United States Department of Agriculture

Forest Service

January 2016

Elk Late-Successional Reserve 

Enhancement Project

Draft Environmental Impact Statement

Shasta-McCloud Management Unit, McCloud Ranger District, Shasta-Trinity National Forest

Siskiyou County California, T40N, R1W, Sec. 4 & 5; and T41N, R1W, Sections 27 to 34, MDM
Cover Image – Collage of images of Elk Flat LSR Enhancement Project area

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Elk Lake-Successional Reserve Enhancement 

Project

Draft Environmental Impact Statement

Siskiyou County California

Lead Agency: USDA Forest Service

Responsible Official: David R. Myers

Shasta-Trinity National Forest Service

3644 Avtech Parkway

Redding, CA 96002

For Information Contact: Cindy Diaz, Natural Resource Planner

Shasta-McCloud Management Unit

204 W. Alma Street

Mount Shasta, CA 96067

530 – 926 - 4511

Abstract: The Shasta-McCloud Management Unit of the Shasta-Trinity National Forest (Forest) is proposing 

to restore and enhance the Elk Late-Successional Reserve (LSR) and restore dry meadow habitat and thin 

stands in adjoining Matrix lands in and around Elk Flat. Treatments proposed on approximately 3,482 acres of 

National Forest System Lands fall within five broad categories: 1) Forest Restoration; 2) Meadow 

Restoration; 3) Fire Restoration and Fuels Reduction; 4) Hydrologic Function and Soils Restoration; and 5) 

Transportation System Management and Decommissioning of Unauthorized Routes.

The Draft Environmental Impact Statement (DEIS) considers four alternatives in detail. Alternative 1, the 

Modified Proposed Action and the Forest Service preferred alternative, is the Proposed Action that was 

scoped to the public with modifications. Alternative 4 is the no action alternative. Alternatives 2 and 3 were 

developed in response to public comments received during scoping. Alternative 2 responds to concerns over 

road construction. Since the project does not propose new Forest Transportation System (FTS) road 

construction, it limits new temporary road construction. Thinning, meadow enhancement, and machine piling 

treatments beyond 1⁄4 mile from an existing FTS or inventoried Unauthorized Route (UA) would not be 

implemented. Prescribed fire would still be conducted. Alternative 3 responds to the issue regarding 

treatments in natural stands within Northern Spotted Owl (NSO) designated critical habit (CH). No 

underburning or thinning would be implemented within natural stands in the CH. Plantations within the CH 

would still be included in the project.

Draft Environmental Impact Statement

i

Document Structure

The Forest Service has prepared this Environmental Impact Statement in compliance with the National 

Environmental Policy Act (NEPA) and other relevant Federal and State laws and regulations. This 

Environmental Impact Statement discloses the direct, indirect, and cumulative environmental impacts that 

would result from the proposed action and alternatives. The document is organized into a Summary followed 

by four chapters, Appendices, and Index:

Summary: The Summary provides a brief synopsis the key elements of the DEIS. The summary emphasizes 

the major conclusions, key issues, and the decision to be made.

Chapter 1. Purpose and Need for Action: The chapter includes information on the history of the project 

proposal, the purpose of and need for the project, and the agency’s proposal for achieving that purpose and 

need. This section also details how the Forest Service informed the public of the proposal and how the public 

responded.

Chapter 2. Alternatives, including the Proposed Action: This chapter provides a more detailed description 

of the agency’s proposed action as well as alternative methods for achieving the stated purpose. These 

alternatives were developed based on significant issues raised by the public and other agencies. This 

discussion also includes resource protection measures. Finally, this section provides a summary table of the 

environmental consequences associated with each alternative.

Chapter 3. Affected Environment and Environmental Consequences: This chapter describes the 

environmental effects of implementing the proposed action and other alternatives. This analysis is organized 

by resource area, followed by required disclosures.

Chapter 4. Consultation and Coordination: This chapter provides a list of preparers and agencies consulted 

during the development of the environmental impact statement.

Appendices: The appendices provide more detailed information to support the analyses presented in the 

environmental impact statement.

Index: The index provides page numbers by topic.

Draft Environmental Impact Statement

i

Table of Contents

Document Structure ............................................................................................................................................. i

Table of Contents............................................................................................................................................. i

List of Tables................................................................................................................................................. iii

List of Figures..................................................................................................................................................v

Summary........................................................................................................................................................... vii

Introduction................................................................................................................................................................vii

Purpose and Need for Action and Proposed Actions.................................................................................................vii

Public Involvement ....................................................................................................................................................xii

Alternatives.............................................................................................................................................................. xiii

Conclusions................................................................................................................................................................xv

Decision to be Made ................................................................................................................................................xvii

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

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

Background......................................................................................................................................................1

Location .......................................................................................................................................................................1

Management Direction ....................................................................................................................................4

Late-Successional Reserves Allocation: Prescription VII-Late-Successional Reserves and Threatened, Endangered, 

and Selected Sensitive Species. ...................................................................................................................................6

Matrix Allocation: Prescription VIII-Commercial Wood Products (CWP).................................................................7

Riparian Reserves Allocation: Prescription IX-Riparian Management .......................................................................7

Other Designations ......................................................................................................................................................7

Revised Recovery Plan for Northern Spotted Owl ......................................................................................................8

Purpose and Need for Action...........................................................................................................................9

Introduction and Summary ..........................................................................................................................................9

Purpose and Need Discussion....................................................................................................................................10

Proposed Action ............................................................................................................................................38

Introduction and Summary ........................................................................................................................................38

Decision Framework......................................................................................................................................43

Public Involvement........................................................................................................................................43

Issues .............................................................................................................................................................44

Issue 1 – Large Trees and Snags................................................................................................................................44

Issue 2 – Road Construction ......................................................................................................................................44

Issue 3 – Critical Habitat............................................................................................................................................45

Issue 4 – Mushroom Collection in Elk Flat ...............................................................................................................46

Issue 5 – Machine Piling............................................................................................................................................46

Other Related Efforts.....................................................................................................................................46

Chapter 2. Alternatives, Including the Proposed Action....................................................................................47

Description of Actions...................................................................................................................................47

Forest Restoration Treatments...................................................................................................................................47

Fire Restoration and Fuels Reduction Treatments.....................................................................................................51

Meadow Restoration ..................................................................................................................................................53

Hydrologic Function and Soils Restoration ...............................................................................................................54

Transportation System Management and Road and Landing Actions.......................................................................55

Other Connected Actions...........................................................................................................................................56

Alternatives Considered in Detail including Resource Protection Measures and Monitoring ......................57

Alternative 1 - The Modified Proposed Action..........................................................................................................57

Alternative 2 - No New Temporary Road Construction Other than Those Required for Landing Use/Access.........64

Alternative 3 - No Treatments of Natural Stands within Designated Critical Habitat for the Northern Spotted Owl70

Alternative 4- No Action ...........................................................................................................................................76

Comparison of Actions - Alternatives Considered in Detail......................................................................................76

Resource Protection Measures Common to All Action Alternatives.........................................................................81

Monitoring Common to All Action Alternatives.......................................................................................................90

Comparison of Effects – Alternatives Considered in Detail ......................................................................................94
Elk Flat Late-Successional Reserve Enhancement

ii Shasta-Trinity National Forest

Alternatives Considered but Eliminated from Detailed Study....................................................................117

The Original Proposed Action as Scoped ................................................................................................................117

Alternative 5: No Treatments in Elk Flat Meadow..................................................................................................117

Alternative 6: Limit Harvest to Trees Less than 10 Inches in Diameter ..................................................................119

Alternative 7: Eliminate the Use of Machine Piling within Treatment Units and Substitute Hand Piling...............119

Alternative 8: Limit Harvest to Trees Less Than 20 Inches in Diameter within the Elk Flat Late-Successional 

Reserve.....................................................................................................................................................................120

Alternative 9: No New Temporary Road Construction............................................................................................121

Chapter 3. Affected Environment and Environmental Consequences ............................................................123

Introduction.................................................................................................................................................123

Approach to Cumulative Effects Analysis...............................................................................................................123

Silviculture and Forest Health.....................................................................................................................124

Introduction..............................................................................................................................................................124

Methodology............................................................................................................................................................124

Affected Environment..............................................................................................................................................127

Environmental Consequences..................................................................................................................................128

Fire and Fuels..............................................................................................................................................149

Introduction..............................................................................................................................................................149

Methodology............................................................................................................................................................149

Affected Environment..............................................................................................................................................151

Environmental Consequences..................................................................................................................................152

Wildlife .......................................................................................................................................................158

Introduction..............................................................................................................................................................158

Methodology............................................................................................................................................................158

Affected Environment..............................................................................................................................................164

Environmental Consequences..................................................................................................................................168

Botany .........................................................................................................................................................186

Introduction..............................................................................................................................................................186

Methodology............................................................................................................................................................187

Affected Environment..............................................................................................................................................189

Environmental Consequences..................................................................................................................................190

Hydrology ...................................................................................................................................................193

Introduction..............................................................................................................................................................193

Methodology............................................................................................................................................................193

Affected Environment..............................................................................................................................................197

Environmental Consequences..................................................................................................................................201

Soils.............................................................................................................................................................208

Introduction..............................................................................................................................................................208

Methodology............................................................................................................................................................208

Affected Environment..............................................................................................................................................213

Environmental Consequences..................................................................................................................................217

Transportation .............................................................................................................................................225

Introduction..............................................................................................................................................................225

Methodology............................................................................................................................................................226

Affected Environment..............................................................................................................................................229

Environmental Consequences..................................................................................................................................231

Cultural Resources......................................................................................................................................235

Introduction..............................................................................................................................................................235

Methodology............................................................................................................................................................236

Affected Environment..............................................................................................................................................237

Environmental Consequences..................................................................................................................................238

Socio-Economics ........................................................................................................................................239

Introduction..............................................................................................................................................................240

Methodology............................................................................................................................................................240

Affected Environment..............................................................................................................................................241

Environmental Consequences..................................................................................................................................244
Draft Environmental Impact Statement

iii

Other Required Disclosures .........................................................................................................................248

Short-term Uses and Long-term Productivity ..........................................................................................................248

Unavoidable Adverse Effects...................................................................................................................................249

Irreversible and Irretrievable Commitments of Resources.......................................................................................249

Energy and Natural or Depletable Resource Requirements and Conservation Potential.........................................251

Urban quality, historic and cultural resources and the built environment................................................................251

Incomplete or Unavailable Information...................................................................................................................251

Compliance and Consistency...................................................................................................................................251

Chapter 4 –Consultation and Coordination ......................................................................................................253

Preparers and Contributors ..........................................................................................................................253

Interdisciplinary Team Members.............................................................................................................................253

Reviewers and Other Contributers...........................................................................................................................254

Consultation and Coordination ....................................................................................................................254

Consultation.............................................................................................................................................................254

Coordination ............................................................................................................................................................255

Distribution of the Draft Environmental Impact Statement .........................................................................255

Federal Agencies......................................................................................................................................................255

Glossary of Acronyms and Terms ...................................................................................................................257

Works Cited .....................................................................................................................................................263

Appendices .......................................................................................................................................................279

Appendices Table of Contents .....................................................................................................................279

Appendix A - Unit-Specific Information, Treatments and Road Actions ...................................................A-1

Appendix B - Issue Management ................................................................................................................B-1

Appendix C - Standard Operating Procedures and Best Management Practices........................................ C-1

Appendix D – Maps..................................................................................................................................... D-1

Appendix E – Threatened and Endangered Species Consultation Record .................................................. E-1

Appendix F-Past, Present and Reasonably Foreseeable Management Activities....................................... F-1

Appendix G-Changes in the Proposed Action ............................................................................................ G-1

Appendix H – Compliance and Consistency ................................................................................................ H-1

Index ..................................................................................................................................................................

List of Tables

Table 1. Successional condition of Elk Flat LSR within the project area. ...........................................................3

Table 2. Vegetation types in Elk project area, as classified by CWHR (CDFW, 2008). .....................................4

Table 3. Forest Plan land allocation, management prescription acres and percentages of total project area. ......4

Table 4. Desired Late-Successional and Old-Growth Characteristics as Described in the NWFP and LSRA ..17

Table 5. Seral Stage Condition of Treatment Units in the Project Area ............................................................19

Table 6. Introduction of Proposed Action Treatments in Response to the Purpose and Need ..........................39

Table 7. Alternative 1 Summary of Forest Restoration Treatments Including Meadow Enhancement.............59

Table 8. Alternative 1 Summary of Reforestation Actions ................................................................................61

Table 9. Alternative 1 Summary of Fuels Reduction Treatments ......................................................................62

Table 10. Alternative 1 Summary of Road and Landing Actions ......................................................................63

Table 11. Alternative 1 Summary of Hydrologic Restoration Actions ..............................................................64

Table 12. Alternative 2 Summary of Vegetation Restoration Treatments and Changes from Alternative 1 .....65

Table 13. Alternative 2 Summary of Reforestation Actions ..............................................................................67

Table 14. Alternative 2 Summary of Fuels Reduction Treatments and Changes from Alternative 1 ................68

Table 15. Summary of Alternative 2 Road and Landing Actions and Changes from Alternative 1 ..................69

Table 16. Alternative 2 Summary of Hydrologic Restoration Actions ..............................................................70

Table 17. Alternative 3 Summary of Vegetation Restoration Treatments and Changes from Alternative 1 .....71

Table 18. Alternative 3 Summary of Reforestation Actions and Changes from Alternative 1 ..........................73

Table 19. Alternative 3 Summary of Fuels Reduction Treatments and Change from Alternative 1 .................74

Table 20. Alternative 3 Road and Landing Actions by Forest Plan Allocation and Changes from Alternative 1

 ...................................................................................................................................................................75
Elk Flat Late-Successional Reserve Enhancement

iv Shasta-Trinity National Forest

Table 21. Summary of Alternative 3 Hydrologic Restoration Actions.............................................................76

Table 22. Summary of Forest and Meadow Restoration Treatments Involving Timber Harvest......................77

Table 23. Summary of Reforestation Treatments..............................................................................................79

Table 24. Summary of Fuels Reduction Treatments.........................................................................................79

Table 25. Summary of Road and Landing Actions...........................................................................................80

Table 26. Summary of Hydrologic Restoration Actions (acres) .......................................................................81

Table 27. Levels of Acceptable Mortality When Underburning Natural Stand Units - Underburn Only.........86

Table 28. Levels of Acceptable Mortality When Underburning Natural Stand Thinning Units.......................86

Table 29. Comparison of Effects of Alternatives Considered in Detail............................................................94

Table 30. Indicators and Measures of Effects for Silviculture and Forest Health...........................................125

Table 31. Alternative 1 Acres of Stand Density Reduction.............................................................................129

Table 32. Alternative 1 Average Percent of Pine-Limiting SDI in Thinning Stands......................................129

Table 33. Alternative 1 Acres of Insect and Disease Treatment and Risk Reduction.....................................131

Table 34. Alternative 1 Plantation Treatments to Accelerate Development ...................................................131

Table 35. Alternative 1 Average Trees Per Acre Over 24 Inches DBH In Thinning Units Pre and PostThinning ..................................................................................................................................................132

Table 36. Alternative 1 Average Overstory Tree DBH in Thinning Units Pre and Post-Thinning.................132

Table 37. Alternative 1 Average snags per acre over 20 inches DBH in Thinning Units Pre and Post-Thinning

.................................................................................................................................................................133

Table 38. Alternative 1 Acres of Increased Heterogeneity..............................................................................134

Table 39. Alternative 1 Acres of Hardwood Release ......................................................................................134

Table 40. Alternative 2 Acres of Stand Density Reduction.............................................................................137

Table 41. Alternative 2 Acres of Insect and Disease Treatment and Risk Reduction.....................................138

Table 42. Alternative 2 Plantation Treatments to Accelerate Development ...................................................138

Table 43. Alternative 2 Acres of Increased Heterogeneity..............................................................................139

Table 44. Alternative 2 Acres of Hardwood Release ......................................................................................140

Table 45. Alternative 3 Acres of Stand Density Reduction.............................................................................141

Table 46. Alternative 3 Acres of Insect and Disease Treatment and Risk Reduction.....................................142

Table 47. Alternative 3 Acres of Increased Heterogeneity..............................................................................143

Table 48. Alternative 3 Acres of Hardwood Release ......................................................................................144

Table 49. Average Percent of Pine-Limiting SDI ...........................................................................................145

Table 50. Average Trees Per Acre, > 24" DBH ..............................................................................................145

Table 51. Average Overstory DBH .................................................................................................................146

Table 52. Average Snags ≥ 20" DBH..............................................................................................................146

Table 53. Summary of Effects to Silviculture and Forest Health....................................................................147

Table 54. Fire Behavior...................................................................................................................................150

Table 55. Summary of Fire and Fuels Effects by Alternative .........................................................................157

Table 56. Indicators for NSO and sensitive species Relative to Purpose and Need and Key Issues...............161

Table 57. Acres of Suitable, Dispersal, and Capable Habitat and Acres of Critical Habitat (CH) in NSO

Action Area .............................................................................................................................................167

Table 58. Acres of Suitable and Capable Habitat in NGO and Fisher Analysis Areas and Project Area .......168

Table 59. Hydrologic Resource Indicators and Measures...............................................................................194

Table 60. ERA of Ongoing and Past Activities at the Sub-Drainage Scale ....................................................200

Table 61. Summary of Hydrologic Resource Elements and Indicators: The Expected Response by the 

Indicator from the Proposed Action, Alternatives and Effect to the Resource........................................206

Table 62. Soil Disturbance Recovery Rates....................................................................................................209

Table 63. Indicators and Measures of Effects for Soils...................................................................................210

Table 64. Elk Flat LSR Enhancement Project Erosion Hazard Rating (EHR)................................................216

Table 65. Soil Resiliency Index Rating...........................................................................................................216

Table 66. Comparison of Alternatives for Soil Productivity...........................................................................223

Table 67. Transportation Resource Indicators and Measures for Assessing Effects.......................................227

Table 68. Existing FTS Roads by Maintenance Level and Functional Class..................................................230
Draft Environmental Impact Statement

v

Table 69. Summary comparison of environmental effects ..............................................................................234

Table 70. Change in Employment from Previous Year, 2002-2010................................................................243

Table 71. Cost Benefit MatrixCost Description...............................................................................................244

Table 72. Present Net Values and Benefit/Cost Ratios of Action Alternatives...............................................246

Table Appendix A-1 Unit-Specific Existing Condition and Objective Information Pertaining to Treatment 

Prescriptions.............................................................................................................................................B-1

Table Appendix A-2. Unit Treatments by Alternative.....................................................................................B-6

Table Appendix A-3. Estimation of Actual Machine Piling by Unit.............................................................B-37

Table Appendix A-4. Stream Flow, Water Table Elevation and Riparian Vegetation Restoration...............B-40

Table Appendix A-5. Proposed Road Actions by Alternative.......................................................................B-41

Table Appendix A-6. Estimated Temporary Road Needs by Unit ................................................................B-44

Table Appendix E-1. Forest Plan land allocations and management areas within the Elk LSR Enhancement 

project area.............................................................................................................................................F-11

Table Appendix F-1. Present and Reasonably Foreseeable Future Activities in the Elk Vegetation 

Management Project’s General Cumulative Effects Boundary and the Project Boundary..................... G-2

Table Appendix H-1. Poverty Status by State and County, 2000 and 2005 .....................................................I-7

Table Appendix H-2. Seral Stage Diversity....................................................................................................I-26

Table Appendix H-3. Summary of Silviculture Treatments and Effects to Seral Stage.................................I-27

Table Appendix H-4. Summary of the Capability of NFS Lands in the Ash Creek Watershed.....................I-28

List of Figures

Figure 1. Vicinity Map.........................................................................................................................................2

Figure 2. Forest Plan Land Allocations ...............................................................................................................5

Figure 3. 2010 Aerial Imagery with Pine Mortality Areas Identified in the Southern Portion of the Elk Flat

LSR Enhancement Project Area. ...............................................................................................................14

Figure 4. Progression of Mortality in Unit 206 Vicinity Between 2005 and 2012............................................15

Figure 5. Pine Mortality in Stand 206 (2012)....................................................................................................16

Figure 6. The Approximate Desired Conditions for Late-Successional Stands: Stand 150 Showing Spacing 

and Structure (November 2012).................................................................................................................18

Figure 7. Existing Condition of Unit 155 with BA of 283 and SDI of 419 .......................................................22

Figure 8. Overstory Pine Density Exceeding Basal area 200 square feet per acre Prior to the Mortality (Unit 

201)............................................................................................................................................................22

Figure 9. Existing Condition of Typical 40+-Year Old Plantations Showing High Density, Lack of Structure 

and Mortality..............................................................................................................................................23

Figure 10. Dense Mixed Conifer Stand in the Project Area Displaying Heavy Surface Fuels..........................26

Figure 11. Larger Predominant Pine in Elk Meadow Established Prior to 1944. Smaller Trees Established Post 

Fire Suppression.........................................................................................................................................31

Figure 12. 2012 Aerial Photograph of Elk Flat Left Compared to 1944 Photograph on the Right Showing 

Increased Conifer Encroachment in the Dry Meadow Ecosystem.............................................................31

Figure 13. Young Stands and Stringers of Encroaching Conifer at Elk Flat Meadow with Interspersed 

Predominant Ponderosa Pine .....................................................................................................................32

Figure 14. Previously Treated Area at Southern End of the Project Area that Represents a Desired Condition 

for Hardwoods ...........................................................................................................................................33

Figure 15. Forest Road 41N19X Surface Runoff into Ash Creek .....................................................................36

Figure 16. Log jam collecting sediment and causing bank erosion along Ash Creek. ......................................37

Figure 17. Elk Project Soils Overlaid with Project Units ................................................................................214

Figure Appendix A-1. Diagram of Oak Release............................................................................................B-27

Figure Appendix D-1. Alternative 1 Modified Proposed Action Map ............................................................E-2

Figure Appendix D-2. Alternative 1 Fuels Map ..............................................................................................E-3
Elk Flat Late-Successional Reserve Enhancement

vi Shasta-Trinity National Forest

Figure Appendix D-3. Alternative 2 Map ....................................................................................................... E-4

Figure Appendix D-4. Alternative 2 Fuels Map.............................................................................................. E-5

Figure Appendix D-5. Alternative 3 Map ....................................................................................................... E-6

Figure Appendix D-6. Alternative 3 Fuels Map.............................................................................................. E-7

Figure Appendix D-7. Alternative 1 Aerial Imagery Map .............................................................................. E-8

Figure Appendix D-8. Wildland Urban Interface Map ................................................................................... E-9

Figure Appendix F-1. Cumulative Effects Boundary Map with Past Actions................................................G-8

(Grouped in 10-Year Increments) ...................................................................................................................G-8

Figure Appendix F-2. Ongoing and Future Projects in General Cumulative Effects Boundary.....................G-1
Draft Environmental Impact Statement

Shasta-McCloud Management Unit vii

Summary

Introduction

The Forest Service has prepared this environmental impact statement in compliance with the National 

Environmental Policy Act (NEPA) and other relevant Federal and State laws and regulations. This 

environmental impact statement discloses the direct, indirect, and cumulative environmental impacts that 

would result from the proposed action and alternatives considered in detail.

Additional documentation, including more detailed analyses of project area resources, may be found in the 

project planning record located in the online project record.

Location

Located in Siskiyou County, California, the Elk Late-Successional Reserve Enhancement project (Project or 

Elk Project) is approximately 9 miles northeast of the community of McCloud and 70 miles northeast of

Redding.

Management Direction

Forest Plan land allocations of Late Successional Reserve, Matrix-Commercial Wood Products, and Riparian

Reserves comprise the 3,519-acre project analysis area (project area). The Project area includes the entire Elk 

Flat LSR, which constitutes approximately 76 percent of the project area, plus adjoining Matrix-Commercial 

Wood Products Emphasis lands in and around Elk Flat meadow. Riparian Reserves overlay the LSR and 

Matrix lands along intermittent and ephemeral streams.

Late-successional reserves were established as part of the conservation strategy for species associated with

late-successional and old-growth forest ecosystems under the Northwest Forest Plan (NWFP, 1994). They 

maintain a functional late-successional and old-growth forest ecosystem and Shasta-Trinity National Forest 

Land and Resource Management Plan (Forest Plan) standards and guidelines are designed to maintain and 

protect these important ecosystems from large-scale losses due to uncharacteristic wildfire, insect and disease

epidemics, and major human impacts. Natural ecosystem processes such as gap dynamics, natural

regeneration, pathogenic fungal and insect activity, and low-intensity fire remain active (NWFP pp. Standards 

and Guidelines, p. B-1) The Forest Plan includes standards and guidelines for LSR and the Shasta-Trinity 

National Forest Late Successional Reserve Assessment (LSRA) provides LSR-specific guidance (Forest Plan 

pp. 4.37, 4.43; LSRA p. 174).

Commercial Wood Products lands are managed to obtain an optimum timber yield of wood fiber within the 

context of ecosystem management (Forest Plan p. 4.67). Riparian Reserves maintain or enhance riparian 

areas, wildlife and fisheries habitat, and water quality by emphasizing streamside and wetland management

(Forest Plan p. 4.59).

Wildland Urban Interface (WUI) associated with adjoining private lands and structures overlays portions of 

the project area. As part of the National Fire Plan, Federal agencies conduct fuels reduction in and around the

WUI to reduce the risk of stand-replacing wildfire to people, communities and natural resources while

restoring forest ecosystems to more closely match their historical characteristics.

Purpose and Need for Action and Proposed Actions

Existing Condition

The majority of forest stands in the Elk Flat LSR lack high quality late-successional habitat and are deficient 

in structural diversity. High stand densities slow tree diameter growth through competition for limited 
Elk Flat Late-Successional Reserve Enhancement

viii Shasta-Trinity National Forest

resources and impede the transition of early- and mid- successional forest to late-successional habitat. Most of 

the project area is ponderosa pine forest with about five percent of the project in a mixed conifer forest type,

where increased elevation transitions from essentially flat ground. Pine plantations ranging in age from just 

over 10 years to over 40 years old account for 25 percent of the project area. The Elk Flat Meadow is the only 

non-forest vegetation type and accounts for 15 percent of the project area. The natural stands range in age 

from 60 to 120 years old. 

Although most of the project area is ponderosa pine type forest, white fir is often the dominant species in the 

natural stands. Past harvest practices selectively removing the large, overstory pine and Douglas-fir, along

with decades of fire suppression have combined to encourage proliferation of white fir in the ponderosa pine 

forests. Preferential removal of the large overstory trees left smaller, more shade tolerant trees such as white 

fir.

Past fire suppression practices have encouraged unnaturally high density, heavy ladder fuels in the understory

and accumulation of brush. Fire suppression essentially removed a natural process from the landscape that 

otherwise would periodically remove surface fuels, much of the young small diameter understory trees and a 

portion of midstory and overstory trees. This transition in species composition occurs because white fir is

able to establish in a shaded understory environment and over time grow into the overstory. In contrast, pines

require more light and openings to successfully regenerate and do not survive well in a shaded understory

environment. The mixed conifer stands are similar in species composition to the ponderosa pine stands, but

generally contain a higher proportion of white fir in the overstory. Approximately 1,500 acres (54 percent of

land capable of producing late-successional forest) consists of this mid-successional forest of dense,

overstocked stands that are near or exceed site capability.

These over-crowded trees grow very slowly and stand vigor suffers. The existing conditions will delay or 

prevent development into late-successional forest on approximately 1,500 acres of early and mid-successional 

forested stands. The same conditions that affect successional development reduce the value of these forests for 

connectivity to existing late-successional forest.

High densities bring high tree mortality rates. Approximately 10 percent of the Elk Flat LSR is currently

comprised of large pockets of standing dead and down trees that increase the risk of additional habitat loss 

through increased fire hazard. Black stain root and Heterobasidion root disease, combined with the 

overstocked conditions, prolonged drought and insect attacks also contribute to mortality. The high numbers 

of standing dead trees pose an increased safety risk to visitors. The Forest Plan and LSRA define desired fuel 

loadings as 5 tons per acre in the Matrix-Commercial Wood Products portion of the project area and 5 to 35 

tons per acre in the LSR. Dead trees have fallen to the ground creating hazardous conditions approaching 60 

tons per acre of surface fuels in some areas that may increase to 100 plus tons as tree mortality spreads in 

coming years.

The Forest Service recognizes that natural disturbance is an important process within late-successional forest

ecosystems, but both human and natural processes have altered the disturbance regime in the Elk Flat LSR

such that without action, further habitat loss will result from density-related mortality, root disease, insect

attacks and predicted lethal fire effects. Without action, the ongoing stand-replacing events in the Elk Flat 

LSR will continue, jeopardizing existing and future late-successional habitat. Nesting, roosting, foraging, 

denning and dispersal habitat for late-successional dependent species would remain at risk, including 

approximately 720 acres of designated critical habitat for the northern spotted owl.

Conifer encroachment is diminishing the dry meadow areas of the McCloud Flats including Elk Flat. The 

meadow at Elk Flat is less than 50 percent of its extent in 1944 (USDA-FS, 2011 p. 69). Restoration of the 

natural fire regime and fire return interval would contribute to maintenance of the dry meadow vegetation 

conditions. Intermittent streams, such as Ash Creek and Swamp Creek, are recognized as providing 

considerable ecological value, especially in the absence of perennial flow, to systems dependent on them. 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit ix

Hydrologic processes, such as flooding, that maintained Elk Flat in the past are disrupted by lack of 

connection to Swamp Creek and its intermittent channel system. Historical road systems have diverted flow 

from Swamp Creek, concentrating flow and disconnecting it from spreading out over the meadow.

Ash Creek lacks riparian plant communities and floodplain interaction. Scattered riparian vegetation is limited 

to discontinuous locations where sunlight can reach the forest floor along Ash Creek, but is absent along 

Swamp Creek as well as other smaller intermittent channels. Woody debris recruitment is a necessary 

component in channels; however, input in large amounts is causing woody debris dams and channel widening. 

An accelerated rate of bank erosion along Ash Creek, where the accumulation of woody debris is high, diverts 

water around log jams.

Hardwoods have a high value to wildlife for foraging, nesting, denning and resting, as well as providing 

habitat for prey species. Aspen and California black oak occur as a scattered, very minor vegetation 

component within the project area, generally in the understory at a reduced abundance and decreased vigor. 

Fire exclusion has allowed white fir understories to become established in many stands. As white fir develops, 

it eventually overtops and shades out hardwoods. 

There are approximately 6.5 miles of unauthorized routes in the project area. Unauthorized routes were not 

designed as part of the Forest Transportation System (FTS). They are not maintained and are not open to legal 

vehicular access, are not shown on the Forest’s Motor Vehicle Use Map (MVUM). Unauthorized routes often 

present a potential resource concern for soils, vegetation, erosion, and wildlife. A 0.1-mile segment of an 

unauthorized route accesses a popular dispersed recreation site on the edge of Elk Flat meadow. There is no 

legal vehicular access to this long-established use area.

Purpose and Need for Action and Proposed Action

In comparing the desired conditions with existing conditions, the Forest Service identified one primary and 

five secondary purposes for action. To meet the needs identified for these six purposes, the Forest proposes 

activities within five broad categories of actions: forest restoration, fire restoration and fuels reduction, 

meadow restoration, hydrologic function and soils restoration, and transportation management and 

unauthorized route decommissioning. The six purpose and needs, with the corresponding objectives and 

proposed actions are:
Elk Flat Late-Successional Reserve Enhancement

x Shasta-Trinity National Forest

Primary Purpose and 

Need

Objectives and Proposed Actions

1. Risk Reduction - Risk 

reduction in early, mid and 

late-successional habitat 

and increased stand 

resilience to disturbance 

(Objectives I and III of the 

LSRA)

Objectives: Address insect and disease conditions, stand composition, 

structure and density concerns, and return the natural fire regime and 

reduce fuel loading to:

- promote resilience

- treat insect and disease centers

- preserve larger legacy ponderosa pines

- promote diversity

- promote and preserve habitat elements

- reduce ladder fuels

- reduce surface fuels

- restore the natural fire regime

Actions: Forest and fire restoration and fuels reduction treatments 

including:

- underburning on 3,482 acres

- machine piling and pile burning on up to 1,461 acres

- variable density thinning from below, with site-specific prescription 

elements on 1,273 acres of natural stands and 584 acres of 

plantations (acres exclusive of unthinned patches in at least 10% of 

the stand).

Secondary Purposes 

and Needs: Objectives and Proposed Actions

2. Accelerate Habitat 

Development -

Accelerate development 

of late-successional and 

old-growth forest 

characteristics (LSRA

Objective II) and promote 

late-successional habitat 

connectivity (LSRA 

Objective IV)

Objectives - Correct conditions that delay or prevent development of 

late-successional forest or reduce connectivity to existing latesuccessional forest. Actions – The actions described in #1 above also 

help address Purpose and Need #2. In addition:

- reforestation of 313 acres – Interplanting of 10 acres, planting of up 

to 2-acre group selections, and planting of a 79-acre extensive 

mortality area, to promote stand species and age diversity

-soils restoration through windrow respreading in 2 older plantations

totaling 167 acres

3. Meadow Restoration -

Restore meadow habitat 

in Elk Flat

Objectives – Return early seral vegetation, restore the natural fire 

regime, and restore hydrologic function in support of maintaining meadow 

habitat.

Actions - Forest, meadow, fire, and hydrologic function restoration, and 

fuels reduction treatments:

- meadow enhancement treatments on 379 acres to remove 

encroaching conifer (acres exclusive of 139 acres of unthinned 

patches within Elk Flat meadow).

- thinning with meadow enhancement to feather treatment into 

adjoining forest stands and on 56 acres of adjoining plantations 

- broadcast burning to return the natural fire regime on the 518 acre 

Elk Flat meadow unit

(also see P&N #5 below; where hydrologic function restorations actions 

overlap Elk Flat meadow they contribute to meadow restoration)
Draft Environmental Impact Statement

Shasta-McCloud Management Unit xi

Primary Purpose and 

Need

Objectives and Proposed Actions

4. Hardwoods - Retain 

hardwoods as a stand 

component at density 

levels commensurate with 

development of latesuccessional stands

Objectives – Assure hardwoods thrive and remain in stands at naturally 

occurring levels.

Actions - Forest restoration, fire restoration, aspen restoration adaptive 

management treatments:

- thinning with oak release (about 30 acres in total) and aspen release

(about 24 acres in total)

- fire restoration to maintain natural processes within the oak and 

aspen release areas

- aspen restoration adaptive management to monitor success and 

assure aspen restoration if initial release fails to stimulate suckering

5. Hydrologic Function 

Restoration - Increase 

Streamflow, Raise Water 

Table Elevation and 

Improve Water Quality 

and Vegetation Conditions 

within Riparian Reserves 

Associated with Elk Flat,

Ash and Swamp Creeks 

and Their Tributaries.

Objectives – Correct floodplain function, improve streambank stability, 

improve health of riparian vegetation, and return the natural fire interval in 

riparian reserves.

Actions - Hydrologic function restoration

- decommissioning of unauthorized routes that intersect stream 

channels, floodplain and stream recontouring on approximately 8.1 

acres

- recontouring stream channel and floodplains, add embedded woody 

debris on approximately 7.2 acres

- thinning in Riparian Reserves to promote riparian vegetation on 

approximately 211 acres (previously included in the natural stand 

thinning, under P&N #1)

- revegetation in the Riparian Reserves on approximately 94.9 acres

- underburning through riparian reserves underburning will promote 

riparian vegetation health.

6. Transportation 

Management - Manage 

the National Forest 

Transportation System

and Decommission 

Unauthorized Routes

Objectives – Restore unauthorized routes and provide legal access to an 

established dispersed site.

Actions – Transportation system management

- decommissioning 6.4 miles of unauthorized routes

- adding 0.1 mile of existing unauthorized route to the managed road 

system

Figure Appendix E-1 and Figure Appendix E-2 show the maps of the Proposed Actions. Thinning in natural 

stands will leave approximately 60 to 100 trees per acre, depending on the average size of the trees. Higher 

densities will be retained where wildlife rest/roost clumps of larger trees combine with smaller trees (less than 

10 inches DBH) to provide age and structural diversity that contributes to habitat function. Lower densities 

would be applied in areas that are primarily dominated by ponderosa pine, higher densities would be retained 

in mixed conifer, and white fir dominated stands. Instead of applying one target density across a stand, the 

variable density thinning prescription would help promote within-stand structural variation that contributes to 

habitat function for late-successional species, while providing the needed growing space, nutrients and water 

for the remaining trees.

All thinning treatments incorporate site-specific prescription elements designed to enhance late-successional 

habitat. Unthinned patches composing at least 10% of treated stands are excluded from silviculture treatments

as unthinned patches. Areas in the LSR that provide relatively large blocks of late-successional habitat will 

have no or moderate thinning treatments. These areas are not currently at risk, or are at risk but are being left 
Elk Flat Late-Successional Reserve Enhancement

xii Shasta-Trinity National Forest

untreated to maintain current nesting, roosting, denning and foraging habitat for the northern spotted owl, 

fisher and northern goshawk.

Radial thinning surrounding individual large pines is incorporated to increase retention of these valuable trees 

in stands. Small (less than 2-acres) group selections, replanted with non-host (for black stain root disease) 

species, will be inserted to break up disease centers and provide structural and species diversity. Conifer 

removal surrounding oak and aspen trees will encourage hardwood species retention, health and vigor. 

Thinning variations around insect or disease centers will remove symptomatic trees and create a buffer to 

prevent root-to-root contact between infected and non-infected pine. Light level increases on the forest floor 

inhibit black stain root disease progression; and regenerating mortality areas with a mix of non-host conifer 

species as well as widely spaced pine would discourage reinfection. Small group selections would regenerate 

pine in areas of dense, homogenous white fir and increase age diversity in older plantations.

While most conifers would be removed outside unthinned patches in the portion of Elk Flat meadow, in the 

LSR land allocation, largest, predominant pines would be retained. More conifers would be retained along the 

edges to “feather” the meadow treatment into surrounding stands.

Prescribed fire through underburning would be utilized every 5 to 10 years for 2 to 3 entries across the project 

area to return fire to the ecosystem. Where surface fuels are particularly heavy, machine piling and pile 

burning would occur before the first underburn entry.

Recontouring of existing disturbed areas impacting stream channels and floodplains will help return natural 

floodplain function and elevate the water table at Elk Flat. Thinning in Riparian Reserves will increase 

sunlight for riparian vegetation, regulate woody debris entry into stream channels, and strengthen 

streambanks.

One 0.3 mile segment of an existing road needs reconstruction, otherwise NTS roads used in the project 

would be maintained. Maintenance level-1 roads would be opened for the project, and then closed again at the 

conclusion. 6.4 miles of unauthorized routes would be decommissioned and 0.1 miles would be added to the 

NTS to access the dispersed area at Elk Flat.

Public Involvement

Scoping

The Notice of Intent (NOI) was published in the Federal Register on February 28, 2013 (USDA-FS, 2013). 

The NOI asked for public comment on the proposal by April 1, 2013. In addition, as part of the public 

involvement process, the agency prepared a scoping document that was mailed to interested individuals, 

organizations and agencies on February 14, 2013 (USDA-FS, 2013b). A Notice of Intent was published in the 

Redding Record Searchlight on February 27, 2013 and March 3, 2013. Public meetings were held March 5 

and March 26, 2013 in McCloud and Mt. Shasta. The Forest Service received 11 comment letters or emails. 

All comments were reviewed. Issues were identified from public scoping comments. Issues are statements of 

cause and effect, linking environmental effects to actions. Issues serve to highlight effects or unintended 

consequences that may occur from the proposed action and alternatives, giving opportunities during the 

analysis to reduce adverse effects and compare trade-offs for the decision maker and public to understand 

(FSH 1909.15 Ch. 12.4).

Key Issues

The Forest Service sorted the issues into two groups: key and non-key issues. Key issues were defined as 

those directly or indirectly caused by implementing the proposed action. Non-key were identified as those that 

are: 1) outside the scope of the proposed action; 2) already decided by law, regulation, Forest Plan, or other 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit xiii

higher level decision; 3) irrelevant to the decision to be made; or 4) conjectural and not supported by 

scientific or factual evidence. Other Comments were non-issues (e.g. no cause effect) or were identified as a 

question or a general statement (general in nature).

The Forest Service identified the following key issues during scoping:

Issue 1 – Large Trees and Snags

Large tree and snag removal and group selection logging would directly harm forest health and latesuccessional ecosystems in Late-Successional Reserves, Riparian Reserves and Critical Habitat; prevent

rather than facilitates forest succession processes; and is not consistent with the Northwest Forest Plan.

Issue 2 – Road Construction

Road construction directly harms forest health and wildlife and results in long-term impacts to soil health 

and productivity.

Issue 3 – Critical Habitat

Treatments within designated critical habitat for the northern spotted owl violate the 2011 Revised 

Recovery Plan and the 2012 Final Critical Habitat Rule for the Northern Spotted Owl.

Issue 4 – Mushroom Collection in Elk Flat

There will be negative impacts to Boletus mushroom growth and collection activities within Elk Flat.

Issue 5 – Machine Piling

Machine piling has disproportionately harmful impacts on watershed and soil resources.

Alternatives

Key Issues 2 and 3 prompted development of alternatives to the proposed action considered in detail. Issues 4 

and 5 prompted development of alternatives considered but not in detail. Analysis of concerns brought 

forward in Issue 1 is included in Chapter 3. Alternatives 1, 2, 3 and 4 are considered in detail. Details of the 

Alternatives are provided in Chapter 2. Summaries of actions by alternatives are provided in Table 22 through 

Table 26 (pp. 77 to 81) and Maps are in Appendix D.

Alternative 1-Modified Proposed Action

Alternative 1 is the Modified Proposed Action and the Agency Preferred Alternative. Alternative 1 is also the 

environmentally preferred alternative in the long term. It is a slightly modified version of what was scoped as 

the Proposed Action. Appendix H describes the incremental changes between the Proposed Action and 

Alternative 1. Alternative 1 Proposed Action is summarized above in the Purpose and Need for Action and 

Proposed Actions starting on page vii. The proposed treatments would be implemented through a combination 

of commercial and non-commercial thinning using mechanical and hand methods.

Alternative 2-No New Temporary Road Construction Other Than Those Required for 

Landing Use/Access

Alternative 2 responds Key Issue 2 regarding temporary road construction impacts on forest health and 

connectivity within the LSR. It is similar to Alternative 1 with the exception that no temporary roads would 

be constructed to complete project activities other than to access landings (typically, a landing “driveway” is 

about 200 feet). Project activities would be completed utilizing the existing FTS roads and existing 

unauthorized routes in the project area. Alternative 1 identified the need for approximately 2.9 miles of new 
Elk Flat Late-Successional Reserve Enhancement

xiv Shasta-Trinity National Forest

temporary road to complete thinning activities and no new permanent road construction was proposed. While 

the total acreage between Alternatives 1 and 2 treated is the same, the difference is between the treatment 

types. This alternative reduces the ability to mechanically treat approximately 103 acres with a corresponding 

decrease in needed landings. Hydrologic function restoration completed through mechanical means also drops 

slightly as access to the work areas decreases. All other project design criteria, thinning, fuels treatments, and 

road actions are the same as Alternative 1. Despite no new construction of temporary roads under Alternative

2 other than what is needed to access landings, the total project area would still be underburned and in 

accordance with RPMs. Maintenance and other actions relating to the FTS system would be the same under 

Alternative 2 as Alternative 1; however, the maintenance would be less intensive due to reduced hauling.

Alternative 3-No Treatment of Natural Stands within Designated Critical Habitat for 

the Northern Spotted Owl

Alternative 3 is responsive to the issue regarding the assertion that treatments within designated critical 

habitat for the northern spotted owl (NSO) violate the 2011 Revised Recovery Plan and the 2012 Final 

Critical Habitat Rule. Alternative 3 is the environmentally preferred alternative in the short-term. Under 

Alternative 3, no NSO critical habitat would be treated, with the exception of the thinning and other 

mechanical treatments proposed in seven plantations (7, 12, 13, 14, 208, part of 15, and part of 6). No units 

within critical habitat would be underburned under Alternative 3. In comparison to Alternative 1, the 

plantations in critical habitat that are prescribed for machine piling and pile burning would require additional 

fireline construction to provide a barrier between the pile burning areas and the surrounding untreated natural 

stands. Alternative 3 treats 270 fewer acres with silvicultural harvest than Alternative 1. All other project 

design criteria, thinning and fuels treatments and road actions outside of critical habitat are the same as under 

Alternative 1.

Alternative 4-No Action

Alternative 4 is the no action alternative. The analysis of the no action alternative provides reviewers a 

baseline to compare the magnitude of environmental effects of the action alternatives. Alternative 4 is the 

continuation of the existing condition, current management and ongoing activities in the project area. Current 

management and ongoing activities in the project area, as permitted under past, current or potential future 

NEPA may include road maintenance, hazard tree felling, fuelwood collection, over-snow vehicle use 

associated with the Pilgrim Creek Snowmobile Park, dispersed recreation (e.g., sightseeing, hunting), forest 

products collection and other permitted special uses. Additional thinning in unit 401 under the Pilgrim 

Vegetation Management Project is pending. This analysis includes modeling of stand growth and fire behavior 

that is predicted if no new action is taken in the project area. Under no action, no treatments or road actions 

would be implemented to accomplish the purpose and need and project resource objectives.

Alternatives Considered but Not in Detail

Five additional alternatives, as well as the original Proposed Action, were considered but not in detailed 

analysis. These Alternatives were either duplicative (the original Proposed Action), or did not adequately meet 

the Purpose and Need for Action or would cause more harm to the environment. Alternatives considered but 

not in detail include: Alternative 5 – No Treatment in Elk Flat Meadow to preserve Boletus mushroom 

habitat; Alternative 6 – Limit Harvest to Trees Less Than 10 Inches in Diameter; Alternative 7 – Eliminate the 

Use of Machine Piling within Treatment Units and Substitute Hand Piling; Alternative 8 – Limit Harvest to 

Trees Less Than 20 Inches in Diameter with the Elk Flat Late-Successional Reserve; and Alternative 9-No 

New Temporary Road Construction. Chapter 2 provides a detailed discussion of these Alternatives and why 

they were not considered in detail starting on page 117.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit xv

Conclusions

This DEIS discloses the environmental effects of four alternatives, including no action. The no action 

alternative is included to provide a baseline to compare the environmental effects resulting from 

implementing one of the action alternatives. 

Table 29 in Chapter 2, starting on page 94, provides a summary of the effects described in Chapter 3. 

Table 29 summarizes effects as they relate to the five Key Issues, six Purpose and Need statements, and other 

resource effects. In some cases, effects between the action alternatives are similar. The project is consistent 

with the Shasta-Trinity National Forest Land and Resource Management Plan and applicable laws, executive 

orders, and policies.

Effects Relative to Purpose and Need for Action

All action alternatives would meet the project purpose and need to varying degrees. Alternative 1 meets it to 

the highest degree. In some cases, Alternatives 2 and 3 are equal to Alternative 1 but otherwise provide a 

reduced response.

Primary Purpose

1. Risk Reduction in Early, Mid and Late-Successional Habitat and Increased Stand Resilience 

to Disturbance (Objectives I and III of the LSRA) (LSRA pp. 174-179)1

Alternative 1 provides the most risk reduction through the most extensive treatments for insect and disease 

activity, the most acres treated for stand density reduction, and the most fuels reduction and the greatest extent 

of fire regime restoration. Alternative 1 provides the highest likelihood of stand resilience immediately post 

project through the next twenty years. Alternative 2 is the next most effective response followed by 

Alternative 3. Alternative 3 leaves the natural stands within critical habitat at a similar risk to No Action and 

the Purpose and Need for Action would not be met within those stands.

Secondary Purposes

2. Accelerate Development of Late-Successional and Old-Growth Forest Characteristics 

(LSRA Objective II) and Promote Late-Successional Habitat Connectivity (LSRA Objective 

IV)

All action alternatives thin plantations and meet this Purpose and Need for action. Alternative 2 treats 14 

fewer acres of plantations than Alternatives 1 and 3. No action jeopardizes the potential of development of 

late-successional habitat. Alternative 1 also treats the most natural stands that may also be in a dense midsuccessional condition that jeopardizes development of late-successional habitat. Alternative 2 is slightly less 

effective than Alternative 1. Alternative 3 leaves mid-successional natural stands in critical habitat untreated, 

even with prescribed fire, leaving those stands in the same condition as No Action. The Purpose and Need for 

Action would not be met within the critical habitat natural stands under Alternative 3. All three action 

alternatives respread old windrows in two plantations to restore soil conditions and productivity. 

 1 In this context the LSRA is referring to young stands and plantations (up to 12.9” DBH) as early seral (LSRA p. Appdx. 

E) and reducing the risk of setting these young stands back successional through large-scale disturbance. The objective 

does not include areas that are not capable or are most valuable as early-seral habitat such as meadow.
Elk Flat Late-Successional Reserve Enhancement

xvi Shasta-Trinity National Forest

3. Restore Meadow Habitat in Elk Flat

Alternatives 1 and 3 restore Elk Flat meadow in full. Alternative 2 has a 25-acre reduction in conifer removal, 

but still provides for return of fire to the ecosystem. No Action jeopardizes retention of the early seral 

meadow habitat at Elk Flat.

4. Retain Hardwoods as a Stand Component at Density Levels Commensurate with 

Development of Late-Successional Stands

All three action alternatives fully restore aspen. In alternative 1 oak release would occur as a component of 

thinning treatments in stands totaling 567 acres. Alternative 2 has 33 fewer acres and Alternative 3 has 148 

fewer acres of stands treated with an oak release component, compared to Alternative 1. No action and the 

untreated areas of Alternatives 2 and 3 do not meet this Purpose and Need for Action.

5. Increase Streamflow, Raise Water Table Elevation and Improve Water Quality and 

Vegetation Conditions within Riparian Reserves Associated with Elk Flat, Ash and Swamp 

Creeks and Their Tributaries

All three action alternatives meet this Purpose and Need by restoring riparian vegetation and floodplains in 

the Riparian Reserves and treating stands to improve resilience to disturbance and attain all of the Aquatic 

Conservation Objectives (ACS). Thinning within the Riparian Reserves favors diversity, health and vigor of 

riparian vegetation, regulates input of woody debris, and enhances instream structure. Alternatives 2 and 3 

have slightly reduced benefits because of fewer acres treated. No Action does not meet this Purpose and Need 

for Action; current trends in hydrology would continue degrading the watershed and riparian areas and ACS

Objectives would not be met.

6. Manage the National Forest Transportation System and Decommission Unauthorized 

Routes

All three action alternatives meet this Purpose and Need for Action. They decommission 6.4 miles of 

unauthorized routes and provide access to the dispersed site at Elk Flat.

Effects Relative to Key Issues

Issue 1 – Large Trees and Snags

All action alternatives leave large predominant and dominant trees but decrease some trees over 24 inch DBH 

for density reduction in dense mid and late successional stands. Modeling results at year 20 project there 

would be considerably more trees per acre over 24 inches than presently exist, but do not account for insect 

and disease mortality. Observed mortality in the project area and research on density related pine mortality 

both indicate that higher numbers of trees per acre over 24 inches DBH are very unlikely to develop or persist 

over time. Density reduction thinning in all action alternatives would promote the resilience and survival of 

the residual large trees and meet the Purpose and Need.

Snags would be retained in all action alternatives except where hazard abatement is needed for human safety 

considerations. An estimate of 20 percent reduction was used to reflect snags removed for hazard abatement, 

but given the intent to retain snags as feasible, a higher proportion may be retained.

Issue 2 – Road Construction

No alternatives construct new FTS roads. All action alternatives decommission 6.4 miles of existing 

inventoried unauthorized routes. The No Action alternative does not decommission the routes. All three action 

alternatives construct new temporary road that is decommissioned at the end of the project. While Alternative 

2 was developed in response to this issue, Alternative 3 has slightly less estimated miles of new temporary 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit xvii

road construction due to the decreased thinning acres. Alternative 1 constructs 2.9 miles, Alternative 2 1.6 

miles (to access landings only), and Alternative 3 includes 1.5 miles.

Issue 3 – [NSO] Critical Habitat

A temporary reduction in the quantity and quality of northern spotted owl foraging habitat designated as 

critical habitat (PCE 3) will occur under Alternatives 1 and 2. PCE 3 will be degraded (habitat quality 

reduced) on approximately 224 acres, and will be downgraded to dispersal habitat (PCE 4) on approximately 

46 acres under Alternatives 1 and 2. The overall habitat function in the affected stands will not be removed. 

The treatments will affect less than one percent of the ECS-3 Critical Habitat Subunit and are considered 

discountable in terms of reducing the overall intended function of this Critical Habitat Subunit. Degraded 

foraging habitat still functions at the pre-treatment habitat level since important habitat elements are 

maintained in the post-treatment condition. Degraded habitat generally returns to its pre-treatment quality 

levels over 20 years. These are time estimates barring any events such as epidemic insect or disease 

outbreaks, or uncharacteristic stand replacing fires that can reset the seral stage in a stand, or part of a stand.

Alternative 3 treats 152 acres of Critical Habitat in plantations. There will be no reduction of nesting/roosting 

habitat or high quality foraging habitats treated by any alternative, and no treatments or effects will occur 

within suitable habitat designated as critical habitat under Alternative 3. Alternative 3 does not have shortterm adverse effects, but meets the Final Critical Habitat Rule on 472 fewer acres than Alternatives 1 and 3. 

316 acres (44%) of the PCE3 is maintained in current condition. All the PCE2/PCE3 remain at risk of loss 

from ongoing density-related mortality and the potential for uncharacteristic wildfire as the current trends 

would continue. All 120 acres of nesting/roosting are also maintained under current trends. At the project 

scale, 12 fewer acres of PCE1 would be treated to encourage progression to PCE3/PCE4.

No Action (Alternative 4) would the continue current trends leaving critical and existing and developing latesuccessional habitat elements vulnerable to loss from overstocking, insect and disease outbreaks and a 

potential reduction or removal of habitat or connectivity within 40 to 60% of the project area CH from 

potential passive crown fire.

Issue 4 - Boletus Mushroom Collection in Elk Flat [Boletus Habitat in Elk Flat]

All action alternatives reduce current or potential boletus mushroom habitat at Elk Flat through Meadow 

Enhancement treatment designed to restore and maintain early-seral meadow habitat in response to Purpose 

and Need #3. All action alternatives retain unthinned patches that would retain some existing boletus habitat

within Elk Flat meadow. Alternative 2 includes 25 fewer acres (at 354 acres of Meadow Enhancement) than 

Alternatives 1 and 3 (379 acres).

Issue 5 – Machine Piling

Alternative 3 includes the least amount of machine piling at up to 1,365 acres. Alternative 2 has up to 1,402

acres and Alternative 1 has the most at 1,461 acres. All units are expected to meet soil quality standards at the 

completion of the project. Existing detrimental compaction in four units would be alleviated. No action would 

leave the existing compaction. Effects to watershed health are mostly short-term disturbance to water-holding 

properties.

Decision to be Made

The Forest Supervisor is the deciding official and will decide whether to implement Alternative 1- Modified 

Proposed Action, or implement one of the other action alternatives that meet the project purpose and need, or 

take no action.

Draft Environmental Impact Statement

Shasta-McCloud Management Unit 1

Chapter 1. Purpose of and Need for Action

Introduction

The Forest Service has prepared this environmental impact statement in compliance with the National 

Environmental Policy Act (NEPA) and other relevant Federal and State laws and regulations. This 

environmental impact statement discloses the direct, indirect, and cumulative environmental impacts that 

would result from the proposed action and alternatives considered in detail.

Additional documentation, including more detailed analyses of project area resources, may be found in the 

project planning record located in the online project record.

Background

Many of the past century’s traditional approaches to land management and increasing ecosystem health 

problems have contributed to deficient late-successional habitat across the landscape and to more severe 

wildland fires. The Northwest Forest Plan (NWFP, 1994) calls for timely management decisions to ensure 

better results in projects that reduce the risk of uncharacteristic wildfire and restore forest health. Authorized 

under the National Forest Management Act of 1976 (NFMA), this project is designed to move the landscape 

toward the desired condition for the Elk Flat Late-Successional Reserve (LSR). Project design is guided by 

the visions, goals, strategies and design criteria embodied in the NWFP, the Shasta-Trinity National Forest 

Land and Resource Management Plan (Forest Plan, 1995) (including Management Areas 2 and 3), and the 

Forest-Wide Late-Successional Reserve Assessment (LSRA, 1999). There are no specific objectives for the 

Elk Flat LSR in the LSRA; however, the project is consistent with general objectives from the LSRA. It is 

also consistent with or incorporates recommendations from:

• the Forest Plan Aquatic Conservation Strategy (ACS) objectives,

• the Revised Recovery Plan for the Northern Spotted Owl (Recovery Plan) (USDI-FWS, 2011), and 

the Revised Critical Habitat Rule for the Northern Spotted Owl (Final Rule) (USDI-USFWS, 2012),

• the National Fire Plan (USDA & USDI, 2000),

• the Forest’s Fire Reference System (USDA-FS, 2015), and

• the Mount Shasta Watershed Assessment (Mt. Shasta WA) (USDA-FS, 2012) and Edson Watershed 

Assessment (Edson WA) (USDA-FS, 2011).

A project consistency review with the Regional Ecosystem Office (REO) will be required for proposed 

treatments, as stated in the NWFP Record of Decision (ROD) on pages C-12, 13, and 26.

Location

Vicinity

The Elk Late-Successional Reserve Enhancement Project (project) is located in Siskiyou County, California, 

approximately nine miles northeast of the community of McCloud and 70 miles northeast of Redding (Figure 

1). The project analysis area (project area) is approximately 3,519 acres. Elevation ranges from 4,000 to 4,500 

feet. The climate is characterized by cool, wet winters and warm dry summers with an average annual 

precipitation of 48 inches. Most precipitation falls between October and May (WRCC, 2010).
Elk Flat LSR Enhancement Project

2 Shasta-Trinity National Forest

Figure 1. Vicinity Map
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 3

Project Area

Figure 2 (page 5) shows the project boundary. The Elk Flat LSR is bounded on the north and west by 

privately owned industrial timberlands and by Matrix lands to the south and east. Table 1 shows the 

distribution of seral stages within the project area.

Table 1. Successional condition of Elk Flat LSR within the project area.

Successional Condition % of Area (capable of supporting late-successional habitat)

Late-successional 46%

Mid-successional 30%

Early-successional 24%

Total 100%

Located within the California Cascades Province (Agee, 1993), 75 percent of the 3,519 acre project area is 

classified as Ponderosa pine (Pinus ponderosa) forest. Southeast of Elk Flat, stands transition to a drier East 

Side Pine forest type. To the west and northwest, approximately 10 percent of the project area is classified as 

Sierra Mixed Conifer (SMC)2 and 15 percent as perennial grassland (PGS) under the California Wildlife 

Habitat Relationship (CWHR) System (CDFW, 2008).

