LOW 

HQ1

UP 

HQ1

TOX 

VAL

TOX 

END

Accidental Acute Exposures

Direct Spray 100% absorption

Honey Bee 2E-02 2E-02 2E-02 1075 NOEC

Non-Accidental Acute Exposures

Contaminated Fruit [Lowest Residue Rates]

Larger Mammal (400g) 4E-03 5E-04 1E-02 104 NOAEL

Large Mammal (70 kg) 2E-03 3E-04 8E-03 104 NOAEL

Small bird (10g) 3E-01 4E-02 1.0 14 NOAEL

Large Bird (4 kg) 3E-02 4E-03 1E-01 14 NOAEL

Contaminated Broadleaf Foliage

Large Mammal (70 kg) 1E-02 1E-03 0.1 104 NOAEL

Contaminated Tall Grass

Large Mammal (70 kg) 8E-03 8E-04 4E-02 104 NOAEL

Contaminated Short Grass [Highest Residue Rate]

Large Mammal (70 kg) 2E-02 2E-03 0.1 104 NOAEL

Contaminated Water

Small mammal (20g) 2E-05 3E-07 9E-05 104 NOAEL

Canid (5 kg) 9E-06 2E-07 5E-05 104 NOAEL

Large Mammal (70 kg) 7E-06 1E-07 4E-05 104 NOAEL

Small bird (10g) 2E-04 4E-06 1E-03 14 NOAEL

Large Bird (4 kg) 3E-05 6E-07 2E-04 14 NOAEL

Contaminated Insects

Small mammal (20g) 2E-02 2E-03 0.1 104 NOAEL

Small bird (10g) 0.3 3E-02 1.8 14 NOAEL

Consumption of small mammal (after direct spray) by predator

Canid (5 kg) 3E-03 9E-04 5E-03 104 NOAEL

Carnivorous bird (640 g) 3E-02 8E-03 4E-02 14 NOAEL

Chronic/Longer-Term Exposures

Contaminated Fruit [Lowest Residue Rates]

Larger Mammal (400g) 2E-03 2E-04 7E-03 50 NOAEL

Large Mammal (70 kg) 1E-03 1E-04 4E-03 50 NOAEL

Small bird (10g) 4E-03 5E-04 2E-02 184 NOAEL

Large Bird (4 kg) 5E-04 5E-05 2E-03 184 NOAEL

Contaminated Broadleaf Foliage

Large Mammal (70 kg) 5E-03 4E-04 3E-02 50 NOAEL

Contaminated Tall Grass

Large Mammal (70 kg) 4E-03 3E-04 2E-02 50 NOAEL

Contaminated Short Grass [Highest Residue Rate]

Large Mammal (70 kg) 9E-03 7E-04 0.1 50 NOAEL

Contaminated Water

Small mammal (20g) 1E-05 3E-07 8E-05 50 NOAEL

Canid (5 kg) 7E-06 2E-07 5E-05 50 NOAEL

Large Mammal (70 kg) 6E-06 1E-07 4E-05 50 NOAEL

Small bird (10g) 6E-06 2E-07 4E-05 184 NOAEL

Large Bird (4 kg) 9E-07 2E-08 6E-06 184 NOAEL

1 Application rate: .11 lb a.e./acre. 

CEN=Central; END=Endpoint; HQ=Hazard Quotient; LOW=Lower; TOX=Toxicity; UP=Upper; VAL=Value

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Table 3.16-5 Summary of Hazard Quotients for Terrestrial Wildlife – Clethodim

Receptor CEN 

HQ1

LOW 

HQ1

UP 

HQ1

TOX 

VAL

TOX 

END

Accidental Acute Exposures

Direct Spray 100% absorption

Honey Bee 5E-02 5E-02 5E-02 860 NOEC

Non-Accidental Acute Exposures

Contaminated Fruit [Lowest Residue Rates]

Larger Mammal (400g) 9E-03 1E-03 3E-02 100 NOAEL

Large Mammal (70 kg) 5E-03 7E-04 2E-02 100 NOAEL

Small bird (10g) 9E-03 1E-03 3E-02 950 NOAEL

Large Bird (4 kg) 1E-03 1E-04 4E-03 950 NOAEL

Contaminated Broadleaf Foliage

Large Mammal (70 kg) 2E-02 2E-03 0.1 100 NOAEL

Insect

Contaminated Tall Grass

Large Mammal (70 kg) 2E-02 2E-03 0.1 100 NOAEL

Contaminated Short Grass [Highest Residue Rate]

Large Mammal (70 kg) 5E-02 5E-03 0.2 100 NOAEL

Contaminated Water

Small mammal (20g) 1E-05 5E-09 2E-04 100 NOAEL

Canid (5 kg) 6E-06 3E-09 1E-04 100 NOAEL

Large Mammal (70 kg) 5E-06 2E-09 9E-05 100 NOAEL

Small bird (10g) 2E-06 1E-09 4E-05 950 NOAEL

Large Bird (4 kg) 3E-07 1E-10 5E-06 950 NOAEL

Contaminated Insects

Small mammal (20g) 5E-02 5E-03 0.2 100 NOAEL

Small bird (10g) 1E-02 1E-03 6E-02 950 NOAEL

Consumption of small mammal (after direct spray) by predator

Canid (5 kg) 7E-03 2E-03 1E-02 100 NOAEL

Carnivorous bird (640 g) 8E-04 3E-04 1E-03 950 NOAEL

Chronic/Longer-Term Exposures

Contaminated Fruit [Lowest Residue Rates]

Larger Mammal (400g) 4E-03 6E-04 2E-02 19 NOAEL

Large Mammal (70 kg) 3E-03 3E-04 1E-02 19 NOAEL

Small bird (10g) 4E-02 5E-03 0.2 20 NOAEL

Large Bird (4 kg) 5E-03 6E-04 2E-02 20 NOAEL

Contaminated Broadleaf Foliage

Large Mammal (70 kg) 1E-02 1E-03 7E-02 19 NOAEL

Contaminated Tall Grass

Large Mammal (70 kg) 1E-02 9E-04 5E-02 19 NOAEL

Contaminated Short Grass [Highest Residue Rate]

Large Mammal (70 kg) 2E-02 2E-03 0.1 19 NOAEL

Contaminated Water

Small mammal (20g) 2E-05 1E-08 6E-04 19 NOAEL

Canid (5 kg) 3E-04 1E-07 6E-03 1 NOAEL

Large Mammal (70 kg) 1E-05 4E-09 3E-04 19 NOAEL

Small bird (10g) 4E-05 2E-08 1E-03 20 NOAEL

Large Bird (4 kg) 6E-06 2E-09 1E-04 20 NOAEL

1 Application rate: .25 lb a.e./acre. 

CEN=Central; END=Endpoint; HQ=Hazard Quotient; LOW=Lower; TOX=Toxicity; UP=Upper; VAL=Value

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Valley Elderberry Longhorn Beetle: Affected Environment

Species and Habitat Account

The valley elderberry longhorn beetle (Desmocerus californicus dimorphus) is listed as Threatened 

under the Endangered Species Act. There is no Designated Critical Habitat on the STF. The valley 

elderberry beetle (VELB) is thought to range from the Central Valley into the eastern portion of the 

Coast Range and the foothills of the Sierra Nevada up to approximately 3,000 feet (USFWS 1999). 

This species is most often found along the margins of rivers and streams in the lower Sacramento 

River and upper San Joaquin Valley. The current known range of the VELB extends from southern 

Shasta County south to Fresno County (Barr 1991). 

Habitat for the VELB consists of elderberry shrubs and trees in a variety of habitats and plant 

communities, but most often in riparian, elderberry savannah or moist valley oak woodlands. 

Common associated plants include Populus spp., Salix spp., Fraxinus spp., Quercus spp., Juglans 

spp., Acer negundo, Rubus spp., Toxicodendron diversiloba, Vitis californica, Rosa spp., and 

Baccharis spp. (USFWS 2006). VELB appear to favor sites with high elderberry densities and are 

limited in their ability to disperse and colonization new sites (Collinge et al. 2001).

Valley elderberry longhorn beetles have not been observed or documented on the STF; however, 

presence is assumed where elderberry plants with stems greater than 1 inch at the base are found.

Most of the elderberry plants damaged by the Rim Fire have resprouted and some have actually 

grown so quickly they are of adequate size to host elderberry beetles (Baumbach pers. obs.). All 

proposed treatment units at or below 3,000 foot elevation have been surveyed. Three elderberry 

shrubs were found in one proposed reforestation unit (Z030). All three plants are resprouts from 

plants burned at high severity in the Rim Fire and no exits holes were observed. The nearest 

documented VELB occurrence was one beetle on an elderberry shrub almost 24 miles to the west of 

the fire near Jamestown in 2002.

Eggs are laid in late spring on elderberry stems greater than 1 inch in diameter on healthy and 

unstressed plants. Larvae excavate passages into the elderberry shrub where they may remain in larval 

form for as long as two years before they emerge as adults. Exit holes are usually on stems greater 

than 0.5 inches in diameter, with 70% of the exit holes at heights of 4 feet or greater; these holes are 

circular to slightly oval, with a diameter of 7 to 10 mm (Barr 1991). 

VELB has been found only in association with its host plant, elderberry. Adults feed on the foliage 

and perhaps flowers of elderberry plants, and are present from March through early June (Barr 1991). 

About 25,413 acres of potential elderberry habitat is below 3,000 foot elevation within the analysis 

area. About 25,517 acres of potential elderberry habitat is within the cumulative analysis area, mainly 

in the river canyons where treatments are not proposed. 

RISK FACTORS IDENTIFIED FOR VELB

1. Loss or alteration of habitat- The primary threat to survival of VELB is the loss or alteration of 

habitat. Stream development and urbanization have resulted in the removal of significant amounts 

of suitable habitat. On NFS lands, cattle grazing has heavily damaged elderberry in some areas 

and may reduce the quantity and quality of available habitat.

2. Pesticides and Herbicides- Individual beetles, localized beetle populations, and plants are subject 

to injury or loss from pesticide applications. Pesticides pose a risk to the VELB and its host plant. 

Some chemicals from the valley are known to drift upslope and into the Sierra on prevailing wind 

currents (McConnell et al. 1998, Bradford et al. 2010). Smaller amounts of pesticides and 

herbicides are used in the local area by the Forest Service to control shrubs and noxious weeds, 

and lesser amounts are used by surrounding local landowners. 

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3. Predation- Predation by birds, other insects and small mammals may have negative effects on 

localized populations. 

4. Argentine Ant- The widely established non-native Argentine Ant (Linepithema humile) also 

poses a threat to VELB. While Argentine Ants are common in the core valley habitat of the 

VELB, it does not appear to be widely established in the Sierra foothills, likely due to summer 

drought or winter cold. 

MANAGEMENT DIRECTION

Conservation Guidelines for VELB are provided in USFWS (1999). While there is no Designated 

Critical Habitat on the STF, habitat exists and so there is the potential for the beetle to occur on the 

forest. Chapter 2.02 identifies the management requirements that would mitigate adverse effects to 

this species under the proposed action and are consistent with the VELB Conservation Measures 

(USFWS 1999).

Valley Elderberry Longhorn Beetle: Environmental Consequences

The project action alternatives could result in direct and indirect effects to the VELB through the 

following activities:

 Site preparation for planting conifers (e.g., dozer piling or herbicide application). 

 Broadcast prescribed fire or pile burning. 

These direct and indirect effects include: 

 Project related death, injury and disturbance. 

 Project related modifications to habitat quality.

Death, Injury and Disturbance

Death or injury of larvae and elderberry shrubs from project related mechanical activities would be 

unlikely to occur given the mechanical activity buffers around elderberry plants and Limited 

Operating Periods (LOPs) which would eliminate the potential for dust and smoke impacts. Death or 

injury from herbicide application would be unlikely to occur given the prohibition of spraying 

elderberry shrubs and the 100 foot buffer protecting each shrub. Larvae and the elderberry plants 

would be protected by these buffers. Prescribed burning operations in unit Z030 has the potential to 

burn individual plants; however, vegetation around existing plants would be pulled back so the risk is 

considered extremely low.

Project Related Modifications to Habitat Quality

No modification of habitat quality is expected from mechanical treatments or pile burning because all 

identified elderberry plants with stems greater than one inch in diameter would have a buffer 

prohibiting mechanical activities within ten feet of shrubs. There is a very low risk of the loss of 

individual shrubs during prescribed fire operations because vegetation surrounding individual shrubs 

would be pulled away from the shrubs. 

Indicators

The following indicators were chosen to provide a relative measure of the direct and indirect effects 

to the VELB and to determine how well project alternatives comply with the species’ conservation 

strategy.

1. Disturbance potential

2. Habitat alteration potential

3. Toxicological effects from herbicide use

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Alternatives 1, 3 and 5

Because the reforestation treatment areas proposed under Alternatives 1, 3 and 5 are the same, the 

effects for indicators 1 and 2 are expected to be the same and are therefore analyzed together.

DIRECT AND INDIRECT EFFECTS

Three elderberry shrubs exist within proposed treatment unit Z030. Contractors will be briefed on the 

need to avoid damaging the elderberry plants and the possible penalties for not complying with these 

requirements. All crews working in the area would be instructed on the status of the beetle and the 

need to protect its host plant. 

Indicator 1

Because virtually all of the VELB lifecycle is spent on elderberry shrubs, either inside the stems as 

larvae or on the foliage or flowers as adults, the greatest risk to individuals would come from 

activities in the immediate vicinity of elderberry plants.

Buffers applied to individual plants where no mechanical activity would occur and LOPs during the 

adult flight period restricting activities would eliminate almost all risk to individuals associated with 

project implementation. 

Buffers applied prohibiting herbicide application within 100 feet of elderberry shrubs would provide 

protection to plants and individual larvae and beetles. Because elderberry beetles are found only in 

association with elderberry plants, there is an extremely low risk of beetles coming in contact with 

herbicides on other species of plant.

Given the mitigation measures in place, the potential for death or injury of individual plants, larvae or 

adult beetles is either insignificant (i.e., cannot be meaningfully measured, detected or evaluated) or 

discountable (i.e., extremely unlikely to occur). 

Indicator 2

Similar to indicator 1, buffers applied to individual shrubs would eliminate almost all risk of habitat 

alteration and effects to individual elderberry shrubs. Additionally, pulling back vegetation away 

from individual shrubs would eliminate almost all risk to shrubs from prescribed fire operations. 

Operating heavy equipment may result in excess deposition of dust and other particulate matter on 

individual plants; however, a study of proximity to roads and dust impacts to elderberry plants found 

no evidence of negative effects (Talley et al. 2006). 

Based on the above analysis and the fact that no elderberry beetles have been documented in the 

project area or the forest, the potential for disturbance or habitat alteration with respect to VELB is 

either insignificant (i.e., cannot be meaningfully measured, detected, or evaluated) or discountable 

(i.e., extremely unlikely to occur). 

CUMULATIVE EFFECTS

Appendix B identifies the present and reasonably foreseeable future actions on all lands within the 

analysis area. Some, but not all of these actions have or may contribute cumulatively to effects on 

VELB. 

Habitat modification was used as a relative measure of cumulative effects of the action alternatives.

The potential habitat area below 3,000 foot elevation is almost entirely within the Tuolumne River 

Canyon and its tributaries, and a small portion of Grapevine Creek, which is managed by the Forest 

Service and the Bureau of Land Management. Much of the Tuolumne River aside from the HetchHetchy facilities are designated and managed as Wild and Scenic River. 

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Habitat Modification

Federal Lands: The Rim Hazard Tree Removal project and the Rim Recovery project are the only two 

present actions on public lands within the potential habitat area. The actions presently underway 

include about 152 acres of tractor or hand piling and burning associated with the Rim Recovery 

project and about 827 acres of tractor piling associated with the Hazard Tree Removal project. These 

projects are not likely to affect habitat suitability for VELB because management requirements 

approved by USFWS are in place and will protect elderberry plants and the VELB. 

Livestock grazing is both a present and foreseeable future action on federal lands within potential 

habitat area. Cattle grazing has heavily damaged elderberry in some areas and may reduce the 

quantity and quality of available habitat across about 12,126 acres within the analysis area. 

Private Lands: The cumulative effects analysis area contains private timberland, residential areas and 

rangeland below 3,000 feet where elderberry plants and beetles may occur. Some of the private 

inholdings include meadows and associated riparian habitat that may support elderberry shrubs. 

Power plants, dams, powerlines and other facilities associated with Hetch-Hetchy also exist in the 

Tuolumne River Canyon and Cherry Creek within the elevation range of VELB. Some of this 

infrastructure intersects with NFS lands and is under special use permits.

Seven acres of NFS lands have a future special use permit proposed for vegetation treatments 

associated with the Reliable Power Project. About two acres of shredding or mastication and 5 acres 

of chemical application to control vegetation under powerlines have been proposed. Reliable Power 

would establish an agreement, if one is not already in place, with USFWS regarding VELB and their 

habitat and are expected to adhere to those requirements as part of their special use permit.

No other present or foreseeable future actions are proposed on private lands within the potential 

habitat area.

Alternatives 1, 3 and 5 Contribution and Summary

Because the Rim Reforestation project is not expected to result in any measurable effects to VELB, it 

is not expected to contribute to cumulative effects.

Alternatives 1 and 5

DIRECT AND INDIRECT EFFECTS

Indicator 3

Under Alternatives 1 and 5, herbicide use is expected to have no toxicological effects upon VELB 

because a buffer of 100 feet around all three elderberry shrubs in unit Z030 would be utilized. 

CUMULATIVE EFFECTS

Because the Rim Reforestation project is not expected to result in any measurable effects to VELB, it 

is not expected to contribute to cumulative effects.

Alternative 2

DIRECT AND INDIRECT EFFECTS

Under No Action, death, injury and disturbance would not be an issue because no active management 

would occur. 

The indirect effects of Alternative 2 are primarily related to the influence no action may have on 

future wildfires and how future wildfires may impact VELB habitat.

Indicator 1

Because no management activities would occur under this alternative, no project related direct effects 

to individual valley elderberry longhorn beetles or larvae or elderberry shrubs would occur. 

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Indicator 2

Within the areas that burned at high severity, elderberry shrubs and other herbaceous and shrub 

vegetation have become somewhat reestablished over the past two years. This vegetation is expected 

to continue to reestablish itself over the next two to three years. Elderberry shrubs that are of 

appropriate size for beetle and larvae occupancy can provide suitable habitat for VELB. These 

benefits are expected in the short-term (10 to 20 years). Elderberry shrubs are expected to be 

vulnerable to loss in a future wildfire; but these plants are expected to resprout vigorously as they 

have done after previous fire events.

Indicator 3

Because no herbicides are proposed under this alternative, no exposure to herbicides and no direct, 

indirect or cumulative toxicological effects would occur under this alternative. 

CUMULATIVE EFFECTS

The cumulative effects analysis discussion under Alternatives 1, 3 and 5 outlines those present and 

foreseeable future activities scheduled on public and private lands considered under this alternative.

Alternative 2 Contribution and Summary

The cumulative contribution of Alternative 2 is attributed to the influence no action would have on 

how future wildfires may adversely impact elderberry habitat. Elderberry shrubs are expected to be 

vulnerable to loss in a future wildfire; but these plants are expected to resprout vigorously as they 

have done after previous fire events.

Alternative 3 

Indicator 3

Because no herbicides are proposed under this alternative, no exposure to herbicides and no direct, 

indirect or cumulative toxicological effects to VELB would occur under this alternative. 

Alternative 4

No management activities are proposed where elderberry shrubs occur; therefore, direct, indirect, and 

cumulative effects are expected to be the same as those described under the No Action alternative.

Valley Elderberry Longhorn Beetle: Summary of Effects

Alternatives 1, 3 and 5 would be unlikely to have any adverse direct or indirect effects to the VELB. 

All elderberry plants capable of supporting VELB would be flagged and avoided. LOPs or buffers 

would be in place under Alternatives 1, 3 and 5 to eliminate negative impacts from dust, smoke or 

herbicides. No management activities occur within habitat under Alternative 4; therefore, effects are 

expected to be the same as under the No Action alternative.

Determinations 

Implementing the Rim Reforestation Project Alternatives 1, 3 or 5 has very little potential to impact 

individual valley elderberry longhorn beetles and the elderberry habitat required by the species. The 

surveys and buffers established around individual plants and project management requirements would 

greatly reduce the potential risk associated with direct and indirect effects to individual VELB or 

associated elderberry plants. The project does not occur within Designated Critical Habitat for the 

species and would have no effect on critical habitat; however, the primary constituent elements occur 

within and adjacent to the project area indicating suitable habitat is present. Therefore, the following 

determinations are supported by this analysis. Specifically, the potential for effects to VELB from 

implementation of the alternatives are either discountable (i.e. extremely unlikely to occur) or 

insignificant (i.e. cannot be meaningfully measured, detected or evaluated).

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ALTERNATIVES 1 AND 5 

Alternatives 1 and 5 may affect but are not likely to adversely affect the valley elderberry longhorn 

beetle. Alternatives 1 and 5 would not affect Designated Critical Habitat for the valley elderberry 

longhorn beetle. This is based on the following rationale: 

 The valley elderberry longhorn beetle has never been documented to occur on the STF. 

(discountable effect)

 All elderberry plants greater than one inch stem diameter would be flagged and avoided where 

they occur (unit Z030). (discountable effect) 

 Any ground based mechanical equipment operations or burning within 10 feet of elderberry 

plants would be prohibited. (discountable effect) 

 Herbicide application within 100 of elderberry shrubs with stems greater than 1 inch dbh is 

prohibited. 

 Pile and broadcast burning, and mechanical activities within 100 feet of flagged shrubs would be 

subject to an LOP from April 1 through June 30 to prevent smoke or dust impacts to beetles. 

(discountable effect)

ALTERNATIVES 2 AND 4 

Alternatives 2 and 4 may affect but are not likely to adversely affect the valley elderberry longhorn 

beetle. Alternatives 2 and 4 would not affect Designated Critical Habitat for the valley elderberry 

longhorn beetle. This is based on the following rationale: 

 The valley elderberry longhorn beetle has never been documented to occur on the STF. 

 There is potential for loss of habitat or individuals in a future fire (natural or human caused). 

ALTERNATIVE 3 

Alternative 3 may affect but is not likely to adversely affect the valley elderberry longhorn beetle. 

Alternative 3 would not affect Designated Critical Habitat for the valley elderberry longhorn beetle.

This is based on the following rationale:

 The VELB has never been documented to occur on the STF. (discountable effect)

 All elderberry plants greater than one inch stem diameter would be flagged and avoided where 

they occur (unit Z030). (discountable effect) 

 Any ground based mechanical equipment operations and burning within 10 feet of elderberry 

plants would be prohibited. (discountable effect)

 Pile and broadcast burning, and mechanical activities within 100 feet of flagged shrubs would be 

subject to an LOP from April 1 through June 30 to prevent smoke or dust impacts to beetles. 

(discountable effect)

Further rationale for determinations:

Guidance provided in the Endangered Species Consultation Handbook (USFWS and NMFS 1998, 

page 3 to12) indicates that “MAY AFFECT BUT IS NOT LIKELY TO ADVERSELY AFFECT” is 

the appropriate conclusion when effects on listed species are expected to be discountable, or 

insignificant, or completely beneficial. Discountable effects are those that are extremely unlikely to 

occur. Insignificant effects relate to the size of the impact and should never reach the scale where take 

occurs. Beneficial effects are positive effects without adverse effects to the species.

Valley Elderberry Longhorn Beetle: Compliance

The action alternatives would not affect the recovery plan objectives for the VELB. The recovery 

plan objectives for VELB are to minimize further degradation, development or environmental 

modification of VELB habitat, and to delist the VELB (USFWS 1984). 

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Bald Eagle: Affected Environment

Species and Habitat Account

The bald eagle (Haliaeetus leucocephalus) is a Region 5 Forest Service Sensitive species. The bald 

eagle breeds primarily in specific and localized large rivers and lakes of the northern third of 

California, with scattered nesting throughout the state. 

Bald eagles typically nest in live trees, some with dead tops, and build a large (approximately 6 foot 

diameter), generally flat-topped and cone-shaped nest usually below the top with some cover above 

the nest (Jackman and Jenkins 2004). In general, bald eagles require a large tree to accommodate a 

large nest in a relatively secluded location within the range of their tolerance of human disturbance 

(Ibid). Diurnal perch habitat is characterized by the presence of tall, easily accessible; often 

predominate trees adjacent to shoreline foraging habitat (Buehler 2000). The entire breeding cycle, 

from initial activity at a nest through the period of fledgling dependency, is about 8 months (Ibid). 

The project is within the current distribution of bald eagles in California. The one bald eagle nest site 

in the project area and is located at Cherry Lake. This site has been occupied for more than 16 years. 

Although nest trees have changed over this period, the nest site has consistently been in the same 

general stand on the Cherry Lake shoreline. The post-fire condition of the nest, nest tree, and nest 

stand all appear intact and suitable (Baumbach, pers.obs.). After over 16 years of being occupied as a 

bald eagle territory, it appears the carrying capacity of Cherry Lake is limited to one pair of breeding 

bald eagles. Bald eagles also use the Cherry Lake area during migration and for overwintering (NRIS 

Wildlife database). No treatments are proposed within one half mile of this nest site; therefore, an 

LOP for this species is not required. The nearest unit is about one mile south of the current nest site.

RISK FACTORS

USDA (2001) summarized risk factors potentially influencing bald eagle abundance and distribution: 

1. Nest site loss and disturbance.

2. Loss of habitat and habitat components such as potential nest or roost trees. 

MANAGEMENT DIRECTION

Current management direction for bald eagle is to follow all law, regulation, and policy as it relates to 

bald eagle because the species is still vulnerable to potential disturbance impacts and is still within the 

delisting monitoring period (R5 Sensitive species evaluation form of 2012). Forest Plan Direction 

(2010) p.43 states: When nesting bald eagles are found, implement suitable restrictions on nearby 

activities based on the Regional habitat management guidelines and the habitat capability model for 

the species. Protect all historic and active nests, as required by the Eagle Protection Act and the 

Migratory Bird Treaty Act.

The Eagle Protection Act (16 U.S.C. 668-668c), enacted in 1940, and amended several times since 

then, prohibits anyone, without a permit issued by the Secretary of the Interior, from “taking” bald 

eagles, including their parts, nests, or eggs. The Act provides criminal and civil penalties for persons 

who disturb nest sites by substantially interfering with normal breeding, feeding, or sheltering 

behavior (USFWS 2007). 

The Migratory Bird Treaty Act (MBTA), 16 U.S.C. 703-712, prohibits the taking of any migratory 

bird or any part, nest, or egg, except as permitted by regulation. The MBTA was enacted in 1918; a 

1972 agreement supplementing one of the bilateral treaties underlying the MBTA had the effect of 

expanding the scope of the Act to cover bald eagles and other raptors. 

Habitat management guidelines to follow for bald eagle are provided by the National Bald Eagle 

Management Guidelines (USFWS 2007). 

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Bald Eagle: Environmental Consequences

The project alternatives could result in direct and indirect effects to the bald eagle through the 

following activities:

 Mechanical site preparation for planting.

 Herbicide application for conifer survival and growth. 

 Planting conifers.

These direct and indirect effects include:

 Project related death, injury and disturbance. 

 Project related modifications to habitat quantity and/or quality.

Death, Injury and Disturbance

Death, injury, and disturbance are potential direct effects to consider for bald eagle (USDA 2004). 

Disturbance issues are expected to be most pronounced within a half mile of nests (USFWS 2007). 

No activities are proposed within one half mile of the known nest site at Cherry Lake. Therefore, the 

risk of death, injury, or disturbance from project activities is extremely low. Human presence related 

to proposed activities more than one mile from the nest site is not likely to change normal behavior or 

impair essential behavior patterns of the bald eagle related to breeding, feeding, or sheltering. While 

herbicide application in new plantations is unlikely to affect bald eagles directly, small mammals and 

birds eaten by eagles have the potential to be exposed to herbicides and therefore could result in bald 

eagle exposure if consuming exposed prey. This scenario is considered highly unlikely and the risk 

extremely low.

Habitat Modification

Planting conifers is proposed within 500 feet of Cherry Lake which is within an area bald eagles 

could use to nest and forage. Bald eagles focus nesting, roosting and perching behaviors along 

shorelines and habitat modification effects are expected to be most pronounced within 500 feet of 

lake shorelines (Jackman and Jenkins 2004). Bald eagles will roost and perch in relatively small trees, 

while the average nest tree size documented in California used by bald eagles is 43 inches dbh and 

131 feet tall (Lehman 1979).

Indicators

The following indicators were chosen to provide a relative measure of the direct and indirect effects 

to the bald eagle and to determine how well project alternatives comply with Forest Plan Direction.

1. Treatments within 500 feet of lake shorelines.

2. Toxicological effects from herbicide use. 

This criterion was chosen based on the best available scientific literature which focuses on various 

aspects of bald eagle ecology and life history requirements. This criterion focuses on the life history 

aspects, or habitat elements, considered most limiting to bald eagle persistence across their range and 

where project effects are expected.

Alternatives 1, 3 and 5

Because there is no difference in areas proposed for reforestation or thinning, under these three 

alternatives, the effects are expected to be similar and are analyzed together. The differences in 

herbicides proposed between Alternatives 1 and 5 versus Alternative 3 were separated below 

accordingly.

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DIRECT AND INDIRECT EFFECTS

Indicator 1 

Only a small portion of one reforestation unit (24 acres) occurs within 500 feet of Cherry Lake. In the 

short-term, up to 20 years, the planted area would provide little benefit to eagles because the trees 

would be of small size and would not contribute to roosting or perching habitat. In the long-term, 

benefits to eagles include additional perch and roost sites adjacent to the shoreline. It is unlikely that 

trees would grow to a sufficient size to be used as nesting trees until well beyond 50 years. Several 

existing plantation units near Cherry Lake are proposed for thinning and the removal of dead 

material, pockets of mortality from the Rim Fire. Thinning these plantations is expected to result in 

accelerated growth rates in remaining trees, providing additional nest, perch and roosting trees sooner 

than without treatments. Additionally, removal of dead material would result in reduced fuel loading. 

The combination of treatments is expected to improve the resiliency of these stands when fire returns 

to this landscape.

Indicator 2

Under Alternatives 1 and 5, herbicide use is expected to have a limited potential for direct or indirect 

toxicological effects on bald eagles as described under the herbicide risk assessment section. Because 

no herbicides are proposed under Alternative 3, no exposure to herbicides and no direct, indirect, or 

cumulative toxicological effects to bald eagles would occur under this alternative.

CUMULATIVE EFFECTS

Appendix B identifies the present and reasonably foreseeable future actions on all the lands within the 

analysis area including non-Forest Service and private. Some, but not all of these actions have or may 

contribute cumulatively to effects on bald eagles.

Based on risk factors affecting bald eagle, the following relevant evaluation criteria were used as 

relative measures of cumulative effects from this alternative to eagles: disturbance, nest and roost site 

availability, and toxicological effects.

Disturbance

Federal Lands: Recreational use adjacent to Cherry Lake is the only present and foreseeable action 

and it is limited to existing and mostly quiet uses in this area (i.e. primarily trailhead parking, motor 

boats and hiking). Based on continued nesting by the bald eagles at this location, these recreation 

activities do not affect bald eagle behavior.

Private Lands: No private land activities exist within one half mile of the known nest site or within 

500 feet of Cherry Lake. 

Nest and Roost Site Availability

No present or foreseeable future federal or private activities are proposed in close proximity to Cherry 

Lake that would affect the availability of nest and roost sites for bald eagles.

Toxicological Effects

Federal Lands: One present federal action of herbicide use on 0.5 acres under the Rim Fire 

Rehabilitation project and two foreseeable federal actions of herbicide use: 8.0 acres under the 

Twomile Ecological Restoration Noxious Weed project and 23 acres under a special use permit for 

the Reliable Power Project powerline. No other present or foreseeable future federal actions are 

related to herbicide use. 

Private Lands: Herbicide use is proposed on 1,583 acres of private land within the project area in 

2017. No other present or foreseeable future actions are proposed on private lands related to herbicide 

application. 

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Alternatives 1, 3 and 5 Contribution and Summary

The limited scope and duration of treatments under these alternatives is not expected to cumulatively 

contribute to disturbance effects to bald eagles. Planting conifers adjacent to Cherry Lake would 

provide potential nest, perch and roost sites for bald eagles in the long-term. Thinning plantations and 

removing dead material would result in faster growth rates of remaining trees and increasing the 

resiliency of these stands, reducing the risk of loss when fire returns to this area. There is limited 

potential for toxicological effects from herbicide use to bald eagles under Alternatives 1 and 5. The 

cumulative contribution of these alternatives on bald eagles is considered minor and is not expected to 

affect the viability of this species.

Alternative 2

DIRECT AND INDIRECT EFFECTS

Under No Action, death, injury and disturbance would not be an issue because no active management 

would occur. 

Indicator 1

The indirect effects of no action are primarily related to the influence no action may have on the 

amount and location of suitable forested habitat available to bald eagles adjacent to Cherry Lake. 

Under Alternative 2, no management activities would occur within 500 feet of Cherry Lake. The only 

tree expansion into this area could occur as a result of natural regeneration. Because no active 

management would occur, it is unknown where naturally regenerating forest would occur. It is likely 

that areas in close proximity to live trees (i.e. seed source) would experience forest expansion to a 

limited degree. If plantations near Cherry Lake are not treated these stands may be at increased risk of 

loss when fire returns to the landscape, which would negatively affect bald eagles in the area.

Indicator 2

Because no herbicides are proposed under this alternative, no exposure to herbicides and no direct, 

indirect, or cumulative toxicological effects to bald eagles would occur under this alternative.

CUMULATIVE EFFECTS

The cumulative effects discussion under Alternatives 1, 3 and 5 outlines those present and foreseeable 

future activities scheduled on public and private lands.

Alternative 2 Contribution/Summary

Alternative 2 is not expected to contribute to direct, indirect, or cumulative effects related to 

disturbance. There may be indirect consequences under this alternative primarily related to the 

influence no action may have on forest development and plantation resiliency adjacent to Cherry 

Lake and how that may impact bald eagles. It is unknown how much and when natural forest 

recovery would occur adjacent to Cherry Lake, which could delay the availability of nest, perch and 

roost sites in the area. The older plantations adjacent to Cherry Lake may be at greater risk of loss 

when fire returns. Alternative 2 cumulative contributions to effects on bald eagles are considered 

minor and are not expected to affect the viability of this species. 

Alternative 4

DIRECT AND INDIRECT EFFECTS

Indicator 1

Under Alternative 4, no reforestation is proposed within 500 feet of Cherry Lake. Plantation units 

near Cherry Lake are proposed for treatments under this alternative. The prescriptions and effects are 

expected to be the same as described under Alternatives 1, 3 and 5.

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Indicator 2

The herbicide use proposed under Alternative 4 is expected to have a limited potential for direct or 

indirect toxicological effects on bald eagles as described under the herbicide risk assessment section.

CUMULATIVE EFFECTS

The cumulative effects discussion under Alternatives 1, 3 and 5 outlines those present and foreseeable 

future activities scheduled on public and private lands.

Alternative 4 Contribution/Summary

Alternative 4 is not expected to contribute to direct, indirect, or cumulative effects related to 

disturbance. The indirect consequence under this alternative is related to the influence not reforesting 

areas adjacent to Cherry Lake would impact bald eagles. It is unknown how much and when natural 

forest recovery would occur adjacent to Cherry Lake, which could delay the availability of nest, 

perch, and roost sites in the area. Thinning plantations and removing dead material would result in 

faster growth rates of remaining trees and increasing the resiliency of these stands, reducing the risk 

of loss when fire returns to this area. There is limited potential for toxicological effects from herbicide

use to bald eagles under Alternative 4. The cumulative contribution of this alternative on bald eagles

is considered minor and is not expected to affect the viability of this species.

Bald Eagle: Summary of Effects

Effects to bald eagles under all action alternatives are considered negligible to minor. Alternatives 1, 

3 and 5 would result in the accelerated development of forested habitat adjacent to Chery Lake, which 

would more quickly benefit bald eagles using this area. Thinning of existing plantations is the same 

under all action alternatives and is expected to benefit bald eagles through the accelerated growth of 

remaining trees and resiliency when fire returns to the landscape.

Determinations

ALTERNATIVES 1 AND 5 

Alternatives 1 and 5 may affect individuals but are not likely to result in a trend toward Federal listing 

or loss of viability for the bald eagle. This determination is based on the following rationale: 

 These alternatives include actions to accelerate the development of forested habitat adjacent to 

Cherry Lake, an occupied bald eagle territory.

 These alternatives would improve existing plantation conditions by accelerating growth rates of 

potential nest, perch and roost trees and improving stand resilience when fire returns. 

 These alternatives may result in negligible affects from herbicide use.

ALTERNATIVE 2 

Alternative 2 may affect individuals but are not likely to result in a trend toward Federal listing or 

loss of viability for the bald eagle. This determination is based on the following rationale:

 No actions would occur to potentially impact this species or habitat. However, with no action to 

thin plantations or accelerate the development of important habitat elements such as perch, roost 

or nest sites adjacent to Cherry Lake, habitat recovery would be delayed and plantations are at 

greater risk of loss from fire.

ALTERNATIVE 3 

Alternative 3 may affect individuals but is not likely to result in a trend toward Federal listing or loss 

of viability for the bald eagle. This determination is based on the following rationale:

 This alternative includes actions to accelerate the development of forested habitat adjacent to 

Cherry Lake, an occupied bald eagle territory.

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 This alternative would improve existing plantation conditions by accelerating growth rates of 

potential nest, perch and roost trees and improving stand resilience when fire returns. 

ALTERNATIVE 4 

Alternative 4 may affect individuals but is not likely to result in a trend toward Federal listing or loss 

of viability for the bald eagle. This determination is based on the following rationale:

 This alternative does not include actions to accelerate the development of forested habitat 

adjacent to Cherry Lake, an occupied bald eagle territory.

 This alternative would improve existing plantation conditions by accelerating growth rates of 

potential nest, perch, and roost trees and improving stand resilience when fire returns.

 This alternative may result in negligible affects from herbicide use.

Bald Eagle: Compliance

This project complies with forest plan direction and the National Bald Eagle Management Guidelines 

(USFWS 2007).

California Spotted Owl: Affected Environment

Species and Habitat Account

The California spotted owl (Strix occidentalis occidentalis) is a Region 5 Forest Service Sensitive 

species and is also a Sierra Nevada Management Indicator Species (MIS). They are listed with the 

State of California as a Species of Special Concern. The California spotted owl occurs from the 

southern Cascades, throughout the Sierra Nevada in California and into Nevada, mountainous regions 

of southern California and the central Coast Ranges up to Monterey County (USDA 2001). They 

breed from 1,000 to 7,700 feet elevation. On the west slope of the Sierra Nevada, they use a wide 

range of habitat types and are considered year round residents (Ibid). 

On December 23, 2014, a petition to list the California Spotted Owl was submitted to the USFWS. 

USFWS has not published information in the Federal Register to date and the USFWS website has 

identified this species as “under review” (USFWS 2015).

The most recent population status and trend information can be found in Keane 2014, Conner et al. 

2013, Tempel and Gutiérrez 2013, and Tempel et al. 2014. In summary, the most recent estimate of 

population size for California spotted owls in the Sierra Nevada reported 1865 owl sites, with 1399 

sites on NFS lands. Ongoing research of recent population trends indicates increasing evidence for 

population declines on the three demographic study areas on NFS lands and a stable or increasing 

population on the National Park study area, (Conner et al. 2013, Tempel and Gutiérrez 2013, Tempel 

et al. 2014). The factors driving these population trends are not known (Keane 2014). 

California spotted owl sites are identified through the use of protocol surveys (USDA March 12, 

1991). Protocol surveys have been conducted throughout the Rim Fire area for the past two decades. 

These surveys are best described as opportunistic depending upon planned activities and funding 

levels but have occurred at a level such that inventory information for the analysis area is considered 

essentially complete. 

The project action area is within the area of current distribution of spotted owls across the Sierra 

Nevada Bioregion. Currently, 44 spotted owl territories exist within the project area; this includes two 

new territories documented post-fire. LOPs will be placed around all documented spotted owl 

protected activity centers from March 1-August 15 of any given year during project implementation. 

California spotted owls are top trophic-level avian predators associated with heterogeneous forests 

characterized by areas with large trees, large snags, and large down woody material (North et al. 

2009, Roberts and North 2012, Keane 2014). General habitat requirements for spotted owls include 

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forested environments with high canopy cover that feature vegetation types such as Montane 

Hardwood, Montane Hardwood Conifer, Ponderosa Pine, Douglas Fir, Sierran Mixed Conifer, and 

White Fir with trees in CWHR size classes 4 and 5 with greater than 40% canopy cover (CDFW 

2008). The most valuable habitat has trees greater than 24 inch dbh and canopy cover greater than 

70%. Approximately 50% of known owl sites are found in mixed conifer forest (USDA 2001). They 

prefer forested stands with complex vertical and horizontal vegetative structure. Recent research 

suggests that within their habitat matrix, spotted owls depend on “green” stands with the 

aforementioned characteristics for nesting, repeated roosting, and for foraging. Spotted owls use a 

broader range of vegetation conditions for foraging than they do for nesting and roosting (Ibid.), and 

this includes post-fire habitats as discussed below. Home range size for this species is highly variable 

and ranges from 2,500 acres on the Sierra National Forest, 4,700 acres on the Tahoe and Eldorado 

National Forests, and 9,000 acres on the Lassen National Forest (USDA 2001). About 39,957 acres of 

moderate to high capability habitat are within the analysis area. Suitable habitat has been greatly 

reduced in the heart of the analysis area and connectivity between large tracts of habitat on the forest 

and areas in Yosemite has been further reduced. This habitat fragmentation has reduced the 

probability of spotted owls accessing and utilizing all available habitat within the analysis area. Either 

natural regeneration recovery or forest management practices, such as planting, is needed to 

effectively reestablish connectivity and make suitable habitat readily available to spotted owls using 

this landscape. About 69,174 acres of moderate and high capability habitat are within the cumulative 

effects analysis area, including all ownerships. 

Moderate to High Capability habitat is defined as that in which a CWHR suitability rating is greater 

than or equal to 0.55. Two of three categories (reproduction, cover, food) must have a medium rating 

to achieve the minimum rating. Reference CWHR version 8.2 users’ manual for further explanation 

on suitability ratings (CDFW 2008). Acres include NFS lands only.

Breeding typically occurs in late winter to spring and is dependent on elevation and weather 

conditions. USDA (2001) cites six studies that summarize spotted owl nesting and roosting habitat 

preferences:

 70 to 95% total canopy cover at about 30 feet. 

 Two or more canopy layers.

 Dominant and co-dominant trees in the canopy averaging at least 24 inches dbh. 

 Total live basal area equal to 185 to 350 square feet per acre. 

 Total snag basal area equal to 30 to55 square feet per acre.

 Higher than average levels of snags, at least 15 inches dbh and 20 feet tall. 

 Downed woody debris averaging 10 to 15 tons per acre comprised of the largest logs. 

Spotted owls use several different nest types; natural cavities in standing trees (live or dead), broken 

top trees and snags, platform nests created by other species, on debris accumulations, and dwarf 

mistletoe brooms (Ibid). Blakesley and others (2005) report nest tree sizes range from 14 to 86 inches 

dbh, with 90% of these greater than 30 inches dbh. Data from the STF show trees or snags ranging 

from 24 to 56 inches dbh have been selected as nest trees (USDA 2015). 

Spotted owls consistently use forested stands with greater: canopy cover, total live basal tree area, 

basal area of hardwoods and conifers, snag basal area, and dead and downed wood, when compared 

to random locations (USDA 2001). Stands preferred by foraging owls consist of: 

 At least 50 to 90% canopy cover at about 30 feet. 

 At least two canopy layers.

 Dominant and co-dominant trees averaging at least 11 inches dbh.

 Total live tree basal area equal to 180 to 220 square feet per acre. 

 Total basal area of snags equal to 15 to 30 square feet per acre.

 Higher than average levels of snags, at least 15 inches dbh and 20 feet tall.

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 Downed woody debris averaging 10 to15 tons per acre, comprised of the largest logs.

Spotted owls typically hunt from elevated perches and will also hunt on the wing. Males will deliver 

food to nesting females, and both sexes cache excess prey for later consumption. The primary prey 

species at lower elevations are woodrats, and at higher elevations flying squirrels. They also prey 

upon gophers, bats, arthropods, and a variety of other rodents (CDFG 2008, Verner et al. 1992). 

Spotted owls show the strongest associations with mature forest conditions for nesting and roosting 

but will forage in a broader range of vegetation types (Keane 2014). Recent research indicates that 

California spotted owls will occupy landscapes that experience low-to moderate-severity wildfire, as 

well as areas with mixed-severity wildfire that include some proportion of high-severity fire (Bond et 

al. 2009, Bond et al. 2010, Roberts et al. 2011, Lee et al. 2012, Bond et al. 2013, Lee et al. 2013). It is 

important to note that because of the overall size and severity of the Rim Fire, many owl sites in the 

Rim Fire had far larger proportions of core areas burned at high severity relative to any of these 

studies. How owls use habitat for foraging where high severity patch sizes are relatively large, and the 

relationship of owl use to the amount and arrangement of burned-unburned edge, among other factors 

needs further study (such as the research PSW currently being conducting within the Rim Fire area). 

In the closely related Northern spotted owl, Clark (2007) found that while spotted owls did roost and 

forage within high severity burn areas, the use was very low suggesting that this cover type was poor 

habitat for spotted owls. Clark et al. (2013) summarized the results provided by the few studies that 

have been conducted on spotted owls in burned landscapes and noted that results were equivocal. 

Eyes (2014) found that overall, California spotted owls avoided high severity forest patches and used 

lower severity patches, similar to Clark (2007). In summary, uncertainties remain regarding long-term 

occupancy and demographic performance of spotted owls at burned sites (Keane 2014). Specifically, 

uncertainty exists regarding how the amounts and patch sizes of high-severity fire will affect 

California spotted owl occupancy, demographics, and habitat over long time frames (Ibid). Spotted 

owls continue to occupy the project area, and are consistently located roosting and nesting in green 

forest including areas that burned at low to moderate severities, not in areas where high severity fire 

removed virtually all canopy cover.

Dispersal distances for spotted owls are not well studied. Northern spotted owl juveniles are expected 

to disperse at least eight miles (USDA 2001). A study of natal dispersal in an insular population in 

southern California documented male dispersal distances ranged from 1.4 to 22.6 miles and female 

dispersal distances ranged from 0.25 to 22 miles (Lahaye et al. 2001). Breeding dispersal probability 

was found higher in younger owls, single owls, paired owls that lost their mates, owls at lower quality 

sites, and owls that failed to reproduce in the year preceding dispersal (Blakesley et al. 2006). 

Dispersal distances were similar in both males and females and ranged from 0.62 to 20.5 miles (Ibid). 

Spotted owls are not migratory but may move down slope to lower elevations during winter months. 

RISK FACTORS

USFWS (2006) and USDA (2001 and 2004) summarized risk factors potentially influencing 

California spotted owl distribution and abundance:

1. Habitat Loss – USFWS determined the primary threat to spotted owls is loss of habitat to highseverity wildfire that has resulted from fire suppression and past fire management policy. Habitat 

loss or modification from vegetation management and effects to the distribution, abundance and 

quality of habitat are also a concern. Logging since the turn of the century has resulted in a 

reduction in the amount and distribution of mature and older forests and specific habitat elements 

such as large trees, snags, and downed logs, used for nesting and foraging by California spotted 

owls.

2. Habitat Fragmentation - This is of particular concern on the STF because large inclusions of nonfederal lands pose uncertainty associated with maintaining a well-distributed spotted owl 

population. 

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3. Climate Change - Climatic changes resulting in wetter winters and springs can affect spotted owl 

reproductive output. 

4. Breeding Habitat Disturbance - Disturbance from recreation activities may interfere with owl 

fitness and nesting success.

5. Barred Owl - Expansion of barred owls has resulted in the introduction of a generalist species 

into the range of the spotted owl, a specialist species. The barred owl is considered a competitor 

for nesting habitat with the spotted owl and can also hybridize with the spotted owl (Dark et al. 

1998). No barred owls have been detected on the Stanislaus, but they do occur on the Eldorado 

National Forest to the north, and the Sequoia National Forest to the south. 

6. Disease - The effect of West Nile virus on owl populations is uncertain at this time because the 

disease was only recently detected in Tuolumne County (summer 2004). Given the mortality rates 

in similar avian species that have contracted West Nile Virus, a high mortality rate could be 

expected in infected spotted owls. 

California Spotted Owl: Environmental Consequences

The project alternatives could result in direct and indirect effects to the California spotted owl through 

the following activities:

 Mechanical site preparation for planting.

 Herbicide application for site preparation and release of conifers.

 Planting and thinning conifers. 

 These direct and indirect effects include: Project related death, injury and disturbance. 

 Project related modifications to habitat quantity and/or quality.

Death, Injury and Disturbance

Death, injury and disturbance are potential direct effects to consider for spotted owl (USDA 2004). 

Project activities have the potential to cause death or injury by tree-falling or by the use of heavy 

equipment. There is the potential for death or injury if nest trees are felled while being used by 

nesting birds during the reproductive season. The mobility of the species in question and the 

management requirement of LOPs, make it highly improbable that death or injury would occur as a 

result of project activities.

Project activities have the potential to cause disturbance through the use of loud machinery. Loud 

noise from equipment such as dozers, masticators, chain saws and even large crews of people on site 

at one time is expected throughout project implementation.. Loud noise has the potential to change 

normal behavior patterns during the period operations would take place and could potentially impair 

essential behavior patterns of the spotted owl related to breeding, feeding or sheltering. The potential 

for disturbance to breeding owls is minimized by the implementation of LOPs. 

Habitat Modification

California spotted owls are most closely associated with heterogeneous forests characterized by areas 

with large trees, large snags, and large down woody material (North et al. 2009, Roberts and North 

2012, Keane 2014). They prefer forested stands with complex vertical and horizontal vegetative 

structure. Research from the past several decades continues to suggest that within their habitat matrix, 

spotted owls depend on “green” stands with the aforementioned characteristics for nesting, repeated 

roosting, and for foraging. Habitat loss and fragmentation are known to be risk factors affecting 

spotted owl persistence across their range in the Sierra Nevada (USFWS 2006). Research indicates 

that successful territories (i.e., sustained survival and occupancy) have more than 300 acres of high 

quality forested habitat comprised of canopy cover greater than 70% (Draft Interim 

Recommendations for the Management of California Spotted Owl Habitat on National Forest System 

Lands, USDA 2015f). Additionally, territories with greater concentrations of forested habitat with 

canopy cover greater than 50% in close proximity to the nesting area exhibit higher occupancy rates 

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and lower extinction rates (Ibid). Reestablishing forested habitat in close proximity to remaining 

green forest, increasing habitat availability and reducing fragmentation across the project area would 

improve territory and landscape level habitat conditions for spotted owls. Built in design criteria 

would promote heterogeneity when planting or pre-commercially thinning conifers. For example, up 

to 5 oaks per acre would receive a 25 foot radius buffer to provide ample growing space in the long 

term. Up to 20% understory vegetative cover would be retained on a unit basis and would not be 

treated during site preparation or release. Other inoperable areas, such as steep pitches and sensitive 

plant sites would not be planted with conifers. These design criteria would break up the continuity of 

planted conifers, promote several open grown oaks per acre and would provide understory vegetation 

throughout the treated areas. Active or managed reforestation is predicted to provide more complex 

habitat conditions in the long-term. For, example, active reforestation is expected to produce more 

large trees (e.g., greater than or equal to 24 inches dbh) and higher levels of snag recruitment when 

compared to the No Action Alternative. Restoring fire back into this landscape within ten years of 

planting treatments would promote resiliency across reforested areas. Thinning existing plantations is 

also expected to accelerate growth rates and increase structural stand diversity, improving roosting, 

nesting and foraging habitat conditions sooner than without thinning. Thinning these areas would also 

increase resilience to future fire (Fuels, Chapter 3.05). Reforestation and thinning efforts would 

promote the viability of spotted owls across this landscape in the short and long-term.

Short-term, within the next ten years, snags and down woody material will function as habitat 

elements important for owl prey. Snags also serve as potential hunting perch sites that may be utilized 

by foraging owls. Recent research indicates that prey species may be abundant and available in the 

post-fire environment. Work by Bond et al. (2009, 2013) indicates that owls may use high-severity 

fire areas for foraging and that foraging owls with burned forest in their home range appear to utilize 

a variety of prey. Results from studies of small mammal habitat associations demonstrate the speciesspecific importance of habitat elements such as shrubs, downed logs, snags, and truffles (Keane 

2014). The time elapsed since fire is closely correlated with habitat elements and the composition of 

prey species (Roberts 2008, Roberts and van Wagtendonk 2008). For example, post-fire habitats are 

typically rich in gophers and deer mice in the first decade following a fire, followed by wood rats 

when understory conditions are well developed in the first and following decades and finally by 

sciurid squirrels and flying squirrels when trees reach maturity (Ingles 1965, Quinn and Keeley 

2006). A diversity of prey species within a habitat mosaic can be expected to benefit predators such 

as the spotted owl (Roberts and North 2012). Retention of burned habitat within PACs and areas not 

proposed for reforestation would provide habitat for prey that may in turn benefit resident owls. 

While research (such as that currently underway in the Rim Fire area) will help better determine 

retention thresholds and spatial arrangements of snags compatible with owl use, snag retention of 12 

to 30 square feet basal area per acre proposed under all action alternatives is likely to allow for an 

adequate number of perch sites for owl foraging within and adjacent to treatment units.

Long-term over several decades, large snags and large down logs are considered biological legacies in 

the post-fire environment and play important roles in the structure of the future forest (Lindenmayer 

et al. 2008). For example, large snags and large down logs are fundamental to the definition of old 

forest and are important attributes for the development of the old forest ecosystem and associated 

species such as the spotted owl. Snags may stand for decades and in time, may become future nest 

trees for spotted owl as the regenerating forest nears maturity, although few large snags may be 

expected to remain intact by that time. Snag dynamics in the Sierra Nevada are complex and snags 

fall at different rates depending on many factors (Cluck and Smith 2007). Once recruited into the 

down woody material on the ground, this coarse woody debris again serves as an important element 

in owl habitat (Verner et al. 1992). Thus, decaying wood serves different functional roles overtime, 

first providing cover for spotted owl prey in the complex early seral stage of the forest, and ultimately 

decaying and playing a critical role in soil development of old forests. For example, logs in decay 

class five (i.e. highly decayed) are associated with hypogeous fungi (i.e. truffles), which in turn serve 

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as a primary food source for spotted owl prey in old forests - the flying squirrel in particular (Verner 

et al. 1992). 

Spotted owls use habitat at multiple scales ranging from breeding territories that are several hundred 

acres, home ranges that are several thousand acres, to landscapes when considering population 

viability. Because spotted owls focus their breeding activities in the best available habitat around 

roost and nest sites (Verner et al. 1992), habitat modification effects are expected to be most 

pronounced in PACs (at least 300 acres) and Home Range Core Areas (HRCAs) (700 acres adjacent 

to PACs). 

Indicators

The following indicators were chosen to provide a relative measure of the direct and indirect effects 

to the spotted owl and to determine how well project alternatives comply with Forest Plan Direction. 

1. Acres of future moderate and high capability habitat planted and thinned. 

2. Toxicological effects from herbicide use.

These criteria were chosen based on the best available scientific literature which focuses on various 

aspects of spotted owl ecology and life history requirements. These criteria focus on those life history 

aspects, or habitat elements, considered most limiting to California spotted owl persistence across 

their range and where project effects are expected.

Alternatives 1, 3 and 5

Because there is little difference in the planting prescription and outcome in the short and long-term 

under these three alternatives, the effects are expected to be similar and are analyzed together. The 

difference in herbicide proposed between Alternatives 1 and 5 versus Alternative 3 were separated 

below accordingly.

DIRECT AND INDIRECT EFFECTS

Indicator 1, PACs

Reforestation (includes natural regeneration): Under Alternatives 1, 3 and 5, eight PACs exist where 

reforestation is proposed on about 98 acres where hazard trees were removed post Rim Fire; 

Ackerson Creek, Ackerson Mountain, MF Tuolumne, Cottonwood Creek, and Lower Skunk Creek. 

Table 3.16-6 displays the affected territories, proposed treatments, desired conditions, and associated

acres; maps are available in the Terrestrial Wildlife BA/BE, Appendix A. No treatments are proposed 

within 500 feet of current activity centers. Reforesting these areas would provide screening from the 

roads and restore the amount of interior habitat that was available to resident owls pre-fire. Because 

of the limited acreage involved in these treatments, minor benefits are expected for resident owls.

Three PACs exist where reforestation is proposed on about 89 acres that burned at higher severity to 

enhance and protect sensitive plant habitat and Watchlist species of interest habitat; Femmons, South 

Fork Tuolumne, and Soldier Creek, Table 3.16-6. No treatments are proposed within 500 feet of 

current activity centers. These areas are known to be occupied by these sensitive and unique plant 

species and local populations would benefit from proposed treatments (Sensitive Plants, Chapter 

3.09). The Region 5 sensitive plants are Mountain ladyslipper and Goward’s waterfan, and the 

botanical species of interest is madrone. Small fire killed trees less than 15 inches dbh would be 

removed to reduce fuel loading and increase safety for workers when planting conifers. All trees, live 

and dead, greater than 15 inches dbh within these planting areas would be retained and would 

continue to provide perch, roost, and potential nest sites for owls. Oaks would be buffered similar to 

other planting prescriptions under these alternatives. All madrones would be buffered by 25 feet 

during planting. Owls are also expected to realize minor benefits from these proposed treatments. 

Most notably, increased within stand structure and diversity comprised of uneven aged forest. 

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Draft Environmental Impact Statement and Environmental Consequences

Table 3.16-6 Alternatives 1, 3 and 5: Spotted Owl PAC Acres by Treatments and Desired Condition

Spotted Owl PAC and ID Reforestation1

in OFM

Reforestation1

in OCM

Thin in 

OFM Totals

Soldier Creek TUO0010 42 0 0 42

Ackerson Creek TUO0012 0 17 0 17

SF Tuolumne TUO0024 21 0 0 21

MF Spinning Wheel TUO0025 0 0 68 68

Ackerson Mtn TUO0039 0 16 0 16

MF Tuolumne TUO0040 0 21 0 21

Femmons Meadow TUO0072 26 0 0 26

Cottonwood Creek TUO0149 0 27 0 27

Lower Skunk Creek TUO0218 17 0 0 17

Totals 106 81 68 255

1 Includes natural regeneration

PAC=Protected Activity Center; OFM=Old Forest Mosaic; OCM=Open Canopy Mosaic

Thinning: One PAC proposes thinning of existing plantations on about 68 acres; South Fork 

Tuolumne, Table 3.16-6. Three distinct plantations comprised of trees ranging in size from 10 to 20 

inches dbh are located within this PAC. Thinning of plantations is designed to promote increased 

vertical and horizontal structure, release oaks, breaking up the continuity of vegetation and increasing 

resilience when fire returns. Thinning existing plantations in this PAC would increase the growth rate 

of remaining trees and promote understory herbaceous and woody vegetation recruitment. The 

expected increase in stand diversity coupled with snag retention would provide higher quality habitat 

for owls and important prey species such as mice and squirrels in the short term. 

Indicator 1, HRCAs

Reforestation (includes natural regeneration): About 4,793 acres are within 28 HRCAs proposed for 

reforestation. Table 3.16-7 displays the affected territories, proposed treatments, desired conditions, 

and associated acres. Planting areas adjacent to and near spotted owl activity centers as proposed 

under these alternatives would more quickly improve breeding habitat conditions for resident birds. 

The HRCA acres proposed for reforestation were mostly burned at high severity, reducing the amount 

of green forested habitat available in close proximity to the owl’s activity centers.

Thinning: About 983 acres are within 16 HRCAs proposed for thinning of existing plantations, Table 

3.16-7. While some of these plantations are considered suitable because they are CWHR size class 4 

or 5 and have greater than 40% canopy cover, they lack structural diversity. Thinning these 

plantations would promote vertical and horizontal diversity which in turn improves habitat capability. 

Prescribed fire would be the first tool used for thinning these stands. The goal in using prescribed fire 

is to open up these stands, creating a habitat mosaic with individual trees, clumps of trees, and 

openings. If we are unable to accomplish thinning by using prescribed fire, we would use mechanical 

means to achieve the desired conditions in these plantations. Mechanical thinning prescriptions for 

these plantations focus on using an Individual, Clumps, and Openings (ICO) design that would 

provide structural diversity where it doesn’t currently exist. For example, the prescription calls for 

releasing oaks and creating groups of trees separated by openings. After thinning, remaining trees are 

expected to grow faster and understory vegetation would become established, improving habitat 

conditions for owls and their prey in the short and long term. Also, by breaking up the continuity of 

vegetation across a given area, the habitat would be more resilient when fire or other stochastic events 

occur. 

Spotted owls are expected to benefit in the short and long term from reforestation and thinning 

treatments. Reforestation and thinning as proposed under Alternatives 1, 3 and 5 would improve 

habitat conditions and increase the amount of moderate and high capability habitat available within 

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these territories, moving them toward the desired condition outlined in the Draft Interim 

Recommendations for the Management of California Spotted Owl Habitat on National Forest System 

Lands (USDA 2015).

Table 3.16-7 Alternatives 1, 3 and 5: Spotted Owl HRCA Acres by Treatment and Desired Condition

HRCA and ID Reforestation 

in OFM1,2

Reforestation 

in OCM1,2

Thin1 in 

OFM

Thin1 in 

OCM

Total 

Acres1

% HRCA1 

Treated

Cherry Lake HRCA TUO0AAA 0 2 91 69 163 16

Mather HRCA TUO0BBB 52 163 3 2 220 20

Soldier Creek HRCA TUO0010 251 120 0 0 371 37

Big Creek HRCA TUO0011 87 65 0 36 187 18

Ackerson Creek HRCA TUO0012 5 58 0 0 64 6

SF Tuolumne HRCA TUO0024 239 234 0 0 474 47

MF Spinning Wheel HRCA TUO0025 56 148 71 75 349 35

Rush Creek HRCA TUO0026 112 104 0 0 218 22

North Bear Mtn HRCA TUO0027 150 152 0 21 323 26

Bear Mtn HRCA TUO0028 183 222 0 28 432 43

Reed Creek HRCA TUO0031 143 550 6 0 699 70

Ackerson Mtn HRCA TUO0039 47 58 0 0 106 10

MF Tuolumne HRCA TUO0040 52 163 3 2 220 20

Bear Spring Creek HRCA TUO0061 13 15 30 0 58 5

Spotted Owl HRCA TUO0065 0 4 0 37 41 4

Femmons Mdw HRCA TUO0072 44 48 0 0 175 17

Crocker Mdw HRCA TUO0078 18 53 0 3 73 5

Harden Flat NW HRCA TUO0085 129 272 0 0 401 39

Bear Creek HRCA TUO0145 0 18 0 71 89 9

Hunter Creek HRCA TUO0146 0 90 0 247 337 34

Cottonwood Creek HRCA TUO0149 0 135 0 84 219 22

Ascension Mdw W HRCA TUO0177 18 56 5 12 90 9

N Niagara HRCA TUO0205 0 18 0 16 34 3

L Skunk Creek HRCA TUO0218 386 153 0 0 539 5

U Cherry Lake HRCA TUO0219 17 0 57 6 80 8

Box Spring HRCA TUO0255 0 27 0 4 31 3

Spotted Owl HRCA TUO0257 0 33 0 0 33 3

Spotted Owl HRCA TUO0258 0 44 0 0 44 4

Total HRCA Acres 1,950 2,844 263 720 5,777

1 Includes PAC treatment acres 2 Includes Natural Regeneration

HRCA=Habitat Conservation Area; OFM=Old Forest Mosaic; OCM=Open Canopy Mosaic

Greater Landscape: Under these alternatives, an additional 21,650 acres are proposed for 

reforestation (reforestation and natural regeneration) across the project area. The reforestation

treatments when combined with reforestation in PACs and HRCAs would increase the amount of 

moderate and high capability habitat available to owls on STF lands by 67% in the long term. Under 

these alternatives, an additional 13,000 acres of thinning existing plantations occur across the project 

area. The reforestation and thinning treatments proposed under these alternatives have the potential to 

benefit spotted owls at the landscape scale. These alternatives would result in the greatest increase of 

moderate and high capability forested habitat across this landscape. Because habitat loss and 

fragmentation have been identified as a significant risk to spotted owl persistence across their range, 

reestablishing forest habitat across the landscape is critical. Reduced fragmentation and increased 

availability of suitable habitat is expected to benefit resident and dispersing spotted owls. 

Indicator 2

Under Alternatives 1 and 5, herbicide use is expected to have a limited potential for direct or indirect 

toxicological effects on spotted owls, as described under the herbicide risk assessment section. 

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Because no herbicides are proposed under Alternative 3, no exposure to herbicides and no direct, 

indirect, or cumulative toxicological effects to goshawks would occur under this alternative.

CUMULATIVE EFFECTS

Appendix B identifies the present and reasonably foreseeable future actions on all lands within the 

analysis area. Some, but not all of these actions have or may contribute cumulatively to effects on 

spotted owls. 

Based on risk factors affecting spotted owl abundance and distribution, the following evaluation 

criteria were used as relative measures of cumulative effects from Alternatives 1, 3 and 5: habitat 

modification. In addition, Alternatives 1 and 5 used toxicological effects for evaluation criteria. 

Habitat Modification

Federal Lands: Present and foreseeable future activities on federal lands include: Funky Stewardship, 

Groovy Stewardship, Reynolds Creek Stewardship, Soldier Creek Timber Sale, Campy Timber Sale, 

Looney Timber Sale, Thommy Timber Sale, which are green thinning projects treating 6,546 acres of 

green forest across the analysis area. All snags and many declining trees will be retained unless they 

pose a safety hazard in these projects. The snag and declining tree retention will provide snags that 

could serve as potential roost or nest sites for spotted owls in the short term as well as recruits for 

future nest sites in the long term. Other federal activities potentially impacting breeding habitat for 

spotted owls is fuels reduction associated with the Rim Recovery project. Fuels reduction associated 

with this project will reduce the risk of further loss of remaining green forest within the project area.

Toxicological Effects

Federal lands: There is one present federal action of herbicide use on 0.5 acres under the Rim Fire 

Rehabilitation project and two foreseeable federal actions of herbicide use: 8.0 acres under the 

Twomile Ecological Restoration Noxious Weed project and 23 acres under a special use permit for 

the Reliable Power Project powerline. No other present or foreseeable future federal actions are 

related to herbicide use. 

Private lands: Herbicide use is proposed on 1,583 acres of private land within the project area in 

2017. No other present or foreseeable future actions are proposed on private lands related to herbicide 

application. 

Alternatives 1, 3 and 5 Contribution and Summary

Alternatives 1, 3 and 5 would contribute cumulatively to short and long term effects to California 

spotted owls. Under these alternatives, reforestation on about 26,400 acres would increase the amount 

of moderate and high capability habitat available across the analysis area by 38% in the long term. 

Thinning about 14,000 acres of existing plantation is also expected to benefit spotted owls. These 

alternatives would result in similar benefits with respect to existing plantation thinning when 

compared to Alternative 4 because the thinning prescription is the same under all action alternatives. 

However, under Alternatives 1, 3 and 5, the reforestation treatments would complement the thinning 

to improve habitat conditions across the landscape. Alternatives 1 and 5 would contribute to the short 

term limited potential of exposure to toxicity from herbicide use. Alternatives 1, 3 and 5 would result 

in the greatest increase in available habitat and connectivity at the territory and landscape scale when 

compared to Alternatives 2 and 4. The cumulative contribution under this alternative is expected to 

benefit resident and dispersing California spotted owls and may beneficially affect the viability of this 

species.

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Alternative 2

DIRECT AND INDIRECT EFFECTS

Indicator 1

The indirect effects of no action are primarily related to the influence no action may have on the 

amount of moderate and high capability habitat available, the restoration of habitat connectivity 

across the landscape, and how that may impact California spotted owls in the long term. Under this 

alternative, about 9,800 acres of forested habitat is predicted to develop naturally with no active 

management across the landscape. This would increase habitat availability across STF lands by 25%, 

almost .66 less than that expected under Alternatives 1, 3 and 5. Because no active management 

would occur, it is unknown where naturally regenerating forest would occur and what benefits that 

would provide spotted owls. It is likely that areas in close proximity to live trees (i.e. seed source) 

would experience forest expansion to a limited degree, depending on the competing vegetation in the 

localized area. It should be noted that natural conifer expansion is sporadic in nature, could be 

delayed for decades due to shrub suppression, would likely be dominated by fir, and would not result 

in significant gains in forested habitat (Vegetation, Chapter 3.13). Areas far from seed sources would 

likely persist as chaparral for decades if not well over a hundred years. Existing plantations would not 

be thinned under this alternative; therefore, increasing structural diversity and improving habitat 

quality in these areas would not be realized. The plantations, if left untreated, could be at greater risk 

of loss when fire returns to this landscape because of the tightly spaced live trees and fuel loading 

from fire mortality (Fuels, Chapter 3.05). 

Indicator 2

Because no herbicides are proposed under Alternative 2, no exposure to herbicides and no direct, 

indirect, or cumulative toxicological effects to spotted owls would occur under this alternative.

CUMULATIVE EFFECTS

The cumulative effects discussion under Alternatives 1, 3 and 5 outlines those present and foreseeable 

future activities scheduled on public and private lands.

Alternative 2 Contribution and Summary

Under Alternative 2, no direct cumulative effect is expected because no active management would 

occur, however, there may be indirect consequences under this alternative primarily related to the 

influence no action may have on future forest development and how that may impact California 

spotted owls. At the landscape scale, the cumulative contribution under this alternative would 

increase the available suitable habitat by 14% (9,800 acres) compared to a 38% increase (acres) under 

Alternatives 1, 3 and 5. It is unknown where and how long it would take natural regeneration to occur 

and what, if any, benefits would be realized by spotted owls at the territory or landscape level. The 

cumulative contribution under this alternative may negatively affect individuals and would not result 

in beneficial effects to the viability of this species.

Alternative 4

DIRECT AND INDIRECT EFFECTS

Indicator 1, PACs

Reforestation (includes natural regeneration): Under Alternative 4, five PACs with up to 23 acres are 

proposed for reforestation. Effects from these limited proposed treatments are not measureable and 

are considered negligible or discountable. 

Thinning: There is one PAC where thinning of existing plantations on about 68 acres is proposed; 

South Fork Tuolumne. The thinning prescriptions and expected benefits are the same as those 

discussed under Alternatives 1, 3 and 5. 

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Indicator 1, HRCAs

Reforestation (includes natural regeneration): About 820 acres are within 14 HRCAs proposed for 

reforestation. This is about 4,000 acres less than Alternatives 1, 3 and 5. Table 3.16-8 displays the 

affected territories, proposed treatments, desired conditions, and associated acres. The planting 

prescription under this alternative is termed founder stands. This prescription calls for small variable 

shaped planting areas ranging from two to ten acres in size within a larger unplanted area. The 

unplanted area would likely be comprised of chaparral with scattered oaks. The planted area is only 

20% of a given unit. Herbicides would be used to control shrubs and competing vegetation within 

planted areas and incorporating a 25 to 50 foot buffer around planted areas. These trees would be 

planted with a much tighter spacing, groups of 5 trees spaced 6 feet from each other. With the tighter 

spacing of planted trees, it may be necessary to thin the plantations around year 7 to allow growing 

space for the trees to mature. Prescribed fire or hand tools would be used to thin the new plantations. 

Prescribed fire would be applied to 50% of planted areas within ten years and the other 50% within 

20 years. Reforesting in this manner would result in several small fragmented patches of forested 

habitat no bigger than ten acres separated by large tracts of chaparral. Small patches of forested 

habitat covering 20% of a given area would not provide the moderate and high capability habitat 

required by breeding spotted owls, which include large areas of contiguous forest. 

Table 3.16-8 Alternative 4: Spotted owl HRCA Acres by Treatment and Desired Condition

HRCA and ID Reforestation 

in OFM1,2

Reforestation 

in OCM1,2

Thin1

in OFM

Thin1

in OCM

Total 

Acres1

% HRCA1

Treated

Cherry Lake HRCA TUO0AAA 0 0 91 69 161 16

Soldier Creek HRCA TUO0010 89 24 0 0 113 11

Big Creek HRCA TUO0011 40 5 0 36 80 8

SF Tuolumne HRCA TUO0024 98 48 0 0 148 15

MF Spinning Wheel HRCA TUO0025 12 21 71 75 178 18

Rush Creek HRCA TUO0026 16 30 0 0 46 5

North Bear Mtn HRCA TUO0027 24 12 0 21 57 6

Bear Mtn HRCA TUO0028 38 42 0 28 109 12

Reed Creek HRCA TUO0031 15 98 6 0 119 12

MF Tuolumne HRCA TUO0040 4 16 3 2 25 2

Bear Spring Creek HRCA TUO0061 3 10 30 0 42 7

Spotted Owl HRCA TUO0065 0 0 0 37 37 8

Bear Creek HRCA TUO0145 0 0 0 71 71 16

Hunter Creek HRCA TUO0146 0 0 0 247 247 25

Cottonwood Creek HRCA TUO0149 0 0 0 84 84 18

Ascension Mdw W HRCA TUO0177 17 6 5 12 41 6

N Niagara HRCA TUO0205 0 0 0 16 16 11

Lower Skunk Creek HRCA TUO0218 70 25 0 0 95 9

U Cherry Lake TUO0219 0 0 57 6 63 6

Box Spring HRCA TUO0255 0 28 0 4 32 3

Westside West HRCA TUO0258 0 28 0 0 28 3

Total HRCA Acres 426 394 263 709 1792

1 Includes PAC treatment acres 2 Includes Natural Regeneration

Similar to the No Action Alternative, about 9,800 acres of forested habitat is predicted to develop 

naturally with no active management across the landscape. Because no active management would 

occur on these acres, it is unknown where naturally regenerating forest would occur and what benefits 

it would provide for spotted owls. It is likely that areas in close proximity to live trees (i.e. seed 

source) would experience forest expansion to a limited degree, depending on the competing 

vegetation in the localized area. As stated under the No Action Alternative, natural conifer expansion 

is sporadic, could be delayed for decades due to shrub suppression, would likely be dominated by fir, 

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and would not result in significant gains in forested habitat (Vegetation, Chapter 3.13). Areas far from 

seed sources would likely persist as chaparral for decades if not well over a hundred years. While this 

alternative would increase the amount of forested habitat across STF lands by up to 25%, it is

unknown how fragmented or contiguous the distribution would be across the landscape and if it 

would provide benefits to spotted owls at the territory or landscape scale. 

Thinning: About 973 acres within 16 HRCAs are proposed for thinning of existing plantations. 

Because the prescription for thinning is the same for all action alternatives, benefits are expected to be 

the same as discussed under Alternatives 1, 3 and 5.

Spotted owls are expected to benefit in the short and long term from thinning treatments. 

Reforestation as proposed under Alternative 4, small isolated patches of forest no larger than ten acres 

in size, is not likely to improve habitat conditions or increase the amount of moderate and high 

capability habitat available within these territories. It is unknown if spotted owls would benefit from 

natural regeneration, but it is expected to take much longer for suitable breeding habitat to develop 

across these territories under this Alternative.

Greater Landscape: Under this alternative, an additional 2,107 acres proposed for reforestation 

(reforestation and natural regeneration) exist across the project area. These treatments are not likely to 

benefit spotted owls because reforestation would result in small fragmented patches of forest no 

larger than ten acres in size separated by large tracts of chaparral. About 13,000 additional acres of 

existing plantation are proposed for thinning. These thinning treatments are likely to benefit spotted 

owls in the short and long term. This alternative would result in the least amount of moderate and 

high capability forested habitat and the lowest reduction in habitat fragmentation when compared to 

Alternatives 1, 3 and 5.

Indicator 2

Herbicide use is expected to have a limited potential for direct or indirect toxicological effects on 

spotted owls, as described under the herbicide risk assessment section.

CUMULATIVE EFFECTS

The cumulative effects discussion under Alternatives 1, 3 and 5 outlines those present and foreseeable 

future activities scheduled on public and private lands.

Alternative 4 Contribution and Summary

Alternative 4 would contribute cumulatively to short and long term effects to northern goshawks. 

Under this alternative, reforestation on up to 2,950 acres in discreet patches no larger than ten acres is 

not expected to result in benefits to spotted owls. Natural forest recovery under this alternative is 

expected to increase available habitat by up to 14% across the analysis area. However, this natural 

forest recovery is expected to be sporadic, delayed, and a limited contribution to moderate and high 

capability habitat in the long term. The founder stands prescription is not expected to provide 

moderate and high capability habitat because it would be located in small fragmented patches 

separated by large tracts of chaparral. Under this alternative about 14,000 acres of existing plantation 

would be thinned, promoting structural diversity and improving habitat capability in the short and 

long term. This alternative would result in similar benefits with respect to existing plantation thinning 

when compared to Alternatives 1, 3 and 5 because the thinning prescription is the same under all 

action alternatives. Alternative 4 would contribute to the short term limited potential of exposure to 

toxicity from herbicide use. The cumulative contribution under this alternative is expected to provide 

limited benefits to resident or dispersing spotted owls and would not result in beneficial effects to the 

viability of this species.

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Draft Environmental Impact Statement and Environmental Consequences

California Spotted Owl: Summary of Effects

Indicator 1

Table 3.16-9 shows the number of acres proposed for planting and the number of acres of existing 

plantation proposed for thinning at the PAC, HRCA and landscape scales. Alternatives 1, 3 and 5 

would provide the greatest amount of moderate and high capability habitat for spotted owls in the 

long-term when compared to Alternative 4. All action alternatives would result in the same amount of 

future moderate and high capability habitat within the treated existing plantations; however, 

Alternative 4 does not complement the existing plantation treatments by accelerating forest 

reestablishment in adjacent areas or across the landscape as proposed under Alternatives 1, 3 and 5. 

Table 3.16-9 California Spotted Owl Summary of Effects: Future Moderate to High Capability Habitat

Metric Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5

Acres reforested in PACs1 187 0 187 23 187

Acres reforested in HRCAs1 4,793 0 4,793 820 4,793

Acres reforested (landscape)1 21,650 0 21,650 2,107 21,650

Total reforested acres 26,630 0 26,630 2,950 26,630

Acres of existing plantation thinned in 

PACs 68 0 68 68 68

Acres of existing plantation thinned in 

HRCAs 983 0 983 983 983

Acres of existing plantation thinned 

(landscape) 13,000 0 13,000 13,000 13,000

Total thinned acres 14,051 0 14,051 14,051 14,051

1 Includes natural regeneration. 

Indicator 2

Herbicide use under Alternatives 1, 4 and 5 are expected to have limited potential for direct or 

indirect toxicological effects on spotted owls. Because Alternative 4 has fewer proposed acres of 

herbicide application, the potential for effects would be less than under Alternatives 1 and 5. 

However, it is important to note that the toxicity exposure scenarios analyzed in the risk assessment 

show that all HQs are several orders of magnitude less than the NOAEL; therefore, spotted owls are 

provided an adequate margin of safety in the event that they are exposed to contaminated prey or 

water.

DETERMINATIONS

Alternatives 1 and 5

Alternatives 1 and 5 may affect individuals but is not likely to result in a trend toward Federal listing 

or loss of viability for the California spotted owl. This determination is based on the following 

rationale:

 These alternatives include actions to reestablish contiguous forested habitat, accelerating the time 

in which these areas would be suitable for nesting, roosting and foraging. 

 These alternatives include actions to thin existing plantations, accelerating the time in which these 

areas would be suitable for nesting, roosting and foraging.

 Habitat connectivity would be restored under these alternatives.

 Snag retention in close proximity to green forest would result in maintaining roosting and nesting 

structures as well as habitat for prey throughout the treated areas.

 These alternatives require the use of LOPs to reduce disturbance potential to breeding spotted 

owls. 

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 These alternatives provide for surveys to establish or confirm the location of activity centers and 

boundaries. 

 Toxicity exposure levels from herbicide use under these alternatives are all several orders of 

magnitude below the Forest Service established threshold of concern. 

Alternative 2

Alternative 2 may affect individuals but is not likely to result in a trend toward Federal listing or loss 

of viability for the California spotted owl. This determination is based on the following rationale:

 This alternative would result in the smallest increase in moderate to high capability habitat 

available to spotted owls in the long-term.

 The structural diversity of existing plantations would not be enhanced and thus habitat quality 

would not be improved in the short or long-term.

 Untreated existing plantations may be at greater risk of loss when fire returns to this landscape.

 There would be no potential for exposure to herbicides. 

Alternative 3

Alternative 3 may affect individuals but is not likely to result in a trend toward Federal listing or loss 

of viability for the California spotted owl. This determination is based on the following rationale: 

 This alternative includes actions to reestablish contiguous forested habitat, accelerating the time 

in which these areas would be suitable for nesting, roosting and foraging. 

 This alternative includes actions to thin existing plantations, accelerating the time in which these 

areas would be suitable for nesting, roosting and foraging.

 Habitat connectivity would be restored under this alternative.

 Snag retention in close proximity to green forest would result in maintaining roosting and nesting 

structures as well as habitat for prey throughout the treated areas.

 This alternative requires the use of LOPs to reduce disturbance potential to breeding spotted owls. 

 This alternative provides for surveys to establish or confirm the location of activity centers and 

boundaries. 

 There would be no potential for exposure to herbicides. 

Alternative 4

Alternative 4 may affect individuals but is not likely to result in a trend toward Federal listing or loss 

of viability for the California spotted owl. This determination is based on the following rationale: 

 This alternative includes actions to establish small fragmented patches of forest that would not 

provide suitable nesting or roosting habitat. 

 This alternative includes actions to thin existing plantations, accelerating the time in which these 

areas would be suitable for nesting, roosting, and foraging.

 Snag retention in close proximity to green forest would result in maintaining roosting and nesting 

structures as well as habitat for prey throughout the treated areas.

 This alternative requires the use of LOPs to reduce disturbance potential to breeding spotted owls. 

 This alternative provides for surveys to establish or confirm the location of activity centers and 

boundaries. 

 Toxicity exposure levels from herbicide use under this alternative are all several orders of 

magnitude below the Forest Service established threshold of concern. 

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California Spotted Owl: Consistency with Draft Interim Recommendations for the 

Management of California Spotted Owl Habitat on NFS Lands

Applicable Interim Recommendations

Region 5 is in the process of developing a new conservation strategy for the California spotted owl 

throughout its range in California. The Conservation Assessment is near completion, and it is 

intended to serve as the primary scientific foundation for the Conservation Strategy, which Region 5 

anticipates to be completed by March 31, 2016. In the intervening time period, the Region asked the 

leading experts in the California spotted owl, forest ecology and fire ecology in the Sierra Nevada 

associated with the Conservation Assessment to provide interim recommendations on changes to 

forest management prior to the development of the Conservation Strategy. 

CONSERVATION MEASURES

The following applicable conservation measures are listed in the Draft interim recommendations for 

the management of California spotted owl habitat on National Forest System Lands (USDA 2015b): 

1a. Recommendation that habitat conservation for California spotted owls should be addressed at four 

scales – activity center, territory, home range and landscape. 

2b. Recommendation that target canopy cover conditions for PAC habitat be set at greater than or 

equal to 70%. Further, it is recommend that all snags, 15 inches and above, be retained in PACs, 

unless they represent a safety hazard.

3d. Designated habitat patches or stands ideally are large enough to provide interior stand conditions 

(1 to 2 tree heights from edge) to minimize edge effects, particularly for the acres with greater than or 

equal to 70% canopy cover.

4d. Desired conditions for a 1,000-acre territory are the following:

 Greater than or equal to 40% (400 acres) with greater than 70% canopy cover (or best available – 

see recommendation 3b).

 Additional minimum of 300 acres (30%) with greater than 50% canopy cover. 

 The remaining area (less than 300 acres) should represent fine-scale mosaic (gaps and patches of 

0.03 to 2.0 acres) of low, moderate and high canopy cover that create heterogeneous conditions 

and are in turn conducive to supporting suitable foraging habitat and an abundance of prey. 

 The condition of the territory is a function of all lands that occur within the territory.

5d. Recommendation that the area outside the territory circle and within any given home range area 

be managed to maintain an average of 40% canopy cover across the entire home range area (not at the 

stand scale), with conditions ranging from less than 25% to less than 70% canopy cover across a finescale mosaic of heterogeneous conditions. The average condition is intended to serve as a guide in 

balancing a wide range of stand-scale canopy cover conditions across the home range area toward 

creating heterogeneous forest conditions. 

Interim Guidance Consistency

The action Alternatives 1, 3, 4 and 5 demonstrate Interim Recommendation Consistency through the 

following: 

Alternatives 1, 3, 4 and 5 address spotted owl habitat conservation at the activity center, territory and 

landscape scale.

Alternatives 1, 3 and 5 retain all snags greater than 15 inches dbh within PACs, unless they represent 

a safety hazard.

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Alternatives 1, 3 and 5 would provide habitat patches and stands that provide interior stand conditions 

to minimize edge effects.

Alternative 4 would not consistently provide interior habitat patches or stands in close proximity to 

each other. The fragmented nature of the founder stands would likely present a barrier to spotted owl 

use of small forested patches and movement across non-forested areas to reach other small forested 

patches.

Alternatives 1, 3 and 5 address and propose actions that would result in moving spotted owl territories 

and the greater landscape toward desired conditions identified in the interim recommendations in the 

long-term, specifically conservation measures 3d and 4d.

Alternative 4 does not address or propose actions to address conservation measures 3d or 4d.

Great Gray Owl: Affected Environment

Species and Habitat Account

The great gray owl (Strix nebulosa) is a Region 5 Forest Service Sensitive species and is listed as 

Endangered under the California Endangered Species Act. The great gray owl occurs from Alaska to 

northern and south-central Ontario, Idaho, Montana, Wyoming, central Seskachewan, northern 

Minnesota, and California (USDA 2006a). In California, they occur in the Sierra Nevada from the 

vicinity of Quincy and Plumas County, south to Yosemite National Park (CDFG 2008). 

Hull et al. 2010 and Hull et al. 2014 found that great gray owls in the Yosemite area (i.e. including 

the Rim Fire area), are a genetically-unique population warranting subspecies status as ssp.

yosemitensis. The genetic analysis completed by Hull et al. (2010) indicates that the S.n. yosemitensis

population has experienced a recent genetic bottleneck and exhibits a small effective population size. 

Both of these factors are a significant conservation concern. The limited genetic diversity in this 

population may contribute to population instability because of the already low population levels, low 

census numbers, limited migration potential, and the potential for inbreeding depression (Ibid). 

Great gray owls are regarded as locally rare throughout their range in USFS Region 5 and no more 

than 100-200 individuals have been estimated in California since 1980, and only 80 were estimated in 

2006 (R5 Sensitive species Evaluation Form 2012). Although the great gray owl population in 

California is small, the STF contains more great gray owl sites than any other National Forest in 

Region 5, or any area outside of Yosemite National Park (Siegel 2001, 2002, NRIS Wildlife database, 

CNDDB database). Of the great gray owl sites on the STF, most are concentrated within the Rim Fire 

perimeter in areas that border Yosemite National Park.

Great gray owl sites are identified through the use of protocol surveys (Beck and Winter 2000, Keane 

et al. 2011). Protocol surveys for great gray owl have been conducted throughout the Rim Fire area 

for the past two decades. These surveys are best described as twofold: management oriented and 

research oriented. Management oriented survey work is generally opportunistic depending upon 

planned activities and funding levels. Research oriented survey work is generally more systematic 

and focused. Together these efforts have occurred at a level such that inventory information for the 

analysis area is considered essentially complete. Surveys have been conducted in the two breeding 

seasons post-fire (2014 to 2015) and we have documented great gray owls in four territories within 

the Rim Fire area.

The project action area is within the current distribution of great gray owls across the Sierra Nevada 

Bioregion. There are 13 territories documented within the action area. LOPs will be placed around all 

documented great gray owl PACs from March 1-August 15 of any given year during project 

implementation. 

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General habitat requirements for great gray owls include forested environments with high canopy 

cover and large trees that feature vegetation types such as Sierran Mixed Conifer, White fir, Red fir, 

Montane Hardwood, Montane Hardwood Conifer, Wet meadows, and Ponderosa Pine (CDFW 2008, 

Van Riper III and Van Wagtendok 2006). They typically nest in dense canopied forested stands 

adjacent to meadows or meadow complexes in large flat-topped broken snags. Availability of nesting 

structures and prey may limit the use of otherwise suitable habitat. Green (1995) found that occupied 

great gray owl sites had greater plant cover, vegetative height, and soil moisture. Canopy closure was 

the only variable of three variables measured (canopy closure, number of snags greater than 24 inches 

dbh, and number of snags less than 24 inches dbh) that was significantly higher in occupied sites 

versus unoccupied (Ibid). Home ranges have recently been estimated for Yosemite National Park. 

Breeding female home range size has been estimated at 152 acres while winter home ranges average 

6,072 acres. Male breeding home ranges are estimated at 49 acres and winter home ranges average 

5,221 acres (Van Riper III and Van Wagtendok 2006). Moderate to High Capability habitat is defined 

as that in which a CWHR suitability rating is ≥ 0.55. Two of three categories (reproduction, cover, 

food) must have a medium rating to achieve the minimum rating. Reference CWHR version 8.2 

users’ manual for further explanation on suitability ratings (CDFW 2008). Acres include NFS lands 

only. This includes Sierran mixed conifer, ponderosa pine, and white fir in CWHR type, size, and 

class (4M, 4D, 5M, 5D). About 40,000 acres of moderate to high capability year round habitat exist 

within the project action area on NFS lands only. This habitat is arranged in two general areas within 

the Rim fire perimeter; one area on the north end where Rim Fire burn severity was low to moderate 

and another area near the Highway 120 corridor. These two areas are disjunct, potentially prohibiting 

north to south movement or dispersal. Suitable breeding habitat is defined as suitable forested stands 

(4D, 5M, 5D) within 300 meters of an associated meadow or meadow complex. Survey data from 

occupied territories on the STF have documented great gray owls successfully nesting in stands 

classified by CWHR as 4D, thus this size and density class was included as highly suitable breeding 

habitat. About 2,387 acres is highly suitable breeding habitat on NFS lands and is unevenly 

distributed throughout the project area. About 73,700 acres of medium to highly suitable year round 

habitat exist within the cumulative effects analysis area. 

Beck (1985), Bull and Duncan (1993), CDFG (2008) and Greene (1995) also describe suitable 

foraging habitat as follows:

 Open meadows and grasslands in forested areas

 Open woodlands and coniferous stands with herbaceous or shrub component 

 Dense herbaceous cover, vegetative height and adequate soil moisture to provide suitable 

conditions for prey

 Trees, snags and fence posts present to serve as hunting perches

The diet of great gray owls may vary locally, but consists of small mammals, primarily rodents. 

Current literature indicates that great gray owls in the western United State overwhelmingly select 

two prey taxa: voles and pocket gophers (Bull and Duncan 1993). Voles prefer meadows with dense 

herbaceous vegetative cover (CDFW 2008). While it has been suggested by Beck (1985) that 

herbaceous heights ranging from 5 to 15 inches is suitable for voles, Greene (1995) found 12 inches 

to be preferred. Gophers are typically subterranean but also appear to have herbaceous cover 

preferences (Ibid). Compaction of meadow soils may reduce suitability of areas for gophers.

Not much is known on dispersal patterns in great gray owls. Bull et al (1988a) reported that 

maximum dispersal distance for juvenile owls to be 4.6 and 19.9 miles from their natal sites. They 

aren’t considered migratory, though adults make short elevation movements during winter, 

presumably to areas with lower snow depths (Hayward and Verner 1994). In Oregon adults exhibit 

nest site fidelity, 78% returning to within 0.6 miles of the previous year’s nest site (Bull et al. 1988b). 

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Recent burns, where they exist in the Sierras, provide some structural similarity to a meadow 

ecosystem for a few years before the trees or brush shade out the grasses and forbs (Beck and Winter 

2000). Such sites can provide foraging areas for nearby breeding great gray owls in the short term 

(Greene 1995; Beck pers.comm.). Meadows or meadow complexes at least 25 acres in size appear to 

be necessary for persistent occupancy and reproduction but meadows as small as 10 acres will support 

infrequent breeding (Beck and Winter 2000). Reproductive sites are associated with high vole 

abundance and high vole abundance is associated with meadow vegetation height (Beck 1985; Greene 

1995; Sears 2006; Kalinowski et al. 2014). 

All great gray owl PACs burned at mixed severity in the Rim Fire. Overall, approximately half of all 

PAC acres burned at high severity (greater than 75% basal area mortality) and approximately 69% of 

known and potential nest sites were lost in the fire. There is potential for great gray owls to nest in 

burned forest (Beck, pers.comm.) and post-fire conditions may also provide preferred foraging habitat 

in the short term (Greene 1995). 

Mean home-range size in the Sierra Nevada during a radio-tagging study was estimated at 148 acres 

in females and 50 acres in males during the breeding season; great gray owls enlarge their home 

ranges substantially in winter (Van Riper and van Wagtendonk 2006). Most detections of great gray 

owls are within 300 meters of meadow habitat (Green 1995, Van Riper and Van Wagtendonk 2006, 

Winter 1986). 

RISK FACTORS

USDA (2006a) summarized risk factors potentially influencing great gray owl abundance and 

distribution: 

1. Habitat loss and degradation - Green tree and salvage timber harvest can eliminate potential nest 

trees. 

2. Range Management - Grazing can remove cover necessary for prey species and degrade 

meadows, thereby lowering water tables and reducing productivity of grasses and forbs that are 

food sources for prey.

3. Collision with automobiles – Great gray owls are particularly susceptible to collisions with 

vehicles. 

4. Disease – The effect of West Nile virus on owl populations is uncertain; however, given mortality 

rates in other avian species that have contracted this disease, a high mortality rate could be 

expected in infected great gray owls. 

5. Disturbance at nest and roost sites - There is little information on disturbance and great gray 

owls; however, it is logical to assume they would respond like other owls. Spotted owls are 

known to have increased stress levels to disturbance such as chainsaw use and proximity to 

logging roads, which may affect reproduction (Hayward unpubl. data, USFWS 2006b, and 

Wasser et al. 1997). 

Great Gray Owl: Environmental Consequences

The project alternatives could result in direct and indirect effects to the great gray owl through the 

following activities:

 Mechanical site preparation for planting.

 Herbicide application for site preparation and release of conifers.

 Planting and thinning conifers.

These direct and indirect effects include:

 Project related death, injury, or disturbance.

 Project related modifications to habitat quantity and/or quality.

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Death, Injury and Disturbance

Death, injury and disturbance are potential direct effects to consider for great gray owl. Project 

activities have the potential to cause death or injury by tree-falling or by the use of heavy equipment. 

The great gray owl is also susceptible to getting “road killed”. Collision with vehicles is a major 

cause of mortality (Keane et al. 2011); great gray owls tend to fly low over the ground in open areas 

especially adjacent to meadows (Bull and Duncan 1993). LOPs mitigate the probability that death or 

injury would occur as a result of project activities. Loud noise from equipment such as chain saws or 

tractors is expected to occur in reforestation units and staging areas. Human presence in nest stands 

and loud noise in the vicinity of nest stands have the potential to change normal behavior and 

potentially impair essential behavior patterns of the great gray owl related to breeding, feeding or 

sheltering. The potential for disturbance under all action alternatives is minimized by the 

implementation of LOPs.

Habitat modification

Forested habitat is required by roosting and nesting great gray owls (Beck 1985; Greene 1995; Van 

Riper and Van Wagtendonk 2006; Winter 1981). Van Riper and Van Wagtendonk (2006) found that a 

significant proportion of breeding home ranges for females (73%) and males (75%) are comprised of 

forested habitat. Additionally, habitat loss has been identified as a risk influencing great gray owl 

abundance and distribution. Reestablishing forest habitat across the landscape and in close association 

with meadows is critical to ensure the viability of great gray owls in this landscape long-term.

Retention of snags and large downed woody debris is proposed under all action alternatives. Snags 

and down logs are important habitat elements for great gray owls and their prey (USDA 2001, Bull 

and Henjum 1990). Sears (2006) found that sites with a higher density of large snags were more 

likely to be occupied by great gray owl. Juveniles use leaning trees and snags for roosting before they 

can fly, and high stem density in stands are used by juveniles for cover and protection (Bull and 

Henjum 1990). Bull and Henjum (1990) noted that roosts accessible to flightless young, such as 

leaning and deformed trees and perches high enough to avoid terrestrial predators, may increase 

reproductive success. Retention of snags and large downed wood across the landscape will provide 

hunting, roosting and potentially nesting sites when associated with roosting or foraging habitat. 

These features are considered biological legacies in this post fire environment and will play important 

roles in the structure of future forest (Lindenmayer et al. 2008).

As great gray owls concentrate activities around meadows and have relatively small breeding home 

ranges, the potential for habitat modification effects are expected to be most pronounced in and near 

meadows as well as PACs.

Indicators

The following indicators were chosen to provide a relative measure of the direct and indirect effects 

to the great gray owl and to determine how well project alternatives comply with Forest Plan

Direction. These criteria were chosen based on the best available scientific literature which focuses on 

various aspects of great gray owl ecology and life history requirements. These criteria focus on those 

life history aspects, or habitat elements, considered most limiting to great gray owl persistence across 

their range and where project effects are expected.

1. Acres of future moderate and high capability breeding habitat planted and thinned. 

2. Toxicological effects from herbicide use. 

Alternatives 1, 3 and 5

Because there is very little difference in the planting prescription under these three alternatives, the 

effects are expected to be similar and are analyzed together.

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DIRECT AND INDIRECT EFFECTS

Indicator 1

Reforestation (includes natural regeneration): About 1,700 acres proposed for reforestation are 

within 300 meters of meadow habitat across the project area under Alternatives 1, 3 and 5. Planting 

conifers as prescribed under these alternatives would result in maximizing the reestablishment of 

forested habitat across this landscape when compared to Alternatives 2 and 4. These alternatives 

would provide the most habitat for great gray owls in close proximity to meadows in the long-term. 

Because habitat loss has been identified as a significant risk to great gray owl persistence across their 

range, reestablishing forest habitat across the landscape is paramount. Planting areas around meadow 

habitat as proposed under these alternatives would more quickly improve habitat conditions in the 

areas most important for breeding great gray owls. 

Thinning: About 600 acres of existing plantation are within 300 meters of meadow habitat. These 

units are located throughout the project area and associated with several meadows, including 

Ackerson Meadow which is currently occupied by great gray owls. While some of these plantations 

are considered suitable because they are CWHR size class 4 or 5 and have greater than 40% canopy 

cover, they lack structural diversity. Thinning these plantations would promote vertical and horizontal 

diversity which in turn improves habitat capability. Prescribed fire would be the first tool used for 

thinning these stands. The goal is to open up these stands, creating a habitat mosaic with individual 

trees, clumps of trees and openings. The ICO design would provide structural diversity where it does 

not currently exist. For example, the prescription calls for releasing oaks and retaining diverse specie 

and sizes of residual trees. After thinning, remaining trees are expected to grow faster and understory 

vegetation would increase and diversify, improving habitat conditions for great gray owls and their 

prey in the short and long-term. In addition, by breaking up the continuity of vegetation, the habitat 

would be more resilient when fire or other stochastic events occur.

Indicator 2

Under Alternatives 1 and 5, herbicide use is expected to have a limited potential for direct or indirect 

toxicological effects on great gray owls, as described under the herbicide risk assessment section.

Because no herbicides are proposed under Alternative 3, no exposure to herbicides and no direct, 

indirect, or cumulative toxicological effects to great gray owls would occur under this alternative. 

CUMULATIVE EFFECTS

Appendix B identifies the present and reasonably foreseeable future actions on all lands within the 

analysis area. Some, but not all of these actions have or may contribute cumulatively to effects on 

great gray owls.

Based on risk factors affecting great gray owls, the following evaluation criteria were used as relative 

measures of cumulative effects for Alternatives 1, 3 and 5: breeding habitat suitability. In addition, 

Alternatives 1 and 5 used toxicological effects for evaluation criteria.

Breeding Habitat Suitability

Federal Lands: Present and foreseeable future activities on federal lands include: Funky Stewardship, 

Groovy Stewardship, Reynolds Creek Stewardship, Soldier Creek Timber Sale, Campy Timber Sale, 

Looney Timber Sale and Thommy Timber Sale which are green thinning projects treating 6,546 acres 

of forest across the analysis area. All snags and many declining trees will be retained unless they pose 

a safety hazard in these projects. The snag and declining tree retention will provide snags that could 

serve as potential nest sites for great gray owls in the short-term as well as recruits for future nest sites 

in the long-term. Fuels reduction associated with the Rim Recovery project would reduce the risk of 

further loss of remaining green forest within the project area. Other federal activities potentially 

affecting breeding habitat for great gray owls is livestock grazing, meadow restoration and the 

creation of great gray owl nest structures.

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Thirteen grazing allotments are either wholly or partially within the analysis area, resulting in a 

maximum number of 1,632 cow/calf pairs across the project landscape. Livestock grazing may 

influence the abundance and availability of prey in wet meadows great gray owls use for foraging 

(Kalinowski et al. 2014). 

Livestock grazing is subject to utilization and forest plan standards that are specifically designed to 

minimize grazing impacts on great gray owl prey. Meadow restoration projects (Reynolds Creek, Rim 

Fire Rehabilitation, Twomile Meadow Restoration) are expected to improve great gray owl foraging 

habitat across about 180 acres. The Rim Fire Rehabilitation project will also result in the creation of 

30 to 50 nest structures adjacent to several meadows, replacing those lost in the fire as well as adding 

structures within the analysis area. Based on the biological evaluations for each of these projects, 

short-term impacts are minimal and great gray owl habitat is expected to improve in the long-term 

with implementation of these projects. 

Toxicological effects

Federal Lands: There is one present federal action of herbicide use on 0.5 acres under the Rim Fire 

Rehabilitation project and two foreseeable federal actions of herbicide use: 8.0 acres under the 

Twomile Ecological Restoration Noxious Weed project and 23 acres under a special use permit for 

the Reliable Power Project powerline. No other present or foreseeable future federal actions are 

related to herbicide use. 

Private Lands: Herbicide use is proposed on 1,583 acres of private land within the project area in 

2017. No other present or foreseeable future actions are proposed on private lands related to herbicide 

application. 

Alternatives 1 and 5 Contribution and Summary

Alternatives 1 and 5 would contribute cumulatively to short and long-term beneficial effects on great 

gray owl by providing suitable breeding habitat across 1,700 acres more quickly than the other action 

alternatives. They would also contribute cumulatively to short and long-term beneficial effects on 

great gray owls by providing higher quality breeding habitat across 600 acres of existing plantation 

proposed for thinning. These alternatives would result in similar benefits with respect to existing 

plantation thinning when compared to Alternatives 3 and 4 because the thinning prescription is the 

same under all action alternatives. Alternatives 1, 3 and 5 would complement the new nest structures 

being constructed adjacent to several of the meadows considered. Alternatives 1 and 5 would 

contribute to the short-term limited potential of exposure to toxicity from herbicide use. The longterm benefits of herbicide use include the eradication of noxious weeds near Ackerson Meadow and 

Jawbone Lavacap, which is expected to have beneficial effects on the habitat used by prey species 

important to great gray owls. The cumulative contribution under these alternatives may beneficially 

affect individual territories and the viability of this species.

Alternative 2

DIRECT AND INDIRECT EFFECTS

Under No Action, death, injury and disturbance would not be an issue because no active management 

would occur. 

Indicator 1 

The indirect effects of no action are primarily related to the influence no action may have on the 

amount and location of developing coniferous forest and how that may affect great gray owls. 

Because no active management would occur, it is unknown where naturally regenerating forest would 

occur, how long it would take to develop and what benefits it would provide great gray owls. 

Research and data collected from the project area show that areas in close proximity to live trees (i.e. 

seed source) experience limited forest expansion (Bonnet et al. 2005). Natural conifer expansion is 

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sporadic, could be delayed for decades due to shrub suppression and would not likely result in 

significant gains in forested habitat (Vegetation, Chapter 3.13). This could have greater implications 

for this population of great gray owls because they are already considered uncommon and rare on this 

landscape. If conifers are not planted to help reestablish breeding habitat in close proximity to 

meadows, the reduction in habitat availability could affect the number of great gray owls supported 

on the STF. Existing plantations would not be thinned under this alternative; therefore the benefits of 

increased structural diversity and improved habitat quality would not be realized. The plantations 

could be at greater risk of loss when fire returns to this landscape because of the tightly spaced live 

trees and fuel loading from fire killed trees (Fuels, Chapter 3.05). 

Indicator 2

Because no herbicides are proposed under this alternative, no exposure to herbicides and no direct, 

indirect, or cumulative toxicological effects to great gray owls would occur.

CUMULATIVE EFFECTS

The cumulative effects discussion under Alternatives 1, 3 and 5 outline those present and foreseeable 

future activities scheduled on public and private lands.

Alternative 2 Contribution and Summary

Under Alternative 2, no direct cumulative effect is expected because no active management would 

occur, however, there may be indirect consequences under this alternative primarily related to the 

influence no action may have on future forest development and how that may impact great gray owls. 

It is unknown if forest would naturally regenerate adjacent to meadows, which is a critical component 

of suitable breeding habitat. The cumulative contribution under this alternative may negatively affect 

individual territories and the number of great gray owls supported on the STF. It is unknown if this 

alternative would affect the viability of the species.

Alternative 4

DIRECT AND INDIRECT EFFECTS

Indicator 1

Reforestation: Under Alternative 4, up to 23 acres is proposed for reforestation within 300 meters of 

meadow habitat. The effects associated with this alternative are considered the same as under the no 

action, see discussion under Alternative 2. 

Thinning: Effects are the same as discussed under Alternatives 1, 3 and 5.

Indicator 2

Herbicide use is expected to have a limited potential for direct or indirect toxicological effects on 

great gray owls, as described under the herbicide risk assessment section above. 

CUMULATIVE EFFECTS

The cumulative effects discussion under Alternative 1 outlines those present and foreseeable future 

activities scheduled on public and private lands.

Alternative 4 Contribution and Summary

Under Alternative 4, a maximum of 23 acres is proposed for planting within 300 meters of meadow 

habitat. The cumulative contribution of Alternative 4 is primarily related to the influence this 

alternative may have on future forest development and how that may impact great gray owls. This 

alternative would not complement the existing plantation thinning nor would it completely 

complement the new nest structures being constructed adjacent to several of the meadows considered. 

This alternative would contribute cumulatively to short and long-term beneficial effects on great gray 

owls by providing suitable breeding habitat across 600 acres of existing plantation proposed for 

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thinning. This alternative would result in similar benefits with respect to existing plantation thinning 

when compared to Alternatives 1, 3 and 5 because the thinning prescription is the same under all 

action alternatives. The long-term benefits of noxious weed treatments near Ackerson Meadow and 

Jawbone Lavacap could be realized if prescribed fire and grazing are successful. Benefits include 

improved habitat condition in these areas used by prey species important to great gray owls.

Alternative 4 would contribute to the short-term limited potential of exposure to toxicity from 

herbicide use. The cumulative contribution under this alternative may negatively affect individual 

territories and may affect the number of great gray owls supported on the STF. It is unknown if this 

alternative would affect the viability of the species.

Great Gray Owl: Summary of Effects

Indicator 1. Table 3.16-10 shows the number of acres proposed for reforestation (planting) and the 

number of acres of existing plantation proposed for thinning within 300 meters of meadow habitat. 

Alternatives 1, 3 and 5 would provide the most future breeding habitat for great gray owls when 

compared to Alternative 4. All action alternatives would result in the same amount of future breeding 

habitat within the treated existing plantations; however, Alternative 4 does not complement the 

existing plantation treatments by accelerating forest reestablishment in adjacent areas as proposed 

under Alternatives 1, 3 and 5. 

Table 3.16-10 Great Gray Owl Summary of Effects: Future Moderate to High Capability Habitat

Metric Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5

Acres reforested1 1,700 0 1,700 0 1,700

Acres of existing plantation thinned 600 0 600 600 600

Total 2,300 0 2,300 600 2,300

1 Includes natural regeneration

Indicator 2. Herbicide use under Alternatives 1, 4 and 5 are expected to have limited potential for 

direct or indirect toxicological effects on great gray owls. Because Alternative 4 has fewer acres of 

herbicide application proposed, the potential for effects would be less than under Alternatives 1 and 5. 

However, it is important to note that the toxicity exposure scenarios analyzed in the risk assessment 

show that all HQs are several orders of magnitude less than the NOAEL threshold of concern;

therefore, great gray owls are provided an adequate margin of safety in the event that they are 

exposed to contaminated prey or water. 

DETERMINATIONS

Alternatives 1 and 5

Alternatives 1 and 5 may affect individuals but are not likely to result in a trend toward Federal listing 

or loss of viability for the great gray owl. This determination is based on the following rationale: 

 These alternatives include actions to reestablish forested habitat adjacent to meadows, 

accelerating the time in which these areas would be suitable for breeding.

 These alternatives include actions to thin existing plantations, accelerating the time in which these 

areas would be suitable for breeding.

 These alternatives require the use of LOPs to reduce disturbance potential.

 These alternatives provide for surveys to establish or confirm the location of activity centers and 

boundaries. 

 Toxicity exposure levels from herbicide use under these alternatives are all several orders of 

magnitude below the Forest Service established threshold of concern.

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Alternative 2

Alternative 2 may affect individuals but is not likely to result in a trend toward Federal listing or loss 

of viability for the great gray owl. This determination is based on the following rationale: 

 No actions would occur to potentially impact this species or its habitat. However, with no action 

to reestablish forested habitat, this alternative would result in less available breeding habitat in the 

short and long-term.

Alternative 3

Alternative 3 may affect individuals but is not likely to result in a trend toward Federal listing or loss 

of viability for the great gray owl. This determination is based on the following rationale: 

 This alternative includes actions to reestablish forested habitat adjacent to meadows, accelerating 

the time in which these areas would be suitable for breeding.

 This alternative includes actions to thin existing plantations, accelerating the time in which these 

areas would be suitable for breeding.

 This alternative requires the use of LOPs to reduce disturbance potential.

 This alternative provides for surveys to establish or confirm the location of activity centers and 

boundaries. 

 There would be no potential for exposure to herbicides. 

Alternative 4

Alternative 4 may affect individuals but is not likely to result in a trend toward Federal listing or loss

of viability for the great gray owl. This determination is based on the following rationale: 

 This alternative includes actions to thin existing plantations, accelerating the time in which these 

areas would be suitable for breeding.

 This alternative requires the use of LOPs to reduce disturbance potential.

 This alternative provides for surveys to establish or confirm the location of activity centers and 

boundaries. 

 Toxicity exposure levels from herbicide use under this alternative are all several orders of 

magnitude below the Forest Service established threshold of concern.

Northern Goshawk: Affected Environment

Species and Habitat Account

The northern goshawk (Accipiter gentilis) is a Region 5 Forest Service Sensitive species and is also 

listed with the State of California as a Species of Special Concern. Northern goshawks occur 

throughout North America and into Mexico. They occur throughout the Sierra Nevada year round and 

breed from about 2,400 feet to the crest as well as on the east side of the Sierra. On the west slope, 

they use a wide range of habitat types and are considered year round residents (USDA 2001). 

Population trend of goshawks in California are poorly known. Distributional changes and loss of 

breeding territories from timber harvest and wildfire across their range suggest the population size has 

been reduced (Shuford and Gardali 2008). Ongoing concern that populations and reproduction may 

be declining in California due to changes in the amount and distribution of habitat has been 

documented (USDA 2001). Bloom and others (1986) estimated a statewide population of 

approximately 1,300 breeding territory records on public and private lands. Recent synthesis of 

existing breeding territory records documented approximately 1,000 known territories statewide 

between 1970 and 2001 (J. Keane and B. Woodbridge unpubl. data). As of 2014, there are 93 

documented goshawk territories on the STF. 

Northern goshawk sites are identified through the use of protocol surveys (USDA 2000a). Protocol 

surveys for goshawk have been conducted throughout the Rim Fire area for the past two decades. 

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These surveys are best described as opportunistic depending upon planned activities and funding 

levels but have occurred at a level such that inventory information for the analysis area is considered 

essentially complete (USDA 2015). Surveys were conducted in 2014 and 2015, resulting in the 

addition of one new territory discovered in 2014. 

The project area is within the current distribution of northern goshawks across the Sierra Nevada 

Bioregion. There are currently 21 territories within the action area. LOPs will be placed around all 

documented goshawk PACs from February 15-September 15 of any given year during project 

implementation.

General habitat requirements for northern goshawks include forested environments with high canopy 

cover (i.e. greater than 40%) that feature vegetation types such as Montane Hardwood, Montane 

Hardwood Conifer, Ponderosa and Jeffrey Pine, Sierran Mixed Conifer, Lodgepole Pine and Red Fir 

(CDFW 2008). Moderate to High Capability habitat is defined as that in which a CWHR suitability 

rating is greater than or equal to 0.55. Two of three categories (reproduction, cover, food) must have a 

medium rating to achieve the minimum rating. Reference CWHR version 8.2 users’ manual for 

further explanation on suitability ratings (CDFW 2008). Acres include NFS lands only. There are 

about 42,800 acres of moderate and high capability habitat on NFS lands only. The remaining suitable 

habitat was fragmented by the Rim Fire. It is unknown to what extent this fragmentation has reduced 

the ability of goshawks to move between and utilize disjunct patches of habitat because they utilize a 

broad variety of habitats and have such large home ranges. There are about 75,800 acres of moderate 

and high capability habitat within the cumulative effects analysis area. 

Goshawks typically nest in areas with a high density of large trees, high canopy cover, high basal 

area, and gentle to moderate slopes (Reynolds et al. 1992; USDA 2001). Breeding typically occurs in 

late winter to spring and is dependent on elevation and weather conditions. Nest sites are the focal 

point of goshawk breeding territories and are described by Keane (1999) and Maurer (2000): 

 High canopy cover (average 65 to 70%). 

 Greater number of large, live trees between 24 to 39 inches dbh (average 22 per acre).

 Greater number of large, live trees greater than 24 inches dbh (about 33 to 38 per acre). 

 Open understory with low average shrub and sapling cover (about 9.9%). 

 Low average numbers of small trees in the understory (less than 121 trees per acre and less than 

226 trees per acre between 2 to 12 inches dbh). 

Goshawks construct stick nests in live conifer, hardwood trees or snags. These nests are typically 

built in the lower portion of the canopy in a fork or crook of a tree, and occasionally next to the bole 

(3 to 10 feet) on a large branch (USDA 2001). Nest trees are reported to be among the largest trees in 

a stand (Ibid). Data from the STF show trees or snags ranging from 14 to 65 inches dbh have been 

selected as nest trees. Goshawks typically build more than one nest, placing alternates in adjacent 

trees or up to a half mile away (Reynolds et al. 1992). Annual variation in reproduction can be 

influenced by prey abundance, late winter and early spring temperature (Keane 1999).

Northern goshawks hunt on the wing, from elevated perches, and on the ground. They feed on a 

variety of birds and mammals such as Steller’s jays, flickers, Douglas squirrels, and chipmunks 

(Ibid). The presence of structural elements such as snags and large downed woody debris provide 

important habitat for many prey species utilized by goshawks (Reynolds et al. 1992). Foraging habitat 

preferences of goshawks are poorly understood, although limited information from studies in conifer 

forests indicates they prefer to forage in mature forests with greater canopy closure and greater 

density of large trees greater than 40 inches dbh (Bright-Smith and Mannan 1994; Hargis et al. 1994). 

Reynolds et al. (1992) suggest that goshawks prefer relatively open shrub and lower canopy layers 

within forested stands, which may facilitate prey detection and capture. 

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Both natal and breeding dispersal are not well understood in northern goshawks due, in part, to the 

complexity of variables associated with dispersal, including the long distances that this species can 

disperse. Maximum natal dispersal distances in goshawks on the Kern Plateau were reported to range 

from 1.7 to 49 miles (Weins et al. 2006). One banded individual from this study was recovered 275 

miles beyond the study area, indicating that dispersal distances are highly variable. Local recruits 

with short dispersal distances have been reported to establish breeding territories within three to five 

territories from their natal area (Ibid).

Nonbreeding period home ranges average about 20,300 acres for males and about13,800 acres for 

females (USDA 2001). Breeding period home ranges average about 6,700 acres for males and about 

5,000 acres for females (Ibid). Adult’s exhibit site fidelity once breeding territories have been 

established (Reynolds and Joy 2006). Breeding dispersal does occur and has been reported at 

distances of about three to six miles for females and about two to four miles for males in Arizona and 

California (Reynolds and Joy 1998; Woodbridge and Detrich 1994). This species is not considered 

migratory, though limited altitudinal movements likely occur during winter months (USDA 2001). 

Stand replacing fire events have eliminated nesting territories but goshawks are known to nest in 

stands that have experienced understory fires that did not reduce canopy cover and numbers of large 

trees below suitable levels (USDA 2001).

RISK FACTORS

Bloom et al. (1986), Keane and Morrison (1994), Kennedy (1997), Squires and Reynolds (1997), 

Smallwood (1998), and USDA (2001) summarize risk factors potentially influencing the abundance 

and distribution of northern goshawks:

1. Loss of Breeding Habitat - The major threat to goshawks are loss of breeding habitat from 

wildfire and the effects of vegetation management (timber harvest, fuels treatments, etc.).

2. Breeding Site Disturbance - Breeding site disturbance from vegetation treatments, human 

recreation and falconry harvest can negatively affect individuals and potentially local populations. 

3. Chemical pollutants - Investigation of the potential risk of pollutants on this species, such as 

rodenticides and pesticides, is needed.

4. Climate - Weather and prey dynamics are primary factors affecting northern goshawk

reproduction and potential survival. Climatic changes resulting in wetter winters and springs can 

affect northern goshawk demography. 

Northern Goshawk: Environmental Consequences

The project alternatives could result in direct and indirect effects to the northern goshawk through the 

following activities:

 Mechanical site preparation for planting.

 Herbicide application for site preparation, release of conifers and noxious weed applications. 

 Planting and thinning conifers. 

These direct and indirect effects include:

 Project related death, injury and disturbance. 

 Project related modifications to habitat quantity and/or quality. 

Death, Injury and Disturbance

Death, injury and disturbance are potential direct effects to consider for northern goshawk (USDA 

2004). Project activities have the potential to cause death or injury by tree-falling or by the use of 

heavy equipment. Death or injury could occur if nest trees are felled while being used by nesting 

birds during the reproductive season. The mobility of the species in question and the management 

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requirement of LOPs make it highly improbable that death or injury would occur as a result of project 

activities.

Goshawks are highly susceptible to human disturbance (Squires and Reynolds 1997). During 

courtship and nest building, goshawks have been recorded to abandon nest areas following human 

intrusion alone (USDA 2000a). In addition, incubating or brooding females may interrupt incubation 

or nestling care for extended periods to defend a nest (Ibid). 

Logging activities near nests can cause failure, especially during incubation (Boal and Mannan 1994). 

Using heavy equipment too close to active nests can cause abandonment, even with 20 day-old 

nestlings present (Squires and Reynolds 1997). Loud noise from equipment such as chain saws or 

tractors is expected to occur in reforestation and thinning units. Human presence, particularly loud 

noise, has the potential to change normal behavior and potentially impair essential behavior patterns 

of the northern goshawk related to breeding, feeding or sheltering. The potential for disturbance is 

minimized by LOPs. 

The location of nest sites or activity centers are more uncertain following large-scale disturbance 

events (Keane, pers. comm.); conducting surveys to establish or confirm any new locations of nests or 

activity centers is a way to address this movement uncertainty (USDA 2000a). Conducting protocol 

surveys is a management requirement common to all action alternatives.

Habitat Modification

Woodbridge and Detrich (1994) found that northern goshawk territories associated with large 

contiguous forest patches were more consistently occupied compared to highly fragmented stands. 

Forested habitat is required by goshawks for roosting, nesting and foraging (Bright-Smith and 

Mannan 1994; Hargis et al. 1994; Reynolds et al. 1992; USDA 2001). Loss of breeding habitat from 

wildfire is known to be a risk factor affecting goshawk persistence in any given landscape. 

Reestablishing forested habitat in close proximity to remaining green forest, increasing habitat 

availability and reducing fragmentation across the project area would improve territory and landscape 

level habitat conditions for goshawks. Thinning existing plantations is also expected to accelerate 

growth rates and increase structural stand diversity, improving roosting, nesting and foraging habitat 

conditions sooner than without thinning. Thinning these areas would also increase resilience when 

fire returns to this landscape (Fuels, Chapter 3.05). Reforestation and thinning would promote the 

viability of goshawks across this landscape long-term.

Retention of snags and large downed woody debris is proposed under all action alternatives. Shortterm, within the next ten years, existing snags and down woody material will function as habitat 

elements important for goshawk prey. Snags also serve as potential hunting perch sites. Goshawks 

feed on a variety of prey present in post-fire habitat mosaics. Primary prey groups include tree and 

ground squirrels, cottontails, jackrabbits, hares and medium and large sized birds (Squires and 

Reynolds 1997). In the Sierra Nevada primary prey species are Douglas squirrel, golden- mantled 

ground squirrel, chipmunks, Steller’s jay, northern flicker and American robin (Keane 1999). 

Large snags and large down woody material are considered biological legacies in the post-fire 

environment and play important roles in the structure of the future forest (Lindenmayer et al. 2008). 

Snag dynamics in the Sierra Nevada are complex and snags fall at different rates depending on many 

factors (Cluck and Smith 2007). The time elapsed since fire is closely correlated with habitat 

elements present and the composition of prey species (Ingles 1965; Quinn and Keeley 2006). Ground 

squirrels, northern flickers and the American robin use a variety of open forest and shrub habitats 

with abundant insects and fruits (USDA 2001). Douglas squirrels use intermediate and mature stands 

containing large trees capable of providing cones and fungi, and Steller’s jays prefer mature forest 

with open to moderate canopy cover and large, mature trees (Ibid). Thus, snags and down woody 

material serve different functional roles overtime for the goshawk, first providing cover for prey in 

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the complex early seral stage of the forest, and ultimately decaying and playing a critical role in soil 

development of the future forest (Lindenmayer et al. 2008). 

The management of goshawk habitat is typically thought of in three spatial scales (Reynolds et al. 

1992; Reynolds et al. 2008). The first is the nesting habitat scale, or the PAC which corresponds to 

200 acres. The second addresses the post-fledging area which corresponds to about 420 acres (USDA 

2001), and the third addresses the whole foraging area or home range which corresponds to about 

5,000 to 7,000 acres (Ibid).

Goshawks in the Sierra Nevada are year-round residents, and expand their breeding ranges in the 

winter (Keane 1999). As northern goshawks focus their breeding activities around roost and nest sites 

within PACs and raising young to fledgling status, habitat modification effects are expected to be 

most pronounced in PACs and post-fledging areas.

Indicators

The following indicators were chosen to provide a relative measure of the direct and indirect effects 

to the goshawk and to determine how well project alternatives comply with Forest Plan Direction.

These criteria were chosen based on the best available scientific literature which focuses on various 

aspects of goshawk ecology and life history requirements. These criteria focus on those life history 

aspects, or habitat elements, considered most limiting to goshawk persistence across their range and 

where project effects are expected.

1. Acres of future moderate and high capability habitat planted or thinned. 

2. Toxicological effects from herbicide use. 

Alternatives 1, 3 and 5

Because there is little difference in the planting prescription and outcome in the short and long-term 

under these three alternatives, the effects are expected to be similar and are analyzed together. The 

difference in herbicides proposed between Alternatives 1 and 5 versus Alternative 3 were separated 

below accordingly. 

DIRECT AND INDIRECT EFFECTS

Indicator 1

Reforestation (includes natural regeneration): Under Alternatives 1, 3 and 5, there are about 1,400 

acres proposed for planting that fall within the estimated post fledgling areas of nine goshawk 

territories. Planting areas adjacent to and near goshawk territories as proposed under these 

alternatives would more quickly improve breeding habitat conditions for resident birds. Table 3.16-11 

displays the affected territories and acres proposed for reforestation. Under these alternatives an 

additional 23,000 acres are proposed for reforestation across the project area that have the potential to 

benefit goshawks at the landscape scale. Planting conifers as prescribed under these alternatives 

would increase the amount of habitat available to goshawks by 57% on STF lands in the long-term, 

maximizing the reestablishment of contiguous forested habitat across this landscape when compared 

to Alternatives 2 and 4. These alternatives would provide the greatest amount of habitat for goshawks 

in the long-term. Because habitat loss has been identified as a significant risk to goshawk persistence 

across their range, reestablishing forest habitat across the landscape is critical. At the landscape scale, 

reduced fragmentation and increased availability of suitable habitat is expected to benefit resident and 

dispersing goshawks. 

Thinning: Under Alternatives 1, 3 and 5, about 85 acres of planting fall within the estimated post 

fledgling areas of five goshawk territories. Thinning existing plantation adjacent to and near occupied 

territories would also contribute to improving breeding habitat conditions for resident birds in the 

short and long-term. Table 3.16-11 displays the affected territories and acres proposed for thinning. 

Under these alternatives an additional 7,150 acres of existing plantation are proposed for thinning that 

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have the potential to benefit goshawks at the landscape scale. While some of these plantations are 

considered suitable because they are CWHR size class 4 or 5 and have greater than 40% canopy 

cover, they lack structural diversity. Thinning these plantations would promote vertical and horizontal 

diversity which in turn improves habitat capability. Prescribed fire would be the first tool used for 

thinning these stands. Mechanical thinning prescriptions focus on using an ICO design that would 

provide structural diversity where it is currently lacking. For example, the prescription calls for 

releasing oaks and retaining diverse species and sizes of trees. After thinning, remaining trees are 

expected to grow faster and understory vegetation would become more abundant and diverse, 

improving habitat conditions for goshawks and their prey in the short and long-term. Also, by 

breaking up the continuity of vegetation across a given area, the habitat would be more resilient when 

fire or other stochastic events occur. 

Table 3.16-11 Alternatives 1, 3 and 5: Proposed Treatment Acres within Goshawk Post-fledging Areas

Goshawk PAC ID Reforestation1 Thin Existing

Plantation

Total Treatment Acres 

within Post-fledging Area

Dimond O - D54T46 162 6 168

Bear Mtn - D54T01 222 14 236

Pilot Ridge - D54T08 106 0 106

Corral Creek - D54T10 246 0 246

Lower Cherry Creek - D54T13 1 41 42

Skunk Creek - D54T21 111 10 121

Niagra - D54T41 104 0 104

Soldier Creek - D54T43 116 0 116

SF Tuolumne River - D54T44 34 13 47

1 Includes natural regeneration

Indicator 2

Under Alternatives 1 and 5, herbicide use is expected to have a limited potential for direct or indirect 

toxicological effects on goshawks, as described under the herbicide risk assessment section. Because 

no herbicides are proposed under Alternative 3, no exposure to herbicides and no direct, indirect, or 

cumulative toxicological effects to goshawks would occur. 

CUMULATIVE EFFECTS

Appendix B identifies the present and reasonably foreseeable future actions on all lands within the 

analysis area. Some, but not all of these actions have or may contribute cumulatively to effects on 

goshawks.

Based on risk factors affecting goshawks, the following evaluation criteria were used as relative 

measures of cumulative effects from Alternatives 1, 3 and 5: habitat modification. In addition, 

Alternatives 1 and 5 used toxicological effects for evaluation criteria.

Habitat Modification

Federal Lands: Present and foreseeable future activities on federal lands include: Funky Stewardship, 

Groovy Stewardship, Reynolds Creek Stewardship, Soldier Creek Timber Sale, Campy Timber Sale, 

Looney Timber Sale, Thommy Timber Sale, which are green thinning projects treating 6,546 acres of 

forest across the analysis area. All snags and many declining trees will be retained unless they pose a 

safety hazard in these projects. The snag and declining tree retention will provide snags that could 

serve as potential roost or nest sites for goshawks in the short-term as well as recruits for future nest 

sites in the long-term. Other federal activities potentially impacting breeding habitat for goshawks is 

fuels reduction associated with the Rim Recovery project. Fuels reduction associated with this project 

would reduce the risk of further loss of remaining green forest within the project area. 

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Toxicological Effects

Federal Lands: There is one present federal action of herbicide use on 0.5 acres under the Rim Fire 

Rehabilitation project and two foreseeable federal actions of herbicide use: 8.0 acres under the 

Twomile Ecological Restoration Noxious Weed project and 23 acres under a special use permit for 

the Reliable Power Project powerline. No other present or foreseeable future federal actions are 

related to herbicide use. 

Private Lands: Herbicide use is proposed on 1,583 acres of private land within the project area in 

2017. No other present or foreseeable future actions are proposed on private lands related to herbicide 

application. 

Alternatives 1, 3 and 5 Contribution and Summary

Alternatives 1, 3 and 5 would contribute cumulatively to short and long-term effects to northern 

goshawks. Under these alternatives, reforestation on about 24,400 acres would increase the amount of

moderate and high capability habitat available across the analysis area by 32% in the long-term. 

Under these alternatives about 7,240 acres of existing plantation would be thinned, promoting 

structural diversity and improving habitat capability in the short and long-term. These alternatives 

would result in similar benefits with respect to existing plantation thinning when compared to 

Alternative 4 because the thinning prescription is the same under all action alternatives. Alternatives 1 

and 5 would contribute to the short-term limited potential of exposure to toxicity from herbicide use. 

Alternatives 1, 3 and 5 would result in the greatest increase in available habitat and connectivity at the 

landscape scale when compared to Alternatives 2 and 4. The cumulative contribution under this 

alternative is expected to benefit resident and dispersing goshawks and is not expected to affect the 

viability of this species.

Alternative 2

DIRECT AND INDIRECT EFFECTS

Indicator 1

The indirect effects of no action are primarily related to the influence no action may have on the 

amount of moderate and high capability habitat available, the restoration of habitat connectivity 

across the landscape, and how that may impact northern goshawks in the long-term. Under this 

alternative, about 9,800 acres of forested habitat is predicted to develop naturally across the 

landscape. This would increase habitat availability across STF lands by 23%, almost two thirds less 

than that expected under Alternatives 1, 3 and 5. Because no active management would be used, it is 

unknown where naturally regenerating forest would occur and what benefits that would provide 

goshawks. It is likely that areas in close proximity to live trees (i.e. seed source) would experience 

forest expansion to a limited degree, depending on the competing vegetation in the localized area. It 

should be noted that natural conifer expansion is sporadic in nature, could be delayed for decades due 

to shrub suppression, would likely be dominated by fir and would not result in significant gains in 

forested habitat (Vegetation, Chapter 3.13). Areas far from seed sources would likely persist as 

chaparral for decades if not well over a hundred years. Existing plantations would not be thinned 

under this alternative; thereby, not increasing structural diversity or improving habitat quality. The 

plantations could be at greater risk of loss when fire returns to this landscape because of the tightly 

spaced live trees and fuel loading from fire mortality than if treated as proposed under the action 

alternatives (Fuels, Chapter 3.05). 

Indicator 2

Because no herbicides are proposed under Alternative 2, no exposure to herbicides and no direct, 

indirect, or cumulative toxicological effects to goshawks would occur. 

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CUMULATIVE EFFECTS

The cumulative effects discussion under Alternatives 1, 3 and 5 outlines those present and foreseeable 

future activities scheduled on public and private lands.

Alternative 2 Contribution and Summary 

Under Alternative 2, no direct cumulative effect is expected because no active management would 

occur, however, there may be indirect consequences under this alternative primarily related to the 

influence no action may have on future forest development and how that may impact northern 

goshawks. At the landscape scale, the cumulative contribution under this alternative would increase 

the available suitable habitat by 13% (9,800 acres) compared to a 32% increase (acres) under 

Alternatives 1, 3 and 5. It is unknown where it would occur and how long it would take natural 

regeneration to establish and what, if any, benefits that would provide to goshawks at the territory or 

landscape level. The cumulative contribution under this alternative may negatively affect individual 

or resident birds, but is not expected to affect the viability of this species. 

Alternative 4

DIRECT AND INDIRECT EFFECTS

Indicator 1

Reforestation: Under Alternative 4, about 208 acres proposed for planting fall within the estimated 

post fledgling areas of nine goshawk territories. This is 1,200 acres less than Alternatives 1, 3 and 5. 

Table 3.16-12 displays these territories and acres proposed for reforestation. Under this alternative, up

to 2,742 additional acres are proposed for reforestation within the project area. The planting 

prescription under this alternative is termed founder stands. This prescription calls for small variable 

shaped planting areas ranging from two to ten acres in size within a larger unplanted area. The 

unplanted area would likely be comprised of chaparral with scattered oaks. The planted area is only 

20% of a given unit. Herbicides would be used to control shrubs and competing vegetation within 

planted areas and incorporating a 50 foot buffer around planted areas. These trees would be planted 

with a much tighter spacing, groups of 5 trees spaced 6 feet from each other. With the tighter spacing 

it may be necessary to thin the plantations around year 7 to allow growing space for the trees to 

mature. Prescribed fire would be applied to 50% of the areas adjacent to the planted areas within ten 

years and the other 50% within 20 years. Reforesting in this manner would result in several small 

fragmented patches of forested habitat no bigger than ten acres separated by large tracts of chaparral. 

Small patches of forested habitat covering 20% of a given area would not provide the moderate and 

high capability habitat required by breeding goshawks, which include large tract of contiguous forest. 

Similar to the No Action Alternative, about 9,800 acres of forested habitat is predicted to develop 

naturally with no active management across the landscape. Because no active management would 

occur on these acres, it is unknown where naturally regenerating forest would occur and what benefits 

it would provide for goshawks. It is likely that areas in close proximity to live trees (i.e. seed source) 

would experience forest expansion to a limited degree, depending on the competing vegetation in the 

localized area. It should be noted that natural regeneration is sporadic in nature, could be delayed for 

decades due to shrub suppression, would likely be dominated by fir and would not result in 

significant gains in forested habitat (Vegetation, Chapter 3.13). Areas far from seed sources would 

likely persist as chaparral for decades if not well over a hundred years. Under this alternative forested 

habitat could increase up to 30% on STF lands, but it is unknown how fragmented or contiguous the 

distribution would be across the landscape and if it would provide benefits to goshawks at the 

territory or landscape scale.

Thinning: About 7,235 acres of existing plantation proposed for thinning have the potential to benefit 

goshawks at the PAC, post-fledging and landscape scale. Effects expected from plantation thinning 

are the same as those discussed under Alternatives 1, 3 and 5. 

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Table 3.16-12 Alternative 4: Proposed Treatment Acres within Goshawk Post-fledging Areas 

Goshawk PAC ID Reforestation1 Thin Existing

Plantation

Total Treatment Acres 

within Post-fledging Area

Dimond O - D54T46 26 6 31

Bear Mtn - D54T01 46 14 59

Pilot Ridge - D54T08 15 0 15

Corral Creek - D54T10 47 0 47

Lower Cherry Creek - D54T13 8 41 49

Skunk Creek - D54T21 22 10 32

Niagra - D54T41 19 0 19

Soldier Creek - D54T43 22 0 22

SF Tuolumne River - D54T44 3 13 16

1 Includes natural regeneration

Indicator 2

Herbicide use is expected to have limited potential for direct or indirect toxicological effects on 

goshawks, as described under the herbicide risk assessment section.

CUMULATIVE EFFECTS

The cumulative effects discussion under Alternatives 1, 3 and 5 outlines those present and foreseeable 

future activities scheduled on public and private lands.