3

Average elevation throughout most of the project area is 4,150 feet, and as lands transition from essentially 

flat to gentle predominantly east facing slopes, elevation increases to 4,400 feet. While the CWHR classifies 

the majority of the project area as ponderosa pine type, field reviews show there is a variety of species classes, 

primarily due to lack of fire to reduce white fir and cedar regeneration. Field reviews also show there are 

older remnant (or predominant) Douglas fir, white fir, cedar and sugar and ponderosa pine trees (see cover, 

Figure 6 p. 18)

The ponderosa pine-dominated natural stands are primarily within the eastern and southeastern extent of the 

project area. It is also a stand component in other lower elevation portions of the project area in mixed-conifer 

pine, and white fir-pine stands. The SMC forest type increases where there is an increase in elevation; 

dominated by white fir, incense cedar, ponderosa and sugar pine, and higher incidences of Douglas fir and 

black oak. Plantations range in age from just over 10 years to over 40 years, and account for 25 percent of the 

project area. The majority of the 20 to 40+ year-old plantations are ponderosa pine, with younger plantations 

having a wider range of species. The Elk Flat meadow is the only non-forest vegetation type and accounts for 

15 percent of the project area.

 2 The name “Sierra Mixed Conifer” should not be confused by the fact that the project falls within the Southern Cascade 

Mountain range. The SMC vegetation type is mapped within mid to higher elevations throughout much of the central 

North-South axis of the State of California including the Sierra Nevada and Southern Cascade mountain ranges.

3 The CWHR crosswalks to the CalVeg classification system and is used in the Forest’s 2007 existing vegetation layer to 

display reginal dominance types. Those types within the project area break down further into ponderosa pine (PP), mixed 

conifer fir (MF), ponderosa pine-white fir (PW) and mixed conifer pine (MP). Table 2 above only lists the CWHR 

vegetation types for the project area as a general reference. More information is available at 

http://www.fs.fed.us/r5/rsl/projects/classification/cv-cwhr-xwalk.html
Elk Flat LSR Enhancement Project

4 Shasta-Trinity National Forest

Table 2. Vegetation types in Elk project area, as classified by CWHR (CDFW, 2008).

CWHR Vegetation Type Percent Project Area

Sierra Mixed Conifer (natural) 10%

Ponderosa Pine (of which 25% is plantations) 75%

Perennial Grassland (Elk Flat Meadow) 15%

Based on Common Stand Exams completed in 2007 and additional fieldwork, measured tree ages in the 

natural stands ranges from 55 to 95 years with a minor scattered component of older remnant trees (see 

definition of predominant tree in the Glossary, p. 257). Stand ages range between 60 to 100 years in some 

stands and 80 to 120 years in others (USDA-FS, 2007). Younger understory trees are present to varying 

degrees but in most instances are strongly suppressed by the mid and overstory, notably in homogenous 

pockets of white fir.

Management Direction

Land allocations (Table 3 and Figure 2) and management areas from the Forest Plan include:

LSR - Late-successional reserves (LSR) associated with the Elk Flat LSR (designated as RC-360 in 

the LSRA (LSRA, 1999) comprise approximately 87 percent of the project area (3,074 acres).

Matrix – 445 acres of Matrix lands with commercial wood products (CWP) emphasis.

Riparian Reserves –240 acres of Riparian Reserves associated with Ash and Swamp Creeks and 

their tributaries overlay the Matrix and LSR allocations. Ash Creek bisects the Elk Flat LSR, flowing 

intermittently from late spring through early fall. The ephemeral channel of Swamp Creek cuts across 

the eastern section of the project area within and along Elk Flat meadow. Riparian Reserves overlay 

other land allocations and do not represent additional acres.

Table 3. Forest Plan land allocation, management prescription acres and percentages of total project area.

Forest Plan Land Allocation Forest Plan Management Prescription Acres

% of Total 

Treatment 

Area

Late-Successional Reserves

VII - Late-Successional Reserves and 

Threatened, Endangered, and Selected 

Sensitive Species

3,074 87%

Matrix VIII - Commercial Wood Products 445 13%

Total 3,519 100%

Riparian Reserves IX-Riparian Management overlaying LSR 204 included above

IX-Riparian Management overlying Matrix 36 Included above

Total 240
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 5

Figure 2. Forest Plan Land Allocations
Elk Flat LSR Enhancement Project

6 Shasta-Trinity National Forest

Late-Successional Reserves Allocation: Prescription VII-Late-Successional 

Reserves and Threatened, Endangered, and Selected Sensitive Species.

Late-Successional Reserves (LSRs) were established in the Forest Plan and are intended to provide oldgrowth forest habitat, provide for populations of species that are associated with late-successional forests, and 

to help ensure that late-successional species diversity will be conserved. Management direction in LSRs is to 

protect and enhance conditions of late-successional forest ecosystems, which serve as habitat for latesuccessional and old-growth related species, including the northern spotted owl (NWFP, 1994 p. 8) (Forest 

Plan pp. 4-37 to 4-43) (LSRA, 1999 p. 1).

Protection of LSRs includes reducing the risk of large-scale disturbance, including stand-replacing fire, insect 

and disease epidemics, and major human-caused impacts (LSRA p. 1). Both protection and enhancement can 

include application of silviculture and other treatments designed to reduce the risk of loss and/or accelerate 

development of late-successional stand characteristics (Forest Plan pp. 4-37 to 4-39), (LSRA, 1999 pp. 174-

203). The LSRA further describes that the overriding goal of management in LSRs is not only to maintain and 

protect, but also restore, conditions of late-successional forest ecosystems. Inherent in meeting this goal is the 

contribution towards the recovery of listed and petitioned late-successional associated species and treatments 

designed to provide these habitat conditions through time support the objectives for LSRs (LSRA, 1999 p. 

174).

Forest Plan goals describe that the network of LSRs is designated to provide for a viable population of 

northern spotted owls throughout their historic range (Forest Plan pp. 3-27). The Forest Plan adopts the 

NWFP as the Federal contribution to the recovery of the northern spotted owl. The Forest also expects the

network of land allocations that are withdrawn from active timber management4 (e.g., wilderness,

administratively withdrawn areas, wild and scenic rivers, others) to provide habitat adequate to maintain

viable, well-distributed populations of federally listed or proposed and Forest Service sensitive species (pp. 3-

27). Where active management occurs in Late-Successional Reserves and Riparian Reserves, standards and

guidelines and project design features for snags, logs, hardwoods, biodiversity and protection and

enhancement of habitats also contribute towards this goal.

The Forest Plan standards and guidelines direct that the Forest maintain or enhance habitat for threatened, 

endangered, and sensitive (TE&S) species consistent with individual species recovery plans (pp. 4-30), 

though recovery plans themselves are not regulatory.

Relationship to Other Plans

Late-Successional Reserve Assessment

The LSR allocation is managed under Forest Plan Prescription VII, Late-Successional Reserves and 

Threatened, Endangered, and Selected Sensitive Species. In accordance with NWFP Standards and Guidelines 

(NWFP, 1994 pp. C-11), the Forest prepared the Late-Successional Reserve Assessment (LSRA). The purpose 

of the LSRA was to develop management strategies for the LSRs, determine their sustainability, and provide 

information to decision makers for managing LSRs to meet Forest Plan goals and objectives. It describes four 

objectives that guide development and application of treatments in LSRs.

 4 Including those land allocations such as Late-Successional Reserves or Riparian Reserves that may be treated to

reduce the risk of losing habitat, to enhance habitat, and to contribute to Aquatic Conservation Strategy objectives but that

do not regularly contribute to allowable sale quantity.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 7

The Elk Flat LSR is described as a priority for treatment objective II, which is to “promote the continued 

development of late-successional forests” (LSRA, 1999 p. 178). The project is also designed to meet the other 

three treatment objectives (p. 175):

I. Protect existing late-successional habitat from threats (of habitat loss) that occur inside and outside 

LSRs.

III. Protect mid and early-successional vegetation from loss to large-scale disturbance events.

IV. Promote connectivity of late-successional habitat within LSRs.

As described in the LSRA and NWFP, where levels of risk in an LSR are particularly high, they may require 

additional measures. Consequently, management activities designed to reduce risk levels are encouraged in 

those LSRs even if a portion of the activities must take place in current late-successional habitat. While risk 

reduction efforts should generally be focused on young stands, activities in older stands may be appropriate if:

1. the proposed management activities will clearly result in greater assurance of long-term 

maintenance of habitat,

2. the activities are clearly needed to reduce risks, and

3. the activities will not prevent the LSR from playing an effective role in the objectives for which 

they were established (NWFP pp. C-13) (LSRA, 1999 p. 174).

Matrix Allocation: Prescription VIII-Commercial Wood Products (CWP)

Commercial Wood Products lands are managed to obtain an optimum timber yield of wood fiber within the 

context of ecosystem management. Investments will be made in road construction, fuels management, 

reforestation, vegetation management, and timber stand improvement. Timber stands will be managed to 

obtain optimum growth and yields using cultural practices (Forest Plan pp. 4-67).

Riparian Reserves Allocation: Prescription IX-Riparian Management

Riparian Reserve standards and guidelines apply to all Forest lands where Riparian Reserves overlap other 

allocations. Riparian Reserves are managed under Prescription IX, Riparian Management to maintain or 

enhance riparian areas, wildlife and fisheries habitat, and water quality by emphasizing streamside and 

wetland management (Forest Plan pp. 4-59). All management activities must meet or not prevent attainment 

of the Aquatic Conservation Strategy (ACS) Objectives (NWFP pp. B-9, 10) (Forest Plan, 1995 pp. 4-53). 

Riparian Reserve widths are determined by the category of stream or waterbody and are established during 

the watershed analysis process. Two watershed analyses (WA) have been completed that include the Elk 

project area (USDA-FS, 2011; USDA-FS, 2012).

Other Designations

Wildland-Urban Interface

Wildland Urban Interface (WUI) as defined in the Forest’s Fire Reference System (USDA-FS, 2015)

encompasses approximately 1,135 acres of the project area (see Appendix D, Maps, Figure Appendix E-8).

The policy of providing for firefighter and public safety is implicit in considering all fire and fuels desired 

conditions, regardless of land allocation and management direction (USDA-FS, 2009).

Northern Spotted Owl Critical Habitat

The FWS revised critical habitat for the NSO on December 4, 2012 and the Rule was finalized January 3, 

2013 (USDI-FWS, 2012). There are 720 acres in the project area, part of Unit 8, Subunit 3-East Cascades 
Elk Flat LSR Enhancement Project

8 Shasta-Trinity National Forest

South [ECS-3]. Critical habitat is located in the western portion of the Elk Flat LSR; it is not designated in the 

surrounding private lands or the project’s ponderosa pine-dominated stands or meadow at Elk Flat.

The Final Rule describes the East Cascades Unit (pp. 71930-71931) and ECS-3 subunit. ECS-3 consists of 

112,179 acres of land managed by the Forest Service under the NWFP, and Forests that overlay the subunit 

(Shasta-Trinity, Klamath, Modoc). Its function is to “provide demographic support in an area of sparsely 

distributed, high-quality habitat and Federal land and to provide population connectivity between subunits to 

the north and south”. Special management considerations in ECS-3 are “required to address threats to the 

essential physical or biological features of critical habitat from current and past timber harvest, losses due to 

wildfire and the effects on vegetation from fire exclusion, and competition with barred owls” (p. 71931). The 

Final Rule states: “the increase and enhancement of NSO habitat in this subunit is especially important for 

providing essential connectivity between currently occupied areas to support the successful dispersal of

NSOs, and may also help to buffer NSOs from competition with the barred owl” (p. 71931).

As with the Recovery Plan, the Final Rule describes that in the drier, more fire-prone regions of the NSOs 

range, habitat conditions will likely be more dynamic, and active management may be required to reduce the 

risk to essential physical or biological features of critical habitat from fire, insects, disease and climate 

change. It also describes that long-term NSO recovery could benefit from forest management actions that 

restore or maintain ecological processes and resilience (USDI-FWS, 2012 p. 71908).

While the Rule recommends active management, it also describes that treatment activities should be focused 

on lower quality habitat with lower relative habitat sustainability and be based on ecological restoration and 

application of ecological forestry principles, or be focused where ecological conditions are most departed 

from the natural or desired range of variability. It recommends:

1. Following the NWFP guidelines and focusing on lands in or outside LSRs where uncharacteristic 

disturbance has occurred, or where the landscape management goal is to restore more natural or 

resilient forest ecosystems;

2. Avoiding or minimizing activities in active NSO territories (or high-quality habitat in those

territories), and; 

3. Using an active adaptive forest management framework to assess effects of activities on NSOs 

and their prey (USDI-FWS, 2012 pp. 71882-71883).

Other

The project area is not in a congressionally designated or inventoried roadless area, a Key Watershed (Forest 

Plan p. 4.59) or a municipal watershed.

Revised Recovery Plan for Northern Spotted Owl

The Revised Recovery Plan for the Northern Spotted Owl (Recovery Plan) was released in June 2011 (USDIFWS, 2011). The Recovery Plan identifies primary range-wide threats to the northern spotted owl (NSO) as 

competition with barred owls; ongoing loss of spotted owl habitat as a result of timber harvest, habitat loss or 

degradation from stand-replacing wildfire and other disturbances; and the loss and reduced distribution of 

spotted owl habitat due to past activities (pp. vii, II-2). It describes a Recovery Strategy that includes habitat 

conservation and active forest management to address these threats, including conserving more occupied 

habitat and unoccupied high-value habitat; and encouraging and initiating active management actions that 

restore, enhance and promote development of high value habitat, consistent with broader ecological 

restoration goals (pp. III-4 to III-5).

Specific to the dynamic, disturbance-prone, drier forests of the California Cascades physiographic province 

where the Elk project is located, it recommends active management “in a way that reconciles the overlapping 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 9

goals of NSO conservation, responding to climate change and restoring dry forest ecological structure, 

composition and processes, including wildfire and other disturbances” (pp. III-20 to III-21). The California 

Cascades scores high in the Recovery Plan in terms of threats from ongoing habitat loss as a result of wildfire, 

and the effects of fire exclusion on vegetation change (pp. I-8). Management recommendations within dry 

forest ecosystems is fully described in the Recovery Plan, including seven principles that should be part of 

any dry forest restoration treatment (pp. III-20 to III-40).

Those principles, and recommendations under Recovery Actions 10 and 32, were utilized throughout project 

development. Refer to Appendix H for additional discussion on how the project is meeting the goals and 

standards and guidelines from the Forest Plan (pp. 3-27, 4-30). There are no other available species recovery 

plans that apply to the project.

Purpose and Need for Action

Introduction and Summary

The purposes, or objectives, of the project are derived from the project area management direction, including 

the Forest Plan and LSRA objectives, priorities and criteria. The need for action is determined by comparing 

the existing conditions with the desired conditions relative to the identified purposes.5 Existing conditions, 

causal mechanisms and needs for action in relation to the Forest Plan desired conditions were identified in 

Step 5 of the Edson WA and Chapter 5 of the Mount Shasta WA. Guided by the needs identified in the WAs, 

the interdisciplinary team further examined forest and meadow habitat and stream channel morphology within 

the project area to determine existing conditions including age, stocking, mortality, fuel loading, and presence 

of insects and disease, and stream channel function. One primary and five secondary purposes were identified.

The primary purpose is:

1. Risk Reduction in Early, Mid and Late-Successional Habitat and Increased Stand Resilience to 

Disturbance (Objectives I and III of the LSRA) (LSRA pp. 174-179)6

Secondary purposes are:

2. Accelerate Development of Late-Successional and Old-Growth Forest Characteristics (LSRA

Objective II) and Promote Late-Successional Habitat Connectivity (LSRA Objective IV)

3. Restore Meadow Habitat in Elk Flat

4. Retain Hardwoods as a Stand Component at Density Levels Commensurate with Development of 

Late-Successional Stands

 5 The Forest Plan describes the desired condition, which is embodied in the forest goals and objectives, further clarified 

by the standards and guidelines, and is described for each Management Area (Forest Plan p. 4.6). The LSRA provides 

desired condition descriptions (starting page 162) and conditions existing at the time of publication in 1999 (LSRA, 

Chapter 2). The Recovery Plan provides objectives for conserving NSO habitat. Additionally, compliance with regulatory 

frameworks, consistency with policy, and consideration of best available science (per 40 CFR 1607.3) also helps guide 

identification of desired condition.

6 In this context the LSRA is referring to young stands and plantations (up to 12.9” DBH) as early seral (LSRA p. Appdx. 

E) and reducing the risk of setting these young stands back successional through large-scale disturbance. The objective 

does not include areas that are not capable or are most valuable as early-seral habitat such as meadow.
Elk Flat LSR Enhancement Project

10 Shasta-Trinity National Forest

5. Increase Streamflow, Raise Water Table Elevation and Improve Water Quality and Vegetation 

Conditions within Riparian Reserves Associated with Elk Flat, Ash and Swamp Creeks and Their 

Tributaries.

6. Manage the National Forest Transportation System and Decommission Unauthorized Routes

Rationale for each purpose and the identified need for action in the project area is discussed in detail below. 

Crosswalks to Forest Plan direction are included.

Purpose and Need Discussion

1. Reduce Risk from Insects, Disease and Fire in Early-, Mid- and LateSuccessional Habitat, and Increase Stand Resilience to Disturbance (LSRA pp. 

174-179) 7

Need for Action

Action is needed because the existing conditions have departed from the desired conditions for:

1. insect and disease conditions,

2. stand composition, structure, and density,

3. fire regime, fuel loading and fire behavior.

The majority of the forested portion of the project area is departed from the natural fire regime and is at risk 

of large-scale undesirable disturbance due to existing fuel loading from the ongoing mortality that has 

occurred from high stand densities and associated stress from insects, disease and drought conditions. Without 

action, further stand and structural composition will be lost due to a combination of continued density related 

mortality, root disease, insect attacks and predicted lethal fire effects. These losses have and would continue 

to result in a further loss and decline of late-successional habitat and a failure to maintain or meet Forest Plan

direction and LSRA objectives for the LSR and surrounding stands.

Background

As described in the NWFP (pp. B-7) and (LSRA p. 2) natural disturbance is an important process within latesuccessional forest ecosystems but humans have altered the disturbance regimes. Natural fire disturbance 

serves a key role in creating and maintaining vegetation community diversity and in consuming fuels 

accumulations. Due to fire suppression, some forests have become quite dense and multistoried, primarily 

from the invasion of shade-tolerant species. Density reduction in mid-level canopy layers by thinning may 

reduce the probability of crown fires occurring. At the same time, these forests may have become much more 

vulnerable to insects and diseases. The Recovery Plan describes that frequent and extensive outbreaks of 

native forest insects, such as bark beetles, have occurred historically in the western U.S. However, the 

anthropogenic influences through past management and fire suppression have altered the landscape vegetation 

patterns, subsequently altering the timing, duration and magnitude of outbreaks (pp. III-27).

Frequent low- to moderate-severity fires can remove dead fuel accumulations, as well as a minor portion of 

living vegetation, while leaving most of the larger overstory vegetation intact. It also frees up resources, 

 7 In this context the LSRA is referring to early seral forest habitat, which is defined as young stands and plantations (up to 

12.9” DBH) (LSRA p. Appdx. E)), and reducing the risk of setting these young stands back successionally through largescale disturbance. The objective does not include areas that are not capable or are most valuable as early-seral habitat 

such as meadows.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 11

which reduces competition among the surviving vegetation. This allows residual and overstory trees to grow 

more quickly and forest stands to develop more structural diversity. Small openings and areas of reduced 

overstory shading can also be created by frequent low- and moderate-severity fire, which allows understory 

vegetation to develop. Frequent low intensity disturbances of insects and disease can also create canopy 

openings and gaps in various strata of vegetation, and disease played an important role in shaping and 

maintaining special habitats in pre-settlement conditions (USDA-FS, 2011 p. 67). Without these frequent, 

lower intensity disturbances, forest stands continually grow until dieback begins, largely as a result of 

competition between trees for resources (e.g. water, nutrients, and sunlight). Under conditions of increasingly 

high density and competition for resources, tree growth slows or stagnates, tree vigor declines and forest 

stands become increasingly at risk for large-scale disturbance from events including insect outbreaks and high 

intensity fire.

The 1994 NWFP describes large-scale disturbances as natural events, such as fire, that can eliminate spotted 

owl habitat on hundreds of thousands of acres (pp. C-12). As a principle objective of silvicultural systems 

within LSRs, it identifies prevention of large-scale disturbances by fire, wind, insects and diseases that can 

destroy or limit the ability of the reserves to sustain viable forest species populations (p. B-5). It also calls for 

timely management decisions to ensure better results in projects that reduce the risk of catastrophic wildfire 

and restore forest health (pp. B.1, C.12 - 13). The Plan’s 20-year monitoring report summary for the ‘Status 

and Trend of Late-successional and Old-growth Forests’ states: “some portions of the NWFP area have been 

setback by decades from achieving those outcomes [expectations for older forest abundance, diversity, and 

connectivity] particularly resulting from large wildfires in the fire-prone portions of the NWFP area” ( (Davis, 

et al., 2015). Also, the summary report for the 20-year monitoring of the ‘Status and Trend of Northern 

Spotted Owl Habitat’ states: “large wildfires continue to be the leading cause for loss of NSO habitats on 

federal lands. Most of these fire-related losses have occurred within the network of large reserves that were 

designed for the protection and restoration of habitat for long-term northern spotted owl conservation” (Davis, 

et al., 2015). The summary report further notes that the loss rates in fire prone portions of the NSOs range 

exceeded the expected 2.5% rate for the 20-year period at rates of 3.9-7.4% per decade, including the 

California Cascades area. Most large wildfires and resulting habitat losses have occurred in the federally 

reserved land use allocations [including LSRs] designed for NSO conservation (Davis, et al., 2015). Climate 

change is also expected to expand the area of fire-prone landscapes and an increased frequency of large 

wildfires this century has already been observed.

The California Cascades Province is identified as being an area of elevated risk to large-scale disturbance 

from changes in the characteristics and distribution of mixed-conifer forests that have resulted from fire 

suppression. Risk reduction and efforts are encouraged where they are consistent with the overall 

recommendations in management guidelines and the Recovery Plan notes that in some cases in dry forests, 

failure to intervene or restore forest conditions may lead to dense stands heavy with fuels and in danger of 

stand-replacing fires and insect and disease outbreaks. Active management is recommended to restore dry 

forest ecological structure, composition and processes, including wildfire and other disturbances (pp. III-20).

Within both the California Klamath and California Cascades Provinces, the greatest threat to further loss and 

degradation of habitat for late-successional associated species is catastrophic wildfire (LSRA p. 174). As 

noted in the Recovery Plan (USDI-FWS, 2011 pp. III-6-7):

Natural landscape resilience mechanisms have been decoupled by fire exclusion and wildfire suppression 

activities (Hessburg et al. 2005, Moritz et al. 2011). Before the era of management, patchworks of burned 

and recovering vegetation, caused by mostly small and medium-sized fires, reduced the likelihood of the 

largest fires, which usually resulted from extreme weather events. Twentieth century fire suppression 

eliminated most of these fires, and forest landscapes are now susceptible to large wildfires.

The LSRA (p. 175) identifies the late-successional habitat in the Elk Flat LSR as at risk of loss to large-scale 

disturbance due to a high percent of expected late-successional sustainable level (5th highest LSR on the 

Forest at the time the LSRA was published). This LSR was included among the highest priority for treatment 
Elk Flat LSR Enhancement Project

12 Shasta-Trinity National Forest

on the Forest for early to mid-successional habitat (objective III), however ongoing mortality between 2009 

and present creates a high priority under criteria b, c, and d (pp. 179-180).

Desired and existing conditions relative to risk reduction (stand composition and structure, density, insects 

and disease, and fire and fuels) are described below.

Insects and Disease

Desired Condition

It is desirable to keep insects and related mortality at levels more closely associated with historic levels. This 

would fall into the range of no more than 0.2 to 0.5% of standing live biomass mortality/acre/year with 

occasional spikes of 1 to 1.5% during drought periods (LSRA p. 163). The Edson WA identified maintaining 

resilience of forest stands with respect to insects and disease as a key concern to address (p. 22).

Mortality levels caused by bark beetles in ponderosa pine stands are directly related to increases in stand 

densities (Zhang, et al., 2013; Oliver, et al., 1997; Oliver, 1995). In the absence of other forms of disturbance,

stands grow increasingly dense over time until a threshold is reached and bark beetle mortality occurs. It has 

been widely held that a zone of imminent mortality begins when Stand Density Index8 (SDI) reaches 230. At 

this point mortality from bark beetles begins to increase; culminating at a maximum SDI of 365 (Oliver, et al., 

1997; Oliver, 1995). As stands approach this maximum SDI, bark beetle outbreaks and wide-spread mortality 

develops, often killing large overstory pines and dropping stand densities to near or below an SDI of 230 

(Oliver, et al., 1997; Oliver, 1995). Recent research (Zhang, et al., 2013) found that the imminent mortality 

SDI may be as high as 425, depending on site index, however the relationship of stand density driven pine 

beetle mortality remains the same. This relationship is evident with the widespread pine mortality from 

western pine beetle in the Elk project area.

Existing Condition

Although ponderosa pine mortality has been occurring regularly across the entire McCloud Flats, primarily 

due to black stain root disease (Leptographium wageneri) and western pine beetle (Dendroctonus brevicomis), 

pine mortality has increased dramatically over the past five years in the project area. Ponderosa pine trees 

weakened by black stain root disease provide a ready food supply that can support large build-ups of pine 

beetle populations. When the western pine beetles attack trees, they emit a chemical signal to attract more 

beetles, causing them to aggregate and expand out as they look for more food sources.

Due to the combined overstocking that increases individual tree stress stressed trees and the root disease, there 

are pockets of recent and ongoing mortality in ponderosa pine in numerous stands throughout the project area 

(Snyder, 2012). With a large beetle population outbreak, pine that are not infected with black stain root 

disease, but are otherwise stressed by dense conditions or other factors, will also be attacked and killed. Direct 

field observations and long term (six consecutive years or more) aerial detection of pine mortality patterns 

indicative of black stain root disease have identified certain stands as known or likely areas of black stain root 

disease.

Mortality pockets range from several (10 to 25) trees to over 70 acres. In 2011, approximately 245 acres of 

pine mortality was identified based on field observations and aerial photography imagery taken in 2010. 

Expanded areas of mortality were observed in 2012 and 2014 and have continued to expand (Payne, 2015b).

 8 Stand Density Index (SDI) is a measure that expresses relative stand density in terms of number of trees as related to 

the quadratic mean diameter in the stand. In other words, SDI is the degree of tree crowding within the stand.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 13

Considerable bark beetle mortality has also occurred throughout the project area outside of stands where black 

stain root disease has been detected due to tree stress caused by dense conditions and other factors. Ongoing 

mortality is expected to continue as overstocked stand conditions support elevated bark beetle populations, 

including in areas where black stain has not been found.

The combination of overstocking (high stand density), root disease, and subsequent western pine beetle 

infestation has and continues to result in mortality of the larger diameter (20-inch, plus) ponderosa pine that 

were providing desirable habitat. This loss is particularly striking considering the lack of live large overstory 

pine or other species in the project area. Mortality is also spreading throughout pine plantations of various

ages. Since the LSRA was published (1999), mortality levels in the Elk Flat LSR have increased dramatically, 

now putting it at “high risk to loss by large-scale disturbance due to adjacent areas of extreme fire hazard: 

identified as having two or more years of moderate or high levels of insect and disease-related mortality . . .”

(LSRA p. 180).

Figure 3 shows the areas of mortality mapped on the south end of the project area based on field review and 

aerial imagery from 2009 and 2010. Figure 4 compares aerial imagery in the vicinity of unit 206 (the 

extensive mortality area) between 2005 and 2012. Figure 5 is a photograph of stand 206.
Elk Flat LSR Enhancement Project

14 Shasta-Trinity National Forest

Figure 3. 2010 Aerial Imagery with Pine Mortality Areas Identified in the Southern Portion of the Elk Flat LSR

Enhancement Project Area.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 15

2005 2012

Figure 4. Progression of Mortality in Unit 206 Vicinity Between 2005 and 20129

 9 Unit 206 shown in the image is a plantation that was thinned in the interval. Other areas in the images were not thinned.
Elk Flat LSR Enhancement Project

16 Shasta-Trinity National Forest

Figure 5. Pine Mortality in Stand 206 (2012)

Heterobasidion root disease is also present in the project area and has infected white fir in units 160 (Snyder, 

2012) and evidence is present in other units. The presence of slow-growing tops on many understory and 

intermediate white fir suggest that Heterobasidion is widespread within the stand. Because the use of borate 

stump treatments (used to reduce the spread of Heterobasidion) did not become a routine treatment until the 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 17

latest revision of the Forest Plan, there are numerous Heterobasidion root disease pockets on the McCloud 

Flats. Both black stain and Heterobasidion root disease may be present in the same stand.

Dwarf mistletoe (Arceuthobium spp.) infections are also present in both white fir and ponderosa pine. Fir 

engraver beetles (Scolytus ventrallis) are present in dead and dying white fir. With few exceptions dwarf 

mistletoe and fir engraver beetle presence is generally light and not above endemic levels.

Stand Composition, Structure and Density

Desired Condition

Composition and Structure

The Forest Plan (pp. 4-4) calls for a diversity of plants at all ecosystem scales. The desired condition within 

LSR is late-successional and old-growth forest in which structure and composition are consistent with site 

conditions and ecological processes (LSRA p. 162). Late-successional forests include mature and old-growth 

age classes. The intent in LSR it to maintain natural ecosystem processes such as gap dynamics, natural 

regeneration, pathogenic fungal activity, insect herbivory, and low-intensity fire (NWFP pp. B-1).

The Forest Plan (pp. 4-81, 4-85) describes late-successional stands as containing large numbers of “OldGrowth” trees with large branching, flattened or dead tops, and high levels of decadence (broken tops, old and 

decaying wood). These older stands are structurally diverse and often multi-storied. The LSRA describes latesuccessional conditions as structurally diverse (p. 169). Conditions should not be uniform across the 

landscape. Denser patches should be intermixed with the more open areas. Decadence should be present or 

even obvious in the stand; snags and coarse woody material would be common, although in varying 

concentrations throughout the stand. Deformed, broken and diseased trees would also be common enough to 

provide nesting and roosting opportunities for wildlife. There would be gaps created by natural mortality 

where early-successional vegetation is present. Desired forest vegetation structure and composition would

vary according to the vegetation community, soil conditions, site class, elevation, slope, aspect, climatic 

influences and other site circumstances. Table 4 provides the late-successional and old-growth characteristics 

from the NWFP and the LSRA.

Table 4. Desired Late-Successional and Old-Growth Characteristics as Described in the NWFP and LSRA

NWFP (p. B-2, B-5) LSRA (pp. 1, 164-165)

Multispecies and multilayered assemblages of trees in the 

mixed conifer types. Multiple canopy layers. Live old-growth trees.

Moderate-to-high accumulations of large logs and snags. Snags.

Moderate-to-high canopy closure. Gaps in the canopy. Coarse Woody Debris.

Moderate-to-high numbers of trees with physical 

imperfections such as cavities, broken tops, and large 

deformed limbs.

Logs in streams.

Moderate-to high accumulations of fungi, lichens, and 

bryophytes.

Smaller understory trees [Some smaller diameter (<10 

inch DBH) trees provide perching and roost sites, 

contributing to vertical and horizontal structure (Carey, 

2006).] Patchy understory.

Snags - Snags should be in a variety of size and decay classes and distribution should range from individuals 

to larger aggregations. Desired numbers of snags should vary based on vegetation type with the average 

number of snags at 3 to 7 per acre at least 20 inches in diameter. It is desired to have scattered individual 

snags and down logs as well as larger aggregations that result from natural events such as wildfire, insect 
Elk Flat LSR Enhancement Project

18 Shasta-Trinity National Forest

outbreaks and wind-storms. Larger aggregations are desired as long as they do not put other important latesuccessional characteristics at risk to large-scale disturbances. The desired levels identified in the vegetative 

descriptions (Tables 3-1 through 3-4 of the LSRA) represent an average for a landscape or treatment area (i.e. 

100 acres). Numbers of snags and down logs can vary on any particular acre (LSRA, 1999 p. 164).

Coarse Woody Debris (CWD) - Large woody material is defined as at least five logs per acre in contact with 

the soil surface. Desired logs are about 20 inches in diameter and 10 feet long, representing a range of 

decomposition classes. Logs in decomposition classes 3 through 5 should be protected from burning and 

mechanical disturbance.

These conditions can begin to appear when forest stands are between 80 and 140 years old, depending on site 

conditions, species composition and site history (LSRA p. 162). In pine-dominated forest, stands under 

normal conditions are more open with relatively fewer snags and logs. On dry sites, stands may be well over 

180 years before these characteristics develop. Figure 6 depicts approximate desired conditions for late 

successional habitat.

Figure 6. The Approximate Desired Conditions for Late-Successional Stands: Stand 150 Showing Spacing and Structure

(November 2012)

The LSRA describes sustainable levels of late-successional habitat within LSRs as between 50 to 60% (of 

land capable of sustaining late-successional habitat) (p. 196). Vegetation would be varied over the landscape, 

consisting of dense multi-layered stands, more open multi-layered stands, dense and open single storied 

stands, a variety of trees per acre with differing size classes, snags, down logs, etc. The desired character is in 

line with site capability, elevation, slope, aspect and soil conditions.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 19

Density

The desired condition for density for late-successional and old-growth stands on the McCloud Flats is 50 to 

70% of normal basal area10 (Dunning, et al., 1933), (LSRA, 1999 p. 167), and should apply to stands 150 to 

200 years old. This density range would allow stands to maintain desired characteristics for a longer time 

without an imminent threat of high levels of mortality. After the 200-year timeframe, basal area should not be 

as much of a concern in order to allow decadence and increased mortality processes to occur naturally.

The Forest Plan (pp. 4-79, 4-82, 4-86) describes density-related desired condition as forest stands managed at 

levels that maintain and enhance growth and yield to improve and protect forest health and vigor, recognizing 

the natural role of fire, insects and disease and other components that have a key role in the ecosystem. Stand 

understories would appear more open with less ingrowth particularly in stands on sites where wildfire plays a 

key role in stand development. The actual target stand densities depend on stand species, site quality, stand 

age, and stand objectives (i.e. stand densities are maintained at lower levels to grow larger old trees within 

LSR).

Existing Condition

Composition and structure

Most of the project area consists of dense relatively homogeneous forested stands of medium- and small-sized 

trees. Understory vegetation is sparse to nonexistent in these dense stands because most of the site resources 

are being taken up by the overstory and because little sunlight reaches the forest floor. In contrast,

approximately 20% of forested stands are open canopied and have available growth resources to support an 

appreciable understory vegetation layer. Currently the ecological processes that develop old-growth habitat 

are departed from their natural regimes.

Table 5 describes the seral stages present in the proposed treatment units in the project area. The Forest Plan

description by Wildlife Habitat Relationship (WHR) classification, canopy closure, and DBH (Forest Plan pp. 

4-15) does not correspond well with the Elk project area where high site quality leads to early large tree 

development, atypical to the size/successional stage correlation described in the Forest Plan.

Table 5. Seral Stage Condition of Treatment Units in the Project Area

WHR*

Seral 

Stage

Canopy 

Closure

(percent)

DBH

(inches) Forest Plan Description Site Specific Elk Project Area 

Description Acres

Percent 

of 

Capable# 

Acres

1 

≤ 10% N/A

Grass & forbs with or without 

shrubs and seedlings same 518^ 14.9%

2 

Shrub/seedling/sapling mixed 

or pure stands up to 20 feet 

in height

same 0 0%

3a 10-39%

5” – 21”

Pole/medium tree stage 

including larger trees in the 

size range 20-50 feet in 

height

Pole to medium tree stage 

predominantly mid-successional 

with some early successional 

stands. May include some larger 

trees. Average height generally 

20-60 feet. Average age is 

generally 15 – 50 years.

195 5.6%

3b 40-69% 356 10.2%

3c ≥ 70% 42 1.2%

4a 10-39% 21 + ” Large tree stage Same except: 401 11.5%

 10 Basal area is the cross-sectional area of all trees in a stand measured at breast height and expressed as square feet 

per acre.
Elk Flat LSR Enhancement Project

20 Shasta-Trinity National Forest

WHR*

Seral 

Stage

Canopy 

Closure

(percent)

DBH

(inches) Forest Plan Description Site Specific Elk Project Area 

Description Acres

Percent 

of 

Capable# 

Acres

4b 40-69% corresponding roughly to a 

late successional 

classification. Trees generally 

> 50 feet tall except for oak 

types at lower elevations. 

Average age is generally 

over 110 years

Medium to large tree stage 

spanning mid and late 

successional classification. 

Average age is generally 60-100 

years

1,920 55.1%

4c

≥ 70%

51 1.5%

4c -

older

Multi-layered large tree stage 

with obvious signs of latesuccessional. At least 2.5 

snags per acre and 20 tons 

of dead/down material. 

Stands should contain at 

least 3 trees (alive or dead) 

per acre > 36” DBH. 

Dominant trees are over 180 

years of age

Same except:

Dominant trees are generally 80-

120 years old

0 0

Total 3,482 100%

Table Notes

* Classification using Wildlife Habitat Relationship (WHR) models

** Descriptions are specific to Elk Flat LSR project area where high site quality leads to early large tree development, atypical to 

size/successional stage correlation described in the Forest Plan.

# Capable of supporting late-successional forest

^ Mostly Elk Flat Meadow. While designated as capable, it is a meadow type rather than a forest type.

Many of the natural stands in the Elk Flat LSR contain elements of late-successional habitat and provide stand 

structural conditions suitable as either reproductive or foraging habitat for NSO, northern goshawk or fisher

habitat (summarized for the project area in the Chapter 3 wildlife section and described in detail in the 

Biological Assessment for the NSO). These stands generally meet the Forest Plan classification elements of 

older late-seral stands (4c in Table 5) except for stand age and canopy closure, which are required to exceed 

70% to meet the Forest Plan classification. This divergence between habitat suitability for these latesuccessional dependent wildlife species and Forest Plan seral classification reflects the stand elements within 

a portion of the project area, namely ponderosa pine, that cannot sustain over the long term at densities which

provide canopy cover greater than 70 percent.

Within the LSR, 2,836 acres are capable of supporting late-successional habitat (LSRA p. 125). Of the land 

capable of supporting-late successional habitat, 1,306 acres (46% of capable land within the LSR) were in 

late-successional habitat when the LSRA was published in 1999. Currently, there is a shortage of high quality

late-successional habitat in the LSR. Many late-successional stands are deficient in structural diversity.

Although most of the project area falls in to the CWHR classification of ponderosa pine, in the natural stands 

white fir (Abies concolor) is often the dominant species in all size classes. Ponderosa pine forests typically 

contain a mix of tree species but the proliferation of white fir and relative scarcity of ponderosa pine reflects

past harvest practices and decades of fire suppression policies.

Initial logging occurred in the project area in the late 1800s and early 1900s. Large overstory ponderosa pine,

sugar pine (Pinus lambertiana) and Douglas-fir (Pseudotsuga menziesii) were preferentially removed, with 

smaller trees and less marketable species left uncut. Though in some areas of the project, there are remnant 

trees (predominants) of these species.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 21

Fire suppression essentially removed the natural and historic fire regime from the landscape, which would 

have periodically reduced surface fuels, much of the young small diameter understory trees and a portion of 

mid and overstory trees. Current stand conditions reflect an increase in a shade-tolerant understory and 

midstory, composed primarily of white fir and incense cedar (Calocedrus decurrens). This transition occurred

because white fir and cedar are able to establish in a shaded understory environment and grow into the 

overstory over time. White fir, followed by incense cedar and ponderosa pine are the most common species in 

the understory. Douglas-fir and sugar pine represent a minor understory component. Pine requires more light 

and openings to successfully regenerate, and does not survive well in a shaded understory environment.

Ponderosa pine is a component of large overstory trees (30 inches DBH and greater) where it is found in 

combination with white fir, incense cedar, Douglas-fir and sugar pine. The mixed conifer stands are similar in 

composition to the ponderosa pine stands but generally contain a higher proportion of white fir in the 

overstory in combination with ponderosa pine, Douglas-fir, incense cedar and sugar pine.

Prior to the recent western pine beetle outbreak, snags occurred individually and in small groups throughout 

the natural stands. The 2007 stand exams (conducted prior to the heavy mortality onset in 2009-2012) found

an average of 4.7 snags per acre within natural stands (50% of project area), with a median size of 20 inches 

DBH. The current mortality has likely increased snag densities to 10 or more snags per acre in the same size 

class. It is recognized that snags and large CWD provide important habitat elements and are important 

features to promote and maintain across the landscape. However, with the significant additional widespread 

mortality in pine, these snags will decay, drop and create large fuel loadings >100 tons per acre unless 

otherwise treated.

Density

Stands have grown increasingly dense over time, causing understory vegetation to die out due to overtopping 

and competition, and causing overstory trees to grow slowly due to inter-tree competition for resources. Nonconifer vegetation, including understory shrubs and herbaceous vegetation, are lacking in the project area and 

are at levels considerably lower than would be expected under historic natural fire regimes. Both natural and 

plantation forest stands in the Elk Flat LSR are highly to extremely dense in relation to the survivability of 

pine (see also discussion about density related bark beetle vulnerability in ponderosa pine on page 12).

The 2007 stand exams recorded basal areas ranging from 156 to 342 square feet per acre with an average tree

diameter of 16 inches. Because of the lack of low intensity fire or other past disturbance, stand densities 

increased as trees have continued to grow larger. Tree growth has slowed as stands approach and reach their

maximum carrying capacity. Density related mortality is expected to continue to increase and spread 

throughout the project area. Many of the largest dominant and predominant ponderosa pine trees have died, or 

are dying in the project area.

The majority of the mid- and late-successional stands in the project area consist of dense, overstocked stands. 

Approximately 80% has dense (ranging from 40-90+%) canopy cover. The preponderance of small- and 

medium-sized trees reflects the lack of differentiation that occurs under dense, stagnant growth conditions. 

Many of these stands have reached or exceeded a density threshold causing individual tree growth, health and

overall stand vigor to decline. The current pine mortality demonstrates the limiting stand density relationship 

and resulting loss of desirable late-successional tree features including large overstory pine. While stand 

densities remain high, the risk of further loss of these stand elements persists.

Older plantations (greater than 40 years) currently exceed the threshold SDI of 365. These overstocked, 

monoculture ponderosa pine plantations are not developing desirable habitat features but are expected, with 

treatment, to provide an important source of future (next few decades) habitat. In the interim, they remain at 

risk of widespread mortality due the high density.
Elk Flat LSR Enhancement Project

22 Shasta-Trinity National Forest

Figure 7 illustrates the overly dense conditions in some natural stands in the project area. Figure 8 shows a 

stand with average basal area of 283 square feet per acre, an SDI of 419 and an average tree diameter of 16 

inches. While basal area is often used as a measure of NSO (and other species) habitat suitability, other factors 

such as average tree diameter, species composition, decadence, and snag/CWD size also contribute to the 

overall suitability. Figure 9 illustrates the overly dense conditions in plantations.

Figure 7. Existing Condition of Unit 155 with BA of 283 

and SDI of 419 

(Stand Exam 2007, Photo July 2012)

Figure 8. Overstory Pine Density Exceeding Basal area 

200 square feet per acre Prior to the Mortality (Unit 201)
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 23

Fire and Fuels

Fire regime, fuel loading, and potential fire behavior contribute to risk of large-scale disturbance.

Desired Condition

Fire Regime

The Forest Plan states the goal of returning fire to its natural role in the ecosystem (pp. 4-4). Stand 

understories appear more open with less ingrowth particularly stands on sites where wildfire plays a key role 

in stand development (pp. 4-79, 4-86).

Prior to historical logging, the natural fire regime was frequent low to moderate intensity fire, and much of the 

forest stands would have been fairly open-canopied with brush, forbs and grasses underneath. More dense 

stands of mixed conifers would have been present at higher elevations, along riparian corridors and on northfacing slopes where local moisture levels are higher and fires were less frequent. The Edson WA describes 

pre-settlement fire regime (USDA-FS, 2011 p. 89). Prior to European settlement of the region, wildland fire 

was the primary factor that influenced the vegetation patterns across the watershed.

Historically, approximately 91% of the Elk project area experienced a high frequency (0 to 35 years) low to 

mixed severity fire return interval.

11 Fires started by lightning probably burned large areas during periodic 

 11 Fire return interval is the average period between fires under a presumed historical fire regime.

Figure 9. Existing Condition of Typical 40+-Year Old Plantations Showing High Density, Lack of Structure and Mortality

(Stand 6, November 2012)
Elk Flat LSR Enhancement Project

24 Shasta-Trinity National Forest

droughts with mixed severity, perpetuating shrubs and very open conifer forest. Native American sites in the 

watershed indicate that some wildland fires were deliberately started to maintain early-successional

vegetation that favored game species such as deer and elk. Prior to organized fire suppression frequent low to 

moderate severity fire occurred as a combined result of summer drought, winter precipitation and lightning. 

Mature trees in this forest type are adapted to frequent surface fire. Historically, periodic wildfires limited the 

main species composition of dry sites to pines (cedar and fir are more susceptible to fire-induced mortality 

than pine due to their branch characteristics and bark qualities).

The LSRA (p. 163) notes it is desirable to have low to moderate intensity fires burn in LSRs. Low intensity 

fires can reduce fine fuels and ladder fuels, create a seedbed for a diversity of herbaceous plants, and create a 

patchy understory open enough for spotted owl movements. Moderate intensity fires are desirable if they 

create small openings in the canopy of less than one to five acres. This allows for ingrowth of tree seedlings 

and other early successional plants, and creates snag patches and concentrations of down woody debris which 

are important for prey base habitat. Burned openings are most desirable if they occupy only a small 

percentage (five to ten percent) of the stands providing habitat. Introducing a fire cycle more similar to what

occurred in pre-suppression times will reduce the risk of catastrophic fires. Large stand replacing, high 

intensity fires are not desirable within LSRs.

The desired condition is a fuels profile where fire plays a natural role in the ecosystem with conditions that 

result in low to moderate fire behavior. When a natural ignition occurs within the project area, it would be 

allowed to play its natural role in the ecosystem. 

Fuel Loading

Research has described natural frequent low-intensity fire in dry pine and mixed conifer forests in the West as 

"fuels limited" fire regimes (Agee, 1993; Schoennagel, et al., 2004). In other words, fuels sufficient to sustain 

and carry a fire are a more limiting and determining factor than weather or climatic conditions.

The Forest Plan describes dead and down material presence for LSR (pp. 4-44) and matrix lands (pp. 4-67). 

Actual fuel loadings vary according to vegetation type, but average from 5 to 35 tons per acre in LSR and 5 

tons per acre in matrix lands with CWP emphasis.

The LSRA (p. 163) describes the desired variability of fuel conditions across the landscape as some high 

concentrations of fuel intermixed with areas of low fuel accumulations. Heavier scattered pockets of fuels 

would occur on relatively cool, moist sites, such as those found on north and east facing slopes, or low on 

slopes adjacent to perennial riparian areas. South and west slope aspects and upper slope positions, which are 

typically drier and harsher, would generally contain lighter fuel loadings, with fewer scattered pockets of 

heavy fuel. Site capability also influences fuel loadings. Fuels would break down with the assistance of fire 

and cycle nutrients back into the soil in a form available to vegetation. There would be a low, manageable 

level of excess residual natural and activity fuels that remains after management activities are implemented 

that would not contribute to increased probabilities of high severity wildfire within the LSR.

Fire Behavior

The LSRA (p. 163) describes the desired fuel conditions as those that promote low to moderate fire behavior. 

Low to moderate intensity disturbances (such as fire, wind, insects and disease) create canopy openings and 

gaps in vegetation, establish trees beneath the maturing overstory trees either in gaps or under the canopy, and 

close canopy gaps by lateral growth or growth of understory trees (p. 162).

The wildfire behavior goal is to develop a fuels profile that will have moderate wildfire intensities determined 

by flame length (a measure of fire intensity) on a 90th percentile (mid to late summer or hotter) fire weather 

day over most of the land base. The desired flame length and rate of spread would be those in which overstory 

trees are not likely to be killed (LSRA pp. 164-165). The LSRA recommends a fuels profile with moderate 

wildfire intensities determined by flame length (a measure of fire intensity) of four feet or less, allowing for 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 25

safe direct attack by hand crews, and rates of spread less than twenty chains (1 chain = 66 feet) per hour 

(LSRA p. 165). Fuel Models12 2 and 9 are the desired condition. Fuel Models 2 and 9 are present, but the fire 

behavior within these fuel models is moderated by surface fuels and tree densities not exceeding desired 

levels.

• Fuel Model-2 – Fire spread would be primarily through the fine herbaceous fuels, either curing or 

dead. These would be surface fires where the herbaceous material, litter and dead-down stemwood 

from the open timber overstory contribute to fire intensity. 

• Fuel Model-9 – Fires would move through the surface litter. Fuel bed depth would be less than 1 

foot. 

Existing Condition

Fire Regime

The Mt. Shasta region has experienced nearly 100 years of fire suppression resulting in a vegetation structure 

and composition that is vastly altered from historical conditions. The restricted size and frequency of fires 

across the landscape has resulted in increased stand density, a shift from fire-tolerant to fire-intolerant species, 

and reduced structural diversity throughout the region and watershed area. As a result, severe wildfires have 

increased throughout the Cascade Range, especially in the low and mid-elevation forests (USDA-FS, 2012 p. 

58; Skinner, et al., 2006). Effective fire suppression within the dry forested landscape of the California 

Cascades Province where the project is located has resulted in changes to forest structure, stand density and 

species composition, changing the fire regime from frequent low intensity surface fires, to infrequent, stand 

replacement fires (Agee, 1993). In the past several decades, the frequency of large wildfires and the acres 

burned each year have increased across the western United States (Miller, et al., 2012), (Agee, et al., 2005). 

Many of these fires are burning with uncharacteristic severity and scale (Agee, et al., 2005).

The Elk project area has experienced the results of effective fire suppression. Large-scale, frequent, lowintensity fires have not occurred in the project area. The result has been an accumulation of surface and 

understory fuels and overstocked stands that are more susceptible to drought stress, insects and disease. Fire 

cannot play its natural role (short interval, low to mixed intensity fire regime) in the project area at this time. 

In a fire, dramatic changes to the stands could occur due to fire size, intensity, severity, and landscape 

patterns. (NWCG, 2006).

The entire project area is in fire regime condition class 3 (high departure) (USDA-FS, 2012a). The fire regime 

has been substantially altered from the natural (historic) range resulting in a high risk of losing key ecosystem 

components. Fire frequencies have departed from natural frequencies by multiple return intervals. There is no 

record of large fires in the project area in the last 100 years. There are numerous areas with fire scared trees 

indicating smaller fires throughout the project area.

Fuel Loading

Departure from the natural fire regime has led to dense accumulations of live and dead fuels, combined with 

the recent mortality from bark beetles. Current surface fuel loadings in the Elk Flat LSR range from 5 to 19 

tons per acre. Where there are high levels of existing and ongoing mortality, fuel loads are expected to 

increase to 35 to 100+ tons per acre when these dead and dying trees fall. Approximately 10% of the Elk Flat 

LSR is currently comprised of large pockets (10 to 70+ acres) of standing dead trees that present a current and 

 12 Fuel models are tools that help land managers estimate fire behavior, and are described in terms of expected fire 

behavior and associated vegetation. Fuels models depict the types and amounts of fuels that are available to support fire, 

and are an important factor in determining fire behavior potential for a given site.
Elk Flat LSR Enhancement Project

26 Shasta-Trinity National Forest

future threat to the surrounding habitat and Forest visitors due to increasing fuel loads and safety 

considerations. Smaller mortality pockets range from groups of 5 to 10 trees up to 1⁄2-acre, primarily in the 

ponderosa pine component, with additional root disease-related mortality occurring in white fir stands.

Many conifer stands are overly dense 

with many small trees in the understory 

layer that can act as fuel ladders, allowing 

fire to move quickly from the forest floor 

into the upper canopy layer. Stand species 

composition is shifting from 

predominately pine to pine mixed with 

incense cedar and white fir. Incense cedar 

and white fir are prolific throughout the 

understory and mid-story of many stands. 

The shift in species composition from 

pine to cedar and fir increases the risk of 

loss due to wildfire. Figure 10 shows a 

typical mixed conifer stand with heavy 

ground fuel accumulation.

Fire Behavior

The large areas of pine mortality would

influence fire behavior in the event of a

fire start. Mortality pockets provide a 

component of late-successional reserve conditions in the form of multiple snags, standing dead trees and large 

CWD. However, the current and future fuel loads, and risk of natural and human caused fire starts would 

result in high heat and spotting that could ignite other dense forested stands within the project area. The 

current strategy for responding to a fire in this area is to not commit firefighters in the mortality zone, but 

back off to a safe location to manage the fire, potentially increasing risk to late-successional forest. The 

natural stands and older plantations are susceptible to high severity fire effects due to fire suppression and 

natural fire exclusion over the past 100 years.

In the case of a wildfire during the summer season, fire behavior modeling predicts rates of spread, flame 

lengths, and resistance to control that would result in high acreage burned and significant post-fire adverse 

effects on resources. Three fuel models account for approximately 85% of the LSR: Fuel Models-10, -2 and -

9 (LSRA p. 126).

• Fuel Model-10 is characterized by dense late-successional conifer stands (Timber Condition Classes 

4N, 4G, and greater) with heavy amounts of dead and down woody fuels. The understory is densely 

populated with intermediate size conifers. A wildfire carried by these fuels would be intense enough 

to cause crowning (fire moving from the understory to the tree crowns), fire spotting ahead of the 

main fire and rapid rates of spread during high winds. Large stand replacing fires can be expected.

• Fuel Model-2 is characterized by poorer timbered sites and young plantations with grass and brush 

where surface fires can spread easily with pockets of fuels generating high heat intensities.

• Fuel Model-9 is characterized by closed-canopy conifer stands (Timber Condition Classes 3N, 3G, 

4N, and 4G) with densely stocked pole size trees in the understory. Typically, these stands contain 

pockets of dead and down woody fuels that create high fire intensities during surface fires that can 

easily spread through the understory to the crowns of the dominant conifers.

Figure 10. Dense Mixed Conifer Stand in the Project Area Displaying 

Heavy Surface Fuels
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 27

Fire occurrence has been very low in the Elk Flat LSR, with lightning caused fires accounting for 92 percent 

of the recorded occurrences. However, fire hazard/risk in the 1999 LSRA was determined to be 

moderate/moderate due to several large pockets of standing dead trees. Because of the ongoing western pine 

beetle outbreak, a higher level of snags than would normally occur under a natural fire regime developed 

throughout most of the project area. Existing snag estimates are 10 snags 20 inches DBH per acre. Some of 

these snags have already fallen and become down wood, and snags will continue to fall the over the next few 

years without treatment. While snags and large down logs are an important habitat component in the project 

area, they are also a high fire hazard at the current densities. Widespread high concentrations of snags and 

down wood create a fuel hazard. Extensive dense fuels increase the risk of undesirable high intensity fire that 

could kill adjacent residual trees as well as newly regenerating stands growing up through the dead and down 

trees.

With the current and projected fuel loads, the risk from potential for human caused fire starts has increased, 

notably along roads. Additionally, the low level of recent timber-stand management activities such as thinning

to reduce forest stand density, has resulted in overcrowded stands with slowed tree growth and poor vigor.

The recent insect-caused mortality compounds the current hazardous fuel conditions. Without treatment, these 

areas of dead and dying trees will add significantly to the potential fire behavior hazard. Once the trees have 

fallen, surface fuel loadings are estimated to exceed 100 tons per acre in the mortality pockets. These areas 

would be characterized as a Fuel Model 13. Appendix B of the Fireline Handbook (NWCG, 2006) describes 

fire activity in Fuel Model 13 as:

“Fire is generally carried by a continuous layer of slash. Large quantities of greater than 3-inch material 

are present. Fires spread quickly through the fine fuels and intensity builds up as the large fuels start 

burning. Active flaming is sustained for long periods and a wide variety of firebrands can be generated.”

A wildfire in these pockets with high fuel loading would be a high intensity. This may require firefighters to 

back off to an area where intensity will be less. Equipment would have a difficult time working in these areas, 

making the tactic of creating control lines with dozers unlikely.

With the existing conditions and ongoing mortality, portions of the project area are expected to experience 

passive crown fire and flame lengths greater than 4 feet. This would not allow ground forces to directly attack 

the flanks or head of the fire. Equipment and/or aircraft would be needed to manage a fire under these 

conditions. Modeling indicates up to 40% mortality from a wildfire in the natural stands, under 97th percentile 

weather conditions. With these conditions, fire managers are limited in the tactics that would be effective. 

Potentially, this could impact adjacent landowners, as a fire that starts within the project area could move onto 

private lands.

While fire modeling does not predict a running crown fire, the predicted high heat and potential for torching 

and spotting in the heavy mortality areas presents a risk to current and developing late-successional habitat, 

adjacent private lands and WUI. Without action, the mortality will continue to increase and spread throughout 

the project area, contributing to higher levels of standing and dead fuels and increasing the risk of high 

severity, stand-replacing fire.

2. Accelerate Development of Late-Successional and Old-Growth Forest 

Characteristics (LSRA Objective II) and Promote Late-Successional Habitat 

Connectivity (LSRA Objective IV)

Need for Action

Action is needed because the existing conditions will delay or prevent development of late-successional forest 

in early and mid-successional forested stands in the project area. The same conditions that affect successional 

development reduce the value of these forests for connectivity to existing late-successional forest.
Elk Flat LSR Enhancement Project

28 Shasta-Trinity National Forest

Background

Development of old-growth forest characteristics including snags, logs on the forest floor, large trees, and 

canopy gaps that enable establishment of multiple tree layers and diverse species composition are a primary 

objective in LSR. Some of the mid-successional forest is already providing components of late-successional 

forests. Most of the mid-successional forest in natural stands provides habitat that is utilized by a latesuccessional dependent species (NSO, northern goshawk, fisher, rare mosses). Restoration treatments in earlysuccessional forests can accelerate development of some of the structure and composition of latesuccessional forests (NWFP, 1994 pp. B-6). The NWFP standards and guidelines (p. B-1) encourage 

accelerating development of overstocked young plantations and early-successional forests (p. B-5) into stands 

with late-successional and old-growth forest characteristics.

While the LSRA describes that plantations are important in the development and sustenance of latesuccessional habitat and associated species (p. 172), the plantations in the project area are predominantly a 

monoculture of ponderosa pine which contribute little current habitat value for late-successional species. The 

stand and species composition of the early- and mid-successional stands (both natural and plantations) are 

critical factors to consider when assessing current and future potential habitat suitability and value for these 

species. With treatment, these stands may support late-successional forest conditions over the long-term, and 

potentially succeed and replace current late-successional stands that will fail (p. 173). Also as described in the 

LSRA, emphasis should be placed on moving older plantations toward conditions that will provide additional 

support to prey base and foraging habitats for the fisher and northern goshawk, and dispersal habitat for 

northern spotted owl.

The Forest Plan (pp. 4-81, 4-85) also directs managing younger to mature forest stands (in LSR) to replace 

older dead and dying stands as they no longer are suitable for old-growth ecosystem dependent organisms. 

The LSRA identifies Elk Flat LSR as a priority for promoting development of late-successional forest (LSRA 

p. 178) and notes the importance of maintaining young plantations as healthy and fast growing. Stocking 

levels and fuel accumulations should be at levels that reduce the likelihood of loss to catastrophic fire and that 

encourage the growth of large trees (LSRA pp. 162-163). The Forest Plan also directs connecting travel 

corridors for wildlife species, particularly late-successional dependent species (pp. 4-14), and maintaining or 

improving soil productivity (pp. 4-5). The LSRA describes connectivity of early and mid-successional habitat 

(pp. 181-182) as:

a. Areas of early- and mid- successional forest adjacent to "isolated" stands of late-successional habitat 

that will respond to treatment in order to promote greater connectivity and reduce fire hazards 

throughout LSR.

b. Areas of early- and mid-successional forest that coincide with landscape features that may be 

important to dispersing animals.

Desired Condition

The desired condition is to achieve and maintain individual tree growth, health and resilience of contiguous 

early and mid-successional pine and mixed-conifer habitat across the Elk Flat LSR and adjacent matrix lands 

to foster connectivity and develop late-successional habitat. Connectivity provided by Riparian Reserves is 

also important and described starting on page 33.

Existing Condition

Early and mid-successional forest in the project area totals approximately 1,500 acres13. Most of the midsuccessional forest consists of dense, overstocked stands. Many of these stands support density levels that are 

 13 This does not include Elk Flat, which is early seral, but not a forest type.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 29

near or exceed site capability because they are often slow growing and lacking stand vigor. Growth 

projections indicate potentially high levels of mortality with associated surface and standing dead fuel 

increases that can add to uncharacteristic fire behavior and effects. Under the current conditions of 

increasingly high density and competition for resources, tree growth slows, tree vigor declines and attainment 

of late-successional status and quality of connectivity is decreased, delayed or prevented.

The practice of “brush to trees” windrowing14 in the 1950’s through the 1970’s plowed brush fields into 

windrows, displacing from four to eight inches of topsoil, followed by conifer planting. Topsoil was scalped 

to tear out brush and to remove duff and seeds to expose bare soil for planting. Windrowed brush was burned,

leaving large rows of topsoil rich in soil organic matter. The loss of soil productivity between the windrows 

directly affects site productivity and sustainability resulting in reduced or delayed tree and stand development.

3. Restore Meadow Habitat in Elk Flat

Need for Action

A need exists to restore the natural opening and dry meadow ecosystem at Elk Flat. Elk Flat appears to be in a 

drying phase which is allowing tree encroachment to occur. A high water table supports meadow vegetation 

and discourages tree growth. When the water table is lower, trees can out-compete meadow vegetation 

because of their deeper roots. Currently, the water table is greater than one meter below the ground surface in 

most years, so this meadow area is probably best classified as a dry meadow/grassland area with conifer 

encroachment (Weixelman, 2015). Specifically, the following processes need restoration or application to 

maintain the dry meadow ecosystem:

1. Restoration of early seral vegetative conditions that are more reflective of those before fire

suppression; and restoration of herbaceous species that would maintain sufficient sod and root 

densities to discourage tree establishment and keep the area open.

2. Re-introducing fire as a disturbance element that contributes to maintaining the dry meadow 

vegetation conditions.

3. Restoration of the natural water table to encourage and support meadow vegetation and discourage 

tree encroachment. Water table restoration is elaborated on in Purpose and Need #5 below(see p. 

33).

Background

Elk Flat is a natural opening, a dry meadow (Weixelman, et al., 2011) and the outwash plain for Swamp 

Creek. Openings were probably maintained in the past by outwash and mudflow events. Although the 

frequency and duration of these events is unknown, soil pits show a wide range of stratification indicating 

recurring outwash was deposited.

The fire interval and intensity may have been very different between the surrounding forest and Elk Flat. 

There is little physical evidence on the role of fire in maintaining the open condition; however, the meadow 

edges probably shared the same fire interval as the surrounding conifer forests and this may have helped

limited conifer encroachment. Nineteenth-century historical anecdotes indicate that Elk Flat was about three 

to four miles wide and without trees (USDA-FS, 2011 p. 99). A range of fire intervals and intensities would 

have depended on the occurrence of fuels. Lighter fuels, grasses and forbs of the meadow interior would have

likely supported low intensity surface fire that would contribute to maintaining the opening.

 14 Windrowing is a site preparation method in which topsoil is scalped and piled. It was used in the past prior to tree 

planting as a way to remove competing vegetation.
Elk Flat LSR Enhancement Project

30 Shasta-Trinity National Forest

Elk Flat meadow contains deep soils formed in glacial outwash and mudflows overlain by several feet of the 

more recent outwash deposits (USDA-FS & USDA-SCS, 1983). Soils are deep and somewhat excessive to 

well-drained. Due to the deep soils overlain by outwash, a seasonal water table elevation sufficient to support 

a high density of grasses and upland sedges probably maintained enough sod and root densities to discourage 

tree establishment and keep the area open. In the past during successive high water years, there may have 

been shallower water tables, thus increasing grassy cover, and during drier periods lowering water tables and 

reduced grassy cover (Weixelman, 2015).

Within the project area, 353 acres of Elk Flat meadow are in LSR allocation, with the remaining 378 acres in 

matrix with Commercial Wood Products (CWP) emphasis. Forest Plan Standard and Guidelines provide for 

maintenance of at least five percent of each timber type/seral stage (pp. 4-14).

Desired Conditions

The Forest Plan directs that management of natural openings will be determined at the project level,

consistent with desired future conditions (pp. 4-14). In the Forest Plan supplemental management direction 

for Management Area 2 (pp. 4-81), Elk Flat meadow is specifically identified for management of early seral 

stage vegetation (WHR Seral Stage 1, Table 4-3). Forest goals that contribute to identification of the desired 

future conditions in the Elk Flat meadow include:

• maintaining a rich diversity of plants, fish, and wildlife and maintaining the diversity and quality of 

habitats that support viable populations of plants, fish, and wildlife (pp. 4-4).

15

• restoring fire to its natural role in the ecosystem when establishing the desired future condition (p.

4.4).

16 maintaining natural wildlife species diversity by continuing to provide special habitat elements 

within the Forest’s ecosystems (p. 4.6).

The LSRA (p. 205) lists protection and improvement of meadow areas as the desired condition and neutral to 

the objectives of LSR. The Edson WA identified opportunities to restore the distribution, size and functions

associated with wet and dry meadows, including Elk Flat (p. 116) and to evaluate the potential for 

maintaining meadows through reintroduction of fire and vegetation management (p. 105).

Low intensity surface fires would not necessarily produce scarring on the larger trees or produce significant 

charcoal in the soil layers; it is possible that low intensity surface fires maintained the open nature of the 

meadow in the past (Weixelman, 2015). The best evidence available that demonstrates the size of the Elk Flat

opening before the control of fires are 1944 aerial photographs (see Figure 12). The desired condition is:

 15 Elk Flat does not provide fish habitat, but it does contribute to diversity of plants and wildlife.

16 While it is suspected that fire did not maintain the habitat in Elk Flat, returning fire to the landscape as an agent that 

helps maintain the early seral vegetation is consistent with the Forest Plan goals
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 31

4. The early seral area of Elk Flat is restored to its historic size 

as evident in the 1944 photographs. Scattered conifers are a 

natural component of the meadow. The largest trees are 

retained, primarily the predominants that established prior to 

1944 and within LSR, those with late-successional 

characteristics (see Figure 11).

5. Fire is re-introduced to act as a natural disturbance agent 

and to promote conditions more reflective of a natural fire 

regime prior to fire exclusion.

Existing Conditions

Conifer encroachment is diminishing the dry meadow area at Elk 

Flat. Based on 1998 aerial photography analysis, the extent of the 

meadow at Elk Flat was less than 50% of its extent in 1944 (USDAFS, 2011 p. 69). The photo comparison below shows 2012 and 1944 

aerial photography and demonstrates continued decline of meadow 

area from encroaching conifer (see Figure 12).

Figure 12. 2012 Aerial Photograph of Elk Flat Left Compared to 1944 Photograph on the Right Showing Increased Conifer 

Encroachment in the Dry Meadow Ecosystem

The meadow at Elk Flat is predominantly comprised of herbaceous plants and perennial grasses. Remnant 

islands of conifer trees (primarily ponderosa pine, but some white fir and incense cedar) are present, and 

young regeneration and stringers from these islands and the adjacent forest stands are encroaching on the 

meadow. Rapid conifer establishment in the meadow is evident where dense even-aged dog-haired stands of 

ponderosa pine regeneration line the meadow periphery (see Figure 13) and the stream channels.

Figure 11. Larger Predominant Pine in 

Elk Meadow Established Prior to 1944. 

Smaller Trees Established Post Fire 

Suppression
Elk Flat LSR Enhancement Project

32 Shasta-Trinity National Forest

Hydrologic conditions also influence the existing condition at Elk Flat. Due to the current gully confinement, 

and lower seasonal water table, Swamp Creek is no longer able to hydrate the meadow. However, during 

periods of snowmelt and rainfall, relict multiple channels on the meadow experience minor flooding and 

transport sand and gravels, which is a minor contribution to the larger-scale disturbance required to maintain 

the natural opening.17 Hydrologic function restoration is discussed in Purpose and Need #5.

Figure 13. Young Stands and Stringers of Encroaching Conifer at Elk Flat Meadow with Interspersed Predominant 

Ponderosa Pine

4. Retain and Enhance Hardwoods as a Stand Component at Density Levels 

Commensurate with Development of Late-Successional Stands.

Need for Action

The need exists to assure hardwoods thrive and remain in stands at naturally occurring levels throughout the 

Elk Project area.

Background

The Forest Plan identifies hardwoods as having high value to wildlife for foraging, nesting, denning, resting 

and shelter, as well as providing habitat for prey species. Acorn production is especially important as a food 

source (pp. 3-25). The Edson WA describes aspen as a keystone species, vital to maintaining biodiversity (p. 

68), and identifies hardwood decline as a concern for vegetation and forest resilience in the watershed (pp. 

103, 108, 120).

Without disturbance, forest stands continue to follow a process of natural succession in which encroaching 

conifers establish in the understory, excluding the shade-intolerant hardwoods and eventually fully occupying 

the sites. Conifer species, particularly white fir establishing in the understory, increasingly dominate the overstory canopy, overtop aspen and oak, and successfully out-compete hardwoods for available sunlight, water 

and nutrients. The LSRA notes hardwoods are a desired component (p. 162) in existing plantations. 

 17 Restoring the full hydrology would require upper watershed restoration of road drainage. This is outside the scope of 

this project and is recognized as needing further consideration in the Edson WA (USDA-FS, 2011).
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 33

Hardwood groups and individuals should be retained and managed as stand components at appropriate levels

for the development of late-successional stands.

Desired Conditions

Forest Plan goals that contribute to identifying the desired future conditions for hardwoods in the project area 

include:

• maintaining a rich diversity of plants, fish, and wildlife and maintaining the diversity and quality of 

habitats that support viable populations of plants, fish, and wildlife (pp. 4-4).

• maintaining natural wildlife species diversity by continuing to provide special habitat elements within 

the Forest’s ecosystems (pp. 4-6).

Additionally the Forest Plan directs that within LSR, hardwoods should be maintained at naturally occurring 

levels and enhanced (Forest Plan pp. 4-42, 4-44). Within Matrix CWP emphasis they are sustained on a 

landscape basis consistent with the desired future conditions. The desired condition in the McCloud Flats 

Management Area is to maintain hardwoods as a stand component where they exist (Forest Plan pp. 4-82).

The desired condition for hardwoods is groups and individual hardwoods restored to naturally occurring 

levels. Openings and canopy gaps would be restored to the historic size and conditions that reflect a natural 

fire regime prior to fire exclusion. Aspen stands would be at a sustainable level on a landscape basis and 

aspen would be encouraged to reclaim sites it historically occupied.

Figure 14 shows a previously treated area (North Flats project), located in the southern portion of the project 

area with released oak representing the desired condition.

Existing Conditions

Aspen (Populus tremuloides) and California black oak 

(Quercus kelloggii) occur as a scattered, minor vegetation 

component within the project area, generally in the 

understory at reduced abundance and decreased vigor. Fire 

exclusion has allowed white fir understories to become 

established in many stands. As white fir develops, it 

eventually overtops and shades out hardwoods (USDA-FS, 

2011 p. 37).

5. Increase Streamflow, Raise Water Table 

Elevation and Improve Water Quality and 

Vegetation Conditions within Riparian

Reserves Associated with Elk Flat, Ash 

and Swamp Creeks and Their Tributaries.

Need for Action

A need exists to improve and maintain Riparian Reserve 

function by raising water table elevation, reconnecting 

floodplains to the stream channel, and promote the 

development of riparian vegetation along Ash Creek and 

Swamp Creek to increase streambank stability. Specifically, 

Figure 14. Previously Treated Area at Southern 

End of the Project Area that Represents a Desired 

Condition for Hardwoods
Elk Flat LSR Enhancement Project

34 Shasta-Trinity National Forest

a need exists to:

• Riparian Vegetation - Improve conditions that favor the growth of riparian vegetation, and restore 

streamflow and vegetation conditions to support establishment of riparian vegetation within the 

Riparian Reserves associated with Ash and Swamp Creeks and their tributaries. Riparian vegetation is 

scattered along Ash Creek and limited to areas where sunlight has reached the forest floor. Understory 

vegetation is nearly absent in the dense stands and there is a need to increase exposure to sunlight to 

promote riparian plants within the Ash Creek Riparian Reserve.

• Water Table – Increase and maintain water table elevation. Although intermittent stream flow is an 

inherent background characteristic for both Ash Creek and Swamp Creek, conditions could improve 

that would incrementally raise water table elevation, leading to increased water storage and flow 

duration. 

• Channel Banks - Strengthen channel banks. Banks are more susceptible to erosion in the project area 

than the channel upstream. In contrast, abundant riparian vegetation and in-stream bedload structure 

demonstrate active processes of channel evolution that are deficient within the project area.

• Road Interaction - Reduce road interactions with stream channels. The compacted road surfaces 

concentrate surface flows, increase stream power and increase erosive energies flowing into channels. 

In Elk Flat, old road crossings and unauthorized routes capture streamflow to Swamp Creek resulting 

in channel entrenchment, headward erosion into the meadow and subsequently lowering the water 

table. 

• Floodplain Restoration – Reduce overland flow from adjacent compacted surfaces such as old 

landings and unauthorized routes, and restore floodplain function at existing previously used landings 

on floodplains. These features alter the flood topography, do not support hydrologic function and 

prevent attainment of ACS objectives. Restoring floodplain topography is needed in these areas to 

restore floodplain processes and functions and associated water table elevation.

• Woody Debris - Increase instream channel structure. Excessive inputs of large wood from whole tree 

failure create log-jams that obstruct the channel and cause widening. There is a need to moderate the 

rate of large woody debris input to incremental, to support channel structure and allow channels to 

detain sediment load, construct banks and facilitate floodplain interaction.

• Habitat and Natural Corridor - There is a need to meet the Forest Plan desired future condition for 

Riparian Reserves to meet dispersion habitat requirements for the NSO and other late-successional 

dependent species such as fisher and northern goshawk (Forest Plan pp. 4-80), as well as appear as 

natural corridors throughout the Matrix (Forest Plan pp. 4-81). Past landings reduce floodplain 

function and are detrimental to the appearance and function of a natural corridor.

Background

The Forest Plan and ACS Objectives (pp. 4-53) provide objectives that watersheds need to maintain or 

improve their processes and functions at a 5th field watershed scale. Additionally the Edson WA identified 

Riparian Reserve habitat improvement opportunities through improved stand condition and reduced fuels, and 

reduced road density in close proximity to riparian and aquatic habitats (p. 124).

Desired Conditions

The desired condition is a restored hydrologic environment within the project area in support of the ACS

objectives as listed on page 4-53 of the Forest Plan. The desired condition is to meet or not prevent attainment 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 35

of all nine ACS objectives. The following ACS objectives highlight the greatest difference identified between 

the existing condition and the desired condition:

ACS Objective #4. Maintain and restore water quality necessary to support healthy riparian, aquatic, 

and wetland ecosystems. Water quality must remain within the range that maintains the biological, 

physical, and chemical integrity of the system and benefits survival, growth, reproduction, and 

migration of individuals composing aquatic and riparian communities.

ACS Objective #7. Maintain and restore the timing, variability, and duration of floodplain inundation 

and water table elevation in meadows and wetlands.

ACS Objective #8. Maintain and restore the species composition and structural diversity of plant 

communities in riparian areas and wetlands to provide adequate summer and winter thermal 

regulation, nutrient filtering, appropriate rates of surface erosion, bank erosion, channel migration,

and to supply amounts and distributions of coarse woody debris (CWD) sufficient to sustain physical 

complexity and stability.

ACS Objective #9. Maintain and restore habitat to support well-distributed populations of native 

plant, invertebrate and vertebrate riparian-dependent species.

Existing Conditions

There are only intermittent channels and no perennial streams in the project area. Ash Creek is the dominant 

channel, flowing through the project and transporting more water more frequently than any other intermittent 

channel. Swamp Creek is an intermittent channel that carries seasonal or stormflow of very short duration 

with a substantial sediment load. These are the most distinctive channel forms found though there are many 

less well-formed channels nearby as evidence of historical activity.

Upstream of the project area, abundant riparian vegetation, well-defined inner gorges and instream bedload 

structure demonstrate active processes of channel evolution. However, these processes are interrupted in the 

project area. Reaches of channel are disconnected from their floodplain. Shade from dense overstory 

vegetation prevents sun-loving riparian vegetation from establishing and thriving. Unauthorized roads 

intercept streamflow in channels and divert flow during runoff events. The hydrologic and watershed 

resources within the project boundary do not support ecological processes necessary to maintain properly 

functioning conditions. Specifically, existing conditions departing from desired conditions and outside a 

natural range of variability include:

• Existing Landings from Past Activity in Riparian Reserves reduce floodplain function and 

potential diversion of surface flow.

• Unauthorized Routes not designed and not maintained. Topography and unauthorized routes often 

interact with streams during flood events in the project area. Many of these routes become connected 

when they capture surface runoff that would otherwise infiltrate into the ground and concentrate it on 

the road surface. When these routes collect runoff, they often pick up and transport fine sediment and 

leave the winnowed coarser rock, which is then detrimental to the overall hydrology. Unauthorized 

routes U41N09B, U41N02YB, U41N46B, U41N13B, 41N12D, U41N10AB and U41N10AC all 

intercept channels in one or more locations. High road prisms may also control flow by intercepting 

or damming runoff while low road prisms may concentrate flow.

• Road Interactions - The interactions of topography, roads and streams are magnified by several 

roads that are in close proximity. Several sources of water that contribute flow to a given location can 

and does lead to flooding and sediment inputs into streams. Ash Creek receives such inputs at several 
Elk Flat LSR Enhancement Project

36 Shasta-Trinity National Forest

locations during moderate flow and melting events, such as the intersection of the Military Pass Road 

(41N19X) with 41N09 (see Figure 15).

Figure 15. Forest Road 41N19X Surface Runoff into Ash Creek

• Hydrologic Function - Intermittent streams, such as Ash Creek and Swamp Creek, provide

considerable ecological value, especially in the absence of perennial flow, to systems dependent on 

them. Hydrologic processes, such as flooding, that maintained Elk Flat in the past have been

disrupted by lack of connection to Swamp Creek and its intermittent channel system. Historical road 

systems have diverted flow from Swamp Creek, concentrating flow and eroding Swamp Creek into a 

gully, disconnecting it from spreading out over the meadow.

• Woody Debris - Woody debris recruitment is a necessary component in channels; however, input in 

large amounts is causing woody debris dams and channel widening. An accelerated rate of bank 

erosion along Ash Creek, where the accumulation of woody debris is high, diverts water around log 

jams (see Figure 16).
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 37

Figure 16. Log jam collecting sediment and causing bank erosion along Ash Creek.

• Riparian Vegetation - Ash Creek lacks riparian plant communities and floodplain interaction. 

Scattered riparian vegetation is limited to discontinuous locations where sunlight can reach the forest 

floor along Ash Creek, but is absent along Swamp Creek as well as other smaller intermittent 

channels.

6. National Forest Transportation System (FTS) Management and Decommission 

Unauthorized Routes

Need for Action

A need exists to increase FTS efficiency and provide access to a dispersed recreation area in Elk Flat. The 

project Transportation Analysis Process (TAP) recommends adding approximately 0.10 miles of existing 

unauthorized route that is currently utilized as public access to a dispersed recreation area in Elk Flat. This 

segment would be added to the FTS as an open, maintenance level 2 road to provide legal motorized access 

(Bonivert, 2015a).

A need exists to remove several existing unauthorized routes in the project area and restore these areas to a 

more natural condition.

Background

The Record of Decision for Motorized Travel Management (MTM ROD) established the National Forest 

System transportation network (FTS or “system”) on the Shasta-Trinity National Forest (USDA-FS, 2010a). 

The MTM ROD acknowledged that unauthorized routes not added to the FTS may in the future be considered 

for removal from the landscape and restored to the natural condition, converted to trails, or added to the FTS 

in future NEPA analyses (USDA-FS, 2010a p. 4). The Pilgrim Vegetation Management Project’s Road 
Elk Flat LSR Enhancement Project

38 Shasta-Trinity National Forest

Analysis documents the analysis of some roads within the Elk project boundary and provides 

recommendations for changes to the FTS to reduce the open road density. A similar process evaluated the 

remainder of the system and unauthorized routes in the project area during identification of the purpose and 

need for action.

Roads and routes were considered for impacts to wildlife connectivity, stream channels and floodplain 

function within the LSR and the meadow at Elk Flat. Additionally the road system and unauthorized routes 

were evaluated in the context of broader FTS management with the desired and existing condition described 

here.

Desired Condition

The Forest Plan directs providing and maintaining roads per pages 4-16 to 4-17. In particular, it recommends

retaining roads that will be needed for future activities (beyond one season) such as forest health, timber 

management, fire protection, recreation management, mining, wildlife and range. Non-inventoried roads 

[unauthorized routes] would be analyzed to determine whether they should be added to the transportation 

system or obliterated as time and funding allow.

In identifying the desired condition and the need for action, the forest- wide goals for facilities, including 

roads, were reviewed:

Goal 8: Manage the Forests' transportation system to facilitate resource management activities, protect 

wildlife, meet water quality objectives, and provide recreational access (page 4-4).

Goal 9: Provide and maintain those administrative facilities that effectively and safely serve the public 

and Forest Service work force (page 4-4).

The desired condition is a safe, efficient transportation system in the project area with the minimum road 

density needed to meet administrative, recreational, and cultural access needs while protecting natural 

resources (Forest Plan, 1995 pp. 4-4, 4-16, 4-17). Open road density would only include FTS roads that are 

open to vehicle use as designated on the Forest Motor Vehicle Use Map (MVUM). Unauthorized routes not 

needed for the FTS system would be restored to a natural condition (USDA-FS, 2010a p. 4).

Existing Condition

The 18.64 miles of existing road system provides access to old landing locations, plantations and adjacent 

private inholdings. Maintenance levels can indicate an approximate average cost of maintenance per mile. 

Roads are typically closed for resource protection, cost-efficiency and to reduce open road density. Closed 

roads may be opened and made available for resource management as needed, then closed again. The project 

area contains an approximate FTS open road density of 2.72 miles per square mile.

Approximately 6.5 miles of unauthorized routes exist in in the project area. A 0.1-mile segment of an 

unauthorized route accesses a popular dispersed recreation area on the edge of Elk Flat meadow. Currently the 

route is not approved for motor vehicle use on the MVUM, preventing legal motorized access to the area.

Proposed Action

Introduction and Summary

The Proposed Action (PA) was developed to meet the purpose and need for action by moving the existing 

conditions toward desired conditions. The PA is briefly introduced here in Chapter 1 as a qualitative 

description of the types of activities proposed to achieve the Purpose and Need for Action. Chapter 2 presents 

the PA and alternatives to it in detail, including the connected actions, geographic locations, scale, and 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 39

timeframes of the actions along with the required Resource Protection Measures (RPMs) and Monitoring.18

Silvicultural prescription details and unit-specific information is provided in Appendix B.

The interdisciplinary team incorporated guidance from the Forest Plan, the LSRA, and the Northwest Forest 

Plan along with management recommendations from the Edson and Mt. Shasta WAs, the National Fire Plan

and the Forest’s Fire Reference System in developing the PA.

19 The PA is an incrementally modified version 

of the original Proposed Action as presented in public scoping and the notice of intent. The original PA was 

dropped from detailed consideration (see p. 117). The incremental changes to the PA are listed in Appendix H.

This Modified PA is presented as Alternative 1.

The PA falls into five broad categories that may contain overlapping treatments:

6. Forest Restoration Treatments – Thinning, with site-specific prescription elements, reforestation 

and adaptive management strategies. 

7. Fire Restoration and Fuels Reduction Treatments – Piling, pile burning and underburning.

8. Meadow Restoration – Meadow vegetation enhancement, with reintroduction of fire 

(underburning) and restoration of hydrologic function through road decommissioning and 

recontouring.

9. Hydrologic Function and Soils Restoration –Floodplain recontouring, decommissioning 

unauthorized routes that intersect stream channels, forest restoration (thinning and revegetation in 

the Riparian Reserves), fire restoration (underburning in Riparian Reserves). Soil restoration would 

be completed through windrow respreading.

10. Transportation System Management and Decommissioning of Unauthorized Routes – Adding a 

road to the FTS and decommissioning unauthorized routes. 

Table 6 summarizes the Proposed Actions that respond to the Purpose and Need for Action, with discussion 

following.

Table 6. Introduction of Proposed Action Treatments in Response to the Purpose and Need

Purpose and Need Objectives Proposed Action

Primary Purpose and Need

1. Risk Reduction in Early, Mid and Late-Successional Habitat and Increased Stand Resilience to Disturbance

Reduce the risk of losing existing and developing latesuccessional habitat structure from stand density, 

drought, disease, insect and fire-related mortality.

Forest and Fire Restoration and Fuels Reduction

Treatments

 18 Appendix B (Unit-Specific Information, Treatments and Road Actions), 0 (Standard Operating Procedures and Best 

Management Practices) and 0 (Maps) provide more detailed information about the Proposed Action.

19 (Forest Plan, 1995), (LSRA, 1999), (NWFP, 1994 p. Attch. B), (USDA-FS, 2011), (USDA-FS, 2012), (USDA & USDI, 

2000), (USDA-FS, 2015). The proposed action is also designed to be consistent with applicable Recovery Actions (10 and 

32) and the overall intent of the Revised Recovery Plan for the Northern Spotted Owl (USDI-FWS, 2011) and comply with 

all law and policy. Best available science was incorporated in the design of the Proposed Action.
Elk Flat LSR Enhancement Project

40 Shasta-Trinity National Forest

Purpose and Need Objectives Proposed Action

Insect and Disease Conditions

Reduce the spread of black stain and 

Heterobasidion root disease and associated 

mortality.

Forest Restoration - Natural Stand and Plantation 

Thinning to promote resilience and treat insect and 

disease centers through:

• group selections to remove host species for 

Heterobasidion and blackstain.

• removal of affected trees and buffering to break 

up root-root contact and increase sunlight on 

forest floor to treat blackstain.

• reforestation with non-host species in the group 

selections and interplanting to break up disease 

centers.

Stand Composition, Structure and Density

Emphasize maintenance, protection and 

enhancement of the forest vegetation conditions

and elements that serve as suitable habitat for latesuccessional dependent species, and more open 

stands for late-successional ponderosa pine.

Forest Restoration - Natural Stand Thinning to decrease 

density with:

• variable density thinning from below.

• biomass thinning with adaptive management to 

decrease density in the understory.

• radial thinning to preserve large legacy pine.

• unthinned patches to promote heterogeneity.

• group selections to promote heterogeneity.

• habitat Rest/Roost Clumps to promote and 

preserve habitat elements.

Fire Regime, Fuel Loading and Fire Behavior

Restore forest stand conditions to maintain ladder 

and surface fuels at levels that allow for return of a 

natural fire regime to the landscape and more 

effective suppression when it is necessary.

Forest Restoration - Natural Stand and Plantation 

Thinning with:

• biomass thinning to reduce fuel ladders.

• salvage Adaptive Management to treat additional 

mortality in limited stands that would contribute to 

fuel loading.

Fire Restoration and Fuels Reduction

• machine pile and pile burn to treat high 

concentrations of down fuel to allow prescribed 

and natural fire to play a more natural role in the 

environment.

• underburn to treat fuels and reintroduce fire to 

restore the natural fire regime.

Secondary Purpose and Needs

2. Accelerate Development of Late-Successional and Old-Growth Forest Characteristics and Promote LateSuccessional Habitat Connectivity

Correct conditions that delay or prevent development of 

late-successional forest and reduce value for 

connectivity to existing late-successional forest.

Forest and Soils Restoration Treatments

The actions that meet the P&N for risk reduction also 

accelerate meeting this P&N. Additionally the following 

specifically meet P&N #2.

Pine Overstory

Promote the healthy growth and development of a 

pine overstory by reducing density and retaining the 

healthiest trees, while retaining and promoting a mix 

of species where they occur.

Forest Restoration – Plantation thinning to reduce 

density and retain stands and accelerate growth with:

• interplanting to promote heterogeneity.

• group selection and reforestation to promote 

heterogeneity.

Forest Restoration – Radial thinning around legacy 

pines in natural stands and plantations

Soil Productivity

Restore soil productivity in previously windrowed 

plantations.

Soils Restoration

• windrow respreading to restore topsoil distribution 

to restore fertility.

3. Restore Meadow Habitat in Elk Flat
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 41

Purpose and Need Objectives Proposed Action

Restore the dry meadow ecosystem at Elk Flat. Forest, Meadow, Fire Restoration and Fuels Reduction, 

Hydrologic Function Restoration.

Early Seral Restoration

Restore early-seral vegetation to pre fire-suppression 

conditions.

Meadow Restoration

• meadow enhancement treatment to remove 

conifer encroachment.

Forest Restoration

• thinning with meadow enhancement to feather 

meadow enhancement treatment into adjoining 

stands.

Meadow Fire Regime Restoration

Restore the natural fire regime and fire return interval that 

contributes to maintenance of early seral vegetation.

Fire Restoration

• underburning.

Hydrologic Function Restoration

Maintain or increase water table elevation and 

remove unauthorized route interactions with 

channels.

Restore floodplain function, drainage network 

connectivity and natural contours

Decommissioning of Unauthorized Routes

• decommission unauthorized routes, which capture 

and concentrate runoff causing channel erosion, 

to improve groundwater retention.

Hydrologic Function Restoration

• contour floodplain geometry in Elk Flat Riparian

Reserves where needed along decommissioned 

unauthorized routes and old skid trails to restore 

natural flooding between floodplains and channels 

to improve sheetflow, infiltration and groundwater 

storage.

4. Retain Hardwoods as a Stand Component at Density Levels Commensurate with Development of LateSuccessional Stands

Assure hardwoods thrive and remain in stands at 

naturally occurring levels.

Forest, Meadow and Fire Restoration and Fuels Reduction

Treatments and Aspen Restoration Adaptive Management

Retain and enhance oak as a stand component. Forest Restoration - Thinning with:

• oak release to decrease conifer encroachment.

Release and Restore Aspen Clones.

Forest Restoration – Thinning with:

• aspen release through conifer removal.

Meadow Restoration-meadow enhancement removes 

conifer including around aspen in Elk Flat meadow.

Aspen Restoration Adaptive Management

• aspen restoration adaptive management – fire or 

mechanical stimulation of suckering if initial 

release not effective.

• browse fencing will protect young aspen shoots if 

monitoring shows it is needed.

Restore a natural fire regime.

Fire Restoration

• undeburning which may favor retention of aspen 

in stands by encouraging a more open understory 

and stimulate suckering in aspen.

5. Improve streamflow and vegetation conditions within Riparian Reserves associated with Ash and Swamp 

Creeks and their tributaries

Restore Hydrologic Function.

Forest, Meadow, Fire Restoration and Fuels Reduction, 

Hydrologic Restoration Treatments. Unauthorized Route 

Decommissioning.
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42 Shasta-Trinity National Forest

Purpose and Need Objectives Proposed Action

Vegetation in Riparian Reserves

Improve conditions that favor the growth of riparian 

vegetation.

Improve the connectivity and natural appearance of 

riparian corridors.

Forest Restoration Treatments

• thinning in Riparian Reserves to promote sunlight 

favoring riparian plant reproduction.

• reforestation – planting/seeding riparian and 

upland (mesic) species that support riparian 

function.

Fire Restoration and Fuels Reduction Treatments

• underburning in Riparian Reserves to increase 

sunlight to improve growing conditions for riparian 

species.

Streamflow

Maintain or improve water table elevation and 

remove road runoff interactions with channels.

Restore floodplain function, drainage network 

connectivity and natural contours.

Decommission Unauthorized Routes

• Decommission unauthorized routes that

concentrate runoff directly into channels and 

cause erosion to stream channels, restoring 

processes leading to more natural groundwater 

storage by decreasing water diversions.

Hydrologic Function Restoration

• Contour floodplain geometry and old landings in 

Riparian Reserves where needed to restore 

natural flooding between floodplains and 

channels, improving sheetflow and infiltration 

leading to restoring of more natural groundwater 

storage processes in the floodplains.

Streamflow

Strengthen channel banks.

Increase instream structure.

Forest Restoration Treatments

• thinning in Riparian Reserves to improve growing 

conditions for sunlight-dependent riparian 

vegetation to strengthen channel banks and to 

improve forest stand health to a condition that can 

more naturally meter woody material input into the 

channel and instream structure.

• reforestation – planting/seeding riparian species to 

stabilize stream banks.

Fire Restoration Treatments

• underburning in Riparian Reserves to enhance 

growing conditions for riparian vegetation which 

will strengthen stream banks.

6. National Forest Transportation System (FTS) Management and Decommissioning of Unauthorized Routes

Remove unauthorized routes and restore to the natural 

condition. • decommissioning unauthorized routes.

Meet the administrative, recreational, and cultural 

access needs.

• adding 0.1 miles of existing unauthorized route 

segment to the system to access the dispersed 

recreation site at Elk Flat.

The PA includes Resource Protection Measures (RPMs) that set site-specific requirements during 

implementation. Connected Actions are not needed to meet the Purpose and Need for Action, but needed to 

implement the PA. They include actions such as road and landing work needed for access and hauling of 

timber products, fireline construction, borate fungicide stump treatments to inhibit the spread of 

Heterobasidion root disease, hazard reduction and danger tree felling, timber hauling, legal compliance 

processes or permits, and administrative actions. RPMs and Connected Actions are described in Chapter 2.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 43

Decision Framework

After reviewing this environmental impact statement and supporting documents, and considering all public

input on the project, the Forest Supervisor of the Shasta-Trinity National Forest will decide whether to

implement the Proposed Action as described, select another action alternative that meets the purpose and

need, or take no action. The decision would be in accordance with Forest Plan goals, objectives, and desired

future conditions.

If an action alternative is selected, the decision would specify:

When proposed activities could begin and whether there are any time restrictions,

How roads in the project area would be managed,

What mitigation and monitoring requirements would take place.

Public Involvement

Under 36 CFR 215, the Notice of Intent (NOI) was published in the Federal Register on February 28, 2013.20

The NOI asked for public comment on the proposal by April 1, 2013 (USDA-FS, 2013). In addition, as part of 

the public involvement process, the agency prepared a scoping document that was mailed to interested 

individuals, organizations and agencies on February 14, 2013 (USDA-FS, 2013b). A Notice of Intent was 

published in the Redding Record Searchlight on February 27, 2013 and March 3, 2013. Public meetings were 

held March 5 and March 26, 2013 in McCloud and Mt. Shasta. The Forest Service received 11 comment 

letters or emails. Appendix C summarizes the scoping effort, results and responses to scoping comments.

Outside of the formal scoping period, the Forest has reached out to the public, resource and other agencies 

and Tribes for input on the Elk Project since 2010:

• Schedule of Proposed Actions (SOPA) – Status and basic information about the Elk project has been 

continually listed in the Forest’s SOPA since January 2010 (USDA-FS, 2010-2015).

• Field Trips – As a potential stewardship contract project, the proposed action was developed 

collaboratively (USDA-FS, 2008). The Elk Late Successional Reserve Enhancement Project 

Stewardship Collaborative Working Group hosted by the Shasta Valley Resource Conservation 

District (RCD) conducted two field trips to the project area in 2012 for stewardship collaboration 

feedback during project development. Working Group members represent various agencies, 

organizations, neighboring landowners and Tribal governments with a stake in implementation of a 

stewardship project in the area. Field trips took place on July 26 and August 9 and project feedback 

was collected and considered during development of the Proposed Action (RCD, 2012).

• Tribal Consultation – Tribal Consultation information is provided in Chapter 3 (see p. 236).

• FWS Consultation – FWS consultation is summarized in the Chapter 3 wildlife section and detailed 

in Appendix E).

 20 Subsequent to scoping, the regulations changed making the project subject to 36 CFR 218, Subparts A and B. 

Pursuant 36 CFR 218, only those who submit timely project-specific written comments regarding a proposed project or 

activity 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.
Elk Flat LSR Enhancement Project

44 Shasta-Trinity National Forest

• Shasta-McCloud Management Unit Open Houses –Elk Project information was made available along 

with the opportunity for discussion at annual open houses in 2014 (February 5 and 6) and in 2015 

(February 10 and 12) in McCloud and Mt. Shasta.

Issues

The project’s interdisciplinary team (IDT) sorted the issues into two groups: key and non-key issues. The IDT 

identified key issues as those directly or indirectly caused by implementing the proposed action. Non-key 

issues were identified as those that are: 1) outside the scope of the proposed action; 2) already decided by law, 

regulation, Forest Plan, or other higher level decision; 3) irrelevant to the decision to be made; or 4) 

conjectural and not supported by scientific or factual evidence. 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)...” 

Appendix C provides the comments. The IDT identified the following key issues. Issues are paraphrased from 

the sometimes lengthier or duplicative comments.

Issue 1 – Large Trees and Snags

Large tree and snag removal and group selection logging directly harms forest health and latesuccessional ecosystems in Late-Successional Reserves, Riparian Reserves and Critical Habitat; prevents 

rather than facilitates forest succession processes; and is not consistent with the Northwest Forest Plan.

Discussion and Indicators

While the commenter did not define “large tree,” two alternatives are responsive to the issue of harvest tree 

size selection. Alternative 6-Limit Harvest to Trees Less than 10 Inches in Diameter, suggested by a 

commenter, limits tree removal to those under 10 inches DBH and is described on page 119. It is eliminated 

from detailed study because modeling the stands shows that while it would reduce fuel ladders in the shortterm, it would not meet the need to reduce the risk of late-successional habitat loss due to overstocking that is 

ongoing in the project area, nor would it sufficiently reduce existing standing and dead fuels. Similarly, 

Alternative 8-Limit Harvest to Trees Less Than 20 Inches in Diameter within the Elk Flat Late-Successional 

Reserve, described on page 120, is responsive to this issue. This alternative was dropped from detailed 

consideration because preliminary modeling showed it would not meet the purpose and need for action for the 

same reasons as Alternative 6, with the exception that it would still meet the meadow restoration purpose and 

need since Elk Flat meadow is in Matrix.

The discussions for Alternatives 6 and 8 provide rationale for why these alternatives were dropped from 

detailed consideration. The Modified Proposed Action is summarized as it relates to larger trees and snags and 

the corresponding effects on forest health, late-successional ecosystems in the Elk Flat LSR, designated 

critical habitat for NSO, successional processes and compliance with the Northwest Forest Plan. Chapter 3 

(starting p. 124) provides the effects analysis related to this issue. Indicators and measures specific to effects 

to large trees and snags are:

c. number of trees greater than 24 inches DBH immediately post-treatment and projected in 20 years 

based on comparative modeling of the alternatives,

d. number of snags greater than 20 inches DBH projected in 20 years based on comparative modeling.

Issue 2 – Road Construction

Road construction directly harms forest health and wildlife and results in long-term impacts to soil health 

and productivity.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 45

Discussion and Indicators

This issue is interpreted to pertain only to temporary road construction because the Modified Proposed Action

(Alternative 1) does not include new permanent road construction.21 Alternative 2 (considered in detail) and 

Alternative 9 (considered but not in detail) respond to this issue.

Alternative 9-No New Temporary Road Construction, discussed on page 120, was not considered in detail due 

to concerns with project feasibility, potential environmental harm, and meeting Forest Plan Visual Quality 

Objectives. The discussion for Alternative 9 provides rationale for why this alternative was not considered in 

detail.

Alternative 2 - No New Temporary Road Construction Other than Those Required for Landing Use/Access

limits rather than eliminates new temporary road construction.

Chapter 3 (starting pp.208 and 225) provides the effects analysis related to this issue. Indicators specific to 

road impacts are:

e. miles of new temporary road construction,

f. total open road density post-implementation in comparison to No Action,

g. miles of existing unauthorized route decommissioning, and

h. acres meeting soil quality standards post-implementation.

Forest Transportation System roads are not considered within the soils resource under the Forest Plan (pp. 

Appdx. O-2).

Issue 3 – Critical Habitat

Treatments within designated critical habitat for the northern spotted owl violate the 2011 Revised 

Recovery Plan and the 2012 Final Critical Habitat Rule for the Northern Spotted Owl.

Discussion and Indicators

Alternative 3 -No Treatments of Natural Stands within Designated Critical Habitat for the Northern Spotted 

Owl is responsive to this issue and is considered in detail. As Recovery Plans are not regulatory, they cannot 

be violated. However, as described earlier in this Chapter, Forest Plan standards and guidelines direct that the 

Forest maintain or enhance habitat for threatened, endangered, and sensitive (TE&S) species consistent with 

individual species recovery plans (p. 4.30).

Emphasizing the protection and enhancement of the forest vegetation conditions and elements that serve as 

suitable habitat for late-successional dependent species (including the NSO) is integral to the Purpose and 

Need for Action and Forest Plan management direction. The predicted effects on NSO, all suitable habitat, 

dispersal habitat as it relates to connectivity, and designated critical habitat are analyzed for all alternatives 

considered in detail to measure the achievement of the Purpose and Need. This information is summarized in 

Chapter 2 (

Table 29, p. 94) and in Chapter 3 in the Wildlife section.

The indicators specific to this issue are as follows:

a. acres of critical habitat, per primary constituent element, maintained/benefitted in NSO core areas, 

home ranges and the project area,

 21 One existing FTS road will be reconstructed.
Elk Flat LSR Enhancement Project

46 Shasta-Trinity National Forest

b. acres of critical habitat, by primary constituent element, degraded, downgraded or removed through 

treatments in NSO core areas, home ranges and the project area,

c. acres of suitable and dispersal habitat projected in 20 years within critical habitat, and

d. acres of capable habitat projected within 20 to 30 years within critical habitat.

These issue indicators are used to measure the scale of how the alternatives considered in detail meet the 

management guidance, and the special management considerations for critical habitat subunit ECS-3, in the 

2012 Final Critical Habitat Rule for the Northern Spotted Owl. 

Issue 4 – Mushroom Collection in Elk Flat

There will be negative impacts to Boletus mushroom growth and collection activities within Elk Flat.

Discussion

Alternative 5, No Treatments in Elk Flat Meadow, described on page 117 is responsive to this issue. It is not 

considered in detail because it would not meet the Purpose and Need for Action of meadow restoration in Elk 

Flat. The discussion for Alternative 5 provides rationale for why this alternative was not considered in detail 

and summarizes the protections integrated into the Modified Proposed Action pertaining to edible 

mushrooms.

Chapter 3 provides the analysis of effects to edible mushrooms (specifically Boletus habitat) in Elk Flat, for 

all alternatives considered in detail, and as compared with the no action alternative (see discussion starting on 

p. 186).

Issue 5 – Machine Piling

Machine piling has disproportionately harmful impacts on watershed and soil resources.

Discussion and Indicators

Alternative 7-Eliminate the Use of Machine Piling within Treatment Units and Substitute Hand Piling, 

described on page 119, responds to this issue but was not considered in detail because it is not supported by 

the local monitoring data and best available science for soil types within the project area. The discussion for 

Alternative 7 provides rationale for why this alternative was not considered in detail and summarizes the 

protections integrated into the Modified Proposed Action pertaining to preserving soil productivity.

Chapter 3 provides the analysis of effects to the soil resource for all alternatives considered in detail and as 

compared with the no action alternative (see discussion starting on p. 208). Indicators for this issue include:

e. acres of machine piling, and

f. attainment of soil quality standards post-implementation.

Additionally, at the watershed scale, both qualitative and quantitative (Equivalent Roaded Area) analyses 

include disturbance from machine piling by alternative. Each action alternative is compared to the No Action 

alternative (see discussion starting on p. 193).

Other Related Efforts

There are no related actions that will affect the Proposed Action or Purpose and Need for Action.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 47

Chapter 2. Alternatives, Including the Proposed Action

Chapter 2 describes the Proposed Action and compares the alternatives to the Proposed Action considered for 

the Elk project. It includes a description of each alternative considered. The Proposed Action in Chapter 2 is a 

description of how, how much, and where actions would be implemented

Alternatives are presented as either “Alternatives Considered in Detail” (starting with Alternative 1on p. 57) 

or as Alternatives Considered but Eliminated from Detailed Study (starting p. 81).The alternatives are 

presented in comparative form, defining the differences between each alternative and providing a clear basis 

for choice among options by the decision maker and the public. The Comparison of Actions - Alternatives (p. 

76) provides tables comparing the alternatives by the principal actions. 

Table 29 (p. 94) summarizes the Chapter 3 analysis of effects to resources, effects related to the Purpose and 

Need for Action, and effects pertaining to the key issues.

Description of Actions

All action alternatives include the following actions, but differ in quantity and spatial application of these 

actions. General descriptions of the actions, and their tie to the Purpose and Need for Action, are provided 

below. Appendix B provides detailed information as needed. Resource Protection Measures (RPMs) common 

to action alternatives are listed starting on page 81, required monitoring on page 90, and standard operating 

procedures in Appendix D.

Vegetation manipulation and fuels treatments are proposed in concert and are developed consistent with the 

guidance in management direction and other informing sources to best address the Purpose and Need for 

Action. Processes that historically created late-successional and old-growth ecosystems include (NWFP pp. 

B-2): tree growth and maturation; death and decay of large trees; low to moderate intensity disturbances (such 

as fire, wind, insects and disease as described) that create canopy openings and gaps in various strata of 

vegetation; establishment of trees beneath the maturing overstory trees either in gaps or under the canopy; and 

closing of canopy gaps by lateral growth or growth of understory trees (LSRA p. 162). These processes result 

in forests moving through different stages of late successional and old-growth conditions that may span 

several hundred years.

Forest Restoration Treatments

Forest restoration treatments include thinning and reforestation. Variations and prescription elements are 

based on site-specific conditions.

Thinning

Thinning is the selective removal of certain trees to manage overcrowding while retaining desirable attributes 

such as large trees and species and structural diversity. Thinning promotes the survival and health of larger 

overstory trees while maintaining and developing a variety of habitat conditions within the stands. Thinning 

reduces individual tree stress by freeing up resources, such as water, nutrients and available sunlight for the 

remaining trees to increase their resilience to drought, disease and insect impacts. Thinning also reduces live 

ladder and canopy fuels, increasing a stand’s resilience to high severity wildfire effects. 

Thinning is divided broadly by whether the stand is natural or a plantation. Thinning of natural stands 

responds primarily to Purpose and Need #1 - Risk Reduction in Early, Mid and Late-Successional Habitat and 

Increased Stand Resilience to Disturbance. Plantation thinning responds primarily to Purpose and Need #2 -

Accelerate Development of Late-Successional and Old-Growth Forest Characteristics and Promote LateSuccessional Habitat Connectivity.
Elk Flat LSR Enhancement Project

48 Shasta-Trinity National Forest

Variable density thinning would accomplish thinning treatments for natural stands and some older plantations. 

Variable density thinning does not include a singular density target, rather it retains a range of densities by 

including unthinned patches (also referred to in some literature as skips), areas of heavy thinning or small 

openings (radial release of pine and black oak, gaps, or group selections), and thinning within a target basal 

area range elsewhere within the stand.

Thinning prescriptions were specifically developed to reduce the risk of losing habitat for late-successional

species, increase conifer species diversity in plantation areas and natural stands, treat black stain and 

Heterobasidion root disease, and reduce the risk of developing future extensive mortality areas. Proposed 

thinning prescriptions reduce stand density, break up fuel continuity, promote the healthy growth of residual 

trees, and promote species and structural diversity. Residual basal area targets and tree selection criteria retain 

canopy cover and habitat elements while addressing the current unsustainable stand densities.

Generally, thinning would leave the largest healthiest trees that are expected to survive long term into the 

future, with exceptions for species diversity. Trees to be removed would primarily be midstory intermediate 

and smaller co-dominant trees, particularly the shade tolerant white fir that has grown up through the 

understory over the last several decades. For example, in some cases white fir that are larger in relation to 

adjacent healthy trees of other less common mixed conifer species such as Douglas fir and incense cedar 

would be removed to promote species diversity.

Thinning would retain and promote late-successional habitat structures and features while reducing 

overstocking, treating fuels, and promoting the survival of pine while maintaining a mix of tree species. Stand 

variability is important for providing habitat. Variable density thinning (see discussion under Natural Stand 

Thinning below), along with other silviculture prescription elements are designed to support and develop latesuccessional habitat through promoting structure heterogeneity, while addressing undesirable (unsustainable) 

stand densities and excess fuels.

Prescription Elements

Specific elements of the thinning prescriptions would be applied in thinning units based on site-specific 

conditions including:

Tree Selection

Tree selections will be made per the general marking guidelines as described starting page B-22 and as 

applicable for the stand conditions in the treatment unit. Predominant trees are retained across all 

prescriptions.

Unthinned Patches

Whether natural stand or plantation, thinning within the LSR includes leaving unthinned patches (UTPs)

within treatment units within LSR allocation to retain variable conditions and stand elements that promote 

structural heterogeneity for wildlife and late-successional forest values. Unthinned patches vary in size and 

placement, but typically range between 12 and 50 percent of the unit acreage. The UTPs would be selected by 

identifying the best available NSO and fisher habitat elements within a unit. Snag retention areas would 

comprise the unthinned patches in units with heavy mortality when other valuable features are not available to 

retain. See Appendix A page B-24 for more information on unthinned patch designation and Table Appendix 

B-2 on page B-6 for unit-specific unthinned patch acreage.

Habitat Roost/Rest Clumps

As available, six roost-rest clumps per acre dispersed throughout the unit boundary would be retained. Habitat 

roost-rest clumps are distinct groups of tightly spaced overstory trees and snags, often with late-successional

characteristics and with smaller (less than 10-inch size class) shade tolerant trees growing underneath. These 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 49

clumps can range from a tight group of 3 to 6 trees or snags to 1/10 of an acre. See Appendix A page B-25 for 

more discussion.

Radial Release of Predominant Pine

Radial thinning around a maximum of two predominant pine per acre, except unit 157 which is four trees per 

acre, would be implemented where it would have the greatest beneficial effect on predominant pine that are 

relatively healthy but crowded by advanced second growth trees. Radial thinning generally removes smaller 

diameter trees within a 50-foot radius of the bole except for other predominant trees of any species. Radial 

thinning would reduce density, remove fuels and promote tree vigor and long term survival of these larger 

older trees. See page B-25 for more discussion on radial thinning and Table Appendix B-2 on page B-6 for 

unit-specific radial release information.

Biomass Thinning

Biomass-sized trees (4 to 9.9-inch DBH) would be mechanically thinned on a prescribed spacing, or to a 

prescribed basal area, in those natural and plantation thinning units that have a biomass thinning component 

as listed in Table Appendix B-2 on page B-6. Biomass material that is thinned would either be removed from 

the unit or left on site, such as when thinning is accomplished by mastication. Masticated material would 

remain on site until to decay or be treated with prescribed fire.

Oak Release

The oak release treatment removes adjacent conifers in an egg-shaped clearing with the long side to the south 

of the oak tree (see diagram Figure Appendix B-1 on p. B-27). Predominant trees and dominant trees that 

have late-successional characteristics and healthy sugar pine would not be removed. In NSO Critical Habitat,

oak release would additionally retain any 24 inch and larger Douglas-fir, sugar pine or incense cedar.

Aspen Release

To help restore aspen it would be released by removing conifer encroaching within 150 feet. If predominant

conifer or healthy sugar pine larger than 10” DBH are present, up to 10 conifer per acre would be retained 

within the 150 foot area (see p.B-27). All predominant conifer would be retained even if in excess of 10 trees 

per acre.

Plantation Thinning

Plantation thinning reduces stand density, breaks up fuel continuity and promotes the healthy growth of 

residual trees as well as species and structural diversity. Plantation thinning removes trees (other than large 

predominant pine) that have been successfully attacked and are dying or likely to die when they are not 

needed to meet wildlife snag retention needs. See the detailed description starting on page B-27.

Older Plantation Thin – Plantations 40 Years or Older

The older pine plantations would be thinned to an average of 80 to 100 square feet of basal area to reduce 

stand density and retain the largest healthiest pine; however, some areas would have a higher basal area 

retained based on site-specific conditions. Group selections ranging from one to two acres (covering 

approximately 20% of the stands) would facilitate development of more diverse and resilient stands. Group 

selections would contribute to developing a second age class in the six stands where more structural diversity 

is needed. The older plantation thinning treatment varies by site specific features such as bordering the Elk 

Flat meadow or the presence of black stain or western pine beetle and in some cases also includes 

interplanting to address past and ongoing mortality, stocking deficiencies and to promote species diversity.

(See the Reforestation section below for information about planting the group selections.)
Elk Flat LSR Enhancement Project

50 Shasta-Trinity National Forest

Young Plantation Thin – Plantations Younger than 40 Years

Young plantation thinning reduces density for plantation development, removes ladder fuels and retains and 

promotes species diversity. Young plantation thinning would thin trees 4 inches DBH and larger to 75 to 100 

TPA depending on site specific conditions while retaining the healthiest largest trees. Thinning would remove 

ladder fuels and promote species and structural diversity.

Thinning of Natural Stands

Natural stand thinning of approximately 60 to 120 year old stands applies a target basal area to each stand

varying between 125 to 175 square feet per acre, but may be higher or lower as listed in Table Appendix B-2

starting on page B-6. Variations in treatment elements are based on site-specific characteristics such as stand 

type and predominant species, northern spotted owl and fisher habitat, the presence of aspen, oak or insect or 

disease activity. Thinning of natural stands retains some lower and mid story trees and higher densities in 

mixed conifer and white fir dominated stands as compared to ponderosa pine stands. Higher densities in the

vicinity of roost/rest clumps would be retained. Other variations include favoring or cultivating species that 

are more valuable to NSO and fisher habitat such as Douglas-fir, sugar pine and incense cedar, by creating

small (average 1/10th to 1/4th acre) gaps in white-fir dominated stands to develop structural heterogeneity and 

encourage understory development. Habitat diversity would be enhanced through retention of a fairly closed 

overstory and understory in patches, retaining trees overstory trees that will make desirable snags to meet 

future snag requirements if needed, and retaining dominant trees that meet the criteria (see B-22) which may 

result in higher than target basal areas in places.

Where Heterobasidion root disease occurs, one-to two-acre group selections would open the canopy to 

facilitate pine regeneration in areas of dense homogenous white fir that have developed as a result of past 

management practices and the exclusion of natural frequent fire.

Reforestation

Reforestation through planting of seedlings would promote stand resiliency by planting a mix of species that 

include non-host trees for black stain and Heterobasidion root disease and help assure pine reestablishment in 

areas where it is lacking. Hand planting would be conducted in mortality openings (Interplanting) and in 

group selections (Planting Group Selections) where natural regeneration is not expected to sufficiently 

establish within five years of thinning or fuels treatments or where a mix of tree species is desired to promote 

diversity or certain species are not expected to establish naturally.

Openings created by mortality pockets between one and two acres would be evaluated post-treatment for 

interplanting needs. All group selections regardless of size, and openings created by mortality pockets two 

acres or larger would be planted. Table Appendix B-2 (starting p. B-6) lists approximate acres of group 

selections and mortality openings in applicable units.

Mechanical site preparation would be implemented as needed in larger openings (generally more than five 

acres) to remove competing understory vegetation, such as grass, prior to planting. Mechanical site 

preparation is typically completed with a small tractor with a wildland rototiller or drum masticator. Where 

mortality openings are smaller (generally less than 5 acres) and less contiguous, site preparation would be 

conducted as needed by hand scalping using hand tools.

Planting in areas generally five acres or larger would occur in a pattern of widely spaced clusters or groups of 

three to five seedlings, otherwise known as cluster planting, for a total of approximately 250 trees per acre, to 

establish seedling dominance in the vicinity of the cluster. Excess smaller saplings adjacent to the dominant 

conifers within the clusters may be removed during post-planting monitoring and release treatments. Smaller 

openings, generally less than 5 acres, would be planted with up to approximately 150 trees per acre scattered 

as individuals throughout the planted area.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 51

See Appendix A page B-33 for more information on reforestation.

Forest Restoration Adaptive Management

Aspen Restoration Adaptive Management

If aspen release monitoring indicates clumps or stands are not actively suckering within three years of conifer 

removal, underburning or mechanical soil disturbance treatments (disking) may be used to stimulate 

suckering. If aspen monitoring indicates browse damage at a level that may prevent achievement of healthy 

aspen establishment, the appropriate type and size of fencing would be installed and removed when no longer 

necessary. See pages B-27 for more information.

Salvage Adaptive Management

Under adaptive management, in the event conditions deteriorate further post-decision and post marking, 

salvage of dead and dying trees may occur in conjunction with harvest in 12 ponderosa-pine dominated

treatment units (listed in Table Appendix B-2). Areas would typically be within or adjacent to larger mortality 

areas, which are the result of the ongoing overstocking, insect or disease problem and RPMs would still apply.

Biomass Adaptive Management for Changed Market Conditions

Biomass (4 to 9.9 inch DBH) material would be mechanically thinned on a prescribed spacing, or to a 

prescribed basal area, in those units that have a biomass thinning component (as listed in Table Appendix B-2

on p. B-6). Depending on the market conditions at the time of implementation, material that is 4 to 6.9 inches 

DBH may not be mechanically thinned and removed, but instead would be treated on site with a combination 

of mechanical treatments, hand thinning or thinned through the use of prescribed fire during the underburning 

operations. Modifications to the limits of acceptable mortality for this size class during underburning under

adaptive management are defined in the RPMs (see RPM 24).

Forest Restoration Connected Actions

The following connected actions would be necessary to implement the vegetation treatments described above.

Road actions including connected actions to vegetation treatments are described separately starting on page 

55. Hazard reduction in heavy mortality areas along some roads and property lines, including some areas 

within thinning units, is connected to fuels and other various actions including thinning, and is described 

separately on page 56.

Borate Fungicide

Borate fungicide such as Sporax® or Cellu-Treat® would be applied to stumps over 14 inches in harvested 

areas within 4 hours of harvest to prevent the spread of Heterobasidion annosum.

Release of Reforested Areas

Reforestation treatments would be monitored for the need to control competing vegetation such as grasses, 

forbs, brush and dense naturally seeded in conifers from the surrounding stand (typically white fir in an area 

where ponderosa pine is being reestablished) that could inhibit the survival and growth of desirable seedlings. 