Alternative 4 Contribution and Summary

Alternative 4 would contribute cumulatively to short and long-term effects to northern goshawks. 

Under this alternative, reforestation on up to 2,950 acres in discreet patches no larger than ten acres is 

not expected to result in benefits to goshawk. Reforestation and natural forest recovery is expected to 

increase available habitat by up to 17% across the analysis area. However, this natural forest recovery 

is expected to be sporadic, delayed and a limited contribution to moderate and high capability habitat 

in the long-term. The founder stands prescription is not expected to provide moderate and high 

capability habitat because it would be located in small fragmented patches separated by large tracts of 

chaparral. Under this alternative about 7,235 acres of existing plantation would be thinned, promoting 

structural diversity and improving habitat capability in the short and long-term. This alternative 

would result in similar benefits with respect to existing plantation thinning when compared to 

Alternatives 1, 3 and 5 because the thinning prescription is the same under all action alternatives. 

Alternative 4 would contribute to the short-term limited potential of exposure to toxicity from 

herbicide use. The cumulative contribution under this alternative is expected to provide limited 

benefits to resident and dispersing goshawks and is not expected to affect the viability of this species.

Northern Goshawk: Summary of Effects

Indicator 1. Table 3.16-13 shows the number of proposed planting acres and the number of existing 

plantation acres proposed for thinning at the post-fledging and landscape scales. Alternatives 1, 3 and 

5 would provide the greatest amount of moderate and high capability habitat for goshawks in the 

long-term when compared to Alternative 4. All action alternatives would result in the same amount of 

future moderate and high capability habitat within the treated existing plantations; however, 

Alternative 4 does not complement the existing plantation treatments by accelerating forest 

reestablishment in adjacent areas or across the landscape as proposed under Alternatives 1, 3 and 5. 

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Table 3.16-13 Northern Goshawk Summary of Effects: Future Moderate to High Capability Habitat

Metric Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5

Acres reforested in post-fledging area1 1,400 0 1,400 208 1,400

Acres reforested1 (landscape) 23,000 23,000 2,742 23,000

Total reforested acres 24,400 0 24,400 2,950 24,400

Acres of existing plantation thinned in 

post fledgling area 85 0 85 85 85

Acres of existing plantation thinned

(landscape) 7,235 7,235 7,235 7,235

Total thinned acres 7,320 0 7,320 7,320 7,320

1 Includes natural regeneration 

Indicator 2. Herbicide use under Alternatives 1, 4 and 5 are expected to have limited potential for 

direct or indirect toxicological effects on goshawks. Because Alternative 4 has fewer acres of 

proposed herbicide application, the potential for effects would be less than under Alternatives 1 and 5. 

However, it is important to note that the toxicity exposure scenarios analyzed in the risk assessment 

show that all HQs are several orders of magnitude less than the NOAEL threshold of concern; 

therefore, goshawks are provided an adequate margin of safety in the event that they are exposed to 

contaminated prey or water. 

Determinations

ALTERNATIVES 1 AND 5 

Alternatives 1 and 5 may affect individuals but are not likely to result in a trend toward Federal listing 

or loss of viability for the Northern goshawk. This determination is based on the following rationale: 

 These alternatives include actions to reestablish contiguous forested habitat, accelerating the time 

in which these areas would be suitable for nesting, roosting and foraging.

 These alternatives include actions to thin existing plantations, accelerating the time in which these 

areas would be suitable for nesting, roosting and foraging.

 Habitat connectivity would be restored under these alternatives.

 Snag retention in close proximity to green forest would result in maintaining roosting and nesting 

structures as well as habitat for prey throughout the treated areas.

 These alternatives require the use of LOPs to reduce disturbance potential to breeding goshawks. 

 These alternatives provide for surveys to establish or confirm the location of activity centers and 

boundaries. 

 Toxicity exposure levels from herbicide use under these alternatives are all several orders of 

magnitude below the Forest Service established threshold of concern. 

ALTERNATIVE 2 

Alternative 2 may affect individuals but is not likely to result in a trend toward Federal listing or loss 

of viability for the Northern goshawk. This determination is based on the following rationale:

 This alternative would result in the smallest increase in moderate to high capability habitat 

available to goshawk in the long-term.

 The structural diversity of existing plantations would not be promoted and thus habitat quality 

would not be improved in the short or long-term.

 Existing plantations may be at greater risk of loss when fire returns to this landscape.

 There would be no potential for exposure to herbicides. 

ALTERNATIVE 3 

Alternative 3 may affect individuals but is not likely to result in a trend toward Federal listing or loss 

of viability for the Northern goshawk. This determination is based on the following rationale:

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 This alternative includes actions to reestablish contiguous forested habitat, accelerating the time 

in which these areas would be suitable for nesting, roosting and foraging. 

 This alternative includes actions to thin existing plantations, accelerating the time in which these 

areas would be suitable for nesting, roosting, and foraging.

 Habitat connectivity would be restored under this alternative.

 Snag retention in close proximity to green forest would result in maintaining roosting and nesting 

structures as well as habitat for prey throughout the treated areas.

 This alternative requires the use of LOPs to reduce disturbance potential to breeding goshawks. 

 This alternative provides for surveys to establish or confirm the location of activity centers and 

boundaries. 

 There would be no potential for exposure to herbicides. 

ALTERNATIVE 4 

Alternative 4 may affect individuals but is not likely to result in a trend toward Federal listing or loss 

of viability for the Northern goshawk. This determination is based on the following rationale:

 This alternative includes actions to establish small fragmented patches of forest that would not 

provide suitable nesting or roosting habitat. 

 This alternative includes actions to thin existing plantations, accelerating the time in which these 

areas would be suitable for nesting, roosting and foraging.

 Snag retention in close proximity to green forest would result in maintaining roosting and nesting 

structures as well as habitat for prey throughout the treated areas.

 This alternative requires the use of LOPs to reduce disturbance potential to breeding goshawks. 

 This alternative provides for surveys to establish or confirm the location of activity centers and 

boundaries. 

 Toxicity exposure levels from herbicide use under this alternative are all several orders of 

magnitude below the Forest Service established threshold of concern. 

Pacific Marten: Affected Environment

Species and Habitat Account

The marten (Martes caurina) is a Region 5 Forest Service Sensitive species and is also a Sierra 

Nevada Management Indicator Species (MIS), as described in the Rim Fire Reforestation MIS report 

available in the project record. Marten occur throughout much of their historic range from Trinity and 

Siskyou counties east to Mount Shasta, south through the Cascades and Sierra Nevada ranges to 

Tulare County. They are considered rare when compared to other forest carnivore species (USDA 

2001). Their core elevation range is 5,500 to 10,000 feet. Marten have been documented on the STF

as low as 3,200 feet elevation.

Population estimates and trends are not available for marten in California. Although classified as a 

furbearer, there has been no open trapping season for this species since 1954 (USDA 2001). Declines 

in marten population size in the early twentieth century have been attributed to habitat modifications, 

trapping, and predator control. Based on surveys conducted from 1989-2002, the marten appears to 

occupy much of its historic range in California (Zielinski et al. 1995; Slauson et al. 2007). 

Carnivore camera stations have been employed within suitable habitat in and near the project area 

from 2005 to 2015. No marten detections were made as a result of these survey efforts (NRIS 

Wildlife database).

The project is within the current distribution of marten across the Sierra Nevada Bioregion. The 

nearest documented occurrence of marten was in 2006 less than two miles north of the project area 

near Reynolds Creek and south of the project area in Yosemite National Park. Their presence within 

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the analysis area is unknown; however, presence is assumed where suitable habitat exists. Because no 

documented den sites exist, LOPs for this species are not required for this project.

Marten are considered one of the most habitat-specific mammals in North America. Habitat quality is 

likened to the structural diversity consistent with late seral, mesic coniferous forests, interspersed with 

riparian areas and meadows. Preferred forest vegetation types include red fir, red fir/white fir mix, 

lodgepole pine, and Sierra mixed conifer (Freel 1991). Marten home ranges are very large relative to 

their body size. Mean home ranges in the central Sierra Nevada are 960 acres for males and 801 acres 

for females (USDA 2001). The analysis area still contains relatively high quality habitat for marten in 

areas that burned at low or low-moderate intensity such as Twomile, Bourland, and Reynolds Creek, 

Pilot Ridge and the Crocker Meadow area. Moderate to high capability habitat is defined as that in 

which a CWHR suitability rating is greater than or equal to 0.55. Two of three categories 

(reproduction, cover, food) must have a medium rating to qualify as moderate or high capability 

habitat. Suitable habitat consists of CWHR habitat types Jeffrey pine, lodgepole pine, montane 

hardwood conifer, ponderosa pine, red fir, sierra mixed conifer, and white fir and size classes 4P, M, 

D, 5M, D. The analysis area contains about 17,692 acres of moderate and high capability habitat on 

NFS lands only. About 45,300 acres of moderate and high capability habitat are within the cumulative 

effects analysis area, including all ownerships.

A road density of less than 1 mile of road per square mile has been recommended for high quality 

habitat for marten and a road density of 1 to 2 miles per square mile is recommended for medium 

capability habitat (USDA 1991). The road density including all routes open to motor vehicles in the 

analysis area is 3.0 miles per square mile on NFS lands and is more than twice the acceptable density 

found in high quality habitat and more than 1 mile per square mile above that found in moderate 

capability habitat.

Marten natal dens are typically found in cavities in large trees, snags, stumps, logs, shrubs, burrows, 

caves, rocks, or crevices in rocky areas (USDA 1991 and Zielinski et al. 1997). Dens are lined with 

vegetation and are found in structurally complex, late succession forests (Buskirk and Powell 1994). 

Breeding occurs from late June to early August, followed by embryonic diapause, and birth in MarchApril (Ibid). 

Freel (1991), Slauson (2003), and Spencer et al. (1983) characterized suitable habitat for 

denning/resting marten as follows:

 Canopy cover greater than or equal to 70%.

 Largest live conifers are greater than or equal to 24 inches dbh and occur at a density of at least 9 

per acre.

 Live tree basal area ranges from 163 to 326 square feet per acre.

 Snags average 25 square feet basal area per acre and average 30 inches dbh.

 Coarse woody debris is present at 5 to 10 tons per acre in decay classes 1 and 2. 

Marten diet varies geographically and seasonally with local prey availability. In the Central Sierra, 

marten diets are comprised primarily of voles, while in the southern Sierra it is squirrels and voles, 

insects, hypogeous fungi and secondarily (less than 20% of diet) reptiles and birds (Zielinski et al. 

1983; Zielinski and Duncan 2004). Zielinski and others (1983) noted Douglas squirrels, snowshoe 

hare, northern flying squirrels and deer mice were the prey species used almost exclusively during the 

winter, while ground squirrels formed the largest component of the diet from late spring through fall. 

Coarse woody debris is an important component of marten habitat, especially in winter, when it 

provides structure that intercepts snowfall and creates subnivean (below snow) tunnels, interstitial 

spaces, and access holes. Zielinski and others (1983) suggested that marten activity varied to take 

advantage of subnivean dens utilized by their prey. Sherburne and Bissonette (1994) found that when 

coarse woody debris covered a greater percent of the ground, marten use also increased. Older growth 

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forests appeared to provide accumulated coarse woody debris necessary to enable marten to forage 

effectively during the winter.

Freel (1991) and Spencer et al. (1983) characterized suitable habitat for travel/foraging marten as 

follows: 

 Canopy cover greater than or equal to 40%.

 Largest live conifers are greater than or equal to 24 inches dbh and occur at a density of at least 6 

per acre.

 Largest snags average 2.5 per acre and are greater than or equal to 24 inches dbh (8 sqarefeet per 

acre).

 Coarse woody debris is present at 5 to 10 tons per acre in decay classes 1 through 3. 

Reports of long-distance movements, likely representing dispersal, are largely anecdotal. Movement 

patterns in marten, dispersal and migration, have not been intensively studied for this species because 

of the difficulty and high cost of studying long-distance movements in small bodied mammals 

(Buskirk and Powell 1994; Ruggiero et al. 1994). Martens exhibit seasonal variation in habitat 

selection within stable home ranges, with little evidence to suggest shifts in home range boundaries. 

RISK FACTORS

Hargis et al. (1999) and USDA (2001) summarize several risk factors potentially influencing marten 

abundance and distribution: 

1. Habitat fragmentation – Fragmentation can limit occupancy and dispersal of marten across the 

landscape. Marten were negatively associated with low levels of habitat fragmentation. When the 

average nearest neighbor distance between non-forested patches was less than 100 meters, it 

created more edge and less interior forested habitat preferred by marten.

2. Meadow habitat degradation – Grazing can reduce the amount of shrub and herbaceous cover 

available and can increase soil compaction for prey species such as voles.

3. Fire suppression – Fire suppression has contributed to degraded conditions in meadows and 

riparian habitats by allowing encroachment of trees which reduces the availability of understory 

vegetation required by prey. 

4. Lack of, or removal of coarse woody debris - Removal of coarse woody debris (piles of several 

smaller logs, or single large logs) can also reduce access and abundance of prey during the 

important winter months, and may also reduce resting site availability for marten. 

Pacific Marten: Environment Consequences

The project alternatives could result in direct and indirect effects to the marten through the following 

activities:

 Mechanical site preparation. 

 Herbicide application for site preparation, release, and noxious weed applications. 

 Planting conifers.

These direct and indirect effects include:

 Project related death, injury and disturbance. 

 Project related modifications to habitat quantity or quality.

Death, Injury and Disturbance

Death or injury from project related activities would be unlikely to occur given the mobility of this 

species. However, if a den or rest tree were felled while being used by martens death or injury could 

occur. 

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Project activities, especially loud noise, could result in disturbance that may impair essential behavior 

patterns of the marten related to denning, resting or foraging. Loud noise from equipment such as 

chain saws, tractors or feller bunchers is expected to occur in all treatment units. The location of 

marten within the analysis area is uncertain following the 2013 Rim Fire, a large-scale disturbance 

event. Temporary avoidance of the project site or displacement of individuals is expected during 

project implementation. Any displacement or avoidance would be of short duration and would 

subside shortly after project completion. LOPs in place for spotted owls and goshawks would afford 

protection to individual marten in these areas during parturition, kit rearing and subsequent breeding 

(March through August). The potential risk to individual marten is considered low because of the lack 

of documented marten occurrence within or near the analysis area.

Habitat Modification

Reforesting areas that burned at high severity would accelerate development of forest habitat, 

increasing the amount of habitat available and restoring connectivity across the landscape. Active or 

managed reforestation is predicted to provide more complex habitat conditions in the long-term. For 

example, active reforestation would result in more large trees (e.g., greater than or equal to 24 inches 

dbh) and higher levels of snag recruitment when compared to the No Action Alternative. Thinning 

existing plantations is also expected to accelerate growth rates and increase structural stand diversity, 

improving foraging and breeding habitat conditions sooner than without thinning. Thinning these 

areas would also increase resilience when managed or wildfire returns to this landscape. Reducing

fragmentation and increasing the amount of interior forest is likely to increase habitat effectiveness 

and use by marten (Hargis et al. 1999). 

Retention of snags and large downed woody debris is proposed under all action alternatives. 

Retention of snags and downed logs within reforestation and thinning units and in close proximity to 

currently suitable habitat (green forest) would provide denning and resting sites, as well as habitat for 

prey species (Freel 1991). The number of snags and downed logs available across a marten’s home 

range affects the quality of that habitat for foraging and breeding. For example, they select sites with 

at least 25 square feet of basal area per acre of large snags (Slauson 2003; Spencer et al. 1983). While 

Spencer does not report an average dbh of snags, Slauson (2003) reports snags average 30 inches dbh 

in areas where marten were detected. In moderate and high capability traveling and foraging habitat 

they use areas with fewer snags, eight to twelve square of feet basal area per acre that are 24 inches 

dbh or greater (Freel 1991). 

Long-term, large snags and large downed logs are considered biological legacies in a post fire 

environment and play important roles in the structure of future forest (Lindenmayer et al. 2008). 

Large snags and downed logs may take hundreds of years to develop, emphasizing the need to retain 

these elements across the landscape. Because large snags and large downed logs are important habitat 

elements found in high capability marten habitat, it is important to retain these structural elements 

during project implementation to provide structural diversity within thinned or newly planted areas. 

Indicators

The following indicators were chosen to provide a relative measure of the direct and indirect effects 

to the marten and to determine how well project alternatives comply with Forest Plan Direction.

These criteria were chosen based on the best available scientific literature which focuses on various 

aspects of marten ecology and life history requirements. These criteria focus on those life history 

aspects, or habitat elements, considered most limiting to marten persistence across their range and 

where project effects are expected.

1. Acres of future moderate and high capability habitat planted and thinned. 

2. Toxicological effects from herbicide use. 

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Alternatives 1, 3 and 5

Because these three Alternatives propose reforestation and thinning within the same locations, the 

effects are expected to be similar and are analyzed together. The differences in herbicides proposed 

between Alternatives 1 and 5 versus Alternative 3 were separated below accordingly.

DIRECT AND INDIRECT EFFECTS

Indicator 1

Reforestation (includes natural regeneration): Under these alternatives, about 3,400 acres are 

proposed for reforestation within the elevation range typically used by marten. Planting conifers as 

prescribed under these alternatives would result in the restoration of moderate and high capability 

forested habitat across the landscape. This would increase the amount of habitat available to marten 

by 19% on STF lands in the long-term. While habitat connectivity is still largely intact at the 

landscape scale within this elevation range, the proposed reforestation would restore habitat 

connectivity to adjacent private lands that are also being reforested.

Thinning: About 4,900 acres of existing plantation are proposed for thinning within the elevation 

range used by marten. While some of these plantations are considered suitable because they are 

CWHR size class 4 or 5 and have greater than 40% canopy cover, they lack structural diversity. 

Thinning these plantations would promote vertical and horizontal diversity which in turn improves 

habitat capability. Prescribed fire would be the first tool used for thinning these stands. Mechanical 

thinning prescriptions for these plantations focus on using an ICO design that would provide 

structural diversity where it does not currently exist. For example, the prescription calls for releasing 

oaks and creating groups of trees separated by openings. After thinning, remaining trees are expected 

to grow faster and understory vegetation would become established, improving habitat conditions for 

marten and their prey in the short and long-term. By breaking up the continuity of vegetation across a 

given area, the habitat would be more resilient when fire or other stochastic events occur.

These alternatives address and maximize habitat suitability and connectivity in the short and longterm for marten on this landscape. Because marten have not been documented in the project area, it is 

unknown if marten would realize the benefits discussed in this analysis. 

Indicator 2

Under Alternatives 1 and 5, herbicide use is expected to have an extremely limited potential for direct 

or indirect toxicological effects on marten, as described under the herbicide risk assessment section. 

Because no herbicides are proposed under Alternative 3, no exposure to herbicides and no direct, 

indirect, or cumulative toxicological effects to marten would occur under this alternative.

CUMULATIVE EFFECTS

Appendix B identifies the present and reasonably foreseeable future actions on all lands within the 

analysis area. Some, but not all of these actions have or may contribute cumulatively to effects on 

marten. 

Based on risk factors affecting marten, the following evaluation criteria were used as relative 

measures of cumulative effects from Alternatives 1, 3 and 5: habitat modification. In addition, 

Alternatives 1 and 5 used toxicological effects for evaluation criteria.

Habitat Modification

Federal Lands: Present and foreseeable future activities on federal lands include: Funky Stewardship, 

Groovy Stewardship, Reynolds Creek Stewardship, Soldier Creek Timber Sale, Campy Timber Sale, 

Looney Timber Sale, Thommy Timber Sale, which are green thinning projects treating 6,546 acres of 

forest across the analysis area. All snags and many declining trees will be retained unless they pose a 

safety hazard in these projects. Downed woody debris will be retained at rates up to 20 tons per acre. 

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The snag, declining tree and downed log retention in these projects will provide snags and downed 

logs that could serve as potential denning or resting sites for marten in the short-term as well as 

recruits for future den and rest sites in the long-term. Fuels reduction associated with the Rim 

Recovery project will reduce the risk of further loss of remaining green forest within the project area. 

One other federal activity potentially impacting habitat for marten is meadow restoration. 

Meadow restoration projects (Reynolds Creek, Rim Fire Rehabilitation, Twomile Meadow 

Restoration) are expected to improve foraging habitat across about 290 acres. Treatments would 

result in improved functioning of meadow habitat, thus improve conditions for prey species that 

utilize these areas.

Toxicological Effects

Federal Lands: There is one present federal action of herbicide use on 0.5 acres under the Rim Fire 

Rehabilitation project and two foreseeable federal actions of herbicide use: 8.0 acres under the 

Twomile Ecological Restoration Noxious Weed project and 23 acres under a special use permit for 

the Reliable Power Project powerline. No other present or foreseeable future federal actions are 

related to herbicide use. 

Private Lands: Herbicide use is proposed on 1,583 acres of private land within the project area in 

2017. No other present or foreseeable future actions are proposed on private lands related to herbicide 

application. 

Alternatives 1, 3 and 5 Contribution and Summary

Alternatives 1, 3 and 5 would contribute cumulatively to short and long-term effects to marten. Under 

these alternatives, reforestation on about 3,400 acres would provide the most suitable foraging, 

denning and resting habitat when compared to Alternative 4. Reforestation under these alternatives 

would result in an 8% increase in moderate and high capability habitat available across the analysis 

area in the long-term. Under these alternatives about 4,900 acres of existing plantation would be 

thinned, promoting structural diversity and improving habitat capability in the short and long-term. 

These alternatives would result in similar benefits with respect to existing plantation thinning when 

compared to Alternative 4 because the thinning prescription is the same under all action alternatives. 

Alternatives 1 and 5 would contribute to the short-term limited potential of exposure to toxicity from 

herbicide use. Because no documented occurrences of marten exist in the project area, it is unknown 

to what degree the cumulative contribution under this alternative may affect individuals. The 

cumulative effects considered in this analysis are not expected to affect the viability of this species.

Alternative 2

DIRECT AND INDIRECT EFFECTS

Indicator 1

The indirect effects of no action are primarily related to the influence no action may have on the 

amount of suitable forested habitat available to marten in the long-term. Under this alternative, only 

about 940 acres of forested habitat is predicted to develop naturally with no active management 

within the elevation range of marten. Because no active management would occur, it is unknown 

where naturally regenerating forest would occur and what benefits that would provide marten. It is 

likely that areas in close proximity to live trees (i.e. seed source) would experience forest expansion 

to a limited degree, depending on the competing vegetation in the localized area. It should be noted 

that natural conifer expansion is sporadic in nature, could be delayed for decades due to shrub 

suppression, would likely be dominated by fir and would not result in significant gains in forested 

habitat (Vegetation, Chapter 3.13). Areas far from seed sources would likely persist as chaparral for 

decades if not more than a hundred years. Existing plantations would not be thinned under this 

alternative; therefore, increasing structural diversity and improving habitat quality would not be 

realized. The plantations could be at greater risk of loss when fire returns to this landscape because of 

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the tightly spaced live trees and fuel loading from fire mortality than if treated as proposed under the 

action alternatives. Habitat connectivity is still relatively intact where marten are expected to occur. 

This alternative would result in a very small increase in long-term habitat available to marten on STF 

lands. 

Indicator 2

Because no herbicides are proposed under Alternative 2, no exposure to herbicides and no direct, 

indirect, or cumulative toxicological effects to marten would occur under this alternative.

CUMULATIVE EFFECTS

The cumulative effects discussion under Alternatives 1, 3 and 5 outlines those present and foreseeable 

future activities scheduled on public and private lands.

Alternative 2 Contribution and Summary

Under Alternative 2, no direct cumulative effect is expected because no active management would 

occur, however, there may be indirect consequences under this alternative primarily related to the 

influence no action may have on future forest development and how that may impact marten. At the 

landscape scale, the cumulative contribution under this alternative would only increase the available 

suitable habitat by 2% (940 acres) compared to 8% (3,400 acres) under Alternatives 1, 3 and 5. 

Because no documented occurrences of marten exist in the project area, it is unknown to what degree 

the cumulative contribution of this alternative may affect individuals. The cumulative effects 

considered in this analysis are not expected to affect the viability of this species.

Alternative 4

DIRECT AND INDIRECT EFFECTS

Indicator 1

Effects expected resemble those discussed under the No Action alternative. Under Alternative 4, up to 

30 acres of unsuitable habitat are proposed for reforestation within the elevation range typically used 

by marten. Natural, unmanaged forest development is estimated to result in an increase of habitat 

available to marten by 5% on STF lands in the long-term, as discussed in the No Action alternative.

About 4,900 acres of existing plantation proposed for thinning are within the elevation range used by 

marten. Effects expected from plantation thinning are the same as those discussed under Alternatives 

1, 3 and 5. 

This alternative does not address or maximize habitat suitability and connectivity in the short or longterm for marten on this landscape. Because marten have not been documented in the project area, it is 

unknown if marten would be affected by implementation of this alternative or to what degree. 

Indicator 2

Herbicide use is expected to have an extremely limited potential for direct or indirect toxicological 

effects on marten, as described under the herbicide risk assessment section.

CUMULATIVE EFFECTS

The cumulative effects discussion under Alternatives 1, 3 and 5 outlines those present and foreseeable 

future activities scheduled on public and private lands.

Alternative 4 Contribution and Summary

Alternative 4 would contribute cumulatively to short and long-term effects to marten. Under this 

alternative, reforestation on up to 30 acres is not expected to result in measureable benefits to marten.

Natural forest recovery is expected to increase available habitat by 2% across the analysis area. This 

is 2,460 acres less forested habitat available to marten when compared to Alternatives 1, 3 and 5. 

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Under this alternative about 4,900 acres of existing plantation would be thinned, promoting structural 

diversity and improving habitat capability in the short and long-term. This alternative would result in 

similar benefits with respect to existing plantation thinning when compared to Alternatives 1, 3 and 5 

because the thinning prescription is the same under all action alternatives. Alternative 4 would 

contribute to the short-term extremely limited potential of exposure to toxicity from herbicide use. 

Because no documented occurrences of marten in the project area, it is unknown to what degree the 

cumulative contribution under this alternative may affect individuals. The cumulative effects 

considered in this analysis are not expected to affect the viability of this species.

Pacific Marten: Summary of Effects

Indicator 1. Table 3.16-14 shows the number of acres proposed for reforestation (planting) and the 

number of acres of existing plantation proposed for thinning within the elevation range typically used 

by marten. Alternatives 1, 3 and 5 would provide more moderate to high capability habitat for marten 

when compared to Alternative 4. All action alternatives would result in the same amount of future 

moderate and high capability habitat within the treated existing plantations. 

Table 3.16-14 Pacific Marten Summary of Effects: Future Moderate to High Capability Habitat

Metric Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5

Acres reforested1 3,400 0 3,400 30 3,400

Acres of existing plantation thinned 4,900 0 4,900 4,900 4,900

Total acres 8,300 0 8,300 4,930 8,300

1 Includes natural regeneration. 

Indicator 2. Herbicide use under Alternatives 1, 4 and 5 are expected to have an extremely limited 

potential for direct or indirect toxicological effects on marten because of the low Hazard Quotients 

related to exposure and the fact that no marten have been documented in the project area. Because 

Alternative 4 has fewer acres of herbicide application proposed, the potential for effects would be less 

than under Alternatives 1 and 5. It is important to note that the toxicity exposure scenarios analyzed 

in the risk assessment show that all HQs are well below the threshold of concern, and most are several 

orders of magnitude less than the threshold of concern or NOAEL. Marten are provided an adequate 

margin of safety in the event that they are exposed to contaminated prey, fruit or water. 

Determinations

ALTERNATIVES 1 AND 5 

Alternatives 1 and 5 may affect individuals but are not likely to result in a trend toward Federal listing 

or loss of viability for the Pacific marten. This determination is based on the following rationale: 

 These alternatives include actions to reestablish forested habitat, accelerating the time in which 

these areas would be suitable for resting, denning and foraging.

 These alternatives include actions to thin existing plantations, accelerating the time in which these 

areas would be suitable for resting, denning, and foraging.

 Habitat connectivity would be restored under these alternatives.

 Snag retention in close proximity to green forest would result in maintaining denning and resting 

structures as well as habitat for prey throughout the treated areas.

 LOPs for wildlife associated with similar habitat under these alternatives would reduce 

disturbance potential to marten. 

 Toxicity exposure levels from herbicide use under these alternatives are all well below the Forest 

Service established threshold of concern. 

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ALTERNATIVE 2 

Alternative 2 may affect individuals but is not likely to result in a trend toward Federal listing or loss 

of viability for the Pacific marten. This determination is based on the following rationale:

 This alternative would result in the smallest increase in moderate to high capability habitat 

available to marten in the long-term.

 The structural diversity of existing plantations would not be promoted and thus habitat quality 

would not be improved in the short-term.

 Existing plantations may be at greater risk of loss when fire returns to this landscape.

 There would be no potential for exposure to herbicides. 

ALTERNATIVE 3 

Alternative 3 may affect individuals but is not likely to result in a trend toward Federal listing or loss 

of viability for the Pacific marten. This determination is based on the following rationale:

 This alternative includes actions to reestablish forested habitat, accelerating the time in which 

these areas would be suitable for resting, denning and foraging.

 This alternative includes actions to thin existing plantations, accelerating the time in which these 

areas would be suitable for resting, denning and foraging.

 Habitat connectivity would be restored under this alternative.

 Snag retention in close proximity to green forest would result in maintaining denning and resting 

structures as well as habitat for prey throughout the treated areas.

 LOPs in place for wildlife associated with similar habitat under these alternatives would reduce

disturbance potential to marten. 

 There would be no potential for exposure to herbicides. 

ALTERNATIVE 4 

Alternative 4 may affect individuals but is not likely to result in a trend toward Federal listing or loss 

of viability for the Pacific marten. This determination is based on the following rationale:

 This alternative includes actions to thin existing plantations, accelerating the time in which these 

areas would be suitable for resting, denning and foraging.

 Snag retention in close proximity to green forest would result in maintaining denning and resting 

structures as well as habitat for prey throughout the treated areas.

 LOPs for wildlife associated with similar habitat under these alternatives would reduce 

disturbance potential to marten. 

 Toxicity exposure levels from herbicide use under this alternative are all well below the Forest 

Service established threshold of concern. 

Fisher: Affected Environment

Species and Habitat Account

The fisher (Pekania pennanti, formerly Martes pennanti pacifica) is a Region 5 Forest Service 

Sensitive species and a candidate for listing under the ESA. On October 7, 2014, the U.S. Fish and 

Wildlife Service (FWS) announced they were proposing to list the West Coast Distinct Population 

Segment (DPS) as threatened under the Endangered Species Act (USFWS 2014). The West Coast 

Fisher DPS includes all potential fisher habitats in Washington, Oregon and California from the east 

side of the Cascade Mountains and Sierra Nevada to the Pacific coast. The status review and proposed 

listing is a result of a multidistrict litigation settlement agreement under which the Service agreed to 

submit a proposed rule or a not-warranted finding to the Federal Register for the West Coast DPS of 

the fisher no later than the end of Fiscal Year 2014 (USFWS 2013). 

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Fishers have been listed with the State of California as a Species of Special Concern since at least 

1986 (Williams 1986). In 2009, the California Fish and Game Commission recommended that the 

fisher be assessed for listing as Threatened or Endangered under the California State Endangered 

Species Act. Based on the recommendation CDFW conducted a 12-month review and concluded that 

the fisher did not merit protection under the State Endangered Species Act in 2010. An 11 March 

2013 Notice of Findings stated that pursuant to court order, the FGC set aside its 15 Sep 2010 

findings rejecting the petition to list, and the Pacific fisher is a candidate species for the purposes of 

CESA. Although they accepted additional comments regarding the status of fisher, they did not 

change their finding. 

Fishers historically occurred in the Lassen, Plumas, Tahoe, Lake Tahoe Basin, Eldorado, Stanislaus, 

Sierra, and Sequoia National Forests. Zielinski and others (1995) determined that fishers remain 

extant in just two areas comprising less than half of the historic distribution: northwestern California 

and the southern Sierra Nevada from Yosemite National Park southward, separated by a distance of 

approximately 250 miles. 

A number of southern Sierra Nevada population estimates and simulations have been conducted for 

fisher populations occurring across the Sequoia and Sierra National Forests, Mountain Home State 

Park, tribal lands, Yosemite and Sequoia/Kings Canyon National Parks. These estimates range from 

100 to 600 adults (Lamberson et al. 2000; Spencer et al. 2008; Self et al. 2008). 

Status and trend monitoring for fisher and marten was initiated in 2002; the monitoring objective is to 

be able to detect a 20% decline in population abundance and habitat (USDA 2006). This monitoring 

includes intensive sampling to detect population trends on the Sierra and Sequoia national forests, 

where the fisher currently occurs, and is supplemented by less intensive sampling in suitable habitat 

in the central and northern Sierra Nevada specifically designed to detect population expansion. From 

2002 through 2008, 439 sites were surveyed throughout the Sierra Nevada on 1,286 sampling 

occasions, with the bulk of the sampling effort occurring within the Southern Sierra fisher population 

monitoring study area (USDA 2009). 

Preliminary results indicate that fishers are well-distributed in portions of the Sequoia and Sierra 

National Forests; annual occupancy rates are consistently higher on the Sequoia (33.3% to 41.1%) 

than the Sierra (14.5% to 22.7%) (USDA 2005). Comparisons to southern Sierra Nevada survey data 

from the 1990’s suggest that the areal extent of occurrence for fisher may have expanded during the 

past 10 years (USDA 2005). Thus there has been no conspicuous difference in occupancy rates 

among years, and no seasonal effects on detection probabilities within the June to October sampling 

periods (Truex et al. 2009). 

Carnivore cameras stations have been employed within suitable habitat in and near the analysis area 

in 2005 through 2015. No fisher detections were made as a result of these survey efforts (NRIS 

Wildlife database).

The project is within the historic distribution of fisher across the Sierra Nevada Bioregion. Fishers 

have been documented both in Yosemite National Park and south of the Merced River on the Sierra 

National Forest. Although their presence within the analysis area is undocumented, it is within 

dispersal distance of the closest known population, thus, their presence is assumed where suitable 

habitat exists. Because no documented den sites exist, LOPs for this species are not required for this 

project.

In the Sierra Nevada, fishers occur in mid-elevation forests (Grinnell et at. 1937; Zielinski et al. 1997) 

largely on NFS lands, below the elevations of most national parks and wilderness areas. In the 

southern Sierra Nevada, fishers occur sympatrically with martens at elevations of 5,000 to 8,500 feet 

in mixed conifer forests (Zielinski et al. 1995). The Sierra Nevada status and trend monitoring project 

has detected fishers as low as 3,110 feet and as high as 9,000 feet in the southern Sierra Nevada, 

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which are considered to be extremes of the elevation range for this species (USDA 2006). Male 

fishers have much larger home ranges than female fishers. Home range estimates for male fishers on 

the Sierra and Sequoia National Forests range from about 5,400 to 15,400 acres whereas female 

fishers range from 1,300 to 3,500 acres (Mazzoni 2002; Thompson et al. 2011; Zielinski et al. 1997 

and 2004a). These differences in home range size are attributed to size calculation techniques.

The following California Wildlife Habitat Relationships (CWHR) types occur in the project area and 

are considered important to fishers: generally structure classes 4M, 4D, 5M, 5D and 6 in ponderosa 

pine, montane hardwood-conifer, Sierran mixed conifer, red fir, white fir, Jeffrey pine and lodgepole 

pine (CDFW 2008). These stands are comprised of trees greater than 12 inches dbh and canopy cover 

greater than 40%.

Habitat connectivity across this landscape has been compromised by several large fires including the 

2013 Rim Fire, the 2003 Kibbie Fire and the 1996 Ackerson and Rogge Fires. The analysis area still 

contains relatively high quality habitat for fisher in areas that burned at low or low-moderate intensity 

such as Twomile, Bourland, and Reynolds Creek, Pilot Ridge and the Crocker Meadow areas. The 

analysis area contains about 40,000 acres of moderate and high capability habitat on the STF. Suitable 

habitat was greatly reduced in the heart of the analysis area and connectivity between large tracts of 

unoccupied habitat on the forest and currently occupied areas in Yosemite has been further reduced. 

Acres of suitable habitat lost in the Rim Fire were enough to have supported up to 25 female fishers 

(Spencer et al. 2015). The majority of this large tract of suitable habitat and the predicted linkage area 

between Yosemite and the STF was rendered unsuitable based on post-fire analysis (Ibid, USDA 

2014a). Spencer and others (2015) estimate that at least 14 modeled female fisher home ranges were 

rendered unsuitable because greater than or equal to 50% of the area burned at high severity. Figure 

3.16-1 displays the pre-Rim Fire suitable female fisher home ranges modeled by Spencer and others 

(2015) overlaid with the high severity burn areas (greater than or equal to 50% basal area mortality), 

illustrating the need for restoring forested habitat across this landscape.

This habitat fragmentation has reduced the likelihood of fisher moving through or dispersing and 

settling into the area until natural vegetation recovery or forest management practices, such as 

planting, effectively reestablishes connectivity. About 72,084 acres of moderate and high capability 

habitat are within the cumulative effects analysis area, this includes all ownerships. A new linkage 

corridor was identified that is largely intact after the Rim Fire and is located to the northof the former 

linkage corridor, straddling Lake Eleanor and Cherry Lake (Ibid).

A road density of 0 to 0.5 miles per square mile is associated with high capability habitat for fishers 

(USDA 1991). A road density of 0.5 to 2.0 miles per square mile is associated with medium 

capability habitat (Ibid). The road density including all routes open to motor vehicles in the analysis 

area is 3.0 miles per square mile on National Forest Service lands and is more than six times the 

acceptable density found in high quality habitat and more than 1 mile per square mile above that 

found in moderate capability habitat. 

Breeding occurs from late February through May, just a few days after giving birth to young. Den site 

structural elements must exist in the proper juxtaposition within specific habitats in order to provide a 

secure environment for birth and rearing of fisher kits. Natal dens, where kits are born, are most 

commonly in tree cavities at heights of greater than 20 feet (Lewis and Stinson 1998). Maternal dens, 

where kits are raised, may be in cavities closer to the ground so active kits can avoid injury in the 

event of a fall from the den (Ibid). 

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Figure 3.16-1 Pre-Rim Fire Suitable Female Fisher Home Ranges (2015)

Truex et al. 1998, Zielinski et al. 2004, Purcell et al. 2009 characterize suitable habitat for 

denning/resting as follows:

 Canopy cover greater than 60%. 

 Large live and dead conifers and hardwoods 21 to 51 inchesdbh; showing preference for largest 

tree or snag in area.

 Live and snag tree basal area ranges from 100 to 500 feet2 per acre.

Fishers are considered prey generalists and their diet varies widely with local prey available in the 

diverse habitats they occupy (Zielinski et al. 2006). Prey items include squirrels, voles, porcupine, 

snowshoe hares and reptiles (Zielinski and Duncan 2004). They also readily consume hypogeous 

fungi, fruit and deer carrion (Ibid). While information is lacking regarding fishers use of meadows, 

they are known to eat meadow voles and it is likely that they forage along meadow edges as marten

do. 

Freel 1991 characterized highly suitable habitat for foraging as follows: 

 Canopy cover greater than 40% with a shrub component in the understory. 

 Largest snags average 4 to 5 per acre and are greater than 20 inches dbh. 

 Downed logs average 4 per acre and are greater than 30 inches dbh. 

No research is available regarding fisher use of high severity burn areas in the first few years after a 

fire. Fishers have been documented in shrub habitat, but their activities and time spent in this habitat 

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are currently unknown (Thompson pers. comm.). Although not similar to the existing condition in the 

project area, 2 years post-fire, Hanson (2013) did look at fisher use of un-salvaged burned and 

unburned forest 10 to 12 years post-fire. Specific vegetative conditions along sampled transects at the 

time of the study were not presented; only the pre-fire CWHR vegetation type, size and density class 

were used. Thus it is unclear what the existing vegetative conditions were at the time of the study, 

such as understory vegetation composition and cover. Hanson (2013) found that fisher selected 

mixed-conifer forest in both post-fire habitat and unburned forest 10 to 12 years post-fire. Although 

fisher did use pre-fire dense, mature forest more than expected, the results were not significant. More 

research is needed to clarify fisher use and the value of burned habitat for this species (Spencer et al. 

2015). 

Dispersal ability is low in the western population and Arthur and others (1993) suggest that short 

dispersal distances (from 6 to 12 miles from natal home range) may be problematic in the 

maintenance of suitable fisher populations in areas where suitable habitat is fragmented. The current 

disjunct distribution pattern may also be partially attributed to movement and dispersal constraints 

imposed by the elongated and peninsular distribution of montane forests in the Pacific states (Wisely 

et al. 2004). The synergistic effect of road and rodenticide related mortalities documented in the 

southern Sierra populations, the apparent reluctance of fishers to cross open areas and the more 

limited mobility of this terrestrial mammal, make it more difficult for fishers to locate and occupy 

distant, but suitable, habitat. 

RISK FACTORS

1. Uncharacteristically Severe Wildfire- High severity wildfires have been increasing in number and 

intensity over the past several decades and this trend is predicted to continue. For example, the 

Rim Fire of 2013 removed 28,205 acres of moderate and high capability habitat, as defined 

above. Many fires within the current range of the fisher have resulted in the destruction of 

important denning, resting and foraging habitat. Spencer et al. (2008) found that the short-term 

negative localized effects to fisher from active vegetation management designed to reduce high 

severity wildfire in and near suitable habitat would out-weigh the positive long-term effects of 

protecting suitable fisher habitat. 

2. Vegetation Manipulation to Reduce Risk of Uncharacteristically Severe Wildfire- Aggressive 

stand thinning for forest health and reduced fire risk may remove important cover, snags and 

vegetative diversity for fisher. These treatments may prevent more adverse effects associated with 

drought and wildfire, but may nonetheless leave habitat with reduced value for fisher or even 

render it unsuitable.

3. Habitat Fragmentation, Loss of Connectivity- Habitat connectivity is key to maintaining fisher

within a landscape. Activities under Forest Service control that result in habitat fragmentation or 

population isolation pose a risk to the persistence of fishers. Timber harvest, fuels reduction 

treatments, road presence and construction, and recreational activities may result in the loss of 

habitat connectivity resulting in a negative impact on fisher distribution and abundance.

4. Climate Change- Climate change is a concern for fishers because of the widespread ecological 

effects. There is the potential that climate change could increase habitat quality for this species, 

but various models and studies appear to support the idea that the core habitat for fisher in the 

middle elevation would suffer from fires and disease.

Fisher: Environmental Consequences

The project alternatives could result in direct and indirect effects to the fisher through the following 

activities:

 Mechanical site preparation for planting.

 Herbicide application for site preparation, release of conifers and noxious weed applications. 

 Planting and thinning conifers.

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These direct and indirect effects include:

 Project related death, injury and disturbance. 

 Project related modifications to habitat quantity or quality.

Death, Injury and Disturbance

Death or injury from project related activities would be unlikely to occur given the mobility of this 

species. However, if a den or rest tree were felled while being used by fisher death or injury could 

occur. Project activities, especially loud noise, could result in disturbance that may impair essential 

behavior patterns of the fisher related to denning, resting or foraging. Loud noise from equipment 

such as chain saws or tractors is expected to occur in treatment units. The location of fisher within the 

analysis area is uncertain following the 2013 Rim Fire, a large- scale disturbance event; but surveys 

conducted to date have resulted in no detections of fisher in the project area. This is consistent with 

Regional monitoring that has resulted in no detection of fisher on the STF. Temporary avoidance of 

the project site or displacement of individuals is expected during project implementation. Any 

displacement or avoidance would be of short duration and would subside shortly after project 

implementation activities. LOPs in place for spotted owls, goshawks and great gray owls would 

afford protection to individual fisher in these areas during parturition, kit rearing and subsequent 

breeding (March through August). The potential risk to individual fisher is considered low because of 

the lack of documented fisher occurrence within or near the analysis area.

Habitat Modification

Reforesting areas that burned at high severity would accelerate development of contiguous forested 

habitat, increasing the amount of habitat available and restoring connectivity across the landscape.

These reforestation efforts are largely located within the Fisher Conservation Strategy Area, an area 

identified as an integral part of southern Sierra fisher conservation and northern expansion (Spencer 

et al. 2015). Active or managed reforestation is predicted to provide more complex habitat conditions 

in the long-term. For, example, active reforestation is expected to produce more large trees (e.g., 

greater than or equal to 24 inches dbh) and higher levels of snag recruitment when compared to the 

No Action Alternative. Thinning existing plantations is also expected to accelerate growth rates and 

increase structural stand diversity, improving foraging and breeding habitat conditions sooner. 

Thinning these areas would also increase resilience when managed or wildfire returns to this 

landscape (Fuels, Chapter 3.05). Reducing fragmentation across the landscape and increasing the 

amount of interior forest is likely to increase habitat effectiveness and use by dispersing and future 

resident fisher. While restoring the lost habitat and linkage area near the Tuolumne and Clavey River 

Canyons will take many decades, reforesting this area would provide long-term benefits. These 

benefits include; increasing habitat availability to support several breeding females and decreasing the 

bottleneck created by the Rim Fire where habitat and linkage between current populations in the south 

to suitable yet unoccupied habitat to the north is very limited. 

Retention of snags and large downed woody debris is proposed under all action alternatives. 

Retention of snags within and near suitable fisher habitat (green forest) would provide denning and 

resting sites as well as habitat for prey species (Freel 1991; Thompson et al. 2011; Zielinski et al. 

2004). The number of snags and downed logs available across a fisher’s home range affects the 

quality of habitat for foraging and breeding. Because resting and denning structures are likely the 

most limiting habitat elements within fisher home ranges, retaining these elements across the 

landscape is critical (Ibid).

No research is available regarding fisher use of high severity burn areas in the first few years after 

fire, fishers have been documented in shrub habitat, but their activities and time spent in this habitat is 

currently unknown (Thompson pers. comm.). Hanson (2013) looked at fisher use in burned versus 

unburned habitat in the McNally and Manter fire footprints 10 to 12 years post-fire in an area that was 

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not salvage logged. They report that fishers were using habitat that burned at moderate and high 

severity greater than 500 meters from the edge of unburned forest habitat, although these findings 

were not significant. The vegetative conditions of this research do not mimic the existing condition 

within the Rim Fire area because they are two years post-fire, not 10 to 12 years post-fire. Prey 

species that tolerate disturbance or open conditions are known to be abundant in post fire 

environments, such as mice, rats, chipmunks and squirrels (Amacher et al. 2008; Diffendorfer et al. 

2012). Structural elements such as snags and downed logs, when combined with the flush of shrubs, 

forbs and grasses returning post-fire, could provide habitat suitable for prey and foraging within a few 

years; however, more research is needed to clarify fisher use and the value of burned habitat for this 

species (Spencer et al. 2015). Reforestation efforts may result in the short-term removal of a small 

fraction of potential foraging habitat (i.e. burned forest in close proximity to green forest edge); 

however, currently, no documented fishers occur in the project area and the risk of effects to 

individuals is considered extremely low.

Large snags and large downed logs are considered biological legacies in a post fire environment and 

play important roles in the structure of future forest (Lindenmayer et al. 2008). Large snags and 

downed logs may take hundreds of years to develop, emphasizing the need to retain these elements 

across the landscape. Snag fall and decay rates vary considerably by species and can remain standing 

for decades (Cluck and Smith 2007; Ritchie et al. 2013). When snags eventually fall, they are 

incorporated as large downed logs, another critical structural element important for fisher and prey 

species (Freel 1991; Zielinski et al. 2004a).

Indicators

The following indicators were chosen to provide a relative measure of the direct and indirect effects 

to the fisher and to determine how well project alternatives comply with Forest Plan Direction and the 

Draft Conservation Strategy (Spencer et al. 2015). These criteria were chosen based on the best 

available scientific literature which focuses on various aspects of fisher ecology and life history 

requirements. These criteria focus on those life history aspects, or habitat elements, considered most 

limiting to fisher persistence across their range and where project effects are expected.

1. Acres of future moderate and high capability habitat planted and thinned. 

2. Toxicological effects from herbicide use.

Alternatives 1, 3 and 5

Because the areas proposed for reforestation and thinning are the same under these three alternatives, 

the effects are expected to be similar and are analyzed together. The differences in herbicides 

proposed between Alternatives 1 and 5 versus Alternative 3 were separated below accordingly.

DIRECT AND INDIRECT EFFECTS

Indicator 1

Reforestation (includes natural regeneration): Habitat availability and connectivity was much 

reduced by the Rim Fire and the proposed reforestation would restore a significant portion of lost 

habitat. Under these alternatives, about 23,800 acres are within the Fisher Conservation Strategy 

Area. Planting conifers as prescribed under these alternatives would result in the restoration of 

moderate and high capability forested habitat across the landscape. Reforestation under these 

alternatives would result in increasing the amount of moderate and high capability habitat available to 

fisher by 59% on STF lands in the long-term.

Thinning: About 8,000 acres of existing plantation are within the Fisher Conservation Strategy Area. 

While some of these plantations are considered suitable because they are CWHR size class 4 or 5 and 

have greater than 40% canopy cover, they lack structural diversity. Thinning these plantations would 

promote vertical and horizontal diversity which in turn improves habitat capability. Prescribed fire

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would be the first tool used for thinning these stands. Mechanical thinning prescriptions for these 

plantations focus on using an ICO design that would provide structural diversity where it does not 

currently exist. For example, the prescription calls for releasing oaks and retaining diverse conifer 

species and sizes. After thinning, remaining trees are expected to grow faster and the amount of 

understory vegetation would increase and diversify, improving habitat conditions for fisher and their 

prey in the short and long-term. By breaking up the continuity of vegetation across a given area, the 

habitat would be more resilient when fire returns to this landscape (Fuels, Chapter 3.05). 

Reforestation and thinning treatments proposed under these alternatives would begin the restoration 

of habitat that could support several female fishers in the future. These alternatives address and 

maximize habitat suitability and connectivity in the long-term for fisher at home range and landscape

scales, increasing connectivity within the Fisher Conservation Strategy Area Cores 6 and 7 as well as 

pre-fire linkage area. Although fishers have not been recently documented in the project area, benefits

could be realized if and when they occupy this landscape in the future. 

Indicator 2 

Under Alternatives 1 and 5, herbicide use is expected to have an extremely limited potential for direct 

or indirect toxicological effects on fisher, as described under the herbicide risk assessment section. 

Because no herbicides are proposed under Alternative 3, no exposure to herbicides and no direct, 

indirect, or cumulative toxicological effects to fisher would occur under this alternative. 

CUMULATIVE EFFECTS

Appendix B identifies the present and reasonably foreseeable future actions on all lands within the 

analysis area. Some, but not all of these actions have or may contribute cumulatively to effects on 

fisher. 

Based on risk factors affecting fishers, the following evaluation criteria were used as relative 

measures of cumulative effects from Alternatives 1, 3 and 5: habitat modification. In addition, 

Alternatives 1 and 5 used toxicological effects for evaluation criteria.

Habitat Modification

Federal Lands: Present and foreseeable future activities on federal lands include: Funky Stewardship, 

Groovy Stewardship, Reynolds Creek Stewardship, Soldier Creek Timber Sale, Campy Timber Sale, 

Looney Timber Sale, Thommy Timber Sale, which are green thinning projects treating 6,546 acres of 

forest across the analysis area. All snags and many declining trees will be retained unless they pose a 

safety hazard. The snag and declining tree retention will provide snags that could serve as potential 

denning or resting sites for fishers in the short-term as well as recruits for future denning or resting 

sites in the long-term. One other federal activity potentially impacting habitat for fishers is fuels 

reduction associated with the Rim Recovery project which will reduce the risk of further loss of 

remaining green forest within the project area.

Toxicological Effects

Federal Lands: There is one present federal action of herbicide use on 0.5 acres under the Rim Fire 

Rehabilitation project and two foreseeable federal actions of herbicide use: 8.0 acres under the 

Twomile Ecological Restoration Noxious Weed project and 23 acres under a special use permit for 

the Reliable Power Project powerline. No other present or foreseeable future federal actions are 

related to herbicide use. 

Private Lands: Herbicide use is proposed on 1,583 acres of private land within the project area in 

2017. No other present or foreseeable future actions are proposed on private lands related to herbicide 

application. 

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Alternatives 1, 3 and 5 Contribution and Summary

Alternatives 1, 3 and 5 would contribute cumulatively to short and long-term effects to fishers. Under 

these alternatives, reforestation on about 23,800 acres would provide the most suitable resting, 

denning and foraging habitat when compared to Alternative 4. The cumulative contribution of 

reforestation under Alternatives 1, 3 and 5 would result in a 33% increase in moderate and high 

capability habitat available across the analysis area in the long-term. Under these alternatives about 

8,000 acres of existing plantation would be thinned, promoting structural diversity and improving 

habitat capability in the short and long-term. These alternatives would result in similar benefits with 

respect to existing plantation thinning when compared to Alternative 4 because the thinning 

prescription is the same under all action alternatives. Alternatives 1 and 5 would contribute to the 

short-term limited potential of exposure to toxicity from herbicide use. Because no documented 

occurrences of fishers exist within the project area, it is unknown to what degree the cumulative 

contribution would be under these alternatives to affect individuals. The cumulative effects 

considered in this analysis have the potential to beneficially affect the viability of this species. 

Alternative 2

DIRECT AND INDIRECT EFFECTS

Indicator 1

The indirect effects of no action are primarily related to the influence no action may have on the 

amount of suitable forested habitat available to fishers in the long-term. Under this alternative, only 

about 9,800 acres of natural regeneration is predicted to occur within the Fisher Conservation 

Strategy Area. This would increase habitat availability across STF lands by 24%, almost two thirds 

less than that expected under Alternatives 1, 3 and 5. Because no active management is proposed, it is 

unknown where naturally regenerating forest would occur, how long it would take to develop and 

what benefits it would provide fishers. Research and monitoring data from the project area show that 

areas in close proximity to live trees (i.e. seed source) would experience forest expansion to a limited 

degree, depending on the competing vegetation in the localized area (Bonnet et al. 2005). It should be 

noted that natural conifer expansion is sporadic in nature, could be delayed for decades due to shrub 

suppression, would likely be dominated by fir and would not result in significant gains in forested 

habitat (Vegetation, Chapter 3.13). Areas far from seed sources would likely persist as chaparral for 

decades if not well over a hundred years. Existing plantations would not be thinned under this 

alternative; therefore, no increase in structural diversity or improvement of habitat quality would 

occur. The plantations, if left untreated, could be at greater risk of loss when fire returns to this 

landscape because of the tightly spaced live trees and existing fuel loads (Fuels, Chapter 3.05). 

Habitat connectivity would not be restored in critical areas such as the Tuolumne River Canyon, 

which was considered the most likely route for fisher dispersal and movement between large tracts of 

suitable habitat prior to the Rim Fire (Spencer et al. 2015). This alternative could result in a small 

increase in long-term habitat available to fishers on STF lands.

Indicator 2 

Because no herbicides are proposed under Alternative 2, no exposure to herbicides and no direct, 

indirect, or cumulative toxicological effects to fisher would occur under this alternative. 

CUMULATIVE EFFECTS

The cumulative effects discussion under Alternatives 1, 3 and 5 above outlines those present and 

foreseeable future activities scheduled on public and private lands.

Alternative 2 Contribution and Summary

Under Alternative 2, no direct effect is expected because no active management would occur, 

however, there may be indirect consequences primarily related to the influence no action may have on 

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future forest development and how that may impact fishers. At the landscape scale, the cumulative 

contribution under this alternative would potentially increase the available suitable habitat by up to 

14% compared to a 33% increase under Alternatives 1, 3 and 5. Because there are no documented 

occurrences of fishers in the project area, it is unknown if or to what degree the cumulative 

contribution under this alternative may affect individuals or the viability of this species. 

Alternative 4

DIRECT AND INDIRECT EFFECTS

Indicator 1

Under Alternative 4, about 2,950 acres are proposed for reforestation within the Fisher Conservation 

Strategy Area. This is 20,850 acres less than proposed under Alternatives 1, 3 and 5. The planting 

prescription under this alternative is termed founder stands. This prescription calls for small variable 

shaped planting areas ranging from two to ten acres in size within a larger unplanted area. The 

unplanted area would likely be comprised of chaparral with scattered oaks. The planted area is only 

20% of a given unit. Herbicides would be used to control shrubs and competing vegetation within 

planted areas and incorporate a 50 foot buffer around planted areas. These trees would be planted 

with a much tighter spacing, groups of 5 trees spaced 6 feet from each other. With the tighter spacing 

of planted trees, it may be necessary to thin trees sooner. Prescribed fire would be applied to 50% of 

planted areas within ten years and the other 50% within 20 years. Reforesting in this manner would 

result in several small fragmented patches of forested habitat no bigger than ten acres separated by 

large tracts of chaparral. Small patches of forested habitat covering 20% of a given area would not 

provide the moderate and high capability habitat required by fishers, which includes large tracts of 

contiguous forest. Similar to the No Action Alternative, about 9,800 acres of forested habitat is 

predicted to develop naturally with no active management across the landscape. Because no active 

management would occur on these acres, it is unknown where naturally regenerating forest would 

occur and what benefits it would provide for fishers. It is likely that areas in close proximity to live 

trees (i.e. seed source) would experience forest expansion to a limited degree, depending on the 

competing vegetation in the localized area. As stated under the No Action Alternative, natural conifer 

expansion is sporadic, could be delayed for decades, would likely be dominated by fir and would not 

result in significant gains in forested habitat (Vegetation, Chapter 3.13). Areas far from seed sources 

would likely persist as chaparral for decades if not well over a hundred years. While this alternative 

would increase the amount of forested habitat across STF lands by up to 24%, it is unknown how 

fragmented or contiguous the distribution would be and if it would provide benefits to fishers at the 

home range or landscape scale.

Thinning: About 8,000 acres of existing plantation proposed for thinning are within the Fisher

Conservation Strategy Area. Effects expected from plantation thinning are the same as those 

discussed under Alternatives 1, 3 and 5. 

In summary, this alternative does not address or maximize habitat suitability and connectivity in the 

short or long-term for fishers at the home range or landscape scale. Because fishers have not been 

recently documented in the project area, it is unknown if fishers would be affected by implementation 

of this alternative or to what degree.

Indicator 2

Herbicide use is expected to have an extremely limited potential for direct or indirect toxicological

effects on fisher, as described under the herbicide risk assessment section.

CUMULATIVE EFFECTS

The cumulative effects discussion under Alternatives 1, 3 and 5 outlines those present and foreseeable 

future activities scheduled on public and private lands.

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Alternative 4 Contribution and Summary

Alternative 4 would contribute cumulatively to short and long-term effects to fishers. Under this 

alternative, reforestation on up to 2,950 acres in discrete, fragmented patches is not expected to result 

in any measureable benefits to fishers. Reforestation and natural forest recovery under this alternative 

is expected to increase available habitat by up to 14% across the analysis area. However, this natural 

forest recovery is expected to be sporadic, delayed and provide a limited contribution to moderate and 

high capability habitat in the long-term. The founder stands prescription is not expected to provide 

moderate and high capability habitat because it would be located in small fragmented patches 

separated by large tracts of chaparral. Under this alternative about 8,000 acres of existing plantation 

would be thinned, promoting structural diversity and improving habitat capability in the short and 

long-term. This alternative would result in similar benefits with respect to existing plantation thinning 

when compared to Alternatives 1, 3 and 5 because the thinning prescription is the same under all 

action alternatives. Alternative 4 would contribute to the short-term potential of exposure to toxicity 

from herbicide use, but this would be extremely limited. Because no documented occurrences of 

fishers exist in the project area, it is unknown to what degree the cumulative contribution under this 

alternative may affect individuals. The cumulative contribution under this alternative would not result 

in beneficial effects to the viability of this species.

Fisher: Summary of Effects

Indicator 1. Table 3.16-15 displays the number of acres proposed for reforestation (planting) and the 

number of acres of existing plantation proposed for thinning within the Fisher Conservation Strategy 

Area. Alternatives 1, 3 and 5 would provide more moderate to high capability habitat for fishers when 

compared to Alternative 4. Habitat provided under Alternatives 1, 3 and 5 would consist of large 

tracts of contiguous forest, reducing fragmentation across the landscape. Habitat provided under 

Alternative 4 would be much more fragmented, reducing its effectiveness for fishers. All action 

alternatives would result in the same amount of future moderate and high capability habitat within the 

treated existing plantations. 

Table 3.16-15 Fisher Summary of Effects: Future Moderate to High Capability Habitat

Metric Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5

Acres reforested1 23,800 0 23,800 2,950 23,800

Acres of existing plantation thinned 8,000 0 8,000 8,000 8,000

Total acres 31,800 0 31,800 10,950 31,800 1 Includes natural regeneration

Indicator 2. Herbicide use under Alternatives 1, 4 and 5 are expected to have an extremely limited 

potential for direct or indirect toxicological effects on fisher because of the low Hazard Quotients 

related to exposure and no fishers have been documented in the past several decades within the 

project area. Because Alternative 4 has fewer acres of proposed herbicide application, the potential 

for effects would be less than under Alternatives 1 and 5. It is important to note that the toxicity 

exposure scenarios analyzed in the risk assessment show that all HQs are well below the threshold of 

concern, and most are several orders of magnitude less than the NOAEL. Fishers are provided an 

adequate margin of safety in the event that they are exposed to contaminated prey, fruit or water.

Determinations

ALTERNATIVES 1 AND 5 

Alternatives 1 and 5 may affect but are not likely to jeopardize the continued existence of the fisher. 

This determination is based on the following rationale: 

 These alternatives include actions to reestablish contiguous forested habitat, accelerating the time 

in which these areas would be suitable for resting, denning and foraging.

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 These alternatives include actions to thin existing plantations, accelerating the time in which these 

areas would be suitable for resting, denning and foraging.

 Habitat connectivity would be restored under these alternatives.

 Snag retention in close proximity to green forest would result in maintaining denning and resting 

structures as well as habitat for prey throughout the treated areas.

 LOPs for wildlife associated with similar habitat under these alternatives would reduce 

disturbance potential to fishers. 

 Toxicity exposure levels from herbicide use under these alternatives are all well below the Forest 

Service established threshold of concern. 

ALTERNATIVE 2 

Alternative 2 may affect but is not likely to jeopardize the continued existence of the fisher. This

determination is based on the following rationale: 

 This alternative would result in the smallest increase in moderate to high capability habitat 

available to fishers in the long-term.

 The structural diversity of existing plantations would not be promoted and thus habitat quality 

would not be improved in the short-term.

 Existing plantations may be at greater risk of loss when fire returns to this landscape.

 There would be no potential for exposure to herbicides. 

ALTERNATIVE 3 

Alternative 3 may affect but is not likely to jeopardize the continued existence of the fisher. This

determination is based on the following rationale: 

 This alternative includes actions to reestablish contiguous forested habitat, accelerating the time 

in which these areas would be suitable for resting, denning and foraging. 

 This alternative includes actions to thin existing plantations, accelerating the time in which these 

areas would be suitable for resting, denning, and foraging.

 Habitat connectivity would be restored under this alternative.

 Snag retention in close proximity to green forest would result in maintaining denning and resting 

structures as well as habitat for prey throughout the treated areas.

 LOPs for wildlife associated with similar habitat under these alternatives would reduce 

disturbance potential to fishers. 

 There would be no potential for exposure to herbicides. 

ALTERNATIVE 4 

Alternative 4 may affect but is not likely to jeopardize the continued existence of the fisher. This

determination is based on the following rationale: 

 This alternative includes actions to establish small fragmented patches of forest that would not 

provide suitable resting, denning, or foraging habitat. 

 This alternative includes actions to thin existing plantations, accelerating the time in which these 

areas would be suitable for resting, denning, and foraging.

 Snag retention in close proximity to green forest would result in maintaining denning and resting 

structures as well as habitat for prey throughout the treated areas.

 LOPs for wildlife associated with similar habitat under these alternatives would reduce 

disturbance potential to fishers. 

 Toxicity exposure levels from herbicide use under this alternative are all well below the Forest 

Service established threshold of concern. 

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Fisher: Consistency with the Fisher Conservation Strategy

Applicable Conservation Measures from the Conservation Strategy

Objective 1.1: Increase the geographic extent of occupied fisher habitat, especially via northward 

expansion into currently unoccupied habitat cores. 

Conservation Measure: Manage for increased quality and quantity of fisher habitat, and mitigate 

dispersal impediments.

Objective 1.2: Maintain or increase fisher carrying capacity within each core area.

Conservation Measure: Manage vegetation to restore fine-scale habitat heterogeneity, promote 

denning habitat quality and extent, retain and recruit essential fisher habitat elements, increase and 

diversify the fisher prey base, promote growth and recruitment of black oaks, and increase forest 

resilience to climate change and disturbance events.

Objective 2.1: Increase dispersal potential within and between core habitat areas.

Conservation Measure: Where site conditions permit in delineated linkage areas, maintain or increase 

tree canopy cover and retain and promote recruitment of downed logs, standing trees, and shrub 

patches to provide hiding and escape cover in non-forested portions; prevent new impediments to 

movement (e.g., wide openings, reservoirs); protect linkage areas from stand-replacing fire.

Objective 3.1: Improve fisher habitat resiliency and restore fire as a key ecological process.

Conservation Measure: Reduce hazardous fuel conditions and increase habitat heterogeneity patterns 

that reflect how topography, soil, and other factors affect vegetation characteristics and fire behavior; 

implement ecological restoration concepts described in GTR 220/237 to promote conditions that 

allow fire to serve its natural ecological role in maintaining resilient and heterogeneous forest 

conditions; maximize use of prescribed fire or wildfire managed for resource benefits at large scales 

and under conditions that promote resiliency and fisher habitat values.

Objective 3.2: Maintain or increase important fisher habitat elements.

Conservation Measure: Retain and promote recruitment of large trees, coarse woody debris (large 

snags and logs), trees with cavities and other defects, large black oaks, dense tree clusters and gaps at 

fine (less than 0.5 acres) resolution and clumps of multi-storied tree canopies.

Consistency with the Fisher Conservation Strategy

Alternatives 1, 3 and 5 manage for contiguous forested habitat and connectivity across the landscape 

through reforestation within about 80 years. 

Alternative 4 manages for small fragmented patches of forested habitat no larger than ten acres each 

across the landscape within about 80 years. 

Alternatives 1, 3, 4 and 5 manage for heterogeneity, promoting retention of fisher habitat elements, 

releasing black oaks and increasing habitat resilience by thinning existing plantations.

Alternatives 1, 3, 4 and 5 manage for heterogeneity, planting multiple conifer species including pine, 

cedar and fir, and buffering oaks when planting. 

Alternatives 1 and 3 manage for heterogeneity that reflects topography, soil and other factors 

highlighted in GTR 220/237 by using different prescriptions and desired conditions where appropriate 

on the landscape that implement these concepts.

Alternative 5 manages for heterogeneity that reflects topography, soil and other factors highlighted in 

GTR 220/237 by using different prescriptions, pre-commercial thinning treatments and desired 

conditions where appropriate across the landscape that implement these concepts.

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Alternatives 1, 3, 4 and 5 manage to reduce hazardous fuels, increase habitat heterogeneity reflecting 

topography, soil and other factors as highlighted in GTR 220/237 by thinning using the ICO concept 

and introducing prescribed fire to existing plantations. 

Alternatives 1, 3, 4 and 5 promote retention of large trees (conifers and black oaks), snags and logs, 

trees clusters and gaps (ICO) and multi storied canopies in existing plantations. 

Alternatives 1, 3, 4 and 5 manage to retain large snags and logs in reforestation units to contribute to 

the development of future forest.

Fringed Myotis, Pallid and Townsend’s Big-Eared Bat: Affected Environment

Species and Habitat Accounts

The pallid bat (Antrozous pallidus) is a Region 5 Forest Service Sensitive species and is designated as 

a Species of Special Concern by CDFW. They occur in arid regions of western North America from 

British Columbia to Mexico and east to Wyoming (Hermanson and O’Shea 1983). They are usually 

found in low to mid elevation habitats below 6,000 feet; however, they have been documented up to 

10,000 feet in the Sierra Nevada (USDA 2001). Considered yearlong residents, they inhabit 

vegetation types such as Blue Oak Woodland, Mixed Chaparral, and coniferous forests (CDFW 

2014b, Baumbach pers. obs.). 

The fringed myotis (Myotis thysanodes) is a Region 5 Forest Service Sensitive species and is 

designated as a Species of Special Concern by CDFW. The fringed myotis occurs from southern 

British Columbia south through the western United States and most of Mexico (O’Shea and Bogan 

2003). In California, it occurs from near sea level at the coast to elevations of at least 6,400 feet in the 

Sierra Nevada and in a variety of habitats from low desert scrub to high-elevation conifer forest 

(Philpott 1997). The fringed myotis is a widely distributed species, but it is considered rare (Ibid). 

Although this species occurs in netting and night roost surveys in a number of localities, it is always 

one of the rarest taxa (Pierson et al. 1996).

The Townsend’s big-eared bat (Corynorhinus towsendii) is a Region 5 Forest Service Sensitive 

species and is designated as a candidate for Threatened status under the California Endangered 

Species Act (CESA). They occur in low desert to mid-elevation montane habitats throughout the west 

and are distributed from the southern portion of British Columbia south along the Pacific Coast to 

central Mexico and east into the Great Plains, with isolated populations occurring in the south and 

southeastern United States (Kunz and Martin 1982). They can be found from sea level to 10,000 feet 

elevation and are considered yearlong residents. Their distribution in California is strongly correlated 

with limestone caves, old mines, and abandoned buildings (Ibid, USDA 2001). In the Sierra Nevada, 

they are associated with vegetation types such as Blue Oak Woodland, Sierran Mixed Conifer, and 

Montane Riparian (CDFW 2008). 

The status of pallid, fringed myotis and Townsend bat populations is not well researched, but all 

populations are thought to have declined over the past several decades (Williams 1986, Macfarlane 

and Angerer draft, O’Shea and Bogan 2003). Data from California suggest population declines 

associated with habitat loss and destruction along with disturbance at roost sites have contributed to 

reduced or lost occupancy at historic sites (Ibid and O’Shea and Bogen 2003, USDA 2001). 

Bat surveys have been conducted in and near the analysis area. Pallid bats have been documented on 

the North Fork Merced River and along Cottonwood Creek (project record). Fringed myotis have 

been documented at Fahey Pond and the Hetch Hetchy adit at the end of road 1N45 (CNDDB, USDA 

2015e). They have also been documented just outside the analysis area in the lower Tuolumne River 

and a bridge over the South Fork Tuolumne River. All documented occurrences of Townsend’s bigeared bats in the vicinity of the Rim Fire were in caves, mines, and bridges (CNDDB database, 

Pierson and Fellers 1998, Pierson et al. 2001). One maternity colony has been documented on the 

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STF system lands, Bower Cave; about three miles west of the fire perimeter. Suitable roosting and 

foraging habitat is present throughout the project area and presence of all three species is assumed.

Pallid bats are common in open, dry habitats including grasslands, shrublands, woodlands, and 

coniferous forests. They roost in a variety of locations such as bridges, buildings, caves, rock 

crevices, mines, and trees (Hermanson and O’Shea 1983). This species can be found singly but is 

gregarious and can often be found roosting in groups. They are sensitive to roost site disturbance 

which may lead to roost abandonment. Suitable habitat is present throughout the project area. No 

barriers exist precluding movement (dispersal, seasonal, etc.) of this species both within and in close 

proximity to the project area.

In California, the fringed myotis occurs in valley foothill hardwood, hardwood conifer, and 

coniferous forested habitats. In mist netting surveys, they are found on secondary streams and ponds 

(USDA 2015e). They roost in caves, buildings, mineshafts, rock crevices and bridges (O’Farrell and 

Studier 1980). Studies conducted in California, Oregon, and Arizona, have documented that fringed 

myotis roosts in tree hollows, particularly in large conifer snags (Chung-MacCoubrey 1996; Rabe et 

al. 1998; Weller and Zabel 2001; Pierson et al. 2006). Most of the tree roosts were located within the 

tallest or second tallest snags in the stand and were surrounded by reduced canopy closure (Ibid). 

They are gregarious and can be found roosting with other bat species, such as the long eared myotis 

(M. Baumbach pers. obs.). They exhibit high roost site fidelity, sometimes in different trees but 

within a small area (O’Farrell and Studier 1980; Weller and Zabel 2001). Fringed myotis are highly 

sensitive to roost site disturbance (Ibid). 

Townsend’s bats are uncommon and can be found in close association with limestone caves and 

abandoned mines. They readily forage in meadow habitat, often associated with willows (M. 

Baumbach pers. obs.). They can also be found in other habitats including oak woodlands, grasslands, 

and riparian corridors. Although documented to occasionally use basal hollows of trees in coastal 

forest dominated by redwood, Douglas fir, and California bay (Fellers and Pierson 2002), this has not 

been documented in the Sierra Nevada. Snag habitat is not considered typical roosting habitat for this 

species and a reduction in snag habitat has not been identified as a significant threat to this species 

(Philpott 1997, Region 5 species account). While they’re not considered gregarious, they can be 

found roosting singly or together with big-eared bats and other species. No barriers precluding 

movement (dispersal, seasonal, etc.) exist both within and in close proximity to the project area.

All three species breed in the fall with delayed implantation occurring in the spring. Females form 

maternity colonies in spring (Zeiner et al. 1990). Pallid bats prefer horizontally-oriented rock crevices 

as diurnal roost sites in the summer, which coincides with maternity colony selection and use 

(Hermanson and O’Shea 1983). Townsend’s bats select the warm parts of caves, mines, and buildings 

for their maternity roosts (Kunz and Martin 1982). 

Pallid bats forage in open canopied woodlands, riparian areas, and grassland or meadow habitat. They 

are maneuverable on the ground and commonly forage between one and five feet above the ground 

for prey such as Jerusalem crickets, longhorn beetles, scorpions, and occasionally large moths and 

grasshoppers (USDA 2001, Zeiner et al. 1990). They readily use roads, meadows, oak woodlands and 

other open areas to hunt. 

Fringed myotis emerge from roost sites to forage approximately 1-2 hours after sunset. They forage in 

and among vegetation along forest edges and in the overstory canopy. They feed on a variety of insect 

prey, including small beetles, moths, and fly larvae caught in flight or gleened from vegetation (Ibid). 

Fringed myotis often forage in meadows and along secondary streams, in fairly cluttered habitat. 

(Pierson et al. 2001). They are known to fly during colder temperatures, precipitation, and even snow 

(Hirshfeld and O’Farrell 1976; O’Farrell and Studier 1975; M. Baumbach pers. obs.). Keinath (2004) 

found that travel distances from roosting to foraging areas may be up to five miles.

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Townsend’s take primarily lepidopteron (moth) prey and are known as moth specialists (Kunz and 

Martin 1982; Zeiner et al. 1990). They forage along forested edges and vegetated stream corridors 

(Ibid). 

Dispersal patterns for pallid, fringed myotis and Townsend’s bats are unknown and they are not 

known to migrate long distances. Pearson et al. (1952) documented an individual Townsend’s male 

that travelled 20 miles. Movements between Townsend maternity colonies and hibernacula have been 

documented from 1.9 to 24.6 miles (Ibid). Pallid and Townsend’s big-eared bats are relatively 

inactive and either hibernate or enter extended periods of torpor during the winter (Hermanson and 

O’Shea 1983; Kunz and Martin 1982). Fringed myotis are known to hibernate, but are also capable of 

periodic winter activity (Philpott 1997). 

RISK FACTORS

1. White Nose Syndrome- The largest emerging threat to all cave-roosting species is the fungal 

disease white-nose syndrome (WNS). Massive die-offs result once a colony is infected. Because 

pallid, fringed myotis and Townsend’s big-eared bats readily use caves for roosting, they are 

considered highly susceptible to contracting WNS. Although not yet documented in California, 

this disease is moving to the west.

2. Timber Harvest and loss of snags as roosting sites - The loss of large diameter snags and live 

trees for roosts due to fire or harvest activities can affect roost availability for pallid bats and 

fringed myotis. In some forested settings, the fringed myotis appears to rely heavily on tree 

cavities and crevices as roost sites (Weller and Zable 2001), and may be threatened by certain 

timber harvest practices that result in the removal of snags. Retention of existing large trees and 

management of forested habitat will provide short and long-term habitat.

3. Fire Suppression- Pallid bats are at risk from loss of open foraging habitat from fire suppression 

may reduce foraging habitat in the long-term.

4. Mining- The resurgence of gold mining in the West potentially threatens mine dwelling bat 

species such as fringed myotis, pallid and Townsend’s big-eared bats (Macfarlane and Angerer 

draft). Recreational mining exploration has resulted in an increase in roost disturbance and 

abandonment. Closure of old mines for hazard abatement or safety can reduce habitat availability 

if mines are not closed using bat friendly gates.

5. Rangeland management- Pallid bats frequently forage in open areas such as oak woodlands. 

Fringed myotis frequently forage along riparian corridors or over meadows. Overgrazing and 

trampling may alter meadow hydrology or riparian ecosystems, resulting in reduced insect 

diversity, productivity and reduced foraging success (Macfarlane and Angerer draft, Ferguson 

and Azerrad 2004). 

Fringed Myotis, Pallid and Townsend’s Big-Eared Bat: Environmental 

Consequences

The project action alternatives could result in direct and indirect effects to Townsend’s big-eared bats, 

pallid bats, or fringed myotis through the following activities:

 Mechanical site preparation for planting.

 Herbicide application for site preparation, release of conifers, and noxious weed applications. 

 Biomass removal and similar fuel treatments.

 Planting conifers.

These direct and indirect effects include:

 Project related death, injury and disturbance. 

 Project related modifications to habitat quantity or quality.

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Chapter 3.16 Stanislaus

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Death, Injury and Disturbance

Death or injury from project related activities would be unlikely to occur given the mobility of this 

species. However, death or injury could occur if a day roost tree were felled while being used by 

pallid bats or fringed myotis. 

Project activities, especially loud noise, could result in disturbance to day roosting bats. Loud noise 

from equipment such as chain saws or tractors is expected to occur in treatment units. Smoke from 

pile or prescribed burning may also impact bats that are roosting in close proximity to burning 

activities. The location of these species within the analysis area is uncertain, but presence is assumed. 

While these species are susceptible to disturbance at roost sites that may lead to roost abandonment, it 

is unlikely that females would abandon their young due to their ability to carry pups from roost to 

roost during normal roost-switching behavior. The tendency for bats to switch roosts under normal 

circumstances would preclude this from causing negative effects to reproduction. If a maternity roost 

is discovered, an LOP from April 1 through August 1 would be applied within 300 feet surrounding 

the site. LOPs in place for spotted owls, goshawks and great gray owls would afford protection to bats 

roosting in these areas during pup rearing in the spring and summer months. Foraging behavior would 

not be affected due to their nocturnal foraging behavior.

Habitat Modification

Reforestation would result in a slight reduction of roost sites available for pallid bats and fringed 

myotis. However, many snags including most hardwood snags would be retained across the treatment 

units and would continue to provide roosting sites. Suitable habitat outside and adjacent to treatment 

units would continue to provide potential roosting sites interspersed with foraging habitat in the short 

and long-term. Prescribed fire would likely benefit these bats, resulting in some tree mortality and 

snag recruitment in the short-term.

Indicators

The following indicators were chosen to provide a relative measure of the direct and indirect effects 

to the fisher and to determine how well project alternatives comply with Forest Plan Direction. These 

criteria were chosen based on the best available scientific literature which focuses on various aspects 

of pallid, fringed myotis and Townsend’s big-eared bat ecology and life history requirements. These 

criteria focus on those life history aspects, or habitat elements, considered most limiting to fisher 

persistence across their range and where project effects are expected.

1. Acres of snag retention (pallid bats and fringed myotis).

2. Toxicological effects from herbicide use (pallid bats, Townsend’s big-eared bats and fringed 

myotis).

Effects Common to Alternatives 1, 3 and 5

DIRECT AND INDIRECT EFFECTS

Because there is no difference in treatment units between these alternatives, the effects are expected 

to be the same for Indicator 1 and are therefore analyzed together. 

Indicator 1

Trees or snags with existing cavities or furrowed bark provide roosting habitat for pallid bats and 

fringed myotis (Pierson 1996; Pierson et al. 2006). Suitable habitat occurs within and adjacent to 

treatment units. Hazard trees removed in green forest adjacent to reforestation areas is expected to be 

rare, but may result in a slight reduction of snags or roost sites available. Conifer snags would be 

retained at a rate of 12 to 30 square feet basal area or 4 to 6 per acre within treatment units. The 

largest size class available would be selected as the highest priority for retention and averaged across 

each unit, ensuring a supply of snags are retained throughout a given unit and the analysis area. 

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Additionally, most hardwood snags would be retained, further contributing to important roosting 

habitat used by pallid bats. The hardwood and conifer snags across the project area would continue to 

provide short-term roost sites for pallid bats and fringed myotis. Trees that are declining across the 

project area will provide the long-term snag recruitment, generally outside of treatment areas. Forest 

edges and open habitats would remain intact and would continue to provide suitable foraging 

conditions for pallid bats, Townsend’s big-eared bats and fringed myotis. Alternatives 1, 3 and 5 

would have negligible effects on roost site availability, foraging habitat and foraging success for these 

species. About 30,354 acres of forested habitat within the analysis area are on NFS and available for 

bats within this landscape. 

Indicator 2

Herbicide use under Alternatives 1 and 5 are expected to have some potential for direct or indirect 

toxicological effects on bats, as described under the herbicide risk assessment section. Because no 

herbicides are proposed under Alternative 3, no exposure to herbicides and no direct, indirect, or 

cumulative toxicological effects to bats would occur under this alternative.

CUMULATIVE EFFECTS

Appendix B identifies the present and reasonably foreseeable future actions on all lands within the 

analysis area. Some, but not all of these actions have or may contribute cumulatively to effects on 

Townsend’s big-eared, pallid bats and fringed myotis. 

Based on risk factors affecting these species, the following relevant evaluation criteria were used as 

relative measures of cumulative effects from Alternatives 1, 3 and 5: habitat modification and 

Disturbance. In addition, Alternatives 1 and 5 used toxicological effects for evaluation criteria.

Habitat Modification

Federal Lands: Present and foreseeable future projects on federal lands include: Funky Stewardship, 

Groovy Stewardship, Reynolds Creek Stewardship, Soldier Creek Timber Sale, Campy Timber Sale, 

Looney Timber Sale, Thommy Timber Sale, which are green thinning projects treating 6,546 acres of 

forest. All snags and many declining trees will be retained unless they pose a safety hazard in these 

projects. This snag and declining tree retention will provide snags in the short-term as well as recruit 

snags in the long-term. Other federal activities potentially impacting habitat for bats is the fuels 

reduction associated with the Rim Recovery project. Fuels reduction associated with this project will 

reduce the risk of further loss of remaining green forest within the project area. 

Disturbance

Federal Lands: Several sources of noise disturbance occur throughout the forest and include activities 

such as timber harvest, mastication, prescribed fire operations, restoration and recreation. These 

activities have occurred in the past and present and will continue into the future (Twomile, Reynolds

and Rim Fire Rehabilitation) whether or not this project is implemented. Mechanized equipment such 

as feller-bunchers, skidders and chippers are used to accomplish vegetation treatments, while more 

people would be used during prescribed fire operations for lighters, holders and fire engines. Under 

normal winter weather years, access to a large portion of the project area is restricted until late spring 

or early summer. The past two winters, have had almost no restrictions on access in virtually the 

entire Rim Fire area. Vegetation and prescribed fire treatments could occur during the pup rearing 

period, potentially affecting maternity colonies. Recreation disturbance likely occurs as soon as 

access to an area is opened and continues to some degree until access to the area is restricted by snow 

in the fall or early winter. Recreation disturbance would consist of OHVs, camping, hiking, cycling, 

wood cutting and passenger car driving. These effects vary in intensity, duration and scope with 

weekends typically being a higher use time than weekdays.

Private Lands: Noise disturbance on private lands will primarily consist of new plantation 

management, which could involve heavy equipment and personnel. 

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Toxicological Effects

Federal Lands: There is one present federal action of herbicide use on 0.5 acres under the Rim Fire 

Rehabilitation project and two foreseeable federal actions of herbicide use: 8.0 acres under the 

Twomile Ecological Restoration Noxious Weed project and 23 acres under a special use permit for 

the Reliable Power Project powerline. No other present or foreseeable future federal actions are 

related to herbicide use. 

Private Lands: Herbicide use is proposed on 1,583 acres of private land within the project area in 

2017. No other present or foreseeable future actions are proposed on private lands related to herbicide 

application. 

Alternatives 1, 3 and 5 Contribution and Summary

Alternatives 1, 3 and 5 are expected to negligibly contribute cumulatively to effects on pallid and 

fringed myotis. Occasional removal of hazard trees as a result of implementation would result in 

slightly fewer roost sites. Disturbance at roost sites is possible and may result in displacement of 

individuals or groups of roosting bats, including roost abandonment. LOPs in place near day roosts 

would afford protection to roosting bats, as their pup rearing season overlaps with the breeding 

seasons for spotted owls, goshawks and great gray owls. Alternatives 1 and 5 would contribute to the 

short-term limited potential of exposure to toxicity from herbicide use. The cumulative contribution 

to effects on these species is considered negligible and is not expected to affect their viability.

Alternative 2

DIRECT AND INDIRECT EFFECTS

Under No Action, death, injury and disturbance would not be an issue because no active management 

would occur. 

Indicator 1

The indirect effects of no action would result in retention of the maximum number of snags or 

potential roost sites across the project area. It is unknown how many additional roost sites would be 

retained under this alternative and what benefits would be realized by bats in the project area as a 

result of the availability of these additional roost sites.

Indicator 2

Because no herbicides are proposed under this alternative, no exposure to herbicides and no direct, 

indirect, or cumulative toxicological effects to bats would occur. 

CUMULATIVE EFFECTS

The cumulative effects discussion under Alternative 1 outlines those present and foreseeable future 

activities scheduled on public and private lands.

Alternative 2 Contribution and Summary

Under Alternative 2, no direct cumulative effect is expected because no active management would 

occur and it is unknown what indirect cumulative effects would be realized by bats on the 1,886 acres 

where some additional roost sites would be retained. Because no herbicides are proposed under this 

alternative, no exposure to herbicides and therefore no cumulative toxicological effects would occur.

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Alternative 4

DIRECT AND INDIRECT EFFECTS

Indicator 1

There is essentially no overlap (10 acres) between suitable bat habitat and planting areas under this 

alternative. No measureable direct or indirect effects to roost site availability or foraging habitat are 

expected for indicator 1 under this alternative. 

Indicator 2

Herbicide use under Alternative 4 is expected to have some potential for direct or indirect 

toxicological effects on bats, as described under the herbicide risk assessment section.

CUMULATIVE EFFECTS

The cumulative effects discussion under Alternatives 1, 3 and 5 outlines those present and foreseeable 

future activities scheduled on public and private lands.

Alternative 4 Contribution and Summary

No cumulative effects to suitable habitat are expected from Alternative 4. Disturbance at roost sites is 

possible and may result in displacement of individuals or groups of roosting bats, including roost 

abandonment. LOPs in place near day roosts would afford protection to roosting bats, as their pup 

rearing season overlaps with the breeding seasons for spotted owls, goshawks and great gray owls. 

Alternative 4 would contribute to the short-term limited potential of exposure to toxicity from 

herbicide use. The cumulative contribution to effects on these species is considered negligible and is 

not expected to affect their viability.

Fringed Myotis, Pallid and Townsend’s Big-Eared Bat: Summary of Effects

Indicator 1. Of the action alternatives, Alternative 4 would result in the highest level of snag 

retention. Alternative 4 may provide the greatest benefit to pallid bats and fringed myotis amongst the 

action alternatives; however, it is unknown if this assumed benefit would be realized. 

Indicator 2. Herbicide use under Alternatives 1, 4 and 5 are expected to have limited potential for 

direct or indirect toxicological effects on bats. Because Alternative 4 has fewer acres of herbicide 

application proposed, the potential for effects would be less than under Alternatives 1 and 5. 

However, it is important to note that the toxicity exposure scenarios analyzed in the risk assessment 

show that all but one HQ value is less than the NOAEL threshold. The one scenario with an HQ of 

1.0 just reaches the threshold of concern, meaning there is a slightly elevated toxicological risk for 

bats ingesting contaminated insects. Given the foraging behavior of these species, it is unlikely that 

they would realize this actual level of exposure. Therefore, these species are provided an adequate 

margin of safety in the event that they are exposed to contaminated prey or water.

Determinations

ALTERNATIVES 1 AND 5 

Alternatives 1 and 5 may affect individuals but are not likely to result in a trend toward Federal listing 

or loss of viability for the pallid bat, Townsend’s big-eared bat, or the fringed myotis. This

determination is based on the following rationale: 

 Snag retention would result in maintaining roosting structures throughout the treated areas. 

 Foraging habitat would be available throughout the analysis area.

 Toxicity exposure levels from herbicide use under these alternatives are at or below the Forest 

Service established threshold of concern. 

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ALTERNATIVE 2 

Alternative 2 may affect individuals but is not likely to result in a trend toward Federal listing or loss 

of viability for the pallid bat, Townsend’s big-eared bat or the fringed myotis. This determination is 

based on the following rationale: 

 There would be no removal of snags throughout the analysis area.

 There would be no potential for exposure to herbicides. 

ALTERNATIVE 3 

Alternative 3 may affect individuals but is not likely to result in a trend toward Federal listing or loss 

of viability for the pallid bat, Townsend’s big-eared bat or the fringed myotis. This determination is 

based on the following rationale:

 Snag retention would result in maintaining roosting structures throughout the treated areas. 

 Foraging habitat would be available throughout the analysis area.

 There would be no potential for exposure to herbicides. 

ALTERNATIVE 4 

Alternative 4 may affect individuals but is not likely to result in a trend toward Federal listing or loss 

of viability for the pallid bat, Townsend’s big-eared bat or the fringed myotis. This determination is 

based on the following rationale: 

 There would be virtually no removal of snags throughout the analysis area.

 Foraging habitat would be available throughout the analysis area.

 Toxicity exposure levels from herbicide use under this alternative are at or below the Forest 

Service established threshold of concern. 

Western Bumble Bee: Affected Environment

Species and Habitat Accounts

The Western Bumble Bee (Bombus occidentalis) is a Region 5 Forest Service Sensitive species. The 

western bumble bee currently occurs on many national forests throughout California and in all states 

adjacent to California. Historically, the western bumble bee was one of the most broadly distributed 

bumble bee species in North America (Cameron et al. 2011). Currently, the western bumble bee is 

experiencing severe declines in distribution and abundance due to a variety of factors including 

diseases and loss of genetic diversity (Tommasi et al. 2004; Cameron et al. 2011; Koch et al. 2012).

The overall status of populations in the west is largely dependent on geographic region: populations 

west of the Cascade and Sierra Nevada mountains are experiencing dire circumstances with steeply 

declining numbers, while those to the east of this dividing line are more secure with relatively 

unchanged population sizes. The reasons for these differences are not known. 

No records of western bumble bee exist on the STF. The nearest documented western bumble bee was 

at Lake Eleanor in 1983, about one mile from the project area boundary (Thorp et al. 1983). No 

surveys for western bumble bee have been conducted on the STF to date. 

The project area is not known to be within the current distribution of the western bumble bee in the 

Sierra Nevada Bioregion. Although their presence within the analysis area is undocumented, their 

presence is assumed where suitable habitat exists. Habitat considered suitable in this document 

includes montane chaparral, mixed chaparral, annual and perennial grassland, and wet meadows. 

There is about 69,000 acres of suitable habitat on the STF and about 95,400 acres on STF and YNP 

lands. Several botanical species that are known to be utilized by the western bumble bee are found 

throughout the project area. 

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The following account of bumble bee life history is summarized from Heinrich (1979). Queens 

overwinter in the ground in abandoned rodent (i.e., mouse, chipmunk or vole) nests at depths from 6-

18 inches and typically emerge about mid-March. The queen then lays fertilized eggs and nurtures a 

new generation. She first creates a thimble-sized and shaped wax honey pot, which she provisions 

with nectar-moistened pollen for 8 to 10 individual first-generation workers when they hatch. The 

larvae receive all of the proteins, fats, vitamins and minerals necessary for growth and normal 

development from pollen. Eventually all the larvae spin a silk cocoon and pupate in the honey pot. 

The workers that emerge begin foraging and provisioning new honey pots as they are created to 

accommodate additional recruits to the colony. Individuals emerging from fertilized eggs become 

workers that reach peak abundance during July and August. Foraging individuals are largely absent 

by the end of September. Those that emerge from unfertilized eggs become males, which do not 

forage and only serve the function of reproducing with newly emerged queens. During the season, a 

range of 50 to hundreds of individuals may be produced depending on the quantity and quality of 

flowers available. When the colony no longer produces workers, the old queen eventually dies and 

newly emerged queens mate with males and then disperse to found new colonies. During this 

extended flight that may last for up to two weeks she may make several stops to examine the ground 

for a suitable burrow. Mikkola (1984) reported that bumble bees may forage up to a distance of 80 km 

in Finland.

Unlike all other bees, bumble bees are large enough to be capable of thermoregulation, which allow 

them to maintain their foraging activities for longer periods of the day, but also to occupy regions 

with more extreme latitudes and temperatures compared to other bees (Heinrich 1979). Bumble bees 

may continue to forage when temperatures are below freezing even in inclement weather (Heinrich 

(1979). 

Queens end the year by locating a sheltering burrow, where they may spend the winter months under 

cover. Where nesting habitat is scarce, bumble bee species having queens that emerge early (midMarch) in the season, like B. vosnesenskii which co-occurs with the later emerging B. occidentalis, 

may be able to monopolize available nest sites and reduce the chances of success for bumble bee 

species emerging later.

Bumble bees are central place foragers, meaning individuals rely on exploration to find resources 

(Osborne et al. 2008). Bees may communicate with chemical cues to fellow nest mates signaling the 

presence of a good food source (Dornhaus and Chittka 2001 and Dornhaus and Chittka 2004). The 

western bumble bee is a generalist forager, meaning they do not rely on any one flower or flower 

type. However, they have a short proboscis or tongue length relative to other co-occurring bumble bee 

species, which restricts nectar gathering to flowers with short corolla lengths and limits the variety of 

flower species it is able to exploit.

RISK FACTORS

1. Non-native bumble bee species introductions- Bumble bees introduced from Europe for 

commercial pollination apparently carried a microsporidian parasite, Nosema bombi, which has 

been introduced into native bumble bee populations. Highest incidences of declining B. 

occidentalis populations are associated with highest infection rates with the Nosema parasite, and 

the incidence of Nosema infection is significantly higher in the vicinity of greenhouses that use 

imported bumble bees for pollination of commercial crops (Cameron et al. 2011). 

2. Grazing- According to studies done in England (Goulson et al. 2008), grazing during the autumn 

and winter months may provide excellent bumble bee habitat and prevent the accumulation of 

coarse grasses. Heavy grazing and high forage utilization should be avoided since flowering 

plants providing necessary nectar and pollen may become unavailable, particularly during the 

spring and summer when queens, workers and males are all present and active.

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3. Habitat fragmentation and alteration- Bumble bees are threatened by many kinds of habitat 

alterations that may fragment or reduce the availability of flowers that produce the nectar and 

pollen they require, and decrease the number of abandoned rodent burrows that provide nest and 

hibernation sites for queens. In the absence of fire, native conifers encroach upon meadow

habitat, which also decreases foraging and nesting habitat available for bumble bees.

4. Development- Major threats that alter landscapes and habitat required by bumble bees include 

agricultural and urban development. Exposure to organophosphate, carbamate, pyrethroid and 

particularly neonicotinoid insecticides has recently been identified as a major contributor to the 

decline of many pollinating bees, including honey bees and bumble bees (Henry et al. 2012; 

Hopwood et al. 2012; Krupke et al. 2012). 

Western Bumble Bee: Environmental Consequences

The project action alternatives could result in direct and indirect effects to the western bumble bees 

through the following activities: 

 Mechanical site preparation for planting.

 Herbicide application for site preparation and release.

 Biomass removal and similar fuel treatments.

 Planting conifers.

These direct and indirect effects include:

 Project related death, injury and disturbance. 

 Project related modifications to habitat quantity or quality.

Death, Injury and Disturbance

Death or injury from project related activities could occur because this species nests and over winters 

underground in abandoned rodent burrows.

Project activities, such as heavy equipment use for site preparation, are expected to occur in thinning 

and reforestation units, project roads, and at landings. Ground disturbance from reforestation 

activities is likely to result in mortality and loss of any bee colony or overwintering queens in the area 

(Hatfield et al. 2012). Prescribed burning is also expected to occur in units and landings and could 

result in injury or death of overwintering queens if the nest is not deep enough to withstand the 

residual heat at the soil surface. Because no occurrence records on the forest or in the project area, the 

potential risk for death or injury is unknown. 

Habitat Modification

Reforestation, thinning, and prescribed fire activities are expected to alter, fragment, and reduce bee 

habitat availability across the project area in the short term (about 10-12 years). Reforestation and 

prescribed fire would reduce or remove forage through direct mortality of floral resources. 

Management activities should aim at improving diverse assemblages of primarily native flora and 

keeping undisturbed areas, such as logs, clumps of grass, and floral resources constantly available 

throughout the year so bees can find nesting, foraging, and overwintering sites (Blake et al. 2011). 

Assuring continuity of nectar and pollen resources when bees are active from spring to late summer is 

also recommended to mitigate project effects to bees (Schweitzer et al. 2012). Snag and downed log 

retention throughout the project area combined with oak buffers, small pockets of understory 

vegetation in planting units, and untreated areas, would provide short term native plant cover and 

nesting or overwintering habitat for bees during project implementation. Thinning existing plantations 

is expected to result in a more open understory and recruitment of herbaceous vegetation which could 

benefit the bee following treatment (USDA/USDI 2015). Prescribed fire treatments do not typically 

result in 100% consumption of vegetation. Prescriptions call for a mosaic burn in which some 

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vegetation is left intact. Therefore, herbaceous and woody vegetation would remain available to some 

extent in treated areas for bees.

Indicators

The following indicator was chosen to provide a relative measure of the direct and indirect effects to 

the western bumble bees and to determine how well project alternatives comply with Best 

Management Practices for Federal lands.

1. Habitat modification. 

2. Toxicological effects from herbicide use. 

These criteria were chosen based on the best available scientific literature which focuses on various 

aspects of western bumble bee ecology and life history requirements. These criteria focus on those 

life history aspects, or habitat elements, considered most limiting to western bumble bee persistence 

across suitable habitat and where project effects are expected.

Alternatives 1, 3 and 5

DIRECT AND INDIRECT EFFECTS

Because there is very little difference in the site preparation, prescriptions, and plantation release 

results, the effects are expected to be similar under these three alternatives and are analyzed together.

The differences in herbicides proposed between Alternatives 1 and 5 versus Alternative 3 were 

separated below accordingly. 

Indicator 1

Reforestation (includes natural regeneration): Under these alternatives about 26,000 acres of suitable 

habitat is proposed for reforestation. Ultimately this would result in up to a 38% reduction in the 

amount of suitable habitat across the project area. Site preparation is designed to eliminate competing 

vegetation from the planting areas, although this does not occur on every acre. This would be 

accomplished through deep tilling or herbicide application or a combination of both. The effects are 

the same: reduced habitat available for bees during implementation and management for the short 

term (10-12 years). Implementation would be phased over several years and each unit includes areas 

where site preparation, herbicide application, and planting treatments would not occur. It is in these 

areas that suitable habitat would be retained.

Several design criteria would result in the retention of bee habitat in any given unit and across the 

entire project area. Sensitive and Watchlist plant sites would have buffers applied and would not be 

reforested, offering foraging opportunities for bees. In reforestation units, up to five oaks would be 

buffered and no reforestation or release treatments would occur within 20 feet of these oaks. This 

would provide up to 15% of any given acre that would contain habitat for bees. Up to 20% vegetative 

cover is also retained on each acre in reforestation units before release treatments are triggered. This 

would provide up to an additional 20% of a given acre that would contain habitat for bees. When 

combined, up to 35% of any given acre proposed for treatment could contain native floral resources 

available to bees. Areas where snags and downed logs are retained would also provide potential 

nesting or overwintering sites. While it is not known how much of these untreated areas would 

contain flowering plants utilized by bees, it is assumed that at least some portion would be suitable 

for foraging. Bumble bees have been documented to fly up to 0.9 miles from their nest site to 

foraging habitat (Osborne et al. 2008). Osborne and others (2008) found that the energetic cost of 

travelling from 0.08 miles to 0.9 miles to a foraging site did not appear to be prohibitive compared to 

the rewards gained (i.e., nectar and pollen). Cresswell and others (2000) used realistic parameters for 

time and energy expenditure to predict if foraging resources were inadequate that bumble bees could 

forage profitably at distances greater than 2.5 miles. Given the design criteria and potential for 

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foraging habitat retention throughout the project area, it is unlikely that individuals would need to 

travel these distances to find foraging habitat. 

Prescribed fire would be introduced to new plantations within 10 years of planting. USDA/USDI 

(2015) recommends implementing prescribed burning operations in the late fall to early spring and 

early or late in the day to mitigate some negative effects to bees. They also suggest leaving small 

unburned patches within burned areas to ensure that some flowers are always available. Prescribed 

burns are most often implemented fall through spring when the weather conditions are conducive 

with the burning prescription. This timeframe would ensure that the blooming period for many plants 

is avoided. While some habitat would be removed in the short term, burning prescriptions include the 

objective of retaining patches of vegetation (i.e., suitable habitat) across the treatment area. Retaining 

open stand conditions using prescribed fire would also result in the long term benefit of retaining 

suitable bee habitat.

Forested habitat was not identified as suitable habitat when calculating acres for this analysis; 

however, open canopied forests contain understory vegetation that would benefit bees (USDA/USDI 

2015). About 10,800 acres are proposed for planting with the open canopy mosaic prescription and 

are located throughout the landscape. Therefore 12,200 acres out of the 26,000 proposed for 

reforestation are still expected to provide landscape level habitat benefits to bees (Ibid).

Thinning: Under these alternatives about 5,400 acres of existing plantation is proposed for thinning 

and creating an open canopy mosaic. Thinning existing plantations would result in opening up the 

understory promoting the recruitment of herbaceous vegetation within a year or two post treatment 

which would benefit bees in these areas (Schweitzer et al. 2012; USDA/USDI 2015). Prescribed fire 

would be the first tool used for thinning these stands. The goal in using prescribed fire is to open up 

these stands, creating a habitat mosaic of more open conditions. If we are unable to accomplish 

thinning by using prescribed fire, we would use mechanical means to achieve the desired conditions. 

The short term impacts to forage availability and potential loss of nest or overwintering sites would 

be outweighed by the short- and long-term benefits realized by implementing these alternatives. 

While these units are classified as forested habitat, the open canopy desired condition in these units is 

expected to provide landscape level habitat benefits to bees (USDA/USDI 2015). 

Indicator 2

Herbicide use under Alternatives 1 and 5 are expected to have some potential for direct or indirect 

toxicological effects on bees, as described under the herbicide risk assessment section. Because no 

herbicides are proposed under Alternative 3, no exposure to herbicides and no direct, indirect, or 

cumulative toxicological effects to bees would occur under this alternative. 

CUMULATIVE EFFECTS

Appendix B identifies the present and reasonably foreseeable future actions on all lands within the 

analysis area. Some, but not all of these actions have or may contribute cumulatively to effects on 

western bumble bees.

Based on risk factors affecting bees, the following relevant evaluation criteria were used as relative 

measures of cumulative effects from Alternatives 1, 3 and 5: habitat modification. In addition, 

Alternatives 1 and 5 used toxicological effects for evaluation criteria.

Habitat Modification

Federal Lands: Present and foreseeable future activities on federal lands include meadow restoration 

(Reynolds Creek, Rim Fire Habitat Improvement and Rehabilitation, and Twomile meadow 

restoration). Other federal activities potentially impacting habitat for bees is grazing.

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Meadow restoration projects are expected to improve foraging habitat across about 180 acres for bees. 

By removing encroaching conifers and improving hydrologic function of meadows on this landscape, 

native flora and habitat suitability in these meadows would increase forage availability for bees.

Grazing is occurring and will continue to occur across the analysis area whether or not this project is 

implemented. Grazing and high forage utilization should be avoided since flowering plants providing 

necessary nectar and pollen may become unavailable, particularly during the spring and summer 

when queens, workers and males are all present and active. Grazing is subject to utilization standards 

in the SNFPA (USDA 2004) that protect resources such as meadow habitat.

Private Lands: About 1,583 acres of herbicide application are on private lands in the foreseeable 

future across the analysis area. The near complete coverage of most acres across private lands has 

resulted in almost complete removal of foraging habitat for bees. These areas will likely not provide 

foraging habitat for bees for several years.

Toxicological Effects

Federal lands: There is one present federal action of herbicide use on 0.5 acres under the Rim Fire 

Rehabilitation project and two foreseeable federal actions of herbicide use: 8.0 acres under the 

Twomile Ecological Restoration Noxious Weed project and 23 acres under a special use permit for 

the Reliable Power Project powerline. No other present or foreseeable future federal actions are 

related to herbicide use. 

Private lands: Herbicide use is proposed on 1,583 acres of private land within the project area in 

2017. No other present or foreseeable future actions are proposed on private lands related to herbicide 

application. 

Alternatives 1, 3 and 5 Contribution and Summary

Alternatives 1, 3 and 5 would contribute cumulatively to short- and long-term effects to western 

bumble bees. Reforestation would result in modification of about 38% of suitable habitat on STF 

lands and about 27% of suitable habitat across the analysis area. Although suitable habitat would be 

altered, several design elements included in prescriptions under these alternatives would ensure 

habitat is available throughout the project area during implementation. Thinning of existing 

plantations would result in more open stand conditions increasing the amount of herbaceous and 

woody vegetation available as forage to bees across 6% of the analysis area. Using prescribed fire is 

expected to help create and maintain these conditions. These alternatives would result in the most 

suitable habitat modified when compared to Alternative 4. Alternatives 1 and 5 would contribute to 

the short-term potential of exposure to toxicity from herbicide use. Because no western bumble bees 

are documented on the STF, it is unknown to what degree the cumulative contribution under these 

alternatives may affect individual bees or the viability of this species.

Alternative 2

Under No Action, death, injury and disturbance would not be an issue because no active management 

would occur. 

Indicator 1

The indirect effects of no action would likely benefit the western bumble bee. The early seral habitat 

present across the landscape would provide additional food, nesting, and overwintering resources to 

bees in the short term. Over time, the shrubs will become dense thickets, eliminating essential forbs, 

an important food source for bees. This may affect long-term habitat suitability for bees across the 

landscape. When wildfire returns, it would reset the clock, beginning with the flood of herbaceous 

vegetation that is most valuable for bees.

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Indicator 2

Because no herbicides are proposed under this alternative, no exposure to herbicides and no direct, 

indirect, or cumulative toxicological effects to bees would occur under this alternative. 

CUMULATIVE EFFECTS

The cumulative effects discussion under Alternatives 1, 3 and 5 outline those present and foreseeable 

future activities scheduled on public and private lands.

Alternative 2 Contribution and Summary

Under Alternative 2, no direct cumulative effect is expected because no active management would 

occur; however, the indirect effects under this alternative would result in additional resource and 

habitat availability for bees in the short-term. Because no western bumble bees are documented on the 

STF, it is unknown to what degree the cumulative contribution under this alternative may affect 

individual bees or the viability of this species.

Alternative 4

DIRECT AND INDIRECT EFFECTS

Indicator 1 

Reforestation: Under Alternative 4, up to 2,950 acres of suitable habitat is proposed for reforestation. 

Up to 4,130 acres of suitable habitat would be subject to site preparation and release treatments 

(founder stands and the 50 foot buffer around each founder stand). This would result in up to a 6% 

decrease in the amount of suitable habitat across the project area on STF lands. Site preparation is 

designed to eliminate competing vegetation from the planting areas. This would be accomplished 

through herbicide application. The effects are the same: reduced habitat available for bees during 

implementation and management for the short term (10 to12 years). Implementation would be phased 

over several years and each unit includes areas where site preparation, herbicide application, and 

planting treatments would not occur. It is in these areas that suitable habitat would be retained. 

Design criteria for reforestation described under Alternatives 1, 3 and 5 are also applicable under this 

alternative. In addition to the standard design criteria, no planting would occur within 200 feet of any 

sensitive plant site or within complex early seral habitat, both which provide habitat to bees. 

Prescribed fire would be introduced to 50% of new plantations within 10 years and the other 50% 

between 10 and 20 years. The same burning prescriptions and expected retention of habitat discussed 

under Alternatives 1, 3 and 5 would apply under this alternative on a smaller scale. 

Forested habitat was not identified as suitable habitat when calculating acres for this analysis; 

however, open canopied forests contain understory vegetation that would benefit bees (USDA/USDI 

2015). Planting is proposed on 2,950 acres with an ultimate goal of being open canopy. Therefore the 

areas proposed for reforestation are still expected to provide some habitat benefits to bees (Ibid). 

Thinning: Because prescriptions for thinning existing plantations under this alternative are the same 

as described under Alternatives 1, 3 and 5, the effects are expected to be the same, see discussion 

under Alternatives 1, 3 and 5. 

Indicator 2

Herbicide use under Alternative 4 is expected to have some potential for direct or indirect 

toxicological effects on bees, as described under the herbicide risk assessment section.

CUMULATIVE EFFECTS

The cumulative effects discussion under Alternatives 1, 3 and 5 outline those present and foreseeable 

future activities scheduled on public and private lands.

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Alternative 4 Contribution and Summary

Alternative 4 is expected to contribute cumulatively to effects on western bumble bees. Minor 

cumulative effects are expected from reforestation. Suitable habitat would be altered on up to 4% of 

the analysis area. Cumulative effects from thinning existing plantations are expected to be the same as 

described under Alternatives 1, 3 and 5. Alternative 4 would contribute to the short-term potential of 

exposure to toxicity from herbicide use. Because no western bumble bees are documented on the 

STF, it is unknown to what degree the cumulative contribution under this alternative may affect 

individual bees or the viability of this species.

Western Bumble Bee: Summary of Effects

Indicator 1. As shown in Table 3.16-16, Alternative 4, of the action alternatives, would result in the 

least amount of suitable habitat modification when compared to Alternatives 1, 3 and 5. Effects of 

thinning existing plantations would be the same among all action alternatives.

Table 3.16-16 Western Bumble Bee Summary of Effects: Habitat Modified

Indicator and Metric Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5

Acres of habitat modified1 26,000 0 26,000 4,130 26,000

Percent of habitat modified1 38 0 38 6 38

1STF lands only

Indicator 2. Herbicide use under Alternatives 1, 4 and 5 are expected to have the potential for direct 

or indirect toxicological effects on bees. Because Alternative 4 has fewer acres of herbicide 

application proposed, the potential for effects would be less than under Alternatives 1 and 5. 

However, it is important to note that the toxicity exposure scenarios analyzed in the risk assessment 

show that all HQ values for clopyralid, aminopyralid, and clethodim are several orders of magnitude 

less than the NOEC threshold or No Observable Effect Concentration. The HQ values for the 

glyphosate scenarios of ingesting contaminated vegetation were slightly above the NOAEL threshold 

or No Observable Adverse Effect Level. The HQ values were 1.7 and 3.0, indicating an elevated

toxicological risk for individual western bumble bees. Given the fact that most glyphosate spraying 

would occur before plants are flowering and no western bumble bees have been documented on the 

STF, it is unlikely that bees would realize this actual level of exposure. Therefore, this species is 

provided an adequate margin of safety in the event that they are exposed to direct spray or 

contaminated vegetation.

Determinations

ALTERNATIVES 1 AND 5 

Alternatives 1and 5 may affect individuals but are not likely to result in a trend toward Federal listing 

or loss of viability for the western bumble bee. This determination is based on the following rationale: 

 Foraging, nesting, and overwintering habitat would be available throughout the analysis area in 

the short- and long-term.

 Most toxicity exposure levels from herbicide use under these alternatives are all several orders of 

magnitude below the Forest Service established threshold of concern. 

ALTERNATIVE 2 

Alternative 2 may affect individuals but is not likely to result in a trend toward Federal listing or loss 

of viability for the western bumble bee. This determination is based on the following rationale:

 There would be no modification of currently suitable habitat. 

 There would be no potential for exposure to herbicides. 

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ALTERNATIVE 3 

Alternative 3 may affect individuals but is not likely to result in a trend toward Federal listing or loss 

of viability for the western bumble bee. This determination is based on the following rationale:

 Foraging, nesting, and overwintering habitat would be available throughout the analysis area in 

the short- and long-term.

 There would be no potential for exposure to herbicides. 

ALTERNATIVE 4 

Alternative 4 may affect individuals but is not likely to result in a trend toward Federal listing or loss 

of viability for the western bumble bee. This determination is based on the following rationale:

 Foraging, nesting, and overwintering habitat would be available throughout the analysis area in 

the short- and long-term.

 Most toxicity exposure levels from herbicide use under these alternatives are all several orders of 

magnitude below the Forest Service established threshold of concern. 

Black-Backed Woodpecker: Affected Environment

Species and Habitat Account

The black-backed woodpecker (Picoides arcticus) is not designated as a Region 5 Forest Service 

Sensitive species. They are currently listed as a Management Indicator Species (MIS) representing the 

ecosystem component of snags in burned forests, as described in the Rim Reforestation MIS report 

available in the project record.

Black-backed woodpeckers are distributed in boreal regions from south-central Alaska across Canada 

to Newfoundland and Nova Scotia, and south in the western United States in Montana and 

Washington through east-central California (Region 5 Sensitive species evaluation form for blackbacked woodpecker 2012). The black-backed woodpecker is a monotypic species that occurs at 

elevations of 4,000 to 10,000 feet (1200 to 3000 meters) in the Siskiyou, Warner, and Shasta counties, 

the Sierra Nevada Mountains of California and Nevada south to the southern limits of Tulare County 

in Sequoia National Forest (Ibid). 

Black-backed woodpeckers are still distributed across their historical breeding range in California 

(Bond et al. 2012). They have been documented within the Rim Fire perimeter in both 2014 and 

2015, but in low numbers (White pers. comm.).

In December 2011, the California Fish and Game Commission accepted for consideration a petition 

submitted by the John Muir Project and the Center for Biological Diversity (Hanson and Cummings 

2010) to list the black-backed woodpecker (Picoides arcticus) as Threatened or Endangered under the 

California Endangered Species Act. The Commission’s December 15, 2011 action conferred on the 

species the interim designation of “candidate for listing”, effective January 6, 2012, and gave the 

California Department of Fish and Game (now California Department of Fish and Wildlife or CDFW) 

12 months from that date to review the petition, evaluate the available information, and report back to 

the Commission whether or not the petitioned action is warranted. In May 2013, the Fish and Game 

Commission found listing the black-backed woodpecker as Threatened or Endangered under CESA 

was not warranted (Bonham 2013). 

The Commissions conclusion was based on the following summary (Bonham 2013): 

 The lack of an apparent range retraction or changes in distribution within the range.

 The episodic cycles of high density occurrences (i.e., prey invasion, high woodpecker 

productivity, prey decline, and woodpecker dispersal) and the lack of current data on the cycle’s 

impact on the long-term viability of California’s black-backed woodpecker population. 

 The lack of data concerning the role of green forest on the species but its apparent use as habitat. 

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 The trending increase in fire frequency, size, and severity as compared to the early and mid 20th 

century.

 Uncertainty regarding the magnitude of the threat posed to black-backed woodpeckers by postfire salvage logging.

 Lack of logging on approximately 80% of severely burnt USFS forest habitat since 2003 (i.e., 

87,200 acres). 

 The ongoing long-term monitoring of the species as an MIS.

 Black-backed woodpecker populations in California are not geographically isolated from 

populations in adjacent states. 

Having considered these factors, the Department concluded that the best available scientific 

information available to the Department does not indicate that the black-backed woodpecker’s 

continued existence is in serious danger or is threatened by any one or any combination of the 

following factors found in relevant regulation: present or threatened modification or destruction of 

black-backed woodpecker habitat, overexploitation, predation, competition, disease, or other natural 

ocurrences or human-related activities. (Cal. Code Regs., tit 14, § 670.1 (i)(1)(A)). Therefore, based 

upon the best scientific information available to the Department, listing the black-backed woodpecker 

as threatened or endangered is not warranted. 

A consortium of environmental groups including the John Muir Project, the Center for Biological 

Diversity, the Blue Mountains Biodiversity Project, and the Biodiversity Conservation Alliance filed 

a petition (Hanson et al. 2012) to list the Oregon/California and Black Hills (South Dakota) 

populations of the black-backed woodpecker as Threatened or Endangered under the Federal 

Endangered Species Act. The U.S. Fish and Wildlife Service prepared a 90-day finding indicating 

that the petitioned action may be warranted based on the information provided by the petitioners; 

therefore when funds become available, they will initiate a review of the status of the two populations 

to determine if listing either or both the Oregon Cascades-California population and the Black Hills 

population as either subspecies or Distinct Population Segments is warranted (USFWS 2013a).

Currently, the USFWS website says this species is under review.

The IUCN Red List of Threatened Species evaluated the black-backed woodpecker as a species of 

“Least Concern” in 2012 (http://www.iucnredlist.org/details/22681181/0). IUCN provided 

justification for this evaluation as follows: “This species has an extremely large range, and hence does 

not approach the thresholds for Vulnerable under the range size criterion (Extent of Occurrence 

<20,000 km2

 combined with a declining or fluctuating range size, habitat extent/quality, or population 

size and a small number of locations or severe fragmentation). The population trend appears to be 

stable, and hence the species does not approach the thresholds for Vulnerable under the population 

trend criterion (>30% decline over ten years or three generations). The population size is extremely 

large, and hence does not approach the thresholds for Vulnerable under the population size criterion 

(<10,000 mature individuals with a continuing decline estimated to be >10% in ten years or three 

generations, or with a specified population structure). For these reasons the species is evaluated as 

Least Concern”.

NatureServe has ranked this species as G5 = demonstrably secure at the Global level and N4 = 

apparently secure at the National level (NatureServe.org).

Population trends of black-backed woodpeckers are poorly known (Bond et al. 2012). Such analyses 

are especially difficult for this species due to the ephemeral nature of the woodpecker’s burned 

habitat, its tendency not to re-use nesting cavities in subsequent years, and the low density at which 

the species occurs in unburned forests (Ibid). Inclusion of black-backed woodpecker monitoring in 

the Forest Service’s MIS program for 10 national forest units in California, as well as additional 

research, should yield trend information for the species in burned forests of the Sierra Nevada and 

southern Cascades in the coming years (Siegel et al. 2008, 2010, 2011, 2012, 2015; Saracco et al. 

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2011). According to Siegel et al. (2015), “there is no evidence in fire-level occupancy by blackbacked woodpeckers, but there is marginal evidence of a negative linear trend in point-level 

occupancy, amounting to an annualized loss of 1.35% of points per year during the six years (2009-

2014) we have been monitoring black-backed woodpeckers on National Forests in California. 

Although the distribution of the species appears to change slightly from year to year, black-backed 

woodpeckers remain present across their historic range in California” (p. 39). 

Trend information available from Breeding Bird Surveys (BBS) is available; however, these trend 

estimates were based on observations along only five BBS routes. Trends in black-backed 

woodpecker populations according to BBS data throughout the species range were non-significantly 

positive between 1966 and 2007 but significantly negative (minus 7% per year) between 1980 and 

2007. Within the Sierra Nevada Physiographic Province, including most of the species range in 

Region 5, trends were non-significantly negative during both 1966 to 2006 and 1980to 2006. Thus, 

black-backed woodpecker trends are not well-monitored by the BBS methodology, due to its patchy 

distribution and low detection probability during passive point counts (Region 5 Sensitive species 

evaluation form for black-backed woodpecker 2012).

The number of black-backed woodpeckers occupying recent fire areas that burned from 2000 to 2010 

in the Sierra Nevada appears not to exceed several hundred pairs (Bond et al. 2012). Population 

estimates in ‘green’ forests of the Sierra Nevada range from several hundred to several thousand pairs 

(Ibid). 

The analysis area is within the current distribution of black-backed woodpeckers across the Sierra 

Nevada Bioregion. Prior to the Rim Fire, there were very few acres of burned forest suitable for 

black-backed woodpeckers within the Rim Recovery analysis area. Exact acres could not be 

calculated because snag retention from previous fires and the associated projects were based on 

numbers of snags, not acres of snag patches. However, only low snag densities were retained and 

many of those snags have likely fallen. Therefore it is reasonable to assume that there were very few 

acres, if any, of burned forest suitable for black-backed woodpeckers prior to the Rim Fire. The 

project contains suitable habitat for this species and presence has been documented in various 

locations throughout the fire area (White pers. comm., pers. obs.). 

The black-backed woodpecker is strongly associated with burned forests, more closely than any other 

western bird species (Hutto1995; Hutto 2008; Bond et al. 2012). Although the black-backed 

woodpecker is found in unburned forested stands throughout its range, population densities in 

recently burned forest stands are substantially higher (Hutto 1995; Hoyt and Hannon 2002; Smucker 

et al. 2005; Hutto 2008; Fogg et al. 2012). During broadcast surveys for black-backed woodpeckers in 

burned forests throughout the Sierra Nevada, southern Cascades, and Warner mountains in 2009 and 

2010, 95% of detections were between 4,793 – 8,517 feet (1,461 and 2,596 meters) above sea level 

(R. Siegel unpublished data). Survey stations above (9,186 feet (2,800 meters) have not been 

established, so the upper boundary of the range of detection may be higher than currently 

documented. Black-backed woodpecker home-ranges are highly variable and are shown to range from 

59 to 751 acres (24 to 304 hectares) (Siegel pers. comm.; Siegel et al. 2013, 2014; Tingley et al. 

2014b). Snag basal area alone best predicted home-range size, explaining 54 to 62% of observed 

variation (Tingley et al. 2014b). As snag basal area increased, home-ranges exponentially decreased 

in size, strongly suggesting increased habitat quality. 

Suitable black-backed woodpecker habitat is defined specifically for this project and includes the 

following CWHR habitat types, size classes, and densities: Douglas-fir (DFR), Jeffrey pine (JPN), 

lodgepole pine (LPN), ponderosa pine (PPN), red fir (RFR), subalpine conifer (SCN), Sierran mixed 

conifer (SMC), and white fir (WFR); size classes greater than or equal to 3; pre-fire canopy closures 

M and D; and basal area mortality greater than or equal to 50%. Habitat criteria used in this analysis 

were determined from CWHR (CDFW 2008), scientific literature (e.g., Russell et al. 2007; Hanson 

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and North 2008; Vierling et al. 2008; Bond et al. 2012; Siegel et al. 2013; Siegel et al. 2014; and 

USDA Forest Service Region 5 Regional Office guidance). 

Burned forest habitat is most productive for black-backed woodpeckers during the first eight years 

following a fire. Burned habitat on private lands is assumed to be completely removed through 

salvage logging. Treatments are limited on National Park Service Lands, typically consisting of 

minimal removal of hazardous trees along roadways. NFS lands are treated to varying degrees 

following a fire, typically harvesting only a small proportion of fire-killed trees in burned forest.

Suitable habitat exists outside the Rim Fire perimeter within California on NFS lands and is 

distributed throughout the Sierra Nevada and California. For example, in 2012, the Chips and 

Reading Fires on the Lassen and Plumas National Forests burned about 75,000 acres of NFS lands, of 

which about 67,000 acres of burned NFS lands remain untreated. In 2013, the American and Aspen 

Fires burned about 44,000 acres on NFS lands, of which about 32,000 acres of burned NFS lands will 

remain untreated. In 2014, the King Fire burned about 63,500 acres on NFS lands, of which about 

10,000 acres will be salvaged or treated for fuels reduction. On the STF wildfires have occurred in the 

past several years and include:

1. The Knight Fire in 2009 burned about 6,000 acres, of which zero acres were salvaged; 

2. The Ramsey Fire in 2012 burned about 1,000 acres, of which 250 acres was salvaged; 

3. The Power Fire in 2013 burned about 1,000 acres, of which zero acres were salvaged; and, 

4. The Rim Fire in 2013 burned about 257,000 acres (155,000 on NFS Lands), of which 42,300 

were either salvaged, treated for fuels reduction, or hazard tree removal.

As is evident with the acres burned versus the acres treated displayed above, most burned habitat 

remains on the landscape and provides habitat benefits to black-backed woodpeckers. When 

combined with suitable burned forest habitat on National Park Service such as Yosemite, even more 

habitat is available to black-backed woodpeckers. According to Miller and Safford (2012) and 

Westerling et al. (2006), large, high-severity wildfires have been increasing in frequency and duration 

over the past few decades and are predicted to continue into the future. Based on these reported trends 

and the large, high severity fires that have occurred in Region 5 over the past few years, it is 

reasonable to assume that the availability of burned forest habitat will continue increasing into the 

future.

The Rim Fire burned primarily on public land in two administrative units: STF and Yosemite 

National Park. Most of the suitable black-backed woodpecker habitat within the Rim Fire perimeter 

occurs on Yosemite National Park. Table 3.16-17 shows the amount of suitable habitat on public 

lands. Suitable habitat on private lands is assumed to have been removed through salvage operations.

Black-backed woodpeckers are primary cavity excavators, creating holes in trees in which to lay their 

eggs and raise their young (Dixon and Saab 2000). The breeding season generally occurs from April 

through July and both sexes incubate, brood, and feed young (Bond et al. 2012). Nest cavities are 

usually excavated in snags but can be found in dead portions of live trees and in unburned forests. 

Nests are excavated in conifer trees and typically average 13 to 14 inches, which corresponds to 

CWHR size classes 4 and 5. Nest trees have occasionally been documented as small as 7 inches, 

which corresponds with CWHR size class 3 (Bond et al. 2012; Seavy et al. 2012). 

Table 3.16-17 Amount of Suitable Black-Backed Woodpecker Habitat in the Rim Fire Area

Ownership Suitable Habitat (acres) Proportion of Habitat (percent)

Stanislaus National Forest 10,326 37%

Yosemite National Park 17,487 63%

Total 27,813 100%

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Black-backed woodpeckers readily forage on larvae of wood-boring beetles, engraver beetles, and 

mountain pine beetles found in the trunks of burned conifers (Dixon and Saab 2000). Hanson and 

North (2008) found preferential foraging on large snags greater than 20 inches dbh (50 centimeters) in 

a study of 3 fire areas in the Sierra Nevada, which corresponds to CWHR size classes 4 to 6. 

Preliminary data from an ongoing study at two recent fire areas on Lassen National Forest suggests 

that black-backed woodpeckers forage on all available size classes of snags, but they forage on snags 

4 inches less than was predicted (R. Siegel unpub. data). 

Black-backed woodpeckers in western North America are not known to be migratory, although 

limited down-slope dispersal in winter has been reported (Dixon and Saab 2000). Reliance on 

recently burned areas of coniferous forest for breeding necessitates some post-breeding and post-natal 

dispersal to colonize new burns, but dynamics of dispersal in this species are not well studied (Ibid.). 

Occasional irruptions of hundreds of 100's of km or more have been documented in eastern North 

America in response to food- resource and breeding dynamics; similar irruptions in western North 

America have not been recorded. In the Sierra Nevada, black-backed woodpeckers frequently 

colonize burned forest patches and breed in them less than one year after fire; no information is 

available indicating how far such individuals have dispersed (Dixon and Saab 2000; Siegel et al. 

2008). 

RISK FACTORS

Risks factors to black-backed woodpeckers have been summarized in “A Conservation Strategy for 

the black-backed woodpecker (Picoides arcticus) in California – Version 1.0”:

1. Salvage logging and other management involving post-fire snag removal- Management activities 

commonly employed following wildfire include salvage logging and hazard tree removal have 

resulted in negative impacts such as reduced abundance and reproductive success in black-backed 

woodpeckers (Saab and Dudley 1998; Hutto and Gallo 2006; Saab et al. 2007; Koivula and 

Schmiegelow 2007; Hutto 2008; Cahall and Hayes 2009). Saab and Dudley (1998) and Hutto and 

Gallo (2006) found that nest densities were much higher in unlogged post-fire stands when 

compared with salvaged stands.

2. Thinning of unburned forests- Pre-fire forest thinning can decrease post-fire occupancy rates and 

nest densities of black-backed woodpeckers, and thinning or removal of medium and large snags 

may decrease habitat suitability in unburned forests. For example, black-backed woodpecker 

abundance in forests that were commercially thinned and then later burned in wildfire was lower 

than in burned forests that were not thinned before fire in the Rocky Mountains (Hutto 2008). 

3. Firewood cutting for personal use in recent fire areas- Although systematic data on the effects of 

fuelwood cutting on nesting black-backed woodpeckers are not available, small scale harvesting 

of fuelwood by the public for personal use, from recent fire areas as well as unburned lodgepole 

pine forests, can destroy active black-backed woodpecker nests.

4. Time since fire- Probability of occupancy and nesting by black-backed woodpeckers in burned 

forest is negatively correlated with years since fire during the decade after the fire.

5. Fire Suppression- If fire suppression reduces the amount of mid- and high-severity post-fire 

habitat available for black-backed woodpecker, it may be considered a threat to the species.

6. Climate change- Although uncertain, climate change may affect the black-backed woodpecker 

through altered fire regimes and adjustments in distribution (e.g., occupying higher elevations and 

northern latitudes.

Black-Backed Woodpecker: Environmental Consequences

This analysis is focused on the project effects related to management of burned forest, areas with 

documented basal area mortality greater than 50%. The project alternatives could result in direct and 

indirect effects to the black-backed woodpecker through the following activities: 

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 Removal of fire-killed trees.

These direct and indirect effects include:

 Project related death, injury and disturbance. 

 Project related modifications to habitat quantity or quality.

Death, Injury and Disturbance

Death or injury from project related activities would be unlikely to occur given the mobility of this 

species. However, there is the potential for death or injury if a nest tree were felled while being used 

by black-backed woodpeckers. These potential direct effects are considered to be short-term and will 

only affect treated areas. Retained snags in treated areas would continue to provide cavity and 

foraging substrates. Untreated areas that burned at high severity and are suitable black-backed 

woodpecker habitat would be left intact, providing nesting and foraging habitat for black-backed 

woodpeckers. 

Project activities, especially loud noise, could result in disturbance that may impair essential behavior 

patterns of the black-backed woodpeckers related to breeding or foraging. Loud noise from 

equipment such as chainsaws or tractors is expected to occur in reforestation units, on project roads, 

and at landings. The location of black-backed woodpeckers within the analysis area is uncertain but 

expected given the increase in available suitable habitat following the Rim Fire. Temporary 

avoidance of the project site or displacement of individuals is expected during project 

implementation.

Any displacement or avoidance related to noise disturbance would be of short duration and would 

subside shortly after project implementation activities. LOPs in place for spotted owls, goshawks, 

great gray owls, and bald eagles would afford protection to individual black-backed woodpeckers in 

these areas during the breeding season. The potential risk to individual black-backed woodpeckers is 

uncertain because the presence of suitable habitat is a recent development and limited surveys have 

been conducted. They have been documented in the project area in both 2014 and 2015 in low 

numbers. 

The length of exposure to these disturbances is considered short-term and would occur in different 

areas any given year as implementation progresses across the landscape.

Habitat Modification

Removal of fire-killed trees in reforestation units would degrade suitable black-backed woodpecker 

habitat by removing burned snags this species requires for breeding and foraging. Home ranges are 

known to average about 89 hectares or 220 acres based on recent research (Tingley et al. 2014b). The 

basal area of burned snags is correlated with the home range size of black-backed woodpeckers 

(Ibid). Retaining large patches of burned snags, preferably greater than 220 acres and at elevations 

above 4,793 feet would provide high quality habitat for black-backed woodpeckers, potentially 

increasing the predicted bird density across the analysis area (Bond et al. 2012; Tingley et al. 2014b). 

Although treated areas are not expected to provide suitable habitat that would contribute to a blackbacked woodpecker home range, snags retained within treated areas could provide foraging and 

possibly nesting structures. In addition, trees that survived the fire will remain on the landscape. 

Some of these trees will likely die, contributing to snag recruitment over the next several years and 

will provide additional habitat for black-backed woodpeckers.

In order to compare alternatives and potential effects to black-backed woodpeckers, we used a model 

developed by Tingley and others (2014a) that was designed specifically for the Rim Fire area. This 

model presents a method for predicting black-backed woodpecker pair density that combines modelbased estimates of occupancy with expected bird density given occupancy (Ibid). Some of the 

covariates used in the model include pre-fire canopy cover, burn severity, CWHR size class 3 and 

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greater, and CWHR forest class. This model allows us to compare alternatives, accounting for the 

expected effects to black-backed woodpeckers. The model predicts the probability that a single cell 

(100 by 100 feet) is occupied by a black- backed woodpecker. The developer’s intent for use of this 

model includes using density estimates to examine the relative effects of proposed alternatives to 

black-backed woodpeckers. Values are relative and should scale proportionally (Ibid). 

Incorporating removal of habitat from the Rim Fire Hazard Tree Removal Project and Rim Fire 

Recovery Project, a total of 21 predicted pairs of black-backed woodpeckers are within the Rim Fire 

area on the STF. For analysis of direct and indirect effects associated with this project, 21 were used 

as the maximum predicted pair density possible.

Indicators

The following indicators were chosen to provide a relative measure of the direct and indirect effects 

to the black-backed woodpecker and to determine how consistent the project alternatives are with this 

species’ conservation strategy recommendations.

1. Amount of suitable habitat modified.

2. Predicted pair density retained as a proportion of modeled pairs (Tingley et al. 2014a). 

3. Toxicological effects from herbicide use. 

These criteria were chosen to supplement the information provided in the MIS report by identifying 

and analyzing potential effects to the black-backed woodpecker related to expected densities within 

the project area. While the Rim Fire Recovery MIS Report focuses on the relationship of project-level 

habitat impacts to bioregional scale and trend, the effects analysis here focuses on the relative value 

of different proposed management units by alternative within the Rim Fire area based on habitat 

quantity and quality (Tingley et al. 2014a). Acres in this analysis may vary slightly from those 

presented in the MIS report due to rounding error or to minor corrections made to continuously 

revised dynamic database sources.

Alternatives 1, 3 and 5

Because there is no difference in the areas proposed for treatment under these three alternatives, the 

effects are expected to be same and are analyzed together. The differences in herbicides proposed 

between Alternatives 1 and 5 versus Alternative 3 were separated below accordingly.

DIRECT AND INDIRECT EFFECTS

Indicator 1

Under Alternatives 1, 3 and 5, about 2,260 acres of suitable habitat would be modified, while 8,066 

acres of suitable habitat would be retained, Table 3.16-18. Snags would be retained at a rate of 12 to 

30 square feet of basal area per acre, averaged on a unit basis. While snags retained at this density are 

not expected to provide suitable habitat that would contribute to a black-backed woodpecker home 

range, they would provide foraging and possibly nesting structures. 

Indicator 2

Under Alternatives 1, 3 and 5 about 76% of modeled pairs (16) would be retained on STF lands, 

Table 3.16-18. 

Of the action alternatives, Alternatives 1, 3 and 5 result in the least amount of habitat retention for 

black-backed woodpeckers and the lowest predicted pair density. 

Indicator 3

Herbicide use under Alternatives 1 and 5 are expected to have limited potential for direct or indirect 

toxicological effects on black-backed woodpeckers, as described under the herbicide risk assessment 

section. Because no herbicides are proposed under Alternative 3, no exposure to herbicides and no 

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direct, indirect, or cumulative toxicological effects to black-backed woodpeckers would occur under 

this alternative.