Hand or mechanical cutting of competing vegetation may be implemented within the first one to five years 

following reforestation, depending on monitoring results. Hand treatments would be most anticipated in the 

areas of less than five acres where mechanical site preparation was not utilized.

Fire Restoration and Fuels Reduction Treatments

The following fuel reduction treatments would contribute to meeting the desired condition for fire and fuels 

for Purpose and Need #1 (see p. 23). Detailed information is provided in Appendix A starting on page B-35. 
Elk Flat LSR Enhancement Project

52 Shasta-Trinity National Forest

Underburn

Underburning or broadcast burning (burning in a stand with little or no overstory, such as the meadow 

restoration units) involves a prescribed burn utilizing a low to moderate intensity fire, often under a timber 

canopy.22 Due to the high degree of departure from the natural fire regime, one burn entry is unlikely to 

achieve the objective of returning the natural role of fire to the ecosystem. Instead, 2 to 3 incremental 

underburns, repeated every 5 to 10 years would be implemented.23 The entire area would not be underburned 

in any one year, contributing to a diverse mosaic of treated area conditions. Achieving underburning 

treatments would require the following connected actions:

• Heavy concentrations of natural or activity-generated coarse woody debris would be machine piled 

and piles would be burned as a pretreatment before underburning to limit adverse fire severity effects 

to wildlife habitat and overstory trees.

• Natural and activity-generated fuels would be ignited by ground crews or aerial ignition and burned 

with a low to moderate intensity surface fire, creating a mosaic of vegetative retention.

• Naturally ignited fires moving across the project area could accomplish second and third entry

underburning objectives.

Machine Pile and Pile Burn

Where there are heavy concentrations of coarse woody debris, typically more than 40 tons per acre (or as 

specified by the Project RPMs), machine piling and burning of some piles would be utilized as a pretreatment 

before underburning to increase consumption of excess fuels over what underburning would accomplish and 

to limit adverse effects to overstory trees and wildlife habitat.

• Treatment-generated and natural fuels in excess of desired retention levels would be piled with 

mechanized equipment such as an excavator or tractor with a mounted brush rake or grapple designed 

to minimize soil disturbance.

• Piling will focus on the high fuel load/mortality pockets and machine piling passes will be limited to 

the extent needed to reduce fuel loads to the levels described in the resource protection measures.

• Treated areas would not be rigorously cleaned of slash material, and duff materials would be largely

left in place for soil cover and erosion protection consistent with Forest Soil Quality Standards (Forest 

Plan p. Appdx. O), RPMs and BMPs.

• Piles would be burned when there is low fire danger and per the project burn plan, which is designed 

in compliance with the RPMs.

 22 The terms “underburning” and “broadcast burning” may be used interchangeably in this document and the project 

record in general. 

23 While 2 to 3 underburn entries are anticipated to fully restore the natural fire regime, the acreages in the Alternative 

summaries reflect the total acres to be underburned and are not multiplied for possible repeat entries.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 53

Fuels Modifications for Site-Specific Conditions

Extensive Mortality Area (EMA)

An approximately 79-acre area of contiguous pine mortality within five units where hazardous conditions 

from the numerous snags present a safety concern to project implementers, the general public and the project 

area. To reduce the hazard, the Extensive Mortality Area would be burned (see discussion of underburning 

above) to reduce heavy fuels, most likely utilizing aerial ignition techniques since it is unsafe to put 

firefighters on the ground or conduct other machine-based fuels reduction within this area. It is anticipated 

burning the EMA would achieve a 70-80% reduction in hazard trees with an expected 20% low intensity, 50% 

moderate intensity, and 30% high intensity burn. The Extensive Mortality Area fuels subunit overlays the 

underlying thinning units, however, no thinning will take place within it.

Extensive Mortality Area Adaptive Management - If conditions at the time of treatment are unsafe for 

thinning operations in all or portions of the remainder (outside of the Extensive Mortality Area) of the five

units, a combination of felling and machine piling as feasible to provide operational safety, and burning would 

be employed as an adaptive management strategy. The Extensive Mortality Area is not listed separately in 

Table Appendix B-2 or Table Appendix B-3 but enhances the treatments already described for the underlying 

units.

Fuels Connected Actions

The following connected actions would be necessary to implement the fuels treatments described above. 

Hazard reduction in heavy mortality areas along some roads and property lines, including some areas where 

fuels actions takes place, is connected to the fuels actions, as well as the vegetation actions, and is described 

separately on page 56.

Fireline Construction

Control lines to prevent prescribed fire from entering private lands or to manage prescribed fire within the 

project area would be constructed by hand crews or small to medium crawler tractors where existing barriers 

are not available. Rehabilitation of control lines post-burning includes dragging the bermed material, brush, 

and small trees back over the line. See page B-35 for more detail.

Meadow Restoration

Meadow restoration includes a combined suite of actions of meadow enhancement treatment, aspen release 

and aspen restoration adaptive management, underburning in the meadow, hydrologic function restoration at 

Elk Flat, and meadow restoration connected actions.

Meadow Enhancement

Thinning for meadow enhancement within and surrounding Elk Flat is different from thinning a forested stand 

in that there is no target density level such as a desired basal area or spacing. Rather than manage for a 

forested stand, the intent is to create conditions more reflective of those found historically; namely few 

scattered pine within an otherwise open meadow. A tree’s size, age and position – both within the meadow 

and in relation to adjacent trees, are considerations when selecting trees for retention or removal.

Predominant trees would be retained. All other trees that have grown into and along the meadow edges would 

be removed. A basal area of approximately 60 square feet per acre of the largest diameter trees would be 

retained where the meadow transitions into natural stands and young plantation stands along the edge. This 

thinning prescription would create a ‘feathered’ effect of few trees within the meadow, transitioning to an 

open forest stand along the meadow’s edge. Within 100 feet of the meadow’s edge, young plantations would 

be thinned to a lower basal area/trees per acre to achieve the ‘feathered’ effect (see description in Young 

Plantation thinning in Appendix A starting on page B-28).
Elk Flat LSR Enhancement Project

54 Shasta-Trinity National Forest

Aspen Release and Aspen Restoration Adaptive Management in Elk Flat

Aspen encountered in Elk Flat meadow would be released by conifer removal consistent with the meadow 

enhancement prescription for conifer removal.

Broadcast Burning in the Meadow

Prescribed burning would be utilized every five to ten years after initial treatments to maintain the meadow as 

described for underburning (below), mimicking the effects of a historic natural fire regime and serving as an 

important tool in restoring and enhancing ecological function and processes by promoting soil nutrients, grass 

and forb regeneration. While prescribed fire would be employed across Elk Flat, it is recognized that 

vegetation varies; some areas of the meadow will carry fire readily while other areas may not Prescribed 

burning is described below in “Underburn”.

Hydrologic Function Restoration at Elk Flat

Within Elk Flat meadow, hydrologic function would be restored through the decommissioning of 

unauthorized routes as described in Hydrologic Function actions below, to restore overland sheetflow and 

infiltration in the floodplains to restore groundwater storage to a more natural condition.

Meadow Restoration Connected Actions

Meadow restoration treatments would include the connected actions for road maintenance and borate 

fungicide described under Forest Restoration above.

Hydrologic Function and Soils Restoration

Stream Flow, Water Table Elevation, and Riparian Vegetation Restoration

The following hydrologic and Riparian Restoration actions meet the Purpose and Need of improving 

streamflow, water table elevation and vegetation conditions within Riparian Reserves associated with Ash and

Swamp Creeks and their tributaries (also see p. 33 and Appendix A starting on p. B-39):

• Recontouring - The Ash and Swamp Creek floodplains would be recontoured to restore portions of 

reaches previously disturbed in past activities. Heavy equipment would recontour existing landings, 

skid trails and unauthorized routes. Low profile/embedded woody debris structure would be added by 

burying woody debris on the floodplain.

• Decommissioning - Unauthorized routes and old landings that interact with creeks and divert or 

capture runoff or prevent floodplain function would be decommissioned to a natural grade to help 

promote infiltration, natural water table elevation and floodplain function.

• Riparian Revegetation - Restored, recontoured and thinned areas within Riparian Reserves would be 

planted with hardwood, riparian, or mesic species native to the area and most appropriate for the 

location to help restore riparian vegetation and strengthen streambanks.

• Thinning treatments within Riparian Reserves would retain current stand densities for terrestrial 

shading and thermal regulation in some locations and in other locations, reduce densities and shade to 

promote development of riparian understory, stream bank stabilizing vegetation such as willow and 

near-stream shading.

Windrow Respreading

Windrows would be respread using equipment such as a small tractor with a blade to redistribute top soil 

more evenly (P&N #2 starting p. 9).
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 55

Transportation System Management and Road and Landing Actions

The following road actions respond to the Purpose and Need for action directly or are connected actions 

necessary to implement treatments to meet the Purpose and Need for Action, or both. Existing FTS roads, 

existing routes and temporary roads would provide access for harvest operations. Most roads are suitable for 

hauling forest products with pre-haul maintenance. Appendix A provides road-specific information in Table 

Appendix B-5 on page B-41.

Addition to the FTS

A 0.10 mile segment of unauthorized road U41N10A in the Matrix land allocation would be added to the 

system as a maintenance level 2 road, and maintained under action alternatives. The road will remain open 

after completion of the project. As noted in the Purpose and Need (See #6 on page 37), road U41N10A is 

needed for current and long-term management objectives as recommended by the Travel Analysis Process 

completed for the Elk Project (Bonivert, 2015a p. Appdx. X).

Transportation Connected Actions

Maintenance

Roads used in implementation of the project would be actively maintained to standard during use. 

Maintenance activities can include grading, resurfacing, culvert cleaning, hazard tree removal, snow plowing, 

and slide removal (36 CFR 220.6(d)(4) as well as dust abatement as needed. Roads requiring additional 

actions such as reconstruction or closure would also be maintained. Also see Appendix A starting page B-43.

Reconstruction

One road, the 41N01YB, totaling approximately 0.27 miles, is proposed for reconstruction entailing clearing 

and brushing, and surface reconditioning. The work required to restore 41N01YB will focus on restoring the 

road to usable condition. No surface upgrades are proposed. Also see Appendix A page B-44.

Closure

Maintenance level 1 (see footnote 106 on page 43 for explanation of Maintenance Levels) roads would be 

temporarily opened for access to treatment units, then at completion of the project, reclosed to vehicular 

traffic by blocking the entrance utilizing installation of an earthen berm, a guardrail barricade or natural 

obstacles with consideration for cost, effectiveness and resource protection. A detailed description of closure 

is provided in Appendix A on page B-47.

Temporary Roads and Landings

Temporary roads in thinning and meadow enhancement units across the project area would be used or 

constructed to provide access for harvest operations. To avoid new disturbance and as feasible, unauthorized

routes would serve as temporary roads rather than constructing new temporary roads when feasible. Sections 

of unauthorized routes used as haul routes would be improved for equipment access and hauling as needed. 

Once project operations are completed temporary roads would be decommissioned. Given the generally flat 

terrain, temporary roads would require minimal construction measures. The need for more extensive work 

such as cuts and fills or drainage structures is very limited. Table Appendix B-5 lists unauthorized routes that 

would be available for use as a temporary road and then decommissioned at the end of the project.

Landings averaging approximately 0.75 acres would be used or constructed to facilitate the transfer of 

materials from treatment units to trucks for hauling. All new landing locations would be preapproved.

Existing landings would be utilized when operationally feasible and if in compliance with RPMs; legacy 

landings in Riparian Reserves will not be utilized and all new landings will be constructed outside of Riparian 
Elk Flat LSR Enhancement Project

56 Shasta-Trinity National Forest

Reserves. Landings and skid trails would be decommissioned when no longer needed for the project (see 

Decommissioning below).

Also see RPMs 13 on page 84, 14 on page 84, 15 on page 84, 45a on page 90, and more detail in Appendix A 

page B-44.

Decommissioning

Existing unauthorized routes including those unauthorized routes used as temporary roads, new temporary 

roads, landings and main skid trails would be decommissioned at the completion of the project.24

Decommissioning typically involves physically blocking the entrance at a minimum to allow natural 

revegetation, and may also include ripping to promote natural revegetation and restoration, and water bars to 

prevent erosion when necessary, including the necessary cleanup work. Decommissioning of existing 

unauthorized routes helps implement the Purpose and Need for Action (See #6 on page 37), while the 

construction, use and decommissioning of new temporary roads is necessary to implement the Proposed 

vegetation treatment actions and protect the resources. The extent of decommissioning activities would be 

contingent on the extent of construction disturbance. Typically, the entrance would be blocked, drainage 

patterns restored and the temporary road surface disturbed to break down compaction and allow the 

reestablishment of vegetation. Decommissioned roads and routes do not receive maintenance. A detailed 

description of decommissioning is provided in Appendix A on page B-47.

Other Connected Actions

Hazard Reduction

Hazard Reduction is a connected action to the vegetation and fuels treatments described above to increase 

safety during implementation in areas of particularly high mortality that are near roads, or near property lines 

that also have fire line construction. Hazard Reduction is shown on the alternative fuels maps. All snags

would be felled as a connected action for project implementation within 150 feet of some system roads and 

300 feet of private property in units 158, 159, 162, 175, 176, 179, 204 and 206 to improve safety during 

implementation. Felled snags would be removed as sawlogs or biomass material if feasible, or through 

machine piling and burning. Hazard Reduction treatment is not listed separately in Table Appendix B-2 or 

Table Appendix B-3 but enhances the treatments already described. Elsewhere on the project, where snags 

pose a hazard to the public or operations, snags would be felled. Coarse woody debris including any felled 

snags would be retained at levels described in RPM 40, p. 89.

Implementation and Compliance Requirements

Implementation would require numerous routine connected actions such as a burn permit and smoke 

management plan in compliance with Siskiyou County regulations, a California Water Quality Control Board 

Conditional Waiver of Waste Discharge (CVRWQCB, 2010), (All timber sales that may have the potential to 

impact water quality are evaluated, identified and monitored and reported by the forest service and the state 

under a Conditional Waiver of Waste Discharge Requirements to assure BMPs are applied to prevent impacts 

to water quality (CVRWQCB, 2010).) routine contract administration for elements of the proposed action 

completed through various contractual mechanisms and hauling of harvest material to mills and cogeneration 

facilities. All connected actions not specifically detailed in the discussions above are standard operating 

procedures.

 24 The Forest Plan directs the dedication of no more than 20 percent of the land harvested by uneven-aged systems be 

dedicated to non-productive purposes such as roads, trails, landings, etc. Appendix O defines detrimental soil disturbance 

for compaction as porosity less than 90 percent of the total porosity found under undisturbed or natural conditions.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 57

Alternatives Considered in Detail including Resource Protection 

Measures and Monitoring

The proposed action as scoped in February 2013 and described in the Notice of Intent (NOI) (USDA-FS, 

2013) was incrementally modified by corrections incorporated to address rapidly changing conditions in the 

project area, ongoing tribal and federal agency consultation, typographical errors in the scoping materials, and 

refinement or clarification of the descriptions of actions. This modified Proposed Action is considered in 

detail as Alternative 1. Additionally, the No Action Alternative (Alternative 4), and two action alternatives 

(Alternative 2 – No New Temporary Road Construction, and Alternative 3 – No Treatments in Natural Stands 

in Northern Spotted Owl Critical Habitat) were developed in response to the key issues raised during scoping 

and are considered in detail.

Alternative 1 - The Modified Proposed Action

The Modified Proposed Action (Alternative 1) and the Alternatives to it are described here and summarized 

starting on page 76.

Alternative 1 is the Modified Proposed Action and the Agency Preferred Alternative. The proposed treatments 

would be implemented through a combination of commercial and non-commercial thinning using mechanical 

and hand methods. In addition to thinning activities, existing natural and activity generated fuels within the 

entire project area would be treated with a combination of machine piling and burning given the size and 

amount of existing and expected future down fuel, hand piling in sensitive areas such as EEZs or historic 

properties as needed, (see RPMs 1c and 11) lop and scatter, or underburning (or any combination thereof) to 

meet the desired condition for fuel load objectives and begin the process for returning natural fire to the 

landscape.

Forest Restoration and Meadow Enhancement Treatments

Table 7 on page 59 summarizes the Alternative 1 Forest Restoration treatments listed below. Also see the 

description of forest and meadow restoration treatments starting on page 47. The restoration of the natural fire 

regime and hydrologic functions for Meadow Restoration are included in those section below. This section 

includes the Meadow Enhancement portion of Meadow Restoration.

Thinning

Alternative 1 thins approximately 2,190 acres of units in which approximately 1,859 acres are treated 

(thinning treatments occur within the unit boundaries but not in the unthinned patches that are also within the 

unit boundaries, therefore thinning treatment acres or harvest acres are less than unit acres) as follows:

• Natural Stand Thinning – Alternative 1 applies natural stand thinning to 1,526 unit acres in which 

1,273 acres outside of the UTPs will be treated. See the description of Natural Stand Thinning starting 

on pages 50 and B-31.

• Plantation Thinning – Alternative 1 applies plantation thinning to 664 unit acres in which 584 acres 

outside of UTPs will be treated. Within these acres, 344 unit acres (303 treatment acres) apply to 

older plantations, and 320 unit aces (281 treatment acres) applies to younger plantations.

Table 7 on page 59 further breaks down the natural and plantation thinning by prescription elements. Table 

Appendix B-2 (starting p. B-6) lists each unit including all thinning units by alternative. The site-specific 

prescription elements are also listed, and implemented as the site-specific conditions within the units are 

encountered. 

Meadow Enhancement
Elk Flat LSR Enhancement Project

58 Shasta-Trinity National Forest

Alternative 1 treats the 518-acre unit 402 with the meadow enhancement prescription described on page 53. 

Within the 518 acre unit, 379 acres include harvest activities. Additionally, 56 acres of young plantation 

thinning at the edge of the meadow also include an altered thinning prescription within 100 feet of the 

meadow as described on page B-28, to feather the meadow enhancement into the plantation.

Unit 401, treated under the Pilgrim project in 201225 will also receive underburning under the Elk project to 

further enhance meadow characteristics and is included in the Project area. Unit 401 underburning acres are 

included in the underburning-only units described below.

Adaptive Management Strategies

• Biomass Adaptive Management for Changed Market Conditions - Biomass (4 to 9.9-inch DBH) 

material will be mechanically thinned on a prescribed spacing, or to a prescribed basal area, in those 

units that have a biomass thinning component (as listed in Table Appendix B-2). Depending on the 

market conditions at the time of implementation, material that is 4 to 6.9 inches DBH may not be 

mechanically thinned and removed, but would be treated on site with a combination of mechanical 

treatments, hand thinning or thinning through the use of prescribed fire. Modifications to the limits of 

acceptable mortality for this size class during underburning under adaptive management are defined 

in the RPMs (see RPM 24, Table 28, p.86).

• Salvage Adaptive Management - Alternative 1 applies salvage adaptive management to 811 acres in 

12 ponderosa pine-dominated units as listed in Table Appendix B-2. Additional dead and dying trees 

may be salvaged during harvest operations as approved by the Forest Service if mortality expands 

between the unit layout and when a unit is closed during operations.

• Aspen Restoration Adaptive Management - As described on pages 51, and B-34, Alternative 1 

releases aspen whenever it is encountered in a thinning or meadow enhancement unit through 

application of the marking guidelines. Thinning units 157, 175 and 402 are known to contain aspen. 

Under adaptive management, if aspen monitoring fails to show a positive establishment within three 

years then underburning or soil disturbance would be utilized to stimulate suckering.

Table 7 Summarizes Alternative 1 vegetation restoration treatments. Part I of the table lists the unit acres, 

unthinned patch acres (within the units) and the remaining acres, which are thinned or receive meadow 

enhancement conifer removal. Those acres within units receiving thinning or meadow enhancement are listed 

as “harvest acres”. Thinning is divided into natural stands and plantations. Within each of these categories, the 

table further groups treatments by prescription elements. Part II of the table summarized subtreatment acres 

applied under natural stand thinning, plantation thinning, and meadow enhancement. These subtreatment 

acres are the actual estimated acres of each subtreatment, not the unit or larger harvest acres unless noted.

 25 The Pilgrim Vegetation Management Project (FSEIS ROD January 10, 2011) dry meadow restoration described in the 

Pilgrim FSEIS (January 2010) has not been fully completed. Thinning was completed in 2012 however the prescribed 

basal area of 80 ft2/ac was not met over the entire unit and some, primarily intermediate trees contribute to a higher basal 

area than desired. Removal of all trees under 14” DBH was also not completed; instead they were thinned to a set 

spacing. Additional thinning in unit 401 to fully implement the Pilgrim prescription will occur under the Pilgrim Record of 

Decision. The Pilgrim Project prescribed 25 acres of underburning in unit 401 which has not been completed. The Elk 

project underburns the full 147-acre unit boundary to more fully meet meadow enhancement desired conditions, and the 

the underburning is analyzed in the Elk Project.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 59

Table 7. Alternative 1 Summary of Forest Restoration Treatments Including Meadow Enhancement

Part I

Treatment Prescriptions

Unit Acres* Unthinned Patch

Acres*

Harvest Acres

Thinning Units

Natural Stand Thinning 1,526 181 1,273

Thinning Only 333 38 295

With Group Selection, Plant Groups 39 5 34

With Interplant 468 56 341

With Radial Thin 224 27 197

With Radial Thin, Group Selection, Plant Groups 108 13 95

With Radial Thin, Interplant 354 42 312

Plantation Thinning 664 80 584

Young Plantations (10-39 Years) 320 39 281

Thinning Only 160 19 141

With Meadow Enhancement 63 8 56

With Interplant 96 12 84

Older Plantations (40-50 Years) 344 42 303

With Group Selection, Plant Groups 59 7 52

With Radial Thin 14 2 13

With Radial Thin, Group Selection, Plant Groups 272 33 239

Total Thinning 2,190 Unit Acres

261 Acres

Unthinned 

Patches in Units

1,858 Acres

Thinning

Meadow Enhancement Unit

Meadow Enhancement 518 62 379

Total Vegetation Treatment 2,708 Unit Acres

323 Acres

Unthinned 

Patches in Units

2,237 Acres
Elk Flat LSR Enhancement Project

60 Shasta-Trinity National Forest

Table 7 Part II – Vegetation Subtreatments - acres of subtreatments within units27

Subtreatment

Subtreatments overlap those listed above and do not 

represent additional acres.26 The treatments above 

indicate when the subtreatment is applied.

27 Acres 

represent the estimated acres within units unless 

noted.

Natural Stand 

Thinning

Prescription

Plantation 

Thinning

Prescription

Meadow 

Enhancement

Prescription

Total

Acres

Group Selection 16 58 75

Radial Thinning 139 58 197

Interplanting

(Interplanting within other primary treatments including 

reforestation of the extensive mortality area. 

“Interplanting-only” as the primary treatment is included 

with reforestation treatments in Table 8 below) 

195 33 228

Biomass Thinning (harvest acres) 933 576 379 1,888

Aspen Release

(and adaptive management restoration if needed)28 18.1 6 24

Oak Release29 30 30

Adaptive Management Salvage (if needed – harvest 

acres of units) 528 283 811

Borax Stump Treatment 

(harvest acres where stumps are over 14” diameter) 1,273 388 379 2,040

*Minor discrepancies in subtotals and totals may exist due to rounding of data

Reforestation actions are described starting on pages 50 and B-33. Table Appendix B-2 provides individual 

unit reforestation actions. Table 8 below provides a summary of reforestation actions for Alternative 1.

Reforestation acres are not spatially new areas, but reflect additional actions on acreages listed in the primary 

vegetation or fuels treatments. The second column displays the actual proposed site preparation, planting, and 

release acres within larger units (entire units are not proposed for reforestation). Site preparation and release 

acres indicate the areas where the need for reforestation actions would be evaluated on a case by case basis. 

Some machine piled units are not expected to need additional site preparation treatment and are not included 

in the table for site preparation.

 26 Unit 152-1 is the exception because the primary prescription puts it in the “Natural Stand Thinning with Radial thin, 

Group Selection, and Plant Groups” treatment but it also includes interplanting.

27 Acreage estimates for the subtreatments are the total accumulated when applied in smaller areas where the sitespecific condition that prompts the treatment is encountered. The exception to this is harvest acres were used to estimate 

the biomass thinning and borax stump treatments.

28 This figure includes aspen release in association with the Meadow Enhancement Prescription.

29 Since oaks are widely scattered across a number of natural stand thinning and plantation thinning units, oak release 

treatment was not broken down by natural stand or plantation. See Appendix A page A-26 for a list of units known to 

contain oak.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 61

Table 8. Alternative 1 Summary of Reforestation Actions

Reforestation Action

Alternative 1

Estimated Reforestation 

Activity Acres within Units

Site Preparation for Planting (Mechanical Scalp) 269

Hand Planting 313

Interplanting without thinning 10

Interplanting in thinning units in smaller mortality areas and gaps over 1 acres (as 

needed) 168

Planting group selections in thinning units 75

Reforestation of extensive mortality area 6030

Post Planting Hand Release for Growth (1 entry between years 1-5) 313

Fire Restoration and Fuels Reduction Treatments

Fuels restoration treatments and their connected actions are generally described in the Description of Actions

section (starting p. 51).

• Underburning - Underburning as described (p. 52) would be completed on 3,482 acres unless 

restricted by RPMs. Burning will be completed when weather conditions allow for fire managers to 

meet the desired objectives. It is possible that it will take several years to accomplish burning across 

the project area. Table Appendix B-2 (starting p. B-6) lists units where underburning-only would be 

implemented without prior thinning. The total acres reflect underburning area, without multiplication 

for the potential 2 to 3 underburns every 5 to 10 years.

• Machine Piling - Machine pile and pile burn treatments would occur on up to 1,461 acres as shown in 

the Alternative map for fuels and described on page 52. Table Appendix B-3 list units where machine 

piling and pile burn treatments may occur to address potentially high fuel loading from ongoing 

mortality. The table lists the maximum potential piling acres (unit acres minus the unthinned patches) 

and the percentage and acres of each unit estimated to need piling based on field review by the fuels 

specialist. Monitoring would determine the actual need and extent of piling at the time of 

implementation.

• Extensive Mortality Area Fuels Subunit - The approximately 79-acre area of contiguous pine 

mortality within units 112, 158, 175, 204 and 206 as shown in the alternative map for fuels would be 

treated as described (see p. 53).

Table 9 below provides the summary of fuels treatments. Appendix A provides additional detail (p. B-35). The 

alternative maps show the fuels prescriptions.

 30 The extensive mortality area also covers smaller portions of several adjoining units. The planting acres in the adjoining 

units is included within the “interplanting” row of the table.
Elk Flat LSR Enhancement Project

62 Shasta-Trinity National Forest

Table 9. Alternative 1 Summary of Fuels Reduction Treatments

Fuels Reduction Treatment Alternative 1 Acres

Underburning31

(see description starting on pp. 52, B-35)

Underburn After Thinning and Meadow Enhancement Treatments 2,708

Underburn Prior to Interplanting in Plantations

(No Timber Harvest Proposed) 28

Underburn Only

(No Timber Harvest or Planting Proposed) 746

Total Underburning 3,482

Machine Pile and Pile Burn

(see description pp. 52, B-36 and Table Appendix B-3)

Maximum Estimated

1,461 944

Fuels Subtreatments

The following treatments overlap other fuels treatments and are not additive

Extensive Mortality Area

(see description starting on pp. 53, B-38) 79

Fuels Connected Actions (miles)

Miles of Machine Fireline Construction

(see descripton startong on p. B-35) 9.3 miles

Road and Landing Actions

Proposed road actions are a combination of those needed to meet the Purpose and Need for Action and those 

needed to implement other actions (connected actions). Addition of approximately 1/10th of a mile of 

currently existing unauthorized route to the FTS and decommissioning of approximately 6.4 miles of existing 

unauthorized routes meets the Purpose and Need for Action. Some road actions for decommissioning 

unauthorized routes also meet Purpose and Need related to hydrology as described below. The remainder of 

the actions, maintenance, opening and closure, reconstruction and temporary road use and construction are 

connected actions. Landing construction and use is also a connected action to facilitate transportation of 

harvested material. Alternative 1 requires approximately 78 landings to implement the vegetation treatments.

Of these, approximately 38 already exist and if operationally feasible and approved for use, would be utilized 

rather than constructing new landings. Existing landings were identified through a combination of aerial 

photography interpretation, field notes and site visitation. Actual use or construction of landings would be 

approved on a site-specific basis by the sale administrator specific basis as requested by the timber operator.

Table 10 provides the road and landing summary for Alternative 1. General descriptions of these actions are 

provided above in the Description of Actions starting on page 47. Detailed descriptions are provided in 

Appendix A including road-specific actions (starting page B-39 and Table Appendix B-5 and Table Appendix 

B-6). Refer to the Alternative 1 map for a graphic display, though this map does not display temporary roads 

as placement of these roads is subject to agreement with the implementation purchaser in accordance with 

resource protection measures.

 31 Within the constraints and guidelines detailed by the resource protection measures. There are unthinned patches that 

may not be burned or would have no direct ignition, and other sites that will have fire excluded within this total acreage.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 63

Table 10. Alternative 1 Summary of Road and Landing Actions

Road or Landing Action

Modified Proposed Action

Alternative 1 

Miles32

Forest Transportation System Actions

Maintenance Only

(Roads without other actions. All road actions listed elsewhere also 

include maintenance. See description pp. 55, B-43)

14.9

LSR 12.9

Matrix 2.0

Open, Use and Maintain for Project, Close in LSR

(See description pp. 55, B-47) 2.6

Reconstruct and Close in LSR

(See description pp. 55, B-47) 0.3

Add and Maintain in Matrix

(See description pp. 55, B-43) 0.1

Total FTS Road Action Miles 17.9

Other Transportation Actions

Unauthorized Routes, Temporary Roads and Decommissioning

Decommission Unauthorized Route in LSR

(See description pp. 56, B-47) 0.7

Use Unauthorized Route as a Temporary Road then 

Decommission

(See description pp. 55, B-44)

5.7

LSR 3.8

Matrix 1.9

New Temporary Road Construction then Decommission 2.9

Total Decommissioning - Unauthorized Routes and Temporary 

Road Use, Construction and Decommissioning 9.3

Landings

Estimated Numbers 

of Landings

Estimated Acres of 

Landings

Subtotal Estimated Existing Landings 38 28

LSR 31 23

Matrix 7 5

Subtotal Estimated New Landings (LSR) 40 30

Estimated Total Landings Needed

(See description pp. 55, B-44) 78 58

Hydrologic Function and Soils Actions

Hydrologic Restoration

Alternative 1 restores hydrologic function through the hydrologic actions summarized below. Where noted,

the actions are not additional but provide further information as listed in other tables.

 32 Rounding may cause slight discrepancies in totals.
Elk Flat LSR Enhancement Project

64 Shasta-Trinity National Forest

Table 11. Alternative 1 Summary of Hydrologic Restoration Actions

Treatment RR Acres RR Length (ft)

Stream channel and floodplain restoration: Unauthorized Route 

Decommission with Recontour Stream and Floodplain 8.1 1,700

Stream Channel and Floodplain Restoration: Recontour Stream and 

Floodplain, Add Low Profile/Embedded Woody Debris Structure 7.2 1,569

Riparian Reserve Thinning (previously included in thinning acres) 211 N/A

Riparian Reserve Revegetation 94.9 16,127

Soil Restoration

• Alternative 1 respreads windrows in older plantation units 6 and 14 for a total of 167 acres Also see 

page 64.

Other Connected Actions

Hazard reduction would be implemented on 87 acres in units 158, 159, 162, 175, 176, 179, and 206 as 

described on page 56 to improve safety during implementation. Other hazard trees or snags throughout the 

project area may also be felled as needed for safety.

Alternative 2 - No New Temporary Road Construction Other than Those 

Required for Landing Use/Access

Alternative 2 is responsive to the issue regarding temporary road construction impacts on forest health and 

connectivity within the LSR. It is similar to Alternative 1 with the exception that no temporary roads would 

be constructed to complete project activities other than to access landings (typically a landing “driveway” is 

about 200 feet). Project activities would be completed utilizing the existing FTS roads and existing 

unauthorized routes in the project area. Alternative 1 identified the need for approximately 2.9 miles of new 

temporary road to complete thinning activities and no new permanent road construction was proposed. This 

alternative reduces the ability to mechanically treat approximately 103 acres with a corresponding decrease in 

needed landings. All other project design criteria, thinning and fuels treatments and road actions are the same 

as Alternative 1. While the total acreage between Alternatives 1 and 2 treated is the same, the difference is 

between the treatment types. Despite no new construction of temporary roads under Alternative 2 other than 

needed to access landings, the total project area would still be underburned and in accordance with RPMs.

Maintenance and other actions relating to the FTS system would be the same under Alternative 2 as 

Alternative 1, however the maintenance would be less intensive due to reduced hauling.

Forest and Meadow Restoration Treatments

Thinning

Alternative 2 thins approximately 2,124 acres of units in which approximately 1,800 acres are treated outside 

of UTPs as follows:

• Natural Stand Thinning – Alternative 2 applies natural stand thinning to 1,476 (50 fewer than Alter 

native 1) unit acres in which 1,230 acres outside of the UTPs (43 fewer than Alternative 1) will be 

treated. See the description of Natural Stand Thinning starting on pages 50 and B-31.

• Plantation Thinning – Alternative 2 applies plantation thinning to 648 unit acres (16 fewer than 

Alternative 1) in which 570 acres outside of UTPs would be treated. Within the total thinning unit

acres, 328 acres (16 fewer than Alternative 1) with 289 treatment acres (14 fewer than Alternative 1) 

apply to older plantations. Young plantation thinning is the same as Alternative 1.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 65

Table 12 further breaks down the natural and plantation thinning by prescription elements.

Meadow Enhancement

Meadow Enhancement - Alternative 2 treats approximately 25 fewer acres than Alternative 1.

Adaptive Management Strategies

Alternative 2 includes the same adaptive management strategies as Alternative 1. However, individual 

adaptive management actions would be reduced if they were to occur in the units where thinning was 

eliminated.

Table 12 summarizes Alternative 2 vegetation restoration treatments. It displays information similarly to 

Alternative 1.33 The table also shows the change in Alternative 2 for each row when compared to Alternative 

1.

Table 12. Alternative 2 Summary of Vegetation Restoration Treatments and Changes from Alternative 1

Part I

Treatment Prescription

Unit Acres* Unthinned Patch Acres* Timber Harvest Acres*

Alt. 2 Change 

from Alt. 1 Alt. 2 Change 

from Alt. 1 Alt. 2 Change 

from Alt. 1

Thinning Units

Natural Stand Thinning 1,476 -50 175 -6 1,230 -43

Thinning Only 300 -33 34 -4 266 -29

With Group Selection, Plant 

Groups 39 no change 5 no change 34 no change

With Interplant 461 -7 55 -1 335 -6

With Radial Thin 224 no change 27 no change 197 no change

With Radial Thin, Group Selection, 

Plant Groups 99 -9 12 -1 87 -8

With Radial Thin, Interplant 353 -1 42 no change 311 -1

Plantation Thinning 648 -16 78 -2 570 -14

Young Plantations

(10-39 Years) 320 no 

change 39 no change 281 no change

Thinning Only 160 no change 19 no change 141 no change

With Meadow Enhancement 63 no change 8 no change 56 no change

With Interplant 96 no change 12 no change 84 no change

Older Plantations

(40-50 Years) 328 -16 39 -2 289 -14

With Group Selection, Plant 

Groups 59 no change 7 no change 52 no change

With Radial Thin 14 no change 1 no change 13 no change

 33 Part I of the table lists the unit acres, unthinned patch acres (within the units) and the remaining acres, which are 

thinned or receive meadow enhancement conifer removal. Those acres within units receiving thinning or meadow 

enhancement are listed as “harvest acres”. Thinning is divided into natural stands and plantations. Within each of these 

categories, the table further groups treatments by prescription elements. Part II of the table summarized subtreatment 

acres applied under natural stand thinning, plantation thinning, and meadow enhancement. These subtreatment acres are 

the actual estimated acres of each subtreatment, not the unit or larger harvest acres unless noted.
Elk Flat LSR Enhancement Project

66 Shasta-Trinity National Forest

Part I

Treatment Prescription

Unit Acres* Unthinned Patch Acres* Timber Harvest Acres*

Alt. 2 Change 

from Alt. 1 Alt. 2 Change 

from Alt. 1 Alt. 2 Change 

from Alt. 1

With Radial Thin, Group Selection, 

Plant Groups 255 -16 31 -2 225 -14

Total Thinning 2,124 Unit

Acres -66

253 Acres 

of UTPs in 

Units

-8

1,800

Acres of 

Thinning

-58

Meadow Enhancement Unit

Meadow Enhancement 494 -24 59 -3 354 -25

Total Vegetation Treatment 2,618 Unit 

Acres -90

312 Acres 

of UTPs in 

Units

-11 2,154

Acres -83

PART II - Vegetation Subtreatments - acres of actual subtreatments*

Subtreatment

Subtreatments overlap 

those listed above and do 

not represent additional 

acres.

34 The treatments 

above indicate when the 

subtreatment is applied.35

Acres represent the 

estimated acres within units 

unless noted.

Alt. 2

Natural 

Stand 

Thinning

Rx

Change 

from

Alt. 1

Alt. 2

Plantation 

Thinning

Rx

Change 

from

Alt. 1

Alt. 2

Meadow 

Enhancement

Rx

Change 

from

Alt. 1

Alt. 2

Total

Acres

Change 

from

Alt. 1

Group Selection 16 no 

change 55 -4 no 

change 71 -4

Radial Thinning 137 -2 55 -3 no 

change 191 -5

Interplanting

(Interplanting within other 

primary treatments

including reforestation of 

the extensive mortality 

area. “Interplantingonly” is 

included with reforestation 

treatments in table below) 

195 no 

change 33 no 

change

no

change 228 no change

Biomass Thinning

(harvest acres) 898 -35 562 -14 354 -25 1,814 -74

Aspen Release36

(and adaptive management 

restoration if needed) 

18.1 no 

change

no 

change 6.0 no 

change 24.1

no 

chang

e

 34 Unit 152-1 is the exception because the primary prescription puts it in the “Natural Stand Thinning with Radial thin, 

Group Selection, and Plant Groups” treatment but it also includes interplanting.

35 Acreage estimates for the subtreatments are the total accumulated when applied in smaller areas where the sitespecific condition that prompts the treatment is encountered. The exception to this is harvest acres were used to estimate 

the biomass thinning and borax stump treatments.

36 These acres include aspen within the meadow enhancement prescription and all thinning prescriptions.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 67

PART II - Vegetation Subtreatments - acres of actual subtreatments*

Subtreatment

Subtreatments overlap 

those listed above and do 

not represent additional 

acres.

34 The treatments 

above indicate when the 

subtreatment is applied.35

Acres represent the 

estimated acres within units 

unless noted.

Alt. 2

Natural 

Stand 

Thinning

Rx

Change 

from

Alt. 1

Alt. 2

Plantation 

Thinning

Rx

Change 

from

Alt. 1

Alt. 2

Meadow 

Enhancement

Rx

Change 

from

Alt. 1

Alt. 2

Total

Acres

Change 

from

Alt. 1

Oak Release37 30, no change Oak 

Release

30, no 

change

Adaptive Management 

Salvage

(if needed)

522 -6 283 no 

change

no 

change 805 -6

Borax Stump Treatment 

(in units with stumps over 

14” diameter)

1,230 -43 374 -14 354 -25 1,958 -82

*Minor discrepancies in subtotals and totals may exist due to rounding of data

Reforestation actions under Alternative 2 differ from Alternative 1 by four fewer acres of planting group 

selections. Table 13 provides a summary of reforestation actions for Alternative 2 and how each action differs 

in acres of treatment from Alternative 1.

Table 13. Alternative 2 Summary of Reforestation Actions

Reforestation Action

Alternative 2

Estimated 

Reforestation Activity 

Acres within Units

Change from 

Alternative 1

Site Preparation for Planting (Mechanical Scalp) 266 -3

Hand Planting 309 -4

Interplanting without thinning 10

Interplanting in thinning units in smaller mortality areas and gaps no Change

over 1 acres (as needed) 168

Planting group selections in thinning units 71 -4

Reforestation of extensive mortality area 6038 no change

Post Planting Hand Release for Growth (1 entry between years 

1-5) 309 -4

 37 Since oaks are widely scattered across a number of natural stand thinning and plantation thinning units, oak release 

treatment was not broken down by natural stand or plantation. See Appendix A page A-26 for a list of units known to 

contain oak.

38 The extensive mortality area also covers smaller portions of several adjoining units. The planting acres in the adjoining 

units is included within the “interplanting” row of the table.
Elk Flat LSR Enhancement Project

68 Shasta-Trinity National Forest

Fire Restoration and Fuels Reduction Treatments

Alternative 2 increases the proportion of underburn-only to thinning treatments from Alternative 1 as 

described above, but otherwise underburns the same physical acres. The Extensive Mortality Area treatment 

remains the same. Machine Pile and Pile Burn treatments are reduced from Alternative 1 corresponding to the 

reduced thinning acres. Table 14 summarizes fuels restoration treatments under Alternative 2.

Table 14. Alternative 2 Summary of Fuels Reduction Treatments and Changes from Alternative 1

Fuels Reduction Treatment Alternative 2

Alt. 2 Change from the 

Modified Proposed 

Action

Underburning39

(see description starting on pp. 52, B-35)

Underburn After Thinning and Meadow Enhancement Treatments

(unit acres – includes the unthinned patches) 2,617 -91

Underburn Prior to Interplanting in Plantations

(No Timber Harvest Proposed) 28 no change

Underburn Only

(No Timber Harvest or Planting Proposed) 837 +91

Total Underburning 3,482 No change

Machine Pile and Pile Burn

(see description pp. 52, B-36 and Table Appendix B-3)

Maximum Estimated Maximum Estimated

1,402 906 -59 -38

Fuels Subtreatments

The following treatments overlap other fuels treatments and are not additive

Extensive Mortality Area

(see description starting on pp. 53, B-38) 79 no change

Fuels Connected Actions (miles)

Miles of Mechanical Fireline Construction

(see descripton startong on p. B-35) 9.3 miles no change

Road Actions

Road action activities under Alternative 2 will be the same as Alternative 1 except for the differences noted 

below:

• Road Maintenance - The miles of roads to be maintained would remain the same as Alternative 1, but 

the frequency and intensity of maintenance work would be reduced slightly to account for a slightly 

less volume of material to be removed.

• Temporary Roads - Only temporary roads needed to access landings will be constructed. Temporary 

roads constructed to access landings are typically 100 feet to 200 feet and allow landing operations to

take place within a safe distance from the road. Unauthorized routes will be used as temporary roads

as feasible, as they are under Alternative 1. New temporary road construction totals approximately 1.6

miles; 1.3 mile less than Alternative 1

• Landings – Alternative 2 would require an estimated 70 landings; 8 fewer than Alternative 1.

 39 Within the constraints and guidelines detailed by the resource protection measures. There are unthinned patches that 

may not be burned or would have no direct ignition, and other sites that will have fire excluded within this total acreage.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 69

Table 15 summarizes Alternative 2 road and landing actions and indicates the relative differences between 

Alternative 2 and Alternative 1, the Modified Proposed Action.

Table 15. Summary of Alternative 2 Road and Landing Actions and Changes from Alternative 1

Road and Landing Action

Alternative 2

No New Temporary 

Road Construction

Alt. 2 Change from 

the Modified 

Proposed Action

(Alternative 1)

Road Actions by Forest Plan Land Allocation Miles40 Miles

Forest Transportation System Actions

Maintenance Only

(Roads without other actions. All road actions listed elsewhere 

also include maintenance. See description pp. 55, B-43)

14.9 no change

LSR 12.9 no change

Matrix 2.0 no change

Open, Use and Maintain for Project, Close in LSR

(See description pp. 55, B-47) 2.6 no change

Reconstruct and Close in LSR

(See description pp. 55, B-47) 0.3 no change

Add and Maintain in Matrix

(See description pp. 55, B-43) 0.1 no change

Total FTS Road Action Miles 17.9 no change

Other Transportation Actions

Temporary Roads and Decommissioning

Decommission Unauthorized Route (LSR)

(See description pp. 56, B-47) 0.7 no change

Subtotal Use Unauthorized Route as a Temporary Road then 

Decommission

(See description pp. 55, B-44)

5.7

no change

LSR 3.8 no change

Matrix 1.9 no change

New Temporary Road Constructed then Decommission 1.6 -1.3

Total Decommissioning - Unauthorized Routes and 

Temporary Road Use, Construction and Decommissioning 8.0 -1.3

Landings

Est. # of 

Landings

Est. 

Acres

Est. # of 

Landings

Est. 

Acres

Subtotal Estimated Existing Landings 30 22 -8 -6

LSR 24 18 -7 -5

Matrix 6 4 -1 -1

Subtotal Estimated New Landings (LSR) 40 30

no 

cha

nge

no 

cha

nge

Estimated Total Landings Needed

(See description pp. 55, B-44) 70 52 -8 -6

 40 Rounding may cause slight discrepancies in totals
Elk Flat LSR Enhancement Project

70 Shasta-Trinity National Forest

Hydrologic Function and Soils Actions

Alternative 2 actions would eliminate 4.3 acres of stream channel and floodplain restoration (recontouring) 

because temporary roads to access the areas would not be constructed. Hand work such as revegetation in 

those areas would remain the same as Alternative 1.

Table 16. Alternative 2 Summary of Hydrologic Restoration Actions

Treatment RR Acres Change from 

Alternative 1 RR Length (ft)

Stream channel and floodplain restoration: Unauthorized Route 

Decommission with Recontour Stream and Floodplain 4.4 -3.7 1,700

Stream Channel and Floodplain Restoration: Recontour Stream 

and Floodplain, Add Low Profile/Embedded Woody Debris 

Structure

7.2 no change 1,569

Riparian Reserve Thinning (previously included in thinning 

acres) 211 No change N/A

Riparian Reserve Revegetation 94.9 no change 16,127

Other Connected Actions

Hazard reduction as described in Alternative 1 remains the same.

Alternative 3 - No Treatments of Natural Stands within Designated Critical 

Habitat for the Northern Spotted Owl

Alternative 3 is responsive to the issue regarding the assertion that treatments within designated critical 

habitat for the northern spotted owl violate the 2011 Revised Recovery Plan and the 2012 Final Critical 

Habitat Rule. Under Alternative 3, no NSO critical habitat would be treated, with the exception of the 

thinning and other mechanical treatments proposed in seven plantations (7, 12, 13, 14, 208, part of 15, and 

part of 6). No units within critical habitat would be underburned under Alternative 3. In comparison to 

Alternative 1, the plantations in critical habitat that are prescribed for machine piling and pile burning would 

require additional fireline construction to provide a barrier between the pile burning areas and the surrounding 

untreated natural stands. Alternative 3 treats 270 fewer acres with silvicultural harvest than Alternative 1. All 

other project design criteria, and thinning and fuels treatments and road actions outside of critical habitat are 

the same as under Alternative 1. Plantations in the CHU that are prescribed for machine piling and pile 

burning would require additional fireline construction over Alternative 1 to provide a barrier between the pile 

burning areas and the surrounding natural stands.

Forest and Meadow Restoration Treatments

Thinning

Alternative 3 thins approximately 1,886 acres of units in which approximately 1,590 acres are treated outside 

of UTPs as follows:

• Natural Stand Thinning – Alternative 3 applies natural stand thinning to 1,222 (304 fewer than 

Alternative 1) unit acres in which 1,006 acres outside of the UTPs (267 fewer than Alternative 1) will 

be treated. See the description of Natural Stand Thinning starting on pages 50 and B-31.

• Plantation Thinning – Alternative 3 applies the same plantation thinning as Alternative 1.

Table 17 further breaks down the natural and plantation thinning by prescription elements.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 71

Meadow Enhancement

Meadow Enhancement - Alternative 3 is the same as Alternative 1 for meadow enhancement.

Adaptive Management Strategies

Alternative 3 includes the same adaptive management strategies as Alternative 1. However, individual 

adaptive management actions would be reduced if they were to occur in the units where thinning was 

eliminated in critical habitat. Table 17 displays information similarly to Alternative 1.41 Additionally, changes 

from Alternative 1 are noted in each row.

Table 17. Alternative 3 Summary of Vegetation Restoration Treatments and Changes from Alternative 1

PART I

Treatment Prescription

Unit Acres* Unthinned Patch Acres* Timber Harvest Acres*

Alt. 3 Change 

from Alt. 1 Alt. 3 Change 

from Alt. 1 Alt. 3 Change 

from Alt. 1

Thinning Units

Natural Stand Thinning 1,222 -304 144 -37 1,006 -268

Thinning Only 182 -151 20 -18 162 -133

With Group Selection, Plant 

Groups 39 no change 5 no change 34 no change

With Interplant 436 -32 52 -4 312 -29

With Radial Thin 104 -120 12 -15 91 -106

With Radial Thin, Group Selection, 

Plant Groups 108 no change 13 no change 95 no change

With Radial Thin, Interplant 354 no change 42 no change 312 no change

Plantation Thinning 664 no change 80 no change 584 no change

Young Plantations 

(10-39 Years) 320 no change 39 no change 281 no change

Thinning Only 160 no change 19 no change 141 no change

With Meadow Enhancement 63 no change 8 no change 56 no change

With Interplant 96 no change 12 No change 84 No change

Older Plantations

(40-50 Years) 344 no 

change 41 No change 303 no change

With Group Selection, Plant 

Groups 59 no change 7 no change 52 no change

With Radial Thin 14 no change 2 no change 13 no change

With Radial Thin, Group Selection, 

Plant Groups 272 no change 33 no change 239 no change

Total Thinning 1,886 Unit 

Acres -304

224 Acres 

of UTPs in 

Units

-37

1,590

Acres of 

Thinning

-268

 41 Part I of the table lists the unit acres, unthinned patch acres (within the units) and the remaining acres, which are 

thinned or receive meadow enhancement conifer removal. Those acres within units receiving thinning or meadow 

enhancement are listed as “harvest acres”. Thinning is divided into natural stands and plantations. Within each of these 

categories, the table further groups treatments by prescription elements. Part II of the table summarized subtreatment 

acres applied under natural stand thinning, plantation thinning, and meadow enhancement. These subtreatment acres are 

the actual estimated acres of each subtreatment, not the unit or larger harvest acres unless noted.
Elk Flat LSR Enhancement Project

72 Shasta-Trinity National Forest

PART I

Treatment Prescription

Unit Acres* Unthinned Patch Acres* Timber Harvest Acres*

Alt. 3 Change 

from Alt. 1 Alt. 3 Change 

from Alt. 1 Alt. 3 Change 

from Alt. 1

Meadow Enhancement Unit

Meadow Enhancement 518 no change 62 no change 379 no change

Total Vegetation Treatment 1,704 Unit 

Acres -1004

286 Acres 

of UTPs in 

Units

-37 1,969

Acres -268

PART II - Vegetation Subtreatments – acres of actual subtreatments (not unit acres)

Subtreatment

Subtreatments overlap those 

listed above and do not 

represent additional acres.42

The treatments above indicate 

when the subtreatment is 

applied.43 Acres represent the 

estimated acres within units 

unless noted.

Alt. 3

Natural 

Stand 

Thinning

Rx

Change 

from

Alt. 1

Alt. 3

Plantation 

Thinning

Rx

Change 

from

Alt. 1

Alt. 3

Meadow 

Enhancement

Rx

Change 

from

Alt. 1

Alt. 3

Total

Acres

Change 

from

Alt. 1

Group Selection 16 no 

change 58 no 

change

no 

change 75 no change

Radial Thinning 114 -25 58 no 

change

no 

change 172 -25

Interplanting

(Interplanting within other 

primary treatments including 

reforestation of the extensive 

mortality area. 

“Interplantingonly” is included 

with reforestation treatments in 

table below) 

186 -9 33 no 

change

no 

change 219 -9

Biomass Thinning

(harvest acres) 705 -228 576 no 

change 379 no 

change 1,660 -228

Aspen Release44

(and adaptive management 

restoration if needed) 

18.1 no 

change

no 

change 6.0 no change 24.1 no 

change

Oak Release45 9, -21 from Alternative 1 no 

change

no 

change

 42 Unit 152-1 is the exception because the primary prescription puts it in the “Natural Stand Thinning with Radial thin, 

Group Selection, and Plant Groups” treatment but it also includes interplanting.

43 Acreage estimates for the subtreatments are the total accumulated when applied in smaller areas where the sitespecific condition that prompts the treatment is encountered. The exception to this is harvest acres were used to estimate 

the biomass thinning and borax stump treatments.

44 These acres include aspen within the meadow enhancement prescription and all thinning prescriptions.

45 Since oaks are widely scattered across a number of natural stand thinning and plantation thinning units, oak release 

treatment was not broken down by natural stand or plantation. See Appendix A page A-26 for a list of units known to

contain oak.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 73

Adaptive Management 

Salvage

(if needed)

483 -45 283 no 

change

no 

change 766 -45

Borax Stump Treatment 

(in units with stumps over 14” 

diameter)

1,006 -267 388 no 

change 379 no change 1,773 -267

*Minor discrepancies in subtotals may exist due to rounding of raw data

Reforestation actions under Alternative 3 differ from Alternative 1 by nine fewer acres of interplanting. Table 

18 provides a summary of reforestation actions for Alternative 3 and how each action differs in acres of 

treatment from Alternative 1.

Table 18. Alternative 3 Summary of Reforestation Actions and Changes from Alternative 1

Reforestation Action Alternative 3

Estimated Acres

Change from 

Alternative 1

Site Preparation for Planting (Mechanical Scalp) 269 no change

Hand Planting 304 -9

Interplanting without thinning 10 no change

Interplanting in thinning units in mortality areas and gaps over 1 

acres (as needed) 159 -9

Planting group selections in thinning units 75 no change

Reforestation of extensive mortality areas 6046 no change

Post Planting Hand Release for Growth (1 entry between years 

1-5) 304 -9

Fire Restoration and Fuels Reduction Treatments

Alternative 3 reduces fuels treatment acres from Alternative 1 by eliminating underburning treatments in the 

NSO CHU. The other fuels treatments remain the same including machine piling and pile burning in units 6, 

12, 13, and 14. Alternative 3 requires additional mechanical fireline construction to isolate these units from 

the surrounding untreated natural stands for the purposes of pile burning. Roads would be used for control 

line to prevent the pile burning prescribed fire from entering critical habitat, with the exception of constructed 

mechanical fireline south of unit 230 and 6, at their boundary with unit 165, resulting in an overall 0.8-mile 

increase in mechanical fireline from Alternative 1. Table 19 summarizes fuels restoration treatments under 

Alternative 3 and how that differs from Alternative 1.

 46 The extensive mortality area also covers smaller portions of several adjoining units. The planting acres in the adjoining 

units is included within the “interplanting” row of the table.
Elk Flat LSR Enhancement Project

74 Shasta-Trinity National Forest

Table 19. Alternative 3 Summary of Fuels Reduction Treatments and Change from Alternative 1

Fuels Reduction Treatment

Alternative 3

No Treatment in 

Natural Stands in NSO

CHU

Alt. 3 Change from the 

Modified Proposed 

Action

Underburning47

(see description starting on pp. 52, B-35)

Underburn After Thinning and Meadow Enhancement Treatments 2,209 -499

Underburn Prior to Interplanting in Plantations

(No Timber Harvest Proposed) 28 no change

Underburn Only

(No Timber Harvest or Planting Proposed) 529 -217

Total Underburning 2,766 -716

Machine Pile and Pile Burn

(see description pp. 52, B-36 and Table Appendix B-3)

Maximum Estimated Maximum Estimated

1,365 884 -96 -60

Fuels Subtreatments

The following treatments overlap other fuels treatments and are not additive

Extensive Mortality Area

(see description starting on pp. 53, B-38) 79 no change

Fuels Connected Actions (miles)

Machine Fireline Construction

(see descripton starting on p. B-35) 10.1 +0.80

Road Actions

Road action activities under Alternative 3 will be the same as Alternative 1 except for the differences noted 

below:

• Maintenance - The miles of roads to be maintained would be reduced slightly from Alternative 1 by 

approximately 0.7 miles. The frequency and intensity of maintenance work would also decrease due 

to 304 fewer acres of thinning than Alternative 1.

• Temporary Roads - Approximately 1.7 miles of existing unauthorized routes within the dropped 

treatment units would not be used as temporary roads but would still be decommissioned. The new 

construction for temporary roads would drop from 2.9 miles to 1.5 miles. 4.7 miles of UA routes 

would be used as temporary roads then decommissioned.

• Landings – Alternative 3 would require 62 landings, 16 fewer than Alternative 1. Landings in critical 

habitat would be reduced.

 47 Within the constraints and guidelines detailed by the resource protection measures. There are unthinned patches that 

may not be burned or would have no direct ignition, and other sites that will have fire excluded within this total acreage.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 75

Table 20. Alternative 3 Road and Landing Actions by Forest Plan Allocation and Changes from Alternative 1

Road or Landing Action

Alternative 3

No Treatments in Natural 

Stands in NSO CHU

Alt. 3 Change from the 

Modified Proposed 

Action

(Alternative 1)

Road Actions and Forest Plan Land Allocation Miles48 Miles

Forest Transportation System Actions

Maintenance Only

(Roads without other actions. All road actions listed 

elsewhere also include maintenance. See description 

pp. 55, B-43)

14.7 -0.2

LSR 12.2 -0.2

Matrix 2.0 no change

Open, Use and Maintain for Project, Close in LSR

(See description pp. 55, B-47) 2.6 no change

Reconstruct and Close in LSR

(See description pp. 55, B-47) 0.3 no change

Add and Maintain in Matrix

(See description pp. 55, B-43) 0.1 no change

Total FTS Road Action Miles 17.7 -0.2

Other Transportation Actions

Temporary Roads and Decommissioning

Decommision Unauthorized Route (LSR)

(See description pp. 56, B-47) 1.7 +1

Use Unauthorized Route as a Temporary Road then 

Decommission

(See description pp. 55, B-44)

4.7 -1

LSR 2.8 -1

Matrix 1.9 no change

New Temporary Road Constructed then Decommission 1.5 -1.4

Total Decommissioning - Unauthorized Routes and 

Temporary Road Use, construction and 

decommissioning

7.9 -1.4

Landings

Est. # of 

Landings Est. Acres Est. # of Landings Est. Acres

Subtotal Estimated Existing Landings 29 22 -9 -6

LSR 22 16 -9 -7

Matrix 7 5 no change no change

Subtotal Estimated New Landings (LSR) 33 24 -7 -6

Estimated Total Landings Needed

(See description pp. 55, B-44) 62 46 -16 -12

 48 Rounding may cause slight discrepancies in totals
Elk Flat LSR Enhancement Project

76 Shasta-Trinity National Forest

Hydrologic Function and Soils Actions

Alternative 3 hydrologic function actions are summarized in Table 21. Windrow respreading is the same as in 

Alternative 1.

Table 21. Summary of Alternative 3 Hydrologic Restoration Actions

Treatment RR Acres RR Length (ft)

Stream channel and floodplain restoration: Unauthorized Route 

Decommission with Recontour Stream and Floodplain

3.8

(4.3 fewer 

than Alt. 1)

1,700

Stream Channel and Floodplain Restoration: Recontour Stream and 

Floodplain, Add Low Profile/Embedded Woody Debris Structure 7.2 1,569

Riparian Reserve Thinning (previously included in thinning acres) 165 N/A

Riparian Reserve Revegetation 94.9 16,127

Other Connected Actions

Hazard reduction as described in Alternative 1 remains the same.