CUMULATIVE EFFECTS

Appendix B identifies the present and reasonably foreseeable future actions on all lands within the 

analysis area. Some, but not all of these actions have or may contribute cumulatively to effects on 

black-backed woodpeckers.

Based on risk factors affecting black-backed woodpeckers, the following relevant evaluation criteria 

were used as relative measures of cumulative effects of Alternatives 1, 3 and 5 to black-backed 

woodpeckers: habitat modification. In addition, Alternatives 1 and 5 used toxicological effects for 

evaluation criteria.

Habitat Modification

Federal Lands: Present and foreseeable future fuels reduction projects on federal lands include: Funky 

Stewardship, Groovy Stewardship, Reynolds Creek Stewardship, Soldier Creek Timber Sale, Campy 

Timber Sale, Looney Timber Sale, Thommy Timber Sale, which are green thinning projects treating 

6,546 acres of green forest. All snags and many declining trees will be retained unless they pose a 

safety hazard in these projects. This snag and declining tree retention will provide snags in the short 

term as well as recruit snags in the long term.

Toxicological Effects

Federal lands: There is one present federal action of herbicide use on 0.5 acres under the Rim Fire 

Rehabilitation project and two foreseeable federal actions of herbicide use: 8.0 acres under the 

Twomile Ecological Restoration Noxious Weed project and 23 acres under a special use permit for 

the Reliable Power Project powerline. No other present or foreseeable future federal actions are 

related to herbicide use. 

Private lands: Herbicide use is proposed on 1,583 acres of private land within the project area in 

2017. No other present or foreseeable future actions are proposed on private lands related to herbicide 

application. 

Alternatives1, 3 and 5 Contribution and Summary

Alternatives 1, 3 and 5 are expected to contribute cumulatively to effects on black-backed 

woodpeckers. Modification of 2,062 acres (8%) of the remaining suitable habitat within the analysis 

area is expected from implementation of this alternative. The predicted pair density within the 

remaining suitable habitat on Stanislaus NFS when added to suitable habitat in Yosemite National 

Park is predicted to support a total of 80 pairs (94%) of black-backed woodpeckers in the Rim Fire 

perimeter. Alternatives 1 and 5 would contribute to the short-term potential of exposure to toxicity 

from herbicide use. The cumulative contribution to effects on black-backed woodpeckers is 

considered minor and is not expected to affect the species viability.

Alternative 2

Under No Action, death, injury and disturbance would not be an issue because no active management 

would occur. 

DIRECT AND INDIRECT EFFECTS

Indicators 1 and 2

The indirect effects of No Action are related to the amount of habitat retained and predicted pair 

density across the project area. Under this alternative, 10,326 acres of suitable habitat would be 

available to black-backed woodpeckers, Table 3.16-18. The predicted pair density associated with this 

alternative is 21, Table 3.16-18. This alternative provides the greatest amount of habitat and the 

highest predicted pair density when compared to Alternatives 1, 3 and 5. It provides the same amount 

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of suitable habitat and predicted pair density as Alternative 4. Black-backed woodpeckers would be 

expected to occupy the available suitable habitat for the next 6 to 8 years, which is typically the 

period of time burned habitat is most suitable for this species.

Indicator 3

Because no herbicides are proposed under this alternative, no exposure to herbicides and no direct, 

indirect, or cumulative toxicological effects to black-backed woodpeckers would occur under this 

alternative.

CUMULATIVE EFFECTS

Under the No Action alternative, no direct cumulative effect is expected because no active 

management would occur. 

Alternative 2 Contribution and Summary

The cumulative contribution under this alternative would result in the highest retention of suitable 

habitat available for black-backed woodpeckers when compared to Alternatives 1, 3 and 5, Table 

3.16-19. Alternative 4 results in the same retention as the No Action alternative because no suitable 

black-backed woodpecker habitat is proposed for planting under Alternative 4. Retention of about 

10,326 acres (30%) of suitable habitat on STF lands is expected from implementation of this 

alternative. The predicted pair density within the analysis area is 21 pairs of black-backed 

woodpeckers. About 27,813 acres of suitable black-backed woodpecker habitat would be retained 

across the analysis area on NFS lands and Yosemite National Park. This habitat is predicted to 

support a total of 85 pairs of black-backed woodpeckers. 

Alternative 4

DIRECT AND INDIRECT EFFECTS

Indicators 1 and 2

Because no treatments are proposed in suitable black-backed woodpecker habitat under this 

alternative, effects are expected to be the same as discussed under Alternative 2.

Indicator 3

Herbicide use under Alternative 4 is expected to have limited potential for direct or indirect 

toxicological effects on black-backed woodpeckers, as described under the herbicide risk assessment 

section.

CUMULATIVE EFFECTS

The cumulative effects discussion under Alternatives 1, 3 and 5 outline those present and foreseeable 

future activities scheduled on public and private lands.

Alternative 4 Contribution and Summary

Cumulative effects related to habitat modification under this alternative are expected to be the same 

as discussed under Alternative 2. Alternative 4 would contribute to the short-term potential of 

exposure to toxicity from herbicide use. The cumulative contribution to effects on black-backed 

woodpeckers is considered minor and is not expected to affect the species viability.

Black-backed Woodpecker: Summary of Effects

Indicator 1. The amount of suitable habitat modified varies among the action alternatives, shown in 

Table 3.16-18. Alternatives 1, 3 and 5 would result in the greatest amount of suitable habitat modified 

when compared to Alternative 4. Alternative 4 would result in the least amount of suitable habitat 

modified. 

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Indicator 2. The predicted pair density varies between action Alternatives 1, 3 and 5 and Alternative 

4, Table 3.16-18. Alternatives 1, 3 and 5 would result in the lowest predicted pair density when 

compared to Alternative 4. Alternative 4 would result in the highest predicted pair density among the 

action alternatives.

Table 3.16-18 Blacked-Backed Woodpecker Summary of Direct and Indirect Effects

Indicator and Metric Alternative 

1

Alternative 

2

Alternative 

3

Alternative 

4

Alternative 

5

1. Amount of suitable habitat modified on 

STF lands1 2,260 0 2,260 0 2,260

1. Percent of suitable habitat modified1 22 0 22 0 22

2. Predicted pair density retained (modeled 

pairs retained)

16 21 16 21 16

2. Predicted pair density retained (% of 

modeled pairs retained)

76 100 76 100 76

1 Based on acres of suitable habitat on STF.

Table 3.16-19 Blacked-Backed Woodpecker Summary of Cumulative Effects

Indicator and Metric Alternative 

1 

Alternative 

2 

Alternative 

3 

Alternative 

4 

Alternative 

5 

1. Amount of suitable habitat modified in the 

Rim Fire perimeter (acres modified)

2,260 0 2,260 0 2,260

1. Amount of suitable habitat modified in the 

Rim Fire perimeter (% modified)

8 0 8 0 8

2. Predicted pair density retained in the Rim 

Fire perimeter (modeled pairs retained)

80 85 80 85 80

2. Predicted pair density retained in the Rim 

Fire perimeter (% of modeled pairs retained)

94 100 94 100 94

Indicator 3. Herbicide use under Alternatives 1, 4 and 5 are expected to have limited potential for 

direct or indirect toxicological effects on black-backed woodpeckers. Because Alternative 4 has fewer 

acres of herbicide application proposed, the potential for effects would be less than under Alternatives 

1 and 5. However, it is important to note that the toxicity exposure scenarios analyzed in the risk 

assessment show that all but three HQ values are at or less than the NOAEL threshold or No 

Observable Adverse Effect Level. Three scenarios with HQs from 1.1 to 1.8 involve ingestion of 

contaminated insects or fruit. These HQs are just above the threshold of concern, meaning there is a 

slightly elevated toxicological risk for individual black-backed woodpeckers ingesting contaminated 

insects or fruit. Given the foraging behavior of these species, it is unlikely that they would realize this 

actual level of exposure. Therefore, this species is provided an adequate margin of safety in the event 

that individuals are exposed to contaminated prey, fruit, or water. 

Black-backed Woodpecker: Consistency with Conservation Strategy

No standards and guidelines or direction specific to black-backed woodpecker are in the STF, Forest 

Plan Direction (USDA 2010a). The Conservation Strategy for the Black-backed Woodpecker 

(Picoides arcticus) in California version 1.0 includes the following recommendations: 

 Recommendation 1.1. Within the range of the Black-backed Woodpecker, ensure that post-fire 

management occurring in new fires that burn 123 acres (50 hectares) or more of conifer forest at 

moderate- to high-severity consider snag retention and other burned-forest habitat needs of the 

species.

 Where feasible, Black-backed Woodpeckers will likely benefit most from large patches of burned 

forest being retained in unharvested condition. 

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 Recommendation 1.4. Retain high tree density in the unburned forest periphery around fire areas, 

to provide foraging habitat in the later post-fire years (see Saab et al. 2011).

 Recommendation 1.5. Avoid harvesting fire-killed forest stands during the nesting season 

(generally May 1 through July 31). 

The action alternatives do not specifically incorporate a limited operating period for this species to 

prohibit salvage harvest during the black-backed woodpecker nesting season. However, the action 

alternatives do incorporate limited operating periods for Sensitive species within potential blackbacked woodpecker habitat. Additionally, 78 to 100% of existing suitable habitat would be retained 

under all action alternatives. Alternative 4 considers full snag retention and no harvest within suitable 

black-backed woodpecker habitat.

It is important to note, the Conservation Strategy for Black-backed Woodpecker (Picoides arcticus) 

in California (Bond et al. 2012) is not a legally binding or regulatory document or agency policy; 

moreover, it was not designed to constrain the FS in its actions and activities. It seeks to summarize 

known information about the species, recommends management approaches for conservation, and 

suggests future research priorities (Bond et al. 2012). By its very nature, the Black-backed 

Woodpecker Conservation Strategy only considers one species. The FS has to balance multiple 

priorities, objectives, uses, and species in its activities as a multiple use agency. And, at times, certain 

management objectives are in tension, if not direct conflict, with one another. For example, through 

this Project, the Forest Service seeks to plant conifers to reestablish green forest for species dependent 

upon it; yet, the Forest Service also wishes to conserve burned forest habitat for the black backed 

woodpecker and other species. The Forest Service has tried to strike a reasonable balance between 

these two goals at the landscape level, realizing it is not possible to fully achieve both of these goals 

on each and every acre.

Mule Deer: Affected Environment

Species and Habitat Account

The mule deer (Odocoileus hemionus) is an MIS species representing oak-associated hardwood and 

hardwood/conifer in the Sierra Nevada. The mule deer is also a species of conservation concern on 

the STF and is considered common to abundant with a wide distribution throughout the Sierra 

Nevada. They occur at elevations of 1,800 to 11,800 feet on the west slope of the Sierra Nevada.

Summer range typically occurs above 6,500 feet elevation, transition range occurs between 4,500 to 

6,500 feet elevation and winter range from 1,800 to 4,500 feet elevation. Mule deer are an important 

game species that is hunted throughout its range in California.

Trends in the migratory deer populations on the STF have been declining since the 1970s (Maddox 

1980). The Tuolumne and Yosemite herds have experienced downward population trends over the 

past several decades (Graveline pers. comm.). 

Deer composition counts are conducted by CDFW in the spring and fall of each year in order to 

assess population trends. In 2009, Greg Gerstenberg, Senior Environmental Scientist with CDFW, 

initiated a study of the Tuolumne Mule Deer Herd to investigate exotic louse infestation, effects on 

individuals, potential spread, and the resulting influence on deer populations. Ear tag radio 

transmitters and G.P.S. collars are being used to monitor deer and gather data on over-winter survival, 

habitat relationships such as migration routes, summer range extent, and winter range habitat use 

(Gerstenberg 2012, unpub. report).

Collared deer were monitored shortly after the Rim Fire burned through the critical winter range for 

the Tuolumne Deer herd. Several collared individuals were lost, which indicates loss of many deer 

during the fire (Gerstenberg pers. comm.). Because the fire hit prior to the winter migration, most 

migratory deer were still on their summer ranges at higher elevations. There is a resident herd that 

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remains in the lower country year round and these deer were much more susceptible to mortality from 

the Rim Fire. About 80% of collared deer (n=5) are thought to have perished in the fire (Graveline 

pers. comm.).

The Tuolumne and Yosemite deer herds have summer, transition, and winter range within the 

analysis area. The Jawbone Ridge area on the STF currently supports the highest concentration of 

wintering California mule deer from the Tuolumne Deer Herd and much of this area burned at high 

severity in the Rim Fire.

Mule deer utilize a variety of vegetation types including oak woodlands, coniferous forest, meadows 

and grasslands, chaparral and riparian corridors. Favorable habitat conditions for deer include 

vegetation communities that occur in a mosaic pattern with multiple age classes represented, and 

where cover and forage are in close proximity to free water (Ahlborn 2006). 

Mule deer are polygynous; bucks mate with multiple does. Rutting begins in the fall and dominant 

bucks mate with multiple does as they come into estrous. Bucks fight and displace each other 

establishing and reestablishing dominance throughout the season. Gestation is about six to seven 

months, with fawns born typically May through July on the STF. 

Mule deer browse or graze, showing preferences for forbs and grasses, as well as tender new shoots 

on various shrub species including mazanita, ceanothus, mountain mahogany, and bitterbrush (Kufeld 

1973). Forage patterns vary with season, forage quality, and availability. Acorns are a critically 

important fall and winter food. Fawns from the Tuolumne Herd have an average weight that is 10

to15% greater with a heavy black oak acorn crop (Gerstenberg, unpub. data).

Mule deer are either resident or migratory. Migratory deer travel downslope in the winter where 

conditions are milder and snow pack is minimal. The deer migrate upslope in the spring and early 

summer after the snow melts to birth fawns and gain access to high elevation meadows and 

grasslands that offer herbaceous forage high in nutrients.

RISK FACTORS

Risks to mule deer on the STF have been summarized by CDFW (Maddox 1980) and include: 

1. Range decadence- Areas where shrub communities become decadent from the lack of fire or 

active management results in forage providing lower quality nutrients to deer. Areas become 

inaccessible or unavailable and may impact individual fitness.

2. Grazing - On the summer range, cattle and deer compete for limited forage found in meadows 

and grasslands. Conflicts between cattle and deer on the winter range are not known to be a 

limiting factor for deer on the STF. 

3. Oak and shrub removal in type conversions – Establishment of plantations in areas that would 

otherwise be dominated by shrub and oaks can reduce the amount of forage available to deer in a 

given area.

4. Poaching- Poaching occurs most often on the winter range and has affected not only the number 

of deer, but the age distribution of bucks. Poachers typically target older bucks presumably for 

the extensive antlers sought by many hunters; however, does are taken as well.

5. Loss of Acorn Producing Oaks due to Catastrophic or Stand Replacing Wildfire - Oaks take 

several decades to develop the capacity to produce acorns. Oaks that are lost to wildfire 

effectively reduce the amount of forage available and this is a critical food source in both 

transition and winter ranges.

6. Loss of Meadow Habitat - Meadows are an important component of deer habitat. Conifer 

encroachment threatens the viability and availability of meadows in the long term.

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Mule Deer: Environmental Consequences

The project alternatives could result in direct and indirect effects to the mule deer through the 

following activities:

 Mechanical site preparation for planting.

 Herbicide application for site preparation and release of conifers.

 Planting conifers.

 Prescribed fire

These direct and indirect effects include:

 Project related death, injury and disturbance. 

 Project related modifications to habitat quantity or quality.

Death, Injury and Disturbance

Death or injury from project related activities would be unlikely to occur given the mobility of this 

species. Project activities, especially loud noise, could result in disturbance that may impair essential 

behavior patterns of deer primarily on the winter range and transition or intermediate zones present 

within the analysis area. Loud noise from equipment such as chainsaws or tractors is expected to 

occur in reforestation and thinning units. Temporary avoidance of the project site or displacement of 

individuals is expected during project implementation. Any displacement or avoidance would be of 

short duration and would subside shortly after project implementation activities. The potential risk to 

individual deer is considered low because of their natural avoidance behavior.

Habitat Modification

Thinning green plantations would result in short- and long-term benefits to mule deer. Short-term, 

thinning existing plantations would allow us to release surviving oaks and create effective hiding and 

thermal cover adjacent to foraging habitat. Thinning would also open up areas for herbaceous 

vegetation to reclaim the understory. Under these conditions, early seral vegetation, shrubs, grasses, 

and forbs are expected to establish within a few years post treatment. Creating a more open canopy 

forest would improve the ability of deer to evade predators. Additionally, thinning these areas would 

increase structural diversity and resiliency when fire moves through this area in the future.

Limited reforestation in deer winter range would also result in short- and long-term benefits to deer. 

Short-term, reforestation of areas adjacent to high quality forage would increase accessibility to 

foraging habitat and provide protection from inclement weather throughout the winter range. 

Optimizing the location and size of hiding and thermal cover patches interspersed with foraging 

habitat would increase habitat effectiveness on the winter range (Thomas 1979). Long-term, foraging 

habitat interspersed with mature forest cover would provide high quality winter range and improve 

individual and herd health and survival. Using prescribed fire would also result in short- and longterm benefits including reducing dense thickets of shrubs that grow up next to oaks making them 

more vulnerable to mortality from wildfire, providing new more palatable forage in a variety of age 

classes, and maintaining open conditions in the understory to provide for easy navigation of the 

landscape. While Salwasser and others (1982) have suggested that optimal habitat structure for deer 

in areas of cover includes dense vegetation, the vegetation under four feet should be sufficiently open 

to allow for deer movement. More open conditions would also improve the ability for deer to more 

easily evade predators.

Indicators

The following indicators were chosen to provide a relative measure of the direct and indirect effects 

to mule deer. 

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1. Acres of hiding and thermal cover adjacent to high quality foraging areas and travel corridors, 

thinned and planted. 

2. Toxicological effects from herbicide use. 

These criteria were chosen based on the best available scientific literature, which focuses on various 

aspects of deer ecology and life history requirements. These criteria focus on those life history 

aspects, or habitat elements, considered most limiting to deer persistence across their range and where 

project effects are expected.

Alternative 1, 3 and 5

DIRECT AND INDIRECT EFFECTS

Because there is very little difference in the planting prescription and outcome in the short- and longterm under these three alternatives, the effects of indicator 1 are expected to be similar under these 

three alternatives and are analyzed together.

Indicator 1

Reforestation (includes natural regeneration): Under Alternatives 1, 3 and 5, about 646 acres are 

proposed for reforestation to provide forested cover in areas that burned at high severity in the Rim 

Fire in 2013. These areas, if reforested, would maximize habitat capability across the winter range. 

Benefits of these treatments include improving concealment cover and thermal relief along important 

movement corridors between foraging and bedding areas and increasing access to high quality 

foraging habitat. Reforestation would result in habitat improvement and increased access to forage 

across the winter range.

The planting prescriptions under Alternatives 1 and 3 for hiding cover include alternating clusters of 

three and five trees and providing a 30 foot oak buffer for up to five oaks per acre. The desired 

condition is to create an open canopy structure that provides effective hiding cover, concealment from 

predators and humans. Planting prescriptions for thermal cover include planting individual trees 

ranging from 10 to 14 foot spacing while also providing buffers for up to five oaks per acre as 

described for hiding cover. All other oaks under both prescriptions would become part of the planting 

prescription, taking the place of a conifer seedling when planting. 

The planting prescription under Alternative 5 is the same across all 646 acres: planting conifers with a 

7 by 14 foot spacing. Up to five oaks per acre would be buffered as described under Alternatives 1 

and 3. With the tighter spacing of planted trees, it would be necessary to thin the plantations around 

year 7 to create the open canopy desired for hiding cover and to provide longer-term growing space to 

individual trees in areas designated for thermal cover. While the initial planting prescription calls for 

more trees, the outcome and long term benefits described under Alternatives 1 and 3 above, would be 

realized under Alternative 5 with the incorporation of thinning these new plantations around year 7. 

Thinning would be by hand and material would be piled and burned on site. This is not expected to 

affect deer as this would be limited in scope and duration. Prescribed fire would be introduced to all 

new plantations as early as ten years after planting. Benefits of prescribed fire are discussed under 

habitat modification. 

Thinning: Under these alternatives, 1,164 acres were identified for thinning within existing 

plantations. With the dense vegetation conditions that currently exist in these plantations, deer have 

limited movement corridors within the winter range and are more susceptible to predation 

(Gerstenberg pers. comm.). These conditions have resulted in much less deer use in these plantations 

today than several years ago (pers. obs.). TTrees range from 8 to 12 inches dbh and are mature 

enough to provide the designated cover type immediately post treatment. 

Deer are expected to benefit in the short- and long-term from the thinning of existing plantations. 

Prescribed fire would be the first tool used for thinning these stands. The goal in using prescribed fire 

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is to open up stands, creating a habitat mosaic of more open conditions interspersed with dense 

pockets of trees that together would serve as hiding and thermal cover. If we are unable to accomplish 

thinning by using prescribed fire, we would use mechanical means to achieve the desired conditions. 

Surviving oaks greater than or equal to six inches dbh would be targeted for release, removing any 

conifer within 30 feet of the bole of up to 5 oaks per acre. All other oaks would be included in the 

matrix of the stand where the remaining conifers would either be thinned to create hiding or thermal 

cover. Hiding cover areas would be thinned to create several small groups of trees (four to seven per 

group) with 30-foot spacing between groups. Thermal cover areas would be thinned to a spacing of 

about 20 to 25 feet to promote denser forested conditions. 

Under these alternatives, thinning the plantations would result in more open stand conditions much 

easier for deer to navigate. Thinning would also increase light penetration and the availability of 

herbaceous forage throughout these stands. Proposed treatments would result in beneficial impacts on 

individual fitness through increased forage availability and quality, as well as the potential reduction 

in susceptibility to predation across the critical winter range.

The combination of thinning existing plantations and reforesting areas adjacent to high quality 

foraging habitat would improve habitat conditions across about 70% of the critical winter range. The 

collective suite of treatments including reforestation and thinning adjacent to high quality foraging 

habitats, and prescribed fire to manage vegetation densities and decadence, would result in high 

quality and sustainable habitat throughout the 7,000-acre critical winter range.

Indicator 2

Herbicide use under Alternatives 1 and 5 are expected to have limited potential for direct or indirect 

toxicological effects on mule deer, as described under the herbicide risk assessment section. Because 

no herbicides are proposed under Alternative 3, no exposure to herbicides and no direct, indirect, or 

cumulative toxicological effects to mule deer would occur under this alternative.

Noxious Weeds: Herbicides would be used to eradicate noxious weeds. The long term benefits of 

noxious weed treatments near Jawbone Lavacap include increased forage availability on critical 

winter range. 

CUMULATIVE EFFECTS

Appendix B identifies the present and reasonably foreseeable future actions on all lands within the 

analysis area. Some, but not all of these actions have or may contribute cumulatively to effects on 

mule deer. 

Based on risk factors affecting deer, the following relevant evaluation criteria were used as relative 

measures of cumulative effects from Alternatives 1, 3 and 5: habitat modification. In addition, 

Alternatives 1 and 5 used toxicological effects for evaluation criteria.

Habitat Modification

Federal Lands: Present and foreseeable future activities on federal lands include: Funky Stewardship, 

Groovy Stewardship, Reynolds Creek Stewardship, Soldier Creek Timber Sale, Campy Timber Sale, 

Looney Timber Sale, Thommy Timber Sale, which are green thinning projects treating 6,546 acres of 

green forest across the analysis area. Releasing oaks is a part of all thinning prescriptions, which will 

protect an important food source for deer across the landscape, including transition zones. Fuels 

reduction associated with the Rim Recovery project will reduce the risk of further loss of remaining 

green forest within the project area. Other federal activities potentially impacting habitat for mule 

deer is meadow restoration. 

Meadow restoration projects (Reynolds Creek, Rim Fire Rehabilitation, Twomile Meadow 

Restoration) are expected to improve foraging habitat across about 180 acres for mule deer. By 

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removing encroaching conifers and improving hydrologic function of meadows on this landscape, 

habitat suitability in these meadows would increase forage availability for deer.

Toxicological Effects

Federal lands: There is one present federal action of herbicide use on 0.5 acres under the Rim Fire 

Rehabilitation project and two foreseeable federal actions of herbicide use: 8.0 acres under the 

Twomile Ecological Restoration Noxious Weed project and 23 acres under a special use permit for 

the Reliable Power Project powerline. No other present or foreseeable future federal actions are 

related to herbicide use. 

Private lands: Herbicide use is proposed on 1,583 acres of private land within the project area in 

2017. No other present or foreseeable future actions are proposed on private lands related to herbicide 

application. 

Alternatives 1, 3 and 5 Contribution and Summary

Alternatives 1, 3 and 5 would contribute cumulatively to short- and long-term beneficial effects to 

mule deer by providing hiding and thermal cover in close proximity to high quality foraging habitat 

as well as releasing surviving and resprouting oaks, a critical food source for deer on their winter 

range. With a combination of thinning and reforestation where appropriate, habitat conditions would 

be improved throughout the 7,000 acres of designated critical winter range. Prescribed fire would 

play an important role in maintaining high quality habitat conditions across the winter range. These 

alternatives would result in benefits not realized under Alternative 4 where only 88 acres is proposed 

for reforestation, leaving high quality foraging habitat inaccessible. Alternatives 1 and 5 would 

contribute to the short-term potential of exposure to toxicity from herbicide use. Benefits for deer 

from the effective eradication of noxious weeds such as medusahead include increased herbaceous 

forage availability in critical wintering areas including Jawbone lavacap and far outweigh the limited 

exposure risk presented from the use of herbicides. The cumulative contribution under these 

alternatives may affect individual mule deer, but is not expected to affect the viability of this species.

Alternative 2

DIRECT AND INDIRECT EFFECTS

Under No Action, death, injury and disturbance would not be an issue because no active management 

would occur. 

Indicator 1

The indirect effects of no action are primarily related to the influence no action may have on the 

availability of cover adjacent to high quality foraging habitat and important travel corridors, and not 

maintaining desired cover densities and palatable forage using prescribed fire. Under this alternative, 

it is likely that shrub cover would take the place of potential forested habitat. In the short-term, this 

would provide some cover and relief for deer from weather and predators. In the long-term, the 

shrubs would grow into dense thickets, prohibiting deer movement, increasing susceptibility to 

predation, and increasing range decadence. No thinning of existing plantations would occur under this 

alternative. Surviving and resprouting oaks would not be released from competition and fuel loading 

would continue to increase adjacent to oaks resulting in increased vulnerability to mortality when the 

next wildfire moves through the winter range. 

Indicator 2

Because no herbicides are proposed under this alternative, no exposure to herbicides and no direct, 

indirect, or cumulative toxicological effects to mule deer would occur under this alternative. 

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CUMULATIVE EFFECTS

The cumulative effects discussion under Alternative 1 outlines those present and foreseeable future 

activities scheduled on public and private lands.

Alternative 2 Contribution and Summary

Under Alternative 2, no direct cumulative effect is expected because no active management would 

occur; however, there may be indirect consequences under this alternative primarily related to the 

influence no action may have on the availability of cover adjacent to high quality foraging habitat and 

important travel corridors and not maintaining desired cover densities and palatable forage using 

prescribed fire. Oaks in untreated plantations would be at risk of loss when fire returns to this 

landscape. At the landscape scale, the cumulative contribution under this alternative would not 

increase habitat effectiveness for mule deer. The cumulative contribution under this alternative may 

negatively affect individual and potentially herd fitness, but would not likely affect the viability of the 

species across its range in the Sierra Nevada Bioregion. 

Alternative 4

DIRECT AND INDIRECT EFFECTS

Indicator 1

Thinning: Under Alternative 4, the thinning prescriptions and expected effects are the same as 

described under Alternatives 1, 3 and 5. 

Reforestation: Under Alternative 4, only 88 acres are proposed for reforestation. This is 558 acres less 

planting than proposed under Alternatives 1, 3 and 5. The planting prescription under this alternative 

is termed founder stands. This prescription calls for small variable shaped planting areas ranging from 

two to ten acres in size within a larger unplanted area. The planted area is only 20% of a given unit. 

Plant 20 to 40 clusters per acre spaced an average of 33 feet apart. Within each cluster, plant five trees 

spaced six feet between each tree. Herbicides would be used to control shrubs and competing 

vegetation within planted areas and incorporating a 25 to 50 foot buffer around planted areas. With 

the tighter spacing of planted trees, it may be necessary to thin the plantations around year 7 to allow 

growing space for the trees to mature. Mechanical thinning is not proposed under this alternative; 

however, prescribed fire is proposed and would be used to thin the new plantations. Prescribed fire 

would be applied to 50% of planted areas within ten years and the other 50% within 20 years. 

Prescribed fire is expected to result in benefits similar to those discussed under the habitat 

modification section. Reforestation effects under this alternative include reduced access to high 

quality foraging habitat and reduced thermal cover and reduced habitat effectiveness. This alternative 

is less beneficial to deer when compared to Alternatives 1, 3 and 5. 

Indicator 2

Herbicide use under Alternative 4 is expected to have limited potential for direct or indirect 

toxicological effects on mule deer, as described under the herbicide risk assessment.

Noxious Weeds: Herbicides would not be used to eradicate noxious weeds, but we would use other 

methods such as prescribed fire and targeted grazing to reduce weed populations where feasible. The 

long term benefits of noxious weed treatments near Jawbone Lavacap could be realized if prescribed 

fire and grazing are successful. Benefits include increased forage availability on critical winter range. 

CUMULATIVE EFFECTS

The cumulative effects discussion under Alternative 1 outlines those present and foreseeable future 

activities scheduled on public and private lands.

Alternative 4 Contribution and Summary

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Alternative 4 would contribute cumulatively to short- and long-term effects to mule deer. This 

alternative would provide only 13% of the desired hiding and thermal cover in close proximity to 

high quality foraging habitat. This alternative would result in reduced habitat effectiveness across the 

winter range when compared to Alternatives 1, 3 and 5. Thinning existing plantations would result in 

improved habitat conditions across about 2,600 acres. Prescribed fire would play an important role in 

maintaining habitat conditions across the winter range, including reducing fuel loading and 

stimulating growth of new palatable forage. Alternative 4 would contribute to the short-term potential 

of exposure to toxicity from herbicide use. The cumulative contribution under these alternatives may 

affect individual mule deer, but is not expected to affect the viability of this species.

Mule Deer: Summary of Effects

Indicator 1. As shown in Table 3.16-20, of the action alternatives, Alternatives 1, 3 and 5 would 

improve the greatest amount of habitat by thinning existing plantations, planting conifers in close 

proximity to high quality foraging habitat, and using prescribed fire to maintain high quality habitat 

conditions. Alternative 4 would improve the least amount of habitat and would incorporate the use of 

prescribed fire to maintain habitat conditions. 

Table 3.16-20 Mule Deer Summary of Effects

Indicator and Metric Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5

1. Hiding and thermal cover adjacent to 

high quality foraging areas (acres 

reforested1)

646 0 646 88 646

1. Hiding and thermal cover adjacent to 

high quality foraging areas (acres of 

existing plantation thinned)

1,164 0 1,164 1,164 1,164

1 Includes natural regeneration

Indicator 2. Herbicide use under Alternatives 1, 4 and 5 are expected to have limited potential for 

direct or indirect toxicological effects on mule deer. Because Alternative 4 has fewer acres of 

herbicide application proposed, the potential for effects would be less than under Alternatives 1 and 5. 

However, it is important to note that the toxicity exposure scenarios analyzed in the risk assessment 

show that all HQ values are less than the NOAEL threshold of concern or No Observable Adverse 

Effect Level. Therefore, this species is provided an adequate margin of safety in the event that 

individuals are exposed to contaminated vegetation or water.

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3.17 SHORT-TERM USES AND LONG-TERM PRODUCTIVITY

NEPA requires consideration of “the relationship between short-term uses of man’s environment and 

the maintenance and enhancement of long-term productivity” (40 CFR 1502.16). As declared by the 

Congress, this includes using all practicable means and measures, including financial and technical 

assistance, in a manner calculated to foster and promote the general welfare, to create and maintain 

conditions under which man and nature can exist in productive harmony, and fulfill the social, 

economic, and other requirements of present and future generations of Americans (NEPA Section 

101). 

Short-term uses 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 is complete. No short-term uses of a renewable resource are a part of 

this project. Trees can be reestablished and grow if the long-term productivity of the land is 

maintained. Long-term productivity is maintained through application of management requirements 

described in Chapter 2, in particular those applicable to soil and water resources. 

The action alternatives (1, 3, 4 and 5) all would provide for the long-term productivity of the project 

area through site preparation, planting, release, and noxious weed treatments creating a resilient forest

where areas can recover from future fire effects naturally. 

3.18 UNAVOIDABLE ADVERSE EFFECTS

Implementation of any action alternative would result in some unavoidable adverse environmental 

effects. Although formation of the alternatives included avoidance of some effects, other adverse 

effects could occur that cannot be completely mitigated. The environmental consequences section for 

each resource area discusses these effects (EIS Chapter 3). 

3.19 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS

Irreversible commitments of resources are those that cannot be regained, such as the extinction of a 

species or the removal of a mined ore. No irreversible commitments of resources would result from 

implementation of any action alternative because no permanent, irreversible resource loss would 

occur. 

Irretrievable commitments are those that are lost for a period of time such as the temporary loss of 

timber productivity in forested areas that are kept clear for use as a power line right-of-way or road. 

Irretrievable losses can be regained over time. Implementation of any action alternative would not 

irretrievably commit resources, but help in the long-term recovery of the landscape.

3.20 OTHER REQUIRED DISCLOSURES

The Rim Reforestation project was prepared in accordance with the following laws and regulations. 

National Environmental Policy Act

The National Environmental Policy Act of 1969 (NEPA) requires that all major federal actions 

significantly affecting the human environment be analyzed to determine the magnitude and intensity 

of those impacts and that the results be shared with the public and the public given opportunity to 

comment. The regulations implementing NEPA further require that to the fullest extent possible, 

agencies shall prepare EISs concurrently with and integrated with environmental analyses and related 

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surveys and studies required by the Endangered Species Act of 1973, the National Historic 

Preservation Act of 1966, and other environmental review laws and executive orders. Other laws and 

regulations that apply to this project are described below. 

Clean Air Act

The Clean Air Act of 1970 provides for the protection and enhancement of the nation’s air resources. 

No exceeding of the federal and state ambient air quality standards is expected to result from any of 

the alternatives. The Clean Air Act makes it the primary responsibility of States and local 

governments to prevent air pollution and control air pollution at its source. 

California has a plan that provides for implementation, maintenance, and enforcement of the primary 

ambient air quality standards. This project is located in an area designated as non-attainment for 

Ozone. The burn treatments in the action alternatives will be conducted under an EPA approved 

California Smoke Management Program (SMP). Under the revised Conformity Rules the EPA has 

included a Presumption of Conformity for prescribed fires that are conducted in compliance with a 

SMP; therefore, the federal actions conform and no separate conformity determination is indicated 

(EIS Chapter 3.02).

Clean Water Act

The Clean Water Act of 1948 (as amended in 1972 and 1987) establishes federal policy for the 

control of point and non-point pollution, and assigns the states the primary responsibility for control 

of water pollution. The Clean Water Act regulates the dredging and filling of freshwater and coastal 

wetlands. Section 404 (33 USC 1344) prohibits the discharge of dredged or fill material into waters 

(including wetlands) of the United States without first obtaining a permit from the U.S. Army Corps 

of Engineers. Wetlands are regulated in accordance with federal Non-Tidal Wetlands Regulations 

(Sections 401 and 404). No dredging or filling is part of this project and no permits are required. 

Compliance with the Clean Water Act by National Forests in California is achieved under state law. 

The California Water Code consists of a comprehensive body of law that incorporates all state laws

related to water, including water rights, water developments, and water quality. The laws related to 

water quality (sections 13000 to 13485) apply to waters on the national forests and are directed at 

protecting the beneficial uses of water. Of particular relevance for the Rim Reforestation project is 

section 13369, which deals with non-point-source pollution and best management practices. As 

described in the EIS (Chapter 3.15), the action alternatives result in the maintenance of the applicable 

beneficial uses of water in the Water Quality Control Plan for the California Central Valley Water 

Quality Control Board. 

Endangered Species Act

Section 7 (d) of the Endangered Species Act (ESA) of 1973 requires that after initiation of 

consultation required under section 7(a)(2), a Federal agency “shall not make any irreversible or 

irretrievable commitment of resources with respect to the agency action which has the effect of 

foreclosing the formulation or implementation of any reasonable and prudent alternative which would 

not violate subsection (a)(2).” 

Rim Fire Recovery (2014)

The Rim Fire started on August 17, 2013. Several days later, it became clear the Rim Fire was a large

incident, the forest initiated contact with the USFWS to alert them of potential impacts from the fire 

or fire suppression activities to listed species, including valley elderberry longhorn beetle and listed or 

candidate amphibian species. Forest service biologists conducted a field trip with a USFWS biologist 

in the Rim Fire burn area on November 4, 2013 to discuss conditions and concerns for listed species. 

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The Forest Service then prepared a Biological Assessment (BA) and a subsequent addendum 

following a meeting with USFWS, considering the effects to three federally listed species: California 

red-legged frog (Threatened), Sierra Nevada yellow-legged frog (Endangered), and valley elderberry 

longhorn beetle (Threatened) are found within the project analysis area in Tuolumne County, 

California (USDA 2014g). That BA requested concurrence with the determination that the overall 

project ‘may affect, not likely to adversely affect” the valley elderberry longhorn beetle, and “may 

affect, likely to adversely affect” California red-legged frog and Sierra Nevada yellow-legged frog. 

As such, the Forest Service engaged with the USFWS in formal consultation and requested a 

Biological Opinion (BO) in support of these determinations with the acknowledgement that effects to 

individuals or habitat are not discountable. 

The determination of “may affect, likely to adversely affect” for California red-legged frog and Sierra 

Nevada yellow-legged frog was limited to 7 locales. Section 7(a)(2) of the ESA requires Federal 

agencies, in consultation with USFWS and the National Marine Fisheries Service (NMFS), to insure 

that their actions are “not likely to jeopardize the continued existence of any” listed species (or 

destroy or adversely modify its designated critical habitat; 16 USC 1536(a)(2)). As such, my decision 

is that no operational implementation activities will occur in those 7 locales as part of this decision 

until such time as formal consultation with USFWS results in issuance of a BO.

Rim Fire Reforestation (2015)

In February 2015, the Forest Service met with USFWS to discuss numerous projects within the Rim 

Fire foot print including reforestation. On August 19, 2015 the Stanislaus National Forest formally 

requested to begin conferencing on the Reforestation project with USFWS. 

The Rim Reforestation project unit specific treatments (EIS Appendix E) reflect project management 

requirements and the content of the BA. The project does not lie within a critical habitat unit for the 

California red legged frog per the Federal Register (March 17, 2010; Volume 75, Number 51) and is 

not within a proposed critical habitat unit for the Sierra Nevada yellow legged frog per the Federal 

Register (April 25, 2013; Volume 78, Number 80). 

Environmental Justice

Executive Order 12898 “Federal Actions to Address Environmental Justice in Minority Populations 

and Low-Income Population” requires that federal agencies make achieving environmental justice 

part of their mission by identifying and addressing, as appropriate, disproportionately high and 

adverse human health and environmental effects of their programs, policies, and activities on minority 

populations and low-income populations. As described in the EIS (Chapter 3.10), the action 

alternatives would not disproportionally impact minority or disadvantaged groups. 

Floodplain Management

Executive Order 11988 applies to Floodplain Management. Floodplains are found along stream 

channels throughout the project area. Implementation of this decision would maintain or improve the 

existing condition of these floodplains by maintaining or improving meadow conditions. The intent of 

Executive Order 11988 would be met since this project would not affect floodplains in the Rim 

Reforestation analysis area and thereby would not increase flood hazard. As described in the EIS 

(Chapter 3.15) no measurable changes in stream flow are anticipated from the action alternatives.

Migratory Bird Treaty Act

The Migratory Bird Treaty Act decreed that all migratory birds and their parts (including eggs, nests, 

and feathers) were fully protected. Under the Act, taking, killing or possessing migratory birds is 

unlawful. The original intent was to put an end to the commercial trade in birds and their feathers that 

wreaked havoc on the populations of many native bird species. On January 17, 2001 President 

459
Chapter 3.20 Stanislaus

Other Required Disclosures National Forest

Clinton signed Executive Order 13186, directing executive departments and agencies to take certain 

actions to further implement the Migratory Bird Treaty Act (FR Vol. 66, No.11, January 17, 2001). 

The Forest Service and USFWS entered into a memorandum of understanding (MOU) to promote the 

conservation of migratory birds as a direct response to the executive order (USDA and USFWS 

2008). One of the steps outlined for the Forest Service is applicable to this analysis: “Within the 

NEPA process, evaluate the effects of agency actions on migratory birds, focusing first on species of 

management concern along with their priority habitats and key risk factors.” The Forest Service 

additionally agreed, to the extent practicable, to evaluate and balance benefits against adverse effects, 

to pursue opportunities to restore or enhance migratory bird habitat, and to consider approaches for 

minimizing take that is incidental to otherwise lawful activities.

This analysis complies with the Migratory Bird Treaty Act but may result in an “unintentional take” 

of individuals during proposed activities. However the project complies with the USFWS Director’s 

Order #131 related to the applicability of the Migratory Bird Treaty Act to Federal agencies and 

requirements for permits for “take”. In addition, this project complies with Executive Order 13186 

because the analysis meets agency obligations as defined under the December 8, 2008 Memorandum 

of Understanding between the Forest Service and USFWS designed to complement Executive Order 

13186 (Migratory and Landbird Conservation Report 2015). If new requirements or direction result 

from subsequent interagency memorandums of understanding pursuant to Executive Order 13186, 

this project would be reevaluated to ensure that it is consistent.

National Forest Management Act

The National Forest Management Act (NFMA) of 1976 amends the Forest and Rangeland Renewable 

Resources Planning Act of 1974 and sets forth the requirements for Land and Resource Management 

Plans for the National Forest System.

The Forest Service completed the Stanislaus National Forest Land and Resource Management Plan 

(Forest Plan) on October 28, 1991. The “Forest Plan Direction” (USDA 2010a) presents the current 

Forest Plan management direction, based on the original Forest Plan, as amended. The Forest Plan 

identifies land allocations and management areas within the project area including: Wild and Scenic 

Rivers, Proposed Wild and Scenic Rivers, Critical Aquatic Refuge (CAR), Riparian Conservation 

Areas (RCAs), Near Natural, Scenic Corridor, Special Interest Areas, Wildland Urban Intermix, 

Protected Activity Centers (PACs), Old Forest Emphasis Areas, and Developed Recreation Sites. 

The Forest Plan and its amendments were prepared pursuant to the 1982 version of the NFMA 

planning regulations (36 CFR 219 (1983)). The current regulations, adopted in 2012 supersede those 

regulations, as well as other versions of the NFMA planning regulations (36 CFR 219.17(c) “This 

part supersedes any prior planning regulation.”). The current NFMA planning regulations do not 

apply to this project (36 CFR 219.7(c) “None of the requirements of this part apply to projects or 

activities on units with plans developed or revised under a prior planning rule ...”). Therefore, the 

sole NFMA duty applicable to this project is for the project to be consistent with the governing Forest 

Plan8

. 

The Forest Plan Compliance document (project record) identifies the Forest Plan S&Gs applicable to 

this project and provides related information about compliance with the Forest Plan. Based on that 

document and other information in the project record, the action alternatives are consistent with the 

Forest Plan and all other requirements of the National Forest Management Act. 

8 The Forest Plan, although developed pursuant to the 1982 planning regulations, did not incorporate any specific aspects of those 

planning regulations. For example, the Forest Plan includes Management Indicator Species (MIS) and was designed to maintain the 

viability of wildlife species, as required by the former 36 C.F.R. § 219.19 regulations, the Forest Plan did not incorporate any of the 

particular legal requirements from the 1982 regulations related to MIS or viability. Therefore, the 1982 regulations are not directly 

applicable to this project.

460

 
Rim Fire Reforestation (45612) Affected Environment

Draft Environmental Impact Statement and Environmental Consequences

National Historic Preservation Act

The National Historic Preservation Act (NHPA) of 1966 is the principal, guiding statute for the 

management of cultural resources on NFS lands. Section 106 of NHPA requires federal agencies to 

consider the potential effects of a Preferred Alternative on historic, architectural, or archaeological 

resources that are eligible for inclusion on the National Register of Historic Places and to afford the 

President’s Advisory Council on Historic Preservation an opportunity to comment. The criteria for 

National Register eligibility and procedures for implementing Section 106 of NHPA are outlined in 

the U.S. Code of Federal Regulations (36 CFR Parts 60 and 800, respectively). Section 110 requires 

federal agencies to identify, evaluate, inventory, and protect National Register of Historic Places 

resources on properties they control. 

The Stanislaus National Forest developed a specialized agreement: “Programmatic Agreement 

Among United States Department of Agriculture, Forest Service, Stanislaus National Forest, the 

California State Historic Preservation Officer, and the Advisory Council on Historic Preservation 

Regarding the Program of Rim Fire Emergency Recovery Undertakings, Tuolumne County, 

California” (Rim PA, project record). This agreement defines the Area of Potential Effects (APE) (36 

CFR 800.4(a)(1)) and includes a strategy outlining the requirements for cultural resource inventory, 

evaluation of cultural resources, and effect determinations; it also includes protection and resource 

management measures that may be used where effects may occur. Additionally, this agreement 

provides opportunities to reforest and remove/eradicate noxious weeds within some sites after 

consultation with the local tribe. 

Protection of Wetlands

Executive Order 11990 requires protection of wetlands. Wetlands within the project area include 

meadows, stream channels, springs, fens, and shorelines. The EIS (Chapter 3.03 and Chapter 3.15) 

and the Watershed Report (project record) address wetlands and riparian vegetation. This project is 

consistent with Executive Order 11990 since this project would maintain or improve the condition of 

wetlands in the Rim Reforestation project area (EIS Chapter 3.15).

461
Chapter 3.20 Stanislaus

Other Required Disclosures National Forest

462
Rim Fire Reforestation (45612) Consultation

Draft Environmental Impact Statement and Coordination

4. Consultation and Coordination

This Chapter includes a section for Preparers and Contributors followed by a section for Distribution 

of the DEIS.

4.01 PREPARERS AND CONTRIBUTORS

The Forest Service worked with the following individuals; federal, state and local agencies; 

organizations; and, tribes during the development of this DEIS. 

Interdisciplinary Team

Marcie Baumbach

Education: A.A. General Education, Chabot College 2000; B.S. Wildlife Management, Humboldt State 

University 2003 

Experience: Wildlife Biologist, Stanislaus National Forest 8 years; Wildlife Biologist, Bureau of Land 

Management 2 years; Wildlife Technician, BLM 3 years

Team Responsibility: Wildlife

Maria Benech

Education: A.A. General Education, Modesto Junior College 1984; B.S. Natural Resources Management 

(Watershed), California Polytechnic State University San Luis Obispo 1987 

Experience: ID Team Leader, Stanislaus National Forest 2 years; Resource Management Program Area 

Leader, Stanislaus National Forest 15 years; Forester, Stanislaus National Forest 9 years; Forester, 

Shasta-Trinity National Forest 2 years

Team Responsibility: ID Team Leader

Ken C. Boucher Jr.

Education: Biological Sciences Certificate, University of Las Vegas 2007

Experience: Fire Management Specialist, Rogue-River Siskiyou National Forest 1 year, Fuels Planner, 

South Fork Management Unit Shasta-Trinity National Forest 23 years

Team Responsibility: Fire and Fuels

Scott T. Cones

Experience: Assistant District Fire Management Officer (Fuels), Stanislaus National Forest 4 years; Fuels 

Technician, Stanislaus National Forest 4 years; Forestry Technician (Fire), Stanislaus National 

Forest 8 years

Team Responsibility: Fire and Fuels

Dawn Coultrap

Education: B.S. Rangeland Resource Science (Botany minor), CSU Humboldt 2005; M.S. Natural 

Resources Sciences (Rangeland Resources and Wildland Soils), CSU Humboldt 2007 

Experience: Rangeland Management Specialist, Stanislaus National Forest 5 years; Staff Biologist, 

Integrated Environmental Services 1 year; Junior Specialist, UC Davis Plant Sciences 5 years; 

Biological Technician, Adaptive Management Services Enterprise 3 years

Team Responsibility: Range 

463
Chapter 4.01 Stanislaus

Preparers and Contributors National Forest

Mary Ellen Emerick

Education: B.A. Writing, Michigan State University 1985. Graduate and undergraduate level coursework 

in Biology, Wilderness and Recreation Management and related fields, Oregon State University 

2002-2004 

Experience: Recreation Planner, Integrated Resources Enterprise 4 years; Outdoor Recreation Planner, 

BLM 5 years; Wilderness Manager, Tongass National Forest 7 years; North Zone Recreation 

Staff Officer, Wallowa-Whitman National Forest 3 years; Seasonal wilderness ranger, Sawtooth 

National Recreation Area 5 years; Chair and board member, Chief’s Wilderness Advisory Group 

4 years

Team Responsibility: Recreation, Wild and Scenic Rivers and Wilderness

Lisa DeHart

Education: B.A. Anthropology (Prehistoric Archaeology), California State University Stanislaus 1984 

Experience: District Archaeologist, Stanislaus National Forest 24 years; Archaeological 

Technician/Archaeologist, Stanislaus National Forest 1 year; Commissioner, Tuolumne County 

Historic Preservation Review Commission 22 years; Archaeologist survey and excavation crews 

in California, Nevada, Montana and Australia 8 years

Team Responsibility: Cultural Resources

Marty Gmelin

Education: A.S. Forestry, Paul Smith’s College NY 1986; B.S Forest Management, University of 

Montana 1989; Forest Service Certified Silviculturist 2011

Experience: Forest Silviculturist, Stanislaus National Forest 2 years; Resource Management Program 

Area Leader, Stanislaus National Forest 8 years; Reforestation Forester, Stanislaus National 

Forest 8 years; Image Analyst, Northern Region 4 years; Regional Snow Survey Coordinator, 

Pacific Southwest Region 14 years 

Team Responsibility: Silviculture

Carly Gibson

Education: B.A. Environmental Studies (Natural History and Conservation Biology), University of 

California Santa Cruz 2000. M.S. Forest Resources (Fire Ecology), University of Idaho 2006 

Experience: GIS Resource Specialist, Stanislaus National Forest 5 years; Ecologist, BeaverheadDeerlodge National Forest 4 years; Research Assistant, University of Idaho 2 years; Biologist, 

Cleveland National Forest 1 year; Restoration Ecologist, San Bernardino National Forest 3 years; 

Biologist, Merkel and Associates 1 year

Team Responsibility: Ecology

Curtis Kvamme

Education: B.S. Natural Resources Ecology and Conservation Biology (Forest Resources minor), 

University of Idaho 2006; M.S. Forest Ecology and Management, Michigan Technological 

University 2010 

Experience: Soil Scientist, Stanislaus National Forest 5 years; Soil Scientist Student Career Experience 

Program (SCEP), Shoshone National Forest 2 years 

Team Responsibility: Soils

John Maschi

Education: B.S. Landscape Architecture, Rutgers University 1976; Master of Landscape Architecture 

(Regional Planning), University of Illinois 1978 

Experience: Forest Planner, Stanislaus National Forest 19 years; Assistant Recreation Officer 6 years; 

Landscape Architect 11 years

Team Responsibility: Land Management Planning and NEPA 

Christopher Mease

Education: B.S. Biology, Oregon State University 1997 

464
Rim Fire Reforestation (45612) Consultation

Draft Environmental Impact Statement and Coordination

Experience: Aquatics Biologist, Forest Service TEAMS Enterprise 5 years; Assistant Forest Aquatics 

Biologist, Stanislaus National Forest 2 years; Fisheries Biologist, Tahoe National Forest 9 years

Team Responsibility: Aquatic Species

Terry Miller

Education: B.A. Plant Biology, Southern Illinois University Carbondale 2000; M.S. Forest Resources 

University of Idaho Moscow 2004 

Experience: Botanist, TEAMS Enterprise 7 years; Forest Botanist, Hiawatha National Forest 2 years; 

District Botanist, Plumas National Forest 4 years; SCEP Botanist, Fishlake National Forest 2 

years

Team Responsibility: Botanical Resources

Fernando Perez

Education: A.A. Pre-Medical, University of Puerto Rico Ponce 1997; B.S. Natural Sciences General, 

University of Puerto Rico Cayey 2002 

Experience: District Hydrologist, Stanislaus National Forest 9 years; Hydrologist Trainee, Caribbean 

National Forest 3 years

Team Responsibility: Hydrology 

Chris Sorensen

Education: B.S. Forestry (Ecological Restoration), Northern Arizona University 2008; M.S. Forestry 

(Silviculture, Forest Carbon and Natural Resource Economics), Northern Arizona University 

2010 

Experience: Planning Forester, Stanislaus National Forest 5 years; Data Management Assistant, Southern 

Colorado Plateau Inventory and Monitoring Network, National Park Service 1 year; Research 

Assistant, Ecological Restoration Institute 3 years

Team Responsibility: Silviculture

Jan Spencer

Education: A.S. Northwest Community College, 1985; Bachelor of Landscape Architecture, Utah State 

University 1988 

Experience: Landscape Architect, Forest Service TEAMS Enterprise 13 years; Environmental Analysis 

(scenery management), Forest Service 20 years; Landscape Architect, White River National 

Forest 10 years

Team Responsibility: Visual Resources

Steven Spickard

Education: B.A. Economics, University of California Berkeley 1974; M.C.P. College of Environmental 

Design, University of California Berkeley 1978 

Experience: Consulting in Economics, Sole Proprietor of Land Economics Consultants 5 years; Sr. V.P., 

AECOM 3 years; Principal, Economics Research Associates 29 years; Research Analyst, Stanford 

Research Institute 2 years

Team Responsibility: Social, Culture and Economy 

Karen Walden

Education: B.S. Forest Resources Management, Humboldt State University 1984 

Experience: Writer/Editor, Stanislaus National Forest 2 years; Forester/Resource Management Planning, 

Tahoe National Forest 8 years; Forester (private) 7 years.

Team Responsibility: Writer/Editor

Federal, State and Local Agencies

Advisory Council on Historic Preservation 

California Department of Fish and Wildlife 

California Farm Bureau Federation

465
Chapter 4.01 Stanislaus

Preparers and Contributors National Forest

City and County of San Francisco Hetch Hetchy Water and Power 

City of San Jose 

Mariposa County Board of Supervisors

Modesto Irrigation District 

San Francisco Public Utilities District

Tuolumne County Board of Supervisors 

Turlock Irrigation District

USDI Environmental Protection Agency 

USDI Fish and Wildlife Service 

Yosemite National Park

Organizations

American Forest Resource Council

American Motorcyclist Association, District 36

Blue Mountain Minerals 

California Forestry Association

California Native Plant Society (Local Chapter)

Camp Towanga 

Central Sierra Audubon Society 

Central Sierra Environmental Resource Center

CT Bioenergy Consulting 

Forest Cattle Permittees

Friends of Berkeley Camp

Friends of Camp Mather

Gold Rush News 

James R. Dambacher Construction

Merced Dirt Riders/4x4 in Motion

Mule Deer Foundation 

SBC Pacific Bell

Rim Fire Technical Workshop

Sierra Forest Legacy

Sierra Pacific Industries

Stanislaus Trail Bike Association

Tuolumne County Alliance for Resources and the Environment (TuCARE) 

Tuolumne County Farm Bureau 

Tuolumne County Sportsmen 

Tuolumne Group Sierra Club 

Tuolumne River Trust

Yosemite Deer Herd Advisory Council 

Yosemite Stanislaus Solutions (YSS)

Tribes

Tuolumne Band of Me-Wuk Indians

466
Rim Fire Reforestation (45612) Consultation

Draft Environmental Impact Statement and Coordination

4.02 DISTRIBUTION OF THE DEIS

The Forest Service is circulating either the DEIS or a notice of the availability of the DEIS to the 

following agencies, elected officials, tribes, organizations and individuals. 

Federal, State and Local Agencies

Federal Agencies

Advisory Council on Historic Preservation, Director, Planning and Review 

Army Corp of Engineers 

Environmental Protection Agency, Region 9 EIS Review Coordinator 

Federal Aviation Administration, Western-Pacific Region Regional Administrator

Federal Highway Administration

National Marine Fisheries Service Habitat Conservationists Division Southwest Region

Rural Utilities Service

USDA APHIS PPD/EAD

USDA National Agricultural Library Head Acquisitions and Serials Branch

USDA Natural Resources Conservation Service, National Environmental Coordinator

USDA Office of Civil Rights

US Coast Guard, Environmental Management 

US Department of Energy, Director, Office of NEPA Policy and Compliance 

USDI Bureau of Land Management 

USDI Fish and Wildlife Service

USDI Office of Environmental Policy and Compliance 

California State Agencies

California Department of Fish and Wildlife 

California Department of Transportation

State Water Resources Control Board (California)

State of California Sierra Nevada Conservancy 

State Clearinghouse (California)

Local Agencies

Modesto Irrigation District 

San Francisco, Hetch Hetchy Water and Power

San Francisco Public Utilities Commission

Turlock Irrigation District

Elected Officials

Federal Officials

Congressman Jeff Denham 

Congressman Tom McClintock

Senator Barbara Boxer

Senator Dianne Feinstein

California State Officials

Kristen Olsen, California Assembly

Frank Bigelow, California Assembly

Tom Berryhill, California Senate 

467
Chapter 4.02 Stanislaus

Preparers and Contributors National Forest

Local Officials

Connie Williams, City of Sonora Council 

Mariposa County Board of Supervisors 

Tuolumne County Board of Supervisors 

Tribes

Tuolumne Band of Me-Wuk Indians

Organizations

American Forest Resource Council

Calforests, California Forestry Association

California Chaparral Institute

California Native Plant Society

Center for Biological Diversity

Central Sierra Audubon Society 

Central Sierra Environmental Resource Center

Cornell University

Crook Logging 

CT Bioenergy Consulting, LLC 

Defenders of Wildlife

Forest Issues Group

John Muir Project of Earth Island Institute 

Mariposa County Agriculture Commissioner

Mother Lode Chapter Sierra Club

Pacific Rivers Council

Sierra Foothills Audubon Society 

Sierra Forest Legacy

Sierra Pacific Industries

Sunset Inn - Yosemite Vacation Cabins

The Wilderness Society

TuCARE

Tuolumne County Sportsmen 

Tuolumne Group Sierra Club 

Tuolumne Irrigation District 

Tuolumne River Trust

Western Watersheds Project

Yosemite Stanislaus Solutions 

Individuals

Albrecht, Mike

Alexander Tr, Mark

Barsanti, Cristine

Bayer, John

Bell, Maren

Ben-Horin, Daniel 

Bentler, Michelle

Berliner, Andrew 

Bodiford, Larry 

Bright II, Thomas A 

Bunge, Gail & Ted 

Chipponeri, Laura 

Claunch, Alan 

Coenenberg, A.J.

Cole, Tristan

DeGrazio, John

Delvin, Rick

Doddridge, Diane 

Emmons, Elaine 

Erich, Richard

Filiberti, Edward 

Fiske, Megan

Galiste, Sally

George, Melvin

Gheno, Tony

Giacomini, Jenny

Gorman, Elaine 

Gottschall, Glenn

Grasse, Dr. Lauri 

Guillot, Leslie

Harris, Arielle

Hill, Arthur

Jenkins, Dave

Kelly, Leanne

Kelso, Bob 

Kendall, John

Klemm, Roger

Koenig R TR, 

Franklin

Kozarsky, Daniel 

Martin, Michael

McCarthy, Guy 

McGinnis, Patrick

Mendenhall, Miles

Micheau, Jill

Moore, Matthew 

Nethercott, Matthew

Nickell, Bill

Oakdale, Heidi

Olds, Vicki

Perreira, Steve

Pfeiffer, Patrick

Phelan, Jim

Quesnoy Tr, Louette 

Raine, Michelle

Rajewski, Robert 

Reichle, Susan

Rice, Kerry

Rinne, Fred 

Robinson, Susan 

Rumney, Liz 

Rutty, Mike

Sarvis, Patricia

Simpson, Eric 

Sorensen, Sunny 

Stephens, Julia

Stevens, Mark

Szymanski, Ron 

Thomas, Donald 

Tripp, Sue

Voorhees, Jeff

Washburn, Colin 

468
Rim Fire Reforestation (45612)

Draft Environmental Impact Statement Index

Index

Adaptive Management, 12, 14, 19, 20, 21, 22, 150

Air Quality, 39, 51, 52, 57, 60, 62, 63, 64, 65, 66, 

67, 68, 69, 70, 149, 150, 153, 154, 212, 222, 

223, 224, 226, 227, 295, 359, 362, 363, 458

Aquatic Features

Critical Aquatic Refuge, 56, 460

Seeps, 32, 157

Wetlands, 307

Aquatic Habitat, 39, 72, 73, 74, 75, 76, 78, 81, 84, 

86, 87, 88, 89, 91, 93, 95, 97, 98, 99, 102, 103, 

104, 310, 315

Aquatic Species Sensitive

Foothill Yellow-legged Frog, 30, 51, 72, 73, 74, 

75, 79, 80, 81, 82, 84, 85, 91, 92, 95, 97, 99, 

100, 103, 104

Hardhead, 51, 73, 82, 95, 97, 104, 220

Western Pond Turtle, 30, 39, 51, 72, 73, 74, 75, 

81, 82, 85, 92, 93, 94, 95, 97, 99, 100, 103, 

104

Aquatic Species T&E

California red-legged frog, 30, 39, 51, 73, 74, 75, 

76, 77, 86, 87, 88, 89, 90, 95, 96, 97, 98, 99, 

100, 102, 103, 459

Sierra Nevada yellow-legged frog, 30, 51, 72, 73, 

74, 78, 79, 88, 91, 95, 97, 99, 102, 103, 459

Climate Change, 8, 9, 59, 60, 62, 64, 65, 68, 113, 

128, 129, 174, 229, 245, 246, 261, 273, 372, 

414, 422, 442

Counties

Mariposa County, 3, 63, 66, 157, 158, 165, 166, 

168, 169, 170, 171, 172, 173, 174, 177, 178, 

180, 182, 184, 186, 188, 189, 190, 192

Tuolumne County, 3, 15, 16, 18, 39, 63, 66, 155, 

158, 165, 166, 168, 169, 170, 171, 172, 173, 

174, 175, 177, 178, 180, 182, 184, 186, 188, 

189, 190, 192, 216, 224, 372, 459, 461

Cultural Resources, 22, 30, 39, 40, 51, 57, 105, 

106, 107, 108, 109, 110, 111, 212, 213, 215, 

216, 217, 218, 227, 461

Economy, 5, 15, 17, 18, 19, 55, 59, 62, 151, 165, 

166, 167, 168, 169, 170, 171, 172, 174, 175, 

177, 178, 179, 180, 181, 182, 183, 184, 185, 

186, 187, 189, 190, 457

Employment, 165, 166, 168, 169, 171, 172, 173, 

178, 180, 182, 184, 186, 188, 190

Income, 165, 166, 169, 170, 171, 177, 181, 190, 

459

Fire and Fuels

Prescribed Fire, 4, 21, 22, 30, 32, 35, 36, 37, 38, 

42, 44, 46, 50, 63, 66, 68, 69, 70, 85, 86, 91, 

93, 100, 107, 108, 110, 111, 114, 117, 118, 

120, 126, 129, 137, 138, 141, 142, 143, 146, 

150, 154, 166, 167, 184, 189, 193, 196, 200, 

201, 206, 207, 208, 210, 229, 233, 234, 242, 

243, 244, 254, 258, 262, 264, 265, 266, 268, 

276, 281, 282, 283, 287, 295, 297, 314, 317, 

329, 331, 333, 335, 337, 359, 360, 375, 379, 

388, 391, 397, 399, 406, 416, 419, 422, 423, 

426, 427, 432, 434, 435, 436, 450, 451, 452, 

453, 454, 455, 458

Forest Plan, 4, 7, 8, 9, 15, 17, 23, 32, 42, 44, 45, 

46, 47, 48, 49, 55, 56, 62, 63, 72, 105, 113, 116, 

117, 120, 123, 131, 133, 145, 147, 155, 165, 

191, 203, 211, 212, 213, 216, 229, 230, 289, 

294, 299, 323, 328, 340, 364, 365, 369, 374, 

387, 389, 396, 405, 416, 426, 447, 460

Herbicide (Manual), 7, 12, 18, 21, 24, 30, 31, 32, 

33, 39, 49, 50, 51, 73, 86, 87, 88, 89, 90, 91, 92, 

93, 98, 99, 100, 102, 103, 107, 110, 117, 120, 

125, 127, 128, 129, 130, 135, 136, 137, 138, 

149, 150, 152, 153, 167, 182, 189, 192, 193, 

194, 198, 200, 201, 202, 203, 204,205, 206, 207, 

208, 209, 210, 218, 222, 225, 230, 240, 241, 

242, 243, 253, 257, 258, 260, 268, 278, 280, 

283, 285, 286, 317, 318, 319, 321, 322, 323, 

336, 338, 342, 343, 344, 345, 346, 347, 348, 

359, 360, 361, 363, 365, 366, 367, 368, 369,

372, 374, 376, 377, 380, 381, 382, 386, 387, 

388, 389, 390, 391, 392, 394, 396, 397, 398, 

400, 401, 402, 404, 405, 406, 407, 408, 409, 

410, 414, 416, 417, 418, 419, 420, 421, 425, 

426, 427, 428, 429, 430, 432, 433, 434, 435, 

436, 437, 438, 444, 445, 446, 447, 450, 451, 

452, 453, 454, 455

Issues, 16, 17, 18, 32, 35, 37

Large Woody Debris, 82, 83, 86, 87, 88, 89, 90, 93, 

98, 103, 199, 200, 316, 330, 373, 403, 404, 422

Limited Operating Period, 39, 43, 102, 103, 359, 

363, 364, 426, 448

Manual Release, 22, 30, 33, 49, 73, 88, 110, 126, 

129, 139, 162, 167, 182, 183, 184, 189, 196, 

197, 205, 206, 207, 210, 218, 231, 240, 242, 

277, 278, 279, 280, 286, 297, 298

Noxious Weed, 1, 4, 10, 12, 14, 19, 20, 21, 24, 26, 

30, 31, 32, 33, 35, 37, 40, 48, 52, 57, 61, 85, 88, 

89, 90, 92, 94, 98, 99, 100, 106, 107, 109, 110, 

118, 120, 123, 124, 125, 126, 127, 128, 129, 

130, 131, 133, 134, 135, 136, 138, 139, 140, 

141, 142, 143, 149, 152, 153, 156, 160, 161, 

162, 164, 166, 167, 175, 178, 180, 193, 195, 

198, 201, 202, 206, 207, 208, 212, 216, 225, 

258, 269, 278, 285, 294, 314, 317, 318, 319, 

321, 322, 328, 331, 333, 334, 342, 343, 347, 

351, 352, 353, 358, 366, 377, 389, 391, 394, 

398, 404, 407, 414, 417, 425, 428, 435, 445, 

452, 453, 454, 457, 461

Private Land, 2, 7, 8, 20, 68, 95, 96, 97, 99, 100, 

137, 182, 248, 251, 267, 268, 269, 271, 276, 

277, 284, 289, 290, 296, 326, 361, 362, 366, 

367, 368, 377, 378, 380, 389, 390, 392, 398, 

399, 400, 406, 407, 408, 417, 418, 419, 427, 

428, 429, 435, 436, 441, 445, 446, 453, 454

Regulations

California Water Code, 299, 458

Clean Air Act, 14, 63, 65, 66, 212, 458

Clean Water Act, 14, 299, 310, 458

469
Stanislaus

Index National Forest

Endangered Species Act, 14, 71, 339, 358, 384, 

410, 411, 423, 438, 439, 458, 459

Environmental Justice, 165, 169, 170, 171, 190, 

459

National Historic Preservation Act, 14, 105, 109, 

217, 218, 458, 461

NEPA, 1, 5, 7, 14, 17, 24, 47, 55, 56, 57, 61, 62, 

341, 457, 460

NFMA, 191, 229, 460

Riparian

Meadow, 4, 5, 23, 26, 29, 38, 39, 45, 49, 58, 79, 

80, 81, 82, 84, 92, 93, 94, 116, 119, 135, 137, 

138, 142, 156, 157, 161, 201, 204, 206, 219, 

225, 251, 252, 267, 268, 270, 293, 307, 314, 

323, 353, 375, 385, 386, 388, 389, 390, 391, 

403, 404, 407, 412, 413, 424,425, 432, 434, 

435, 449, 452, 459

Riparian Conservation Areas, 42, 44, 45, 56, 

307, 308, 315, 325, 338, 460

Riparian Conservation Objectives, 32, 44, 45, 46

Riparian Vegetation, 7, 11, 22, 32, 37, 45, 46, 

53, 76, 84, 86, 87, 89, 91, 95, 96, 97, 235, 

300, 314, 315, 318, 328, 329, 337, 461

Roadless Area, 12, 60

Sensitive Plants, 5, 11, 21, 22, 26, 36, 38, 41, 52, 

57, 127, 132, 155, 156, 157, 158, 159, 160, 161, 

162, 163, 164, 342, 373, 374, 436

Site Preparation, 7, 10, 12, 20, 21, 22, 24, 25, 26, 

32, 33, 35, 37, 42, 47, 49, 50, 53, 61, 66, 85, 88, 

107, 108, 109, 110, 111, 116, 117, 118, 120, 

123, 125, 128, 129, 131, 134, 136, 138, 139, 

141, 143, 149, 150, 152, 159, 166, 167, 178, 

192, 193, 194, 196, 197, 198, 199, 200, 201, 

202, 203, 204, 205, 206, 207, 208, 216, 230, 

235, 240, 256, 257, 260, 261, 280, 295, 311, 

312, 313, 318, 329, 331, 333, 334, 337, 340, 

342, 365, 372, 373, 386, 394, 404, 414, 425, 

432, 433, 436, 450, 457

Deep Till with Forest Cultivation, 21, 25, 31, 32, 

33, 34, 35, 37, 38, 39, 41, 42, 46, 50, 85, 88, 

100, 106, 108, 110, 111, 126, 127, 150, 152, 

167, 175, 192, 198, 201, 212, 218, 240, 241, 

253, 256, 257, 258, 277, 278, 279, 280, 295, 

296, 297, 311, 313, 332, 333, 334, 337, 342, 

433

Feller Bunch, 21, 22, 24, 25, 33, 41, 42, 44, 108, 

111, 169, 175, 197, 199, 201, 225, 295, 312, 

334, 405

Hand Cut, 21, 22, 24, 25, 33, 106, 161, 167, 175, 

212, 231, 256, 335

Hand Pile, 21, 22, 24, 25, 33, 50, 161

Jackpot Burn, 21, 25, 33, 47, 50, 64, 66, 67, 68, 

70, 150, 161, 167, 295, 313

Machine Pile, 21, 24, 25, 33, 42, 46, 51, 64, 88, 

106, 108, 111, 161, 192, 196, 197, 198, 199, 

201, 203, 204, 207, 212, 313, 332, 336, 337, 

359

Masticate, 21, 22, 25, 33, 41, 46, 50, 91, 93, 

106, 108, 111, 139, 159, 167, 197, 199, 201, 

212, 264, 268, 295, 297, 305, 311, 312, 313, 

330, 332, 334, 361, 427

Special Interest Area, 56, 211, 212, 213, 214, 215, 

216, 217, 218, 227, 460

Strategic Fire Management Area, 4, 9, 26, 27, 34, 

36, 37, 38, 40, 43, 51, 118, 120, 121, 340

Strategic Fire Management Feature, 4, 34, 40, 51, 

52

Visual Resources, 152, 154, 289, 290, 293, 295, 

297

Watershed

Best Management Practices, 12, 44, 45, 47, 191, 

299, 300, 301, 312, 315, 317, 433, 458

Cumulative Watershed Effects, 44, 47, 57, 75, 

95, 99, 214, 299, 300, 301, 311, 323

Wild and Scenic Rivers

Clavey River, 219, 224

South Fork Tuolumne River, 219, 221

Tuolumne River, 60, 148, 211, 213, 219, 220, 

221, 222, 223

Wilderness

Emigrant Wilderness, 60, 66, 148, 213, 224, 225

Yosemite Wilderness, 213, 225

Wildlife

Black-backed woodpecker, 43, 53, 340, 341, 

344, 346, 347, 349, 350, 352, 438, 439, 440, 

441, 442, 443, 444, 445, 446, 447, 448

Mule Deer, 9, 10, 11, 12, 14, 19, 20, 22, 24, 30, 

32, 33, 35, 37, 50, 53, 80, 81, 84, 92, 94, 107, 

109, 110, 116, 118, 119, 120, 133, 134, 141, 

143, 152, 157, 167, 175, 193, 196, 200, 203, 

205, 206, 207, 216, 222, 225, 234, 235, 248, 

254, 263, 266, 293, 294, 306, 328, 340, 344, 

345, 348, 349, 353, 373, 403, 413, 448, 449, 

450, 451, 452, 453, 454, 455

PACs, 43, 56, 375, 376, 378, 379, 381, 383, 386, 

396, 397, 399, 400, 460

Wildlife Sensitive

Bald Eagle, 43, 53, 340, 344, 346, 350, 352, 

364, 365, 366, 367, 368, 369, 443

California Spotted Owl, 5, 9, 43, 53, 340, 344, 

369, 371, 372, 374, 376, 377, 378, 381, 382, 

383

Fisher, 5, 9, 53, 220, 340, 343, 344, 345, 348, 

410, 411, 412, 413, 414, 415, 416, 417, 418, 

419, 420, 421, 422, 426

Fringed Myotis, 53, 340, 344, 346, 349, 423, 

424, 425, 426, 427, 428, 429, 430

Great Gray Owl, 43, 53, 161, 340, 344, 346, 350, 

353, 384, 385, 386, 387, 388, 389, 390, 391, 

392, 415, 426, 428, 429, 443

Northern Goshawk, 5, 9, 43, 53, 340, 380, 392, 

393, 394, 395, 396, 398, 399, 400, 401, 402

Pacific Marten, 53, 340, 344, 345, 348, 402, 403, 

404, 405, 406, 407, 408, 409, 410, 411, 413

Pallid Bat, 53, 340, 344, 346, 349, 423, 424, 425, 

426, 427, 429, 430

Western Bumble Bee, 53, 340, 347, 430, 431, 

432, 433, 434, 435, 436, 437, 438

Wildlife T&E

Valley Elderberry Longhorn Beetle, 43, 53, 340, 

344, 358, 359, 360, 361, 362, 363, 458, 459

470
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504
Rim Fire Reforestation (45612) Appendix A

Draft Environmental Impact Statement Abbreviations and Acronyms

A. Abbreviations and Acronyms

ACHP Advisory Council on Historic Preservation

AMS Aquatic Management Strategy

APCD Air Pollution Control District

APE Area of Potential Effects

BA Biological Assessment

BACM Best Available Control Measure

BAER Burned Area Emergency Response

BE Biological Evaluation

BF Board Feet

BLM Bureau of Land Management

BMI Benthic Macro Invertebrate

BMP Best Management Practice

BTU British Thermal Unit

CAA Clean Air Act

CAAQS California Ambient Air Quality Standards

CAR Critical Aquatic Refuge

CARB California Air Resources Board

CDFW California Department of Fish and Wildlife

CEQ Council on Environmental Quality

CFR Code of Federal Regulations

CSO California Spotted Owl

CNDDB California Natural Diversity Database

CRPR California Rare Plant Rank

CWD Coarse Woody Debris

CWE Cumulative Watershed Effect

CWHR California Wildlife Habitat Relationships

DBH Diameter at Breast Height

DEIS Draft Environmental Impact Statement

DEM Digital Elevation Model

DTFC Deep Till with Forest Cultivation

EA Environmental Assessment

EEC Expected Environmental Concentration

EHR Erosion Hazard Rating

EIS Environmental Impact Statement

EPA Environmental Protection Agency

ERA Equivalent Roaded Acres

ESA Endangered Species Act of 1973

FB Feller Buncher

FS Forest Service

FFE Fire and Fuels Extension

FOFEM First Order Fire Effects Model

505
Appendix A Stanislaus

Abbreviations and Acronyms National Forest

FSH Forest Service Handbook

FSM Forest Service Manual

FSS Forest Service Sensitive

FYLF Foothill Yellow-Legged Frog

GIS Geographic Information System

GRUB Hand Removal

GTR General Technical Report

HC Hand Cut

HCRA Home Range Core Area

HERB Manual Herbicide Application

HFC Hydrologic Function Class

HP Hand Pile

HQ Hazard Quotient

HR Heritage Resources

HSA Hydrologically Sensitive Area

HT Hazard Trees

HUC Hydrologic Unit Code

ID Interdisciplinary

IDT Interdisciplinary Team

ICO Individuals, Clumps and Openings

INFRA Infrastructure Database

IPM Integrated Pest Management

IRA Inventoried Roadless Area

JP Jackpot Burning

LOP Limited Operating Period

MA Masticate

MBF Thousand Board Feet

MCL Maximum Contaminant Level

MMBF Million Board Feet

MBTA Migratory Bird Treaty Act

MIS Management Indicator Species

ML Maintenance Level

MOI Memorandum of Intent

MOU Memorandum of Understanding

MP Machine Pile

MYLF Mountain Yellow-Legged Frog

NAAQS National Ambient Air Quality Standards

NAT Natural Regeneration

NEPA National Environmental Policy Act

NF National Forest

NFMA National Forest Management Act

NFS National Forest System

NFSR National Forest System Road

NFST National Forest System Trail

NHPA National Historic Preservation Act

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Rim Fire Reforestation (45612) Appendix A

Draft Environmental Impact Statement Abbreviations and Acronyms

NNIS Non-native Invasive Species

NOAEL No Observable Adverse Effect Level

NOEC No Observable Effect Concentration

NOI Notice of Intent

NRCS Natural Resources Conservation Service

NRHP National Register of Historic Places

NRIS Natural Resource Information System

NVUM National Visitor Use Monitoring

OFEA Old Forest Emphasis Area

OHV Off-Highway Vehicle

PA Programmatic Agreement

PAC Protected Activity Center

PCE Primary Constituent Element

PCT Pre-Commercial Thin

PF Prescribed Fire

PM Particulate Matter

PNB Present Net Benefit

PNC Present Net Cost

PNV Present Net Value

PPF Post-planting Prescribed Fire

PSW Pacific Southwest Research Station

R5 Forest Service Region 5

RAVG Rapid Assessment of Vegetation Condition after Wildfire

RCA Riparian Conservation Area

RCO Riparian Conservation Objective

RD Ranger District

RNA Research Natural Area

ROD Record of Decision

ROS Recreation Opportunity Spectrum

SAF Special Aquatic Feature

SDI Stand Density Index

SDV Soil Data Viewer

SFMA Strategic Fire Management Area

SFMF Strategic Fire Management Feature

SHPO State Historic Preservation Officer

SIA Special Interest Area

S&G Standard and Guideline

SMP Smoke Management Program

SMS Scenery Management System

SNFPA Sierra Nevada Forest Plan Amendment

SNYLF Sierra Nevada Yellow-Legged Frog

SOM Soil Organic Matter

SOPA Schedule of Proposed Actions

SPM Semi-Primitive Motorized

SPNM Semi-Primitive Non-Motorized

507
Appendix A Stanislaus

Abbreviations and Acronyms National Forest

SSI StreamScape Inventory

STF Stanislaus National Forest

SUP Special Use Permit

TE Threatened and Endangered

TES Threatened, Endangered and Sensitive

TOC Threshold of Concern

TPA Trees Per Acre

USDA United States Department of Agriculture

USDI United States Department of Interior

USFS United States Forest Service

USFWS United States Fish and Wildlife Service

VELB Valley Elderberry Longhorn Beetle

VMS Visual Management System

VQO Visual Quality Objective

WSA Watershed Sensitive Area

508
Rim Fire Reforestation (45612) Appendix B

Draft Environmental Impact Statement Cumulative Effects Analysis

B. Cumulative Effects Analysis

According to the CEQ NEPA regulations, “cumulative impact” is the impact on the environment 

which results from the incremental impact of the action when added to other past, present and 

reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person 

undertakes such actions (40 CFR 1508.7). The Forest queried its databases, including the Schedule of 

Proposed Actions (SOPA) to determine past, present and reasonably foreseeable future actions as 

well as present and reasonably foreseeable future actions on other public (non-Forest Service) and 

private lands. This appendix lists the specific findings and information used for the cumulative effects 

analysis presented for each resource in Chapter 3.

Past Actions

In order to understand the contribution of past actions to the cumulative effects of the proposed action 

and alternatives, this analysis relies on current environmental conditions as a proxy for the impacts of 

past actions. Existing conditions reflect the aggregate impact of all prior human actions and natural 

events that affected the environment and might contribute to cumulative effects. This cumulative 

effects analysis does not attempt to quantify the effects of past human actions by adding up all prior 

actions on an action-by-action basis for three reasons.

First, a catalog and analysis of all past actions would be impractical to compile and unduly costly to 

obtain. Innumerable actions over the last century (and beyond) impacted current conditions and trying 

to isolate the individual actions with residual impacts would be nearly impossible. 

Second, providing the details of past actions on an individual basis would not be useful to predict the 

cumulative effects of the proposed action or alternatives. In fact, focusing on individual actions would 

be less accurate than looking at existing conditions, because information on the environmental 

impacts of individual past actions is limited, and one cannot reasonably identify each and every action 

over the last century that contributed to current conditions. Additionally, focusing on the impacts of 

past human actions ignores the important residual effects of past natural events which may contribute 

to cumulative effects just as much as human actions. By looking at current conditions, we are sure to 

capture all the residual effects of past human actions and natural events, regardless of which 

particular action or event contributed those effects. 

Finally, the CEQ issued an interpretive memorandum on June 24, 2005 regarding analysis of past 

actions, which states, “agencies can conduct an adequate cumulative effects analysis by focusing on 

the current aggregate effects of past actions without delving into the historical details of individual 

past actions” (CEQ 2005).

The cumulative effects analysis in this EIS is also consistent with the Forest Service’s NEPA 

Regulations on cumulative effects analysis (36 C.F.R. § 220.4(f) (“Cumulative effects considerations 

of past actions”), which state:

Cumulative effects analysis shall be carried out in accordance with 40 CFR 1508.7 and in accordance 

with “The Council on Environmental Quality Guidance Memorandum on Consideration of Past 

Actions in Cumulative Effects Analysis” dated June 24, 2005. The analysis of cumulative effects 

begins with consideration of the direct and indirect effects on the environment that are expected or 

likely to result from the alternative proposals for agency action. Agencies then look for present effects 

of past actions that are, in the judgment of the agency, relevant and useful because they have a 

significant cause-and-effect relationship with the direct and indirect effects of the proposal for agency 

action and its alternatives. CEQ regulations do not require the consideration of the individual effects of 

all past actions to determine the present effects of past actions. Once the agency has identified those 

present effects of past actions that warrant consideration, the agency assesses the extent that the effects 

509
Appendix B Stanislaus

Cumulative Effects Analysis National Forest

of the proposal for agency action or its alternatives will add to, modify, or mitigate those effects. The 

final analysis documents an agency assessment of the cumulative effects of the actions considered 

(including past, present, and reasonably foreseeable future actions) on the affected environment. With 

respect to past actions, during the scoping process and subsequent preparation of the analysis, the 

agency must determine what information regarding past actions is useful and relevant to the required 

analysis of cumulative effects. Cataloging past actions and specific information about the direct and 

indirect effects of their design and implementation could in some contexts be useful to predict the 

cumulative effects of the proposal. The CEQ regulations, however, do not require agencies to 

catalogue or exhaustively list and analyze all individual past actions. Simply because information 

about past actions may be available or obtained with reasonable effort does not mean that it is relevant 

and necessary to inform decision making. (40 CFR 1508.7). 

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

conditions described in Chapters 1 and 2. 

Present Actions

For the purposes of cumulative effects analysis, present actions include: ongoing activities; Forest 

Service and other Federal land disturbance actions with completed NEPA decisions that are not yet 

fully implemented on the ground; and private land activities.

Ongoing Activities

Ongoing activities on NFS lands within the Rim Fire perimeter include:

Livestock Grazing: 14 grazing allotments are either wholly or partially within the cumulative 

analysis area as defined previously, covering about 152,560 acres. The maximum number of cattle 

run across all the allotments is about 1,632 cow/calf pairs in any given season. Grazing is subject to 

utilization standards in the SNFPA (2004) that protect resources such as meadow habitat.

Recreation: recreation is abundant in the area and consists of activities including, but not limited to, 

Off Highway Vehicle (OHV) use, passenger car driving, wood cutting, camping (dispersed and 

developed), hiking, cycling (mountain and road), fishing, backpacking, horseback riding, and winter 

sports. These recreation activities provide increased human access to the forest.

Forest Service

Table B.01-1 displays present NFS land disturbance actions, followed by a brief description of each. 

Table B.01-1 Present National Forest System land disturbance actions

Project Name Activity Acres Miles Decision 

(year)

Funky Stewardship Green Thinning 1,073 2012

Groovy Stewardship Green Thinning 1,319 2012

MiWok OHV Restoration Block and Restore 11.8 2012

Rim Fire Habitat Improvement Botany Restoration Areas 2,575 2015

Rim Fire Habitat Improvement Encroaching Conifers 397 2015

Rim Fire Habitat Improvement Hand treat Weeds, not roadside 298 2015

Rim Fire Habitat Improvement Meadows Handwork 30 2015

Rim Hazard Tree EA Tractor Piling 10,315 2014

Rim Recovery Fuels treatments 26,892 2014

Twomile Ecological Restoration Soil Improvement 23.5 2012

Funky Timber Sale: thinning to increase structural diversity, improve wildlife habitat, and 

encourage pine and hardwoods. Treatments proposed on 1,073 acres include thinning (mechanical 

and hand) and biomass removal. These acres dropped slightly from the original proposal, 

510
Rim Fire Reforestation (45612) Appendix B

Draft Environmental Impact Statement Cumulative Effects Analysis

Groovy Timber Sale: thinning to increase structural diversity, improve wildlife habitat, and 

encourage pine and hardwoods. Treatments proposed on 1,319 acres include thinning (mechanical 

and hand) and biomass removal. These acres have dropped by almost half due to the fire. The high 

severity burn units are analyzed as part of this EIS. Timber sale was modified to include salvage 

logging of dead trees burned in the Rim Fire. Roadside hazard tree removal occurred on 106 acres. 

Miwok OHV Restoration: authorize physical road actions and access designation changes to 

minimize resource damage and move the road system toward one that can be efficiently maintained 

while also maintaining access for management and public use. Includes block and restore 11.6 miles 

of unauthorized OHV routes and restore 4 acres of impact areas; install barriers at beginning of 

blocked routes; designate rock barrier source at Bourland and Coffin Quarries. 

Rim Fire Habitat Improvement: Post-fire wildlife, watershed, sensitive plants and special aquatic 

features habitat improvement with hand-only treatments including: pulling noxious weeds; fencing 

meadows and other sensitive areas; and, creating nest structures for great gray owls.

Rim Fire Hazard Tree EA: complete tractor piling and burning and other fuels work within and 

adjacent to facilities including 194 miles of high-use roads; private property; developed sites; 

recreation use areas; and powerlines.

Rim Fire Recovery: in areas burned in the Rim Fire, fuels treatments include biomass removal, 

mastication, drop and lop, machine piling and burning and/or jackpot burning on 26,892 acres. 

Twomile Ecological Restoration Soil Improvement: push apart windrowed materials to restore soil 

productivity on 23 acres of volcanic soils in a ponderosa pine plantation established after the 1950 

Wrights Creek Burn.

Private Land

The present land disturbance actions on private lands that are on file with California Department of 

Forestry and Fire Protection (Cal Fire) includes herbicide use on 9,719 acres. 

Reasonably Foreseeable Future Actions

The Forest Service NEPA regulations define reasonably foreseeable future actions as: “Those Federal 

or non-Federal activities not yet undertaken, for which there are existing decisions, funding, or 

identified proposals.” 36 C.F.R. § 220.3. The regulations go on to describe an “identified proposal” 

as a situation in which “[t]he Forest Service has a goal and is actively preparing to make a decision on 

one or more alternative means of accomplishing that goal and the effects can be meaningfully 

evaluated (see 40 CFR 1508.23).” 36 C.F.R. § 220.4(a)(1). In practice, an action becomes reasonably 

foreseeable and subject to meaningful evaluation when the agency has written a proposal and has 

circulated that proposal for public scoping. See 40 C.F.R. §1501.7. 

For the purposes of cumulative effects analysis, the following are the reasonably foreseeable future 

actions within the Project’s cumulative effects analysis area.

Table B.01-2 lists the reasonably foreseeable National Forest System land disturbance actions.

511
Appendix B Stanislaus

Cumulative Effects Analysis National Forest

Table B.01-2 Reasonably foreseeable National Forest System land disturbance actions

Project Name Activity Acres Miles Quantity Decision 

(year)

Reynolds Creek Ecological Restoration Aspen release 2 0 0 2012

Reynolds Creek Ecological Restoration Meadow restoration 15 0 0 2012

Reynolds Creek Fuels Prescribed burn 2,323 0 0 2012

Rim Fire Rehabilitation Aspen 32 0 0 2015

Rim Fire Rehabilitation Campground planting 0 0 2 2015

Rim Fire Rehabilitation Fence repair 0 18.4 0 2015

Rim Fire Rehabilitation Great Grey Owl 718 0 0 2015

Rim Fire Rehabilitation Hand pull roadside weeds 2.4 0 0 2015

Rim Fire Rehabilitation Hand Treat Weeds 2 0 0 2015

Rim Fire Rehabilitation Herbicide Weeds .5 0 0 2015

Rim Fire Rehabilitation Knapweed herbicide .5 0 0 2015

Rim Fire Rehabilitation Meadows 155 0 0 2015

Rim Fire Rehabilitation Troughs, Guzzlers, Water Tank 0 0 35 2015

Twomile Ecological Restoration Noxious Weeds 8 0 0 Pending

Twomile Meadow Restoration Restore disturbance areas 11 0 0 2012

Subtotal Ecological Restoration 3,269.4 18.4 37

City of Berkeley Tuolumne Camp Permit Reconstruct, occupy and 

maintain

12 0 0 Pending

Lower Cherry Aqueduct Install bat gates 0 0 3 2015

Lower Cherry Aqueduct Pipelines, Tunnels, and Canals 0 3.7 0 2015

Reliable Power Chemical 23 0 0 Pending

Reliable Power Manual 63 0 0 Pending

Reliable Power Shred 48 0 0 Pending

San Jose Camp Permit EA Improvements to camp 

structures

51 0 0 Pending

Subtotal Recreation 197 3.7 3

Reynolds Creek Stewardship Green thinning 952 0 0 2012

Soldier Creek Timber Sale Green Thinning 250 0 0 2008

Twomile Ecological Restoration Vegetation: Campy 

Timber Sale

Green Thinning 995 0 0 2012

Twomile Ecological Restoration Vegetation: Looney 

Timber Sale

Green Thinning 1,445 0 0 2012

Twomile Ecological Restoration Vegetation: Thommy 

Timber Sale

Green Thinning 514 0 0 2012

Subtotal Timber Harvesting 4,156 0 0

Ferretti Non-Motorized Trail System Add non-motorized trails 18.5

Ferretti OHV Restoration Block and restore routes

Reynolds Creek Ecological Restoration Trail Reroute buffer zone-Route 

2

12 0 0 2013

Reynolds Creek Motorized Routes EA Decommission unauthorized 

routes

0 3.5 0 2013

Rim Fire Rehabilitation Decommission and block routes 0 3.0 0 2015

Twomile Ecological Restoration Motorized Trails 0 24.5 0 2012

Twomile Ecological Restoration Transportation 0 29.2 0 pending

Subtotal Transportation Restoration 12 88.7 0

Totals 7,634.4 110.8 40

Ecological Restoration

Reynolds Creek Ecological Restoration Aspen Release: aspen stand improvement/expansion 

involving the removal of encroaching conifers. Treatments proposed in 2 stands for 2 acres include 

thinning (mechanical and hand), biomass removal, removal of encroaching conifers, repairing gullies 

and stabilizing streambeds. 

Reynolds Creek Ecological Restoration Meadow Restoration: meadow treatments including 

headcut repair, fencing, removal of encroaching conifers, and planting of riparian vegetation. 

512
Rim Fire Reforestation (45612) Appendix B

Draft Environmental Impact Statement Cumulative Effects Analysis

Treatments proposed in 8 meadows for 14 acres include thinning (mechanical and hand), biomass 

removal, removal of encroaching conifers, repairing gullies and stabilizing streambeds. 

Reynolds Creek Fuels: prescribed burning within and adjacent to Reynolds Creek Stewardship 

thinning units (2,323 acres). 

Rim Fire Rehabilitation: Post-fire wildlife, watershed and range rehabilitation with heavy 

equipment treatments including: aspen released, campground planting, fence repair, great Grey Owl 

habitat improvement, hand pull roadside weeds, hand treat weeds, herbicide weeds, meadow 

restoration; and, installing water troughs and wildlife guzzlers. 

Twomile Ecological Restoration Noxious Weeds: control of 2 noxious weeds: the only known 

population of Dyers Woad on the Stanislaus National Forest and perennial sweetpea, on 8 acres near 

Reed Creek. The herbicide glyphosate is proposed for treatment since 12 years of hand pulling has 

not eradicated the weeds. 

Twomile Meadow Restoration: improve meadow function in five meadows and associated streams 

by raising water tables nearer to natural levels. Treatments include stabilizing banks and headcuts, 

revegetation with native species and subsoiling compacted areas.

Recreation and Special Use Permits

City of Berkeley Tuolumne Camp Permit: Issue a Special Use Permit (SUP) for reconstruction, 

occupancy, use and maintenance of the City of Berkeley Tuolumne Camp which was completely 

destroyed by the 2013 Rim Fire. 

Lower Cherry Aqueduct Emergency Rehabilitation: Improve Hetch Hetchy Water and Power's 

existing Lower Cherry Aqueduct for reliable water conveyance to augment San Francisco Bay Area 

supply during droughts. Includes corrections to right-of-ways to match as-built location. The Forest 

would issue special use authorizations for use of National Forest Lands as required for the 

rehabilitation work along 3.6 miles of the Lower Cherry Aqueduct operated by Hetch Hetchy Water 

and Power, a division of the San Francisco Public Utilities Commission. This includes the use of and 

work along National Forest System roads, particularly Cherry Lake Road (1N07) which is accessed 

via State Highway 120. 

Reliable Power Project EA: Special Use Management. Vegetation management, along power 

transmission lines operated by Hetch Hetchy Water and Power, to meet North American Electric 

Reliability Corporation (NERC) standards and improve the reliability of the power transmission 

system. Transmission lines from Early Intake and Holm Power Plants to Moccasin.

San Jose Camp Permit EA: Master Development Plan including improvements to camp structures 

and utilities. Modify existing permit or issue new permit incorporating the new plan for continued 

operation and maintenance. 

Timber Harvesting

Reynolds Creek Stewardship: thinning to increase structural diversity, improve wildlife habitat, 

and encourage pine and hardwoods. Treatments proposed on 952 acres include thinning (mechanical 

and hand) and biomass removal. 

Soldier Creek Timber Sale: thinning to increase structural diversity, improve wildlife habitat, and 

encourage pine and hardwoods. Treatments proposed on 250 acres include thinning (mechanical and 

hand) and biomass removal. 

Twomile Ecological Restoration Campy Timber Sale: thinning to increase structural diversity,

improve wildlife habitat, and encourage pine and hardwoods. Treatments proposed on 995 acres 

include thinning (mechanical and hand), biomass removal. 

513
Appendix B Stanislaus

Cumulative Effects Analysis National Forest

Twomile Ecological Restoration Looney Timber Sale: thinning to increase structural diversity, 

improve wildlife habitat, and encourage pine and hardwoods. Treatments proposed on 1,445 acres 

include thinning (mechanical and hand), biomass removal. 

Twomile Ecological Restoration Thommy Timber Sale: thinning to increase structural diversity, 

improve wildlife habitat, and encourage pine and hardwoods. Treatments proposed on 514 acres 

include thinning (mechanical and hand), biomass removal. 

Transportation Restoration

Ferretti Non-motorized Trail System: Construct and add to the National Forest Trail System 

(NFTS) approximately 3 1/2 miles of multi-use non-motorized trail (pedestrian, equestrian and 

bicycle) and approximately 15 miles of bicycle only non-motorized trail.

Ferretti OHV Restoration: Block and restore unauthorized routes and impact areas, construct 

reroutes and new trails, and install barriers. Areas include along Ferretti Road and Forest Routes 

1S21Y, 1S23, 1S33, 1S53Y, 1S81Y, 17EV402 and 17EV406. Reroute Forest Trail 17EV404. 

Reynolds Creek Ecological Restoration Culvert and Road Work: replace and maintain 3 culverts 

to improve aquatic passage and hydrologic function. Decommission, close, reconstruct, trail reroute 

and complete watershed rehabilitation. 

Reynolds Creek Motorized Routes: decommissioning of 3.5 miles of unauthorized motorized routes 

in the Reynolds Creek area.

Rim Fire Rehabilitation: Post-fire road rehabilitation with heavy equipment treatments including: 

culvert replacement, decommission and block routes, and road maintenance (3.0 miles). 

Twomile Ecological Restoration Motorized Trails: improve motorized trail system in the Twomile 

area to improve public safety and minimize resource damage. Treatments include closure and 

restoration actions on 72 segments of unauthorized routes, reconstruct and/or reroute 5 existing 

segments, and construction of 3 new segments (24.5 miles). 

Twomile Ecological Restoration Transportation: authorize physical road actions and access 

designation changes to minimize resource damage and move the road system toward one that can be 

efficiently maintained while also maintaining access for management and public use. Physical actions 

are those actions on the ground that involve moving earth and vegetation, and change the physical 

condition and drivability of the route. The proposed physical actions are oriented toward improving 

drivability and access and “storm-proofing” routes to minimize future erosion. Physical actions would 

occur on a total of 61 segments including: installation of 4 gates, close (ML1) 11 segments, 

decommission 14 segments, maintain 23 segments, construct one new segment, and reconstruct 9 

segments (29.2 miles). 

Private Land

Reasonably foreseeable land disturbance actions on private lands that are on file with California 

Department of Forestry and Fire Protection (Cal Fire) within the Rim Fire perimeter include permits 

for herbicide use covering 5,760 acres. 

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Rim Fire Reforestation (45612) Appendix C

Draft Environmental Impact Statement Glossary

C. Glossary

90th Percentile 

Weather Conditions 

High air temperature, low relative humidity, strong wind conditions and low fuel 

moisture content levels that historically that are met or exceeded on 10 percent of 

days during the fire season. It defines potential fire behavior as a result of these 

conditions: a 90th percentile weather day has the potential for severe wildfire

behavior.

Activity Generated 

Fuel

Fuel resulting from, or altered by, management practices such as timber 

harvesting, thinning, or road construction.

Adaptive Capacity The ability of ecosystems to respond, cope or adapt to disturbances and stressors, 

including environmental change, to maintain options for future generations. As 

applied to ecological systems, adaptive capacity is determined by genetic diversity 

of species, biodiversity within a particular ecosystem, and heterogeneous 

ecosystem mosaics as applied to specific landscapes or biome regions.

Adaptive Management A system of management practices based on clearly identified intended outcomes 

and monitoring to determine if management actions are meeting those outcomes; 

and, if not, to facilitate management changes that will best ensure that those 

outcomes are met or re-evaluated. Adaptive management stems from the 

recognition that knowledge about natural resource systems is sometimes 

uncertain (36 CFR 220.3).

Administrative Unit A National Forest, a National Grassland, a purchase unit, a land utilization project, 

Columbia River Gorge National Scenic Area, Land Between the Lakes, Lake 

Tahoe Basin Management Unit, Midewin National Tallgrass Prairie, or other 

comparable unit of the National Forest System.

Affected Environment The physical, biological, social and economic environment within which human 

activity is proposed.

Alluvial Pertaining to processes or materials associated with transportation or deposition 

by running water.

Alternative One of several policies, plans or projects proposed for decision making.

Aquatic Growing or living in or frequenting water; taking place in or on water.

Aquatic Ecosystem A stream channel, lake or estuary bed, the water itself, and the biotic (living) 

communities that occur therein.

ARC/INFO The name of a Geographic Information System software program.

Area of Potential 

Effects (APE)

This is the geographic area or areas within which an undertaking may directly or 

indirectly cause alterations in the character or use of historic properties, if any 

such properties exist. The area of potential effects is influenced by the scale and 

nature of an undertaking and may be different for different kinds of effects caused 

by the undertaking.

Aspect The direction a slope faces. For example, a hillside facing east has an eastern 

aspect.

Basal Area The total cross-sectional area of all stems, including the bark, in a given area, 

measured at breast height (4.5 feet above the ground). Usually given in units of 

square feet per acre.

Beneficial Uses of 

Water

Uses of water that are protected against degradation as described in the Basin 

Plan of the California Central Valley Regional Water Quality Control Board. These 

uses include municipal, agriculture, industry, recreation and aquatic and wildlife 

habitat categories.

Best Management 

Practices (BMPs)

Water Quality Best Management Practices, a codified series of about 100 

practices for protecting water quality when conducting forest management 

activities. BMPs are referenced in R5 FSH 2509.22, Soil and Water Conservation 

Handbook; Chapter 10, Water Quality Management Handbook.

515
Appendix C Stanislaus

Glossary National Forest

Biological Assessment An evaluation of the effects of a proposal on threatened, endangered or proposed 

species in accordance with legal requirements under Section 7 of the Endangered 

Species Act. An evaluation of the effects of a proposal on threatened, 

endangered, and proposed species for non-construction activities.

Biological Diversity 

(Biodiversity)

The number and abundance of species found within a common environment. This 

includes the variety of genes, species, ecosystems, and the ecological processes 

that connect everything in a common environment.

Biological Evaluation A documented Forest Service review of Forest Service programs or activities done 

in conjunction with the NEPA process in sufficient detail to determine whether a 

proposed action will result in a trend toward a sensitive species becoming 

Federally listed.

Biomass Trees less than 10 inches dbh not used as sawlogs. This material is usually 

chipped and/or removed from the project area and hauled to a mill to be used for 

cogeneration of energy or as fiber for wood products.

Biota The plant and animal life of a particular region.

Biotic Potential Factors that influence the ability of an animal to utilize its environment, including: 

reproductive rates, dispersal ability, habitat and life requisite specificity, and 

adaptability. Combine, these factors assign biotic potential of the animal.

Blue Oak Woodlands An ecosystem dominated by blue oak, valley oak, interior live oak (tree form), or 

Oregon white oak.

Board Feet A unit of measure of sawlog volume, equivalent to 12 inches by 12 inches by 1 

inch. One thousand board feet is denoted as mbf.

Buffer Used in the context of GIS; a buffer is a zone of a specified distance around a 

feature in a coverage.

Burned Area 

Emergency Response 

(BAER)

BAER is a Forest Service activity of immediate post-wildfire response to assess 

and reduce the risk of loss of human life, property damage, and adverse effects to 

critical natural and cultural resources from threats caused by the fire. 

Burning Prescription Written direction stipulating fire environment conditions, techniques, and 

administrative constraints necessary to achieve specified resource management 

objectives by use of fire on a given area of land.

California Wildlife 

Habitat Relationships 

(CWHR)

A system of classifying vegetation in relation to its function as wildlife habitat. 

Tree-dominated habitat is classified according to tree size and canopy closure.

Canopy The part of any stand of trees represented by the tree crowns. It usually refers to 

the uppermost layer of foliage, but it can be used to describe lower layers in a 

multi-storied forest.

Canopy cover The degree to which the canopy (forest layers above one’s head) blocks sunlight 

or obscures the sky. Same as crown closure.

Capability The potential of land to produce resources, and supply goods and services under 

a set of management practices and at a govern level of management intensity. 

Capability depends upon site conditions such as climate, soils, and geology, as 

well as the application of management practices, such as silviculture.

Capable Forest Land Those portions of the forest that have an inherent ability to support trees for timber 

harvest and produce at least 20 cubic feet per acre per year of wood fiber.

Capable Rangeland Land that can sustain domestic grazing and generally represent the portions of the 

landscape assumed to be most commonly used by cattle

Chief The Chief, Forest Service, Department of Agriculture (36 CFR 212).

Code of Federal 

Regulations (CFR)

A codification of the general and permanent rules published in the Federal 

Register by the Executive departments and agencies of the Federal Government.

Collaboration Managers, scientists and citizens working together to plan, implement and monitor 

National Forest management. The intention is to engage people who have 

information, knowledge, expertise and an interest in the health of National Forest 

ecosystems and nearby communities.

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Rim Fire Reforestation (45612) Appendix C

Draft Environmental Impact Statement Glossary

Competing Vegetation Any plant that reduces availability of water, nutrients, light and physical growing 

space to desired vegetation (e.g., natural or artificial conifer regeneration).

Complex Early Seral Complex early seral forest follows stand-replacing disturbance in a mature forest 

and is characterized by abundant snags and downed logs, natural conifer 

regeneration, and development of a diverse understory community of postdisturbance vegetation and associated wildlife (Della Sala et al. 2014).

Connected Actions Actions that: (i) automatically trigger other actions which may require 

environmental impact statements; (ii) cannot or will not proceed unless other 

actions are taken previously or simultaneously; or, (iii) are interdependent parts of 

a larger action and depend on the larger action for their justification (40 CFR 

1508.25).

Connectivity (of 

Habitats)

The linkage of similar but separated vegetation stands by patches, corridors, or 

“stepping stones” of like vegetation. This term can also refer to the degree to 

which similar habitats are linked.

Coverage A digital map or layer of data in the ARC/INFO software program.

Council on 

Environmental Quality 

(CEQ)

The Council on Environmental Quality established by Title II of NEPA (40 CFR 

1508.6).

Critical Aquatic Refuge 

(CAR)

A relatively small watershed, ranging in size from about 3,000 to 85,000 acres, 

that is sometimes nested within an emphasis watershed and has localized 

populations of rare and/or at-risk populations of native fish and/or amphibians.

Critical Deer Winter 

Range

Critical habitat area where the highest concentrations of a deer are found during 

winter and where habitat condition directly affects the viability of the population.

Critical Habitat Areas designated for the survival and recovery of federally listed threatened or 

endangered species.

Crown closure Refer to canopy cover.

Crown fire A fire that advances through the canopy of trees or shrubs independently of the 

surface fire.

Cryptogamic Soil 

Crusts 

Biological soil crust composed of living cyanobacteria, green algae, brown algae, 

fungi, lichens, and/or mosses. 

Cumulative Impact The impact on the environment which results from the incremental impact of the 

action when added to other past, present, and reasonably foreseeable future 

actions regardless of what agency (Federal or non-Federal) or person undertakes 

such other actions. Cumulative impacts can result from individually minor but 

collectively significant actions taking place over a period of time (40 CFR 1508.7).

Coarse Woody Debris 

(CWD)

Coarse woody debris is 1,000 hour dead fuel, with a minimum diameter (or an 

equivalent cross section) of 3 inches at the widest point and includes sound and 

rotting logs, standing snags, stumps, and large branches (located above the soil).

Cultural Resources An object, site structure or location associated with past human activity or 

important to contemporary ethnic groups or individuals.

Decommission Activities that result in the stabilization and restoration of unneeded roads or trails 

to a more natural state (FSM 7703.2(1)).

Deep Tilling Also known as subsoiling. Mechanical lifting and shattering of the layer of soil 

beneath the topsoil in order to reduce soil density and strength, improve moisture 

infiltration and retention, and increase root penetration in the soil.

Designated Road, 

Trail or Area

A National Forest System road, trail or area that is designated for motor vehicle on 

a motor vehicle use map (36 CFR 212).

Desired Future 

Conditions

Land or resource conditions that are expected to result based on goals and 

objectives.

Diameter at Breast 

Height (DBH)

The diameter of a tree trunk 4.5 feet above the ground.

Digital Elevation Model 

(DEM)

A digital GIS file typically used to represent terrain relief.

517
Appendix C Stanislaus

Glossary National Forest

Disjunct A population of plants or animals which are separated by a large distance from the 

typical distribution of the species.

Draft Environmental 

Impact Statement 

(DEIS)

A detailed written statement as required by section 102(2) (C) of the NEPA (40 

CFR 1508.11) that is released to governmental agencies and the general public 

for review and comment.

Drop and Lop A treatment that involves felling non-merchantable trees less than about 10 inches 

dbh and lopping them into pieces small enough to ensure the material is not 

stacked and has as much ground contact as practical.

Duff The layer of partially and fully decomposed organic material lying below the litter 

and immediately above the mineral soil.

Early Forest 

Succession

The biotic (or life) community that develops immediately following the removal or

destruction of vegetation in an area. For example, grasses may be the first plants 

to grow in an area that was burned.

Ecological Integrity The quality or conditions of an ecosystem when its dominant ecological 

characteristics (for example, composition, structure, function, connectivity and 

species composition and diversity) occur within the natural range of variation and 

can withstand and recover from most perturbations imposed by natural 

environmental dynamics or human influence.

Ecology The interrelationships of living things to one another and to their environment, or 

the study of these interrelationships.

Ecosystem An arrangement of living and non-living things and the forces that move them. 

Living things include plants and animals. Non-living parts of ecosystems may be 

rocks and minerals. Weather and wildfire are two of the forces that act within 

ecosystems.

Endangered Species Those plant or animal species that are in danger of extinction throughout all or a 

significant portion of their range. Endangered species are identified by the 

Secretary of the Interior in accordance with the Endangered Species Act of 1973.

Endemic An organism that evolved in and is restricted to a particular locality. The Little Kern 

golden trout found only in the Sierra Nevada region is an example.

Endlining Moving logs using cables where the log is in full or partial contact with the ground.

Environmental Justice The state (or condition) which all populations are provided the opportunity to 

comment before decisions are rendered on, are allowed to share in the benefits of, 

are not excluded from, and are not affected in a disproportionately high and 

adverse manner by government programs and activities affecting human health or 

the environment.

Environmental Impact 

Statement (EIS)

A detailed written statement as required by section 102(2) (C) of NEPA (CFR 

1508.11).

Environmentally 

Preferable Alternative

The alternative that will best promote the national environmental policy as 

expressed in NEPA section 101 (42 USC 4321). Ordinarily, the environmentally 

preferable alternative is that which causes the least harm to the biological and 

physical environment; it also is the alternative which best protects and preserves 

historic, cultural, and natural resources. In some situations, there may be more 

than one environmentally preferable alternative (36 CFR 220.3).

Ephemeral Stream Streams that flow only as the direct result of rainfall or snowmelt. They have no 

permanent flow since their streambeds are not connected to groundwater below.

Equivalent Roaded 

Acres

A standardized unit of measure for land disturbance. A road prism is considered 

the reference to which other types of land disturbing activities are measured. A 

road is given an ERA coefficient of 1.0 (1 acre of road is equal to 1.0 ERA). Other 

disturbances such as logging, site preparation and wildfires are equated to a road 

surface by ERA coefficients that reflect their relative level of contribution to 

changes in runoff and sediment regimes in the watershed.

Erosion Hazard Rating 

(EHR)

A rating system used to classify the relative vulnerability of soil to erosion.

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Rim Fire Reforestation (45612) Appendix C

Draft Environmental Impact Statement Glossary

Escarpment A long, more or less continuous cliff or relatively steep slope produced by erosion 

or by faulting.

Fauna The animal life of an area.

Fireline A corridor, which has been cleared of organic material to expose mineral soil. 

Firelines may be constructed by hand or by mechanical equipment (e.g., dozers).

Fire Return Interval Number of years between 2 successive fires in a specified area.

Flag and Avoid The hanging of flagging in order to identify for the purpose of avoidance of a 

special feature in an area.

Flame Length The length of flame measured in feet. Increased flame lengths increase resistance 

to control and likelihood of torching events and crown fires.

Flora The plant life of an area.

Focal Species A species of concern.

Forest Cultivation This treatment immediately follows deep tilling and is designed to uproot 

competing vegetation. The forest cultivator has multiple ripper shanks spaced on a 

V-shaped bar that cultivates to an 18-inch depth.

Forest Road or Trail A road or trail wholly or partly within or adjacent to and serving the National Forest 

system that the Forest Service determines is necessary for the protection, 

administration, and utilization of the National Forest System and the use and 

development of its resources (36 CFR 212).

Free Flowing River Existing or flowing in a natural condition without impoundment, diversion, 

straightening, rip-rapping, or other modification of the waterway.

Fuelbreak A system of linear or mosaic patch treatments of forest or shrub vegetation 

designed and treated to reduce fire spread, intensity, and create barriers to fire 

spread.

Fuel Loading The weight per unit area of fuel, often expressed in tons per acre.

Fuel Moisture Fuel models are described by the volume of 1-hour, 10-hour, 100-hour, and 1000-

hour dead fuels; herbaceous and woody live fuels; and fuel bed depth and 

moisture of extinction (the fuel moisture content, weighed over all fuel classes at 

which a fire will cease spreading).

Fuels Plants and woody vegetation, living and dead that are capable of burning.

Fuels Management The planned manipulation and/or reduction of living and dead forest fuels for forest 

management and other land use objectives.

Fuels Treatment The treatment of fuels that left untreated would otherwise interfere with effective 

fire management or control. For example, prescribed fire can reduce the amount

of fuels that accumulate on the forest floor.

Fuelwood Wood cut into short lengths for burning in a fireplace, woodstove or fire pit.

Geographic 

Information Systems 

(GIS)

A computer system capable of storing, manipulating, analyzing, and displaying 

geographic information.

Ground Cover Natural organic and inorganic material that covers the watershed ground surface 

in sufficient quantity to allow a satisfactory rate of water infiltration to replenish 

ground water and limit erosion to natural rates. Ground cover usually consists of 

perennial vegetation, forest floor litter and duff, rock, downed wood, or similar 

erosion resistant material. Sufficient ground cover is usually 50% or greater, and 

cover of many forested ground surface areas is 80% or higher.

Habitat The area where a plant or animal lives and grows under natural conditions.

Habitat Connectivity The degree to which the landscape facilitates animal movement and other 

ecological flows.

Habitat Fragmentation The degree to which a habitat type, specific to a plant or animal species, is 

interrupted by different, incompatible habitat characteristics or types.

Hand Grub Using hoes or similar tools to severe the competing vegetation adjacent to 

seedlings and clearing to bare mineral soil.

519
Appendix C Stanislaus

Glossary National Forest

Hand Piling Piling by hand branches, limbs, tops and small boles for burning at a later time.

Hand Release See Manual Release.

Hazard Tree A standing tree that presents a hazard to people due to conditions such as 

deterioration of or damage to the root system, trunk, stem, or limbs or the direction 

or lean of the tree. Synonymous with danger tree for purposes of this project.

Herbaceous A vascular plant having little or no woody tissue. This commonly refers to grass 

and grasslike plants.

Heritage Program The comprehensive Forest Service program of responsibilities with regard to 

historic preservation. A pro-active program to manage prehistoric and historic 

cultural resources and cultural traditions for the benefit of the public through 

preservation, public use, and research. 

Home Range Core 

Area (HRCA)

An area designed to encompass the best available spotted owl habitat, and is in 

the closest proximity to owl protected activity centers where the most concentrated 

owl foraging activity is likely to occur. 

Hydrologically 

Connected Segment 

(HCS)

Locations where drainage off a road or trail is likely to enter a watercourse.

Hydrophobic Soils Soils that repel water, causing water to collect on the soil surface rather than 

infiltrate into the ground. Wild fires generally cause soils to be hydrophobic 

temporarily, which increases water repellency, surface runoff and erosion in postburn sites.

Image A graphic representation of a person or thing, typically produced by an electronic 

device. Common examples include remotely sensed data and photographs.

Indigenous Any species of plant or animals native to a given land or water area by natural 

occurrence.

Individuals, Clumps 

and Openings

An array of tree spatial patterns (or structures) that can be categorized into three 

primary components: individual trees, tree clumps and openings

Interdisciplinary Team

(IDT)

A diverse group of professional resource specialists who propose management 

strategies and activities to meet Forest objectives and who analyze the effects of 

these proposals on natural and other resources. Through interaction, participants 

bring different points of view and a broader range of expertise.

Intermittent Stream A stream that flows during the wet season due to precipitation runoff and has 

streamflow extending partially through the dry season due to at least some 

groundwater contribution.

Invasive Species Refer to Noxious Weeds for the purposes of this project.

Inventoried Roadless 

Area

Areas identified in a set of inventoried roadless area maps, contained in Forest 

Service Roadless Area Conservation, Final Environmental Impact Statement, 

Volume 2, dated November 2000, which are held at the National headquarters 

office of the Forest Service, or any subsequent update or revision of those maps.

Irretrievable A term that applies to the loss of production, harvest, or use of natural resources. 

For example, some or all of the timber production from an area is lost irretrievably 

while an area is serving as a winter sports site. The production lost is irretrievable, 

but the action is not irreversible. If the use changes, it is possible to resume 

timber production.

Irreversible A term that describes the loss of future options. Applies primarily to the effects of 

use of nonrenewable resources, such as minerals or cultural resources, or to 

those factors, such as soil productivity that are renewable only over long periods 

of time

Jackpot Burning The prescribed burning of heavy concentrations of down woody fuels.

Lahars Landslide or mudflow material of pyroclastic (hot ash or tephra) on the flank of a 

volcano or the deposit formed by such a landslide or mudflow.

Landing A forested opening, cleared of vegetation, leveled and graded, and used to 

stockpile sawlogs for eventual loading of load log trucks for haul to a sawmill.

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Rim Fire Reforestation (45612) Appendix C

Draft Environmental Impact Statement Glossary

Landscape A large land area composed of interacting ecosystems that are repeated due to 

factors such as geology, soils, climate, and human impacts.

Large Woody Debris Large Woody Debris (LWD) is typically greater than 12 inches in diameter at the 

midpoint and at least 10 feet in length and refers to large logs on the forest floor or 

in stream areas. LWD provides wildlife habitat and soil building processes on 

land, and can provide aquatic habitat complexity and stream stability. Large woody 

debris is important habitat for a variety of wildlife species and their prey.

Late Forest 

Succession

The stage of forest succession in which most of the trees are mature or over 

mature.

Legacy Watershed 

Effects

Impacts to natural features in a watershed that originated in the distant past but 

presently remain evident. Impacts may have occurred from land uses prior to 

establishment of the national forest, forest management activities or natural events 

such as fires, floods and landslides.

LiDAR A remote sensing method that uses light in the form of a pulsed laser to measure 

ranges (variable distances) to the Earth.

Limited Operating 

Period (LOP)

A specified period of time during which certain land management activities are 

prohibited.

Long-Term Risk A risk to be experienced within the next 50 to 100 years.

Machine Piling The use of mechanical equipment to push brush skeletons, small dead trees and 

excess downed fuels into piles for burning.

Maintenance The upkeep of the entire forest transportation facility including surface and 

shoulders, parking and side areas, structures, and such traffic-control devices as 

are necessary for its safe and efficient utilization (36 CFR 212).

Maintenance Level Defines the level of service provided by, and maintenance required for, a specific 

road, consistent with road management objectives and maintenance criteria. 

Management Action Any activity undertaken as part of the administration of the National Forest.

Management 

Requirements

Mandatory components of each alternative designed to implement the Forest Plan 

and to minimize or avoid potential adverse impacts. 

Manual Release Removing vegetative competition without the use of herbicides or mechanical 

equipment.

Mastication Shredding of brush and small trees (live and/or dead) to reduce contiguous fuels 

and remove competing vegetation and inter-tree competition.

Meadow Meadows are an ecosystem type dominated by herbaceous plants due to support 

of shallow groundwater that limits establishment of shrubs or trees. Meadows are 

usually comparatively flat in relation to their surrounding landscape.

Mesic Moderately moist climates or environments. Mesic Vegetation generally refers to 

vegetation found in moist environments. Mesic Soil refers specifically to soils with 

mean annual temperatures of 8 to 15 degrees centigrade.

Metasedimentary 

Rock

Rock formed over a long period of time from marine sediments under heat and 

great pressure.

Mitigation Avoiding an impact by not taking a certain action or parts of an action. Minimizing 

impacts by limiting the degree or magnitude of the action. Rectifying the impact by 

repairing, rehabilitating, or restoring the affected environment. Reducing or 

eliminating the impact over time by preservation and maintenance operations 

during the life of the action. 

Mixed Severity Fire A wildfire that has a wide range of burn severity. Usually includes high, moderate 

and low soil burn severity and multiple classes of vegetation burn severity.

Montane Hardwood 

Forests

Vegetation communities dominated by California black oak, canyon live oak, 

Pacific madrone or tanoak, for the purposes of this project. 

Mosaic Areas with a variety of plant communities over a landscape. For example, areas 

with trees and areas without trees occurring over a landscape.

521
Appendix C Stanislaus

Glossary National Forest

Multiple Use The management of all the various renewable surface resources of the National 

Forests so that they are utilized in the combination that will best meet the needs of 

the American people; making the most judicious use of the land for some or all of 

these resources or related services over areas large enough to provide sufficient 

latitude for periodic adjustments in use to conform to changing needs and 

conditions; that some land will be used for less than all of the resources; and 

harmonious and coordinated management of the various resources, each with the 

other, without impairment of the productivity of the land, with consideration being 

given to the relative values of the various resources, and not necessarily the 

combination of uses that will give the greatest dollar return or the greatest unit 

output. (Multiple-Use Sustained-Yield Act; Public Law 86–517)

Multiplier The concept in regional economic analysis describing how economic impacts that 

are directly caused by an action generally create additional economic impacts 

through indirect or induced mechanisms. The multiplier is the ratio of all economic 

impacts combined (through direct, indirect and induced mechanisms) divided by 

just the direct economic impacts.

Mycorrhizal Fungi A type of fungi which forms a symbiotic relationship with vascular plants for the 

purpose of exchanging nutrients and moisture by growing amongst the roots of the 

plants.

National 

Environmental Policy 

Act (NEPA)

Codifies the national policy of encouraging harmony between humans and the 

environment by promoting efforts to prevent or eliminate damage to the 

environment, thereby enriching our understanding of ecological systems and 

natural resources. It declares the federal government to be responsible for: (a) 

coordinating programs and plans regarding environmental protection; (b) using an 

interdisciplinary approach to decision-making; (c) developing methods to ensure 

that non-quantifiable amenity values are included economic analyses; and (d) 

including in every recommendation, report on proposals for legislation, or other 

major federal actions significantly affecting the quality of the environment a 

detailed environmental impact statement (EIS).

National Forest 

System

As defined in the Forest Rangeland Renewable Resources Planning Act, the 

"National Forest System" includes all National Forest lands reserved or withdrawn 

from the public domain of the United States, all National Forest lands acquired 

through purchase, exchange, donation, or other means, the National Grasslands, 

and land utilization projects administered under title III of the Bankhead-Jones 

Farm Tennant Act (50 Stat. 525, 7 U.S.C. 1010-1012), and other lands, waters or 

interests therein which are administered by the Forest Service or are designated 

for administration through the Forest Service as a part of the system (36 CFR 

212).

Natural Resource A feature of the natural environment that is of value in serving human needs.

Natural Regeneration Seedlings that germinate and grow on site from seed produced by a mature 

tree(s) in that location, without human intervention.

Natural Succession The natural replacement, in time, of one plant community with another. Conditions 

of the prior plant community (or successional stage) create conditions that are 

favorable for the establishment of the next stage.

NOAEL No observable adverse effect level is the toxicity threshold adopted by the Forest 

Service representing values based on longer-term studies of organisms exposed 

to low concentrations of chemicals to determine whether there are physiological or 

generational effects.

NOEC No observable effect concentration is the toxicity threshold adopted by the Forest 

Service representing values based on acute exposure of chemicals to organisms.

Noxious Weeds Any plant or plant product that can directly or indirectly injure or cause damage to 

crops (including nursery stock or plant products), livestock, poultry, or other 

interests of agriculture, irrigation, navigation, the natural resources of the United 

States, the public health, or the environment.

Old Forest (Old 

Growth)

Areas that contain large, old trees relative to the species-specific, environmentallyconstrained growth capacity of the site.

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Rim Fire Reforestation (45612) Appendix C

Draft Environmental Impact Statement Glossary

Outstanding 

Remarkable Value

A river-related value must be a unique, rare, or exemplary feature that is 

significant at a comparative regional or national scale. 

Paleoecological The study of ancient or prehistoric ecosystems.

Patch An area of vegetation, similar in structure and composition. 

Perennial Stream A stream typically with running water on a year-round basis due to precipitation 

runoff in the wet season and continual contribution of groundwater to support 

streamflow throughout the dry season except in smaller streams during droughts. 

Plantation A group of trees that have been planted together in a defined area.

Polygon Used in a GIS to represent an area, a polygon is a digital feature class defined by 

arcs, or lines, that make up its boundary. A polygon would be used to represent 

areas such as lakes and land parcels on a map.

Preferred Alternative The alternative(s) which the Agency believes would best fulfill the purpose and 

need for the proposal, consistent with the Agency’s statutory mission and 

responsibilities, giving consideration to environmental, social, economic, and other 

factors and disclosed in an EIS.

Prescribed Fire or 

Burn

A type of fuel treatment whereby fire is intentionally set in wildland fuels under 

prescribed conditions and circumstances.

Present Net Benefit Future positive values discounted back to the present using an annual discount 

rate of 1.4% for cash flows that occur 30 or more years into the future.

Present Net Cost The cost factors for treatments discounted back to the present using federally 

specified discount rates for economic analysis considered in calendar year 2015. 

The effects of future inflation have been taken out by using constant 2015 dollars.

Present Net Value The single best estimate of the economic efficiency is the sum of Present Net Cost 

and Present Net Benefit.

Proposed Action A proposal made by the Forest Service to authorize, recommend, or implement an 

action to meet a specific purpose and need.

Protected Activity 

Centers (PACs)

Designated areas that are afforded protection to specific species by restricting 

certain management activities. For example, California spotted owl PACs protect 

owl habitat and breeding areas by restricting timber harvest.

Public Involvement Using scoping to inform the public, obtain early and continuing public participation, 

and consider the views of interested parties in planning and decision-making.

Public Land Land for which title and control rests with a federal, state, regional, county, or 

municipal government.

Radio Telemetry The science and technology of automatic measurement and transmission of data 

by radio from remote sources to receiving stations for recording and analysis. 

Radio telemetry is used to track the movements of wild animals that have been 

tagged with radio transmitters.

Reasonably 

Foreseeable Future 

Actions

Those Federal or non-Federal activities not yet undertaken, for which there are 

existing decisions, funding, or identified proposals. Identified proposals for Forest 

Service actions are described in 220.4(a) (1) (36 CFR 220.3).

Record of Decision 

(ROD)

A concise public record of the responsible official’s decision to implement an 

action when an environmental impact statement (EIS) has been prepared.

Reforestation The natural or intentional restocking of existing forests and woodlands that have 

been depleted.

Regeneration Tree seedlings and saplings that have the potential to develop into mature forest 

trees.

Release Removing the competing vegetation adjacent to planted conifer seedlings. This 

could involve manual, mechanical, or chemical treatments.

Remote Sensing Acquiring information about a geographic feature without contacting it physically. 

Methods include aerial photography and satellite imaging.

Resistance to Control A measure of the production rate of a resource to construct and hold a fire line. 

Several factors affect resistance to fire control such as the: type of fuel, volume of 

fuel to construct line through, fire intensity adjacent to the line, slope, etc.

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Appendix C Stanislaus

Glossary National Forest

Resilience The ability of an ecosystem to maintain diversity, integrity, and ecological 

processes following a disturbance.

Responsible Official The Agency employee who has the authority to make and implement a decision 

on a proposed action (36 CFR 220.3).

Riparian Area The area along a watercourse, around a lake or pond, or in other wetlands.

Riparian Conservation 

Area (RCA)

Identified areas within a certain distance from streams, special aquatic features or 

riparian vegetation. RCA width and protection measures are determined through 

project level analysis.

Riparian Ecosystem The ecosystem around or next to water or in wetlands that support unique 

vegetation and animal communities as a result of a high water table.

Riparian Obligate 

Vegetation

Trees, shrubs and herbaceous plants that are sustained by wetland conditions 

along stream courses and in and around meadows and other wetlands. Trees and 

shrubs are usually deciduous species such as alder, aspen, big leaf maple, and 

cottonwoods. Shrubs include willows and dogwoods. Herbaceous plants include 

sedges, rushes and other grasslike plants.

Road A motor vehicle route over 50 inches wide, unless identified and managed as a 

trail (36 CFR 212).

Road Density The length of roads within a given area, most often calculated as miles of road per 

square mile of land area. Road density is often used as an indicator of watershed 

disturbance.

Roadless Area Refer to Inventoried Roadless Area for the purposes of this project.

Salvage Logging Dead conifer trees cut down and transported to a mill for processing. Logging 

systems may include ground based equipment such as harvesters and rubber 

tired skidders, or helicopter logging or skyline systems on steeper slopes and 

where necessary to meet resource objectives.

Schedule of Proposed 

Actions (SOPA)

A Forest Service document that informs the public about those proposed and 

ongoing Forest Service actions for which a record of decision, decision notice or 

decision memo would be or has been prepared. The SOPA also identifies a 

contact for additional information on any proposed actions (36 CFR 220.3).

Scope The range of actions, alternatives and impacts to be considered in an 

environmental impact statement (40 CFR 1508.25).

Scoping An early and open process for determining the scope of issues to be addressed 

and for identifying the significant issues related to a proposed action (40 CFR 

1501.7).

Sensitive Species Plant or animal species which are susceptible to habitat changes or impacts from 

management activities. The official designation is made by the USDA Forest 

Service at the regional level and is not part of the designation of threatened or 

endangered species made by the U.S. Fish And Wildlife Service.

Seral Stage The stage of succession of a plant or animal community that is transitional. If left 

alone, the seral stage will give way to another plant or animal community that 

represents a further stage of succession.

Shaded Fuel Break A defensible location where fuels have been modified, that can be used by fire 

suppression resources to suppress oncoming wildfires.

Short-Term Risk A risk to be experienced within the next 10 to 15 years. For example, prescribed 

burns can disturb habitat in the short-term, but in the long-term the fire resiliency of 

the habitat may be improved.

Silvicultural System The cultivation of forests; the result is a forest of a distinct form. Silvicultural 

systems are classified according to harvest and regeneration methods and the 

type of forest that results.

Silviculture The art and science that promotes the growth of single trees and the forest as a 

biological unit.

Site Preparation Treatments that prepare the planting area by removing excess fuels and/or decompacting soil and/or reducing competing vegetation to ensure initial seedling 

survival.

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Draft Environmental Impact Statement Glossary

Skidding Dragging a log with a tractor to a landing for loading onto a logging truck.

Slash Tree tops and branches left on the ground after logging or accumulating as a 

result of natural processes.

Snag A standing dead tree. Snags are important as habitat for a variety of wildlife 

species and their prey.

Soil Burn Severity The effect of a fire on ground surface characteristics, described in terms of char 

depth, organic matter loss, altered color and structure of soil, and reduced 

infiltration. Soil burn severity is measured in high, moderate and low classes 

based upon the degree of effects.

Soil Compaction An increase in soil density resulting from repeated tracking by mechanized 

equipment. Compaction reduces infiltration of water and can cause subsequent 

erosion, and can adversely affect forest vegetation in compacted areas.

Soil Displacement A lateral relocation of topsoil and often subsoil by movement of mechanized 

equipment or from sawlog yarding practices. Displacement can result in soil berms 

or ditches that divert water and lead to erosion. 

Soil Organic Matter Organic matter that is a component of mineral soil horizons (mainly A horizons).

Spatial Data Represents digitized geographic features associated with real-world locations. 

Special Aquatic 

Features

Lakes, ponds, vernal pools, meadows, bogs, fens, springs, and other wetlands.

Species A class of individuals having common attributes and designated by a common 

name; a category of biological classification ranking immediately below the genus 

or subgenus; comprising related organisms or populations potentially capable of 

interbreeding.

Strategic Fire 

Management Area 

(SFMA)

Fuel reduction areas designed to interrupt fire progression such that the fire 

reduces in intensity and becomes a surface fire. SFMAs serve to break up the 

continuity of the vegetation across the landscape and create mosaic patterns. The 

overall pattern impedes fire spread.

Strategic Fire 

Management Feature 

(SFMF)

Over the last few decades, SFMFs had been identified along roads and ridgelines 

to take advantage of natural or topographic features and established roadways. In 

addition to fire behavior modification, SFMFs create safe travel route options for 

emergency access and egress.

Stand A group of trees that occupies a specific area and is similar in species, age and 

condition.

Standards and 

Guidelines (S&Gs)

The primary instructions for land managers. Standards address mandatory 

actions, while guidelines are recommended actions necessary to a land 

management decision.

Stand Density Index 

(SDI)

A measure of the stocking of a stand of trees based on the number of trees per 

unit area and diameter at breast height of the tree of average basal area. An 

expression of relative stand density, independent of both stand age and site 

quality that provides a basis from which to understand the competitive interactions 

between individual trees.

Stand-Replacing Fire A fire that burns with sufficient intensity to kill the majority of living vegetation over 

a given area (grass and brush fires are stand replacement fires for that vegetation 

type, in forest vegetation types when 75-80% of the stand is killed by fire are also 

considered stand replacement fires).

Stewardship Caring for the land and its resources in order to pass healthy ecosystems on to 

future generations.

Suitability The appropriateness of certain resource management to an area of land. 

Suitability can be determined by environmental and economic analysis of 

management practices.

Surface Organic 

Matter

Organic material on top of the mineral soil surface, including coarse woody debris 

(CWD), fine wood, and forest floor layers (O soil horizon).

Sustainability The ability of an ecosystem to maintain ecological processes and functions, 

biological diversity, and productivity over time. 

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Appendix C Stanislaus

Glossary National Forest

Sustainable The yield of a natural resource that can be produced continually at a given 

intensity of management is said to be sustainable. Recreation activities are 

sustainable if the human activity does not reduce ecologic sustainability.

Taxa Name applied to any one group or entity in the scientific classification system.

Temporary Road A road necessary for emergency operations or authorized by contract, permit, 

lease, or other written authorization that is not a forest road or a forest trail and 

that is not included in a forest transportation atlas.

Thermic A soil with a mean annual soil temperature of greater than or equal to 15 degrees 

centigrade, but less than 22 degrees centigrade and a difference between the 

mean summer and winter soil temperatures of greater than 5 degrees centigrade 

measured at 50 cm below the surface.

Threatened Species Those plant or animal species likely to become endangered throughout all or a 

specific portion of their range within the foreseeable future as designated by the 

U.S. Fish and Wildlife Service under the Endangered Species Act of 1973.

Threshold of Concern The level of watershed disturbance which, if exceeded, could create adverse 

watershed or water quality effects, in spite of application of best management 

practices and project design criteria.

Understory The trees and woody shrubs growing beneath branches and foliage formed 

collectively by the upper portions of adjacent trees. 

Unroaded Area Any area, without the presence of a classified road, of a size and configuration 

sufficient to protect the inherent characteristics associated with its roadless 

condition. Unroaded areas do not overlap with inventoried roadless areas.

Variety Class A A landscape that includes a deep, V-shaped, river-cut canyon through 

metasedimentary rock providing a variety of rapids, cascades and pools.

Vegetation Burn 

Severity

The effect of a fire on vegetation, often described by the degree of scorch, 

consumption, and mortality of vegetation. Vegetation burn severity is measured by 

classes of canopy mortality or basal area loss.

Visual Quality The forest visual resources; terrain, geological features, or vegetation.