Alternative 4- No Action

Alternative 4 is the no action alternative. The analysis of the no action alternative provides reviewers a 

baseline to compare the magnitude of environmental effects of the action alternatives. Alternative 4 is the 

continuation of the existing condition, current management and ongoing activities in the project area. Current 

management and ongoing activities in the project area, as permitted under past, current or potential future 

NEPA may include road maintenance, hazard tree felling, fuelwood collection, over-snow vehicle use 

associated with the Pilgrim Creek Snowmobile Park, dispersed recreation (e.g., sightseeing, hunting), forest 

products collection and other permitted special uses. Additional thinning in unit 401 under the Pilgrim 

Vegetation Management Project is pending. This analysis includes modeling of stand growth and fire behavior 

that is predicted if no new action is taken in the project area. Under no action, no treatments or road actions 

would be implemented to accomplish the purpose and need and project resource objectives.

Comparison of Actions - Alternatives Considered in Detail

The tables below provide treatment summaries by alternative.The summaries often represent overlapping 

treatments and are not necessarily additive in scale.49 Appendix B provides detailed descriptions of the actions 

and specific treatments by unit (Table Appendix B-2. Starting p. B-6) and road actions (Table Appendix B-5, 

p. B-41). Variations in treatments were developed within the broader categories responsive to site specific 

stand conditions as described in Appendix B. The alternative maps in 0 graphically display the vegetation, 

fuels and road actions.

• Vegetation Treatments – See Table 22 for thinning and meadow restoration and Table 23 for 

reforestation actions.

• Fuels Treatments – Table 24 (p. 79) lists fuels treatments by alternative.

 49 All acres are estimated and in the case of subtreatments actual conditions during implementation may create a range of 

acreage. Slight differences in treatment totals throughout the record may exist due to differing rounding methodologies 

and subtotals may reflect a slight difference than the sum of the components shown in the summary table due to 

rounding.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 77

• Road and Landing Actions – See Table 25 (p. 80)

• Hydrologic Restoration Actions – See Table 26 (p. 81)

Forest and Meadow Restoration Treatments

Table 22 displays vegetation treatments including thinning, meadow restoration and adaptive management for 

salvage. The table provides harvest acres, which are typically the unit acres minus UTPs, however some units 

have smaller harvest areas due to unforested areas within the unit boundary from insect and disease activity or 

from natural openings. Table 22 also notes planting within the vegetation subtreatments, and Table 23

provides more detailed information on planting and site preparation.

Table 22. Summary of Forest and Meadow Restoration Treatments Involving Timber Harvest

Restoration Treatment

Alternative 1

Proposed 

Action

Alternative 2

No New 

Temporary 

Road 

Construction

Alternative 3

No Treatment 

in Natural NSO

Critical Hab.

Alternative 4

No Action

Harvest Acres*

Thinning of Natural Stands

(See descriptions starting p. B-31.) 1,273 1,230 1,006 0

Thin 295 266 162 0

Thin, Group Selection, Plant Groups 34 34 34 0

Thinning with Interplant 341 335 312 0

Thin, Radial Thin 197 185 91 0

Thin, Radial Thin, Group Selection, Plant 

Groups 95 87 95 0

Thin, Radial Thin, Interplant 312 311 312 0

Thinning of Plantations

(See descriptions starting p. B-27) 584 570 584 0

Young Plantation Thin 141 141 141 0

Young Plantation Thin with Meadow Enhance 56 56 56 0

Young Plantation Thin, Interplant 84 84 84 0

Older Plantation Thin, Group Selection, Plant 

Groups 52 52 52 0

Older Plantation Thin, Radial Thin 13 13 13 0

Older Plantation Thin, Radial Thin, Group 

Selection, Plant Groups 239 225 239 0

Total Thinning 1,857 1,800 1,590 0

Meadow Restoration

(See description starting p. B-35) 379 354 379 0

Total Harvest Acres 2,236 2,154 1,969 0
Elk Flat LSR Enhancement Project

78 Shasta-Trinity National Forest

Restoration Treatment

Alternative 1

Proposed 

Action

Alternative 2

No New 

Temporary 

Road 

Construction

Alternative 3

No Treatment 

in Natural NSO

Critical Hab.

Alternative 4

No Action

Harvest Acres*

Additional Thinning Detail

(these acres are already included in the thinning listed above)

Group Selection 75 71 75 0

Radial Thinning 197 191 172 0

Interplanting

(Interplanting within other primary treatments

including reforestation of the extensive 

mortality area. “Interplanting-only” as the 

primary treatment is included with 

reforestation treatments in Table 8 below) 

228 228 219 0

Biomass Thinning 1,888 1,814 1,660 0

Aspen Release

(and adaptive management restoration if 

needed) 

24 24 24 0

Oak Release50 30 30 9

Adaptive Management Salvage

(if needed) 811 805 766 0

Borax Stump Treatment

(stumps over 14” diameter) 2,040 1,958 1,773 0

Estimated Net Harvest Volume51

(Hundred Cubic Feet - CCF)

Total Volume 43,900 41,600 37,600 0

Biomass Material

(trees 9.9”DBH and less, and tops) 6,000 5,700 5,300 0

Log Material

(trees 10” DBH and over) 37,900 35,900 32,300 0

*Minor discrepancies in subtotals and totals caused by rounding in the raw data may exist

Reforestation

Table 23 provides the potential site preparation, planting and release by alternative. See page B-33 for more 

information on reforestation activities.

 50 Since oaks are widely scattered across a number of natural stand thinning and plantation thinning units, oak release 

treatment was not broken down by natural stand or plantation. See Appendix A page A-26 for a list of units known to 

contain oak.

51 Net estimations for Alternative 1 derived from cruise sampling (6/5/15 Cruise Report B1) rounded up to nearest 100 

CCF. Other alternatives extrapolated from Alternative 1 data.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 79

Table 23. Summary of Reforestation Treatments

Reforestation Treatment

Alternative 1

Proposed 

Action

Alternative 2

No New 

Temporary 

Road 

Construction

Alternative 3

No Treatment 

in Natural 

NSO

Critical Hab.

Alternative 4

No Action

Reforestation Activity Acres

Site Preparation for Planting (Mechanical 

Scalp) 269 266 269 0

Hand Planting 313 309 304 0

Interplanting without thinning 10 10 10 0

Interplanting in thinning units in smaller 

mortality areas and gaps over 1 acres (as 

needed)

168 168 159 0

Planting group selections in thinning units 75 71 75 0

Reforestation of extensive mortality area 60 60 60 0

Post Planting Hand Release for Growth (1 

entry between years 1-5) 313 309 304 0

* Minor discrepancies in subtotals and totals may exist due to rounding of raw data.

Fuels Treatments

Table 24 lists the fuels actions including underburning, piling and pile burning, and hazard reduction by 

alternative. Underburning overlaps all treatment unit boundaries in Alternatives 1 and 2. Total acres reflect 

unit acres rather than the smaller harvest acres shown in the summary of vegetation treatments in Table 22

above. Certain fuels treatments may be in concert with other fuels treatments and do not represent additive 

acres.

Table 24. Summary of Fuels Reduction Treatments

Fuels Reduction Treatment

Fuels Treatment Acres

Alternative 1

Proposed 

Action

Alternative 2

No New 

Temporary 

Road 

Construction

Alternative 3

No Treatment 

in Natural NSO

Critical Habitat

Alternative 4

No Action

Underburning52

(see description starting on p. B-35) 3,482 3,482 2,961 0

Underburn After Thinning and Meadow 

Enhancement Treatments

(Includes Extensive Mortality Area Treatment

described on p. B-38)

2,708 2,597 2,404 0

Underburn Prior to Interplanting in 

Plantations

(No Timber Harvest Proposed)

28 28 28 0

Underburn Only

(No Timber Harvest or Planting Proposed) 746 857 529 0

 52 Within the constraints and guidelines detailed by the resource protection measures. There are unthinned patches that 

may not be burned or would have no direct ignition, and other sites that will have fire excluded within this total acreage.
Elk Flat LSR Enhancement Project

80 Shasta-Trinity National Forest

Fuels Reduction Treatment

Fuels Treatment Acres

Alternative 1

Proposed 

Action

Alternative 2

No New 

Temporary 

Road 

Construction

Alternative 3

No Treatment 

in Natural NSO

Critical Habitat

Alternative 4

No Action

Machine Pile and Pile Burn

(see description starting on p. B-36 and 

Table Appendix B-3)

est. max. est. max. est. max. est. max.

944 1,461 906 1,402 884 1,365 0 0

Additional Detail

Extensive Mortality Area Subtreatment

(see description starting on p. 53) 79 79 79 0

Mechanical Fireline Construction

(see descripton startong on pp. 53, B-35) 9.3 9.3 10.1 0

* Minor discrepancies in subtotals and totals may exist due to rounding of raw data.

Roads and Landings

Table 25 summarizes the road and landing actions by alternative.

Table 25. Summary of Road and Landing Actions

Road or Landing Action

(see descriptions starting p. B-39) Miles

Alternative 1

Modified 

Proposed 

Action

Alternative 2

No New 

Temporary 

Road 

Construction

Alternative 3

No Treatment 

in Natural NSO

Critical Habitat

Alternative 4

No Action

Forest Transportation System (FTS) Actions

Maintenance Only

(Roads without other actions. All road actions 

listed elsewhere also include maintenance. 

See description pp. 55, B-43)

14.9 14.9 14.7 0

Open, Use and Maintain for Project, Close

(See description pp. 55, B-47) 2.6 2.6 2.6 0

Reconstruct and Close

(See description pp. 55, B-47) 0.3 0.3 0.3 0

Add and Maintain

(See description pp. 55, B-43) 0.1 0.1 0.1 0

Total FTS Road Action Miles 17.9 17.9 17.7 0

Other Transportation Actions

Decommission Unauthorized Route

(See description pp. 56, B-47) 0.7 0.7 1.7 0

Use Unauthorized Route as a Temporary 

Road then Decommission

(See description pp. 55, B-44)

5.7 5.7 4.7 0

New Temporary Road Constructed then 

Decommission 2.9 1.6 1.5 0

Decommissioning - Routes and Roads

(see description starting on p. B-47) 9.3 8.0 7.9 0
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 81

Road or Landing Action

(see descriptions starting p. B-39) Miles

Alternative 1

Modified 

Proposed 

Action

Alternative 2

No New 

Temporary 

Road 

Construction

Alternative 3

No Treatment 

in Natural NSO

Critical Habitat

Alternative 4

No Action

Landings Total Landings*

Existing Landings 38 30 29 44*

New Landings 40 40 33 0

Total 78 70 62 44*

*Landings reflect total needed for the action alternatives. See the individual alternative tables for an estimation of existing landings that 

may be ustilized., Under no action no landings would be needed. Existing landings is higher for No Action that the action alternatives 

because some are unsuitably located.

Hydrologic Function and Soils Restoration Actions

Table 26 summarizes hydrologic restoration actions.

Table 26. Summary of Hydrologic Restoration Actions (acres)

Treatment Alternative 1 Alternative 2 Alternative 3

Stream channel and floodplain restoration: Unauthorized Route 

Decommission with Contour Stream and Floodplain 8.1

4.4

(3.7 fewer than 

Alt. 1)

3.8

(4.3 fewer than 

Alt. 1)

Stream Channel and Floodplain Restoration: Contour Stream 

and Floodplain, Add Low Profile/Embedded Woody Debris 

Structure

7.2 no change no change

Riparian Reserve Thinning (previously included in thinning 

acres) 211 no change

165

(46 fewer than 

Alt. 1)

Riparian Reserve Revegetation 94.9 94.9 94.9

Windrow Respreading 167 no change no change

Other Connected Actions

Hazard reduction as described in Alternative 1 of 87 acres applies to all alternatives.

Resource Protection Measures Common to All Action Alternatives

Resource Protection Measures (RPMs) were developed for site specific conditions relative to the Proposed 

Action and are common to action alternatives. Resource Protection Measures are intended to minimize or 

eliminate potential environmental effects while achieving the desired condition. Development was guided by 

Forest Plan direction as well as other applicable law, regulation and policy; project-specific objectives; and 

resource concerns identified by the resource specialists. In addition to RPMs, practices and procedures that 

may apply to the Elk Project but are not developed as site specific RPMs including compliance with 

applicable law, regulation, policy and Forest Plan Standards and Guidelines (legal and policy framework), and 

the standard operating procedures (SOPs) and Best Management Practices (BMPs) developed to meet the 

legal and policy framework are included in Appendix D. The design criteria (generally limitations on the 

Proposed Action) and design elements (aspects of the Proposed Action) most important to meeting the 

Purpose and Need for Action and legal and regulatory framework are described in the Proposed Action 

including detailed descriptions in Appendix B. Some listed items originate or respond to multiple 

requirements or needs identified for site specific protections.
Elk Flat LSR Enhancement Project

82 Shasta-Trinity National Forest

Cultural Resources

Also see Appendix D on page D-1 for common standard operating procedures for cultural resources.

1. National Register-eligible or unevaluated cultural resource sites (“historic properties”) will be 

avoided except within the parameters listed below, which will preserve the National Register 

integrity that may occur within these historic properties. Prior to project implementation, historic

properties will be delineated with coded flagging or other effective marking (USDA-FS & SHPO, 

2013 pp. 1.1, E-2).

a. Prescribed fire will be excluded from historic properties within the project area using the 

following methods:

 Non soil-disturbing methods, hand-constructed fire line, and dozer-constructed fire line may 

be used around the Ash Creek Mill site.

 Non soil-disturbing methods and hand-constructed fire line may be used in the vicinity of 

Coonrod Flat.

 Non soil-disturbing methods such as fire retardant foam, water, and other wetting agents may 

be utilized to protect all other historic properties (USDA-FS & SHPO, 2013 pp. 2.2, (b) A, D, 

E, F (pg. E-5) E-2).

b. Fire retardant foam, water, other wetting agents may be utilized to protect at risk historic 

properties (USDA-FS & SHPO, 2013 pp. 2.2, (b) A, D, E, F (pg. E-5) E-2).

c. If woody material is removed from historic properties, it will be hand-felled and cut to a size that 

can be hand-carried outside the site boundary (USDA-FS & SHPO, 2013 pp. 2.2 (a), E-2) . 

Mechanical equipment may be used to reach into the site for larger trees within the treatment unit. 

No ground disturbance or an increase in fuel loading from project activities will occur within the 

site boundaries. No woody material will be chipped or piled within site boundaries.53

d. Roads within or adjacent to historic property boundaries may be maintained at their usual 

maintenance level within the existing road prism. Activities that are not permitted within the 

boundaries of historic properties include road reconstruction activities (unless there is no potential 

for subsurface cultural deposits) (USDA-FS & SHPO, 2013 pp. 1.2, E-2; 2.1 (d)(f), E-44).

e. Other activities not permitted include: road widening, realigning, side casting or depositing of any 

earthen or vegetative material, new drainage control work such as wing ditch construction, 

culvert installation, and equipment staging. Roads that are decommissioned or closed within site 

boundaries will be blocked with barriers that do not disturb subsurface deposits or lead to other 

effects to sites. Erosion control features such as seeding and mulching may occur within historic 

property boundaries where the integrity of the property is unlikely to be affected.

2. Areas of Native American importance will be protected.

a. No treatments will occur within 0.25 miles of Coonrod Flat during July and August when this 

area is being utilized by Native Americans (36 CFR 800). Activities such as vegetation treatment, 

burning, and maintenance or hauling on adjacent roads will not occur within Coonrod Flat, and 

will not occur within 1⁄4 mile during this time, thereby eliminating noise, dust, smoke, and other 

disruptive effects. Skidding of felled trees in units 402 and 317 would be completed prior to July 

1, and no operations will occur in unit 402 during the month of July.

b. Road closures proposed near areas of Native American importance will be completed using large 

boulders, directional felling of trees, and other such barriers to maintain a natural setting.

 53 Treatment units have also been designed where possible to exclude site boundaries.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 83

Hydrology and Soils

Also see Appendix D on page D-1 for common standard operating procedures for soil and water resources.

3. Some existing landing piles will not be burned in Riparian Reserves in unit 346. Existing landing 

piles selected for specific retention of either water quality or wildlife values will be identified and 

designated and will not be burned as determined by the hydrologist or wildlife biologist.

4. Unit machine pile size will not exceed 10 feet long by 10 feet wide by 6 feet tall to protect soils from 

destructive burning.

5. Mechanical fireline construction shall only remove litter and duff and avoid removing the upper 

layers of the topsoil.

Riparian Reserves (RR), Including Slash Material, Burning Activities and Landings

Also see Appendix D Best Management Practices Starting on page D-4.

6. A minimum 20-foot equipment exclusion zone (EEZ) will be flagged along intermittent and 

ephemeral stream channels as determined by the hydrologist and may be increased based on the 

hydrologist’s or soil scientist’s site-specific evaluation. This EEZ may be larger, depending on 

resource conditions and RR and wildlife objectives for the treatment unit. From the boundary of the 

delineated EEZ, equipment may reach in to accomplish treatment objectives. The EEZs may be 

entered, if needed, after post-harvest activities are complete, by heavy equipment, to restore 

meadow, channel and floodplain functions to areas disturbed from past activities and as determined 

by the hydrologist.

7. Minimize soil disturbance in RRs by requiring directional felling and minimizing turning of harvest 

equipment. In the event that trees are accidentally felled into Ash Creek or its inner gorge, they will 

be left in place.

8. No mechanical site preparation will take place within RRs.

9. There will be no crossing of Ash Creek with equipment during sale activities. Any required 

temporary stream crossing locations on other intermittent/ephemeral streams will be designed and 

constructed in accordance with the hydrologist’s expertise. If rocking is required to maintain channel 

form and reduce compaction in stream crossing(s), the crossing will be rocked with andesite or 

basalt and source material would be weed-free. Any material used in crossings will be removed postimplementation and either scattered over the ground, if native, or utilized after the project in road 

closures.

10. Within the Elk Flat meadow restoration unit 402, harvest with heavy equipment will be completed 

when there is at least 3 inches of frozen ground or in areas where work can be completed over dry 

soils that will not result in soil displacement leading to potential significant adverse effects to 

meadow, floodplain and hydrologic function.

11. Within RRs, embedded downed logs, stumps and riparian plants and root systems will be retained 

during burning operations with minimal (up to 5%) damage. Large decadent willow scattered within 

RRs will be allowed to lightly burn with up to 5% mortality. Piles may be burned within the Ash 

Creek RR, but no machine piling will occur within the designated EEZ as described in RPM 6. Hand 

piles may be constructed and burned 20 feet away from the inner gorge in the Ash Creek RR (Units 

18, 106, 107, 113, 150, 154, 157, 163, 180, 346, 347, 402, 152-1, 152-2 and 346-U).

12. Excess slash material from operations or heavy mortality pockets within the Ash Creek RR beyond 

that to be retained as prescribed in RPM 40 starting on page 88 may be piled and burned outside of 

the EEZ or left in place and treated with underburning.
Elk Flat LSR Enhancement Project

84 Shasta-Trinity National Forest

13. Existing landings will be utilized and no new landings will be constructed within the Ash Creek RR. 

An earth scientist or hydrologist would assist the sale administrator in designating any new landing 

locations in other units containing intermittent or ephemeral channel RRs.

Landings and Skid Trails

Also Appendix C for common standard operating procedures related to landings and skid trails starting on 

page D-2.

14. Till/sub-soil landings and main skid trails within 200 feet of landings with equipment such as a 

winged sub-soiler or other tilling device to a maximum depth of 18 inches so that the soil is lifted 

vertically and fractured laterally to alleviate any detrimental compaction (Forest Plan pp. 4.25, O2)54 following completion of management activities in units 162, 164, 166, and 206. Tillage/subsoiling would be completed outside of the tree drip line to minimize impacts to root systems.

Invasive Plant Species55

Appendix C for common standard operating procedures related to invasive species starting on page D-2.

15. When seeding decommissioned temporary roads, unauthorized routes, landings and main skid trails, 

use a native mix of pollinator-friendly forbs and grasses at a rate of 10 to 15 pounds per acre and 

mulch with certified weed-free straw, or other approved fine slash to reduce seed predation, retain 

moisture, reduce the potential for wind erosion and, if necessary, to reduce overland flow erosion 

during rainfall events and snow melt.

Road Management

Also see Appendix C for common standard operating procedures related to road management starting on page 

D-3.

16. Road construction and maintenance will be managed for consistency with LSR standards and 

guidelines (Forest Plan, 1995 p. 4.39). If temporary roads are necessary to implement project 

activities, they will be kept to a minimum, be routed through non-late-successional or low quality 

late-successional habitat where possible.

17. If winter snow plowing occurs on FA19 or FA13 beyond the Pilgrim Snowmobile Park between 

December 1 and April 15 single lane plowing would be utilized to minimize impacts to winter 

recreation opportunities. The timing of this requirement may be adjusted through discussion with the 

Recreation Officer on impacts (e.g., periods of low snowfall).

Plant Species of Special Concern

See Appendix C for common standard operating procedures related to sensitive and non-vascular plants on 

page D-3. Implement the following pertaining to hardwoods.

 54 Compaction is considered detrimental if soil porosity is not at least 90 percent of the total porosity found under 

undisturbed or natural conditions. Porosity is evaluated between four and eight inches below the surface for soils with tree 

and shrub potential, and between zero and four inches for soils with herbaceous potential (Forest Plan pp. O-1).

55 At the present time, there are no high priority weed populations within the project boundary. However, there is one 

known population of a high priority weed along Pilgrim Creek Road near the snowmobile park.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 85

18. Minimize impacts to California black oak and other hardwoods during thinning and burning 

operations as much as practicable. Units known to have oaks include 6, 14, 153, 155, 154, 165, 168-

1, 168-2, 170, 173, 178, 317 and 318.

When burning around aspen (units known to have aspen include 157, 175, 318 and 402):

56 19.

a. Exclude prescribed fire in aspen stands that had conifer removal treatment that are actively 

suckering until they are determined to be well established. (see aspen Monitoring starting on page 

91 and adaptive management strategy in the proposed action for aspen where the characteristics 

of an established aspen stand are described starting on page 51.)

b. When burning surrounding areas exclude fire within 75 feet from the outer edge of the 

clump/stand (last sprout) to protect young aspen roots.

c. Point protection will be used to protect small (<0.5 acres) clones. Point protection may include 

but is not limited to sprinklers, mechanical fire line, hand line, existing skid trails and roads, or 

any other tool determined to be applicable. These tools can also be used on larger stands.

20. When burning within aspen:

a. If needed to control fire intensity, reduce combustible fuels in and around aspen to 5 to 15 tons 

per acre by using mechanical or manual methods.

b. Remove young conifer and shrubs if needed, by manual or mechanical means prior to burning;

c. Minimize residency time; implement fast moving prescribed fire.

d. Burn only when soil is moist and surface fuels are dry.

e. Limit mortality of the largest aspen to no more than 5% .

f. Protect the base of live aspen overstory trees from scorch as much as practicable.

Survey and Manage Vascular and Non-Vascular Plants

21. Bryophytes - All known Ptilidium californicum (Pacific fuzzwort) sites will be protected by 

designated unthinned patches where no thinning or mechanical equipment operation will occur as 

described in the proposed action. Trees would be felled away from occupied sites to avoid physical 

damage. 

22. Broadcast burning should not occur within occupied Ptilidium californicum (Pacific Fuzzwort). The 

occupied site(s) would be buffered to a sufficient distance (approximately 100 feet) such that radiant 

heat and smoke will not cause mortality to individuals (Harpel, et al., 2006 pp. 14-15).

Silviculture and Fuels

Also see Appendix C for common standard operating procedures related to silviculture and fuels starting on 

page D-3.

23. Within four hours of cutting, conifer stumps greater than 14 inches stump diameter will be treated 

with a registered borate compound (such as Cellu-Treat® or Sporax®) to prevent spread of 

Heterobasidion root disease. Aplication of the compound will follow all state and federal rules and 

will not be applied during precipitation events.

24. Underburning treatments in natural stands would be planned and implemented to meet the prescribed 

targets of duff and litter consumption while minimizing mortality of shrubs and trees (displayed in 

Table 27 and Table 28) and retaining coarse woody material at levels that meet RPMs 11 40e, 41

and 42, (also see number 17 on page D-3).The target consumptions and maximum mortality levels

are determined as an average across the project area.

 56 Unless an established research project pertaining to burning in aspen requires an alteration of methodology.
Elk Flat LSR Enhancement Project

86 Shasta-Trinity National Forest

Table 27. Levels of Acceptable Mortality When Underburning Natural Stand Units - Underburn Only

Prescribed Fire Objectives Size Class (DBH) Acceptable Range

Duff Consumption NA 30 to 50%

Litter Consumption

0-3” 40 to 100%

1-3” 40 to 85%

3-10” 30 to 70%

Average CWD Removal Burn to Retain Coarse Woody Debris Objectives in Accordance with

11 40e, 41 and 42, (also see number 17 on page D-3).

Conifer Mortality

<4” 50 to 100%

4 to 8” 10 to 30%

9 to 14” <10%

>14” <5%

Brush and Shrub Mortality N/A 30 to 50%

Table 28. Levels of Acceptable Mortality When Underburning Natural Stand Thinning Units

Prescribed Fire Objectives Size Class (DBH) Acceptable Range

Duff Consumption NA 30 to 50%

Litter Consumption

0-3” 40 to 100%

1-3” 40 to 85%

3-10” 30 to 70%

Average CWD Removal Burn to Retain Coarse Woody Debris Objectives in Accordance with 

RPM 11 40e, 41 and 42, (also see number 17 on page D-3).

Conifer Mortality

<4” 50 to 100%

4 to 8” 10 to 30%*

9 to 14”

<5%

>14”

Brush and Shrub Mortality N/A 30 to 50%

*If material that is 4 to 6.9 inches DBH is not commercially thinned due to market conditions at the time of 

implementation and is instead treated with prescribed fire during the underburning operations with or without 

other mechanical or hand treatments, the range of acceptable mortality is 30-50% to meet objectives since the 

burning treatment would be utilized to complete the thinning of that size class.

25. Measures will be taken to reduce injury or mortality to large predominant trees during prescribed fire 

operations. Potential methods may include but are not limited to:

a. multiple low severity burns to reduce fuels accumulations over time (also see 11 40e, 41 and 42, 

(and SOP number 17 on page D-3).

b. burning in conditions of a moist duff layer (subject to limited operating periods in RPMs 31 , 34, 

39 and 43), ensuring consumption of the upper layer of litter, while protecting the roots in the 

lower duff areas,

c. ignition techniques, such as short head runs, designed to limit residence time at the base of large 

trees,

d. pulling duff away from bole damage such as lighting scars and pitch seams that may cause fire to 

burn longer or move up into the crown,

e. tree well burning to pre-burn the area immediately surrounding the tree during moist conditions 

prior to stand under burning,

f. reducing large down fuels near the base of the tree to limit the heat and residence time for the tree 

bole and fine roots, and
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 87

g. mixing duff and litter to encourage fine roots to grow down into the soil prior to underburning or 

to bring moisture to the surface to discourage fire from reaching the boles.

26. Prescribed fire in plantations that are not thinned as part of project implementation will be managed 

at each entry to minimize mortality to trees to no more than 15% and consumption of shrub, forb, 

grass cover and CWD to no more than 10%. No snags will be directly ignited. Utilize firing 

techniques or control lines as needed to retain this existing migratory bird habitat and deer forage 

and cover, while returning low intensity fire to the landscape. Avoid prolonged duration of fire 

within plantations to prevent damage to roots and root collars of trees less than 10 inches diameter at 

soil level. Evaluate these protection measures prior to repeated burn entries for current conditions.

27. Prescribed fire in plantations that are being thinned as part of project implementation would be 

managed at each entry to minimize mortality to trees to no more than 15% and consumption of 

shrub, forb and grass cover to no more than 25 to 50%. Maintain CWD in accordance with RPMs

11, 40e, 41 and 42, (also see number 17 on page D-3).No snags would be directly ignited. The end 

result should be a mosaic of burned and unburned shrub and understory vegetation pockets 

throughout a treatment unit.

28. Apply prescribed fire only after remaining trees show signs of increased health and vigor. Fuels and 

silviculture specialists will assess signs of readiness by evaluating thinning response (release) 

indicated by increased increment of spring wood in the radial core or increased foliage or shoot 

growth. Adequate response may occur as early as one full growing season following a thinning 

treatment in a healthy stand under average precipitation years.

29. During underburning, maintain at least 30% of grass, forbs and shrubs. Evaluate these protection 

measures prior to repeated burn entries for current conditions.

30. There will be no direct ignition in unthinned patches in units 123, 152-1, 154, 165, 169, 171, 172, 

174, and 235 to reduce fire effects to sensitive and ethnobotanical species and wildlife habitat.

Wildlife

31. A limited operating period (LOP) that restricts ground disturbing activities, loud and continuous 

noise and smoke-generating activities within a 1⁄4-mile of known northern goshawk territories is 

required between February 1 and August 15. The LOP will also be required if a new territory is 

established within, or within 1⁄4-mile of, any treatment unit during project implementation. In any 

year of implementation, activities may occur during the LOP if surveys conducted after June 1 

determine there are no breeding goshawks within the nest core. Currently, this LOP is required for 

units 114, 155, 156, 182, 221, 224, 346 and 346-U. When burning in spring outside of the LOP area, 

smoke should be managed so that light to moderate, dispersed smoke may be present within an area, 

but dissipates or lifts within 24 hours. Ignition should be discontinued if heavy, concentrated smoke 

begins to inundate the area.

32. No mechanical harvest operations, skidding or other ground disturbance (other than prescribed fire 

and road actions) will occur within the 200-acre core of northern goshawk territory(ies).57

33. Northern spotted owl (NSO) surveys, stand searches or spot checks will be conducted prior to and 

throughout implementation, consistent with current survey protocol and as discussed and agreed to 

with the FWS-FS Level 1 (line officers from both agencies) team on an annual basis.

34. A limited operating period (LOP) for habitat altering, smoke-generating and noise-generating 

activities above ambient levels will be required within 0.25-mile of an active NSO nest, and within a 

 57 No cores currently exist within the project boundary that are subject to mechanical harvest, skidding or other ground 

disturbance. This procedure will be followed if a core is established at any time prior to or during implementation.
Elk Flat LSR Enhancement Project

88 Shasta-Trinity National Forest

0.25 mile of Nesting/Roosting habitat (units 150 and 168-2, and portions of units 152-1 and 154). 

The LOP will remain in effect until surveys, stand searches and/or spot checks are completed during 

a year of operations. The NSO LOP begins February 1st and will extend through April 15th, and/or 

the completion of surveys, stand searches and/or spot checks if efforts are not completed by April 

15th:

a. If no NSOs are detected, operations may commence upon notification from the biologist that 

the surveys are negative.

b. If a single NSO is detected, operations may commence after July 9th.

c. If nesting NSOs are detected, the LOP will be remain in effect within 0.25 mile of the nest 

through:

1. July 31st for activities that result in noise above ambient levels (e.g., road actions)

2. September 15th for habitat altering/smoke-generating activities (e.g., thinning, machine 

piling/burning piles, prescribed fire)

Spot checks are intended to supplement the general project-level surveys and avoid the potential 

direct take of spotted owls from project implementation. Based on the survey history for NSOs and 

barred owls in the project area, if implementation is underway before February 1st, the spot 

checks will occur concurrent with operations. If an NSO is detected during any survey efforts, all 

ongoing operations that have a likelihood of direct harm to an NSO or creating above-ambient noise 

shall be postponed. When burning in spring outside of the LOP area, smoke should be managed so 

that light to moderate, dispersed smoke may be present within an area, but dissipates or lifts within 24 

hours. Ignition should be discontinued if heavy, concentrated smoke begins to inundate the area.

35. For all listed LOPs, the wildlife biologist will work with the fuels shop on an annual basis when 

developing, or modifying the project’s burn plan.

36. If a new NSO (non-nesting) or barred owl detection occurs prior to or during project 

implementation, technical advice or re-initiation with the FWS may be required.

37. Where piling and burning is conducted within NSO and NGO (northern goshawk) foraging habitat, 

leave two unburned slash piles per acre to provide small mammal habitat. Pile size can vary as safety 

allows, but in general should not exceed 10 feet long by 10 feet wide by 6 feet tall. The project 

wildlife biologist and fuels specialist will conduct a review of units after piling is completed to 

determine which piles to retain, and if additional piles are needed. If needed, hand piles of smaller 

material will be constructed (~1 to 2 additional piles per acre). Applicable units are: 151, 152-1, 154, 

157, 158, 159, 160, 163, 164, 165, 166, 169, 174, 181, 201 and 235). While units 175, 204 and 206 

do provide for a substantial prey base, notably for goshawk and fisher, it is not operationally feasible 

to retain unburned piles in these units that are within the Extensive Mortality Area.

38. No more than 50 percent of the suitable habitat within an NSO core or home range, or a currently 

known NGO territory will be burned during any given burn season, or if nesting or resident 

NSO/NGO are present, during any 12-month period. In the event that a new NSO activity center or 

NGO territory is established, this same design feature will apply to the Burn Plan (see RPM 35). 

Applicable units are: 156, 182, 221, 224, 346 and 346-U; 150, 151, 152-1, 152-2, 153, 154, 161, 

163, 165, 166, 167, 168-1, 168-2, 170, 171, 172, 173,174 and 178.

39. To minimize direct disturbance to female fishers during their most vulnerable period of denning and 

kit rearing, an LOP for vegetation and fuels management activities will extend from March 1 

through July 31 around known denning areas and within areas that support denning habitat. 

Applicable areas include: units 150, 152-2, 153, 154, 156, 168-2, 182, 221 and delineated areas 

along Ash Creek in units 152-1, 157 and 163.

40. Snag and down log retention outside of the meadow restoration units is based on the 

recommendations for mixed conifer and white fir vegetation communities in Tables 3-1 to 3-3 of the 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 89

LSRA. These recommendations represent an average for a landscape or treatment area (i.e., 100 

acres). Per the LSRA, numbers of snags and down logs can vary on any particular acre (LSRA p. 

164).

a. Within thinning and fuels treatment units in LSR, retain, on average, 7 snags per acre ranging

from 15 to 20+ inches diameter with a preference for snags larger than 20 inches or the largest 

size class available (LSRA p. 164). Plantation units may or may not contain this level of snags, 

and thinning prescriptions were developed with snag objectives as part of the desired condition. 

Live trees with decadent late-successional characteristics count towards snag retention 

recruitment where snags are not available. While snag removal is not proposed as a treatment in 

the majority of the project area, snags may be felled to reduce hazards to the public or during 

operations, or to complete specific elements of the proposed action (e.g., group selections within 

plantations, hazard reduction zones within 300 feet of specified private property boundaries and 

150 feet of designated roads, site preparation for reforestation efforts).

b. Retain Douglas-fir, sugar pine and incense cedar snags larger than 20 inches diameter, safety 

permitting.

c. Where safely feasible retain groups of snags in existing mortality pockets. Retained snag pockets 

should be at least 150 feet from System roads and 300 feet from private property boundaries.

d. Within thinning and fuels treatment units in LSR and matrix outside of the meadow enhancement 

unit 402, maintain and protect existing coarse woody debris from disturbance to the greatest 

extent possible (Forest Plan pp. 4.38, 4.61).

e. In accordance with the LSRA, the desired condition is an average of 6 to 10 large down logs per 

acre. Retained logs are to be in a variety of decay classes with a preference for 20-inch diameter 

logs, or the largest size class available. Within pine dominated stands retain at least 6 logs per 

acre, within fir dominated at least 8 logs per acre and within mixed conifer at least 10 logs per 

acre. Within the hazard reduction zones, large down log retention would average 4 to 6 per acre. 

On average, remaining tonnage will range from 5 tons per acre in size classes less than 3 inches 

to 20 to 35 tons per acre for larger diameter logs, depending on location, and is in accordance 

with the LSRA (LSRA p. 3.3), the Forest Plan, the Forest Plan habitat capability models and best 

available science for maintaining and promoting habitat suitability for the NSO, NGO and fisher.

f. Where safely feasible, retain scattered or concentrations of natural fall and downed wood piles 

and 10-20% of the existing shrubs and minor species important for NSO prey base (whitethorn, 

bush chinquapin, Scouler’s willow) when conducting site preparation and planting to meet the

condition described above in e. Preference is to retain piles within the interior of the treatment 

unit, and not in close proximity (within 50 feet) to main use roads and private property.

41. Within the forested portions of the meadow enhancement unit 402 maintain 15 inch or larger 

diameter snags. Maintain an average of 5 tons of unburned coarse woody debris per acre with a 

preference for at least 5 logs > 10 feet in length at the largest available diameter (Forest Plan pp. 

4.38, 4.61). Maintain scattered conifers or small groups of conifers at a rate of 5 to 20 trees per acre 

(LSRA p. 170).

42. To minimize the loss of nesting, roosting, foraging, resting, denning and prey base habitat

components (including mycorrhizal fungi), underburning would occur during conditions that do not

result in more than 10% full consumption of down logs in the 20 inch diameter and larger size class.

Conditions that limit consumption of 24 inch diameter and larger logs to 5% or less are preferable.

This applies to all units, though may not be operationally or safely feasible in units 163, 175, 204

and 206. This RPM is also intended to minimize the potential for loss of understory layering, large

snags and trees, and large down wood in nesting/roosting, resting/denning, and higher quality

foraging habitats for NSO, NGO and fisher for units 150, 152-1, 152-2, 154, 155, 156, 162, 165,

167, 168-2, 173, 182 and 221. Refer to RPM 11 for CWD burning objectives within Riparian

Reserves that are more restrictive. Also see RPMs 24-30 for additional protections during prescribed

burning.
Elk Flat LSR Enhancement Project

90 Shasta-Trinity National Forest

43. To limit the potential for direct adverse effects to ground-nesting and riparian-obligate migratory 

bird species within Elk Flat meadow and along the Ash Creek RR when underburning:

a. Burning from August 1 to February 1 is permitted, provided the NSO and NGO LOPs described 

in RPMs 31 and 34 are not in place.

b. Avoid burning operations during the primary nesting season of April 15 to July 31 if the LOPs for 

NGO or NSO are not in place.

c. When burning in spring, smoke should be managed so that light to moderate, dispersed smoke 

may be present within an area or drainage, but dissipates or lifts within 24 hours.

d. Ignition should be discontinued if heavy, concentrated smoke begins to inundate the area.

e. Units this RPM applies to include: 150, 152-1, 152-2, 154, 157, 163, 171, 180, 218, 346, 347, 401 

and 402.

44. RPMs specific to the gray wolf are as follows:

a. If a den site is detected within or near the project area during the project’s implementation 

timeframes, a Limited Operating Period (LOP) that restricts noise- and smoke-generating 

activities within one mile of the den will be implemented from April 1 through June 30.

b. While the provision for the den site LOP is expected to provide protections from any prolonged

or substantial project-related disturbance during the critical pup-rearing period at early 

rendezvous site(s), a similar LOP for activities within one mile of active rendezvous sites from 

April 1 through August 31 will be implemented. Further discussions and coordination with the 

FWS may result in modified distances, or more flexible dates, for this specific resource protection 

measure.

c. These LOPs will be implemented unless there are topographic features or terrain that clearly 

separates the noise- or smoke-generating activities from the den or rendezvous site(s).

d. While there are no known den or rendezvous sites associated with the Shasta Pack within one 

mile of the project area at this time, the LOPs specific to the gray wolf will be included in the 

timber sale contract and would be put in place if denning wolves are detected. These measures 

will also be included in the burn plan and any other implementation contracts or plans.

Visual Resources

45. The following resource protection measures are prescribed within a 150-foot visual corridor adjacent 

to the Pilgrim Creek Road (Forest Road 42N13). This visual corridor would apply to units 16-115, 

106, 107, 123, 125, 157, 159, 162, 176, 179, 180, 176, and 347.

a. Use existing landings and locate new landings out of view as seen from the roads where feasible.

b. Stump height will be 6 inches or less (if a landscape feature obstructs the view between the road 

and the cut trees, stump height may be higher).

c. Cut or leave trees will be marked on the sides facing away from the roads. Prior to treatment, 

further measures such as flagging of individual leave trees may be implemented to assure 

operators can clearly identify leave trees.

d. The goal within the visual corridor is to have a clean look by removing the majority of the slash 

and woody debris with the least amount of ground disturbance. This may be accomplished by: 

lopping and scattering if there are not large amounts of residual slash, as generally occurs with 

whole tree-yarding; hand piling and burning excess slash and scattering the burn pile residue that 

is not fully consumed or machine piling the slash outside of the visual corridor.

Monitoring Common to All Action Alternatives

The following monitoring is proposed as applicable for pre, during, and post treatment.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 91

Aspen

Long-term monitoring plots58 will be set up prior to implementation to collect baseline data. Monitoring or

research may be accomplished by enlisting the help of research facilities who are interested in finding ways to 

improve the outcomes for aspen restoration. This will be helpful in providing the forest with more information 

which will lead to better results in restoration.

1. The sprouting stimulus results of conifer removal will be assessed. Conifer removal units will be 

monitored after years one and three post-harvest to determine if conifer removal treatment 

sufficiently improved or stimulated suckering. Thinning and meadow enhancement units with known 

aspen include 157,175 and 402.

d. If suckering is not occurring after three years, other stimulus methods including underburning 

or mechanical soil disturbance as described in the adaptive management for aspen restoration 

of the proposed action will be introduced as appropriate. Assess the health of aspen prior to 

implementation to determine which treatments are most appropriate for the site specific 

situation.

e. If conifer removal treatment successfully stimulates suckering, monitoring will continue in 

year five and then as needed until the aspen has met the initial establishment objectives.

2. Once the initial objectives are met, assess the clump or stand to determine if further actions as 

described in the Proposed Action to meet the Purpose and Need are necessary.

3. Aspen in fuels-only (no timber harvest) units will be monitored after each burn to determine if 

underburning is achieving the desired results. Under aspen restoration adaptive management, if 

desired results are not being met, modifications may be required for future burns, or the use of 

mechanical soil disturbance will be evaluated. Unit 318 is a known underburn unit with aspen.

4. If post-treatment monitoring shows detrimental browsing, determine if browsing is from livestock, 

wildlife or both and fence appropriately as described in the Proposed Action. Continue to monitor 

and remove fencing when appropriate.

Botany

5. Prior to treatment, monitoring plots will be established in units where fungi and plants of interest are 

known to occur and examined post-treatment to assess project effects.

Cultural Resources

6. An archaeologist will be present when protection measures are initiated around prehistoric sites (if 

initiated prior to burning) to ensure adequate distance from and protection of the sites. An 

archaeologist and fuels project leader will visit the site prior to burning to review the site boundaries 

and discuss protection measures, or an archaeologist will be present to monitor when nearby fuels 

are ignited.

7. On-site actions determined necessary for fuels reduction around historic property site boundaries

will be monitored to ensure no damage occurs to historic properties.

8. An archaeologist will monitor the mechanical fire line constructed to determine whether new 

cultural materials have been uncovered (after the mechanical fire line is constructed). Other 

monitoring of historic properties will be conducted as needed.

 58 Accepted monitoring methods will be used to set up these plots. They may consist of photo points as well as some 

other plot method (as yet to be determined) for gathering data.
Elk Flat LSR Enhancement Project

92 Shasta-Trinity National Forest

Fuels

9. Units will be monitored post-harvest by the fuels specialist, silviculturist and wildlife biologist as 

necessary, to evaluate and determine the most appropriate fuels management practice in order to 

avoid unnecessary disturbance to understory vegetation. Specifically, the need for machine piling 

and burning prior to underburning will be evaluated in those units designated for possible machine 

piling. Fuels post-harvest and post-piling monitoring would compare effectiveness, soils impacts, 

and costs, with other nearby projects. Public participation in monitoring would be encouraged.

10. Validate project treatment and habitat objectives, incorporate project monitoring results and check 

for changed circumstances prior to reentry for follow-up fuels work after the initial treatments.

Invasive Species

11. Surveys and treatments for noxious weeds will continue throughout all phases of project 

implementation and beyond by at least 5 years to respond to delayed germination.

Road Management

12. Monitor and any identify draft site damage. Repairs as needed will be conducting during and post 

implementation.

Reforestation

13. The Management Unit or project silviculturist would monitor replanted areas to verify that stocking 

objectives are achieved within five years of planting. For areas where natural regeneration is 

proposed, exams would also occur to assure that stands are restocked.

Silviculture and Wildlife

14. The project silviculturist and wildlife biologist will coordinate with the marking crew and inspect the 

marking to ensure that the unit-specific prescriptions, marking guides and Project Design Features 

are applied as described in order to maintain, improve or promote habitat structure and function.

15. Monitoring will be completed to assess effects of underburning-only treatments within suitable NSO

habitat, as described for Recovery Action 11 in the Revised Recovery Plan. The effects will be 

evaluated periodically to see if the treatment is meeting the levels of acceptable mortality determined 

by the IDT and FWS, or whether there is new information to be assessed prior to continued 

implementation.

16. Stands will be surveyed/monitored for northern goshawk and NSO prior to and for the full extent of 

project implementation utilizing a variety of survey methods. Similar monitoring may also be 

performed for NGOs and NSOs after implementation to evaluate effects of the project on any

territories or home ranges that overlap the project area.

17. Carnivore monitoring, utilizing a variety of methods, will occur prior to, and to the extent 

practicable, during and after project implementation. This monitoring work informs the SMMU 

regarding fisher presence and use of the stands prior to, during and after treatment and contributes 

information to Forest Plan Implementation Monitoring.

18. Point counts to assess migratory and resident bird species presence will be completed prior to, and to 

the extent practicable, during and after project implementation.

19. Oak release treatments in NSO and fisher habitat will be monitored to assess if objectives for oaks 

and foraging, resting and denning habitat are met. The effects will be evaluated periodically to see if 

the treatment is meeting the objectives set determined by the IDT and FWS, or whether there is new 

information to be assessed prior to continued implementation.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 93

20. Camera stations will continue to be utilized to monitor for potential wolf use, including near or at 

potential den or rendezvous habitats within the project area, within one mile of the project’s 

activities and other portions of the wolf action area.

21. Wolves around den and rendezvous sites are fairly obvious, given the tracks, prey carcasses and

bones, scat, visual observation of a wolf or wolves. While these signs have not been observed in or 

near the project area to date during activities or pre-decision planning and field work, surveys for 

other wildlife and implementation monitoring are ongoing and will continue throughout and after 

project implementation. Information from these surveys will be used to determine if LOPs are 

needed, if the determinations made in the BA are still applicable or whether there is new information 

to be considered prior to continued implementation.

22. Interagency coordination and close collaboration with FWS and CDFW is an essential conservation 

measure. The Forest Service will continue to coordinate and communicate with FWS and CDFW on 

their monitoring efforts. While there are no immediate plans to collar individuals in the Shasta Pack, 

as coordination with Oregon and other agencies is needed (Kovacs, 2015) if individuals are collared 

it may be feasible to better track their location and implement necessary conservation measures. If 

the Forest Service observes wolves, dens or rendezvous sites, it will be reported to the CDFW and 

the FWS59 so that follow-up investigation(s) can occur.

Revegetation

23. Decommissioned unauthorized routes and temporary roads would be monitored for adequate 

revegetation response for compliance with the National Forest Management Act.

Water Quality, BMPs and Soil Productivity

Timber sales that have the potential to affect water quality would be enrolled in the Timber Harvest Waiver 

Program administered by the Central Valley Regional Water Quality Control Board (CVRWQCB) under 

Resolution No. R5-2014-0144 (CVRWQCB, 2014). In order to comply with the timber harvest waiver the 

Forest Service would conduct implementation and effectiveness monitoring as described in monitoring 

guidelines provided by the Central Valley Board. The monitoring program would accomplish the following 

objectives.

g. Determine if Best Management Practices, mitigations, resource protection measures and management 

measures have been properly put into place before the start of the winter period (November 15th 

through April 1st).

h. Determine if significant pollution occurs as a result of timber harvest activities during the winter 

period.

i. Determine if the management measures were effective in preventing significant pollution during the 

winter period.

Monitoring of implementation activities would be accomplished by resource personnel including the 

hydrologist and sale administrators. If problems are identified, the Forest Service would consult with the 

CVRWQCB and take corrective actions (e.g., suspension of work, temporary closure, spot-rocking).

 59 The CDFW holds the responsibility for contacting private landowners (CDFW et al. 2012)
Elk Flat LSR Enhancement Project

94 Shasta-Trinity National Forest

Comparison of Effects – Alternatives Considered in Detail

This section provides a brief summary of effects for each alternative considered in detail.

Table 29 presents the comparison of effects by section I-Achievement of the Purpose and Need for Action, II-Effects Relative to Key Issues (starting p. 

101), III, Additional Resource Effects (starting p. 105), and IV Additional Required Disclosures, Compliance and Consistency (starting p. 112). Each 

item in the table references the locations elsewhere in the EIS where the topics are discussed in more detail.

Table 29. Comparison of Effects of Alternatives Considered in Detail

Table 29 Part I. Comparison of Achievement of Purpose and Need for Action

P&N #1. Risk Reduction in Early, Mid and Late-Successional Habitat and Increased Stand Resilience to Disturbance (LSRA Objectives I and III) (see pp. 10, 

149, 153, 157, 125, 128, 136, 141, 144)

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary Road 

Construction)

Alternative 3

(No Treatments in Natural 

Stands in NSO Critical 

Habitat)

Alternative 4

(No Action)

1a. Insect and Disease

Activity – Acres of 

treatment and risk reduction 

of insect and disease 

outbreak

Stands totaling 2,169 acres 

treated to address elevated 

insect and disease outbreaks, 

or reduce the risk of additional 

outbreaks

Stands totaling 2,103 acres 

treated, This is 66 fewer acres 

of risk reduction treatment, but 

all stands with elevated insect 

and disease are still treated 

Stands totaling 1,866 acres 

treated, This is a total of 303 

less acres; of which 169 acres 

are stands with elevated insect 

and disease outbreak, and 135 

acres are stands at risk of 

outbreak. See No Action 

discussion of contiguous 

untreated stands

No Stands Treated. 

Contiguous dense stands are 

left intact, including those with 

elevated insects and disease. 

These areas will continue to be 

active infection centers and 

keep adjacent stands at risk by 

providing conditions that 

support epidemic outbreaks

1b. Stand Composition, Stands totaling 2,002 acres 

treated

Stands totaling 1,936 acres 

treated

Stands totaling 1,699 acres 

treated No stands treated
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 95

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary Road 

Construction)

Alternative 3

(No Treatments in Natural 

Stands in NSO Critical 

Habitat)

Alternative 4

(No Action)

Structure and Density -

Acres of reduced stand 

densities supporting stand 

growth and resilience

Density (SDI) reduced below 

pine mortality threshold postthin

Density (SDI) near pine 

mortality threshold at year 20

Same average reductions in 

SDI but on 66 fewer acres

Same average reductions in 

SDI but on 303 fewer acres

Density (SDI) well above pine 

mortality threshold at year 1 

and year 20 - However 

projections do not account for 

insect and disease outbreak. 

Field observations and 

research indicate the high 

densities will not persist for 20 

years

1c. Fire and Fuels – Fire 

Regime, Fuel Loading, and 

Fire Behavior:

Fuel 

Loading –

acres of 

reduced 

fuels

Thinned 2,237 2,154 1,969 0

Underburned 3,482 Same as Alternative 1 2,766 0

Piled 1,461 1,402 1,365 0

Fuel Models - FMs in 

Project Area (1 and 9 

desired)

2, 9, 10 2, 9, 10

trending to 13

2, 9, 10

trending to 13

2, 9, 10

trending to 13

Potential Fire Behavior –

flame length (feet) on 90th

percentile weather day

<4’ <4’-6’ <4’-6’ 4’-6’

Fire Type - anticipated 

under extreme fire 

conditions

surface fire surface and passive crown fire surface and passive crown fire passive crown fire

Conclusions

Highest response to P&N #1 

with risk reduced in natural 

stands across the project area.

Greatest extent of fire regime 

restoration, with the highest 

potential for manageable 

conditions in the event of 

wildfire. Meets law and policy.

Project area moves towards 

desired conditions. Objectives 

are met on fewer acres than 

Alternative 1.

Project area moves towards 

desired conditions. Objectives 

are met on fewer acres than 

Alternatives 1 and 2.

No achievement of P&N #1. 

Current trends continue with 

the habitat in the project area 

at risk of uncharacteristic 

levels of disturbance.

No restoration of fire regime. 

No action does not meet safety 

or fire behavior objectives and 

does not meet Forest Plan or 

Policy direction.
Elk Flat LSR Enhancement Project

96 Shasta-Trinity National Forest

P&N #2. Accelerate Development of Late-Successional and Old-Growth Forest Characteristics (LSRA Objective II) and Promote Late-Successional Habitat 

Connectivity (LSRA Objective IV) (see pp. 131, 133, 138, 142, 144, I-26, 225)

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary Road 

Construction)

Alternative 3

(No Treatments in Natural 

Stands in NSO Critical 

Habitat)

Alternative 4

(No Action)

2a. Acres early and midsuccessional treated to 

accelerate development of 

late successional 

characteristics

692 Acres of Plantations

1,385 acres of natural stands ( 

of which nearly half are in a 

mid-successional condition)

676 Acres of Plantations; this 

is 16 fewer acres

1,335 acres of natural stands; 

this is 50 fewer acres 

692 Acres of Plantations – no 

change

1,083 acres of natural stands; 

this is 304 fewer acres 

No stands treated

2b. Number of trees > 24”

DBH immediately posttreatment and projected in 20 

years based on comparative 

modeling of the alternatives.

Post thin ranges 16-19 TPA 

>24” DBH (varies by density 

class)

Year 20 ranges 17-22 TPA > 

24” DBH (varies by density 

class)

Same as Alt. 1 Same as Alt. 1

Year one ranges 16 – 24 TPA 

> 24” DBH (varies by density 

class)

Year 20 ranges 16-31 TPA >

24” DBH however mortality 

observations and research on 

pine density threshold do not 

support these upper projected 

numbers at year 20 

2c. Number of snags greater 

than 20 inches dbh projected 

in 20 years from comparative 

modeling. (see modeling 

limitations in Chapter 3 

Silviculture Section)

Post- thin ranges 2.0 to 3.5 

snags/acre depending on 

stand density class

Year 20 ranges 0.3 to 3.6 

snags/acre depending on 

density class

Same as Alt. 1 Same as Alt. 1

Year 1 ranges 2.5 – 4.4 

snags/acre depending on 

stand density class

Year 20 ranges 0.4 – 4.6 

snags/acre depending on 

density class

2d. Retention of late 

successional forest at 

watershed scale

Percent of capable land 

occupied by forest types that 

meet the criteria of latesuccessional forest will remain 

at approximately 53 percent in 

the Ash Creek watershed.

Same as Alt. 1 Same as Alt. 1 No Change

2e. Soil Productivity –

restored top soil 

displacement in windrowed 

plantations to accelerate 

growth

Windrows respread in 2 

plantations Same as Alternative 1 Same as Alternative 1 No windrow respreading
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 97

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary Road 

Construction)

Alternative 3

(No Treatments in Natural 

Stands in NSO Critical 

Habitat)

Alternative 4

(No Action)

Conclusions Highest response to P&N#2 

(equal to alternative 3)

14 fewer acres of meeting 

P&N #2

Highest response to P&N#2 

(equal to alternative 2)

No achievement of P&N #2. 

Current trends continue risking 

the achievement of 

successional development 

within plantations.

P&N #3. Restore Meadow Habitat in Elk Flat (see pp. 29, 153, 190, 192, and also see P&N #5 below)

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary Road 

Construction)

Alternative 3

(No Treatments in Natural 

Stands in NSO Critical 

Habitat)

Alternative 4

(No Action)

3a. Restoration of early seral 

vegetative conditions in Elk 

Flat – acres of meadow 

enhancement treatment in 

Unit 402

379 acres meadow 

enhancement treatment

(518 acres of the meadow 

including the UTPs)

354 acres meadow 

enhancement treatment

(494 acres of the meadow 

including the UTPs)

Same as Alternative 1 0 acres of meadow 

enhancement treatment

3b. Restoration of natural fire 

regime in Elk Flat-acres of 

underburning in Elk Flat unit 

402

518 acres underburned Same as Alternative 1 Same as Alternative 1 0 acres underburned

Conclusions Meadow restoration provided, 

meeting P&N #3

Meadow restoration provided, 

meeting P&N #3. 25 fewer

acres of conifer removal than 

Alternatives 1,2 decrease 

effectiveness on those acres.

Meadow restoration provided, 

meeting P&N #3

No achievement of P&N #3. 

Current trends continue with 

continued loss of dry meadow 

habitat to conifer 

encroachment and fire 

exclusion.
Elk Flat LSR Enhancement Project

98 Shasta-Trinity National Forest

P&N #4. Retain Hardwoods as a stand component at density levels commensurate with development of late-successional stands (see pp. 32, 126, 134, 139

143, 144, 191, 192)

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary Road 

Construction)

Alternative 3

(No Treatments in Natural 

Stands in NSO Critical 

Habitat)

Alternative 4

(No Action)

4a. Acres promoting growth 

and resilience of hardwoods 

including aspen, 

commensurate with late 

successional stand 

development.

Oak released in stands totaling 

567 acres (i.e. oak has been 

detected and will be promoted 

throughout these stands). 

Approximately 30 total acres of 

oak release

Oak released in stands totaling 

534 acres; this is 33 fewer 

acres than Alt. 1. 

Approximately 30 total acres of 

oak release

Oak released in stands totaling 

419 acres; this is 148 fewer 

acres than Alt. 1. 

Approximately 9 total acres of 

oak release

Aspen and oak continue 

declining in stands due to 

competition and shading out by 

overtopping conifers

4b. Acres of aspen release 

and restoration 24 Same as Alternative 1 Same as Alternative 1 0

Conclusions Meets P&N#4 for aspen and 

oak Same as Alternative 1

Meets P&N#4 for aspen. 

Partially meets P&N #4 for oak 

(9 acres for Alternative 3 in 

comparison to 30 acres for 

Alternatives 1 and 2

Does not meet the Purpose 

and Need for Action #4. 

Current trends will continue of 

a declining hardwood 

component

P&N #5. Increase Streamflow, Raise Water Table Elevation and Improve Water Quality and Vegetation Conditions within Riparian Reserves Associated with 

Elk Flat, Ash and Swamp Creeks and Their Tributaries. (see pp. 33, 203)

Resource Elements, 

Indicators and Measures

Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary Road 

Construction)

Alternative 3

(No Treatments in Natural 

Stands in NSO Critical 

Habitat)

Alternative 4

(No Action)

5a. Riparian Processes and 

Functions 

-Water Quality – ACS

Objective #4

Increase in near-channel 

riparian vegetation will 

contribute to lowering water 

temperature and reducing 

turbidity.

Same as Alternative 1 except 

that less access will result in 

4,549 feet less treatment along 

Ash Creek to improve near 

channel riparian vegetation 

and reduction in turbidity.

Same as Alternative 1.