Water Quality 

Objectives

Water quality objectives, as listed in the Basin Plan of the California Central Valley 

Regional Water Quality Control Board, are the limits or levels of water quality 

constituents or characteristics which are established for the reasonable protection 

of beneficial uses of water.

Watershed An area of land above a given point on a stream that contributes water to the 

streamflow at that point.

Watershed Sensitive 

Areas (WSAs)

Portions of watersheds determined to be at high risk of soil erosion and 

sedimentation due to the combined effects of fire and proposed activities. Criteria 

for evaluating WSAs include: proposed recovery activities, burn severity, percent 

slope, slope shape, slope length, existing and potential soil cover, proximity to 

intermittent and perennial drainages, and proximity to high runoff response soils.

Wetlands Areas that are inundated by surface or ground water with a frequency sufficient to 

support (and that under normal circumstances do or would support) a prevalence 

of vegetation or aquatic life that requires saturated or seasonally saturated soil 

conditions for growth and reproduction.

Wild and Scenic River A river that is either already designated or proposed for designation because of its 

free flowing condition and outstanding remarkable values.

Wilderness Undeveloped Federal lands where the earth and its community of life are 

untrammeled by man, where man himself is a visitor who does not remain

Wildland An area in which development is essentially non-existent, except for roads, 

railroads, powerlines and similar transportation facilities.

Xeric A soil moisture regime common to Mediterranean climates that have moist cool 

winters and warm dry summers. A limited amount of water is present but does not 

occur at optimum periods for plant growth.

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Draft Environmental Impact Statement Human Health Risk Assessment

D. Human Health and Ecological Risk 

Assessment

Purpose

The purpose of this analysis is to assess the site-specific risks to human health and ecological risk 

from using the herbicide glyphosate for the control of grass, bearclover or other competing woody 

shrubs within the Rim Fire Reforestation planning area on the Mi-Wok and Groveland Ranger 

Districts, STF. The analysis is based on the planned application rates that are proposed for groundbased application (i.e. backpack directed foliar) under alternatives 1, 4 and 5. The application rates 

are the same for all alternatives. SERA reports and corresponding Worksheets that pertain to Human 

Health and Ecological Risk for noxious weed treatments using the chemicals aminopyralid, clethodim 

and clopyralid can be found in the project record located at the Forest Headquarters in Sonora, CA. 

Alternative 1 proposes to manually apply glyphosate herbicide on 16,215 acres for site preparation 

and 21,300 acres for release. Alternative 1 could apply glyphosate on the 4,031 acres of natural 

regeneration if needed. Alternatives 1 and 5 would also apply glyphosate to 646 acres of deer habitat 

enhancement reforestation units. Alternative 4 would apply glyphosate to 88 acres of deer habitat 

areas for both site preparation and 121 acres for release. Alternative 4 site preparation includes 

manually applying glyphosate prior to reforestation on 2,867 acres (20% of a subset of units proposed 

in Alternative 1). Alternative 4 also includes manually applying glyphosate on up to 4,012 acres to 

maintain a lower brush component in a buffer of 50 feet around Founder Stands to reduce fire spread 

and increase fire resilience within the planted areas. Alternative 5has the same proposed reforestation 

treatment units as Alternative 1; however, areas proposed as natural regeneration in Alternative 1 

would be treated as reforestation units in Alternative 5. Alternative 5 would manually apply 

glyphosate for site preparation on 20,246 acres and release 25,331 acres. 

Chemical release may occur up to three times to ensure seedling survival and the established trees are 

free to grow among the competing vegetation under alternatives 1, 4 and 5. These three alternatives 

propose the same herbicide treatment and application rate and are close in proximity in space and in 

time; therefore, they are analyzed together in this risk assessment.

Glyphosate formulations that are labeled for use in and around aquatic environments (e.g. Rodeo or 

an equivalent) will be used. These liquid formulations consist primarily of a glyphosate salt (i.e. 

isopropylamine salt) in water (SERA 2011). Surfactant and colorant additives would be used in 

addition to the glyphosate formulation. Surfactants improve the activity and penetration of the 

herbicide by reducing surface tension, allowing the herbicide mixture to spread evenly over the 

surface of vegetation. A colorant is added so that the actual treated area can be readily determined, 

which helps reduce skips and overlaps as well as human exposures to recently treated vegetation. 

Backpack sprayers, holding no more than five gallons at one time, would be used to apply the 

glyphosate mixture for the Reforestation project alternatives.

Table D.01-1 summarizes the proposed number of treatment acres, the expected application rates, and 

the additives planned for use under the proposed actions and alternatives of each project. The 

proposed applications would comply with all applicable state and federal regulations, and the label 

requirements, for the safe use of pesticides. For example, applicators would be adequately trained, 

medical aid would be available, wash water and eye wash water would be on-site or nearby, and 

personal protective equipment would be used (e.g. eye protection, gloves, long-sleeved shirt, and long 

pants). Best Management Practices for pesticide application, including a spill contingency plan, 

would be implemented. 

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Appendix D Stanislaus

Human Health Risk Assessment National Forest

Table D.01-1 Proposed Application Rates of Glyphosate

ALT Site Prep 

(acres)

Release 

(acres)

Application 

(acid equivalent) Additives

1 16,215 21,300 5.0 lbs/acre Syl-tacTM surfactant (0.4%), Colorfast® Purple or Hi-Lite® Blue dye (0.25%)

2 0 0 0 none

3 0 0 0 none

4 2,867 4,012 5.0 lbs/acre Syl-tacTM surfactant (0.4%), Colorfast® Purple or Hi-Lite® Blue dye (0.25%)

5 20,246 25,331 5.0 lbs/acre Syl-tacTM surfactant (0.4%), Colorfast® Purple or Hi-Lite® Blue dye (0.25%)

ALT=Alternative

Direction for Pesticide Use Management and Coordination

FSM 2150 and FSH 2109.14,20 provide direction to provide for pesticide use safety for the public 

and employees from unsafe work conditions when pesticides are involved. Development of a 

pesticide risk assessment for reforestation projects is part of this planning process. A pesticide risk 

assessment does not, in itself, ensure safety in pesticide use. The analysis must be tied to an action 

plan providing mitigation measures to avoid potential risks identified by the risk assessment.

FSH 2109.14,20 provides direction on the components of a risk analysis, documentation of risk 

analysis, risk management, risk communication and risk takings.

 Upon completion of a risk analysis, a number of techniques can be used to determine the best 

course of action for preventing identified problems. These range from taking appropriate 

mitigation measures to reduce risk, to not taking the proposed action, thus avoiding potential 

risks.

 Use risk analyses to decide whether, and to what extent, controls on exposure are necessary to 

protect public health and the environment. 

 Managers and decision makers must also recognize the uncertainties associated with risk analyses 

and incorporate those considerations into their decision making. 

Compliance with Direction

Risk assessments for proposed pesticides have been developed for the Forest Service and are 

incorporated into the pesticide risk assessment for this project. The SERA Human Health and 

Ecological Risk Assessment and Worksheets that provide the values for rick characterization are 

located in the project record, located at STF Supervisors office.

Risk Assessment Overview

This risk assessment examines the potential health effects on all groups of people who might be 

exposed to glyphosate. Those potentially at risk fall into two groups: workers and members of the 

public. Workers include applicators, supervisors, and other personnel directly involved in the 

application of herbicides. The public includes other forest workers, forest visitors, and nearby 

residents who could be exposed through the drift of herbicide spray droplets, through contact with 

sprayed vegetation, or by eating, or placing in the mouth, food items or other plant materials, such as 

berries or shoots growing in or near treated areas, by eating game or fish containing herbicide 

residues, or by drinking water that contains such residues. 

The hazards associated with using glyphosate have been determined through a comprehensive review 

of available toxicological studies; this review, which is in a risk assessment completed by SERA in 

March of 2011 under contract with the Forest Service, is incorporated by reference into this sitespecific risk assessment. A copy of the 2011 SERA risk assessment is included in the project record, 

which is available at the STF Supervisors Office.

The analysis of the potential human health effects of the use of glyphosate was accomplished using 

the methodology generally accepted by the scientific community (NRC 1983, EPA 1986). In essence, 

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Draft Environmental Impact Statement Human Health Risk Assessment

this risk assessment consists of comparing doses, based on site-specific herbicide use levels that 

people might receive from applying the herbicides or from being near an application site with the 

U.S.EPA’s established reference doses (RfD), levels of exposure associated with various margins of 

safety. Each type of dose, assumed for workers and the public, was compared to the RfD to 

quantitatively assess the potential level of concern. All calculations were done using FS 

WorksheetMaker Version 6.00.13, which was developed by SERA. The original EXCEL worksheets 

(project record) are summarized in this risk assessment.

The outline of this assessment follows a basic 4-step approach recommended by the National 

Research Council of the National Academy of Sciences (NRC 1983):

1. Hazard Analysis. An identification of the hazards associated with glyphosate and its commercial 

formulations; 

2. Exposure Analysis. An assessment of potential exposure to the glyphosate;

3. Dose-Response Assessment. An assessment of the dose-response relationships; 

4. Risk Characterization. A characterization of the risks associated with plausible levels of 

exposure. This section also examines the potential for the proposed treatments to cause 

synergistic effects, cumulative effects, and effects on sensitive individuals, including women and 

children. 

Unless otherwise specifically referenced, all of the information in the following sections was taken 

directly from the most recent SERA risk assessment (SERA 2011).

STEP 1: HAZARD ANALYSIS

Identifying what, if any, effects a compound is likely to have on an exposed population is the first and 

most critical step in any risk assessment. Unless some plausible biological effect can be 

demonstrated, the nature of the subsequent dose-response assessment and risk characterization is 

extremely limited (SERA 2011). A considerable body of information describing the hazards 

associated with using glyphosate is contained in the risk assessment completed by SERA (2011) 

under contract to the Forest Service. All of these documents are incorporated by reference into this 

risk assessment. The following section includes relevant portions of the hazard analysis provided in 

the most recent SERA risk assessment (SERA 2011).

Mechanism of Action (SERA 2011)

The herbicidal activity of glyphosate is due primarily to the inhibition of a metabolic pathway in 

plants, known as the shikimate pathway. This metabolic pathway does not occur in humans or other 

animals; accordingly, this mechanism of action is not directly relevant to humans. The mechanism by 

which glyphosate exerts toxic effects in humans or experimental mammals is not clear. The 

symptoms of toxicity in mammals, however, are generally consistent with irritation or damage to 

mucosal tissue. In addition, glyphosate may interfere with normal metabolic biochemical functions.

Absorption, Distribution, and Excretion (SERA 2011)

In general, glyphosate is not readily absorbed by humans or other mammals under normal conditions. 

While glyphosate is not rapidly absorbed by the dermal tissue, absorption across abraded skin is much 

more rapid than absorption across intact skin. If glyphosate is orally administered, it remains in the 

gastrointestinal tract where it can cause damage to intestinal cells, which could contribute to more 

rapid absorption after oral exposures. Glyphosate is not extensively metabolized, and more than 95% 

of administered glyphosate is excreted unchanged. Of the small proportion of glyphosate that is 

metabolized the most commonly noted metabolite is amino methyl phosphonic acid (AMPA). 

Differences in metabolic pathways can be an important consideration regarding differences in species 

sensitivity to some chemical agents. There is no indication that this is an important consideration for 

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Appendix D Stanislaus

Human Health Risk Assessment National Forest

glyphosate. Because glyphosate is not extensively metabolized, differences in metabolic pathways are 

not likely to be an important consideration in extrapolating animal toxicity data to risks in humans. 

Acute Oral Toxicity (SERA 2011)

A basic type of acute toxicity information involves time-specific LD50 or LC50 values (i.e. doses or 

concentrations of a toxicant that result in or are estimated to result in 50% mortality of the test species 

during a specified exposure or observation period). Most of the LD50 values for glyphosate 

formulations, as specified on Safety Data Sheets, are non-definitive and indicate that the LD50 values 

for most formulations are less than 5,000 mg/kg body weight (bw). The preponderance of available 

data clearly indicates that the mammalian toxicity of glyphosate is low, and very few specific hazards 

can be identified. Oral doses of technical grade glyphosate that exceed around 300 mg/kg body bw, 

may cause signs of toxicity, including decreased body weight, changes in certain biochemical 

parameters in blood as well as tissues, and inhibition of some enzymes (i.e., P450) involved in the 

metabolism of both endogenous and exogenous compounds. At doses from about 1,000 to 5,000 

mg/kg bw, glyphosate can cause death. 

Although most studies have been limited to laboratory animals, glyphosate formulations have been 

used in human suicides and attempted suicides. Of eight case reports of suicidal ingestions of 

glyphosate formulations, four resulted in mortality with estimated doses ranging from 4,500 to about 

17,000 mg formulation/kg bw. In the other four cases, the individuals survived doses estimated to 

range from about 1,700 to 5,000 mg formulation/kg bw. 

Subchronic or Chronic Systemic Toxic Effects (SERA 2011)

Subchronic and chronic toxicity of glyphosate has been well characterized in laboratory mammals. 

Decreased body weight is one of the more consistent signs of subchronic or chronic exposure. Other 

general signs of toxicity that have been reported are changes in liver weight, blood chemistry that 

would suggest mild liver toxicity, or liver pathology. Signs of kidney toxicity, which might be 

expected based on the acute toxicity of glyphosate, have not been reported consistently and are not 

severe. As summarized by the National Toxicology Program (NTP), various hematological changes 

have been observed but are not considered severe and are attributed to mild dehydration. 

Effects on Nervous System (SERA 2011)

The neurotoxicity of glyphosate has been tested for in several cases involving laboratory animals as 

well as numerous case studies involving human suicide, attempted suicide, and non-suicidal 

exposures. The weight of evidence suggests that any neurologic symptoms associated with glyphosate 

exposures are secondary to other toxic effects.

Effects on Immune System (SERA 2011)

Methods for assessing chemical exposure on immune responses include assays of antibody-antigen 

reactions, changes in the activity of specific types of lymphoid cells, and assessments of changes in 

the susceptibility of exposed animals to resist infection from pathogens or proliferation of tumor cells. 

No subchronic and chronic toxicity studies on technical grade glyphosate and glyphosate 

formulations have reported morphological abnormalities in tissues indicative of an effect on the 

immune system. Similarly, an in vitro study using human natural killer cells or cytotoxic T cells 

revealed no adverse effect on the function of these immune cells at concentrations ranging from 0.01 

to 10 μM (i.e. ≈1.7 μg/L or 1.7 mg/L). 

Experimental, clinical, and field studies have evaluated the ability of glyphosate formulations to 

induce allergic responses in humans. Skin rashes following dermal exposures to glyphosate 

formulations were reported, these effects are thought to derive primarily from irritation rather than 

allergy. The only other data involving human exposure to glyphosate is an observed increase in 

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Draft Environmental Impact Statement Human Health Risk Assessment

leukocyte counts in severely poisoned individuals that committed suicide. The increase in leukocytes, 

however, is believed to have been associated with secondary effects including damage to the 

gastrointestinal tract.

Endocrine Effects (SERA 2011)

Assessment of the direct effects of chemicals on endocrine function are most often based on 

mechanistic studies on estrogen, androgen, or thyroid hormone systems. In vitro tests suggest that 

glyphosate does not exhibit estrogenic activity. Glyphosate has been shown to inhibit androgen 

receptor binding over a concentration range from about 500 to 3,000 mg a.e./L, but the inhibition was 

not concentration related. Some tests involving glyphosate formulations have evidenced inhibition of 

hormone binding estrogen and androgen receptors, but this appears to be more closely related to other 

ingredients, presumably surfactants, in the formulations and not glyphosate, and in these studies there 

is an absence of concentration-dependent patterns. In the only study that evaluated the potential effect 

of glyphosate on estrogen-regulated genes, changes in DNA regulation were assayed using a 

commercial microarray chip for 1,550 genes. Changes (either up or down regulation) were observed 

in approximately 44% of the genes; however, the concentrations tested are likely not reasonable for 

cellular exposure (i.e. approx. 2.3 to 230 mg a.e./L). Furthermore, this study has unresolved 

discrepancies within the report regarding doses. 

In June 2015 the US EPA announced the results of a recently completed Tier 1 screening assays on 

52 pesticide chemicals, including glyphosate, as part of its Ecdocrine Disruptor Screening Program 

(EDSP). The Tier 1 screening data are used to determine whether a chemical has the potential to 

interact with the endocrine system and thus requires more thorough testing. From US EPA’s 

Executive Summary of Tier 1 results for glyphosate: Based on weight of evidence considerations, 

mammalian or wildlife EDSP Tier 2 testing is not recommended for glyphosate since there was no 

convincing evidence of potential interaction with the estrogen, androgen or thyroid pathways (EPA 

2015). 

Reproductive and Developmental Effects (SERA 2011)

The most sensitive endpoint for glyphosate (i.e. the adverse effect occurring at the lowest dose) 

involves developmental effects; accordingly, the EPA-derived RfDs for glyphosate are based on 

developmental effects. These adverse developmental effects, which consist primarily of delayed 

development, occur only at doses causing signs of maternal toxicity (1,000 mg/kg bw/day in rats and 

100 to 175 mg/kg bw/day in rabbits). There is no indication that glyphosate causes birth defects. 

Reproduction studies involve exposing one or more generations of the test animal to a chemical 

compound. Three multi-generation studies are available on technical grade glyphosate. Apparently, 

multi-generation studies have not been conducted on glyphosate formulations or any of the 

surfactants used in glyphosate. The lack of multi-generation studies on glyphosate formulations and 

surfactants is a concern. Notwithstanding this concern, several epidemiology studies on human 

populations involving the use and application of glyphosate formulations are available. None have 

demonstrated a statistically significant association between exposure and adverse reproductive 

effects.

In a multi-generation reproduction study in rats, effects on the kidney were observed in male 

offspring at 30 mg/kg/day but not at 10 mg/kg/day. In this study, however, the historical control 

indices for tubular lesions varied markedly in male weanling rats. Therefore, it was concluded that the 

highest dose tested (30 mg/kg/day) had no adverse reproductive effects. In another study using 

rabbits, developmental toxicity was not observed at maternal doses up to 350 mg/kg/day, but maternal 

effects were seen at this dose. The maternal NOEL in this study was 175 mg/kg/day; this is the value 

EPA has used to establish the current RfD.

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Several publications in the open literature have suggested that glyphosate or some glyphosate 

formulations may have adverse effects on the testes and may lead to a reduction in testosterone. Refer 

to SERA (2011, pp. 59-61) for a detailed discussion of these studies. While these studies may impact 

the perception of risk, they do not have a substantial impact on the hazard identification because 

concerns for reproductive function are adequately encompassed by the current RfD for glyphosate. 

Carcinogenicity and Mutagenicity (SERA 2011)

Demonstrating that a compound is mutagenic is different from demonstrating that a compound is 

carcinogenic. Although mutagenicity data can be used to evaluate the mechanism by which a 

potential carcinogen may operate, quantitative risk assessments for carcinogenicity are based on 

either in vivo cancer bioassays in experimental mammals or epidemiology studies that provide 

adequate measures of both exposure and risk. Based on the available information on glyphosate, the 

EPA/OPP (1993a) has concluded that glyphosate should be classified as Group E (evidence of noncarcinogenicity for humans). 

A few studies have reported mutagenic activity caused by significantly high doses of glyphosate and 

glyphosate formulations (e.g. 100 times greater than plausible levels glyphosate concentrations in the 

plasma of rats exposed to a nontoxic dose of 10 mg/kg bw. Increased incidence of chromosomal 

damage in humans has been observed after aerial applications of glyphosate formulations at rates 

ranging from 1 to 4 lbs a.e./acre. This does not demonstrate, however, that glyphosate causes 

hereditable mutations or that increased risks of cancer or any overt signs of toxicity would be 

expected. Furthermore, the formulations studied in these human exposure cases are not identified for 

use by the Forest Service and should only be viewed as a worst case assumption.

Recently, the International Agency for Research on Cancer (IARC) Monograph Working Group 

determined that glyphosate should be classified as “probably carcinogenic to humans” (Guyton et al 

2015). This recent decision was based on a review of existing studies and not on new research. The 

issue is a particular group of cancers called non-Hodgkin’s lymphomas. The Guyton 2015 paper is 

only a summary of a longer paper that is in-press at this time.

In 1991, US EPA concluded that glyphosate should be classified as a Group E (evidence of noncarcinogenicity for humans) based on a lack of convincing carcinogenicity evidence and considering 

the criteria in EPA Guidelines for classifying a carcinogen. In a few months, US EPA will be 

releasing for public comment their preliminary human health risk assessment for glyphosate as part of 

their program to reevaluate all pesticides periodically.

The USFS human health and ecological risk assessment for glyphosate (SERA 2011), includes a 

lengthy discussion of the mutagenic and carcinogenic potential of glyphosate including nonHodgkin’s lymphoma (Section 3.1.10). Many of the key references used in Guyton (2015) and 

another recent, but more in-depth review (Schinasi and Leon, 2014) are discussed in the glyphosate 

risk assessment. The USFS risk assessment concludes (page 70):

The nature of the available epidemiology data on glyphosate is addressed in the U.S. EPA/OPP 

(2002) assessment:

 This type of epidemiologic evaluation does not establish a definitive link to cancer. Furthermore, 

this information has limitations because it is based solely on unverified recollection of exposure 

to glyphosate-based herbicides.

 Based on an evaluation of the available animal studies as well as epidemiology studies, U.S. 

EPA/OPP (2002, p. 60943) classifies the carcinogenic potential of glyphosate as Group E, No 

Evidence of Carcinogenicity. Given the marginal mutagenic activity of glyphosate (Section 

3.1.10.1), the failure of several chronic feeding studies to demonstrate a dose-response 

relationship for carcinogenicity, and the limitations in the available epidemiology studies on 

glyphosate, the Group E classification in U.S. EPA/OPP (1993a, 2002) appears to be reasonable. 

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It has been USFS practice to defer to US EPA unless there is a compelling reason to do otherwise. At 

this point, there is not yet a compelling reason to adopt the IARC’s classification since all the 

technical details are not yet available from IARC and since US EPA’s and our analyses would 

indicate a different conclusion. As stated, a new risk assessment from US EPA is expected later this 

year which will undoubtedly consider the IARC’s classification. If the US EPA accepts the IARC 

recommendation, then the USFS would consider an update to the glyphosate RA and for purposes of 

existing NEPA documents, such a reclassification would be considered ‘new information’. 

Based on standard animal bioassays for carcinogenic activity in vivo, there is no basis for asserting 

that glyphosate is likely to pose a substantial risk of causing cancer. As with any compound that has 

been studied for a long period of time and tested in a large number of different systems, some 

equivocal evidence of carcinogenic potential is apparent and may remain a cause of concern, at least 

in terms of risk perception. Given the marginal mutagenic activity of glyphosate, the failure of several 

chronic feeding studies to demonstrate a dose-response relationship for carcinogenicity, and the 

limitations in the available epidemiology studies on glyphosate, the EPA Group E classification 

appears to be reasonable. Therefore, no quantitative risk assessment for cancer is conducted as part of 

the current analysis.

Effects on the Skin and Eyes (SERA 2011)

Technical grade glyphosate causes only slight skin irritation and is classified as Category IV (the least 

hazardous category) for this endpoint (EPA/OPP 1993a). Formulations that contain primarily 

glyphosate and water with no surfactants as well as most formulations with surfactants are classified 

as either non-irritating or only slightly irritating to skin.

Based on several eye irritation studies submitted to the EPA as part of the registration process, U.S. 

EPA/OPP (1993b) classifies glyphosate as mildly irritating to the eyes (Category III). Some 

formulations of glyphosate, however, are classified by the EPA/OPP as corrosive (Category I – 

corneal opacity not reversible within 7 days) or severe eye irritants (Category II – corneal opacity 

reversible within 7 days or other eye irritation persisting for 7 days or more). In two studies that 

surveyed 1,912 calls to poison control involving glyphosate and ocular effects, symptoms included 

blurred vision, a stinging or burning sensation, and lacrimation. The most severe cases of eye 

irritation appear to involve accidental exposures in which the glyphosate formulation was sprayed 

into eyes under pressure. No cases of permanent eye damage were reported.

Inhalation Exposure (SERA 2011)

Glyphosate has a very low vapor pressure and will not tend to volatilize. Biomonitoring studies in 

workers indicate that inhalation exposure levels for workers applying glyphosate are low relative to 

the dermal exposure levels. The lowest reported definite LC50 is 1.6 mg formulation/L (i.e. Honcho 

Plus, a 41% formulation of the IPA salt of glyphosate). Thus, the LC50 of 1.6 mg formulation/L 

corresponds to about a concentration of 0.4884 mg a.e./L, which is above the highest detected 

concentration of glyphosate in air during glyphosate applications (i.e. 2.5x10-5 mg a.e./L) by a factor 

of 20,000. 

Impurities and Metabolites (SERA 2011)

The primary metabolite of glyphosate in mammals is aminomethyl phosphonate (AMPA). In 

mammals, only very small amounts of AMPA, less than 1% of the absorbed dose, are formed. In 

general, the common approach to examining the potential importance of the metabolism of a chemical 

agent by a mammal (i.e. xenobiotics) typically involves toxicology studies and monitoring studies of 

the parent compound. Thus, in terms of assessing direct exposures to technical grade glyphosate, the 

inherent exposures to AMPA as a metabolite are encompassed by the existing toxicity data on 

glyphosate. 

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In addition, AMPA is an environmental metabolite of glyphosate. This is to say that AMPA is formed 

in environmental media such as soil and water as a breakdown product of glyphosate. About 20% of 

applied dose of glyphosate may be found in water as AMPA after about 6 months. The EPA, the 

World Health Organization, and others have assessed the potential consequences of exposures to 

AMPA as an environmental metabolite. Based on these reviews, the EPA concluded that only the 

glyphosate parent is to be regulated and that AMPA is not of toxicological concern regardless of its 

levels in food. Consequently, in this risk assessment, AMPA is not quantitatively considered in the 

dose-response and exposure assessments.

Glyphosate also contains N-nitrosoglyphosate (NNG) as an impurity. NNG contains the nitrosoamine 

group. Certain groups of nitrosoamines have served as model compounds in some of the classical 

studies on chemical carcinogenicity. Carcinogenicity testing of nitroso contaminants, however, is 

normally required only in those cases in which the level of nitroso compounds exceeds 1.0 ppm. 

Analyses have shown that greater than 92% of the individual technical glyphosate samples contain 

less than 1.0 ppm NNG. Therefore, the NNG content of glyphosate was not toxicologically significant 

and a detailed dose-response and exposure assessment for NNG does not appear to be warranted.

STEP 2: EXPOSURE ANALYSIS

The exposure scenarios considered in a risk assessment involving pesticide exposure are determined 

by the application method and the chemical and toxicological properties of the compound. Depending 

on the properties of the chemical and the application method, the risk assessment may consider acute, 

subchronic, or chronic durations of oral, dermal, inhalation or combined exposure to the pesticide. 

The SERA FS WorksheetMaker provides a range of assumed values for each of these variables 

(SERA 2011a). Ranges of absorbed doses are calculated based on ranges of these variables (i.e. 

central, low, and high) in addition to the proposed application rate and application volume per acre. 

As discussed earlier in this risk assessment and shown in Table D.01-1, the proposed application rate 

for the Rim Reforestation project is 5.0 lb a.e./acre and the central, low, and high application volumes 

were assumed to be 30, 20, and 40 gallons/acre, respectively. The exposure assessment is also based 

on the assumption that the Rim Reforestation herbicide application units would receive 100% 

coverage with herbicide; when in fact, treatments would only target specific plants and patches of 

vegetation. Therefore, the chances of an individual receiving the absorbed doses reported in the 

following analysis should be viewed as highly conservative.

Worker Exposure

Two types of exposure assessments are considered: general and accidental/incidental. The term 

general exposure is used to designate exposures involving absorbed dose estimates based on handling 

a specified amount of chemical during specific types of applications. The accidental/incidental 

exposure scenarios involve specific events that may occur during any type of application (SERA 

2011). 

While workers are likely to receive some low-level doses when routinely working with chemicals, 

standard safety practices and the use of required protective clothing and equipment normally would 

reduce the actual dose levels below those estimated in the following analysis. Similarly, any general 

or accidental/incidental exposures that might occur would likely be less than those estimated because 

the standard protocol, as specified in the herbicide spill plan prepared for projects involving the use of 

pesticides, would be to wash the chemical off immediately.

General Exposure (SERA 2011)

General occupational exposures typically encompass multi-route exposures (i.e. oral, dermal, and 

inhalation); nonetheless, dermal exposure is generally the predominant route for herbicide applicators. 

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The default exposure rate assumed by the SERA FS WorksheetMaker for the type of glyphosate 

application proposed by the Rim Reforestation project (i.e. backpack directed foliar) is 0.003 mg/kg 

bw per lb applied with a range of 0.0003 to 0.01 mg/kg bw per lb applied. These values correspond 

well with values observed during several worker exposure studies, which are discussed in detail by 

the SERA (2011) glyphosate risk assessment. The estimated absorbed dose for general exposures 

during backpack application of glyphosate is expressed in mg chemical per kg bw per day 

(mg/kg/day) and is summarized in Table D.01-2. Details about the assumptions and calculations used 

in all worker exposure assessments are given in the detailed calculation worksheets in the SERA FS 

WorksheetMaker (Worksheets C01–C03). The rationale for and sources of the specific values used in 

these exposure scenarios are given in the documentation for the worksheets (SERA 2011a) and in the 

SERA (2011) glyphosate risk assessment.

Accidental Exposures (SERA 2011)

Accidental exposures are most likely to involve splashing a solution of herbicide into the eyes and 

may also involve various dermal exposure scenarios. Although quantitative exposure scenarios for 

ocular exposures are not modeled in the SERA FS WorksheetMaker, or developed in other risk 

assessments (e.g. SERA 2003 and 2011), ocular exposures to some formulations of glyphosate may 

cause moderate to severe eye damage, as discussed in the Hazard Analysis section of this risk 

assessment. This effect is considered qualitatively in the Risk Characterization section for workers 

later in this risk assessment.

Two types of accidental dermal exposure scenarios are considered in this risk assessment. They 

involve direct contact with a pesticide solution and accidental spills of the pesticide onto the surface 

of the skin. In addition, two exposure scenarios are developed for each of the two types of dermal 

exposure, and the estimated absorbed dose for each scenario is expressed in units of mg chemical per 

kg bw per event (mg/kg/event). Both sets of exposure scenarios are summarized in Table D.01-2. 

Table D.01-2 Worker Exposure from Backpack Application of Glyphosate

Scenario Central AD1 Lower AD1 Upper AD1

General Exposures

Backpack Application 0.03003 0.0018 0.2

Accidental/Incidental Exposures

Contaminated Gloves, 1 minute 0.000006 0.00000111 0.0000378

Contaminated Gloves, 1 hour 0.00036 0.0000666 0.002268

Spill on Hands, 1 hour 0.000787039 0.000187188 0.00287856

Spill on lower legs, 1 hour 0.001939488 0.000461284 0.007093595

AD=Absorbed Dose (mg/kg/day or mg/kg/event) 1 Milligrams of agent per kilogram of body weight per day or per event with Glyphosate 

applied at a rate of 5.0 pounds acid equivalent/acre. 

Source: SERA FS WorksheetMaker, Worksheet C01,E01. 

The two direct contact scenarios consider a worker that wears grossly contaminated gloves for 1 

minute and for 1 hour. These contact scenarios assume that wearing grossly contaminated gloves is 

equivalent to immersing the hands in a solution. The exposure scenarios involving chemical spills 

onto the skin are characterized by a spill on to the lower legs as well as a spill on to the hands and are 

based on the assumption that a certain amount of the chemical adheres to the skin. The absorbed dose 

is then calculated as the product of the amount of chemical on the surface of the skin. Both of the spill 

scenarios assume that the worker waits 1 hour before washing the chemical off.

General Public Exposure

Under normal circumstances, members of the general public should not be exposed to substantial 

levels of glyphosate as a result of Forest Service activities. Members of the public would generally 

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not be in the areas of maintenance work during herbicide application. Application sites would be 

inspected prior to herbicide application to ensure that no people are present, and signs would be 

posted that state the name of the chemicals applied and date of application. Signs would be posted at 

each application site for at least 30 days after application. In addition, all application activities would 

stop temporarily if a member of the public entered the vicinity of the application site.

Table D.01-3 General Public Exposure from Backpack Application of Glyphosate

Scenario Receptor Central AD1 Lower AD1 Upper AD1

Accidental Acute Exposures (mg/kg/event)

Direct Spray of Child, whole body Child 2.97E-02 7.07E-03 1.09E-01

Direct Spray of Woman, feet and lower legs Adult Female 2.99E-03 7.10E-04 1.09E-02

Water consumption (spill) Child 5.69E-01 5.21E-02 2.56E+00

Fish consumption (spill) Adult Male 6.49E-03 9.74E-04 1.95E-02

Fish consumption (spill) Subsistence Populations 3.16E-02 4.75E-03 9.49E-02

Non-Accidental Acute Exposures (mg/kg/event)

Vegetation Contact, shorts and T-shirt Adult Female 5.96E-03 1.89E-03 1.44E-02

Contaminated Fruit Adult Female 5.88E-02 2.69E-02 9.33E-01

Contaminated Vegetation Adult Female 8.10E-01 5.63E-02 6.75E+00

Swimming, one hour Adult Female 2.18E-08 6.35E-10 6.90E-07

Water consumption Child 4.14E-03 2.98E-04 4.68E-02

Fish consumption Adult Male 4.72E-05 5.58E-06 3.56E-04

Fish consumption Subsistence Populations 2.30E-04 2.72E-05 1.73E-03

Chronic/Longer Term Exposures (mg/kg/day)

Contaminated Fruit Adult Female 9.41E-03 4.30E-03 1.49E-01

Contaminated Vegetation Adult Female 1.30E-01 9.00E-03 1.08E+00

Water consumption Adult Male 2.71E-05 8.80E-06 9.94E-04

Fish consumption Adult Male 5.16E-08 2.39E-08 1.57E-06

Fish consumption Subsistence Populations 4.18E-07 1.93E-07 1.28E-05

AD=Absorbed Dose (mg/kg/day or mg/kg/event) 1 Milligrams of agent per kilogram of body weight per day or per event with Glyphosate applied at a rate of 5.0 pounds acid 

equivalent/acre. 

Source: SERA FS WorksheetMaker, Worksheet E03. 

Despite the precautionary actions taken during application, the chances that members of the general 

public will be exposed to glyphosate in Forest Service applications are highly unpredictable. The 

proposed Rim Reforestation application units are within or near areas used for various purposes by 

the public, such as fishing, camping, hunting, woodcutting and off-highway motor vehicle travel. 

Given this uncertainty, a highly conservative approach for estimating exposure rates for the general 

public is used in this risk assessment. Exposure assessments developed in this risk assessment are 

based on Extreme Values rather than a single value. Extreme value exposure assessments bracket the 

most plausible estimate of exposure (referred to statistically as the central or maximum likelihood 

estimate) with lower and upper bounds of credible exposure levels. This approach is essentially an 

elaboration on the concept of the Most Exposed Individual (MEI). The MEI approach attempts to 

characterize the extreme but still plausible upper limit on exposure (SERA 2011).

The exposure scenarios developed for the general public are summarized in Table D.01-3. As with the 

worker exposure scenarios, details about the assumptions and calculations used in these assessments 

are given in the detailed calculation worksheets in the SERA FS WorksheetMaker (Worksheets D01–

D11). The rationale for and sources of the specific values used in these exposure scenarios are given 

in the documentation for the worksheets (SERA 2011a) and in the SERA (2011) glyphosate risk 

assessment.

Table D.01-3 shows the kinds of exposure scenarios developed for the general public include acute 

accidental, acute non-accidental, and longer-term or chronic exposures. The accidental exposure 

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scenarios assume that an individual is exposed to the compound of concern either during or shortly 

after its application. As well, the nature of the accidental exposures is intentionally extreme. Nonaccidental exposures involve dermal contact with contaminated vegetation as well as the consumption 

of contaminated fruit, vegetation, water, or fish. The longer-term or chronic exposure scenarios 

parallel the acute exposure scenarios for the consumption of contaminated fruit, water, or fish. 

STEP 3: DOSE-RESPONSE ASSESSMENT

Acute RfDs are usually based on developmental studies in which an adverse effect is associated with 

a single dose of a pesticide. The EPA, however, has not derived an explicit acute RfD for glyphosate. 

Instead, a chronic RfD that is equivalent to an acute RfD is used to characterize risks associated with 

both acute and longer-term exposures (EPA/OPP 1993a,c). Three different longer-term RfD values 

have been derived for glyphosate by the EPA/OPP, EPA Office of Research and Development, and 

the World Health Organization. The EPA/OPP derived an RfD of 2 mg/kg/day, which is the only 

chronic RfD for glyphosate based on a study that defines both a NOAEL and a LOAEL (SERA 

2011). Consequently, the SERA (2011) glyphosate risk assessment and SERA FS WorksheetMaker 

(SERA 2011a) adopted the EPA/OPP derived chronic RfD to characterize risks associated with both 

acute and longer-term exposures.

The study that the EPA/OPP used to determine the 2 mg/kg bw/day RfD used in this risk assessment 

was conducted on rabbits. Although this study established a NOAEL of 175 mg/kg bw/day and a 

LOAEL of 350 mg/kg bw/day that does not mean that a dose of 4 mg/kg bw/day is likely to cause 

mortality in humans. As discussed early in the Hazard Analysis section of this risk assessment, 

individuals may well survive suicidal ingestions of more than 4,000 mg/kg bw, so long as they 

receive prompt medical attention (SERA 2011). Furthermore, exposures to doses of more than 2 

mg/kg bw of glyphosate are unlikely, as shown in Table D.01-2 and Table D.01-3. 

STEP 4: RISK CHARACTERIZATION

The quantitative risk characterization is expressed as the hazard quotient (HQ). The HQ is calculated 

as the estimated doses in units of mg/kg bw for acute exposures or units of mg/kg bw/day for longerterm exposures divided by the RfD of 2 mg/kg bw/day. Because the HQs are based on the RfD, an 

HQ of 1 or less suggests that exposures are below the level of concern. HQs greater than 1 indicate 

that the exposure exceeds the level of concern (SERA 2011). All HQs are calculated assuming that 

the Rim Reforestation herbicide application units would receive 100% coverage with herbicide; when 

in fact, treatments would only target specific plants and patches of vegetation. Therefore, HQs 

reported in the following analysis should be viewed as highly conservative.

Workers

A quantitative summary of the risk characterization for workers is presented in Table D.01-4 for the 

unit application rate of 5.0 lbs a.e./acre. Given the very low HQs, none of the accidental exposure 

scenarios approach a level of concern. The highest HQ for any accidental exposure scenario is 0.004, 

the upper bound of the HQ for a pesticide spill over the lower legs that is not effectively mitigated for 

1 hour. This HQ is below the level of concern by a factor of 250. Confidence in this assessment is 

reasonably high because of the availability of dermal absorption data in humans, as presented in the 

Hazard Analysis section of this risk assessment.

The HQs for general or longer-term exposures in workers are also low. Even at the upper bound of 

plausible exposures, all HQs are below the level of concern. For an application rate of 5.0 lbs 

a.e./acre, the highest HQ is 0.1, the upper bound for workers involved in backpack applications. To 

reach a level of concern or an HQ of 1, would require an application rate of about 50 lbs a.e./acre. 

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Such an application rate far exceeds any plausible application of glyphosate as proposed by the Rim 

Reforestation project and is considerably higher than even the maximum labeled application rate of 

about 8 lbs a.e./acre (SERA 2011). 

Table D.01-4 Worker Hazard Quotients (Toxicity)

Scenario Central HQ1 Lower HQ1 Upper HQ1

General Exposures

Backpack Application 2E-02 9E-04 0.1

Accidental/Incidental Exposures

Contaminated Gloves, 1 minute 3E-06 6E-07 2E-05

Contaminated Gloves, 1 hour 2E-04 3E-05 1E-03

Spill on Hands, 1 hour 4E-04 9E-05 1E-03

Spill on lower legs, 1 hour 1E-03 2E-04 4E-03

HQ=Hazard Quotient 1 2 mg/kg bw/day RfD and a glyphosate application rate with Glyphosate applied at a 

rate of 5.0 pounds acid equivalent/acre. 

Source: SERA FS WorksheetMaker, Worksheet E02.

General Public

A quantitative summary of the risk characterization for members of the general public is presented in 

Table D.01-5. Like the corresponding table for workers, Table D.01-5 is based on a unit application 

rate of 5.0 lbs a.e./acre. For an application rate of 5.0 lbs a.e./acre, most of the HQs do not exceed a 

level of concern.

Table D.01-5 Hazard Quotients (Toxicity) for the General Public

Scenario Receptor Central HQ1 Lower HQ1 Upper HG1

Accidental Acute Exposures (mg/kg/event)

Direct Spray of Child, whole body Child 1E-02 4E-03 5E-02

Direct Spray of Woman, feet and lower legs Adult Female 1E-03 4E-04 5E-03

Water consumption (spill) Child 0.3 3E-02 1.3

Fish consumption (spill) Adult Male 3E-03 5E-04 1E-02

Fish consumption (spill) Subsistence Populations 2E-02 2E-03 5E-02

Non-Accidental Acute Exposures (mg/kg/event)

Vegetation Contact, shorts and T-shirt Adult Female 3E-03 9E-04 7E-03

Contaminated Fruit Adult Female 3E-02 1E-02 0.5

Contaminated Vegetation Adult Female 0.4 3E-02 3

Swimming, one hour Adult Female 1E-08 3E-10 3E-07

Water consumption Child 2E-03 1E-04 2E-02

Fish consumption Adult Male 2E-05 3E-06 2E-04

Fish consumption Subsistence Populations 1E-04 1E-05 9E-04

Chronic/Longer Term Exposures (mg/kg/day)

Contaminated Fruit Adult Female 5E-03 2E-03 7E-02

Contaminated Vegetation Adult Female 6E-02 4E-03 0.5

Water consumption Adult Male 1E-05 4E-06 5E-04

Fish consumption Adult Male 3E-08 1E-08 8E-07

Fish consumption Subsistence Populations 2E-07 1E-07 6E-06

HQ=Hazard Quotient 1 2 mg/kg bw/day RfD and a glyphosate application rate with Glyphosate applied at a rate of 5.0 pounds acid equivalent/acre. 

Source: SERA FS WorksheetMaker, Worksheet E04.

Table D.01-5 shows the highest HQ for accidental acute exposures is for a child’s consumption of 

contaminated water after an accidental spill. The upper bound of the HQ for this exposure scenario 

(1.3) slightly exceeds the level of concern. The risk characterization for this upper bound assumes that 

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a field solution of 200 gallons are spilled with no dilution or decomposition of herbicide into a 1 

meter deep pond with a surface area of 1,000 m2, and then a 13.3 kg child drinks 1.5 L of the pond 

water (SERA FS WorksheetMaker, Worksheets B04b and D05). The potential for a spill of herbicides 

into a waterbody is mitigated through designating routes of travel and mixing sites, minimizing 

herbicide mix in tanks while traveling between units, requiring a separate water truck from the batch 

truck, and if a spill occurs, outlining responses required by the contractor. 

Table D.01-5 shows the greatest concern of both the non-accidental exposure scenarios and the 

chronic/longer-term exposure scenarios involves the consumption of contaminated vegetation by an 

adult female. The HQ for the upper bound for the acute exposure is 3.0 (exceeds a HQ of 1.0) and the 

HQ for the upper bound for the chronic exposure is 0.5. At typical and lower levels of exposure, this 

scenario yields HQs below a level of concern. For contaminated vegetation, the maximum labeled 

application rate of about 5 lbs a.e./acre (SERA 2011) would result in a HQ value of about 5.6 with a 

corresponding dose of about 10.8 mg/kg bw, which is much higher than values estimated in this risk 

assessment. There is no basis for asserting that a dose as high as 10.8 mg/kg bw would lead to gross 

signs of toxicity. As discussed in the Dose-Response Assessment section, lethal doses would not be 

expected at this dose. Nonetheless, adverse effects observed in pregnant rabbits at a dose of 350 

mg/kg bw (i.e. a factor of 2 above the NOAEL on which the RfD is based) do raise concerns for 

adverse health effects in sensitive individuals, such as pregnant women (SERA 2011).

The proposed Rim Reforestation project herbicide application units are not areas known to be 

commonly used by local Native Americans or the general public to gather plant materials. It is 

plausible, however, that people would occasionally target these locations for gathering plant 

materials. Edible plant species, such as miner’s lettuce (Montia perfoliata), are known to occur in or 

near the proposed herbicide application units. As discussed previously, however, precautions would 

be taken to increase public awareness of herbicide use by posting signs for 30 days following 

applications. Colorants would also be added to the glyphosate mixture, which would decrease the 

likelihood of people gathering and consuming contaminated vegetation. In most instances, 

particularly for longer-term scenarios, treated vegetation would probably show signs of damage from 

exposure, rendering it undesirable for consumption. Furthermore, all HQs are calculated assuming 

100% coverage of the treatment units; however, treatments will only target specific plants and patches 

of vegetation. Given these circumstances, it is unlikely that someone would consume enough 

contaminated vegetation to result in exposure levels similar to those reported in Table D.01-5. These 

values and all other exposure analyses should be viewed as highly conservative estimates.

Cumulative Effects

Cumulative effects from herbicides may result from additive doses from (1) various routes of 

exposure from a single treatment (i.e. eating contaminated vegetation and drinking contaminated 

water), or (2) exposure to multiple herbicide treatments. 

In terms of repeated exposure to one particular chemical, the analysis of chronic exposure scenarios 

discussed in this risk analysis specifically addresses the potential long-term cumulative impacts 

associated with glyphosate. This risk assessment determined that there is a low likelihood of 

cumulative adverse effects associated with long-term or repeated exposures to the proposed 

chemicals. Furthermore, since glyphosate persists in the environment for a relatively short time 

(generally less than 1 year), does not bioaccumulate, and is rapidly eliminated from the body, doses 

from re-treatments in subsequent years are not expected to have additive effects. 

The most plausible situation that would result in additive doses would result from various routes of 

exposure from the Rim Reforestation project. Although each of the HQs summarized in Table D.01-4 

and Table D.01-5 involves a single exposure scenario, additive doses from multiple sources of 

exposure are inconsequential for glyphosate (SERA 2011). The only substantial exposure scenario 

involves the consumption of contaminated vegetation. All other plausible combinations of exposures 

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would not have a substantial impact on the risk characterization. Furthermore, this risk assessment 

specifically considers the effect of repeated exposure in that the chronic RfD is used as an index of 

acceptable exposure. Consequently, repeated exposure to levels below the toxic threshold should not 

be associated with cumulative toxic effects.

Application of different types of herbicides has occurred on private land within a few miles of the 

Rim Reforestation herbicide application units sometime within the last three years and could continue 

for the next five years; however, the exact location, year, type and quantity being applied by private 

landowners is unknown. Therefore, potential additive doses could occur between the Rim 

Reforestation project and foreseeable future herbicide applications on private land. Rim Reforestation 

herbicide treatments would likely start in the spring of 2017 with subsequent treatments occurring for 

up to 15 years, with less intense applications in subsequent years as the density of targeted vegetation 

decreases. Private land applications are expected to conclude by 2020. Therefore, pesticide 

application on private lands in the same year as the Rim Reforestation treatments would result in the 

worst case scenario for cumulative effects. As previously discussed, the only substantial exposure 

scenario involves the consumption of contaminated vegetation. Precautionary measures that would be 

implemented (e.g. signs and colorants) to decrease the likelihood of people gathering and consuming 

contaminated vegetation, and in most instances treated vegetation would probably show signs of 

damage from exposure, rendering it undesirable for consumption. Furthermore, all HQs were 

calculated assuming 100% coverage of the treatment units; when in fact, treatments would only target 

specific plants and patches of vegetation leaving up to 20% of the vegetation within a unit untouched. 

Given these circumstances, it is unlikely that someone would consume enough contaminated 

vegetation from multiple herbicide application units to result in gross toxicity. Therefore, potential 

future cumulative effects would not be significant.

In summary, cumulative effects from the proposed application of glyphosate under all proposed 

alternatives of the Rim Reforestation project would be insignificant.

Inert Ingredients

The approach used in the SERA Risk Assessments, and this site-specific analysis to assess the human 

health effects of inert ingredients and full formulations has been to: 1) compare acute toxicity data 

between the formulated products (including inert ingredients) and their active ingredients alone; 2) 

disclose whether or not the formulated products have undergone chronic toxicity testing; and 3) 

identify, with the help of EPA and the chemical companies, ingredients of known toxicological 

concern in the formulated products and assess the risks of those ingredients.

Although the biological endpoints between acute and chronic toxicity differ, relationships do exist. 

Therefore, acute toxicity data can be used to give an indication of overall toxicity. The court in NCAP 

v. Lyng, 844 F.2d 598 (9th Cir 1988) decided that this method of analysis provided sufficient 

information for a decision maker to make a reasoned decision. In SRCC v. Robertson, Civ. No. S-91-

217 (E.D. Cal., June 12, 1992), and again in CATS v. Dombeck, Civ. S-00-2016 (E.D. Cal., Aug 31, 

2001), the district court upheld the adequacy of the methodology used in USDA (1989) for disclosure 

of inert ingredients and additives.

The EPA categorized approximately 1,200 inert ingredients into four lists. Lists 1 and 2 contain inert 

ingredients of toxicological concer. List 3 includes substances for which EPA has insufficient 

information to classify as either hazardous (List 1 or 2) or non-toxic (List 4). List 4 contains non-toxic 

substances such as corn oil, honey and water. Use of formulations containing inert ingredients on List 

3 and 4 is preferred on vegetation management projects under current Forest Service policy.

Since most information about inert ingredients is classified as "Confidential Business Information" 

the Forest Service asked EPA to review 13 herbicides (including glyphosate) and the commercial 

formulations and advise if they contain inert ingredients of toxicological concern. The EPA 

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determined that there were no inerts on List 1 or 2. While these formulated products have not 

undergone chronic toxicity testing like their active ingredients, the acute toxicity comparisons, the 

EPA review, and our examination of toxicity information on the inert ingredients in glyphosate leads 

to the conclusion that the inert ingredients in these formulations do not significantly increase the risk 

to human health and safety over the risks identified for the active ingredients.

Additives

None of the additives (i.e. adjuvants) proposed for use contain ingredients found on the EPA’s inerts 

list 1 or 2. The assessment of hazards for these additives is limited by the proprietary nature of the 

formulations. Unless the EPA classifies a compound in the formulation as hazardous, the 

manufacturer is not required to disclose its identity. All of the additives discussed here are no more 

than slightly toxic when ingested, inhaled, or absorbed through the skin (i.e. Acute Toxicity 

Categories III or IV). Therefore, the primary summary statement that can be made is that the more 

common risk factors for the use of these additives are through skin or eye exposure. This points to the 

need for good industrial hygiene practices while utilizing these products, especially when handling 

the concentrate, such as during mixing. The use of chemical resistant gloves and goggles, especially 

while mixing, should be observed (USDA 2007c). 

Syl-tacTM

Syl-tacTM (USDA 2007c) has a “Caution” signal word. It may cause slight skin and eye irritation. It is 

of low acute oral and dermal toxicity. The oral LD50 is greater than 5 g/kg (Category IV), the dermal 

LD50 is greater than 5 g/kg (Category III), and the LC50 is greater than 2.07 ml/L (III). Syl-tacTM is a 

blend of vegetable oils and silicone based surfactants: Hasten® and Sylgard® 309.

Hasten®

Hasten® (USDA 2003; USDA 2007c; SERA 2011) has a “Caution” signal word. It may be mildly 

irritating to the skin and to the eyes. The product is of low acute oral and dermal toxicity. The oral 

LD50 is greater than 5 g/kg (Category IV), the dermal LD50 is greater than 5 g/kg (Category III), and 

the inhalation LC50 is 5.79 ml/L (Category III). The main ingredient in Hasten® is ethylated corn, 

canola, and soybean oil (a regulated food additive under 21 CFR 172.515). This is combined with 

sorbitan alkylethoxylate ester as a nonionic surfactant. The polyoxyethylene dialkylester is not 

sufficiently identified to say anything definite about its composition or toxicity. 

Hasten® contains ethoxylated ingredients. Ethoxylates are formed by reactions of ethylene oxide. In 

the manufacturing process, some unreacted ethylene oxide as well as the contaminant 1, 4-dioxane 

can become part of the final formulation. Both of these chemicals are considered likely human 

carcinogens.

The EPA considers dioxane to be a carcinogen, Class B2 (probable human carcinogen). It has a 

cancer potency factor of 0.011 (mg/kg/day)-1. The upper bound risk is equivalent to a cancer risk of 1 

in about 1.5 million.

Based on the estimated levels of exposure and the criteria for acute and chronic exposures, there is no 

evidence that typical exposures to ethoxylated surfactants will lead to dose levels that exceed the level 

of concern. It is unlikely that any worker would be utilizing such high levels of ethoxylated 

surfactants on a chronic basis, especially in the Forest Service. For a comprehensive look at the risks 

of ethylene oxide in ethoxylated surfactants, refer to USDA (2003). 

Sylgard® 309

Sylgard® 309 (USDA 2007c) has a “Warning” signal word. It is considered slightly irritating to the 

skin and is considered severely irritating to the eyes. It is not a skin sensitizer. The oral LD50 is 

greater than 2 g/kg (Category III) and the dermal LD50 is greater than 2 g/kg (Category III). The 

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main ingredients in Sylgard® 309 are 3-(3-hydroxypropyl)-heptamethyltrisiloxane, ethoxylated 

acetate (EPA List 4); allyloxy polyethylene glycol monallyl acetate (EPA List 3); and polyethylene 

glycol diacetate (EPA List 3)

Besides this acute toxicity data, the MSDS describes a 28-day oral dosing study in rats, in which rats 

were fed doses of 0, 33, 300, or 1,000 mg/kg/day. No significant findings of biological relevance 

were seen in females, while males showed some effects at highest dose (body weight gain, and 

changes in food consumption). This would indicate a subchronic NOEL of 300 mg/kg/day. Concern 

has been expressed about the toxicity of silicone-based surfactants on terrestrial insects. Research 

does indicate that the silicone-based surfactants, because of their very effective spreading ability, may 

represent a risk of lethality through the physical effect of drowning, rather than through any 

toxicological effects. Silicone surfactants are typically used at relatively low rates and are not applied 

at high spray volumes because they are very effective surfactants. Hence it is unlikely that insects 

would be exposed to rates of application that could cause the effects noted in studies.

Hi-Light® Blue

Hi-Light® Blue dye (SERA 1997; USDA 2007c) is not required to be registered as a pesticide; 

therefore it has no signal word associated with it. It is mildly irritating to the skin and eyes. It would 

likely be considered a Category III or IV material and have a “Caution” signal word if it carried one. 

It is a water-soluble dye that contains no listed hazardous substances. It is considered to be virtually 

non-toxic to humans. The dye used in Hi-Light® Blue is commonly used in toilet bowl cleaners and 

as a colorant for lakes and ponds.

ColorfastTM Purple

ColorfastTM Purple dye (SERA 1997; USDA 2007c) is not required to be registered, and therefore it 

has no signal word associated with it. It is mildly irritating to the skin, but because of the acetic acid 

content, can be severely irritating to the eyes, and can cause permanent damage. The label requires 

the use of acid-resistant gloves and goggles to prevent unnecessary exposures. It would likely be 

considered a Category I material and have a “Danger” signal word if it carried one.

Acetic acid is the ingredient in household vinegar, although vinegars are normally 4-10% acetic acid, 

whereas ColorfastTM Purple contains 23.4% by weight. Acetic acid is a very strong eye and skin 

irritant, and eye exposure can be very hazardous, with permanent damage a possibility.

Gentian Violet, a chloride salt, is the dye component of ColorfastTM Purple. It is used as an antifungal 

or antibacterial medication for dermal or mucous membrane infections. In rats, there is an indication 

that the dye accelerates the development of leukemia; however, the effect is less remarkable than that 

observed in mice. It is of moderate acute toxicity, with a LD50 value of 96 mg/kg (Category II). 

Based on SERA (1997), risk characterization leads to typical cancer risks for workers of 4.7 x 10-7 or 

1 in 2.1 million. For the public, the consumption of sprayed berries yielded an estimated single 

exposure risk of 1 in 37 million to 1 in 294 million. For public exposures, it is expected that the dye 

would reduce exposures both to itself and to the other chemicals it might be mixed with (herbicide 

and other adjuvants) as the public would be alerted to the presence of treated vegetation.

Dipropylene glycol is of low acute and chronic toxicity. It is found in many personal care products. It 

is a minor skin and eye irritant. It is not a carcinogen or a teratogen. The acute oral LD50 is 10.6 g/kg 

(IV) and the acute dermal LD50 is 20.5 g/kg (Category IV). At high (multi-gram) chronic doses, 

effects are seen to the kidney and liver. It is of low aquatic toxicity.

Connected Actions and Synergistic Effects

The most important connected action in the use of glyphosate involves surfactants. The glyphosate 

formulations proposed for use by the Rim Reforestation project recommend adding surfactants prior 

to application. As discussed in the Hazard Analysis section, the proprietary nature of surfactants 

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makes them difficult to analyze. To the extent possible, however, the use of surfactants is explicitly 

considered in this human health risk assessment. Surfactants, by their very nature, are intended to 

increase the effect of a pesticide by increasing the amount of pesticide that is in contact with the 

target (by reducing surface tension). This is not synergism, but more accurately is a reflection of 

increased dose of the herbicide active ingredient into the plant (USDA 2007c). 

As discussed in the Hazard Analysis section of this risk assessment, all of the additives proposed for 

use by the Rim reforestation project are no more than slightly toxic when ingested, inhaled, or 

absorbed through the skin (i.e. Acute Toxicity Categories III or IV). Therefore, the primary summary 

statement that can be made is that the more common risk factors for the use of these additives are 

through skin or eye exposure. This points to the need for good industrial hygiene practices while 

utilizing these products, especially when handling the concentrate, such as during mixing. The use of 

chemical resistant gloves and goggles, especially while mixing, should be observed (USDA 2007c). 

Although there is not much data in the technical literature, there is no indication of synergistic effects 

between surfactants and pesticides (USDA 2007c). There are also no definite conclusions regarding 

the potential influence of glyphosate on the toxicity of other chemicals (SERA 2011).

Sensitive Subgroups

The most sensitive subgroup for exposure to glyphosate and glyphosate formulations appears to be 

pregnant women and the developing fetus. The sensitivity of this subgroup is explicitly addressed in 

this risk assessment because the RfD used for the Exposure Analysis and Risk Characterization is 

based on a developmental study (SERA 2011). 

Some individuals suffer from Multiple Chemical Sensitivity (MCS). Individuals with MCS 

experience a variety of adverse effects as a result of exposures to very low levels of chemicals that are 

tolerated by individuals who do not have MCS. Diagnosis of and remediation measures for this 

condition are problematic, and have been suggested by some to be psychosomatic (i.e. individuals 

respond to a perception of hazard rather than to a specific chemical). Despite the ambiguous cause of 

MCS, the condition clearly exists, but is beyond the scope and authority of USDA to attempt to 

resolve concerns for MCS (SERA 2011).

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GLOSSARY

Absorption The process by which the agent is able to pass through the body membranes and enter 

the bloodstream. The main routes by which toxic agents are absorbed are the 

gastrointestinal tract, lungs, and skin.

Acute exposure A single exposure or multiple exposures occurring within a short time (24 hours or less).

Additive effect A situation in which the combined effects of two chemicals is equal to the sum of the 

effect of each chemical given alone. The effect most commonly observed when two 

chemicals are given together is an additive effect.

Adjuvant(s) Formulation factors used to enhance the pharmacological or toxic agent effect of the 

active ingredient.

Adverse-effect level 

(AEL) 

Signs of toxicity that must be detected by invasive methods, external monitoring devices, 

or prolonged systematic observations. Symptoms that are not accompanied by grossly 

observable signs of toxicity. In contrast to Frank-effect level.

Assay A kind of test (noun); to test (verb).

Carcinogen A chemical capable of inducing cancer.

Chronic exposure Long-term exposure studies often used to determine the carcinogenic potential of 

chemicals. These studies are usually performed in rats, mice, or dogs and extend over 

the average lifetime of the species (for a rat, exposure is 2 years).

Contaminants For chemicals, impurities present in a commercial grade chemical. For biological agents, 

other agents that may be present in a commercial product.

Dermal Pertaining to the skin.

Dose-response 

assessment

A description of the relationship between the dose of a chemical and the incidence of 

occurrence or intensity of an effect. In general, this relationship is plotted by statistical 

methods. Separate plots are made for experimental data obtained on different species or 

strains within a species.

Drift That portion of a sprayed chemical that is moved by wind off a target site.

Endogenous Growing or developing from or on the inside.

Enzymes A biological catalyst; a protein, produced by an organism itself, that enables the splitting 

(as in digestion) or fusion of other chemicals.

Epidemiology study A study of a human population or human populations. In toxicology, a study which 

examines the relationship of exposures to one or more potentially toxic agent to adverse 

health effects in human populations.

Estrogenic A substance that induces female hormonal activity.

Exposure 

assessment

The process of estimating the extent to which a population will come into contact with a 

chemical or biological agent.

Formulation A commercial preparation of a chemical including any inerts or contaminants.

Frank-effect level 

(FEL)

The dose or concentration of a chemical or biological agent that causes gross and 

immediately observable signs of toxicity.

Hazard quotient (HQ) The ratio of the estimated level of exposure to the RfD or some other index of acceptable 

exposure.

Hazard identification The process of identifying the array of potential effects that an agent may induce in an 

exposed human population.

Hematological Pertaining to the blood.

Herbicide A chemical used to control, suppress, or kill plants, or to severely interrupt their normal 

growth processes.

In vivo Occurring in the living organism.

In vitro Isolated from the living organism and artificially maintained, as in a test tube.

Inerts Adjuvants or additives in commercial formulations of pesticides that are not readily active 

with the other components of the mixture.

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Irritant effect A reversible effect, compared with a corrosive effect.

LC50 (lethal 

concentration50 )

A calculated concentration of a chemical in air or water to which exposure for a specific 

length of time is expected to cause death in 50% of a defined experimental animal 

population.

LD50 (lethal dose50 ) The dose of a chemical calculated to cause death in 50% of a defined experimental 

animal population over a specified observation period. The observation period is typically 

14 days.

Lowest-observedadverse-effect level 

(LOAEL)

The lowest dose of a chemical in a study, or group of studies, that produces statistically 

or biologically significant increases in frequency or severity of adverse effects between 

the exposed population and its appropriate control.

Metabolite A compound formed as a result of the metabolism or biochemical change of another 

compound.

Mutagenicity The ability to cause genetic damage (that is damage to DNA or RNA). A mutagen is 

substance that causes mutations. A mutation is change in the genetic material in a body 

cell. Mutations can lead to birth defects, miscarriages, or cancer.

No-observedadverse-effect level 

(NOAEL) 

The dose of a chemical at which no statistically or biologically significant increases in 

frequency or severity of adverse effects were observed between the exposed population 

and its appropriate control. Effects may be produced at this dose, but they are not 

considered to be adverse.

No-observed-effect 

level (NOEL)

The dose of a chemical at which no treatment-related effects were observed.

Ocular Pertaining to the eye.

Pathway In metabolism, a sequence of metabolic reactions.

Reference dose (RfD) Oral dose (mg/kg/day) not likely to be associated with adverse effects over a lifetime 

exposure, in the general population, including sensitive subgroups; or a daily dose which 

is not anticipated to cause any adverse effects in a human population over a lifetime of 

exposure. These values are derived by the EPA.

Reproductive effects Adverse effects on the reproductive system that may result from exposure to a chemical 

or biological agent. The toxicity of the agents may be directed to the reproductive organs 

or the related endocrine system. The manifestations of these effects may be noted as 

alterations in sexual behavior, fertility, pregnancy outcomes, or modifications in other 

functions dependent on the integrity of this system.

Route of exposure The way in which a chemical or biological agent enters the body. Most typical routes 

include oral (eating or drinking), dermal (contact of the agent with the skin), and 

inhalation.

Sensitive subgroup Subpopulations that are much more sensitive than the general public to certain agents in 

the environment.

Subchronic exposure An exposure duration that can last for different periods of time, but 90 days is the most 

common test duration. The subchronic study is usually performed in two species (rat and 

dog) by the route of intended use or exposure.

Synergistic effect A situation is which the combined effects of two chemicals is much greater than the sum 

of the effect of each agent given alone.

Systemic toxicity Effects that require absorption and distribution of a toxic agent to a site distant from its 

entry point at which point effects are produced. Systemic effects are the obverse of local 

effects.

Toxicity The inherent ability of an agent to affect living organisms adversely.

Xenobiotic A substance not naturally produced within an organism; substances foreign to an 

organism.

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Draft Environmental Impact Statement Treatments

E. Treatments

This Appendix provides detailed information about the treatments described in Chapter 2.01 and 

proposed in the action alternatives 1, 3, 4 and 5 (Chapter 2.02) in five sections: Reforestation (E.01); 

Natural Regeneration (E.02); Thin Existing Plantations (E.03); Deer Reforestation (E.04); and, Deer 

Habitat Enhancement (E.05). The following tables display the unit numbers with treatment acres (site

preparation, fuels reduction, planting, release, prescribed fire, etc.) using a common legend.9

E.01 REFORESTATION

Table E.01-1 Alternative 1: Reforestation Treatments

Unit FB MA FB/MA MP HC/HP HC/JP DTFC HERB/SP PLANT HERB/REL PPF

AA01B 73 73 73 73 73

AA03C 2 2 2 2 2

AA04C 4 4 4 4 4

AA04D 2 2 2 2 2

AA008 231 231 231 231

AA010 135 135 135 135

AA012 22 22 22 22

AA015 37 37 37 37

AA016 24 24 24 24

AA017 47 47 47 47

AA018 2 32 32 32 32

AA019 3 50 50 50 50

AA020 57 63 63 63 63

AA23B 10 10 10 10 10

AA23C 6 6 6 6 6

BB004 59 59 59 59

BB005 16 16 16 16

BB006 65 65 65 65

BB007 43 43 43 43

BB008 4 161 161 161 161

BB009 24 24 24 24

BB010 87 87 87 87

BB011 55 55 55 55

BB012 87 87 87 87

BB014 2 32 32 32 32

BB015 3 48 48 48 48

BB016 43 43 43 43

BB017 20 20 20 20

BB020 66 66 66 66

BB021 4 125 125 125 125

BB022 4 113 113 113 113

BB23B 2 2 2 2 2

BB23C 6 6 6 6 6

BB024 43 53 53 53 53

BB025 32 32 32 32

BB026 19 19 19 19

BB029 51 51 51 51

9 Legend: DTFC=Deep Till With Forest Cultivation; FB=Feller Buncher; GRUB=hand removal; HC=Hand Cut; HERB=manual herbicide 

application; HP=Hand Pile; JP=Jackpot Burn; MA=Masticate; MP=Machine Pile (with dozer); NAT=Natural Regeneration; PCT=PreCommercial Thin; PF=Prescribed Fire; PPF=Post-planting Prescribed Fire; SP=Site Preparation; REL=Release.