Current trends continue 

towards high variability in 

water temperature with the 

lack of near-surface stream 

shade and road interactions 

with channels and road, 

landings and main skid trails.

- Riparian Vegetation – ACS

objective #8

Thinning in RRs 211 acres 

promotes riparian growth with 

the increase in available 

sunlight.

Same as Alternative 1 except 

that less access would limit 

promoting riparian growth on 

3.3 acres of RR from less 

thinning.

Thinning in RRs 165 acres 

promotes riparian growth with 

the increase in available 

sunlight.

Current trends continue 

towards high stand mortality 

and densities, even-aged 

stands, excessive fuels and 

associated risk of 

uncharacteristic fire, 

compromising riparian 

processes.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 99

Resource Elements, 

Indicators and Measures

Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary Road 

Construction)

Alternative 3

(No Treatments in Natural 

Stands in NSO Critical 

Habitat)

Alternative 4

(No Action)

5b.Floodplain and Meadow 

Processes and Functions -

-Water Table Elevation –

changes within range of 

natural variability

Incremental increase in raising 

local water table elevation as 

greater infiltration increases 

water storage with the removal 

of manmade features and the 

restoration of natural contours.

Same as Alternative 1 except 

that less access would limit 

restoring infiltration to 4.3 

acres of RR reducing benefit to 

raising water table elevation.

Same as Alternative 1

Current trends continue 

towards infiltration limited to 

areas outside of manmade 

features as natural ground 

surface contours would not be 

restored.

-Channel Bank Stability –

ACS #7

Improved stability from riparian 

vegetation growth.

Same as Alternative 1 except 

that less access will result in 

4,549 feet less treatment along 

Ash Creek to improve bank 

stability.

Same as Alternative 1

Current trends continue 

towards low riparian vegetation 

abundance and channel bank 

stability. 

-Road Interactions – ACS

#7

Current road interactions 

eliminated Same as Alternative 1 Same as Alternative 1

Current trends continue to 

contribute road runoff sediment 

to channels.

Floodplain Restoration –

ACS #7

Natural contours restored to 

floodplains at old landings, 

meadows; near-stream 

flooding resumed and flood 

energy dissipated.

Reconnection of floodplain to 

channels improves timing, 

variability and duration of 

streamflow.

Same as Alternative 1 except 

that less access would limit 

restoring 4.3 acres of RR 

floodplain and reconnection to 

channels.

Same as Alternative 1

Current trends continue 

towards floodplain and channel 

disconnect at old landings and 

meadow areas.

Woody Debris – ACS #7

Change from the current whole 

tree failure, causing bank 

erosion and debris dams, to 

incremental input of woody 

debris as riparian vegetation 

stabilizes banks

Same as Alternative 1 except 

that less access would limit 

promoting riparian growth on 

3.3 acres of RR from less 

thinning reducing benefit of 

incremental woody debris input 

and reduced sediment 

detention in channel.

Same as Alternative 1

Current trends continue 

towards whole tree failure, 

bank erosion and debris dams.

5c Riparian Habitat 

Connectivity 

Plant communities expand 

laterally and across the 

floodplain.

– Riparian corridor habitat 

conditions – ACS #9

Plant communities expand 

laterally and across the 

floodplain.

Same as Alternative 1 except 

that less access would limit 7.6 

acres of riparian plant 

community expansion.

Same as Alternative 1

Current trends continue 

towards low riparian vegetation 

species diversity and 

population.
Elk Flat LSR Enhancement Project

100 Shasta-Trinity National Forest

Resource Elements, 

Indicators and Measures

Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary Road 

Construction)

Alternative 3

(No Treatments in Natural 

Stands in NSO Critical 

Habitat)

Alternative 4

(No Action)

Conclusions

Meets P&N by restoring 

riparian vegetation and 

floodplains in the Riparian

Reserves, and treating stands 

to improve resilience to 

disturbance. All ACS

objectives attained. Thinning

within the RR will favor

diversity, health and vigor of 

riparian vegetation and 

regulating the incremental 

input of woody debris to 

enhance instream aquatic 

bedform structure. Activities 

add approximately 0.2% ERA

to the project area. ERA is 

reduced by 4% for each mile of 

road decommissioned.

P&N is met. Reduction of 7.6 

acres and 4,549 feet along 

Ash Cr. meeting the P&N from 

Alternative 1 reduces benefits 

to indicators due to less 

access to areas needing 

restoration. ERA for project 

area and road 

decommissioning is the same 

as Alternative 1.

P&N is met. Slightly reduced 

underburning within the Ash 

Creek RR creates a slightly 

reduced response to the P&N 

from Alternative 1. ERA for 

project area and road 

decommissioning is the same 

as Alternative 1.

P&N not met. ACS objectives 

not met. Nonfunctioning 

hydrologic conditions would 

continue degrading the 

watershed and riparian areas. 

No change in ERA from past 

activity. No reduction in ERA 

for road decommissioning.

P&N #6. Manage the National Forest Transportation System and Decommission Unauthorized Routes (see pp. 37, 230, 232, 235)

(also see resource effects to transportation on p. 110)

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary Road 

Construction)

Alternative 3

(No Treatments in Natural 

Stands in NSO Critical 

Habitat)

Alternative 4

(No Action)

1a. Provide Access to 

Established Dispersed 

Recreation Site at Elk Flat

Provided through addition of 

0.1 mile UA route as ML-2 FTS

road.

Same as Alternative 1 Same as Alternative 1 Current condition of no legal 

access continued

1b. Decommission 

Unauthorized Routes

6.4 miles of existing UA routes 

decommissioned Same as Alternative 1 Same as Alternative 1

6.4 miles of inventoried UA 

routes remain on the 

landscape

Conclusions Achieves P&N #6 Same as Alternative 1 Same as Alternative 1

P&N #6 not achieved. No legal 

access provided to established 

site. UA routes continue to be 

present on the landscape.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 101

Table 29 Part II. Comparison of Effects Relative to Key Issues

Issue 1 - Large Trees and Snags

See the information provided for Purpose and Need #2 for large trees and snags (p. 96).

Issue 2 – Road Construction (see pp. 44, 228, 233, 235)

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary Road 

Construction)

Alternative 3

(No Treatments in Natural 

Stands in NSO Critical 

Habitat)

Alternative 4

(No Action)

a. miles of new temporary 

road construction

2.9 

(will be decommissioned at 

end of project)

1.6

(will be decommissioned at 

end of project)

1.5

(will be decommissioned at 

end of project)

0

b. total open [NTS] road 

density (mi/sq. mi.)

2.74

(addition in matrix of existing 

UA Route that accesses 

established dispersed 

recreation site)

Same as Alternative 1 Same as Alternative 1 2.72

c. miles of existing UA route 

decommissioning 6.4 6.4 6.4 0

d. acres meeting soil quality 

standards See Key Issue #5 below

Conclusions

No new FTS roads 

constructed. Decrease of 6.4 

miles of existing UA route. 

Highest new temporary road 

construction.

Same as Alt. 1 except 1.3 

fewer miles of new temporary 

road constructed

Same as Alt. 1 except 1.4 

fewer miles of new temporary 

road constructed

No new temporary roads 

constructed, but 6.4 miles of 

existing UA routes not 

decommissioned

Issue 3 – [NSO] Critical Habitat (see pp. 45,

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary Road 

Construction)

Alternative 3

(No Treatments in Natural 

Stands in NSO Critical Habitat)

Alternative 4

(No Action)

a. Acres of critical 

habitat, per primary 

constituent 

element, 

Maintained or 

Benefitted In:

Core

PCE1 92

Same as Alternative 1

PCE1 87 PCE1 0

PCE2 120 PCE2 0 PCE2 0

PCE3 38 PCE3 0 PCE3 0

PCE4 0 PCE4 0 PCE4 0

Home 

Range/Pr

PCE1 164 PCE1 152 PCE1 0

PCE2 120 PCE2 0 PCE2 0
Elk Flat LSR Enhancement Project

102 Shasta-Trinity National Forest

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary Road 

Construction)

Alternative 3

(No Treatments in Natural 

Stands in NSO Critical Habitat)

Alternative 4

(No Action)

oject Area PCE3 55 PCE3 0 PCE3 0

PCE4 1 PCE4 1 PCE4 0

b. Acres of critical 

habitat, by primary 

constituent 

element, Degraded

(PCE2/3) or 

Modified (PCE4) 

through treatments 

In:

Core

PCE2 0

Same as Alternative 1

PCE2 0 PCE2 0

PCE3 114 PCE3 0 PCE3 0

PCE4 0 PCE4 0 PCE4 0

Home 

Range/Pr

oject Area

PCE2 0 PCE2 0 PCE2 0

PCE3 224 PCE3 0 PCE3 0

PCE4 14 PCE4 0 PCE4 0

b. Acres of critical 

habitat, by primary 

constituent 

element, 

Downgraded 

(PCE2/3)

through treatments 

In:

Core PCE2 0

Same as Alternative 1

PCE2 0 PCE2 0

PCE3 0 PCE3 0 PCE3 0

Home 

Range/Pr

oject Area

PCE2 0 PCE2 0 PCE2 0

PCE3 46 PCE3 0 PCE3 0

b. Acres of critical 

habitat, by primary 

constituent 

element, Removed 

through treatments 

In:

Core

PCE1 0

Same as Alternative 1

PCE1 0 PCE1 0

PCE2 0 PCE2 0 PCE2 0

PCE3 0 PCE3 0 PCE3 0

PCE4 0 PCE4 0 PCE4 0

Home 

Range/Pr

oject Area

PCE1 0 PCE1 0 PCE1 0

PCE2 0 PCE2 0 PCE2 0

PCE3 0 PCE3 0 PCE3 0

PCE4 0 PCE4 0 PCE4 0

c. Acres of suitable and 

dispersal habitat projected in 20 

years within critical habitat

Suitable PCE 

(2/3) 456

Same as Alternative 1

Suitable PCE 

(2/3) 450 Suitable 

PCE (2/3) 0

Dispersal PCE 

(4)

173 Dispersal PCE 

(4) 172 Dispersal 

PCE (4) 0

d. Acres of capable habitat 

projected within 20 to 30 years 

within critical habitat.

Capable (PCE1) 89 Same as Alternative 1 Capable 

(PCE1) 34 Capable 

(PCE1) 0
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 103

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary Road 

Construction)

Alternative 3

(No Treatments in Natural 

Stands in NSO Critical Habitat)

Alternative 4

(No Action)

Conclusions 624 acres of PCEs treated No change in treatments, 

PCE acres affected or 

Conclusions

152 acres of PCEs treated No treatments in any 

PCEs of CH and 

therefore, no effects

Current trends would 

persist, leaving critical 

habitat elements 

vulnerable to loss from 

overstocking, insect and 

disease outbreaks and a 

potential reduction or 

removal of habitat or 

connectivity within 40-

60% of the project area 

CH from potential 

passive crown fire 

Short-term adverse effects to PCE3 

but meets Final Critical Habitat Rule 

recommendations on most acres 

Treatments and acres 

affected under Alternative 2 

are the same as Alternative 

1

No short-term adverse effects but 

meets Final Critical Habitat Rule 

recommendations on 472 fewer 

acres than Alternative 1

PCE1 – At project scale, stand 

conditions moved toward PCE4 and 

PCE3

Affects 23% of total CH

PCE1 – At project scale, 12 

fewer acres moved toward PCE4 

and PCE3

Affects 21% of total CH

PCE2 – 120 acres (100%) 

benefitted and maintained through 

low-intensity prescribed fire that 

reduces surface and ladder fuel 

loading, and contributes toward 

understory diversity

PCE2 – 120 acres (100%) 

maintained. No increase in 

habitat diversity or risk reduction 

benefits from reintroduction of 

low -intensity prescribed fire

PCE3 – 46 acres in home range 

(outside core) downgraded to PCE4 

for 10-30 years. Represents 

reduction in PCE3 habitat quality 

and loss of stand elements on14% 

of PCE3 in home range/project area

PCE3 – Short-term adverse 

effects absent in PCE3 as habitat 

would not be downgraded 

through oak release or radial 

thinning around legacy pine

316 acres PCE3 maintained in 

current condition (44% of CH).

Short- and long-term adverse 

effects to PCE3 elements for an 

increase in hardwood diversity, 

growing conditions and prey base 

(27 ac) and reducing the risk to 

legacy pine (19 ac)

97% of total PCE3/PCE2 in the 

core (and 100% in the project 

area / home range) remain at risk 

to loss from ongoing density 

related-mortality, and the 

potential for high-severity 

uncharacteristic fire

456 acres or 63% of suitable CH 

benefitted/maintained, degraded 

(maintains function with reduction in 

quality) or moved toward suitable 

conditions over 20 years

6 fewer acres of suitable CH 

benefitted/maintained, degraded, 

or moved toward suitable 

conditions over 20 years
Elk Flat LSR Enhancement Project

104 Shasta-Trinity National Forest

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary Road 

Construction)

Alternative 3

(No Treatments in Natural 

Stands in NSO Critical Habitat)

Alternative 4

(No Action)

PCE1=stands with conditions that could support NSO over time; PCE2=Nesting/Roosting; PCE3=Foraging; PCE4=Dispersal

Issue 4 - Boletus Mushroom Collection in Elk Flat: Boletus Habitat in Elk Flat (see pp. 45, 187, 190, 191)

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary Road 

Construction)

Alternative 3

(No Treatments in Natural 

Stands in NSO Critical 

Habitat)

Alternative 4

(No Action)

Boletus Habitat Reduction in 

Elk Flat Meadow - acres of 

conifer removal in Elk Flat 

Meadow

379 354 379 0

Conclusions

Boletus habitat retained on 33 

acres of UTPs in Elk Flat

Meadow.

Same as Alternatives 1 and 3 

except potentially 25 fewer 

acres reduction.

Same as Alternative 1

No reduction unless natural 

disturbance returns portions of 

Elk Flat to natural condition of 

dry meadow

Issue 5 – Machine Piling (see pp. 46, 203, 220)

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary Road 

Construction)

Alternative 3

(No Treatments in Natural 

Stands in NSO Critical 

Habitat)

Alternative 4

(No Action)

Soil Health Also see resource effects to soil health below (p. 109)

a. acres of machine piling Up to 1,461 Up to 1,402 Up to 1,365 0

b. acres of attainment of soil 

quality standards postimplementation-porosity 

standard most relevant of 

SQSs

All Units Meet 90% Porosity 

Standard-legacy compacted 

areas treated with subsoiling

All Units Meet 90% Porosity 

Standard-legacy compacted 

areas treated with subsoiling

All Units Meet 90% Porosity 

Standard-legacy compacted 

areas treated with subsoiling

4 units do not meet porosity 

standard

Watershed Health

Sediment Transport and 

Erosion Rates

Reduced sediment transport 

and erosion rates. Erosive 

energy dissipated and 

sediment detention processes 

optimized. Increased stream 

bank stability leading to 

decreased sediment and 

erosion rates over time adding 

to watershed health.

Without temporary road 

access, some units will have 

reduced stand treatment, 

landings, machine piling and 

lower ground disturbance. 

However, because of the small 

area relative to the Watershed 

scale, the net outcome would 

be no measurable effect to any 

Same as Alternative 1

Continuing trend of Road 

damage from runoff events 

and poor drainage on some 

unauthorized roads and further 

sediment transport and 

erosion.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 105

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary Road 

Construction)

Alternative 3

(No Treatments in Natural 

Stands in NSO Critical 

Habitat)

Alternative 4

(No Action)

Qualitative Evaluation of 

Disturbance at the SubDrainage Scale

Sub-Drainages continue to be 

resilient to disturbance from 

similar activities and respond 

with similar recovery as 

demonstrated by other areas 

with similar activities have 

shown.

resource indicators.

Same as Alternative 1 No Change in Current 

Condition

Equivalent Roaded Area at 

the 5th field scale

Existing Condition ERA for the 

watershed is 8.3% additional 

future activities modeled for 

the watershed raises ERA to 

1.3%, Alternative 1 increases 

ERA by 0.7%, when added to 

existing and future activities on 

public and non-public lands 

within the watershed ERA 

totals 10.3 for future ERA.

Same as Alternative 1

Existing Condition ERA for the 

watershed is 8.3% additional

future activities modeled for 

the watershed raises ERA to 

10.3%

Conclusions

Effects to Watershed Health 

are mostly short-term 

disturbance to water-holding 

properties with little if any 

effects outside of the treated 

units or project area as

measured by the amount of 

equivalent road acre at the 

project, sub-drainage and 

watershed scales.

Nearly the same as 

Alternative 1

Same as Alternative 1

Continues current trend of 

sediment transport and erosion 

contributing to a decline in 

Watershed Health.

Part III. Comparison of Additional Resource Effects

Additional information important to the Decision to be Made, not already covered under the comparison of effects related to Purpose and Need and 

Key Issues is provided below.

Wildlife (see p. 158)

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary Road 

Construction)

Alternative 3

(No Treatments in Natural 

Stands in NSO Critical 

Habitat)

Alternative 4

(No Action)

Threatened or Endangered Species 
Elk Flat LSR Enhancement Project

106 Shasta-Trinity National Forest

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary Road 

Construction)

Alternative 3

(No Treatments in Natural 

Stands in NSO Critical 

Habitat)

Alternative 4

(No Action)

NSO Habitat

Effects to Northern Spotted 

Owl Habitat (inclusive of 

designated Critical Habitat -

see Issue #3 above)

Suitable Nesting, Roosting, Foraging Habitat (N/R, F)

Benefitted through lowintensity fire only (acres)

120 N/R Same as Alternative 1 0 N/R

Current trends remove due to 

large scale disturbance

338 F 360 F 297 F

Maintained in existing 

condition (acres)

0 N/R

Same as Alternative 1

120 N/R

0 F 270 F

Foraging Degraded through 

thinning treatments (acres) 697 675 473 

Foraging Downgraded to 

Dispersal through thinning,

and radial release of oak 

and legacy pine (acres)

98 Same as Alternative 1 52

Removed (acres) 0 Same as Alternative 1 Same as Alternative 1

NSO Dispersal and Capable Habitat

Dispersal Benefited through 

low-intensity fire only 

(acres)

80 82 Same as Alternative 1

Current trends remove due to 

Dispersal Modified large scale disturbance (acres) 179.5 173.5 Same as Alternative 1

Dispersal Removed (acres) 41.5 Same as Alternative 1 Same as Alternative 1

Capable Improved (acres) 329 320 317

Determination for NSO May Affect Not Likely to 

Adversely Affect Same as Alternative 1 Same as Alternative 1 N/A
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 107

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary Road 

Construction)

Alternative 3

(No Treatments in Natural 

Stands in NSO Critical 

Habitat)

Alternative 4

(No Action)

Determination for NSO

Critical Habitat

Likely to Adversely Affect 

Designated Critical Habitat due 

to oak release and radial 

thinning to promote legacy 

pine, general expanse of 

treatments over time and 

space in CH, and impacts to 

snags/down logs

Same as Alternative 1

May Affect, Not Likely to 

Adversely Affect Designated 

Critical Habitat

N/A

Sensitive Species60

Northern Goshawk

Active territories treated 

mechanically 0 Same as Alternative 1 Same as Alternative 1 N/A

Known territories treated with 

low-intensity fire only 1 Same as Alternative 1 Same as Alternative 1 N/A

Suitable habitat Benefitted 

through low-intensity fire only 

(acres)

420 448 252 Current trends remove due to 

large scale disturbance

Suitable habitat Degraded 

through thinning treatments 

and low-intensity fire (acres)

893 871 623

Suitable habitat Downgraded 

through thinning, radial thin 

treatments and low-intensity 

fire (acres)

98 92 Same as Alternative 1

Suitable habitat Removed 

(acres) 0 Same as Alternative 1 Same as Alternative 1

Capable foraging habitat 

Benefitted through thinning

and low-intensity fire (acres)

608 599 596

 60 Associated with Late-Successional Habitat and an indicators of meeting Purpose and Need #1, #2, #4
Elk Flat LSR Enhancement Project

108 Shasta-Trinity National Forest

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary Road 

Construction)

Alternative 3

(No Treatments in Natural 

Stands in NSO Critical 

Habitat)

Alternative 4

(No Action)

Determination for Northern 

Goshawk

May affect individuals but is 

not expected to result in a 

trend toward federal listing or 

loss of viability

Same as Alternative 1 Same as Alternative 1 N/A

Fisher

Associated with LateSuccessional Habitat and an 

indicators of meeting Purpose 

and Need #1, #2, #4

Known denning areas 

mechanically treated / 

underburned

0 Same as Alternative 1 Same as Alternative 1 N/A

Resting/Denning habitat 

Benefitted through lowintensity fire only (acres)

209 Same as Alternative 1 82 Current trends remove due to 

large scale disturbance

Foraging habitat Benefitted 

through low-intensity fire only 

(acres)

211 239 170

Foraging habitat Degraded 

through thinning treatments 

and low-intensity fire (acres)

990 963 720

Suitable habitat Downgraded 

(acres) 0 Same as Alternative 1 Same as Alternative 1

Suitable habitat Removed 

(acres) 0 Same as Alternative 1 Same as Alternative 1

Capable foraging habitat 

Benefitted through thinning

and low-intensity fire (acres)

608 599 596

Determination for Fisher

May have an adverse effect on 

individuals in the project area, 

but not contribute toward a 

loss of viability of the local 

population

Same as Alternative 1 Same as Alternative 1 N/A
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 109

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary Road 

Construction)

Alternative 3

(No Treatments in Natural 

Stands in NSO Critical 

Habitat)

Alternative 4

(No Action)

Over All Conclusions - NSO and Sensitive Species associated with Late-Successional Habitats

NSO

Moves most acreage toward 

increased resilience and larger 

tree sizes, with corresponding 

reduced risk of loss of habitat 

and connectivity for latesuccessional associated 

species

1,743 acres improved over 20 

years through thinning and 

low-intensity fire

Reduced acreage of increased 

tree resilience and size 

classes from reduced thinning, 

though same benefits of lowintensity prescribed fire

1,730 acres improved over 20 

years through thinning and 

low-intensity fire

Moves least acreage toward 

increased resilience and larger 

tree sizes, with corresponding 

increase in potential for habitat 

loss and reduced connectivity

1,346 acres improved over 20 

years through thinning and 

low-intensity fire

Current trends would persist, 

leaving existing and 

developing late-successional 

elements vulnerable to loss 

from overstocking, insect and 

disease outbreaks and a 

potential reduction or removal 

of habitat or connectivity within 

40% of the natural stands from 

potential passive crown fire

57% of LSR Improved 56% of LSR Improved 44% of LSR Improved

Fisher

2,018 acres improved over 20 

years, including increase in 

denning habitat from oak 

release

6% of the LSR

2010 acres improved over 20 

years

65% of LSR

1568 acres improved over 20 

years

No increase in denning habitat

51% of LSR

Northern goshawk

1,921 acres improved over 20 

years

62% of the LSR

1918 acres improved over 20 

years

62% of LSR

1471 acres improved over 20 

years

48% of LSR

Botany (see p. 186)

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary 

Road Construction)

Alternative 3

(No Treatments in 

Natural Stands in 

NSO Critical Habitat)

Alternative 4

(No Action)

TES botanical species no effect (not present) no effect (not 

present)

no effect (not 

present) not present

Soils (see p. 208)

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary 

Road Construction)

Alternative 3

(No Treatments in 

Natural Stands in 

NSO Critical Habitat)

Alternative 4

(No Action)
Elk Flat LSR Enhancement Project

110 Shasta-Trinity National Forest

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary 

Road Construction)

Alternative 3

(No Treatments in 

Natural Stands in 

NSO Critical Habitat)

Alternative 4

(No Action)

Erosion Hazard Rating Low Low Low Low

WEPP(tons/acre) Soil Loss 0.23 0.20 0.18 0.12

Soil cover -litter & duff (%) 60 65 75 100

Resiliency Litter Fall Mitigates Losses on Thinning Acres

Litter Fall Mitigates 

Losses. Thinning on 

103 Fewer Acres

Litter Fall Mitigates 

Losses. Thinning on 

270 Fewer Acres

N/A

LWD (logs/acre)

(minimum, however RPMs 

may require more in specific 

locations)

5-10 5-10 5-15 >15

Compaction-Porosity

(% of undisturbed) Meets 90% Standard Meets 90% Standard Meets 90% Standard 4 Units do Not meet

Conclusions Highest impacts to soils, but meets soil quality standards Less impact to soils 

than Alternative 1 Least impact to soils

No impact to soils but 

decompaction of 

legacy compacted 

areas does not occur

Transportation (see p. 225)

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary 

Road Construction)

Alternative 3

(No Treatments in 

Natural Stands in 

NSO Critical Habitat)

Alternative 4

(No Action)

Public Safety, Road 

Conditions 17.9 miles maintained, .27 reconstructed Same as Alternative 

1

17.4 miles 

maintained, .27 

reconstructed

No scheduled road 

maintenance

Changes to Road MLs

(miles) Increase of ML 2 from 10.63 to 10.73 Increase of ML 2 from 

10.63 to 10.73

Increase of ML 2 from 

10.63 to 10.73 No Change

Changes to Maintenance 

Costs 0.10 miles added = slight increase 0.10 miles added = 

slight increase

0.10 miles added = 

slight increase No Change

Landings

Estimated 78 

(38 existing and 40 new)

All Decommissioned

Estimated 70 

(30 existing and 40 

new)

All Decommissioned

Estimated 62 

(29 existing and 33 

new)

All Decommissioned

44 existing

Conclusions

Contributes to improved road conditions on 17.9 miles of 

maintained road. Changes to road MLs and costs 

negligible. 

Same as Alternative 1

Same as Alternative 1 

except .5 fewer miles 

maintained

Continued existing 

condition
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 111

Cultural Resources (see p. 235)

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary 

Road Construction)

Alternative 3

(No Treatments in 

Natural Stands in 

NSO Critical Habitat)

Alternative 4

(No Action)

Adverse Effects to Historic 

Properties No Adverse Effect Same as Alternative 1 Same as Alternative 1 N/A

Socio-Economics (see p. 239)

Indicator Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary 

Road Construction)

Alternative 3

(No Treatments in 

Natural Stands in 

NSO Critical Habitat)

Alternative 4

(No Action)

Present Net Value -$1,999,896 -$1,956,841 -$2,057,097 N/A

Benefit Cost Ratio 0.75 0.74 0.71 N/A

Employment

Jobs and income generated directly from the industries 

performing the tasks, as well as indirectly from the interindustry purchasing and expenditures

Same as Alternative 1 Same as Alternative 1 No employment 

created

Forest Use

Legal access to dispersed site. Temporary travel 

restrictions and recreation disruption during 

implementation. Improved safety along roads in hazard 

reduction treatment areas. No disruption of range 

allotment management.

Same as Alternative 1 Same as Alternative 1

No provisions of legal 

access to recreation 

site and no 

improvements to road 

safety. No temporary 

disruptions

Conclusions

Jobs, income and revenue generated. Costs are higher 

than monetary benefits, and so PNV is negative and 

benefit/cost ratio is less than 1. Forest use temporarily 

disrupted but with improvements in legal access and 

safety post project. 

Similar to Alternative. 

In general, slightly 

higher PNV and 

slightly lower benefit/ 

cost ratio, but ratio still 

less than 1.

Similar to Alternative 1 

with lowest PNV and 

lowest benefit/cost 

ratio. As with 

Alternatives 1 and 2, 

ratio is less than 1.

No monetary costs, no 

income, and revenue. 

No improved access 

or safety. No 

temporary disruptions 

in Forest use.
Elk Flat LSR Enhancement Project

112 Shasta-Trinity National Forest

Table 29 Part IV. Additional Required Disclosures, Compliance and Consistency

Other Required Disclosures (see p. 248)

Disclosure Item Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary 

Road Construction)

Alternative 3

(No Treatments in 

Natural Stands in 

NSO Critical Habitat)

Alternative 4

(No Action)

Short-term Uses and Longterm Productivity (see p. 248)

There would be a short-term loss of soil productivity on 

areas dedicated to landings (up to approximately 58 

acres). Some of these needs are provided by existing 

landings in the project area. Soil in treatment units in 

action alternatives would meet Forest Plan soil quality 

standards with implementation, and less than 15 percent 

of any unit would be in a non-productive state. Soil 

productivity would be restored in the previously 

windrowed units, and improved by decommissioning 

roads with residual soil compaction. Decommissioned 

roads would return to forest or grassland.

Same as Alternative 1 

except an estimated 

53 acres of landings

Same as Alternative 1 

except an estimated 

47 acres of landings

Legacy compaction 

would continue in 4 

units. Up to an 

estimated 33 acres in 

existing landings.

Irreversible and Irretrievable 

Commitments of Resources

(see p. 249)

There are no irreversible commitments of resources.

The following irreversible commitments of resources 

occur:

The temporary loss of productive forest lands from 

creation of landings on approximately 58 acres

Skid trails, and temporary road uses (of existing 

unauthorized routes) or construction under Alternative 1 

on approximately 8.6 miles

53 acres

8.3 miles

47 acres

6.2 miles

6.5 mile of existing 

unauthorized routes 

and approximately 28 

acres of existing 

landings

Boletus habitat in Elk Flat meadow will be reduced in 

favor of returning natural processes that produce and 

maintain the unique dry meadow habitat.

Same as Alternative 1 Same as Alternative 1

No reduction until 

natural processes 

reset early seral 

habitat

PCE 3 will be degraded (habitat quality reduced) on 

approximately 224 acres, and downgraded to dispersal 

habitat (PCE 4) on approximately 46 acres 

Same as Alternative 1

0 acres PCE3 

Degraded

0 acres PCE3 

Downgraded

No Effect to PCEs

Loss of habitat elements from new landing construction, 

existing landing enlargement or temporary road 

construction for landings on approximately:

4.25 acres of PCE1

8.75 acres PCE3

Same as Alternative 1 Same as Alternative 1 No Effect to PCEs
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 113

Disclosure Item Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary 

Road Construction)

Alternative 3

(No Treatments in 

Natural Stands in 

NSO Critical Habitat)

Alternative 4

(No Action)

Unavoidable Adverse Effects

(see p. 249)

Unavoidable adverse impacts result from managing the 

land for one resource at the expense or condition of 

other resources. Some adverse effects are short-term 

and necessary to achieve long-term beneficial effects. 

Unavoidable adverse effects, discussed by resource in 

Chapter 3, fall within Forest Plan standards and comply 

with the regulatory framework (see Appendix H). 

Same as Alternative 1 

although 82 fewer 

acres involve thinning

or meadow 

enhancement, and up 

to 59 fewer acres may 

be machine piled. The 

reductions may 

reduce impacts on 

those acres.

Same as Alternative 1 

although 267 fewer 

acres involve thinning

or meadow 

enhancement, and up 

to 96 fewer acres may 

be machine piled. The 

reductions may 

reduce impacts on 

those acres. Reduced 

treatments apply to 

natural stands within 

NSO critical habitat.

Current trends 

continue resulting in 

adverse impacts to 

habitat through risk 

exposure.

Energy and Natural or 

Depletable Resource 

Requirements and 

Conservation Potential (see p. 

249)

No unusual energy requirements under Alternative 1. 

Resources conserved. Same as Alternative 1 Same as Alternative 1 N/A

Urban Quality, Historic and 

Cultural Resources and the 

Built Environment (see p. 251)

Historic and cultural resources protected. There would 

be no changes to urban quality or the built environment 

under Alternative 1.

Same as Alternative 1 Same as Alternative 1 N/A

Incomplete or Unavailable 

Information (see p. 251)

Knowledge about many of the relationships and 

conditions of wildlife, hydrology, forests, jobs and 

communities is evolving as research continues. 

However, the basic data and central relationships are 

sufficiently established in the respective sciences in 

order for the deciding official to make a reasoned 

decision to select an alternative and to adequately 

assess and disclose the possible adverse environmental 

consequences. Given the uncertainty of any modeling 

exercise, the results are best used to compare the 

relative effects of the alternatives, rather than as an 

indicator of absolute effects.

Same as Alternative 1 Same as Alternative 1 N/A
Elk Flat LSR Enhancement Project

114 Shasta-Trinity National Forest

Compliance and Consistency (see p. 251 and Appendix H)

Disclosure Item Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary 

Road Construction)

Alternative 3

(No Treatments in 

Natural Stands in 

NSO Critical Habitat)

Alternative 4

(No Action)

Air Quality Requirements –

Local, State, and Federal

(see p.I-1) 

Consistent with State, Federal, and local requirements. 

No federal conformity determination needed. No change 

in attainment status for any criteria pollutant. Burn plan, 

smoke permit, and burn permit will be required prior to 

implementation.

Same as Alternative 1 Same as Alternative 1 N/A

Climate Change- Forest 

Service Strategic Plan and 

California AB 32

(see p. I-5)

FS Strategic Plan-Alternative 1 is consistent through 

improving the ability of the forest to remain healthy and 

resilient.

CA AB-32 – Alternative 1 is consistent with AB 32 

through sustainable management practices. Alternative 

1 will not likely not have an adverse net effect on carbon 

cycling.

Same as Alternative 1 Same as Alternative 1

Current trends 

continue leaving the 

stands in the Project 

area less resilient.

Endangered Species Act

(see p. I-6)

Compliant with section 7 consultation procedures under 

the Endangered Species Act.

Determinations under Alternative 1 are: May Affect, Not 

Likely to Adversely Affect for the Threatened NSO and 

Likely to Adversely Affect its Critical Habitat; and May 

Affect, Not Likely to Adversely Affect the Endangered 

Gray Wolf 

Same as Alternative 1

Same as Alternative 1 

for the NSO and Gray 

Wolf and 

May Affect, Not Likely 

to Adversely Affect 

NSO Critical Habitat

N/A

Environmental Justice – E.O. 

12898 (see p. I-6) 

No disproportionate adverse effects on low income or 

minority populations because of implementation of any 

of the Elk Project action alternatives. There are expected 

to be no disproportionate adverse effects on Native 

Americans because of implementation of any of the Elk 

Project action alternatives.

Same as Alternative 1 Same as Alternative 1 N/A

Invasive Species – E.O. 

13112, DR 955-10, FSM 2900 

(see p. I-8)

In compliance. No known populations of any weed 

species rated moderate or high risk within the project 

area. Any new populations found will be excluded. 

Prevention of introduction measures are in place.

Same as Alternative 1 Same as Alternative 1

No known populations 

of any moderate or 

high risk species I 

project area.

Migratory Birds – E.O. 13186 

(see p. I-9)

In compliance with the 2008 and 2014 Migratory Bird 

MOU with the USDI-FWS. The project design, treatment 

prescriptions and RPMs will help ensure treated areas 

continue to provide necessary habitat to maintain a 

diversity of species at both the stand and landscape 

scale, and reduce the potential for adverse effects. See 

effects to TES bird species and MIAs.

Same as Alternative 1 Same as Alternative 1 N/A
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 115

Disclosure Item Alternative 1

(Modified Proposed Action)

Alternative 2

(No New Temporary 

Road Construction)

Alternative 3

(No Treatments in 

Natural Stands in 

NSO Critical Habitat)

Alternative 4

(No Action)

Watch List Botanical Species

(DR-9500-4)

(see p. I-10)

In compliance with DR-9500-4. The Project will benefit 

Jones’ muhly through removal of dead thatch during 

burning. RPMs, SOPs, and BMPs in place for protecting 

soils and improving and protecting hydrological function 

will provide protection for this species. 

Same as Alternative 1 Same as Alternative 1 N/A

Clean Water Act and Water 

Quality-Basin Plan (see p. I11)

In compliance with the Clean Water Act for controlling 

non-point pollution sources. Conditional Waiver of Waste 

Discharge Requirements, BMPs are applied to prevent 

impacts to water quality.

Same as Alternative 1 Same as Alternative 1 N/A

National Forest Management 

Act (NFMA) (see pp. I-12)

a. NFMA-Findings

Compliant with required NFMA findings for soil, slope, 

watershed conditions, regeneration, water conditions, 

harvesting system, and land suitability

Same as Alternative 1 Same as Alternative 1 N/A

b. NFMA-Forest Plan

Consistency (see pp. I-12-I30 and also individual 

resource sections in Chapter 

3)

Consistent with Forest Plan Same as Alternative 1 Same as Alternative 1 N/A

Draft Environmental Impact Statement

Shasta-McCloud Management Unit 117

Alternatives Considered but Eliminated from Detailed Study

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

alternatives and to briefly discuss the reasons for eliminating any alternatives that were not developed in 

detail (40 CFR 1502.14). Alternatives to the Proposed Action may be suggested by the public or other 

agencies or were considered by the interdisciplinary team during development of the proposed action. 

Alternatives are eliminated from detailed consideration if they are: Illegal, fail to meet the purpose and need 

for action, technologically infeasible, clearly unreasonable, duplicate actions within the existing range of 

alternatives, the decision has already been made, would cause unreasonable environmental harm, cannot be 

implemented, or are remote or speculative. The following alternatives were considered, but eliminated from 

detailed study.

The Original Proposed Action as Scoped

The original Proposed Action that was scoped in February of 2013 (USDA-FS, 2013b) and published in the 

Notice of Intent (USDA-FS, 2013) is similar to Alternative 1, the Modified Proposed Action. However 

Alternative 1 includes refinements in the description of the Purpose and Need for Action and modifications of 

the Proposed Action. Modifications and refinements were a result of public comment during the scoping 

period, corrections, changed circumstances (primarily ongoing spread of mortality), and further analysis.

More information on why modifications to the original Proposed Action were made are included in the 

introduction of Alternative 1 (see p. 38). Since considering both the original Proposed Action and Alternative 

1 would be redundant, this alternative was dropped from detailed consideration.

Alternative 5: No Treatments in Elk Flat Meadow

Alternative 5 responds to Alternative 3 -No Treatments of Natural Stands within Designated Critical Habitat 

for the Northern Spotted Owl is responsive to this issue and is considered in detail. As Recovery Plans are not 

regulatory, they cannot be violated. However, as described earlier in this Chapter, Forest Plan standards and 

guidelines direct that the Forest maintain or enhance habitat for threatened, endangered, and sensitive (TE&S) 

species consistent with individual species recovery plans (p. 4.30).

Emphasizing the protection and enhancement of the forest vegetation conditions and elements that serve as 

suitable habitat for late-successional dependent species (including the NSO) is integral to the Purpose and 

Need for Action and Forest Plan management direction. The predicted effects on NSO, all suitable habitat, 

dispersal habitat as it relates to connectivity, and designated critical habitat are analyzed for all alternatives 

considered in detail to measure the achievement of the Purpose and Need. This information is summarized in 

Chapter 2 (Table 29, p. 116) and in Chapter 3 in the Wildlife section.

The indicators specific to this issue are as follows:

a. acres of critical habitat, per primary constituent element, maintained/benefitted in NSO core areas, 

home ranges and the project area,

b. acres of critical habitat, by primary constituent element, degraded, downgraded or removed through 

treatments in NSO core areas, home ranges and the project area,

c. acres of suitable and dispersal habitat projected in 20 years within critical habitat, and

d. acres of capable habitat projected within 20 to 30 years within critical habitat.

These issue indicators are used to measure the scale of how the alternatives considered in detail meet the 

management guidance, and the special management considerations for critical habitat subunit ECS-3, in the 

2012 Final Critical Habitat Rule for the Northern Spotted Owl. 
Elk Flat LSR Enhancement Project

118 Shasta-Trinity National Forest

Issue 4 – Mushroom Collection, described on page 45, regarding negative impacts from the meadow 

enhancement treatment to edible mushroom growth and collection activities near and within Elk Flat. 

Alternative 5 would eliminate the 518-acre meadow enhancement treatment in unit 402.

Discussion

Alternative 5 was eliminated from detailed study because it would not reasonably meet the purpose and need 

for meadow restoration in Elk Flat. Encroaching conifer would not be removed, and the natural fire regime 

that helps sustain the meadow habitat would not be returned.

Although Alternative 5 as a whole was eliminated from detailed consideration, aspects of it were adopted into 

the Modified Proposed Action (Alternative 1), and protections for mushroom habitat would be implemented

through soil and coarse woody debris protections. Some species of edible mushrooms also benefit from soil 

disturbance and fire. Alternative 1 preserves some forest vegetation in Elk Flat Meadow that would function

as mushroom refugia. The Modified Proposed Action includes the following layout design, resource 

protection measures, standard operating procedures, and Best Management Practices to help protect 

mushroom habitat:

• UTP Placement – Mushroom habitat was considered in the placement of the UTPs in Elk Flat

meadow.

• Forested and Large Tree Refugia - The design of Alternative 1 preserves refugia for mushrooms 

within and around the Elk Flat meadow. The larger predominant trees within the interior of the 

meadow typically have signs of decadence such as large limbs, forked or broken tops and cavities and 

provide refugia. A basal area of approximately 60 square feet per acre of the largest diameter trees 

would be retained where the meadow transitions into conifer stands along the edge. Plantations 

bordering the meadow would receive a modified thinning prescription to transition between meadow 

and forest, creating a ‘feathered’ effect of few trees within the meadow transitioning to an open forest 

stand along the meadow’s edge. See the description of the Meadow Enhancement treatment on pages 

53 and in Appendix A, page B-35, and the description of plantation thinning with meadow 

enhancement on page B-28.

• Soil and Organic Matter Protection - Alternative 1 protects soils and organic matter at Elk Flat in the 

following ways:

a. RPM 10 on page 83 restricts heavy equipment operation in Elk Flat to frozen ground or in areas

where work on dry soils not result in significant adverse effects from soil displacement

b. RPM 11 on page 83 protects embedded coarse woody debris in the Riparian Reserves in Elk Flat

and elsewhere.

c. RPM 24 on page 85 describes litter and duff retention requirements during underburning.

d. RPM 25 on page 86 describes protections for large predominant trees during underburning.

e. RPM 41 on page 89 describes snags, down logs and clumps of trees to be retained in the Meadow 

unit.

f. Required monitoring will provide information for before and-after-treatment effects for fungi (see 

Monitoring item 5 on page 91). Information learned from monitoring is applied to ongoing and 

future actions.

g. Standard Operating Procedures (SOPs) and Best Management Practices (BMPs) adhered to on 

similar projects also protect soil quality, which in turn helps protect edible mushroom habitat. In 

particular see Appendix C, SOP numbers 5, 6 and 7 on page D-2 for soil and duff protections and 

Best Management Practice implementation. The list of the most pertinent BMPs is provided 

starting on page D-4.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 119

Effects to boleltus mushrooms is included in Chapter 3 in the effects analysis for the botanical resources for 

the action alternatives. Additionally, No Action (Alternative 4) is considered in detail and shows the 

difference between the action alternatives in effects pertaining to Elk Flat meadow and boletus mushroom.

Alternative 6: Limit Harvest to Trees Less than 10 Inches in Diameter

Suggested by a commenter, Alternative 6 responds to Issue 1 – Large Trees and Snags (see page 44). 

Alternative 6 provides a 10-inch maximum DBH for thinning treatments. It is eliminated from detailed study 

because modeling shows that while it would reduce fuel ladders in the short-term, it would not meet or 

seriously diminish the project’s ability to meet major aspects of the purpose and need including: #1-Risk 

Reduction in Early, Mid and Late-Successional Habitat and Increased Stand Resilience to Disturbance; #2 

Accelerate Development of Late-Successional and Old-Growth Forest Characteristics and Promote LateSuccessional Habitat Connectivity; #3 Restore Meadow Habitat in Elk Flat; and compromise improving 

vegetative conditions in Riparian Reserves in #5 (Payne, 2015a).

Discussion

Alternative 6 would not address overstocking nor would it sufficiently reduce existing standing and dead fuels

in the LSR, and the Riparian Reserves. Group selection and radial thinning treatments within plantations and 

natural stands would not be implemented since effective implementation of these prescription elements could 

not be achieved with a 10-inch diameter limit.

Trees within the natural stands and plantations range from less than 1-inch to 50 inches DBH with a very few 

remnant predominant trees. Many trees in both stand types over 10 inches DBH that are competing with the 

larger trees for site resources and some that are infected with black stain or annosus root disease. Because this 

alternative would retain all trees over 10 inches DBH, competition would not be sufficiently alleviated in 

treated stands and a large proportion of diseased trees would remain on the landscape. This alternative would 

result in continued stress-induced mortality with fewer large diameter trees and snags developing and 

persisting on the landscape over time. Suppressed conifer would continue to decline within stands at an 

unnatural rate as late successional habitat develops. Competition would not be effectively reduced in early, 

mid- and late-successional mixed conifer and pine dominated stands or plantations. Consequently, there 

would be minimal improvement to individual tree growth acceleration and larger diameter snag recruitment, 

indicating this alternative does not sufficiently develop a trend toward desired late-successional stand 

characteristics. The release prescriptions for oak and aspen would only be partially implemented leaving 

hardwoods overtopped and suppressed by conifers larger than 10 inches DBH.

The desired condition is derived from the Forest Plan, including the Late-Successional Reserve Assessment as 

required by the Northwest Forest Plan. The project is designed to improve the viability of the Elk Flat LSR, 

increase hardwood diversity, enhance meadow habitat and improve and maintain stream channel and Riparian

Reserve function consistent with the Aquatic Conservation Strategy objectives of the Northwest Forest Plan.

Effects to the LSR, Riparian Reserves and Critical Habitat will be analyzed for each alternative in the 

resource specific effects analyses and as part of the analysis for compliance with vegetation diversity as 

required by the Forest Plan. The Forest Plan integrated the requirements of the Northwest Forest Plan. 

Compliance with the Forest Plan is covered in individual Chapter 3 resource sections and in section starting 

on page 249.

Alternative 7: Eliminate the Use of Machine Piling within Treatment Units and 

Substitute Hand Piling

Suggested by a commenter, Alternative 7 eliminates machine piling and substitutes hand piling. Alternative 7 

responds to Issue 5 – Machine Piling regarding impacts to soil and watershed health from machine piling. 
Elk Flat LSR Enhancement Project

120 Shasta-Trinity National Forest

Alternative 7 was not considered in detail because detrimental soil impacts from machine piling are not 

supported by the local monitoring data and best available science for soil types within the project area. 

Additionally elimination of machine piling would not meet the Purpose and Need for Action for “risk 

reduction in early, mid and late-successional habitat and increased resilience to disturbance" on those acres 

prescribed for machine piling.

Discussion

Alternative 1 utilizes machine piling as a pretreatment before underburning to increase consumption of excess 

fuels over what underburning alone would accomplish, and to limit adverse effects to wildlife habitat during 

the underburning (page 52). The units prescribed for machine piling have heavy concentrations of coarse

woody debris, typically more than 40 tons per acre. Eliminating machine piling within the units (landings 

would still be piled) would not allow for safe and effective reductions of the larger sized material (>12 inches 

in diameter) within various treatment stands on up to 1,461 acres plus the landings on the remaining thinning

units.

Soil surveys and past project monitoring completed within portions of the Elk Flat LSR Enhancement project 

area, and on the McCloud Flats, demonstrates there are no significant negative effects from machine piling on 

the soils resource. The design of the Proposed Action, resource protection measures, and standard operating 

procedures and Best Management Practices would be implemented to reduce, if not eliminate, the potential 

for adverse effects to soils, hydrologic and watershed function.

• Treatment-generated and natural fuels in excess of desired retention levels would be piled with 

mechanized equipment such as an excavator or tractor with a mounted brush rake or grapple designed 

to minimize soil disturbance (see page B-36).

• RPM 483on page 83 limits pile size to decrease potential for soil damage.

• Standard Operating Procedures (SOPs) and Best Management Practices (BMPs) adhered to on similar 

projects also protect soil quality. In particular see Appendix C, SOP numbers 5, 6 and 7 on page D-2

for soil and duff protections and Best Management Practice implementation. The list of the most 

pertinent BMPs is provided starting on page D-4. Practice 5.6 is of particular importance in 

decreasing the potential for soil compaction.

Effects to soils are analyzed in Chapter 3 under the action alternatives with respect to achieving the soil 

quality standards and in comparison to the no action alternative.

Alternative 8: Limit Harvest to Trees Less Than 20 Inches in Diameter within 

the Elk Flat Late-Successional Reserve

Suggested by a commenter, Alternative 8 responds to Issue 1 – Large Trees and Snags described on page 44.

Thinning of trees with a 20 inch or less DBH would be the only silvicultural treatment applied. While not as 

restrictive as Alternative 6 in that it provides for a larger diameter limit that only applies to the LSR, 

Alternative 8 is dropped from consideration in detail because it would not meet the Purpose and need for 

Action in ways similar to those described for Alternative 6; stand heterogeneity would be reduced in all stands 

in the LSR compared to the Proposed Action, two thirds of the stands would not reach desired density, and 

hardwoods would continue to decline as a stand component.

Discussion

Modeling of Alternative 8 (Payne, 2015) predicts a 20 inch upper diameter limit would reduce stocking to 

desirable levels in roughly one third of natural stands in the LSR. The higher basal area retention resulting 

from a 20” upper diameter limit would not meet stand health objectives, result in decreased structural 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 121

heterogeneity, and leave stands at a higher risk for continued black stain spread and mortality. In most stands 

basal area would be retained above 180 ft.2

/ac, stand heterogeneity would be decreased by removing more 

trees less than 20 inches DBH to approach desired basal areas. Radial thin treatment would be dropped where 

release objectives could not be met and thinning would be less effective at promoting long-term health and 

survival of predominant pine. In the remaining two thirds of the stands, all trees less than 20” DBH would be 

removed and stand density would still be above a risk threshold for western pine beetle mortality.

The desired condition of structural heterogeneity for habitat would not be achieved when thinning to a 20” 

upper diameter limit. Prescribed selection criteria that would retain multiple canopy layers, smaller understory 

trees and a patchy understory would not be implementable. Few to no trees under 20 inches (excluding 

unthinned patches) would be retained resulting in a simplified stand structure of essentially a single layer of 

overstory trees. Isolation of healthy pine and increased sunlight to the forest floor would be hampered, 

decreasing the ability to reduce black stain spread, in turn resulting in greater future losses of larger pine. 

Hardwoods, which are mostly within the LSR stands, would remain overtopped and continue to decline as a 

stand component. A substantially higher component of conifers would be left around oaks, leaving higher 

levels of shade and competition. Oak release would be less effective and last for a shorter duration, leading to 

earlier oak decline.

Alternative 9: No New Temporary Road Construction

Alternative 9 is responsive to the issue regarding road construction. It differs from Alternative 2 in that it also 

includes no temporary road construction to access the landings (landing driveways). Alternative 9 was 

dropped from detailed analysis in favor of consideration of Alternative 2 that is considered in detail, because 

Alternative 9 would require more construction of new landings than Alternative 2 as discussed below.

Discussion

Alternative 2 considers in detail the effects relative to resources and meeting the Purpose and Need for Action 

of no new temporary roads other than landing access driveways. Alternative 9, eliminating new temporary 

roads entirely was first considered but dropped from detailed analysis. Under Alternative 9, there is a reduced

ability to meet the Visual Quality Objectives along the Pilgrim Creek Road. Landings would need to be 

placed to minimize the visual impact of the landings and landing piles along these sensitive viewing corridors. 

Without the use of temporary roads, the landings would be adjacent to the main roads creating a visual 

impact. Under Alternative 9, approximately 7additional new landings over Alternative 2 may need to be 

created where existing FTS roads or unauthorized routes do not access existing openings or landings.

The Modified Proposed Action incorporates measures to protect soils, forest health and wildlife from the 

construction and use of temporary roads by:

• Project Design – The Modified Proposed Action is designed to minimize disturbance from temporary 

roads by:

a. Previously created skid trails unauthorized routes would serve as temporary roads rather than 

constructing new temporary roads when possible to avoid new disturbance (see Appendix A page 

B-44).

b. Sections of unauthorized routes used as haul routes would be improved for equipment access and 

hauling as needed (to decrease resource damage), and

c. Existing unauthorized routes, new temporary roads, and landings would be decommissioned at

the completion of the project.
Elk Flat LSR Enhancement Project

122 Shasta-Trinity National Forest

• Resource Protection Measures would be implemented:

a. RPM 15 on page 84 – Specifies revegetation and mulching during temporary road 

decommissioning.

b. RPM 16 on page 84 – Requires road construction and maintenance (including temporary roads) 

be managed for consistency with LSR standards and guidelines and that they will be kept to a 

minimum, and routed through non-late-successional or low quality late-successional habitat 

where possible.

c. RPMs 31-39 starting on page 87 – Limit timing of disturbance to protect wildlife.

• Standard Operating Procedures and Best Management Practices for resource protection would be 

followed (see Appendix D).

Effects to soils from temporary road construction, use and decommissioning are assessed in Chapter 3 on 

soils, forest health and wildlife. Forest Transportation System roads are not considered within the soils 

resource under the Forest Plan (pp. O-2) and are therefore not included in the soils resource effects.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 123

Chapter 3. Affected Environment and Environmental 

Consequences

Introduction

This chapter describes aspects of the environment likely to be affected by the proposed action and 

alternatives. The direct, indirect and cumulative environmental effects that would result from undertaking the 

proposed action or alternatives are described. Effects are quantified where possible and qualitative discussions 

are included. Together these descriptions form the scientific and analytical basis for the comparison of effects 

displayed in chapter 2 (starting on page 94).

The planning record for the project includes project-specific information, including resource reports and 

results of other field investigations. Individual reports, input and analysis from the record are summarized and 

referenced in this chapter. Some reports are included in the appendices or are incorporated by reference. The 

planning record is located at the Mount Shasta Ranger Station.

Approach to Cumulative Effects Analysis

Past, present, and reasonably foreseeable future actions were considered, in order to assess accumulated 

impacts. According to the Council on Environmental Quality NEPA regulations, a “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).

Spatial and temporal boundaries are the two critical elements to consider when deciding which actions to 

include in a cumulative effects analysis. Spatial and temporal boundaries set the limits for selecting those 

actions that are most likely to contribute to a cumulative effect. The effects of those actions must overlap in 

space and time for there to be potential cumulative effects (FSH 1909.15 (15.2)). Therefore the relevant 

boundaries and projects assessed for cumulative effects vary by resource. Each resources’ cumulative effect 

area can be different and possibly larger or smaller. Relevant cumulative effects are documented for the 

resource in the project specialist reports and summarized in this chapter.

The cumulative effects analysis for each environmental component or resource area is guided by and 

consistent with the Council on Environmental Quality letter “Guidance on the Consideration of Past Actions 

in Cumulative Effects Analysis” of June 24, 2005. The current environmental conditions on the landscape 

reflect the aggregate impact of all prior human actions and natural events that have affected the environment 

and might contribute to cumulative effects and can be used as a proxy for the impacts of past actions (36 CFR 

§ 220.4 (f)). The memo 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.” Cumulative effects are discussed here as changes in the existing condition due to present and future 

activities, including the effects of the alternative being discussed unless otherwise noted.

For each resource area, direct and indirect effects of the proposed action were reviewed, in accordance with 

the Forest Service Handbook, and relevant spatial and temporal boundaries for cumulative effects analysis 

were determined. For the Elk project, the longest relevant temporal boundary in this review was 30 years. The 

largest spatial boundary encompassed the 5th field watershed, Ash Creek, where the project is located. The 

wildlife cumulative effects buffer, however, extended just beyond the Ash Creek 5th field watershed 

boundary. As such, the largest combined boundary which is comprised of the Ash Creek 5th field watershed 

combined with areas where wildlife cumulative effects buffer boundaries extend outside the watershed 

boundary, was used (Elk Project general cumulative effects review area). Please refer to Refer to EIS 
Elk Flat LSR Enhancement Project

124 Shasta-Trinity National Forest

Appendix G-Ongoing and Future Activities Map for a spatial representation of this area. All other spatial and 

temporal boundaries either fell within the largest boundary or were unneeded.

Silviculture and Forest Health

A Vegetation Report (Payne, 2015b) was completed for this project and is incorporated by reference. 

Information relevant to this decision is summarized here.

Introduction

Purpose and Need Applicable to Silviculture and Forest Health

Silviculture treatments for the Elk Flat Late Successional Reserve Enhancement Project are designed to help 

achieve the following elements of the purpose and need: #1-Risk reduction in early, mid and late-successional 

habitat and increased stand resilience to disturbance; #2-Accelerate development of late-successional and oldgrowth forest characteristics; #3-Restore meadow habitat in Elk Flat; and #4-Retain hardwoods as a stand 

component at density levels commensurate with development of late-successional stands. Hydrologic function 

restoration (Purpose and Need #5) is also partially related to silviculture and forest health through the health 

of forest stands within Riparian Reserves, as described in the Hydrology Section (starting p. 193). The 

existing and desired conditions relating to the Purpose and Needs are provided in Chapter 1.

Issues Applicable to Silviculture and Forest Health

Issue #1 applies to Silviculture and Forest Health. Concern was raised that large tree and snag removal and 

group selection would negatively impact forest health and late-successional ecosystems in Late-Successional 

Reserves, Riparian Reserves and Critical Habitat. Concern was raised that these treatments would prevent 

rather than facilitate forest succession processes, and as such would not be consistent with the Northwest 

Forest Plan. The Environmental Consequences section discusses silviculture treatment effects relative to the 

above issues.

Methodology

Stand exam data was collected in spring of 2007 and 2010. Exam data, modeling using the Forest Vegetation 

Simulation (FVS) program, multiple field observations, remote aerial imagery and Forest GIS data analysis 

collectively were used to identify forest attributes including distribution of vegetation communities, forest 

structure, composition and density, and mortality from insect and disease activity. FVS modeling was used to 

analyze changes to stands over time under scenarios including: 1) implementing proposed thinning

treatments, 2) with the advent of wildfire, and 3) with no management actions occurring. Further descriptions 

and discussion of the methodology can be found in the silviculture report (Payne, 2015b).

When discussing silviculture treatments and their effects, the effects are considered at the stand level. To 

achieve purpose and need objectives often more than one type of treatment is applied in a stand – for instance 

leaving unthinned patches, thinning to reduce density and thinning to release oak are distinct components of a 

silvicultural prescription that collectively help meet objectives of improving stand resilience and developing 

and retaining late successional forest characteristics. Typically, a forest stand is the smallest administrative 

unit used to describe forest conditions and implement and monitor treatments and conditions over time. 

Silviculture treatments for Alternatives 1 through 3 are described in Chapter 2with unit (stand) acres, timber 

harvest acres and acres of subtreatments (such as radial thinning and oak release) summarized in Table 7, 

Table 12, and Table 17, respectively. Table 22 summarizing the alternatives in Chapter 2 limits the display to 

harvest acres due to space constraints in the table. For clarification, tables used to display effects in this 

section are considering treatments at the stand level, or by delineated unit. For example, the effects of oak 

release are displayed in terms of the stands treated where oak is known to occur.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 125

Indicators and Measures

Table 30 lists resource and key issue indicators and measures used to evaluate effects to Silviculture and 

Forest Health. Discussion of the rationale for each indicator follows.

Table 30. Indicators and Measures of Effects for Silviculture and Forest Health

P&N, Key 

Issue, or 

Resource 

Effect

Resource Element Indicator Source

P&N #1, Key 

Issue #1, 

Resource

Stand Resilience

Acres of stand density reduction that improves 

stand growth and resilience. 

SDI below pine-limiting threshold

LSRA objectives I and 

III) (LSRA pp. 174-179, 

pp. 163) Forest Plan p. 

4.63

Edson WA (p.22) Risk from Large-Scale 

Disturbance

Acres of treatment and risk reduction of insect 

and disease outbreak

P&N #2, 

Resource

Accelerated 

Development and 

Retention of Late-Seral 

Characteristics

Acres early and mid-successional treated to 

accelerate development of late successional 

characteristics Forest Plan ( p. 4.63) 

Acres of natural stands thinned to retain late LSRA (p. 164) -

successional characteristics and accelerate midsuccessional development

Key Issue #1, 

Resource Large Trees and Snags

Number of trees greater than 24 inches diameter 

breast height (DBH) immediately post-treatment 

and projected in 20 years based on comparative 

modeling of the alternatives.

Number of snags greater than 20 inches dbh 

projected in 20 years from comparative 

modeling.

P&N #2 & #4, 

Resource Vegetation diversity

Development of stand level heterogeneity and 

species diversity

Forest Plan pp. 4.4, 

4.14), LSRA (p. 164) 

NWFP (p. B-2) Acres promoting growth and resilience of 

hardwoods including aspen, commensurate with 

late successional stand development.

P&N #3, 

Resource Meadow Acres of reduced conifer encroachment at Elk 

Flat meadow

LRMP (Forest Plan pp. 

4.4, 4.14) LSRA (p. 

205), Edson WA (p. 105)

Discussion of Indicators

Acres of Reduced Stand Densities and Acres of Risk Reduction of Insect and Disease Outbreak

Without disturbance, forest stands continually grow until die-back begins, largely from competition between 

trees for resources (e.g., water, nutrients, and sunlight). With increasing high density and competition for 

resources, tree growth slows, tree vigor declines and forest stands become increasingly at risk of large scale 

disturbance from events including insect outbreaks and high intensity fire (Kolb, et al., 1998; Agee, et al., 

2005; Fettig, et al., 2007). Thinning reduces competition and frees up resources that support the vigor and 

resilience of the residual forest stand. Stand resilience in this context includes the capacity to persist through 

and re-organize after disturbance, adapt to shifting environmental conditions, and maintain basic ecosystem 

structure and function over time (Churchill, 2013). Acres of reduced stand densities can be compared across 

alternatives to gage their effectiveness at meeting Purpose and Need #1 Resilient stands in turn are better 
Elk Flat LSR Enhancement Project

126 Shasta-Trinity National Forest

positioned to persist over time, retaining and promoting the development of late-successional stand 

characteristics (Key Issue #1).

Acres of Early and Mid-Successional Forest treated to retain and accelerate development of 

Late-Successional Characteristics

Thinning young stands to delay or reduce inter-tree competition speeds the development of large diameter 

trees as well as development of vertical diversity and species diversity (Garman, et al., 2003). Acres of 

thinning that accelerate and promote development of late successional characteristics in early and midsuccessional plantations are compared across the alternatives to analyze effectiveness at achieving the purpose 

and need.

Number of Trees Greater than 24 Inches Diameter Breast Height (DBH) Immediately PostTreatment and Projected in 20 Years Based on Comparative Modeling of the Alternatives.

Desired conditions of late-successional forest include having variability of vegetative characteristics reflective 

of differences in site capability and the environment (elevation, slope, aspect, soils, etc.) across the landscape 

(LSRA p. 162). Large overstory trees and snags are key attributes while not reflective of all desired 

characteristics of late successional forest. Structural and species diversity, as well as stand resilience (i.e. 

ability to maintain ecosystem structure and function over time) are also important attributes. 

Number of Snags Greater than 20 Inches DBH Projected in 20 Years

Large trees per acre can be reasonably estimated using stand inventory data and aerial imagery. Recent and 

ongoing bark beetle mortality makes snag estimations challenging. Snag levels have changed markedly from 

one year to the next and are expected to continue changing as densities remain high and bark beetle activity 

continues. Average trees per acre over 24 inches DBH and snags per acre over 20 inches are used in this 

analysis for comparison across the alternatives to address issue #1 and analyze effectiveness at meeting the 

purpose and need.

Development of stand heterogeneity and species diversity

Stand diversity is a key element of forest resiliency and of late successional habitat (Churchill, 2013; Lutz, et 

al., 2013). In this context, diversity refers to stand level structural heterogeneity and species diversity. Stand 

heterogeneity (i.e. a fine-scale mosaic pattern at the stand level) promotes forest resilience by breaking up fuel 

continuity and continuity of conditions that support the spread of disease and epidemic insect outbreaks 

(Churchill, 2013). It is important to consider stand diversity in the context of the naturally occurring 

vegetation community or CWHR type61) and a natural disturbance regime of frequent fire. Forest stand 

structure has changed from open park-like stands dominated by large, fire-resistant trees to over-dense evenaged stands (Weaver, 1943; Convington & Moore, 1994; Moore, et al., 2004), that are more susceptible to 

crown fire ( (Weatherspoon, et al., 1992; Skinner, et al., 1996), and contain trees that are less likely to survive 

fire because of their smaller diameter, thinner bark and low hanging crowns (Fitzgerald, 2004).

Acres Promoting Growth and Resilience of Hardwoods

Acres of treatments that promote the survival and growth of hardwoods, promote the health and longevity of 

large overstory pine, and increase species and structural diversity are compared across the alternatives to 

analyze effectiveness at achieving the purpose and need and addressing resource concerns.

Meadow Enhancement

 61 California Wildlife Habitat Relationships vegetation type (CDFW, 2008). Key to habitat types found here: 

http://www.dfg.ca.gov/biogeodata/cwhr/wildlife_habitats.asp
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 127

Conifer encroachment into Elk Flat is easily observed in comparative aerial imagery from the 1940s and 

today. Acres of reduced conifer encroachment are compared across the alternatives to analyze effectiveness at 

restoring early seral vegetation conditions.

Boundaries

To determine relevant past, present, and foreseeable future projects, spatial and temporal boundaries must be 

defined (36 CFR § 220.4 (f)). For the effects analysis the direct and indirect effects of the Elk project relative 

to Silviculture and forest health are conditions influencing stand structure and composition and stand density.

Spatial Bounding

Spatially, the conditions influencing stand structure, composition and stand density in the project affects forest 

conditions within and immediately adjacent to the treated units. As such, the spatial context being considered 

is the Elk Flat LSR Enhancement Project boundary. This is because this represents area potentially influenced 

by effects from proposed treatment activities.

Temporal Bounding

Temporally, effects of changes to stand structure, composition and density, including trees larger than 24

inches DBH and snags from project activities are expected to remain effective for about twenty years. Beyond 

this time, increases in density from stand growth will begin to cancel the improved resilience and accelerated 

development of late-successional characteristics associated with the silviculture treatments. Subsequent 

prescribed fire entries will reduce accumulations of surface and small ladder fuels but not appreciably affect 

forest structure, composition or density.

The baseline year used for this analysis is 2014 as the existing condition. The description of the existing 

condition includes the accumulation of past activities, which have influenced vegetation. In the effects 

discussion, “short-term” refers to effects over the twenty year period from the time the activity was 

accomplished. Beyond twenty years, effects are considered “long-term.” The current environmental 

conditions reflect the aggregate impact of all prior human actions and natural events that have affected the 

environment and might contribute to cumulative effects, and are a proxy for the impacts of past actions.

Affected Environment

The purpose and need in chapter 1 fully describes existing vegetation conditions. Of note is the intertwined 

relationship of natural fire exclusion, forest stand densification and subsequent insect and disease activity, and 

impacts on the development and sustainability of desirable late-successional habitat. While approximately 91

percent of the project area is identified as having historically experienced high frequency (0 to 35 years) low 

to mixed severity fire, there has been no recorded large scale fire in the project area for 100 years. The 

preponderance of small- and medium-sized trees, which account for about 80 percent of all forested 

vegetation, reflects a lack of differentiation that occurs under dense, stagnant growth conditions. The high 

levels of pine mortality from bark beetle outbreaks further reflect unsustainably high forest stand density.

These conditions result when fire is excluded from an ecosystem that would otherwise be largely shaped by 

natural frequent fire.
Elk Flat LSR Enhancement Project

128 Shasta-Trinity National Forest

Environmental Consequences

Alternative 1- Modified Proposed Action

Direct and Indirect Effects – Alternative 1

Risk Reduction and Increased Stand Resilience

Stand Density Reduction

Under Alternative 1, plantations and natural stands totaling 2,190 unit acres (1,857 of which is actually 

thinned after unthinned patches are subtracted) would be treated to reduce overstocking and promote 

resilience of the residual trees. Thinning would remove excess trees that compete for resources; trees that are 

generally smaller and serve as undesirable ladder and canopy fuels would be removed. Some larger 

intermediate and codominant trees would be removed in order to leave adjacent overstory trees at desirable 

density levels. All distinctly large predominant trees would be retained to the extent operationally feasible 

(e.g. human safety considerations). Thinning would support the health and survival of overstory pine, while 

tree selection would also retain a mix of species and tree sizes.

The measurement of stand density index (SDI) is used to describe existing stand density in relation to a

empirically determined biological maximum and indicate the degree of competition for resources (Shaw, 

2006; Woodall, 2005). Full site occupancy occurs beginning at 60 percent of maximum SDI where density 

induced mortality (self-thinning) begins to occur (Woodall, 2005). As stands reach and exceed 60 percent of 

maximum SDI, individual tree growth slows and the risk of mortality increases as competition for resources 

increases. Research in pure pine stands determined an SDI of 365 represented a pine-limiting threshold 

beyond which high levels of bark beetle mortality typically occurred (Oliver, 1995). Subsequent research has 

found that a limiting SDI for pine stands may be higher than determined by Oliver in 1995 but lower than 

other researchers determined, and it can vary by site index (Zhang, et al., 2013). Recent widespread pine 

mortality associated with western pine beetle outbreak bears evidence that stands have been exceeding their 

density threshold in the Elk project area.

1. Thinning can reduce the number of underground root-root contacts through which the pathogens can 

move from tree to tree.

2. Thinning can promote a mix of host and non-host species, reducing the overall effects of the 

pathogens.

3. L. wageneri prefers cool, moist conditions. Thinning can allow the sun to penetrate through the 

forest canopy, producing warmer soil conditions that are detrimental to the pathogen.

4. Thinning can reduce overall moisture stress on individual trees, allowing infected trees to better 

withstand the loss of root function from the root diseases.

Modeling of pre, post and post-20 year stand densities were compared to a pine limiting SDI of 365. An SDI 

of 230, or roughly 63 percent of the pine limiting SDI is considered the threshold or beginning of a “zone of 

imminent bark beetle mortality” (Oliver, 1995). All of the natural stands proposed for thinning exceed the 

density threshold, most by a large margin. Many of the stands remained near or just above the pine density 

threshold after thinning. Most of the stands exceeded the pine density threshold twenty years after thinning 

but densities were still considerably lower than present day densities. Other species present in the stands (for 

example Douglas-fir and white fir) can persist at higher densities than pure even-aged pine stands.

Additionally, when there are more than one age class in a stand, SDI calculations may over-predict site 

occupancy (Woodall, et al., 2003). Desired species and structural diversity and health of pine overstory were 

considered collectively when analyzing stand density and thinning treatments.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 129

Radial thinning around large predominant pine would be implemented in fourteen stands totaling 196 acres to 

promote the health and survival of these scarce and desirable large older trees. Some large predominant pine 

have recently died during the current pine beetle mortality outbreak, indicative that these trees are under stress 

and at risk in current stand conditions. Radial thinning would reduce competition for resources and create 

open stand conditions immediately adjacent to these predominant trees. Large older (160 years and more) 

ponderosa pine have been found to increase diameter growth and vigor in response to thinning (Latham, et al., 

2002; Kolb, et al., 2007). Radial thin around large older pine frees up site resources that support the vigor of 

the large trees and creates conditions more consistent with those found around large ponderosa pine under a 

natural frequent fire regime.

Dense unthinned patches within the thinning stands would account for at least 10 percent of the stand areas.

Unthinned patches provide functional and structural elements including thermal and visual cover, dense small 

trees, pockets of suppression and mortality, and undisturbed debris. Higher densities would also be retained 

where patches or groups of notably large trees occur in order to retain existing desirable late successional 

characteristics. Unthinned patches and high retention areas would remain at risk of density related and insect 

and disease mortality. These areas however would be smaller and less contiguous than they currently are.

Adjacent thinning would provide growing space that would reduce competition along the edges of unthinned 

patches and high retention areas. When treatments are considered collectively at the stand level the risk of 

large scale disturbance is appreciably reduced and stand resiliency is increased. Treatments would create stand 

conditions where mortality is more likely to occur in smaller isolated patches consistent with endemic (nonepisodic) conditions.

Dense stands totaling 335 acres would not be thinned under Alternative 1. Surface and small ladder fuels 

would be treated in these stands by underburning but overall density will not be appreciably reduced. These 

stands would remain susceptible to insect and disease attack and to density related mortality. These current 

stand conditions are not expected to persist in the long term.

Table 31 and Table 32 summarize density reduction.

Table 31. Alternative 1 Acres of Stand Density Reduction

Seral Stage

Acres of Stands at High Density

Objective Met Through Thinning Objective Not Totals

Met

Plantation 

Thinning

Natural Stand 

Thinning Subtotals Underburn Only

3b 555 79 634 634

3c 62 33 95 95

4a 179 179 179

4b 1,081 1,081 335 1,416

4c 13 13 13

subtotals 617 1,385 2,002 335 2,337

Table 32. Alternative 1 Average Percent of Pine-Limiting SDI in Thinning Stands

Seral Stage Pre-thin Immediately Post-thin Year 20 Post Thin

3a 40% 38% 60%

3b 76% 41% 59%

3c 141% 40% 51%
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130 Shasta-Trinity National Forest

Seral Stage Pre-thin Immediately Post-thin Year 20 Post Thin

4a 73% 46% 57%

4b 115% 60% 79%

4c 124% 66% 82%

Over All Average 95% 49% 65%

Insect and Disease Treatment and Risk Reduction

Thinning selection would favor removal of tress that show advanced symptoms of disease, dwarf mistletoe 

infection or insect activity except when this criteria is superseded by other objectives, such as retaining all 

predominant trees, retaining trees in unthinned patches and retaining trees that provide distinct wildlife habitat 

(e.g. large broken limbs, cavities and other distinct features). By removing heavily infected trees as feasible, 

as well as reducing density, thinning would reduce disease activity closer to endemic levels (Fiddler, et al., 

1989; Otrosina, et al., 2007).

Symptoms of black stain root disease (Leptographium wageneri) have been observed in several stands and is 

likely present in adjacent stands showing elevated pine mortality. Thinning to lower densities in these areas 

helps discourage spread of the disease by allowing sunlight to reach the forest floor, creating conditions less 

favorable for the disease and by breaking up root-to-root contact between susceptible host trees (Otrosina, et 

al., 2007; Snyder, 2012a). While the disease is short lived once a host tree dies, interplanting a mix including 

non-host species in the larger mortality areas will help curtail future spread of black stain in these areas.

Patches of extensive mortality indicative of black stain disease are present in four plantations approximately 

28 years old. These areas would be interplanted with a mix of species to both reduce further mortality from 

black stain and promote development of future late successional forest.

Heterobasidion root disease (Heterobasidion annosum) has been observed in white fir to a more limited extent 

in the project area. Unlike black stain disease in pine, heterobasidion can persist on site for decades after a 

host tree has died, continuing to infect new trees through direct contact and spread of aerial spores. In areas of 

pure or nearly pure white fir heterobasidion is expected to persist and mortality patches expand. Removal of 

symptomatic trees in favor of interplanting non-host species, treating cut stumps with Sporax® and 

underburning are designed to slow the spread of heterobasidion and develop more resilient stand conditions 

(Schmitt, et al., 2000; Snyder, 2012a).

Insect and disease activity has been observed in stands that currently provide high quality nesting and roosting 

habitat, and are not thinned. Underburning in these stands may improve insect and disease conditions to a 

limited extent but will not reduce stand density or treat infection centers. Underburning can provide some 

control of dwarf mistletoe, primarily dependent on the level of crown scorch. Low intensity underburning that 

produces little to no crown scorch has little effect on controlling dwarf mistletoe (Conklin, et al., 2008).

Treatments that improve stand resiliency by reducing excessive density also reduce the risk of undesirable 

insect and disease activity. Most of the stands thinned to reduce excess density have elevated insect and 

disease activity and are reflected in the treatment acres below. Density reduction thinning that is preventative 

(i.e. risk reduction) is included in Table 33 below.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 131

Table 33. Alternative 1 Acres of Insect and Disease Treatment and Risk Reduction

Seral 

Stage

Acres with Elevated Insect and 

Disease Activity

Acres At Risk of Elevated Insect and 

Disease Activity Totals

Insect and Disease 

Activity Reduced 

Through Thinning

Treatments

Objective 

Not Met

Risk Reduced Through 

Thinning Treatments

Objective Not 

Met Objective 

Met Through 

Thinning

Treatments

Objective 

Not Met

Plantations Natural 

Stands

Underburn 

Only Plantations Natural 

Stands

Underburn 

Only

3a 37 130 167

3b 276 32 279 47 634

3c 62 33 96

4a 179 0 179

4b 849 150 232 185 1081 335

4c 13 13

Totals 313 1,190 150 341 325 185 2,169 335

Accelerated Development and Retention of Late-Successional Characteristics

Acres Treated to Retain Late-Successional Characteristics

Thinning to reduce elevated stand density in 1,385 acres of natural stands (refer to Table 31) will both retain 

existing late successional characteristics where present and accelerate their development elsewhere. The 

majority (over 78 percent) of these stands are defined as seral stage 4b which corresponds to a dense mid or 

late successional condition as defined in the LSRA (LSRA pp. 22). Thinning predominantly smaller trees 

provides resources for the resilience and accelerated growth of residual large overstory trees as well as creates 

growing space for development of increased structural diversity (Latham and Tappiener 2002, Garman, 2003, 

Kolb, 2007)

Acres of Early and Mid-Successional Treated to Accelerate Development

A total of 692 acres of plantations are treated under Alternative 1 to accelerate the development of late 

successional characteristics and are displayed in Table 34 below. Thinning in dense early successional (seral 

3b and 3c) stands will accelerate the development of large diameter trees by reducing competition as well as 

speed development of vertical diversity and species diversity (Garman, et al., 2003). Thinning and 

interplanting in open early successional (seral 3a) stands will accelerate the development of species and 

structural diversity.

Table 34. Alternative 1 Plantation Treatments to Accelerate Development

Seral Stage Interplanting Plantation thin Subtotals

3a 28 37 65

3b 565 565

3c 62 62

Total Acres Treated 692

Number of Trees Greater than 24 Inches DBH

Large diameter overstory trees are largely retained, and the likeliness of their survival over time is improved, 

by removing excess density, primarily in smaller size classes. Table 35 displays modeling estimates of 
Elk Flat LSR Enhancement Project

132 Shasta-Trinity National Forest

average trees per acre over 24 inches DBH in all seral stages for thinning units prior to treatment, immediately 

after thinning and at 20 years post-thin.

Modeling projections show thinning would retain approximately 77 to 80 percent of trees over 24 inches 

DBH in seral stage 4b and 4c stands immediately after thinning. By year 20, trees over 24 inches DBH

approximate 89 to 96 percent of current levels prior to treatment. While it is clear that thinning will reduce the 

number of trees per acre over 24 inches DBH from current levels, it is important to consider the relevance of 

this metric in the context of current stand densities and the risk they pose for large-scale disturbance. The 

current widespread mortality of pine in the project area, including desirable large overstory trees considerably 

over 24 inches DBH, underscores this risk.

Tree selection –what criteria selects trees for retention versus removal – is an important consideration when 

discussing numbers and sizes of trees removed. For example, a 26 inches DBH white fir would be selected for 

removal if it is growing under a 40 inches ponderosa pine being radially released, but would be selected for 

retention where it is a healthy dominant overstory tree. Modeling was conducted to try and mimic tree 

selection criteria that would leave some trees in the smaller size classes, thin heaviest in the suppressed and 

intermediate sized trees, and thin some codominant trees where needed to reduce density and promote 

adjacent larger trees.

While some trees over 24 inches DBH are removed by thinning, average stand overstory diameter increases 

by approximately 4 inches immediately after thinning (see Table 36 below). Thinning that result in an 

immediate post-thin increase of average overstory diameter indicates a “thinning from below” where tree 

removal focuses on smaller size classes. When comparing action alternatives including Alternative 1 to the 

No Action Alternative, modeling indicates that unthinned stands would have notably higher levels of trees

greater than 24 inches DBH at year 20 than thinned stands. However, modeling results do not reflect 

extensive and ongoing density related mortality that has been directly observed in the field. This is further 

discussed under the No Action alternative.

Table 35. Alternative 1 Average Trees Per Acre Over 24 Inches DBH In Thinning Units Pre and Post-Thinning

Seral Stage

Trees Per Acre Greater than 24 Inches DBH

Pre-Thin Post-Thin Year-20 Post-Thin

3b 0 0 5

3c 0 0 20

4a 16 16 17

4b 23 18 22

4c 24 19 21

Table 36. Alternative 1 Average Overstory Tree DBH in Thinning Units Pre and Post-Thinning

Seral Stage Average Diameter of Overstory Trees in Thinning Units (inches)

Pre-Thin Post-Thin Year-20 Post-Thin

3a 14” 15” 18”

3b 13” 15” 20”

3c 9” 21” 23”

4a 29” 32” 32”

4b 26” 30” 31”

4c 25” 29” 30”
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 133

Number of Snags Greater than 20 Inches DBH

As discussed throughout this document, tree mortality and subsequent snag levels have increased dramatically 

within the project area over the last several years. Inventory data and modeling forest stands through time 

provide tools for effects comparison between alternatives, but may not accurately reflect changing snag levels

– both because of recent increases in mortality, and because snag densities tend to be patchy and highly 

variable across the project area. Table 37 shows modeled estimated snags per acre over 20 inches DBH before 

and after thinning and at 20 years.

Snag levels are expected to decrease after thinning treatments in order to provide for human safety during 

operations. Snags would be retained where they are not an operational safety risk and in unthinned patches.

Snags would remain at levels consistent with LSRA guidelines for mixed conifer forest after thinning. Open 

mid-successional (seral stage 4a) stands have a projected marked decline in snags at year 20 under all 

Alternatives. These are open stands with fewer trees over 20 inches DBH and current elevated snag levels. As 

existing snags fall, there are low numbers of trees over 20 inches that can recruit into snags and open stand 

conditions that do not lend to density-induced mortality. Model projections may underestimate numbers of 

snags at year 20 in light that ongoing mortality from pine beetle will likely persist until beetle populations 

decline and tree vigor improves. Approximately half of present day snags are projected to fall from natural 

decay by year 20.

Under Alternative 1, snags would continue to develop from disease and insect activity but at more endemic 

levels. Higher levels of mortality would continue to be likely in dense stands where thinning is not undertaken

to retain existing late successional habitat.

Table 37. Alternative 1 Average snags per acre over 20 inches DBH in Thinning Units Pre and Post-Thinning62

Seral Stage Average Snags Per Acre Greater Than 20 inches DBH in thinning units

Pre-Thin Post-Thin Year-20 Post-Thin

4a 3.6 2.8 0.3

4b 2.5 2.0 1.7

4c 4.4 3.5 3.6

Vegetation Diversity

Development of Stand Level Heterogeneity

Thinning and reforestation treatments are designed to increase stand level heterogeneity as well as reduce 

density, in the case of thinning. Stand heterogeneity is increased by thinning to a varying range of density and 

promoting the health and survival of trees or conditions that are sparse such as large pine overstory trees or 

hardwoods. Unthinned patches retain a dense structural component while fuel continuity is broken up and 

excess density is treated in adjacent thinning areas. Creating and reforesting group selections in plantations 

and areas of homogenous white fir, and interplanting mortality areas increases stand level species diversity 

and structural diversity. Table 38 displays acres of treatments that increase vegetation diversity.

 62 The thinning modeling is limited in that it does not reflect the unique tree selection and current snag retention that are in 

the marking guidelines and likely underestimates snags. See further discussion of modeling limitations on snags under the 

No Action Alternative.
Elk Flat LSR Enhancement Project

134 Shasta-Trinity National Forest

Table 38. Alternative 1 Acres of Increased Heterogeneity

Seral Stage

Acres of Increased Heterogeneity Objective Not 

Met

Totals

Interplanting Plantation 

Thinning

Natural Stand 

Thinning Subtotals Underburn 

Only

3a 28 37 141 206 206

3b 565 79 644 644

3c 62 33 95 95

4a 95 95 95

4b 1,165 1,165 335 1,500

4c 13 13 13

subtotals 28 664 1,526 2,218 335 2,552

Hardwood Species Release

Hardwoods are in decline throughout the project area because of crowding and over-shading from conifers. 

Thinning will improve the vigor and long-term survivability of hardwoods by increasing site resource 

availability, particularly sunlight and growing space. Table 39 displays total stand acres with oaks or aspen 

detection and acres treated. Table 7 on page 59 shows the actual estimated acres within these stands that treat 

the hardwoods.

Table 39. Alternative 1 Acres of Hardwood Release

Seral Stage

Acres of Hardwood Release Objective Not 

Met Totals

Oak Release Aspen Release Subtotals Underburn Only

1 6* 6

3a

3b 207 207 207

3c

4a 18 18 2 20

4b 360 360 43 403

4c

subtotals 567 24 591 45 634

The Meadow Enhancement treatment will also release aspen

Meadow Enhancement

Left unchecked, conifer encroachment changes the structure and function of meadows and can result in the 

loss of a distinct and valuable habitat (Halpern, et al., 2010). While a number of factors may influence conifer 

encroachment, fire exclusion appears to play a major role in some instances (Coop, et al., 2007). As discussed 

in Chapter 1 and the Fire and Fuels section of this chapter, the project area has significantly departed from a

natural frequent fire regime. Under Alternatives 1 and 3, thinning and underburning would remove conifer 

encroachment and reintroduce fire into the meadow ecosystem. These treatments would encourage the growth 

of perennial and annual herbaceous plants and grasses. Scattered large pine as well as unthinned patches 

would be retained within the meadow to provide a mix of habitat for other species including mushrooms. 

Effects of thinning for meadow enhancement are further discussed in the Botany and Hydrology sections of 

this chapter. Approximately 379 acres of conifer encroachment would be thinned under Alternatives 1 and 3.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 135

Other resource effects

Sporax® Application

Sporax® (Na2B4O710H2O, Sodium tetraborate decahydrate) is used as a registered pesticide (fungicide) for 

forestry to prevent the spread of Heterobasidion root disease (Wilbur-Ellis, N.D. ). Treatment of conifer 

stumps 14 inches or greater in diameter (outside bark) is recommended (USDA-FS, 2013a p. 11). Sporax®

(or a similar commercial formulation) will be applied to freshly cut stump surfaces at a rate of approximately 

one pound per 50 square feet of stump surface. Based on an estimate of square feet of basal area removal and 

local experience with Sporax® application in stands with similar prescriptions, it is estimated that about 1 

pound of Sporax® per acre would be applied to treated stands. Under Alternative 1 Sporax® would be applied 

on approximately 2,040 acres of thinning.

An assessment on human health and ecological risks associated with applying borax for stump treatment was 

completed by the Forest Service in 2006 (USDA-FS, 2006). The report concludes the use of Sporax® in the 

control of Heterobasidion root disease does not present a significant risk to humans or wildlife species under 

most conditions of normal use, even under the highest application rate. Given the highly focused application 

method for Sporax®, application of granular product to cut tree stump surfaces, exposures considered for both 

the human health and environmental risk assessments are limited to those which are expected to result in 

significant exposure. The most significant risk of toxicity in both humans and wildlife species results from the 

direct consumption of Sporax® applied to tree stumps. For terrestrial species, risk associated with the 

application of Sporax® to tree stumps, appear to be very low. For aquatic animals and plants, hazard quotients 

(HQ) marginally exceed the level of concern for amphibians for the worst-case accidental spill of 25 pounds 

of Sporax® into a small pond (HQ, 1.3) and for the sensitive species of microorganisms for all accidental spill 

scenarios (HQs ranging from about 1 to 4).

Climate Change

The climate in California is predicted to become much warmer in the next three decades with little change in 

annual precipitation rates (CCCC, 2006). Under some predictive scenarios, changes in climate may occur that 

exceed the capacity of existing forest tree populations to adjust physiologically and developmentally 

(Anderson, 2008).

Being relatively long-lived, trees retained or planted as part of this project will likely compose much of the 

forests in the project area over the next century. Long-term adaptation to climate changes requires healthy and 

productive forests in the short term. Declined vigor stemming from environmental stresses of climate change 

may make stands more susceptible to large-scale insect and disease attacks and more frequent or severe fires. 

Existing species or genotypes may be poorly adapted to future climate conditions during all or various parts 

of their life cycles; resulting in altered trajectories of forest growth, development, and productivity.

Cumulative effects to forest vegetation from climate change in the project area may result in decreased tree 

vigor and productivity as well as increase disturbances from insects, disease, and fire. Proposed treatments 

that reduce stand density levels may increase the resilience of the stands to climate change (Anderson, 2008).

Compliance with Law, Regulation and Policy

Alternative 1 meets Forest Plan direction, watershed analyses desired conditions and regional direction 

regarding silviculture and timber harvesting as summarized in the Vegetation report, across the project area.

Cumulative Effects – Alternative 1

Some past actions and natural events may overlap in time and space with the proposed action. However, past 

actions are not being considered individually. The current environmental conditions reflect the aggregate 

impact of all prior human actions and natural events that have affected the environment and might contribute 

to cumulative effects and are a proxy for the impacts of past actions.
Elk Flat LSR Enhancement Project

136 Shasta-Trinity National Forest

Under the Pilgrim Vegetation Management project, thinning of mostly small diameter trees less than 14 inch 

DBH is planned for approximately 147 acres in stand 401, south of Elk Flat. Historic photos showed this 

stand to contain open meadow areas contiguous with Elk Flat mixed with stringers and dense pockets of trees, 

primarily larger diameter pine. This treatment will support the Elk LSR meadow enhancement treatments by 

removing conifer encroachment. Small tree removal will create stand conditions that more closely reflect 

those of a dry pine forest under frequent natural fire. 

Firewood cutting of downed wood is allowed within the LSR to a limited extent and felling and collecting of 

firewood is allowed on the 490 acres of matrix lands within the project area. This activity could potentially 

remove a minor portion of dead fuels but would have no appreciable affect to the forest stand conditions and 

resource indicators discussed in this section.

The felling of snags for hazard tree abatement would remove a component of snags in the project area as 

described in Chapter 2 (see hazard reduction, p. 56). Snags would be retained elsewhere in the project area 

including in thinning units, unthinned patches within treatment units and in unthinned stands. ollectively, the 

treatments and untreated stands would leave a mosaic of snag distributions and snag densities consistent with 

desired conditions described in the LSRA (p.164).

Alternative 2- No New Temporary Road Construction Other Than Those Required 

for Landing Access

Direct and Indirect Effects – Alternative 2

Risk Reduction and Increased Stand Resilience

Stand Density Reduction and Resilience

Under Alternative 2, plantations and natural stands totaling 1,846 acres would be thinned to reduce 

overstocking and promote resilience of the residual trees. This is a decrease of 166 acres from Alternative 1 

and reflective of a decrease in road access to conduct thinning. Effects from thinning are those described 

under Alternative 1.

Radial thinning around large predominant pine would be implemented in fourteen thinning stands totaling 191 

acres. This is a decrease of five acres compared with Alternative 1 and reflects stands left unthinned due to 

limited access.

As described in Alternative 1, approximately 12 percent of thinned stands would remain in unthinned patches 

at stocking levels that pose a risk for density related and insect and disease mortality as described under 

Alternative 1.

Dense stands totaling 400 acres would not be thinned under Alternative 2. This leaves 65 acres of dense 

stands not thinned, compared to Alternative 1. Surface small ladder fuels would be treated in these stands by 

underburning but overall density will not be appreciably reduced. These stands would remain susceptible to 

insect and disease attack and to density related mortality. Presently, 335 acres of these unthinned stands 

provide quality nesting and roosting habitat in their current condition however, these conditions are not 

expected to persist in the long term.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 137

Table 40. Alternative 2 Acres of Stand Density Reduction

Seral Stage

Acres of Stands at High Density

Objective Met Through Thinning Objective Not Totals

Met

Plantation 

Thinning

Natural Stand 

Thinning Subtotals Underburn Only

3b 539 79 618 16 634

3c 62 33 95 95

4a 174 174 5 179

4b 1,036 1,036 379 1,415

4c 13 13 13

subtotals 601 1,335 1,936 400 2,336

Insect and Disease Treatment and Risk Reduction

Alternative 2 thinning acres in stands with elevated insect and disease activity are the same as Alternative 1. 

As discussed under Alternative 1, treatments that improve stand resiliency also reduce the risk of undesirable 

insect and disease activity. Table 41 displays stand acres treated with active insect and disease mortality, and 

acres treated to reduce the risk of undesirable insect and disease mortality.

A total of 401 acres of stands are not treated and remain at density levels that are at risk of undesirable insect 

and disease mortality under Alternative 2. This is an increase of 166 untreated acres compared to Alternative 

1. Underburning in these dense unthinned stands may improve insect and disease conditions to a limited 

extent but will not appreciably reduce stand density. Underburning can provide some control of dwarf 

mistletoe, primarily dependent on the level of crown scorch. Low intensity underburning that produces little 

to no crown scorch has little effect on controlling dwarf mistletoe (Conklin, et al., 2008).
Elk Flat LSR Enhancement Project

138 Shasta-Trinity National Forest

Table 41. Alternative 2 Acres of Insect and Disease Treatment and Risk Reduction

Seral 

Stage

Acres with Insect and Disease 

Activity

Acres of Insect and Disease Risk 

Reduction Totals

Objective Met Through 

Thinning Treatments

Objective 

Not Met

Objective Met Through 

Thinning Treatments

Objective 

Not Met Objective 

Met Through 

Thinning

Treatments

Objective 

Not Met

Plantations Natural 

Stands

Underburn 

Only Plantations Natural Stands

Underburn 

Only

3a 37 129 1 166 1

3b 260 32 16 279 47 618 16

3c 62 33 95

4a 174 5 174 5

4b 804 195 232 184 1,036 379

4c 13 13

Totals 297 1,139 217 341 325 184 2,102 401

Accelerated Development and Retention of Late-Successional Characteristics

Acres Treated to Retain Late-Successional Characteristics

Thinning to reduce elevated stand density in 1,335 acres of natural stands under Alternative 2 (refer to Table 

40) will both retain existing late successional characteristics where present and accelerate their development 

elsewhere. This is a decrease of 50 acres compared to Alternative 1.

Acres of Early and Mid-Successional Treated to Accelerate Development

A total of 676 acres of plantations are treated under Alternative 2 to accelerate the development of late 

successional characteristics (see Table 42). Thinning in dense early successional (seral 3b and 3c) stands will 

accelerate the development of large diameter trees by reducing competition as well as speed development of 

vertical diversity and species diversity (Garman et al, 2003). Thinning and interplanting in open early 

successional (seral 3a) stands will accelerate the development of species and structural diversity.

A total of 400 acres of dense mid and late successional natural stands and plantations are not treated and 

would not meet this objective under Alternative 2 (see acres of “Underburn Only” in tables Table 40 and

Table 42).

Table 42. Alternative 2 Plantation Treatments to Accelerate Development

Seral Stage

Acres of Plantations Treated to Accelerated 

Development of Late-Successional Characteristics

Objective Not 

Met

Totals

Interplanting Plantation 

Thinning Subtotals Underburn Only

3a 28 37 65 65

3b 548 548 16 564

3c 62 62 62

4a

4b

4c

subtotals 28 648 676 16 692
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 139

Number of Trees Greater than 24 Inches DBH and Snags Greater than 20 Inches DBH

On a per acre basis, the retention of late successional characteristics (i.e. trees per acre greater than 24 inches 

DBH, stand average overstory tree diameter and snags greater than 20 inches) in mid and late-successional 

stands are the same across all Action Alternatives, including Alternative 2 (see Table 35 to Table 37). Effects

are the same as described under Alternative 1 except thinning in mid and late successional stands (both 

plantations and natural stands) is reduced by a total of 58 acres compared to Alternative 1

Vegetation Diversity

Development of Stand Level Heterogeneity

The effects of developing stand level heterogeneity are the same as described in Alternative 1. Treatments will 

increase heterogeneity on a total of 2,152 acres of plantations and natural stands Under Alternative 2 (see 

Table 43).

Under Alternative 2, there are 66 fewer acres treated towards this objective compared to Alternative 1. Most 

of the stands left unthinned are natural stand thinning, however this also includes four acres of group 

selections in plantations, and five acres of radial thinning in plantations and natural stands. Group selections 

and radial thin are conducted concurrently with thinning and collectively increase stand heterogeneity. Where 

thinning treatments are not undertaken, stands would remain dense and growth rates slow until disturbance or 

instances of tree mortality occur to free up site resources. While stands remain in a dense overstocked 

condition, little species or structural diversification occurs as site resources are fully captured by existing

vegetation.

Table 43. Alternative 2 Acres of Increased Heterogeneity

Seral Stage

Acres of Increased Heterogeneity Objective Not 

Met

Totals

Interplanting Plantation 

Thinning

Natural Stand 

Thinning Subtotals Underburn Only

3a 28 37 140 205 1 206

3b 548 79 627 16 643

3c 62 33 95 95

4a 90 90 5 95

4b 1,120 1,120 379 1,499

4c 13 13 13

subtotals 28 647 1,475 2,150 401 2,551

Hardwood Species Release

Effects of thinning on hardwood species release are the same as described in Alternative 1. Treatments 

totaling 555 acres would promote the survival and growth of hardwoods under Alternative 2 (see Table 44).

This is a decrease of 38 acres in stands of natural thinning compared to Alternative 1. A total of 76 acres 

would not meet the objective for oak release and 5 acres would not meet the objective for aspen release under 

Alternative 2.

Where left untreated, shade intolerant hardwoods would continue to decline due to overtopping and crowding 

by conifers. Over time, barring disturbance that removes competing conifers, individual oak and aspen will 

die out as they receive insufficient sunlight and site resources. Current mortality in overstory pine is providing 

release of hardwoods including aspen to a limited extent. While this is providing sunlight and growing space 
Elk Flat LSR Enhancement Project

140 Shasta-Trinity National Forest

for hardwood release, as snags fall heavy fuel loadings will accumulate. With heavy fuel loads high intensity 

fire can burn with sufficient intensity and residence time to kill off and prevent sprouting in oak and aspen.

Table 44. Alternative 2 Acres of Hardwood Release

Seral Stage

Acres of Hardwood Release Objective Not 

Met Totals

Oak Release Aspen Release Subtotals Underburn Only

1 6* 6 6

3b 207 207 207

3c

4a 18 18 8 18

4b 327 327 76 403

4c

subtotals 534 24 555 81 634

*Meadow Enhancement treatment also releases aspen

Meadow Enhancement

The effects of thinning conifer encroachment in Elk Flat would be the same as discussed for Alternative 1 

however there would be 25 less acres of conifer encroachment thinning under Alternative 2. Underburning 

would likely remove a minor portion of smaller understory trees in the unthinned areas but larger trees would 

persist and serve as a seed source for further conifer encroachment. Much of the conifer encroachment would 

be largely treated under Alternative 2 however retained forested patches (including the unthinned patches 

under all action alternatives) provide both the seed source and ecotone (i.e. “edge effect”) that can encourage 

a relative rapid expansion of conifer encroachment when other environmental factors are favorable (Halpern 

et al, 2010). Under Alternative 2 the purpose and need of meadow enhancement would be met to an 

incrementally lesser degree, with the consideration that retained forest patches can have a broader impact than 

a simple accounting of forested acres.

Other resource effects

Sporax® Application 

Effects of Sporax® application are those described under Alternative 1. Sporax® would be applied to cut 

stumps 14 inches in diameter and greater on approximately 1,958 harvest acres under Alternative 2.

Climate Change

Effects of climate change are those described in Alternative 1. 

Compliance with Law, Regulation and Policy 

Alternative 2 meets Forest Plan direction, watershed analyses desired conditions and regional direction 

regarding silviculture and timber harvesting as summarized in the Vegetation report, across the treated area.

Cumulative Effects – Alternative 2

Cumulative effects for Alternative 2 would be the same as those described for Alternative 1.

Alternative 3 - No Treatments of Natural Stands within Designated Critical Habitat 

for the Northern Spotted Owl
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 141

Direct and Indirect Effects – Alternative 3

Risk Reduction and Increased Stand Resilience

Stand Density Reduction and Resilience

Under Alternative 3, plantations and natural stands totaling 1,698 acres would be thinned to reduce 

overstocking and promote stand resilience (see Table 45). Effects from thinning are those described under 

Alternative 1.

Dense stands totaling 639 acres are not thinned under Alternative 3. Radial thin treatments decrease by 26 

acres compared to Alternative 1, these radial thin treatments fall within stands left unthinned under this 

alternative. Under Alternative 3, more contiguous dense forest conditions would be retained than in 

Alternatives 1 and 2. Conditions would remain conducive to insect and disease outbreaks and spread from 

these larger contiguous areas.

As in all Action Alternatives, approximately 12 percent of treated stands would be retained as unthinned 

patches dispersed throughout the stands. Higher densities would also be retained where groups of notably 

large trees occur in order to retain existing desirable late successional characteristics. Dense unthinned 

patches and high retention areas within the thinned stands would remain at a higher risk of density related 

mortality but their dispersed less contiguous distribution would be more reflective of endemic conditions.

Table 45. Alternative 3 Acres of Stand Density Reduction

Seral Stage

Acres of Stands at High Density

Objective Met Through Thinning Objective Not Totals

Met

Plantation 

Thinning

Natural Stand 

Thinning Subtotals Underburn Only

3b 555 37 592 42 634

3c 62 62 33 95

4a 179 179 179

4b 853 853 563 1,416

4c 13 13 13

subtotals 617 1,082 1,699 638 2,337

Insect and Disease Treatment and Risk Reduction

Insect and disease conditions are the same as described in Alternative 1. As discussed under Alternative 1, 

treatments that improve stand resiliency also reduce the risk of undesirable insect and disease activity 

(Fiddler, et al., 1989). Table 46 displays stand acres treated with active insect and disease mortality, and acres 

treated to reduce the risk of undesirable insect and disease mortality.

There is a decrease of 157 acres of treatments in stands with active insect and disease mortality compared to 

Alternative 1. Thinning that provides risk reduction for insect and disease mortality is decreased by 168 acres 

compared to Alternative 1. Underburning in these dense unthinned stands may improve insect and disease 

conditions to a limited extent but will not appreciably reduce stand density. Underburning can provide some 

control of dwarf mistletoe, primarily dependent on the level of crown scorch. Low intensity underburning that 

produces little to no crown scorch has little effect on controlling dwarf mistletoe (Conklin, et al., 2008).
Elk Flat LSR Enhancement Project

142 Shasta-Trinity National Forest

Table 46. Alternative 3 Acres of Insect and Disease Treatment and Risk Reduction

Seral 

Stage

Acres with Insect and Disease 

Activity

Acres of Insect and Disease Risk 

Reduction Totals

Objective Met Through 

Thinning Treatments

Objective 

Not Met

Objective Met Through 

Thinning Treatments

Objective 

Not Met Objective 

Met Through 

Thinning

Treatments

Objective 

Not Met

Plantations Natural 

Stands

Underburn 

Only Plantations Natural Stands

Underburn 

Only

3a 37 130 167

3b 276 32 279 37 10 591 42

3c 62 33 62 33

4a 179 179

4b 713 286 140 277 853 563

4c 13 13

Totals 313 1,022 318 341 190 320 1,866 639

Accelerated Development and Retention of Late-Successional Characteristics

Acres of Early and Mid-Successional Treated to Accelerate Development

Natural stands totaling 1,081 acres are thinned under Alternative 3 to both retain and accelerate development 

of late successional characteristics (see Table 45). The majority (approximately 79 percent) of these stands are 

defined as seral stage 4b which corresponds to a dense mid or late successional condition as defined in the 

LSRA (pp. 22).

Within thinning units, snags would continue to develop from disease and insect activity but at more endemic 

levels. Higher levels of mortality would continue to be likely in dense stands where thinning is not undertaken

to retain existing late successional habitat. Growth of large overstory trees would remain suppressed in 

untreated dense stands.

Plantations treated to accelerate the development of late successional characteristics under Alternative 3 are 

the same as Alternative 1 (see Table 34) Thinning in dense early successional (seral 3b and 3c) stands will 

accelerate the development of large diameter trees by reducing competition as well as speed development of 

vertical diversity and species diversity (Garman, et al., 2003). Thinning and interplanting in open early 

successional (seral 3a) stands will accelerate the development of species and structural diversity.

A total of 638 acres of dense mid and late successional natural stands and plantations are left unthinned, and

would not meet the objective under Alternative 3 (see Table 45).

Number of Trees Greater than 24 Inches DBH and Snags Greater than 20 Inches DBH

On a per acre basis, the retention of late successional characteristics (i.e. trees per acre greater than 24 inches 

DBH, stand average overstory tree diameter and snags greater than 20 inches) in dense mid and late 

successional stands are the same across all Action Alternatives, including Alternative 3 (see Table 35 to Table 

37). Effects are the same as described under Alternative 1 except thinning in mid and late successional stands 

(both plantations and natural stands) is reduced by a total of 267 acres compared to Alternative 1.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 143

Vegetation Diversity

Development of Stand Level Heterogeneity 

The effects of developing stand level heterogeneity are the same as described in Alternative 1. Treatments will 

promote stand heterogeneity on a total of 1,194 acres of plantations and natural stands Under Alternative 3 

(see Table 47).

Under Alternative 3, there are 303 fewer acres treated towards this objective compared to Alternative 1 and a 

total of 639 acres left unthinned. Where thinning treatments are not completed, stands would remain dense 

and growth rates slow until disturbance or instances of tree mortality occur to free up site resources. While 

stands remain in a dense overstocked condition, little species or structural diversification occurs as site 

resources are fully captured by existing vegetation.

Table 47. Alternative 3 Acres of Increased Heterogeneity

Seral Stage

Acres of Increased Heterogeneity Objective Not 

Met

Totals

Interplanting Plantation 

Thinning

Natural Stand 

Thinning Subtotals Underburn 

Only

3a 28 37 141 206 206

3b 565 37 602 42 644

3c 62 62 33 95

4a 95 95 95

4b 937 937 563 1,500

4c 13 13 13

subtotals 28 664 1,223 1,915 638 2,553

Hardwood Species Retention

Effects of thinning on hardwood species release are the same as described in Alternative 1. Stand treatments 

totaling 445 acres would promote the survival and growth of hardwoods under Alternative 3 (see Table 48).

This is a decrease of 148 acres identified for oak release in natural stand thinning compared to Alternative 1.

Where left untreated, shade intolerant hardwoods would continue to decline due to overtopping and crowding 

by conifers. Over time, barring disturbance that removes competing conifers, individual oak and aspen will 

die out as they receive insufficient sunlight and site resources. Current mortality in overstory pine is providing 

release of hardwoods including aspen to a limited extent. While this is providing sunlight and growing space 

for hardwood release, as snags fall heavy fuel loadings will accumulate. With heavy fuel loads high intensity 

fire can burn with sufficient intensity and residence time to kill off and prevent sprouting in oak and aspen.
Elk Flat LSR Enhancement Project

144 Shasta-Trinity National Forest

Table 48. Alternative 3 Acres of Hardwood Release

Seral Stage

Acres of Hardwood Release Objective Not 

Met Totals

Oak Release Aspen Release Subtotals Underburn Only

1 6* 6 6

3a

3b 170 170 38 208

3c

4a 18 18 18

4b 250 250 154 404

4c

subtotals 419 24 444 194 634

*Meadow Enhancement treatment will also release aspen

Meadow Enhancement

The effects of meadow enhancement under Alternative 3 are the same as those described in Alternative 1, 

above. 

Other resource effects

Sporax® Application 

Effects of Sporax® application are those described under Alternative 1. Sporax® would be applied to cut 

stumps 14 inches in diameter and greater on approximately 1,773 harvest acres under Alternative 3.

Climate Change

Effects of climate change are those described in Alternative 1. 

Compliance with Law, Regulation and Policy 

Alternative 3 meets Forest Plan direction, watershed analyses desired conditions and regional direction 

regarding silviculture and timber harvesting as summarized in the Vegetation report, across the treated area.

Cumulative Effects – Alternative 3

Cumulative effects for Alternative 3 would be the same as those described for Alternative 1.

Alternative 4 - No Action

Under No Action, the proposed management activities would not be implemented. No direct, indirect, or 

cumulative effects are expected. Although there would be no actions undertaken with this alternative, ongoing 

trends would continue. Chapter 1 describes the existing condition and trends in Purpose and Need #1 and #2.

Under the No Action Alternative, stands would remain at high mortality risk and large tree growth would be 

slow due to inter-tree competition for site resources. While stand modeling is useful for comparing trends 

across Alternatives and through time, it is important to understand modeling limitations when interpreting 

results. For instance, under the No Action Alternative, modeling suggests there would be an increase in the 

average number of trees over 24” DBH and snags over 20” by year 20, compared to the Action Alternatives.

Modeling results do not account for the insect and disease activity and mortality patterns that have recently 

occurred and are ongoing. As noted elsewhere in this document, a complex of bark beetles and root disease, 

further exacerbated by several years of drought, have caused elevated mortality above endemic levels 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 145

throughout much of the project area. There is a loss of large diameter trees not accounted for in the No Action 

modeling results. The model results reflect a more typical pattern of density related mortality where smaller 

trees die off from competition. The No Action modeling results do not reflect the observed pine mortality and 

widely held research findings of a pine mortality threshold (Oliver, 1995; Otrosina, et al., 2007; Egan, et al., 

2010; Snyder, 2012).

In natural stands, ponderosa pine is primarily a component of large overstory trees (30” DBH and greater) 

growing with a dense shade tolerant understory and mid-story, primarily of white fir and incense cedar. As 

most of the mortality is occurring within the pine, including large trees, it is likely that the number of large 

trees and average stand diameter would decrease over time under the No Action alternative, contrary to 

modeling results. This would be due to the loss of large overstory pine and persistence of smaller white fir and 

incense cedar.

With current mortality trends, future stands under the No Action alternative would be characterized by a dense 

layer of smaller shade tolerant trees with fewer large diameter trees and areas of high concentrations of fuels 

conducive to high intensity fire.

The increased risk of further stand loss from heavy fuel accumulation, slow growth of large trees due to high 

stand densities, and continued loss of large overstory pine from insects and disease under the No Action 

alternative do not meet the purpose and need of promoting stand resilience, and retaining and accelerating the 

development of late successional characteristics.

Since there are no direct or indirect effects with No Action, Alternative 4 would result in no cumulative 

effects.

Summary and Conclusions

Comparison of Modeling Projections for Indicators of Stand Resilience and Late 

Successional Forest Characteristics Development and Retention

Table 49 through Table 52 below display modeling results for Silviculture resource indicators under the No 

Action alternative and show a comparison with modeling results for thinning treatments.

Table 49. Average Percent of Pine-Limiting SDI

Seral Stage No Action Year 1 No Action Year 20 Action Alternatives -

post-thin

Action Alternatives -

year 20

3a 40% 66% 38% 60%

3b 73% 102% 41% 59%

3c 141% 138% 40% 51%

4a 70% 85% 46% 57%

4b 112% 128% 60% 79%

4c 117% 130% 66% 82%

Table 50. Average Trees Per Acre, > 24" DBH

Seral Stage No Action Year 1 No Action Year 20 Action Alternatives - year 

20

3b 0 3 5

3c 0 19 20

4a 16 16 17

4b 23 31 22
Elk Flat LSR Enhancement Project

146 Shasta-Trinity National Forest

Seral Stage No Action Year 1 No Action Year 20 Action Alternatives - year 

20

4c 24 31 21

Table 51. Average Overstory DBH

Seral Stage No Action Year 1 No Action Year 20 Action Alternatives- year 

20

3a 14 17 18

3b 13 16 20

3c 9 14 23

4a 29 26 32

4b 25 28 31

4c 26 29 30

Table 52. Average Snags ≥ 20" DBH

Seral Stage No Action Year 1 No Action Year 20 Action Alternatives -

year 20

3a 0 0 0

3b 0 0 0

3c 0 0 0

4a 3.6 0.4 0.3

4b 2.5 2.2 1.7

4c 4.4 4.6 3.6

Silviculture treatments under Action Alternatives 1 through 3 are designed to address issues of stand health 

and densification that have developed largely from decades of natural fire exclusion, while promoting a 

mosaic of stand conditions that support the development and retention of late successional forest 

characteristics. The differences in the Action Alternatives are in the number of acres treated. Along with a 

direct comparison of treated acres, it is important to consider the influence of the spatial arrangement of 

treatments and forest conditions as well. For example, large contiguous areas of susceptible hosts for insects 

or pathogen are more likely to support epidemic outbreaks as compared to forests where there are a mosaic of 

conditions including gaps or openings.

Table 53 below displays a direct comparison of treated acres between the alternatives as well as a summary 

and comparison of effects.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 147

Table 53. Summary of Effects to Silviculture and Forest Health

P&N, Key 

Issue, or 

Resource 

Effect

Indicator Alternative 1 Alternative 2 Alternative 3 Alternative 4

No Action

P&N #1, 

Key Issue 

#1, 

Resource

Acres of reduced 

stand densities that 

support stand growth 

and resilience

Stands totaling 

2,002 acres treated

Stands totaling 

1,936 acres 

treated

Stands totaling 

1,699 acres 

treated

No stands treated

Density (SDI) 

reduced below pine 

mortality threshold 

post-thin

Same average

reductions in SDI 

but on 66 fewer 

acres

Same average

reductions in SDI 

but on 303 fewer 

acres

Density (SDI) well 

above pine 

mortality threshold 

at year 1 and year 

20 - However 

projections do not 

account for insect 

and disease 

outbreak. Field 

observations and 

research indicate 

the high densities 

will not persist for 

20 years

Density (SDI) near 

pine mortality 

threshold at year 20

Acres of treatment 

and risk reduction of 

insect and disease 

outbreak

Stands totaling 

2,169 acres treated 

to address elevated 

insect and disease 

outbreaks, or 

reduce the risk of 

additional 

outbreaks

Stands totaling 

2,103 acres 

treated, This is 66 

fewer acres of risk 

reduction 

treatment, but all 

stands with 

elevated insect 

and disease are 

still treated 

Stands totaling 

1,866 acres 

treated, This is a 

total of 303 less 

acres; of which

169 acres are 

stands with 

elevated insect 

and disease 

outbreak, and 

135 acres are 

stands at risk of 

outbreak. See 

No Action 

discussion of 

contiguous 

untreated stands 

No Stands 

Treated. Under 

both Alternative 3 

and 4, contiguous 

dense stands are 

left intact, 

including those 

with elevated 

insects and 

disease. These 

areas will continue 

to be active 

infection centers 

and keep adjacent 

stands at risk by 

providing 

conditions that 

support epidemic 

outbreaks

P&N #2, 

Key Issue 

#1, 

Resource

Acres early and midsuccessional treated 

to accelerate 

development of late 

successional 

characteristics

692 Acres of 

Plantations

1,385 acres of 

natural stands ( of 

which nearly half 

are in a midsuccessional 

condition)

676 Acres of 

Plantations; this is 

16 fewer acres

1,335 acres of 

natural stands; 

this is 50 fewer 

acres 

692 Acres of 

Plantations – no 

change

1,083 acres of 

natural stands; 

this is 304 fewer 

acres 

No stands treated
Elk Flat LSR Enhancement Project

148 Shasta-Trinity National Forest

P&N, Key 

Issue, or 

Resource 

Effect

Indicator Alternative 1 Alternative 2 Alternative 3 Alternative 4

No Action

Number of trees per 

acre greater than 24 

inches diameter 

breast height (DBH) 

immediately posttreatment and 

projected in 20 years 

based on comparative 

modeling of the 

alternatives. (in the 

4a,b,c Seral stage 

classes)

Post thin ranges 

16-19 TPA >24” 

DBH (varies by 

density class)

Year 20 ranges 17-

22 TPA > 24” DBH 

(varies by density 

class)

Same as Alt. 1 Same as Alt. 1

Year one ranges 

16 – 24 TPA > 24” 

DBH (varies by 

density class)

Year 20 ranges 

16-31 TPA > 24” 

DBH however 

mortality 

observations and 

research on pine 

density threshold 

do not support 

these upper 

projected 

numbers at year 

20 

Number of snags

greater than 20 inches 

DBH immediately post 

treatment and 

projected in 20 years 

from comparative 

modeling. - Refer to 

discussion of 

modeling limitations –

particularly with 

snags. Numbers are 

more suited for 

analysis of trends 

rather than absolutes

Post- thin ranges 

2.0 to 3.5 

snags/acre 

depending on stand 

density class

Year 20 ranges 0.3 

to 3.6 snags/acre 

depending on 

density class

Same as Alt. 1 Same as Alt. 1

Year 1 ranges 2.5 

– 4.4 snags/acre 

depending on 

stand density 

class

Year 20 ranges 

0.4 – 4.6 

snags/acre 

depending on 

density class

P&N #2 & 

#4, 

Resource

Acres promoting 

growth and resilience 

of hardwoods 

including aspen, 

commensurate with 

late successional 

stand development.

Oak released in 

stands totaling 567 

acres (i.e. oak has 

been detected and 

will be promoted 

throughout these 

stands)

Aspen released on 

24 acres

Oak released in 

stands totaling 

534 acres; this is 

33 fewer acres 

than Alt. 1

Aspen – same as 

Alt. 1

Oak released in 

stands totaling 

419 acres; this is 

148 fewer acres 

than Alt. 1

Aspen – same 

as Alt. 1

Aspen and oak 

continue declining 

in stands due to 

competition and 

shading out by 

overtopping 

conifers

Acres of increased 

stand heterogeneity

Treatments in 

stands totaling 

2,218 acres will 

promote stand 

heterogeneity 

Treatments in 

stands totaling 

2,150 acres will 

promote stand 

heterogeneity; this 

is 68 fewer acres 

than Alt. 1

Treatments in 

stands totaling 

1,915 acres will 

promote stand 

heterogeneity; 

this is 303 fewer 

acres than Alt. 1

Dense stand 

conditions with 

little structural 

diversity will 

persist until and 

as forest 

disturbance 

events occur

Meadow Enhancement

P&N #3, 

Resource

Acres of reduced 

conifer encroachment

Stand totaling 518 

acres treated for 

meadow 

enhancement 

(thinning to reduce 

conifer 

encroachment) 

Stand totaling 494 

acres treated for 

meadow 

enhancement; this 

is 24 fewer acres 

than Alt. 1

Same as Alt. 1

With no treatment, 

conifer 

encroachment will 

continue and lead 

to further loss of 

meadow habitat 

over time
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 149

Compliance with Law, Regulation and Policy (includes Forest Plan under NFMA)

All silvicultural treatments in the action alternatives follow Forest Plan direction, are consistent with 

watershed analyses recommendations and comply with regional direction regarding silviculture and timber 

harvesting as summarized in the Vegetation report, across the project area. Appendix H provides the NFMA

compliance consistency and other vegetation-related consistency. Specifically refer to discussions starting on 

pages I-12 (NFMA), I-17 (LSR), and I-26 (Vegetation Diversity).