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Unit FB MA FB/MA MP HC/HP HC/JP DTFC HERB/SP PLANT HERB/REL PPF

BB033 59 59 59 59

BB035 141 141 141 141

BB036 92 92 92 92

BB040 13 13 13 13 13

BB041 35 65 65 65 65

BB43B 4 4 4 4 4

BB43C 5 5 5 5 5

BB045 22 269 269 269 269

BB047 41 41 41 41

BB049 14 198 198 198 198

BB050 44 44 44 44

BB051 101 101 101 101

BB053 75 75 75 75

BB056 12 12 12 12

BB059 8 27 27 27 27

BB060 29 29 29 29

BB062 23 23 23 23

BB063 21 21 21 21

BB064 24 24 24 24

BB065 54 54 54 54

BB066 28 28 28 28

BB71B 6 6 6 6 6

BB71C 10 10 10 10 10

BB073 21 21 21 21

BB075 12 12 12 12

BB076 38 38 38 38

BB077 9 9 9 9

BB080 2 23 23 23 23

CC009 17 17 17 17 17

CC013 11 11 11 11 11

D014 111 111 111 111

DD001 54 54 54 54

DD002 19 19 19 19

DD003 29 29 29 29

DD04B 8 8 8 8 8

DD05B 3 3 3 3 3

DD05C 5 5 5 5 5

DD006 52 52 52 52

DD007 28 28 28 28

DD013 9 9 9 9

DD014 13 13 13 13

DD015 9 9 9 9 9

DD018 17 17 17 17

E002B 14 14 14 14 14

E002C 3 3 3 3 3

E003B 16 16 16 16 16

E006B 7 7 7 7 7

E006C 27 27 27 27 27

EE03B 8 8 8 8 8

E007C 13 13 13 13 13

FF001 9 9 9 9

FF002 14 14 14 14

FF003 5 70 70 70 70

FF007 96 96 96 96

FF008 68 68 68 68

GG001 12 12 12 12

GG002 23 23 23 23

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Unit FB MA FB/MA MP HC/HP HC/JP DTFC HERB/SP PLANT HERB/REL PPF

GG08B 27 27 27 27 27

GG08C 6 6 6 6 6

GG010 41 41 41 41

GG12B 3 3 3 3 3

GG12C 2 2 2 2 2

GG015 19 19 19 19

GG020 12 265 265 265 265

GG021 8 8 8 8

GG023 76 76 76 76

GG025 52 52 52 52

GG026 6 6 6 6

GG027 346 346 346 346

GG031 34 34 34 34

GG032 9 9 9 9

GG034 24 24 24 24

GG37B 12 12 12 12 12

GG37C 30 30 30 30 30

GG048 14 14 14 14 14

GG50B 28 28 28 28 28

GG50C 4 4 4 4 4

GG51B 57 57 57 57 57

GG55B 24 24 24 24 24

GG55C 13 13 13 13 13

GG56B 2 2 2 2 2

GG56C 5 5 5 5 5

GG56D 1 1 1 1 1

GG57B 16 16 16 16 16

GG57C 14 14 14 14 14

GG58A 2 2 2 2 2

GG063 21 21 21 21 21

H009C 31 31 31 31 31

H011B 11 11 11 11 11

H011D 27 27 27 27 27

H016 24 24 24 24 24

H017 47 47 47 47 47

H032B 17 17 17 17 17

H033B 11 11 11 11 11

H034B 7 7 7 7 7

H039 27 27 27 27 27

H049B 7 7 7 7 7

H065 13 13 13 13

H068 54 54 54 54

HH001 67 67 67 67

HH002 93 93 93 93

HH003 116 116 116 116

HH006 104 104 104 104

HH007 22 22 22 22

HH008 9 9 9 9

HH009 22 22 22 22

HH010 41 41 41 41

HH011 46 46 46 46

HH012 34 34 34 34

HH013 3 64 64 64 64

HH014 22 131 131 131 131

HH015 83 83 83 83

HH016 50 50 50 50

HH17B 10 10 10 10 10

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Unit FB MA FB/MA MP HC/HP HC/JP DTFC HERB/SP PLANT HERB/REL PPF

HH018 11 47 47 47 47

HH20C 11 11 11 11 11

HH028 18 18 18 18

HH029 107 116 116 116 116

HH037 5 37 37 37 37

HH038 37 93 93 93 93

HH39B 13 13 13 13 13

HH40B 3 3 3 3 3

HH42B 16 16 16 16 16

HH45D 108 108 108 108 108

HH45E 55 55 55 55 55

I007B 24 24 24 24 24

I007C 21 21 21 21 21

I009D 51 51 51 51 51

I009E 5 5 5 5 5

I014B 59 59 59 59 59

I015 37 37 37 37 37

I017C 19 19 19 19 19

I020B 24 24 24 24 24

I024C 1 1 1 1 1

I024D 4 4 4 4 4

I025C 24 24 24 24 24

I025D 6 6 6 6 6

I028B 2 2 2 2 2

I028C 12 12 12 12 12

I029C 6 6 6 6 6

I033B 6 6 6 6 6

I047B 3 3 3 3 3

I047C 11 11 11 11 11

I048B 3 3 3 3 3

I058B 2 2 2 2 2

I058C 3 3 3 3 3

I058D 13 13 13 13 13

I060B 58 58 58 58 58

I061B 12 12 12 12 12

I062C 15 15 15 15 15

I063B 15 15 15 15 15

I063C 3 3 3 3 3

I065A 2 2 2 2 2

I065C 4 4 4 4 4

I070A 11 11 11 11 11

I070C 8 8 8 8 8

I071B 8 8 8 8 8

I071C 2 2 2 2 2

I072C 45 45 45 45 45

I073B 3 3 3 3 3

I073C 36 36 36 36 36

I075B 12 12 12 12 12

I075C 2 2 2 2 2

I080B 12 12 12 12 12

I084B 29 29 29 29 29

I086B 7 7 7 7 7

I088A 11 11 11 11 11

I089B 22 22 22 22 22

I090B 11 11 11 11 11

I096 20 20 20 20 20

I099B 5 5 5 5 5

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Unit FB MA FB/MA MP HC/HP HC/JP DTFC HERB/SP PLANT HERB/REL PPF

I099C 1 1 1 1 1

I100C 64 64 64 64 64

I101A 5 5 5 5 5

I102B 3 3 3 3 3

I103C 8 8 8 8 8

I104C 23 23 23 23 23

I104D 3 3 3 3 3

I109B 11 11 11 11 11

I110B 6 6 6 6 6

I111B 8 8 8 8 8

I112B 6 6 6 6 6

I113C 9 9 9 9 9

I121A 3 3 3 3 3

I121B 5 5 5 5 5

I121C 3 3 3 3 3

I122C 13 13 13 13 13

I122D 5 5 5 5 5

I122E 24 24 24 24 24

I123B 35 35 35 35 35

I124B 19 19 19 19 19

I125B 18 18 18 18 18

I126B 14 14 14 14 14

I127 24 24 24 24 24

I128C 16 16 16 16 16

I129 30 30 30 30 30

I130 34 34 34 34 34

I131B 27 27 27 27 27

I132B 54 54 54 54 54

I133 19 19 19 19 19

I134B 22 22 22 22 22

I135B 13 13 13 13 13

I136B 2 2 2 2 2

I136C 22 22 22 22 22

I137B 36 36 36 36 36

I138 21 21 21 21 21

I139 25 25 25 25 25

I140B 40 40 40 40 40

J001 69 69 69 69

J002 243 243 243 243

J003 100 100 100 100

J004 73 73 73 73

J005 161 161 161 161

J012 46 46 46 46

K010C 119 119 119 119 119

K011B 2 2 2 2 2

K011C 15 15 15 15 15

K015B 39 39 39 39 39

K018A 75 75 75 75 75

L001 188 188 188 188 188

L002 92 96 96 96 96

L003 86 100 100 100 100

L005 97 120 120 120 120

L006 116 116 116 116

L007 111 111 111 111

L008 152 152 152 152

L009 66 66 66 66

L010 22 22 22 22

551
Appendix E Stanislaus

Treatments National Forest

Unit FB MA FB/MA MP HC/HP HC/JP DTFC HERB/SP PLANT HERB/REL PPF

L011 48 48 48 48

L014 155 155 155 155 155

M001C 67 67 67 67 67

M001E 102 102 102 102 102

M001G 182 182 182 182 182

M004B 121 121 121 121 121

M009B 29 29 29 29 29

M010B 29 29 29 29 29

M010D 44 44 44 44 44

M011A 28 28 28 28 28

M014A 7 7 7 7 7

M014C 9 9 9 9 9

M017B 62 62 62 62 62

M017C 33 33 33 33 33

M020A 19 19 19 19 19

M020C 31 31 31 31 31

M024B 156 156 156 156 156

M025 219 219 219 219

N010B 113 113 113 113 113

N019 213 221 221 221 221

P010 61 61 61 61

P011 23 23 23 23

P014 4 255 255 255 255

P021 149 149 149 149

P022 61 61 61 61

Q002B 248 248 248 248 248

Q002C 10 10 10 10 10

Q002D 3 3 3 3 3

Q003 21 21 21 21

Q004 32 32 32 32

Q005 9 9 9 9

Q006 24 24 24 24

Q007 33 33 33 33

Q008 29 29 29 29

Q009 88 88 88 88

Q010 24 24 24 24

Q013 23 23 23 23

Q014 24 24 24 24

Q015 46 46 46 46

Q016 75 75 75 75

Q017 73 73 73 73

R001 185 185 185 185

R002 4 92 92 92 92

R003 38 38 38 38

R004 104 121 121 121 121

R005 49 49 49 49

R006 39 39 39 39

R007B 3 3 3 3 3

R007C 16 16 16 16 16

R008 9 9 9 9

R009 19 19 19 19

R011 54 54 54 54

R012 48 48 48 48

R013 41 41 41 41

R014B 65 65 65 65 65

R015 15 15 15 15

R016 38 38 38 38

552
Rim Fire Reforestation (45612) Appendix E

Draft Environmental Impact Statement Treatments

Unit FB MA FB/MA MP HC/HP HC/JP DTFC HERB/SP PLANT HERB/REL PPF

R017 14 14 14 14

R019 33 33 33 33

R020 13 13 13 13

R021 21 21 21 21

R022 72 72 72 72

R024 85 85 85 85

R025 174 174 174 174

R026 9 48 48 48 48

R027 60 60 60 60

R028 17 17 17 17

R029 10 10 10 10

R030 24 24 24 24

R031 30 30 30 30

R032 30 30 30 30

R034 33 33 33 33

R036 17 17 17 17

R037 13 132 132 132 132

R038 46 46 46 46

R039 5 10 10 10 10

R046 233 233 233 233

S001 282 282 282 282

S006 32 32 32 32

S007 106 106 106 106

T002 52 52 52 52

T003 78 78 78 78

T004 20 20 20 20

T005 116 116 116 116

T006 461 461 461 461

T007 342 342 342 342

T008 32 32 32 32

T009 47 47 47 47

T010 94 94 94 94

T011 198 198 198 198

T012 71 71 71 71

T013 80 80 80 80

T014 18 18 18 18

T015 14 64 64 64 64

T017 7 45 45 45 45

T019 9 36 36 36 36

T025 71 71 71 71

U003 239 239 239 239

U004 50 50 50 50 50

U005 18 18 18 18

U008 15 15 15 15

U009 48 48 48 48

U010 1 13 13 13 13

U011 24 24 24 24

U012 94 94 94 94

U013 51 51 51 51

U014 5 5 5 5

U015 12 40 40 40 40

U016 28 28 28 28

U018 97 97 97 97

U019 130 130 130 130

U020 51 51 51 51

U021 10 10 10 10

V010B 55 55 55 55 55

553
Appendix E Stanislaus

Treatments National Forest

Unit FB MA FB/MA MP HC/HP HC/JP DTFC HERB/SP PLANT HERB/REL PPF

V012 88 112 112 112 112

V014B 23 23 23 23 23

V015 32 32 32 32 32

V022B 5 5 5 5 5

V022C 11 11 11 11 11

V022D 11 11 11 11 11

V023B 16 16 16 16 16

V024 237 237 237 237 237

W002 226 226 226 226

W003 73 73 73 73

W004B 8 8 8 8 8

W004C 4 4 4 4 4

X003 20 20 20 20

X011 22 22 22 22

X013B 2 2 2 2 2

X013C 3 3 3 3 3

X014 46 46 46 46

X015 64 64 64 64

X019 73 73 73 73

X021 34 34 34 34

X025 12 12 12 12

X026 48 48 48 48

X028 74 74 74 74

X033 4 65 65 65 65

X035 67 67 67 67

X036 240 240 240 240

X037 88 88 88 88

Y002C 86 86 86 86 86

Y008 3 33 33 33 33

Y010 25 25 25 25 25

Y011 10 10 10 10 10

Y014 23 23 23 23 23

Y015 18 18 18 18 18

Y016 17 17 17 17 17

Y018 47 48 48 48 48

Y020 4 50 50 50 50

Y025 69 69 69 69

Y028 6 6 6 6

Y029 52 52 52 52

Y030 143 143 143 143

Z006 20 20 20 20

Z008 15 15 15 15

Z011 91 91 91 91

Z013 38 38 38 38

Z014 17 17 17 17

Z016 7 60 60 60 60

Z017 20 20 20 20

Z018 7 7 7 7

Z020 36 36 36 36

Z021 4 43 43 43 43

Z024 50 50 50 50

Z027 88 88 88 88

Z028 137 137 137 137

Z029 32 32 32 32

Z030 18 44 44 44 44

Total 3,139 1,493 351 912 74 237 5,085 16,215 21,300 21,300 21,300

554
Rim Fire Reforestation (45612) Appendix E

Draft Environmental Impact Statement Treatments

Table E.01-2 Alternative 3: Reforestation Treatments

Unit FB MA FB/MA MP HC/HP HC/JP DTFC PLANT GRUB PPF

AA01B 73 73 73 73 73

AA03C 2 2 2 2

AA04C 4 4 4 4 4

AA04D 2 2 2 2 2

AA008 231 231 231 231

AA010 135 135 135 135

AA012 22 22 22 22

AA015 37 37 37 37

AA016 24 24 24

AA017 47 47 47

AA018 2 32 32 32

AA019 3 50 50 50

AA020 57 63 63 63

AA23B 10 10 10 10

AA23C 6 6 6 6

BB004 59 59 59 59

BB005 16 16 16

BB006 65 65 65 65

BB007 43 43 43

BB008 4 161 161 161 161

BB009 24 24 24 24

BB010 87 87 87 87

BB011 55 55 55 55

BB012 87 87 87

BB014 2 32 32 32 32

BB015 3 48 48 48 48

BB016 43 43 43

BB017 20 20 20

BB020 66 66 66 66

BB021 4 125 125 125 125

BB022 4 113 113 113

BB23B 2 2 2 2

BB23C 6 6 6 6

BB024 43 53 53 53

BB025 32 32 32 32

BB026 19 19 19 19

BB029 51 51 51 51

BB033 59 59 59 59

BB035 141 141 141 141

BB036 92 92 92 92

BB040 13 13 13 13

BB041 35 65 65 65

BB43B 4 4 4 4

BB43C 5 5 5 5

BB045 22 269 269 269

BB047 41 41 41 41

BB049 14 198 198 198

BB050 44 44 44

BB051 101 101 101

BB053 75 75 75

BB056 12 12 12

BB059 8 27 27 27

BB060 29 29 29

BB062 23 23 23 23

BB063 21 21 21

555
Appendix E Stanislaus

Treatments National Forest

Unit FB MA FB/MA MP HC/HP HC/JP DTFC PLANT GRUB PPF

BB064 24 24 24

BB065 54 54 54 54

BB066 28 28 28 28

BB71B 6 6 6 6

BB71C 10 10 10 10

BB073 21 21 21 21

BB075 12 12 12 12

BB076 38 38 38 38

BB077 9 9 9

BB080 2 23 23 23 23

CC009 17 17 17 17 17

CC013 11 11 11 11

D014 111 111 111 111

DD001 54 54 54

DD002 19 19 19

DD003 29 29 29 29

DD04B 8 8 8 8

DD05B 3 3 3 3 3

DD05C 5 5 5 5 5

DD006 52 52 52

DD007 28 28 28

DD013 9 9 9

DD014 13 13 13

DD015 9 9 9 9

DD018 17 17 17 17

E002B 14 14 14 14 14

E002C 3 3 3 3

E003B 16 16 16 16

E006B 7 7 7 7

E006C 27 27 27 27

EE03B 8 8 8 8

E007C 13 13 13 13

FF001 9 9 9

FF002 14 14 14

FF003 5 70 70 70

FF007 96 96 96 96

FF008 68 68 68 68

GG001 12 12 12

GG002 23 23 23

GG08B 27 27 27 27

GG08C 6 6 6 6

GG010 41 41 41

GG12B 3 3 3 3

GG12C 2 2 2 2

GG015 19 19 19

GG020 12 265 265 265

GG021 8 8 8

GG023 76 76 76

GG025 52 52 52

GG026 6 6 6

GG027 346 346 346

GG031 34 34 34

GG032 9 9 9 9

GG034 24 24 24

GG37B 12 12 12 12

GG37C 30 30 30 30

GG048 14 14 14 14

556
Rim Fire Reforestation (45612) Appendix E

Draft Environmental Impact Statement Treatments

Unit FB MA FB/MA MP HC/HP HC/JP DTFC PLANT GRUB PPF

GG50B 28 28 28 28

GG50C 4 4 4 4

GG51B 57 57 57 57

GG55B 24 24 24 24

GG55C 13 13 13 13

GG56B 2 2 2 2

GG56C 5 5 5 5

GG56D 1 1 1 1

GG57B 16 16 16 16

GG57C 14 14 14 14

GG58A 2 2 2 2 2

GG063 21 21 21 21

H009C 31 31 31 31

H011B 11 11 11 11

H011D 27 27 27 27

H016 24 24 24 24

H017 47 47 47 47

H032B 17 17 17 17

H033B 11 11 11 11

H034B 7 7 7 7

H039 27 27 27 27

H049B 7 7 7 7

H065 13 13 13

H068 54 54 54

HH001 67 67 67 67

HH002 93 93 93

HH003 116 116 116 116

HH006 104 104 104 104

HH007 22 22 22

HH008 9 9 9

HH009 22 22 22 22

HH010 41 41 41 41

HH011 46 46 46 46

HH012 34 34 34

HH013 3 64 64 64 64

HH014 22 131 131 131 131

HH015 83 83 83

HH016 50 50 50

HH17B 10 10 10 10

HH018 11 47 47 47

HH20C 11 11 11 11

HH028 18 18 18 18

HH029 107 116 116 116 116

HH037 5 37 37 37

HH038 37 93 93 93

HH39B 13 13 13 13 13

HH40B 3 3 3 3 3

HH42B 16 16 16 16 16

HH45D 108 108 108 108 108

HH45E 55 55 55 55 55

I007B 24 24 24 24

I007C 21 21 21 21

I009D 51 51 51 51

I009E 5 5 5 5

I014B 59 59 59 59

I015 37 37 37 37

I017C 19 19 19 19

557
Appendix E Stanislaus

Treatments National Forest

Unit FB MA FB/MA MP HC/HP HC/JP DTFC PLANT GRUB PPF

I020B 24 24 24 24

I024C 1 1 1 1

I024D 4 4 4 4

I025C 24 24 24 24

I025D 6 6 6 6

I028B 2 2 2 2

I028C 12 12 12 12

I029C 6 6 6 6

I033B 6 6 6 6

I047B 3 3 3 3

I047C 11 11 11 11

I048B 3 3 3 3

I058B 2 2 2 2

I058C 3 3 3 3

I058D 13 13 13 13

I060B 58 58 58 58 58

I061B 12 12 12 12

I062C 15 15 15 15

I063B 15 15 15 15

I063C 3 3 3 3

I065A 2 2 2 2 2

I065C 4 4 4 4 4

I070A 11 11 11 11

I070C 8 8 8 8

I071B 8 8 8 8

I071C 2 2 2 2

I072C 45 45 45 45

I073B 3 3 3 3

I073C 36 36 36 36

I075B 12 12 12 12 12

I075C 2 2 2 2 2

I080B 12 12 12 12

I084B 29 29 29 29 29

I086B 7 7 7 7

I088A 11 11 11 11

I089B 22 22 22 22 22

I090B 11 11 11 11

I096 20 20 20 20

I099B 5 5 5 5

I099C 1 1 1 1

I100C 64 64 64 64

I101A 5 5 5 5

I102B 3 3 3 3

I103C 8 8 8 8

I104C 23 23 23 23

I104D 3 3 3 3

I109B 11 11 11 11

I110B 6 6 6 6

I111B 8 8 8 8

I112B 6 6 6 6

I113C 9 9 9 9

I121A 3 3 3 3

I121B 5 5 5 5

I121C 3 3 3 3

I122C 13 13 13 13

I122D 5 5 5 5

I122E 24 24 24 24

558
Rim Fire Reforestation (45612) Appendix E

Draft Environmental Impact Statement Treatments

Unit FB MA FB/MA MP HC/HP HC/JP DTFC PLANT GRUB PPF

I123B 35 35 35 35

I124B 19 19 19 19

I125B 18 18 18 18

I126B 14 14 14 14

I127 24 24 24 24

I128C 16 16 16 16

I129 30 30 30 30

I130 34 34 34 34

I131B 27 27 27 27

I132B 54 54 54 54

I133 19 19 19 19

I134B 22 22 22 22

I135B 13 13 13 13

I136B 2 2 2 2

I136C 22 22 22 22

I137B 36 36 36 36

I138 21 21 21 21

I139 25 25 25 25

I140B 40 40 40 40

J001 69 69 69

J002 243 243 243

J003 100 100 100

J004 73 73 73

J005 161 161 161

J012 46 46 46

K010C 119 119 119 119

K011B 2 2 2 2

K011C 15 15 15 15

K015B 39 39 39 39

K018A 75 75 75 75 75

L001 188 188 188 188

L002 92 96 96 96

L003 86 100 100 100

L005 97 120 120 120 120

L006 116 116 116

L007 111 111 111

L008 152 152 152

L009 66 66 66

L010 22 22 22 22

L011 48 48 48 48

L014 155 155 155 155 155

M001C 67 67 67 67

M001E 102 102 102 102

M001G 182 182 182 182

M004B 121 121 121 121

M009B 29 29 29 29

M010B 29 29 29 29

M010D 44 44 44 44

M011A 28 28 28 28

M014A 7 7 7 7

M014C 9 9 9 9

M017B 62 62 62 62

M017C 33 33 33 33

M020A 19 19 19 19

M020C 31 31 31 31

M024B 156 156 156 156

M025 219 219 219

559
Appendix E Stanislaus

Treatments National Forest

Unit FB MA FB/MA MP HC/HP HC/JP DTFC PLANT GRUB PPF

N010B 113 113 113 113 113

N019 213 221 221 221 221

P010 61 61 61 61

P011 23 23 23

P014 4 255 255 255 255

P021 149 149 149

P022 61 61 61

Q002B 248 248 248 248

Q002C 10 10 10 10

Q002D 3 3 3 3

Q003 21 21 21 21

Q004 32 32 32

Q005 9 9 9 9

Q006 24 24 24 24

Q007 33 33 33 33

Q008 29 29 29 29

Q009 88 88 88

Q010 24 24 24

Q013 23 23 23 23

Q014 24 24 24 24

Q015 46 46 46 46

Q016 75 75 75 75

Q017 73 73 73

R001 185 185 185

R002 4 92 92 92

R003 38 38 38

R004 104 121 121 121

R005 49 49 49 49

R006 39 39 39

R007B 3 3 3 3 3

R007C 16 16 16 16 16

R008 9 9 9 9

R009 19 19 19

R011 54 54 54 54

R012 48 48 48 48

R013 41 41 41

R014B 65 65 65 65 65

R015 15 15 15

R016 38 38 38

R017 14 14 14

R019 33 33 33

R020 13 13 13

R021 21 21 21 21

R022 72 72 72 72

R024 85 85 85 85

R025 174 174 174 174

R026 9 48 48 48

R027 60 60 60

R028 17 17 17 17

R029 10 10 10 10

R030 24 24 24 24

R031 30 30 30 30

R032 30 30 30 30

R034 33 33 33

R036 17 17 17 17

R037 13 132 132 132

R038 46 46 46 46

560
Rim Fire Reforestation (45612) Appendix E

Draft Environmental Impact Statement Treatments

Unit FB MA FB/MA MP HC/HP HC/JP DTFC PLANT GRUB PPF

R039 5 10 10 10

R046 233 233 233 233

S001 282 282 282 282

S006 32 32 32

S007 106 106 106

T002 52 52 52 52

T003 78 78 78

T004 20 20 20

T005 116 116 116

T006 461 461 461 461

T007 342 342 342 342

T008 32 32 32 32

T009 47 47 47 47

T010 94 94 94

T011 198 198 198 198

T012 71 71 71

T013 80 80 80

T014 18 18 18

T015 14 64 64 64 64

T017 7 45 45 45

T019 9 36 36 36 36

T025 71 71 71

U003 239 239 239 239

U004 50 50 50 50

U005 18 18 18 18

U008 15 15 15 15

U009 48 48 48

U010 1 13 13 13

U011 24 24 24 24

U012 94 94 94

U013 51 51 51

U014 5 5 5 5

U015 12 40 40 40

U016 28 28 28 28

U018 97 97 97

U019 130 130 130

U020 51 51 51

U021 10 10 10

V010B 55 55 55 55

V012 88 112 112 112 112

V014B 23 23 23 23

V015 32 32 32 32 32

V022B 5 5 5 5

V022C 11 11 11 11

V022D 11 11 11 11

V023B 16 16 16 16

V024 237 237 237 237

W002 226 226 226 226

W003 73 73 73

W004B 8 8 8 8 8

W004C 4 4 4 4 4

X003 20 20 20 20

X011 22 22 22 22

X013B 2 2 2 2 2

X013C 3 3 3 3 3

X014 46 46 46

X015 64 64 64 64

561
Appendix E Stanislaus

Treatments National Forest

Unit FB MA FB/MA MP HC/HP HC/JP DTFC PLANT GRUB PPF

X019 73 73 73

X021 34 34 34

X025 12 12 12 12

X026 48 48 48 48

X028 74 74 74 74

X033 4 65 65 65

X035 67 67 67 67

X036 240 240 240 240

X037 88 88 88

Y002C 86 86 86 86

Y008 3 33 33 33

Y010 25 25 25 25 25

Y011 10 10 10 10 10

Y014 23 23 23 23 23

Y015 18 18 18 18 18

Y016 17 17 17 17

Y018 47 48 48 48

Y020 4 50 50 50 50

Y025 69 69 69

Y028 6 6 6 6

Y029 52 52 52 52

Y030 143 143 143

Z006 20 20 20

Z008 15 15 15

Z011 91 91 91

Z013 38 38 38 38

Z014 17 17 17

Z016 7 60 60 60

Z017 20 20 20

Z018 7 7 7

Z020 36 36 36

Z021 4 43 43 43

Z024 50 50 50

Z027 88 88 88 88

Z028 137 137 137 137

Z029 32 32 32 32

Z030 18 44 44 44

Total 3,139 1,493 351 912 74 237 8,893 21,300 21,300 21,300

562
Rim Fire Reforestation (45612) Appendix E

Draft Environmental Impact Statement Treatments

Table E.01-3 Alternative 4: Reforestation Treatments

Unit FB MA MP HC/JP HERB/SP PLANT HERB/REL PPF

AA008 46 46 65 46

AA010 27 27 38 27

AA012 4 4 6 4

AA015 7 7 10 7

AA016 5 5 7 5

AA017 9 9 13 9

AA018 2 6 6 9 6

AA019 3 10 10 14 10

BB004 12 12 17 12

BB005 3 3 5 3

BB006 13 13 18 13

BB007 9 9 12 9

BB008 4 32 32 45 32

BB009 5 5 7 5

BB010 17 17 24 17

BB011 11 11 15 11

BB012 17 17 24 17

BB014 2 6 6 9 6

BB015 3 10 10 13 10

BB016 9 9 12 9

BB017 4 4 5 4

BB020 13 13 18 13

BB021 4 25 25 35 25

BB022 4 23 23 32 23

BB025 6 6 9 6

BB026 4 4 5 4

BB029 10 10 14 10

BB033 12 12 17 12

BB035 28 28 39 28

BB036 18 18 26 18

BB040 4 3 3 4 3

BB041 18 13 13 18 13

BB045 22 54 54 75 54

BB047 8 8 12 8

BB049 14 40 40 55 40

BB050 9 9 12 9

BB051 20 20 28 20

BB053 15 15 21 15

BB059 8 5 5 8 5

BB060 6 6 8 6

BB062 5 5 6 5

BB063 4 4 6 4

BB064 5 5 7 5

BB065 11 11 15 11

BB066 6 6 8 6

BB073 4 4 6 4

BB075 2 2 3 2

BB076 8 8 11 8

D014 22 22 31 22

DD006 10 10 15 10

DD007 6 6 8 6

DD014 3 3 4 3

FF002 3 3 4 3

FF003 5 14 14 20 14

FF007 19 19 27 19

563
Appendix E Stanislaus

Treatments National Forest

Unit FB MA MP HC/JP HERB/SP PLANT HERB/REL PPF

FF008 14 14 19 14

GG010 8 8 11 8

GG015 4 4 5 4

GG020 12 53 53 74 53

GG023 15 15 21 15

GG025 10 10 15 10

GG027 69 69 97 69

GG031 7 7 9 7

GG034 5 5 7 5

H065 3 3 4 3

H068 11 11 15 11

HH001 13 13 19 13

HH003 23 23 32 23

HH006 21 21 29 21

HH007 4 4 6 4

HH009 4 4 6 4

HH010 8 8 11 8

HH011 9 9 13 9

HH012 7 7 9 7

HH013 3 13 13 18 13

HH014 22 26 26 37 26

HH015 17 17 23 17

HH018 11 9 9 13 9

HH028 4 4 5 4

HH038 26 19 19 26 19

J001 14 14 19 14

J002 49 49 68 49

J003 20 20 28 20

J004 15 15 20 15

J005 32 32 45 32

J012 9 9 13 9

L006 23 23 33 23

L007 22 22 31 22

L008 30 30 43 30

L009 13 13 19 13

L010 4 4 6 4

L011 10 10 14 10

M025 44 44 61 44

P014 4 51 51 71 51

P021 30 30 42 30

Q006 5 5 7 5

Q007 7 7 9 7

Q008 6 6 8 6

Q009 18 18 25 18

Q013 5 5 6 5

Q014 5 5 7 5

Q015 9 9 13 9

Q016 15 15 21 15

R001 37 37 52 37

R002 4 18 18 26 18

R003 8 8 11 8

R004 34 24 24 34 24

R005 10 10 14 10

R006 8 8 11 8

R011 11 11 15 11

R012 10 10 14 10

R013 8 8 11 8

564
Rim Fire Reforestation (45612) Appendix E

Draft Environmental Impact Statement Treatments

Unit FB MA MP HC/JP HERB/SP PLANT HERB/REL PPF

R015 3 3 4 3

R016 8 8 11 8

R019 7 7 9 7

R021 4 4 6 4

R022 14 14 20 14

R024 18 18 24 18

R025 35 35 49 35

R026 9 10 10 14 10

R027 12 12 17 12

R028 3 3 5 3

R030 5 5 7 5

R031 6 6 8 6

R032 6 6 8 6

R034 7 7 9 7

R036 3 3 5 3

R037 13 26 26 37 26

R038 9 9 13 9

R046 47 47 65 47

S001 56 56 79 56

S006 6 6 9 6

S007 21 21 30 21

T002 10 10 15 10

T003 16 16 22 16

T004 4 4 6 4

T005 23 23 33 23

T006 92 92 129 92

T007 68 68 96 68

T008 6 6 9 6

T010 19 19 26 19

T011 40 40 55 40

T012 14 14 20 14

T013 16 16 23 16

T014 4 4 5 4

T015 14 13 13 18 13

T019 9 7 7 10 7

T025 14 14 20 14

U003 48 48 67 48

U004 14 10 10 14 10

U005 4 4 5 4

U010 1 3 3 4 3

U011 5 5 7 5

U012 19 19 26 19

U013 10 10 14 10

U015 11 8 8 11 8

U018 19 19 27 19

U019 26 26 36 26

U020 10 10 14 10

U021 2 2 3 2

W002 45 45 63 45

W003 15 15 20 15

X011 4 4 6 4

X014 9 9 13 9

X015 13 13 18 13

X019 15 15 20 15

X021 7 7 9 7

X025 2 2 3 2

X028 15 15 21 15

565
Appendix E Stanislaus

Treatments National Forest

Unit FB MA MP HC/JP HERB/SP PLANT HERB/REL PPF

X033 4 13 13 18 13

X035 13 13 19 13

X036 48 48 67 48

X037 18 18 25 18

Y020 4 10 10 14 10

Y025 14 14 19 14

Y029 10 10 15 10

Y030 29 29 40 29

Z006 4 4 6 4

Z008 3 3 4 3

Z011 18 18 26 18

Z013 8 8 11 8

Z014 3 3 5 3

Z016 7 12 12 17 12

Z017 4 4 5 4

Z020 7 7 10 7

Z021 4 9 9 12 9

Z024 10 10 14 10

Z027 18 18 25 18

Z028 27 27 38 27

Z029 6 6 9 6

Total 140 32 76 51 2,867 2,867 4,012 2,867

566
Rim Fire Reforestation (45612) Appendix E

Draft Environmental Impact Statement Treatments

Table E.01-4 Alternative 5: Reforestation Treatments

Unit FB MA FB/MA MP HC/HP HC/JP DTFC HERB/SP PLANT HERB/REL PPF

AA01B 73 73 73 73 73

AA03C 2 2 2 2 2

AA04C 4 4 4 4 4

AA04D 2 2 2 2 2

AA008 231 231 231 231

AA010 135 135 135 135

AA012 22 22 22 22

AA015 37 37 37 37

AA016 24 24 24 24

AA017 47 47 47 47

AA018 2 32 32 32 32

AA019 3 50 50 50 50

AA020 57 63 63 63 63

AA23B 10 10 10 10 10

AA23C 6 6 6 6 6

B001 62 62 62 62

B002 100 100 100 100

BB004 59 59 59 59

BB005 16 16 16 16

BB006 65 65 65 65

BB007 43 43 43 43

BB008 4 161 161 161 161

BB009 24 24 24 24

BB010 87 87 87 87

BB011 55 55 55 55

BB012 87 87 87 87

BB014 2 32 32 32 32

BB015 3 48 48 48 48

BB016 43 43 43 43

BB017 20 20 20 20

BB020 66 66 66 66

BB021 4 125 125 125 125

BB022 4 113 113 113 113

BB23B 2 2 2 2 2

BB23C 6 6 6 6 6

BB024 43 53 53 53 53

BB025 32 32 32 32

BB026 19 19 19 19

BB028 162 162 162 162

BB029 51 51 51 51

BB033 59 59 59 59

BB035 141 141 141 141

BB036 92 92 92 92

BB038 3 25 25 25 25

BB040 13 13 13 13 13

BB041 35 65 65 65 65

BB43B 4 4 4 4 4

BB43C 5 5 5 5 5

BB045 22 269 269 269 269

BB046 13 13 13 13

BB047 41 41 41 41

BB049 14 198 198 198 198

BB050 44 44 44 44

BB051 101 101 101 101

BB053 75 75 75 75

567
Appendix E Stanislaus

Treatments National Forest

Unit FB MA FB/MA MP HC/HP HC/JP DTFC HERB/SP PLANT HERB/REL PPF

BB055 11 11 11 11

BB056 12 12 12 12

BB057 28 28 28 28

BB059 8 27 27 27 27

BB060 29 29 29 29

BB062 23 23 23 23

BB063 21 21 21 21

BB064 24 24 24 24

BB065 54 54 54 54

BB066 28 28 28 28

BB069 72 72 72 72

BB71B 6 6 6 6 6

BB71C 10 10 10 10 10

BB072 29 29 29 29

BB073 21 21 21 21

BB075 12 12 12 12

BB076 38 38 38 38

BB077 9 9 9 9

BB080 2 23 23 23 23

BB083 94 94 94 94

CC009 17 17 17 17 17

CC010 11 11 11 11

CC013 11 11 11 11 11

D014 111 111 111 111

DD001 54 54 54 54

DD002 19 19 19 19

DD003 29 29 29 29

DD04B 8 8 8 8 8

DD05B 3 3 3 3 3

DD05C 5 5 5 5 5

DD006 52 52 52 52

DD007 28 28 28 28

DD013 9 9 9 9

DD014 13 13 13 13

DD015 9 9 9 9 9

DD016 83 83 83 83

DD018 17 17 17 17

E002B 14 14 14 14 14

E002C 3 3 3 3 3

E003B 16 16 16 16 16

E006B 7 7 7 7 7

E006C 27 27 27 27 27

E007C 13 13 13 13 13

E008 8 17 17 17 17

E009 42 42 42 42

E010 11 11 11 11

E011 26 26 26 26

E012 31 31 31 31

EE03B 8 8 8 8 8

EE013 34 34 34 34

FF001 9 9 9 9

FF002 14 14 14 14

FF003 5 70 70 70 70

F007 65 65 65 65

FF007 96 96 96 96

FF008 68 68 68 68

FF009 61 61 61 61

568
Rim Fire Reforestation (45612) Appendix E

Draft Environmental Impact Statement Treatments

Unit FB MA FB/MA MP HC/HP HC/JP DTFC HERB/SP PLANT HERB/REL PPF

FF010 34 34 34 34

G011 16 16 16 16

G012 5 5 5 5 5

G013 5 5 5 5

G014 176 176 176 176 176

G015 4 4 4 4

GG001 12 12 12 12

GG002 23 23 23 23

GG004 7 7 7 7

GG005 43 43 43 43

GG006 3 3 3 3

GG007 65 65 65 65

GG08B 27 27 27 27 27

GG08C 6 6 6 6 6

GG010 41 41 41 41

GG12B 3 3 3 3 3

GG12C 2 2 2 2 2

GG013 23 23 23 23

GG015 19 19 19 19

GG020 12 265 265 265 265

GG021 8 8 8 8

GG022 27 27 27 27

GG023 76 76 76 76

GG024 75 75 75 75

GG025 52 52 52 52

GG026 6 6 6 6

GG027 346 346 346 346

GG028 70 70 70 70

GG029 183 183 183 183

GG030 13 13 13 13

GG031 34 34 34 34

GG032 9 9 9 9

GG033 18 18 18 18

GG034 24 24 24 24

GG035 72 72 72 72

GG036 28 28 28 28

GG37B 12 12 12 12 12

GG37C 30 30 30 30 30

GG041 18 49 49 49 49

GG042 26 26 26 26 26

GG043 4 26 26 26 26

GG045 10 10 10 10

GG046 16 16 16 16

GG047 2 47 47 47 47

GG048 14 14 14 14 14

GG50B 28 28 28 28 28

GG50C 4 4 4 4 4

GG51B 57 57 57 57 57

GG55B 24 24 24 24 24

GG55C 13 13 13 13 13

GG56B 2 2 2 2 2

GG56C 5 5 5 5 5

GG56D 1 1 1 1 1

GG57B 16 16 16 16 16

GG57C 14 14 14 14 14

GG58A 2 2 2 2 2

GG063 21 21 21 21 21

569
Appendix E Stanislaus

Treatments National Forest

Unit FB MA FB/MA MP HC/HP HC/JP DTFC HERB/SP PLANT HERB/REL PPF

H009C 31 31 31 31 31

H011B 11 11 11 11 11

H011D 27 27 27 27 27

H016 24 24 24 24 24

H017 47 47 47 47 47

H032B 17 17 17 17 17

H033B 11 11 11 11 11

H034B 7 7 7 7 7

H038 14 14 14 14 14

H039 27 27 27 27 27

H049B 7 7 7 7 7

H065 13 13 13 13

H068 54 54 54 54

HH001 67 67 67 67

HH002 93 93 93 93

HH003 116 116 116 116

HH006 104 104 104 104

HH007 22 22 22 22

HH008 9 9 9 9

HH009 22 22 22 22

HH010 41 41 41 41

HH011 46 46 46 46

HH012 34 34 34 34

HH013 3 64 64 64 64

HH014 22 131 131 131 131

HH015 83 83 83 83

HH016 50 50 50 50

HH17B 10 10 10 10 10

HH018 11 47 47 47 47

HH20C 11 11 11 11 11

HH022 8 60 60 60 60

HH023 62 62 62 62

HH025 3 3 3 3

HH028 18 18 18 18

HH029 107 116 116 116 116

HH031 13 33 33 33 33

HH036 21 21 21 21

HH037 5 37 37 37 37

HH038 37 93 93 93 93

HH39B 13 13 13 13 13

HH40B 3 3 3 3 3

HH42B 16 16 16 16 16

HH45D 108 108 108 108 108

HH45E 55 55 55 55 55

I007B 24 24 24 24 24

I007C 21 21 21 21 21

I009D 51 51 51 51 51

I009E 5 5 5 5 5

I014B 59 59 59 59 59

I015 37 37 37 37 37

I017C 19 19 19 19 19

I020B 24 24 24 24 24

I024C 1 1 1 1 1

I024D 4 4 4 4 4

I025C 24 24 24 24 24

I025D 6 6 6 6 6

I028B 2 2 2 2 2

570
Rim Fire Reforestation (45612) Appendix E

Draft Environmental Impact Statement Treatments

Unit FB MA FB/MA MP HC/HP HC/JP DTFC HERB/SP PLANT HERB/REL PPF

I028C 12 12 12 12 12

I029C 6 6 6 6 6

I033B 6 6 6 6 6

I047B 3 3 3 3 3

I047C 11 11 11 11 11

I048B 3 3 3 3 3

I058B 2 2 2 2 2

I058C 3 3 3 3 3

I058D 13 13 13 13 13

I060B 58 58 58 58 58

I061B 12 12 12 12 12

I062C 15 15 15 15 15

I063B 15 15 15 15 15

I063C 3 3 3 3 3

I065A 2 2 2 2 2

I065C 4 4 4 4 4

I070A 11 11 11 11 11

I070C 8 8 8 8 8

I071B 8 8 8 8 8

I071C 2 2 2 2 2

I072C 45 45 45 45 45

I073B 3 3 3 3 3

I073C 36 36 36 36 36

I075B 12 12 12 12 12

I075C 2 2 2 2 2

I080B 12 12 12 12 12

I084B 29 29 29 29 29

I086B 7 7 7 7 7

I088A 11 11 11 11 11

I089B 22 22 22 22 22

I090B 11 11 11 11 11

I096 20 20 20 20 20

I099B 5 5 5 5 5

I099C 1 1 1 1 1

I100C 64 64 64 64 64

I101A 5 5 5 5 5

I102B 3 3 3 3 3

I103C 8 8 8 8 8

I104C 23 23 23 23 23

I104D 3 3 3 3 3

I109B 11 11 11 11 11

I110B 6 6 6 6 6

I111B 8 8 8 8 8

I112B 6 6 6 6 6

I113C 9 9 9 9 9

I121A 3 3 3 3 3

I121B 5 5 5 5 5

I121C 3 3 3 3 3

I122C 13 13 13 13 13

I122D 5 5 5 5 5

I122E 24 24 24 24 24

I123B 35 35 35 35 35

I124B 19 19 19 19 19

I125B 18 18 18 18 18

I126B 14 14 14 14 14

I127 24 24 24 24 24

I128C 16 16 16 16 16

571
Appendix E Stanislaus

Treatments National Forest

Unit FB MA FB/MA MP HC/HP HC/JP DTFC HERB/SP PLANT HERB/REL PPF

I129 30 30 30 30 30

I130 34 34 34 34 34

I131B 27 27 27 27 27

I132B 54 54 54 54 54

I133 19 19 19 19 19

I134B 22 22 22 22 22

I135B 13 13 13 13 13

I136B 2 2 2 2 2

I136C 22 22 22 22 22

I137B 36 36 36 36 36

I138 21 21 21 21 21

I139 25 25 25 25 25

I140B 40 40 40 40 40

J001 69 69 69 69

J002 243 243 243 243

J003 100 100 100 100

J004 73 73 73 73

J005 161 161 161 161

J006 136 136 136 136

J007 35 35 35 35

J008 185 185 185 185

J009 16 16 16 16

J010 17 17 17 17

J011 15 15 15 15

J012 46 46 46 46

J013 72 72 72 72

J014 61 61 61 61

K010C 119 119 119 119 119

K011B 2 2 2 2 2

K011C 15 15 15 15 15

K015B 39 39 39 39 39

K018A 75 75 75 75 75

L001 188 188 188 188 188

L002 92 96 96 96 96

L003 86 100 100 100 100

L005 97 120 120 120 120

L006 116 116 116 116

L007 111 111 111 111

L008 152 152 152 152

L009 66 66 66 66

L010 22 22 22 22

L011 48 48 48 48

L014 155 155 155 155 155

M001C 67 67 67 67 67

M001E 102 102 102 102 102

M001G 182 182 182 182 182

M004B 121 121 121 121 121

M009B 29 29 29 29 29

M010B 29 29 29 29 29

M010D 44 44 44 44 44

M011A 28 28 28 28 28

M012 83 83 83 83 83

M014A 7 7 7 7 7

M014C 9 9 9 9 9

M017B 62 62 62 62 62

M017C 33 33 33 33 33

M020A 19 19 19 19 19

572
Rim Fire Reforestation (45612) Appendix E

Draft Environmental Impact Statement Treatments

Unit FB MA FB/MA MP HC/HP HC/JP DTFC HERB/SP PLANT HERB/REL PPF

M020C 31 31 31 31 31

M024B 156 156 156 156 156

M025 219 219 219 219

N010B 113 113 113 113 113

N019 213 221 221 221 221

P010 61 61 61 61

P011 23 23 23 23

P014 4 255 255 255 255

P019 15 15 15 15

P020 15 15 15 15

P021 149 149 149 149

P022 61 61 61 61

Q002B 248 248 248 248 248

Q002C 10 10 10 10 10

Q002D 3 3 3 3 3

Q003 21 21 21 21

Q004 32 32 32 32

Q005 9 9 9 9

Q006 24 24 24 24

Q007 33 33 33 33

Q008 29 29 29 29

Q009 88 88 88 88

Q010 24 24 24 24

Q011 2 36 36 36 36

Q012 1 61 61 61 61

Q013 23 23 23 23

Q014 24 24 24 24

Q015 46 46 46 46

Q016 75 75 75 75

Q017 73 73 73 73

R001 185 185 185 185

R002 4 92 92 92 92

R003 38 38 38 38

R004 104 121 121 121 121

R005 49 49 49 49

R006 39 39 39 39

R007B 3 3 3 3 3

R007C 16 16 16 16 16

R008 9 9 9 9

R009 19 19 19 19

R011 54 54 54 54

R012 48 48 48 48

R013 41 41 41 41

R014B 65 65 65 65 65

R015 15 15 15 15

R016 38 38 38 38

R017 14 14 14 14

R018 55 124 124 124 124

R019 33 33 33 33

R020 13 13 13 13

R021 21 21 21 21

R022 72 72 72 72

R024 85 85 85 85

R025 174 174 174 174

R026 9 48 48 48 48

R027 60 60 60 60

R028 17 17 17 17

573
Appendix E Stanislaus

Treatments National Forest

Unit FB MA FB/MA MP HC/HP HC/JP DTFC HERB/SP PLANT HERB/REL PPF

R029 10 10 10 10

R030 24 24 24 24

R031 30 30 30 30

R032 30 30 30 30

R033 12 12 12 12

R034 33 33 33 33

R035 68 68 68 68

R036 17 17 17 17

R037 13 132 132 132 132

R038 46 46 46 46

R039 5 10 10 10 10

R046 233 233 233 233

S001 282 282 282 282

S006 32 32 32 32

S007 106 106 106 106

T002 52 52 52 52

T003 78 78 78 78

T004 20 20 20 20

T005 116 116 116 116

T006 461 461 461 461

T007 342 342 342 342

T008 32 32 32 32

T009 47 47 47 47

T010 94 94 94 94

T011 198 198 198 198

T012 71 71 71 71

T013 80 80 80 80

T014 18 18 18 18

T015 14 64 64 64 64

T017 7 45 45 45 45

T019 9 36 36 36 36

T025 71 71 71 71

U003 239 239 239 239

U004 50 50 50 50 50

U005 18 18 18 18

U008 15 15 15 15

U009 48 48 48 48

U010 1 13 13 13 13

U011 24 24 24 24

U012 94 94 94 94

U013 51 51 51 51

U014 5 5 5 5

U015 12 40 40 40 40

U016 28 28 28 28

U018 97 97 97 97

U019 130 130 130 130

U020 51 51 51 51

U021 10 10 10 10

V010B 55 55 55 55 55

V012 88 112 112 112 112

V014B 23 23 23 23 23

V015 32 32 32 32 32

V022B 5 5 5 5 5

V022C 11 11 11 11 11

V022D 11 11 11 11 11

V023B 16 16 16 16 16

V024 237 237 237 237 237

574
Rim Fire Reforestation (45612) Appendix E

Draft Environmental Impact Statement Treatments

Unit FB MA FB/MA MP HC/HP HC/JP DTFC HERB/SP PLANT HERB/REL PPF

W001 51 51 51 51

W002 226 226 226 226

W003 73 73 73 73

W004B 8 8 8 8 8

W004C 4 4 4 4 4

W007 21 21 21 21

X003 20 20 20 20

X011 22 22 22 22

X013B 2 2 2 2 2

X013C 3 3 3 3 3

X014 46 46 46 46

X015 64 64 64 64

X016 26 26 26 26

X017 19 19 19 19

X018 18 18 18 18

X019 73 73 73 73

X020 69 69 69 69

X021 34 34 34 34

X022 19 19 19 19

X023 51 51 51 51

X024 67 67 67 67

X025 12 12 12 12

X026 48 48 48 48

X028 74 74 74 74

X029 70 70 70 70

X031 6 89 89 89 89

X032 82 82 82 82

X033 4 65 65 65 65

X035 67 67 67 67

X036 240 240 240 240

X037 88 88 88 88

X038 17 17 17 17

Y002C 86 86 86 86 86

Y003 23 23 23 23

Y008 3 33 33 33 33

Y009 16 16 16 16

Y010 25 25 25 25 25

Y011 10 10 10 10 10

Y014 23 23 23 23 23

Y015 18 18 18 18 18

Y016 17 17 17 17 17

Y018 47 48 48 48 48

Y019 17 17 17 17

Y020 4 50 50 50 50

Y022 39 39 39 39 39

Y025 69 69 69 69

Y027 31 31 31 31

Y028 6 6 6 6

Y029 52 52 52 52

Y030 143 143 143 143

Y032 33 33 33 33 33

Z004 24 24 24 24

Z006 20 20 20 20

Z007 26 26 26 26

Z008 15 15 15 15

Z011 91 91 91 91

Z012 16 16 16 16

575
Appendix E Stanislaus

Treatments National Forest

Unit FB MA FB/MA MP HC/HP HC/JP DTFC HERB/SP PLANT HERB/REL PPF

Z013 38 38 38 38

Z014 17 17 17 17

Z015 14 14 14 14

Z016 7 60 60 60 60

Z017 20 20 20 20

Z018 7 7 7 7

Z019 16 16 16 16

Z020 36 36 36 36

Z021 4 43 43 43 43

Z023 15 15 15 15

Z024 50 50 50 50

Z027 88 88 88 88

Z028 137 137 137 137

Z029 32 32 32 32

Z030 18 44 44 44 44

Total 3,318 1,528 423 925 271 237 5,085 20,246 25,331 25,331 25,331

576
Rim Fire Reforestation (45612) Appendix E

Draft Environmental Impact Statement Treatments

E.02 NATURAL REGENERATION

Table E.02-1 Alternative 1: Natural Regeneration Treatments

Unit FB MA FB/MA MP HC/HP HC/JP HERB/SP PLANT HERB/REL PPF

B001 62 62 62 62

B002 100 100 100 100

BB028 162 162 162 162

BB038 3 25 25 25 25

BB046 13 13 13 13

BB055 11 11 11 11

BB057 28 28 28 28

BB069 72 72 72 72

BB072 29 29 29 29

BB083 94 94 94 94

CC010 11 11 11 11

DD016 83 83 83 83

E008 8 17 17 17 17

E009 42 42 42 42

E010 11 11 11 11

E011 26 26 26 26

E012 31 31 31 31

EE013 34 34 34 34

F007 65 65 65 65

FF009 61 61 61 61

FF010 34 34 34 34

G011 16 16 16 16

G012 5 5 5 5 5

G013 5 5 5 5

G014 176 176 176 176 176

G015 4 4 4 4

GG004 7 7 7 7

GG005 43 43 43 43

GG006 3 3 3 3

GG007 65 65 65 65

GG013 23 23 23 23

GG022 27 27 27 27

GG024 75 75 75 75

GG028 70 70 70 70

GG029 183 183 183 183

GG030 13 13 13 13

GG033 18 18 18 18

GG035 72 72 72 72

GG036 28 28 28 28

GG041 18 49 49 49 49

GG042 26 26 26 26 26

GG043 4 26 26 26 26

GG045 10 10 10 10

GG046 16 16 16 16

GG047 2 47 47 47 47

H038 14 14 14 14 14

HH022 8 60 60 60 60

HH023 62 62 62 62

HH025 3 3 3 3

HH031 13 33 33 33 33

HH036 21 21 21 21

J006 136 136 136 136

577
Appendix E Stanislaus

Treatments National Forest

Unit FB MA FB/MA MP HC/HP HC/JP HERB/SP PLANT HERB/REL PPF

J007 35 35 35 35

J008 185 185 185 185

J009 16 16 16 16

J010 17 17 17 17

J011 15 15 15 15

J013 72 72 72 72

J014 61 61 61 61

M012 83 83 83 83 83

P019 15 15 15 15

P020 15 15 15 15

Q011 2 36 36 36 36

Q012 1 61 61 61 61

R018 55 124 124 124 124

R033 12 12 12 12

R035 68 68 68 68

W001 51 51 51 51

W007 21 21 21 21

X016 26 26 26 26

X017 19 19 19 19

X018 18 18 18 18

X020 69 69 69 69

X022 19 19 19 19

X023 51 51 51 51

X024 67 67 67 67

X029 70 70 70 70

X031 6 89 89 89 89

X032 82 82 82 82

X038 17 17 17 17

Y003 23 23 23 23

Y009 16 16 16 16

Y019 17 17 17 17

Y022 39 39 39 39 39

Y027 31 31 31 31

Y032 33 33 33 33 33

Z004 24 24 24 24

Z007 26 26 26 26

Z012 16 16 16 16

Z015 14 14 14 14

Z019 16 16 16 16

Z023 15 15 15 15

Total 179 35 72 13 197 4,031 4,031 4,031 4,031

578
Rim Fire Reforestation (45612) Appendix E

Draft Environmental Impact Statement Treatments

Table E.02-2 Alternative 3: Natural Regeneration Treatments

Unit FB MA FB/MA MP HC/HP PLANT GRUB PPF

B001 62 62 62

B002 100 100 100

BB028 162 162 162

BB038 3 25 25 25

BB046 13 13 13

BB055 11 11 11

BB057 28 28 28

BB069 72 72 72

BB072 29 29 29

BB083 94 94 94

CC010 11 11 11

DD016 83 83 83

E008 8 17 17 17

E009 42 42 42

E010 11 11 11

E011 26 26 26

E012 31 31 31

EE013 34 34 34

F007 65 65 65

FF009 61 61 61

FF010 34 34 34

G011 16 16 16

G012 5 5 5 5

G013 5 5 5

G014 176 176 176 176

G015 4 4 4

GG004 7 7 7

GG005 43 43 43

GG006 3 3 3

GG007 65 65 65

GG013 23 23 23

GG022 27 27 27

GG024 75 75 75

GG028 70 70 70

GG029 183 183 183

GG030 13 13 13

GG033 18 18 18

GG035 72 72 72

GG036 28 28 28

GG041 18 49 49 49

GG042 26 26 26 26

GG043 4 26 26 26

GG045 10 10 10

GG046 16 16 16

GG047 2 47 47 47

H038 14 14 14 14

HH022 8 60 60 60

HH023 62 62 62

HH025 3 3 3

HH031 13 33 33 33

HH036 21 21 21

J006 136 136 136

J007 35 35 35

J008 185 185 185

J009 16 16 16

579
Appendix E Stanislaus

Treatments National Forest

Unit FB MA FB/MA MP HC/HP PLANT GRUB PPF

J010 17 17 17

J011 15 15 15

J013 72 72 72

J014 61 61 61

M012 83 83 83 83

P019 15 15 15

P020 15 15 15

Q011 2 36 36 36

Q012 1 61 61 61

R018 55 124 124 124

R033 12 12 12

R035 68 68 68

W001 51 51 51

W007 21 21 21

X016 26 26 26

X017 19 19 19

X018 18 18 18

X020 69 69 69

X022 19 19 19

X023 51 51 51

X024 67 67 67

X029 70 70 70

X031 6 89 89 89

X032 82 82 82

X038 17 17 17

Y003 23 23 23

Y009 16 16 16

Y019 17 17 17

Y022 39 39 39 39

Y027 31 31 31

Y032 33 33 33 33

Z004 24 24 24

Z007 26 26 26

Z012 16 16 16

Z015 14 14 14

Z019 16 16 16

Z023 15 15 15

Total 179 35 72 13 197 4,031 4,031 4,031

580
Rim Fire Reforestation (45612) Appendix E

Draft Environmental Impact Statement Treatments

E.03 THIN EXISTING PLANTATIONS

Table E.03-1 Alternatives 1, 3, 4 and 5: Thin Existing Plantation Treatments

Unit PF FB MA FB/MA MP/BURN HC/HP/BURN

A005 23 23

A007 22 22

A009 16 16

A010 14 14

AA01A 80

AA002 9 9

AA03A 1

AA04A 10

AA04B 5

AA006 31 31

AA007 14 14

AA009 8 10

AA011 13 13

AA022 16 16

AA23A 23

BB23A 14

BB039 9 9

BB43A 13

BB058 10 11

BB068 13 13

BB070 32 33

BB71A 48

CC001 166 167

CC003 10 11

CC004 7 7

CC005 95 95

CC006 66 66

CC007 442 442

CC008 33 33

D015 29 29

DD04A 6

DD05A 3

DD009 6 6

DD012 9 9

E001 45 45

E002A 50

E003A 24

E004 47 47

E006A 105

EE001 10 12

EE03A 2

EE009 123 123

EE014 333 333

EE016 81 81

EE017 29 29

F005 24 24

F006 11 11

F008 24 34

F009 7 9

F010 3 3

F011 13 13

GG08A 6

581
Appendix E Stanislaus

Treatments National Forest

Unit PF FB MA FB/MA MP/BURN HC/HP/BURN

GG12A 3

GG37A 12

GG50A 12

GG51A 40

GG51C 6

GG55A 9

GG56A 14

GG57A 31

GG58B 7

GG061 58 58

GG062 16 16

H001 14 14

H007 40 40

H008 33 33

H009A 5

H009B 37

H011A 11

H011C 47

H014 85 85

H018 20 20

H019 12 12

H020 46 46

H021 36 38

H023 40 40

H024 10 10

H025 11 11

H026 8 8

H027 40 40

H028 39 39

H029 49 49

H030 29 29

H031 28 28

H032A 6

H033A 1

H034A 9

H035 31 31

H036 28 28

H037 28 28

H040 22 22

H041 24 25

H042 34 34

H043 21 30

H044 60 78

H045 18 32

H046 71 80

H047 14 14

H048 93 93

H049A 40

H050 28 43

H051 39 46

H052 3 5

H053 17 21

H054 11 17

H055 11 24

H056 24 32

H057 23 29

H058 8 15

582
Rim Fire Reforestation (45612) Appendix E

Draft Environmental Impact Statement Treatments

Unit PF FB MA FB/MA MP/BURN HC/HP/BURN

H060 10 10

H061 108 108

H062 44 44

H063 52 52

H064 27 27

HH17A 11

HH20A 53

HH20B 13

HH021 32 37

HH39A 27

HH40A 8

HH42A 43

HH45A 122

HH45B 65

HH45C 14

HH046 147 159

I001 67 67

I002 80 80

I003 95 95

I004 48 48

I005 39 39

I006 38 38

I007A 14

I008 102 102

I009A 13

I009B 11

I009C 14

I010 188 188

I011 32 32

I012 38 38

I013 18 18

I014A 6

I016 17 17

I017A 6

I017B 44

I018 18 18

I019 31 31

I020A 11

I021 42 42

I022 62 62

I023 53 53

I024A 6

I024B 9

I025A 4

I025B 12

I026 8 8

I027 63 63

I028A 17

I029A 1

I029B 2

I030 39 39

I031 50 50

I032 35 49

I033A 31

I034 19 19

I035 17 33

I036 10 17

583
Appendix E Stanislaus

Treatments National Forest

Unit PF FB MA FB/MA MP/BURN HC/HP/BURN

I037 18 18

I038 17 17

I039 22 22

I040 18 18

I042 22 22

I045 5 5

I046 49 49

I047A 9

I048A 12

I049 18 18

I050 26 26

I051 15 15

I052 38 38

I053 79 79

I054 38 39

I055 18 19

I056 7 12

I057 16 21

I058A 20

I059 26 26

I060A 9

I061A 4

I062A 10

I062B 10

I063A 17

I064 36 36

I065B 6

I066 57 57

I067 52 63

I068 23 45

I069 92 94

I070B 28

I071A 25

I072A 11

I072B 5

I073A 28

I074 7 7

I075A 118

I076 15 15

I077 34 34

I078 15 15

I080A 50

I081 16 16

I082 13 13

I083 42 42

I084A 9

I084C 11

I085 8 8

I086A 4

I087 4 4

I088B 12

I089A 7

I090A 18

I091 63 63

I092 41 41

I094 34 34

I099A 15

584
Rim Fire Reforestation (45612) Appendix E

Draft Environmental Impact Statement Treatments

Unit PF FB MA FB/MA MP/BURN HC/HP/BURN

I100A 4

I100B 24

I101B 20

I102A 30

I103A 2

I103B 11

I104A 3

I104B 7

I109A 16

I110A 2

I111A 24

I112A 7

I113A 9

I113B 10

I114 21 21

I115 7 7

I116 41 41

I117 21 21

I120 29 29

I121D 32

I122A 11

I122B 6

I123A 8

I124A 9

I125A 4

I126A 6

I128A 2

I128B 2

I131A 8

I132A 7

I134A 6

I135A 11

I136A 7

I137A 3

I140A 10

K001 100 130

K002 210 210

K003 144 148

K008 40 40

K010A 51

K010B 26

K011A 14

K013 123 123

K015A 49

K017 12 12

K018B 170

M001A 23

M001B 227

M001D 108

M001F 19

M002 41 41

M004A 216

M007 22 22

M008 150 150

M009A 16

M010A 52

M010C 108

585
Appendix E Stanislaus

Treatments National Forest

Unit PF FB MA FB/MA MP/BURN HC/HP/BURN

M010E 58

M011B 25

M011C 64

M013 100 100

M014B 35

M014D 5

M015 28 28

M016 242 314

M017A 17

M018 23 43

M019 102 118

M020B 58

M021 420 452

M022 27 42

M023 18 31

M024A 58

N009 77 93

N010A 172

N011 15 15

N014 189 195

P002 23 23

P003 33 33

Q001 175 234

Q002A 30

R007A 3

R014A 6

U001 10 10

V003 9 11

V004 3 7

V005 7 9

V010A 2

V014A 36

V016 21 45

V019 36 41

V020 12 12

V021 63 69

V022A 28

V023A 18

V027 32 32

V028 15 29

V030 42 42

W004A 2

W005 5 5

W006 7 7

X013A 1

Y002A 9

Y002B 6

Y023 29 29

Y024 12 12

Y026 27 27

Z002 15 25

Z003 5 7

Z022 16 16

Z025 5 5

Z026 5 5

Total 8,487 8,720 1,720 377 254 1,698

586
Rim Fire Reforestation (45612) Appendix E

Draft Environmental Impact Statement Treatments

E.04 DEER REFORESTATION

Table E.04-1 Alternative 1: Deer Reforestation Treatments

Unit NAT FB MP PF HERB/SP PLANT HERB/REL PPF

P023 25 25 25 25

P024 43 43 43 43

P025 5 15 15 15 15

P027 25 73 73 73 73

R042B 24 24 24 24 24 24

R042C 7 7 7 7 7 7

R042D 3 3 3 3 3 3

S002A 26 26 26 26

S002B 29 29 29 29

S004A 7 7 7 7 7

S004B 19 19 19 19 19

S004C 22 22 22 22 22

S004D 18 18 18 18 18

S004E 33

T022A 16 16 16 16

T022B 21 21 21 21

T022C 81 81 81 81

T022D 55 55 55 55

T024A 66 66 66 66

T024B 29 29 29 29

U006 26 26 26 26

U017A 13 13 13 13

U017B 28 28 28 28

Total 33 39 25 100 646 646 646 646

Table E.04-2 Alternative 3: Deer Reforestation Treatments

Unit NAT FB MP PF DTFC PLANT GRUB PPF

P023 25 25 25 25

P024 43 43 43 43

P025 5 15 15 15 15

P027 25 73 73 73 73

R042B 24 24 24 24 24 24

R042C 7 7 7 7 7 7

R042D 3 3 3 3 3 3

S002A 26 26 26 26

S002B 29 29 29 29

S004A 7 7 7 7 7

S004B 19 19 19 19 19

S004C 22 22 22 22 22

S004D 18 18 18 18 18

S004E 33

T022A 16 16 16 16

T022B 21 21 21 21

T022C 81 81 81 81

T022D 55 55 55 55

T024A 66 66 66 66

T024B 29 29 29 29

U006 26 26 26 26

U017A 13 13 13 13

U017B 28 28 28 28

Total 33 39 25 100 646 646 646 646

587
Appendix E Stanislaus

Treatments National Forest

Table E.04-3 Alternative 4: Deer Reforestation Treatments

Unit FB PF HERB/SP PLANT HERB/REL1 PPF

P023 5 5 7 5

R042B 5 5 5 5 7 5

S002A 5 5 7 5

S002B 6 6 8 6

S004B 4 4 4 5 4

S004D 4 4 4 5 4

T022A 3 3 4 3

T022B 4 4 6 4

T022C 16 16 23 16

T022D 11 11 15 11

T024A 13 13 18 13

T024B 6 6 8 6

U017B 6 6 8 6

Total 5 13 88 88 121 88

1 HERB/REL (Herbicide Release) acres increase due to founder stand buffers. 

Table E.04-4 Alternative 5: Deer Reforestation Treatments

Unit FB MP PF HERB/SP PLANT HERB/REL PPF

P023 25 25 25 25

P024 43 43 43 43

P025 5 15 15 15 15

P027 25 73 73 73 73

R042B 24 24 24 24 24 24

R042C 7 7 7 7 7 7

R042D 3 3 3 3 3 3

S002A 26 26 26 26

S002B 29 29 29 29

S004A 7 7 7 7 7

S004B 19 19 19 19 19

S004C 22 22 22 22 22

S004D 18 18 18 18 18

S004E 33 33 33 33

T022A 16 16 16 16

T022B 21 21 21 21

T022C 81 81 81 81

T022D 55 55 55 55

T024A 66 66 66 66

T024B 29 29 29 29

U006 26 26 26 26

U017A 13 13 13 13

U017B 28 28 28 28

Total 39 25 100 679 679 679 679

588
Rim Fire Reforestation (45612) Appendix E

Draft Environmental Impact Statement Treatments

E.05 DEER HABITAT ENHANCEMENT

Table E.05-1 Alternatives 1, 3, 4 and 5: Deer Habitat Enhancement Treatments

Unit Alternatives 1,3,5 

FB

Alternatives 1,3,5 

HC/HP

Alternatives 1,3,5 

PF1 Alternative 4 FB

Alternative 4 

HC/HP

Alternative 4 

PF1

P023 20

P026 11 11 11 11

R040 276 276 276 276

R041 404 404

R042A 140 140 140 140

R042B 19

R043 54 54 54 54

S002A 21

S002B 23

S002C 42 42

S003 77 77 77 77

S004B 15

S004D 14

S004E 33

S004F 988 988

S005 52 52 52 52

S008 35 35 35 35

S010 334 334

S011 105 105 105 105

S012 117 117 117 117

S013 100 100 100 100

S014 73 73 73 73

S015 124 124 124 124

T021 73 73

T022A 13

T022B 17

T022C 65

T022D 44

T022E 32 32

T024B 23

T024A 53

T024C 42 42

U017B 22

U017C 63 63

U017D 12 12

Total 1,153 11 3,154 1,153 11 3,536

1 PF (Prescribed Fire) includes deer reforestation units. 

589