Fire and Fuels

A Fire and Fuels Specialist Report (McRae, 2015) was completed for this project and is incorporated by 

reference. Information relevant to this decision is summarized here.

Introduction

Purpose and Need Applicable to Fire and Fuels

Purpose and Need for Action #1-Risk Reduction in Early, Mid and Late-Successional Habitat and Increased 

Stand Resilience to Disturbance is applicable to fire and fuels. The existing and desired conditions relating to 

fuels are provided in Chapter 1, starting on page 23. The departure between the existing condition and desired 

conditions for fire regime, fuel loading and fire behavior contribute to the identification of the Purpose and 

Need for Action. Secondary purposes, applicable to fire and fuels include #3-Restore Meadow Habitat in Elk 

Flat described in Chapter 1 starting on page 29.

Issues Applicable to Fire and Fuels

Issue #5, Machine Piling, described on page 46, indirectly applies to fire and fuels since machine piling is 

proposed for fuels reduction. The acres of machine piling by alternative is the issue indicator; however, the 

issue and indicator relate to effects to soils. Effects to fuel loading from machine piling is addressed here.

Methodology

Stand exam data was collected in spring of 2007, including Brown’s method (Brown, et al., 1982) fuels 

sampling. Modeling assumptions, limits and other specifics can be found in the silviculture report (Payne, 

2015b). In fall 2011 additional data using the photo series (Maxwell, et al., 1979) was collected to assess 

ongoing mortality observed in the project area.

Stand exam data was processed through the FVS, Fire and Fuels Extension (FFE), to derive pre- and posttreatment fuel loading, and vegetation characteristics that influence fire behavior (canopy base height and 

crown bulk density), the results of which were used in the effects analysis. FVS/FFE models fire spread 

through the stands before and after treatment where other fire models such as Flam Map, Behave, and FSPro 

do not.

Weather parameters from 23 years of observations at the Ash Creek Remote Automated Weather Station 

(RAWS) were used for modeling. The date range for weather observations used was July 1 – October 1, 

which represents when the most severe fire behavior conditions are likely to occur. Ninety-seventh percentile 

weather conditions were utilized to evaluate alternatives against the most extreme fire behavior.

Indicators and Measures

Criteria were developed to evaluate how well each alternative meets the project Purpose and Need and 

follows policy and direction as follows:

Indicators of Purpose and Need #1
Elk Flat LSR Enhancement Project

150 Shasta-Trinity National Forest

• Fuel Loading - Acres of reduced ladder and overstory fuels, and surface fuels that meet Forest Plan

standards (average of 5 tons per acre in Matrix and average between 5 and 35 tons per acre in LSR) 

within the constraints of the resource protection measures that require higher levels in specific areas. 

• Fuel Models – Fuel models present within the project area. Fuel models 2 and 9 (with limited surface 

fuel loading) are desired.

• Potential Fire Behavior - Fire behavior characteristics expressed as a measure of expected flame 

length on a 97th percentile fire weather day. Table 54 summarizes fire behavior by flame length 

category. The desired flame length is 0-4 feet for fireline safety and the use of mostly handline during 

wildfire conditions.

Table 54. Fire Behavior

Flame Length (feet) Interpretations

0-4

Fires can generally be attacked at the head or flanks by persons using hand 

tools. 

Handline should hold the fire

4-8

Fires are too intense for direct attack on the head of the fire by persons using 

hand tools. 

Handline cannot be relied on to hold fire. 

Equipment such as dozers, engines, and retardant aircraft can be effective. 

8-11

Fires may present serious control problems – torching out, crowning, and 

spotting. 

Control efforts at the head of the fire will probably be ineffective. 

11+ Crowning, spotting, and major runs are common. 

Control efforts at the head of the fire are ineffective. 

Source: (NWCG, 2006 p. Appdx. B)

• Fire type anticipated under extreme fire conditions. The desired fire type is surface fire with limited 

torching and no running crown fire.

In addition to measuring how well the desired condition pertaining to the Purpose and Need for Action for fire 

restoration and fuels reduction, the ability to manage a fire, firefighter safety, impacts to private property, and 

WUI objectives can all be estimated utilizing these evaluation criteria.

Boundaries

To determine relevant past, present, and foreseeable future projects, spatial and temporal boundaries must be 

defined (CFR § 220.4 (f)). For the effects analysis the direct and indirect effects of the Elk project relative to 

fire and fuels are conditions influencing fuel loading and ladder and crown fuel characteristics. Direct and 

indirect effects from the Elk project that influence these conditions are changes to surface fuel accumulations, 

small tree and brush growth or density, overstory tree density, tree crown heights, and tree mortality (and 

resultant deadfall).

Spatial Bounding

Spatially, direct and indirect effects of changes to fuel loading, ladder and crown fuel characteristics from 

project activities are within and nearby the treated units. As such, the spatial context being considered is the 

Elk Flat LSR Enhancement Project boundary. This boundary represents the area potentially influenced by 

effects from proposed treatment activities.

Temporal Bounding
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 151

Temporally, direct and indirect effects of changes to fuel loading, ladder and crown fuel characteristics from 

project activities are expected to remain effective for about ten about years. Multiple prescribed fire entries 

would be used to restore the historical fire return interval and maintain the stands throughout time. The burn 

entries would be timed to ensure effectiveness of treatments was not lost. The cumulative effects analysis 

timeline of 30 years would encompass 3 burn entries, which coincides with the proposal for 2 to 3

incremental underburns, repeated every 5 to 10 years. As such, the temporal context is 30 years into the 

future.

The baseline year used for this analysis is 2014 as the existing condition. The description of the existing 

condition includes the accumulation of past activities, which have influenced vegetation. In the effects 

discussion, “short-term” refers to effects over the 10-year period from the time the activity was accomplished. 

Beyond 10 years effects are considered “long-term.” The current environmental conditions reflect the 

aggregate impact of all prior human actions and natural events that have affected the environment and might 

contribute to cumulative effects and are a proxy for the impacts of past actions.63

Affected Environment

The purpose and need in Chapter 1 wholly describes the fire and fuels affected environment beginning on 

page 23. Approximately 1,490 acres of natural stands and approximately 675 acres of older plantations are 

susceptible to high severity fire effects due to suppression and exclusion of naturally-occurring fire, which has 

led to dense accumulations of live and dead fuels that have combined with fuels from the recent bark beetlecaused mortality.

In summary: 

• Fire Regime - The entire project area has departed from the natural fire regime; most of the project 

area (91%) historically experienced a high frequency (0-35 years) low to mixed severity fire return 

interval. Currently, it is unlikely fire could play its natural role (short interval, low to moderate 

intensity fire regime) in the project area.

• Fuel Loading - Current surface fuel loadings in portions of the project area range from 5 to 60 tons 

per acre. Where there are high levels of existing and ongoing mortality, it is expected to increase to 35 

to 100 plus tons per acre when these dead and dying trees fall over the next 3-5 years. Approximately 

10 percent of the Elk Flat LSR is currently comprised of large pockets (up to 80 acres) of standing 

dead trees that present a current and future threat due to increasing fuel loads and safety

considerations. Estimated acres of machine piling needed based on fuel loading is approximately 944 

acres. The maximum acreage, pending deadfall, approximates 1,461 acres.

• Fuel Models - Fuel models present within the project area include the following:

FM 10– Fuel model 10 can be characterized by dense late-successional conifer stands with heavy 

amounts of dead and down woody fuels. The understory is densely populated with intermediate 

size conifers. A wildfire carried by these fuels would be intense enough to cause crowning, 

spotting and rapid rates of spread. Large stand replacing fires can be expected. 

FM 9 – Fuel model 9 is characterized by closed canopy conifer stands with densely stocked pole 

size trees in the understory. Typically, these stands contain pockets of dead and down woody 

fuels. These fuels create high fire intensities during surface fires that can easily spread through 

the understory to the crowns of the dominant conifers. 

 63 This approach is consistent with CFR § 220.4 (f) and the Council on Environmental Quality June 24, 2005 

memorandum regarding analysis of past actions.
Elk Flat LSR Enhancement Project

152 Shasta-Trinity National Forest

FM 2– Fuel model 2 is characterized by poorer timbered stands and young plantations with grass 

and brush. Surface fires can spread easily with pockets of fuels generating high heat intensities. 

Environmental Consequences

Alternative 1- Modified Proposed Action

Direct and Indirect Effects – Alternative 1

Reducing surface and ladder fuels and crown density in the project area would directly change the fuel profile 

and fire behavior. Activity fuels (slash generated from harvest and thinning activities), along with natural fuels 

such as standing excess snags, dead and down woody debris and shrubs, would be treated through a variety of 

methods including: removal, piling and burning and underburning. This, when combined with the raising of 

the canopy base heights (by reducing ladder fuels and reducing stand density through thinning and prescribed 

burning) will reduce the ability of surface fires to transition into the tree crowns.

Fire modeling results show a decrease in anticipated fire behavior under 97th percentile weather conditions 

following treatment. Flame lengths would be less than 4 feet, allowing for ground forces to manage the fire. 

The likelihood of passive crown fire would be reduced. Models indicate surface fire would be most probable. 

Stand mortality is expected to be less than 10 percent under a wildfire scenario in the most extreme weather 

conditions, following the initial treatment (thinning, slash treatment, underburn). Pockets of mortality 

resulting in excessive fuel loading would be treated allowing for reduced fire intensity and improved safety 

for firefighters.

Fuel loading would be managed with repeated fire entries. Fuel models 2 and 9 would be present in the 

project area. Fuels model proportions would shift to less than 15 percent fuel model 10 (unthinned patches).

Fule et al. (2012), (2001) and Prichard et al. (2010) indicate the most appropriate fuel treatment strategy is 

thinning (removal of ladder fuels and decreased crown density) followed by prescribed fire and other 

appropriate slash treatments. These treatments provide the best protection from undesirable impacts from fire 

during extreme conditions. Both Fule et al. papers emphasize the importance of continued prescribed fire 

treatments to maintain the achieved condition.

The underburn only treatment areas (including leave islands) will benefit from increased nutrient cycling and 

reduced surface fuel loading. These areas will still have interlocking canopy and ladder fuels. This will be the 

area most susceptible to torching, crown fire initiation, and increased mortality during a wildfire. The 

repeated burn treatments would create some pockets, through thinning with fire. The distribution of these 

areas through the project area would provide for a mosaic pattern across the landscape. In the event of a 

wildfire, any crown fire should be short duration and drop back to the surface when it reaches an area that has 

received mechanical and burn treatment.

Proposed activities include the repeated prescribed fire entries to mimic the historic fire regime. Following the 

initial entry, fire managers would have more (and safer) options for managing fire in the project area. 

Opportunities will exist for fire moving across the landscape to meet multiple resource objectives. This may 

be utilized in place of second or third entry prescribed fire treatments. Re-introducing fire back into a fire 

adapted ecosystem through prescribed fire treatments and wildfire with desirable effects, moves the project 

area towards restoration of ecological processes as directed by current fire policy. Stand composition and 

structure would be maintained through fire, as occurred under the historic fire regime.

The combination of an initial mechanical treatment in most stands, followed by repeated fire entries, would 

move the project area toward a condition class 1. This is defined as fire regimes within the natural historic 

range. The risk of losing key ecosystem components is low. Vegetation attributes are intact and functioning 

within the natural range.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 153

Unthinned patches would be retained in up to 15 percent of the project area. Some of these patches would be 

underburned, while others would not. The effects in the unburned patches will be similar to what is described 

in the no action alternative, for un-burned patches; while the burned patches will result in effects similar to the 

burn only treatment described above. Since these pockets are scattered throughout the project area, overall 

project objectives will be met. A fire response and corresponding management actions may be influenced by 

where the fire starts (in a treated vs. untreated portion of the project area). Resulting fire effects will also vary 

depending on where the fire is located.

Effects relative to Purpose and Need for Action

Alternative 1 provides for the most area treated in the most strategic areas such as adjacent to private property. 

This alternative treats the landscape within the project area providing for the greatest area of restored forest. 

The maximized treatment would provide for the most manageable wildfire behavior following the treatments. 

This alternative also maximizes safety for fire managers implementing prescribed fire treatments and 

management of wildfire.

By reducing surface and ladder fuels and crown density in the project area, thereby changing the fuel profile 

and fire behavior, Alternative 1 would reduce the risk of loss of early, mid and late-successional habitat. 

Treated stands would be more resilient, having the capacity to better withstand and survive disturbances such 

as wildfire, especially under changing conditions such as climate change.

Underburning would reintroduce fire processes in elk flat and help restore meadow habitat.

Compliance with law, regulation and policy

Alternative 1 meets Forest Plan direction, watershed analyses desired conditions, regional direction regarding 

ecological restoration, and national fire management policy that was summarized in the Fire/Fuels report, 

across the project area.

Cumulative Effects – Alternative 1

In elk flat, Pilgrim Vegetation Management Project treatments would be completed64 to meet the objectives of 

returning the area to a pine savannah by substantially reducing stand density in order to restore the more open 

conditions that existed historically and more mimic historical fire regimes.65 When combined with treatments 

in Alternative 1, overall fire behavior will be improved. It will break up the continuity of fuels, helping to 

reduce fire behavior in the event of a wildfire. This will also create a healthier stand, reducing the chances of 

mortality in the residual trees. Less mortality results in less surface fuel accumulation in the future.

Alternative 2- No New Temporary Road Construction Other Than Those Required 

for Landing Access

Direct and Indirect Effects – Alternative 2

Fire behavior would not be completely modified on 98 acres under alternative 2. Passive crown fire and flame 

lengths greater than four feet are anticipated during extreme summer conditions on a portion of the un-thinned 

acres. Prescribed burning is planned on these 98 acres, but there would not be any mechanical vegetation 

removal. Underburning would reduce surface fuels and potentially thin some of the canopy. Repeated fire 

 64 Thinning 4”-14” dbh encroaching conifers on approximately 147 acres down to 80 square feet of basal area per acre 

with underburning on 25 acres of those acres.

65 The area was partially thinned but retains too many trees to meet the objectives of 80 square feet of basal area per 

acre. As such, trees would be thinned down to 80 square feet of basal area per acre.
Elk Flat LSR Enhancement Project

154 Shasta-Trinity National Forest

entries would continue to move these stands toward the desired condition. It would take several fire entries to 

reach the desired state.

Dropping these units totaling 98 acres from thinning of which 58 acres were to be piled, results in anticipated 

effects slightly better than those discussed in the no action alternative. As described in the Alternative 1 

description, a combination of overstory and understory treatment is the best approach for modifying fire 

behavior during extreme conditions. While no thinning or machine piling would be undertaken on the acres 

eliminated due to no temporary road construction, underburning would still be applied resulting in a slight 

improvement over no action, but less effective than in Alternative 1. Some of the areas dropped for thinning 

in this alternative are adjacent to private property, which increases risk of wildfire crossing in either direction 

between the LSR and adjoining private lands.

Resulting fuel models would be 2, 9 and 10. The 98 acres that shift to underburn-only would remain a fuel 

model 10, but may move to a fuel model 13 over time. As mortality occurs and the fuels fall to the ground, 

fire behavior would likely be high intensity. Active flaming is sustained for long periods and a wide variety of 

firebrands can be generated under the fuel model 13 due to the large amounts of surface fuel accumulation. 

This contributes to spotting problems as weather conditions become more severe (NWCG, 2006).

This alternative moves the project area toward the historical fire regime and makes the area safer for fire 

managers. Fire policy and national direction would be met under this alternative and fire managers would

have more options for future treatments. Repeated fire entries are achieved under this alternative. The primary 

difference from Alternative 1 is the 98 acres that would not have overstory thinning completed, a portion of 

which is adjacent to private property. The impacts in the unthinned patches are the same as Alternative 1.

Effects relative to Purpose and Need for Action

Alternative 2 moves the project area toward desired conditions but provides treatments on fewer acres. 

Objectives would be met on the acres being treated. However, Alternatives 2 leaves 98 acres treated through 

underburning only. Underburning will return the ecological process to the ecosystem, but safety will not be 

modified. Fire behavior within these areas would be consistent with the no action alternative. Crown fire will 

still carry through these areas not treated with thinning. Ladder fuels will remain, allowing fire to get into the 

canopy if a fire were to start in the unthinned pockets. By reducing surface and ladder fuels, as well as crown 

density, in the project area (thereby changing the fuel profile and fire behavior), Alternative 2 would help 

reduce the risk of loss of early, mid and late-successional habitat in the project area in thinned areas. Like 

Alternative 1, stands that are thinned and burned would be more resilient.

Compliance with law, regulation and policy

Alternative 2 meets Forest Plan direction, watershed analyses desired conditions, regional direction regarding 

ecological restoration, and national fire management policy that was summarized in the Fire/Fuels report, 

across the project area.

Cumulative Effects – Alternative 2

In elk flat, Pilgrim Vegetation Management Project treatments would be completed66 to meet the objectives of 

returning the area to a pine savannah by substantially reducing stand density in order to restore the more open 

conditions that existed historically and more mimic historical fire regimes.67 When combined with treatments 

 66 Thinning 4”-14” dbh encroaching conifers on approximately 147 acres down to 80 square feet of basal area per acre 

with underburning on 25 acres of those acres.

67 The area was partially thinned but retains too many trees to meet the objectives of 80 square feet of basal area per 

acre. As such, trees would be thinned down to 80 square feet of basal area per acre.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 155

in Alternative 2, overall fire behavior will be improved on the acres being treated. It will break up the 

continuity of fuels, helping to reduce fire behavior in the event of a wildfire. This will also create a healthier 

stand, reducing the chances of mortality in the residual trees. Less mortality results in less surface fuel 

accumulation in the future.

Alternative 3 - No Treatments of Natural Stands within Designated Critical Habitat 

for the Northern Spotted Owl

Direct and Indirect Effects – Alternative 3

Fire behavior will not be modified across approximately 268 acres compared to Alternative 1. Fire will not be 

returned to the landscape on 716 acres and surface fuel loading will not be sufficiently reduced on 96 acres, 

compared to alternative 1. These areas removed from treatment, in comparison to the proposed action, would

see effects as described under the no action alternative. During the summer fire season, it is possible the area 

could experience passive crown fire since it would not be treated with this alternative. Flame lengths are 

likely to exceed 4 feet, requiring equipment to be utilized to manage a wildfire. The area not being treated 

under this alternative is located next to private property and a portion is within the Wildland Urban Interface.

Fuel models 2, 9, 10 and eventually 13 will be present in the project area. Fuel model 13 results in fire being 

carried by a continuous layer of slash. Large quantities of material greater than 3 inches is present. Fires 

spread quickly through fine fuels and intensity builds up as the large fuels start burning. Active flaming is 

sustained for long periods and a wide variety of firebrands can be generated. These contribute to spotting 

problems as the weather conditions become more severe. Total fuel loading may exceed 300 tons, but the less 

than 3 inch fuel is generally only 10 percent of the fuel load. (NWCG, 2006).

The area excluded from treatment would not meet the desired future condition. It does not meet the 

requirements outlined in the Forest Plan, or current fire policy. The recommendations outlined in the 

watershed analyses will not be implemented in this area. This area would also not be treated according to the 

best available science for fire and fuels management.

The direct and indirect effects to the remaining portion of the project area are the same as described under 

Alternative 1. The portion of the project area proposed for treatments with this alternative would meet current 

fire policy, Forest Plan direction and watershed analyses recommendations.

Effects relative to Purpose and Need for Action

Alternative 3 moves the project area toward desired conditions but provides treatments on fewer acres. 

Objectives would be on the acres being treated. However, Alternatives 3 leaves areas un-treated on more 

acreage than Alternatives 1 or 2, resulting in effects constant with no action. Fire behavior, safety and 

ecological process are not modified on a portion of the project area.

By reducing surface and ladder fuels, as well as crown density, in the project area (thereby changing the fuel 

profile and fire behavior), Alternative 3 would help reduce the risk of loss of early, mid and late-successional

habitat in the project area in treated areas. Like Alternative 1, where treated, stands would be more resilient.

Compliance with law, regulation and policy

Alternative 3 meets Forest Plan direction, watershed analyses desired conditions, regional direction regarding 

ecological restoration, and national fire management policy that was summarized in the Fire/Fuels report, 

across the treated areas.

Cumulative Effects – Alternative 3
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156 Shasta-Trinity National Forest

In elk flat, Pilgrim Vegetation Management Project treatments would be completed68 to meet the objectives of 

returning the area to a pine savannah by substantially reducing stand density in order to restore the more open 

conditions that existed historically and more mimic historical fire regimes.69 When combined with treatments 

in Alternative 3, overall fire behavior will be improved, in the areas treated. It will break up the continuity of 

fuels, helping to reduce fire behavior in the event of a wildfire. This will also create a healthier stand, 

reducing the chances of mortality in the residual trees. Less mortality results in less surface fuel accumulation 

in the future.

Alternative 4 - No Action

Under No Action, the proposed management activities would not be implemented. No direct, indirect, or 

cumulative effects are expected. Although there would be no actions undertaken with this alternative, ongoing 

trends would continue.

Surface, ladder and crown fuels would continue to accumulate in the absence of fire or treatment. With no 

modification of forest structure and fuels, fire behavior under normal, summer conditions would be as 

described in the current conditions, threatening resources within the project area and potentially private 

property. The mortality in the pine may continue to spread. The standing dead that currently exist in the 

project area will fall in the next five to ten years adding to the current surface fuel loading. Wildfire 

management options in these areas with standing dead would be limited. Fire management will not put people 

at risk in these areas. The fire would be allowed to burn until it left the mortality pockets allowing firefighters 

to safely engage. This will add to fire size and under extreme conditions, could create fire control issues.

Once the trees have fallen, surface fuel loadings are estimated to exceed 100 tons / acre in the mortality 

pockets. These areas would be characterized as a fuel model 13. Appendix B of the Fireline Handbook 

(NWCG, 2006) describes fire activity in a fuel model 13 as “fire is generally carried by a continuous layer of 

slash. Large quantities of greater than 3 inches material are present. Fires spread quickly through the fine fuels 

and intensity builds up as the large fuels start burning. Active flaming is sustained for long periods and a wide 

variety of firebrands can be generated.” A wildfire in these pockets with high fuel loading will be high 

intensity. This may require firefighters to back off to an area where intensity will be less. Equipment would 

have a difficult time working in these areas. As a result, the creation of control lines with dozers is not a likely 

tactic.

In the natural stands, where mortality is not yet occurring, fire behavior is going to remain an issue under the 

no action alternative. Some areas in the project are expected to experience passive crown fire and flame 

lengths greater than 4 feet. This will not allow ground forces to directly attack the flanks or head of a fire. 

Equipment or aircraft will be needed to manage a fire under these conditions. Modeling indicated up to 40

percent mortality from a wildfire in the natural stands under 97th percentile weather conditions. With these 

conditions, fire managers are limited to the tactics that could be utilized and would be effective. This has the 

potential to impact our neighbors, as a fire that starts on the forest, within the project area, could move onto 

private lands.

In the absence of management actions, no progress would be made towards initiating the restoration of 

ecological processes that include the natural fire regimes, high frequency (0 to 35 years) low to mixed 

severity fire return intervals. The no action alternative does not follow the national fire policy direction, the 

 68 Thinning 4”-14” dbh encroaching conifers on approximately 147 acres down to 80 square feet of basal area per acre 

with underburning on 25 acres of those acres.

69 The area was partially thinned but retains too many trees to meet the objectives of 80 square feet of basal area per 

acre. As such, trees would be thinned down to 80 square feet of basal area per acre.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 157

Forest Plan, Watershed Analysis or LSRA. It would not contribute to the desired condition, purpose and need, 

or respond to policy aimed at reducing hazardous fuels to modify current fire behavior that would increase 

fire management operations. The ability of firefighters to safely and effectively suppress a wildland fire would 

become more difficult as fire behavior characteristics intensify. Opportunities to return fire back into the 

ecosystem will be limited.

Cumulative Effects

Alternative 4 does not alter the fuels profile nor minimizes fire behavior. There would be no additional direct 

effects in regard to reducing forest fuels or modifying fire behavior. There would be no cumulative effects.

Ongoing trends would continue.

Elk flat treatments from the Pilgrim Vegetation Management Project would improve overall fire behavior and 

fire regime processes on those treated acres (147 acres) within the project area boundary.

Summary and Conclusions

All action alternatives provide some level of reduced surface fuel loading, ladder and crown fuel 

characteristics as well as breaking up fuel continuity over the project area. Table 55 provides a summary of 

fuels effects by indicator and alternative.

Table 55. Summary of Fire and Fuels Effects by Alternative

Indicator Alt. 1 Alt. 2 Alt. 3 Alt. 4

Fuel Loading Reduced

Acres Thinned 2,237 2,154 1,969 0

Acres Underburn 3,482 3,482 2,766 0

Acres Piled 1,461 1,402 1,365 0

Fuel Models 2, 9, 10 2, 9, 10

Trending to 13

2, 9, 10

Trending to 13

2, 9, 10

Trending to 13

Potential Fire Behavior

Flame Lengths <4’ <4’-6’ <4’-6’ 4’-6’

Fire Type Surface Surface / 

passive crown

Surface, 

passive crown Passive crown

Alternative 1 provides for the most area treated and in the most strategic areas such as adjacent to private 

property. This alternative treats the landscape within the project area, providing for the greatest area of 

restored forest. The maximized treatment will provide for the most manageable wildfire behavior following 

the treatments. This alternative also maximizes safety for fire managers implementing prescribed fire 

treatments and managing wildfire. Alternative 1 meets the Land and Resource Management Plan direction, 

Watershed Analyses desired conditions, regional direction regarding ecological restoration and national fire 

management policy across the project area.

Alternatives 2 and 3 move the project area toward desired conditions. These alternatives do provide 

treatments across limited acres in the project area. They meet objectives on the acres being treated. However, 

both alternatives leave areas un-treated, resulting in effects constant with no action. Fire behavior, safety and 

ecological process are not modified on a portion of the project area. 

The no action alternative does not provide for firefighter safety, modify fire behavior, respond to national fire 

direction, or meet the Land and Resource Management Plan direction.
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Wildlife

A draft wildlife Biological Assessment (BA) that assess the predicted effects to listed species under the 

preferred alternative (Jordan, 2015) and draft Biological Evaluation (BE) for sensitive wildlife species 

(Jordan, 2015c) was completed for this project and are incorporated by reference. Information relevant to this 

decision is summarized here.

Introduction

Purpose and Need Applicable to Wildlife70

#1-Risk reduction and increased stand resilience; #2-Accelerating development of late-successional and oldgrowth forest characteristics; and #4-Retaining hardwoods as a stand component are all relative to wildlife. 

#5-Restoration of hydrologic function and #6- Managing the National Forest transportation system and 

decommissioning unauthorized routes are also related from the standpoint of protecting and enhancing latesuccessional and connectivity habitat in Riparian Reserves, and reducing route density in the LSR. The 

existing and desired conditions relating to these Purpose and Needs is fully described in Chapter 1.

Issues Applicable to Wildlife

Issue #1-Large tree and snag removal and group selection logging directly harms late-successional 

ecosystems in Late-Successional Reserves, Riparian Reserves and Critical Habitat; and Issue #3- Treatments 

within designated critical habitat for the northern spotted owl violate the 2011 Revised Recovery Plan and the 

2012 Final Critical Habitat Rule for the Northern Spotted Owl (NSO). The Environmental Consequences 

section discusses the effects of various thinning, and other treatments designed to improve NSO, fisher and 

northern goshawk habitat resilience, function and diversity (group selection in plantations, black oak release) 

and fuels treatment relative to the purpose and need. How these treatments are expected to influence 

designated critical habitat for the northern spotted owl (NSO) is addressed (Key Issue #3). Issues not carried 

forward in this section include a portion of #2 and #3; there are no permanent roads proposed for construction, 

but the effects of Alternative 2 (no new temporary road construction) on wildlife will be compared. Also 

recovery plans are not regulatory (USDI-FWS, 2011 pp. I-3 to I-4) and therefore, cannot be violated. The 

Forest has prepared a consistency assessment for the project and the Recovery Plan.

Methodology

Throughout project design and analysis, the best available scientific and commercial data applicable to the 

project area was utilized. This includes direct observations in and near the analysis areas and the most recent 

and appropriate scientific research or species information. Data sources include but are not limited to the 

Revised Recovery Plan for the Northern Spotted Owl (NSO) and Final Rule for NSO Critical Habitat; and 

information from the State of California, FWS and research literature as it applies to the gray wolf. For 

proposed listed and sensitive species, the FWS’ species profile and Forest-level monitoring and research was 

utilized for the fisher; and local, regional and national research and literature was used for the northern 

goshawk, fringed myotis and pallid and Townsend’s big-eared bats, Shasta hesperian and the western bumble 

bee. This information, combined with field reviews and stand modeling described below, was used to design 

the project treatments, locations and resource protection measures, and to determine the likely effects on 

federally and proposed listed species, Forest Service sensitive species and for other wildlife compliance topics 

(see Appendix H – Compliance and Consistency).

A species list was obtained December 22, 2015 from the Yreka Fish and Wildlife Service field office through 

IPaC71 at https://ecos.fws.gov/ipac/gettingStarted/index. Based on review of the list, species assessed in detail 

 70 Purpose and need and issue statements are paraphrased for brevity and applicability to the wildlife resource.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 159

in the BA include the threatened northern spotted owl (NSO) and endangered gray wolf. The Consultation 

section in the BA fully describes the streamlined consultation process to date with the FWS and the 

development and modification of treatment prescriptions and project design features and is included as 

Appendix E. The draft BA is available in the online project record.

Field reviews and ground trothing was done from August 2009 through May 2013. These reviews were used 

to establish a spatial layer and acreage of habitat type and quality for the listed NSO and Forest Service 

sensitive species, and to determine where mechanical treatments should be excluded and fireline may be 

needed to protect higher habitat quality or areas of documented species use (territories, denning habitat). 

Reviews were completed in the project area and on surrounding private and NFS lands, with additional field 

and vegetation analysis work completed in fall 2015 to assess the existing condition for the listed gray wolf. 

Field reviews were supplemented by the draft NSO Habitat EVEG model for SMMU (NSO action area and 

fisher analysis area), the Forest’s existing vegetation layer from the Remote Sensing Lab (USDA-FS, 2007a)

(NSO and gray wolf action areas), aerial photo interpretation (2012 and 2014 NAIP), and NSO habitat maps 

provided by private landowners. SMMU NSO and goshawk survey records (1989-2009) and the 2014 and 

2015 carnivore surveys for the Management Unit (USDA-FS 2014, 2015) were reviewed; and species data 

from the California Natural Diversity Database (CNDDB) and Forest’s Natural Resources Information 

System (NRIS) was queried (2013-2015). Protocol surveys and activity center stand search data for NSO 

(1990-present), northern goshawk surveys (1985-present) and forest carnivore surveys (2002/2003, 2014-

present) have also informed the project design and analysis.

Project area common stand exams (CSE) (USDA-FS, 2007) and FACTS data for plantations was used to 

supplement the field reviews for habitat type and quality. Fuel loading data was assessed in 2007 using 

Browns Transects, and again in 2011 using ocular estimation and photo series methods (Maxwell, et al., 

1979). Predicted future stand attributes were modeled from the CSE and fuels data, using the Forest 

Vegetation Simulator (FVS) Inland California and Southern Cascades variant (Keyser, 2008, 2013). The FVS 

Fire & Fuels Extension (FVS-FFE; (Reinhardt, et al., 2003) was used to model pre- and post-treatment fuel 

loading, vegetation characteristics that influence fire behavior (canopy base height and crown bulk density) 

and flame lengths. These methods are fully described in the Silviculture and Forest Health and Fire and Fuels 

section. The FVS-FFE modeling assumptions, limitations and applicability to the indicators and information 

regarding the Action and No Action alternatives considered in detail are also described in the silviculture

report (Payne, 2015b) and the Fire and Fuels resource report (McRae, 2015).

Wildlife Specific Assumptions

• Acres and stand conditions are approximate and in some cases, existing conditions (basal area, 

canopy closure, tree size classes) are averaged across a combination of similar stands.

• Minor differences in acreage effects may exist between this analysis and other documents or 

appendices due to rounding and/or differences in resource analysis areas and methodologies 

employed for assessing impacts. These differences do not invalidate this analysis or conclusions.

• New landing sizes are approximated to range between 0.5 - 0.75 acre, with the maximum acreage 

assessed to account for the maximum potential effect. Depending on unit acreage, alternative, and 

layout, units smaller than 30 acres may require their own landing. Existing landings and natural 

openings would be used as feasible to reduce new disturbance, and in accordance with RPMs, though 

final landing location is approved during sale administration.

 71 IPaC refers to the USDI Fish and Wildlife Service’s Information for Planning and Conservation. It is a tool to assist 

project proponents in increasing the compatibility of activities with the conservation of FWS trust resources. It is meant to

assist in implementation of all activities proposed under section 7 or 10 of the ESA.
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160 Shasta-Trinity National Forest

• Temporary road widths would not exceed 14 feet.

• Under all proposed activities, trees, snags, or logs that are a safety hazard to the public or operations 

may be felled and/or removed.

Incomplete and Unavailable Information

For stands not included in the 2007 CSE and Browns Transects, similar stand data was utilized to extrapolate 

what the effects may be from treatment and No Action. Extrapolation was applied based on field 

reconnaissance to compare stand conditions, stand history and aerial photo comparisons. There are some 

assumptions and limitations in the analysis regarding the effects of thinning and fuels treatments under both 

No Action and Action scenarios (see the Silviculture and Forest Health section for a full description of 

assumptions). In summary, while the 2007 CSE data and FVS-FFE modeling program work in concert, the 

data is just under nine years old. The subsequent field reviews in 2010-2014, and additional sampling of fuel 

loading in 2011, further informs the analysis. However, the age of the CSE data and the rapidly changing 

conditions and increased mortality, notably in the ponderosa pine component, between 2009 and 2012 is such 

that the conclusions presented in the modeling results reflect trends, and not absolute numbers. This is 

particularly relevant for the indicator of snags larger than 20 inches in diameter.

Additionally, specifics on species, size classes and associated tons per acre of down wood are not available. 

The existing condition for down wood was estimated based on the collected data in Browns Transects and 

subsequent field reviews.

The modeled results of the No Action and Action alternatives considered in detail for fire effects (flame 

lengths, rates of spread, severity) is also not available to be spatially displayed, though the Fire and Fuels 

section discusses these effects in general terms. The wildlife analysis uses these general terms, and the output 

results from individual stand modeling in FVS-FFE, to describe the expected fire behavior in certain stands 

and extrapolating that to similar stands. While the Map 6 data set in the BA displays predicted fire behavior 

under No Action, based on the 2007 CSE and Browns Transect data, this mapping effort has not been updated 

to reflect the changed/changing stand conditions and higher levels (40-100+ tons per acre) of fuel loading in 

the eastern and southeastern portions of the project area. It also does not account for the increase in mortality 

pockets in young and old plantations, or the increase in mortality pockets in the mixed conifer-pine natural 

stands in other portions of the project area. 

Indicators and Measures

When considering effects on wildlife, the primary factors of change and impact include those factors that 

either influence habitat suitability, use or species behavior. Predicted direct, indirect and cumulative effects 

(as defined under the ESA for NSO, as well as NEPA cumulative effects) are evaluated using a combination 

of qualitative and quantitative indicators. These indicators help determine the degree (magnitude, duration and 

intensity) to which treatments may affect individuals and their habitat components; including predicted 

changes in an individual species’ response to a disturbance or habitat manipulation, or changes in habitat 

function at various spatial scales.

Integral to the indicator effects analysis is how specific prescription elements, project design, and resource 

protection measures (RPMs) reduce the potential for direct, indirect or cumulative effects (including shortterm adverse or long-term beneficial effects). This analysis is based on research, local and regional 

monitoring and other applicable best available science. These indicators are also used to compare how 

alternatives meet the purpose and need and the key issues.

Issue indicators applicable to wildlife are listed in Table 56 as they relate to achievement of the purpose and 

need, and key issues. See Table 29 PART II in Chapter 2 for the comparison of Key Issue #3 and the same 

table PART III for the comparison of general habitat indicators for late-successional associated species. There 

are no purpose and need or key issue indicators relative to the gray wolf or sensitive species (other than 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 161

northern goshawk and fisher). Therefore, an analysis for these species is not included here. For the general 

analysis of project effects on these other species, refer to the BA and wildlife BE, available in the online 

project record. For Key Issue #3, the listed indicators in Table 56 are used to measure the scale of how the 

alternatives considered in detail meet the management guidance, and the special management considerations 

described for critical habitat subunit ECS-3 in the 2012 Final Critical Habitat Rule for the Northern Spotted 

Owl (USDI-FWS, 2012).

Table 56. Indicators for NSO and sensitive species Relative to Purpose and Need and Key Issues

Species Indicator Scales Assessed Measurement for how project actions 

inform the indicators

Direct Effects to Individuals

NSO

Potential for direct disturbance 

to breeding pairs, young, 

and/or dispersing individuals

Known Core/ 

Territory

-Distance (miles) to breeding 

pairs/individuals and location of 

treatments (i.e., proximity to nests, high 

quality habitat)

-Duration (time) of silviculture, fuels, 

hydrology treatments and road actions

Northern 

goshawk

Fisher

At the Stand Scale, 

Presence of Denning 

Habitat

Direct and Indirect Effects to Habitat and Achieving Purpose and Need: Risk Reduction and Increased 

Stand Resilience (Issue #1 and 3); Late-Successional Habitat Enhancement including Hardwood Diversity, 

Connectivity and Riparian Reserve function (Issue #1 and 3); and Temporary Road Construction and Route 

Decommissioning (Issue #2)

NSO

-Acres of suitable habitat 

(nesting, roosting, foraging)

benefitted/maintained, 

degraded, downgraded or 

removed

-Acres of dispersal habitat 

affected

-Acres of capable habitat 

moved toward 

dispersal/suitable

0.5-mile core

-Size class, density, species composition 

and canopy cover of the resultant stands 

pre, immediately post and 20-years after 

treatment (informs habitat acres)

-Stand variability and structural 

complexity, including understory 

layering, snags and CWD (informs 

habitat acres)

-Flame lengths and fire type as a 

measure of intensity and severity

-Route density reduction and changes in 

access and potential conflicts with 

humans

1.3-mile home range

Treatment Unit

Project Area 

Elk Flat LSRConnectivity

Northern 

goshawk

-Acres of suitable habitat 

benefitted/maintained, 

degraded, downgraded or 

removed

-Acres of capable habitat 

improved

Known Territory

Treatment Unit

Project Area

Elk Flat LSRConnectivity

Fisher

-Acres of denning, resting, 

foraging (RDF) habitat 

benefitted/maintained, 

degraded, downgraded or 

removed

-Acres of capable habitat 

improved

Denning Structure

Stand Level RDF

Treatment Unit

Project Area

Elk Flat LSRConnectivity
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162 Shasta-Trinity National Forest

Species Indicator Scales Assessed Measurement for how project actions 

inform the indicators

Key Issue #3 – Effects to NSO Critical Habitat

NSO

-Acres maintained/benefitted

-Acres degraded, downgraded 

or removed

-Acres suitable habitat 

projected in 20 years 

(PCE2/PCE3)

-Acres dispersal habitat 

projected in 20 years (PCE4)

-Acres capable habitat 

projected in 20 to 30 years 

(PCE1)

0.5-mile core Acres of PCE1, PCE2, PCE3, PCE4 

affected are measured by:

-Size class, density, species composition 

and canopy cover of the resultant stands 

pre, immediately post and 20-years after 

treatment (informs habitat acres)

-Stand variability and structural 

complexity, including understory 

layering, snags and CWD (informs 

habitat acres)

1.3-mile home range

Project Area

Boundaries

To determine relevant past, present, and foreseeable future projects, spatial and temporal boundaries must be 

defined (CFR § 220.4 (f)). Wildlife use and distribution in and across an area is primarily influenced by 

availability of suitable habitat and connectivity within and between habitat elements. Use is influenced by 

site-specific factors such as structure or physical features (e.g., tree/shrub species, size class, canopy closure; 

CWD and snags; decadence and cavities; water; caves; forage base) as well as by landscape considerations 

such as proximity to other suitable habitat or the need for isolation or seclusion. A multi-scale analysis that 

assesses site-specific conditions within stands proposed for treatment, and on the larger landscape in terms of 

proximity to and availability of other suitable habitat, is generally considered.

Spatial Bounding

For the direct and indirect effects of the project relative to NSO, northern goshawk and fisher, these 

conditions influence these species: disturbance to breeding, feeding and sheltering behaviors and habitats; tree 

and shrub species composition and juxtaposition on the landscape; stand structure (layering, canopy cover, 

decadence); down wood and recruitment; existing snags and large snag recruitment; prey base; and 

connectivity. For all action alternatives, direct and indirect effects are evaluated at the treatment unit and 

project area scale as this this reflects the physical footprint where activities would occur, and therefore, 

potential direct effects (e.g., mechanical thinning/fuels treatments, hand thinning, prescribed fire, road 

management and noise-generating activities).

Other biologically meaningful scales are utilized as described in Table 56 above, including NSO core and 

home range, known northern goshawk territories, and at the stand level for the fisher, resting or denning 

structure or known denning areas (based on field surveys). Effects analyses can also occur across multiple 

analysis units that frequently overlap and are relevant to conservation concerns for species, including larger 

conservation units such as critical habitat or LSR designation. Spatial bounding for cumulative effects is 

generally unique to each species considered and for cumulative effects to occur, the effects of the actions must 

overlap in space and time for there to be potential cumulative effects; determined by how long, and how far 

reaching an action’s direct and indirect effects are felt on a given resource area. While there may be an 

overlap in two or more projects’ cumulative effects spatial (or temporal bounds), where there are no direct or 

indirect effects that overlap in time and space, there are no cumulative effects.

The ESA defines the spatial boundary for analysis as the action area, which includes all areas likely to be 

affected directly or indirectly by the proposed Federal action and not merely the immediate area involved in 

the action (50 CFR §402.02). The action area is generally larger than the project area, but only encompasses 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 163

the geographic extent of environmental changes (i.e., the physical, chemical and biotic effects) that may result 

directly and indirectly from an action, and elicit a response in an individual (USDI-FWS 2015). For the NSO, 

a 1.3-mile buffer on Alternative 172 silviculture, fuels treatments and road actions defines the spatial bounds 

of the action area. This bounding is an appropriate scale, as it is equivalent to the radius of the estimated 

median annual NSO home range size in northern California, based on radio-telemetry data (Thomas et al. 

1990, (USDI-FWS, 2011). It allows for an analysis of any other adjacent or overlapping territories/home 

ranges and potential effects to connectivity, thereby framing the context and significance of potential impacts 

to those other areas. It is also the accepted range by the FWS for NSO effects analysis, and it includes 

managed private timberlands that may influence NSO habitat use in and outside the project area. The NSO 

critical habitat analysis area is simply the portion of the action area that overlaps critical habitat.

For the northern goshawk, spatial bounding also consists of all areas within 1.3 miles of the Alternative 1 

silviculture, fuels treatments and road actions. This area is appropriate as it is equivalent to the radius of a 

typical NGO home range in this region, although territory size is generally at 200-250 acres, and home ranges 

can include multiple territories for an individual pair (Woodbridge and Hargis 2006). It allows for analysis of 

any adjacent known territories of other pairs, framing the context and significance of potential impacts to 

those other areas or individuals. It also includes managed private timberlands that may influence NGO habitat 

use in and outside the project area and it is large enough to assess potential effects to connectivity.

For the fisher, since there are no telemetry studies in this part of the fisher’s range to base an average female 

home range size upon, a habitat-based approach was agreed to with the FWS (Jordan, 2015) (Jordan, 2015c). 

The spatial bounding encompasses the entire project area, and extends north, up to the ~6,500-foot elevation 

range. It then extends northwest and northeast to the extent of available reproductive habitat, based on stand 

conditions, age class, species composition and cover. This approach is biologically meaningful for this 

species, is likely adequate to support approximately three female home ranges and like the NSO and northern 

goshawk, includes managed private timberlands that may influence fisher habitat use in and outside the 

project area and is large enough to assess potential effects to connectivity. The “fine-scale” spatial analysis 

area for effects to fisher consist of treatment unit, stand level and resting/denning structure (see Table 56).

Temporal Bounding

Temporal bounding consists of both short- and long-term timeframes. Short-term consists of when treatments 

occur and vegetation begins to respond, usually within one season to 10 years of treatment implementation.

Long-term effects extend for approximately 20 or more years after treatment and correspond to the modeled 

changes and effectiveness of thinning and fuel treatments described in this EIS and respective analyses. Direct 

effects are defined by the period that actions would be occurring in/near treatment units, reproductive areas, 

and habitat (short term). Indirect effects occur over both the short and long term.

It is estimated to take 5 to 10 years for initial thinning, fuels treatments, reforestation activities and road 

actions to be completed. Fuels treatments are expected to occur within approximately one season to 10 years 

after thinning/harvest treatments, given that some pile burning could occur a few years after the last units are 

harvested. Three prescribed fire entries are proposed and are estimated to take up to 30 years to implement.

Temporal bounding for cumulative effects under the ESA73 consists of the period when all proposed 

treatments and activities are expected to be completed, and when any effects from foreseeable future State or 

 72 This alternative affects the most acres, and therefore accounts for all treatment activities that could occur.

73 Those effects of future State or private activities, not involving Federal activities, that are reasonably certain to occur 

within the action area of the Federal action subject to consultation. [50 CFR §402.02] This definition applies only to 

section 7 analyses and should not be confused with the broader use of this term [cumulative effects] in the National 

Environmental Policy Act or other environmental laws (March 1998 ESA Consultation Handbook, p. xiii).
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164 Shasta-Trinity National Forest

private actions can be reasonably predicted and felt on the landscape in combination with the project’s effects. 

For NEPA cumulative effects, the effects of past, ongoing and reasonably foreseeable future projects on 

Federal, State or private lands is assessed.

The baseline year used for this analysis and the existing condition is 2014. The description of the existing 

condition in Chapter 1 for the project area, and the Affected Environment section below for the three species 

includes the accumulation of past activities, which have influenced vegetation and species use. The current 

environmental conditions reflect the aggregate impact of all prior human actions and natural events that have 

resulted in the current environmental conditions, and might contribute to cumulative effects and are a proxy 

for the impacts of past actions.74

Based on the modeled and expected treatment effectiveness and that past projects maintained a higher tree 

density, allowing for canopy recovery in 15 to 20 years (Fleming 2012), it is reasonable to establish temporal 

bounding by a 20 to 30 year window of recovery. This timeframe is adequate to encompass several NSO, 

northern goshawk and fisher breeding attempts, and potential disturbances to those attempts, notably since 

NSO and northern goshawk do not attempt to breed every year and the number of years varies between each 

attempt (Forsman, et al., 1984); USDA-FS 1989-2015 NGO records). It also includes the period that project 

actions and effects would be occur, and potentially overlap with other private, state, or federal activities and 

those effects. A comprehensive review of past, ongoing and reasonably foreseeable future actions on private 

and NFS lands within the NSO, northern goshawk and fisher spatial and temporal bounding was completed 

and, and is included in the project record (Jordan, 2015c; Jordan, 2015b).

Affected Environment

As described in Chapter 1, the risk of losing late-successional stand conditions, NSO and other latesuccessional species habitat and critical habitat in the project area is the direct result of an elevated epidemic 

natural ecological process; the presence of blackstain and Heterobasidion root disease combined with pine 

and white fir overstocking, prolonged drought conditions and bark beetle attacks in pine. These conditions 

have resulted in increased fuel loading (100+ tons in some portions, but average 60 tons per acre) in a 

significant portion of the project area. Other contributors to the existing condition include past management 

actions, fire suppression and a lack of a low-intensity natural fire return interval. Most plantation and natural 

stands identified for mechanical thinning and other restoration and diversity treatments are either uniformly 

dense in the mid and understory (i.e. pine, white fir and cedar regeneration) or lack horizontal and vertical 

diversity (stands are pole-medium trees with stagnated growth and no under or midstory). In the ponderosa 

pine-dominated stands, the overall stand is at risk due to general overstocking, root disease, beetles or a 

combination of these factors. The natural stands and older plantations typically have scattered predominant 

legacy trees that range from 42-80”+ inches diameter dbh. The 20-40+ year old plantations are predominantly 

ponderosa pine, containing densely spaced trees with interlocking crowns that limit growth potential and put 

surrounding stands at risk.

NSO, fisher and northern goshawk (NGO) habitat, particularly NSO nesting/roosting and high quality 

foraging, fisher resting/denning, and NGO nesting habitat are typically equated with late-successional and 

old-growth forest conditions. Foraging and dispersal habitats provide source habitat for prey base, protection 

from avian and carnivorous (bobcat) predators and contribute to connectivity. Connectivity as defined in the 

NWFP is a measure of the extent to which the landscape pattern of the late-successional and old-growth 

ecosystem provides for biological and ecological flows that sustain late-successional and old-growth 

associated animal and plant species. It does not necessarily mean late-successional and old-growth areas have 

 74 This approach is consistent with CFR § 220.4 (f) and the Council on Environmental Quality June 24, 2005 

memorandum regarding analysis of past actions.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 165

to be physically joined in space, as many late-successional associated species can move across areas not in 

late-successional ecosystem conditions. In dry forest landscapes, retaining structural legacies (large trees that 

tend to be fire tolerant, snags and down wood created through stand development or disturbance events) is 

important to maintaining habitat and connectivity. These structural legacies serve valuable functions, 

including reproductive structure, cooler microclimates, prey and forage base, or help maintain or improve 

connectivity (Franklin, et al., 2007). Restoring ecosystem function that provides increased resiliency will 

necessitate maintaining and restoring these biological legacies that typically persist through disturbance 

events and can help influence stand recovery process in a post-disturbance landscape (Franklin, et al., 2000)

The NSO action area is approximately 15,960 acres in size; consisting of NFS lands (8,303 acres; 52%) and 

private lands (7,657 acres; 48%). Elevation ranges from 3,000 to 5,200 feet. There is one NSO activity center 

(AC) and associated core and home range in the action area, designated ST-215.

Based on survey and stand search data, the ST-215 AC has not been occupied by a pair or a single territorial 

NSO since 1990, when the last nesting attempt failed. In 2003, a single subadult female NSO was detected 

during a nighttime calling survey; and in 2011, a probable NSO feather was found in the core during a stand 

search (Farber, 2013). In both cases, an aural or visual detection of NSO did not occur during follow-up 

surveys. Annual stand searches (2-3) have been completed in the core since 2007, with 3-visit protocol 

surveys of the action area completed from 2003-2005 and 2007-2011. Starting in 2012, and continuing 

through 2014, six nighttime calling visits were completed; with a modified 3-visit spot check completed in 

2015 (in accordance with the January 2012 NSO Survey Protocol and its guidance for annual survey 

coordination with the FWS and landowners (USDI-FWS 20. 12). An adult male barred owl was detected in 

the project area in 2004, and a pair was detected intermittently during the 2012-2014 nighttime calling 

surveys. Barred owls were not detected during the daytime stand searches and neither the Forest Service or 

private land surveys located the nesting area. In fall 2014, the barred owl pair was removed (Feamster, et al., 

2014)During the 2015 surveys and stand searches, there were no NSO or barred owl detections. The BA 

describes the 1989-present survey history.

Approximately 458 acres (92%) of the ST-215 core is on NFS lands in the project area, with the remaining 42 

acres on private lands to the north, owned by Olympic Resource Management (previously Hancock).75

Conversely, approximately 1409 acres (41%) of the home range is on NFS lands, with the remaining 59% on 

private lands to the north and west (owned by Sierra Pacific Industries).

Habitat types for NSO in the action area include suitable (nesting, roosting and foraging, including high 

quality foraging), dispersal, capable and non-habitat. The BA fully describes habitat types, habitat quality, 

quantity and connectivity of NSO habitat in the action area and project area. Habitat in the action area was 

identified and quantified using a combination of sources (see Methodology above). Habitat suitability on NFS 

lands and private lands in the action area are primarily non-functional, followed by a combination of 

dispersal, foraging and pockets of nesting/roosting.

The project area encompasses the 3,074-acre Elk Flat LSR (RC-360) and approximately 445 acres of matrix 

lands in Commercial Wood Products emphasis. The break in land allocation bisects the Elk Flat meadow and 

the meadow and matrix lands are primarily non-functional habitat for NSO, though unit 177 provides some 

foraging habitat. Approximately 36% of the project area provides suitable habitat (nesting, roosting, 

foraging); 9% is dispersal; and another 9% is considered capable of transitioning to dispersal and suitable 

with treatment. The remaining 46% of the project area is not capable of supporting NSO habitat as they 

generally avoid forest stands with overstories dominated by ponderosa pine and relative probability of use 

declines within increasing basal area of ponderosa pine (USDI-FWS, 2011; Irwin, et al., 2007; Irwin, et al., 

 75 Lands are managed by Black Fox Timber Management Group, Inc.
Elk Flat LSR Enhancement Project

166 Shasta-Trinity National Forest

2012). The non-functional NSO habitat includes areas proposed for salvage adaptive management, hazard 

reduction treatments and the extensive mortality area, though these areas do support prey.

Habitat quality and suitability in the project and treatment area was evaluated closely, particularly in the 60-

120 year-old natural stands proposed for mechanical thinning and other restoration treatments, or 

underburning-only. Suitable habitat in the project area is variable and quality and function are wholly 

dependent on the unique, local stand attributes. This includes but is not limited to basal area ranges, tree 

species composition and canopy closure – where there is a mix of incense cedar, sugar and ponderosa pine, 

Douglas fir, black oak, and white fir ranging from 180-260+ basal area, layering and canopy closure of 70+ 

percent, stands type out as high quality foraging or nesting/roosting. Where basal areas are lower, or natural 

stands are primarily composed of ponderosa pine and white fir, with canopy closure of 40-70%, stands 

typically type out as moderate or lower quality foraging or dispersal, though this is also dependent on canopy 

closure and presence of other stand attributes that may support foraging NSOs. Where natural stands are 

predominantly composed of ponderosa pine, they are considered non-functional NSO habitat (Thomas, 1990; 

Thomas, et al., 1990; USDI-FWS, 2011; Irwin, et al., 2007; Irwin, et al., 2012; Zabel, et al., 1992; USDIFWS, 2009).

Other factors that determine habitat type and quality in the project area are average diameter class, species, 

layering or density of mid and understory trees - is stand development stagnate, or is the understory too dense 

for owls to fly through? How many trees (and species composition) per acre >26” dbh and 20-24” dbh with 

cavities, broken tops, or large limbs? Are there large (>20”diameter) snags with cavities? Is there abundant 

large down wood in combination with under, mid and overstory tree species and canopy cover that support 

foraging and dispersing NSOs, including perching sites for hunting, thermoregulation sites for roosting and 

overstory protection from avian predators? Are there openings, edges, hardwood and shrub species or earlier 

seral stands that support dusky-footed woodrat or other NSO prey? Abiotic factors contributing to habitat 

suitability in the project area include elevation, slope position and distance to water. There are 240 acres of 

Riparian Reserves that overlay LSR and matrix, and the Riparian Reserves along Ash Creek in the LSR 

primarily function as nesting/roosting, high quality foraging or foraging habitat. Also as elevation increases in 

the project area, stand suitability increases. Another key factor influencing use of foraging habitat, and 

subsequent evaluation of effects of treating such habitat, is its proximity and connectivity to nesting/roosting 

habitat. It is well-documented that during the breeding season, foraging decreases with increasing distance 

from the nest stand, and therefore stands greater than one mile from suitable nesting/roosting habitat have a 

low probability of use by foraging NSOs (Bart, 1995; Bingham, et al., 1997; USDI-FWS, 2009; USDI-FWS, 

2011).

Based on the preceding general conditions, ground-truthing and 2007 CSE data, the nesting/roosting habitat 

currently exists in the northern portion of the project area, within one large block, and pockets along Ash 

Creek to the southeast. In the western, northern and central portions of the project area, there are stands and 

patches of low, moderate and high quality foraging habitat (foraging habitat trending toward nesting/roosting 

conditions) interspersed with early and mid-seral plantations (10-40+ years old). The older, dense, monotypic 

ponderosa pine plantations are considered capable of transitioning to dispersal or suitable foraging habitat 

with treatment. These stands are primarily in the core and home range on NFS lands, with few stands of 

foraging and dispersal in the eastern portion.

The NSO action area contains approximately 797 acres of designated critical habitat within Unit 8, Subunit 3 

(East Cascades South [ECS-3]) (USDI-FWS, 2012). 720 acres are in the project area, all in the western 

portion of the Elk Flat LSR. The remaining 77 acres are located approximately four miles east of the project 

area critical habitat, along the base of Black Fox Mountain. Critical habitat is not designated on surrounding 

private lands or within the project area’s ponderosa pine-dominated stands or meadow at Elk Flat. The draft 

BA in the online project record contains numerous maps displaying habitat, critical habitat, project treatments 

and other modeling results. Table 57 below displays the amount of habitat types and critical habitat 

designation at the NSO action area, Elk Flat LSR, treatment area, project area, and core/home range scales.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 167

The NGO analysis area is the same spatial area as the NSO action area. There are two NGO territories in the 

analysis area, ST-205 Elk Flat (in the LSR) and ST-259 Cramer (northeast of project area on Matrix lands). 

Based on annual surveys and territory checks, ST-205 has been active since 1985, though not reproducing 

every year (USDA-FS 1989-2015 NGO survey records). This territory is located in the south-central portion 

of the project area and is excluded from mechanical treatment.

Northern goshawks nest in dense, mid-mature and-late successional conifer forests and typically forage in 

these and mid-successional stands. For purposes of this analysis, suitable NGO habitat is considered the same 

as NSO NRF habitat, and also includes more variable NSO dispersal habitat in the project area, depending on 

stand conditions, presence of small natural and man-made openings and forest edges. Approximately 39% of 

the project area is suitable habitat for the NGO and 9% is capable of providing suitable habitat over time. The 

remaining 52% is non-suitable for NGO due to small tree size or lack of cover, but the extensive mortality 

area and other areas of large-scale pine mortality do provide a prey base for NGO and other species.

The fisher analysis area is 10,112 acres, comprised of NFS and private industrial timberlands. There are 

approximately 649 acres of resting/denning habitat and 4,725 acres of foraging habitat with the remaining 

considered non-functional due to clearcuts or other meadow openings that lack cover. For the purposes of this 

analysis, NSO nesting/roosting and high quality foraging is considered a proxy for fisher denning and resting 

habitat due to presence of large trees, denser canopy closure and structural complexity (USDI-FWS, 

2014).While canopy closure may be less dense than that found in NSO N/R habitat, NSO foraging habitat is 

also a proxy for suitable fisher foraging habitat given the presence of large trees, variability in the under and 

midstory and proximity to higher quality stands. As described above, the majority of matrix lands in the 

project area are not considered suitable habitat for NSO, but some portions of the forested stands along the 

eastern boundary of the project may provide foraging or resting habitat for NSO, NGO or fisher. See Table 58

for the acres of habitat in the analysis area and project area for both NGO and fisher.

Female home ranges for fisher in the analysis area are unknown, though based on field observations and 

camera survey detections, there is at least one, if not two, in the project area (USDA-FS 2014-2015). Within 

the detection and denning habitat areas, no mechanical treatments are proposed and direct ignition during 

prescribed fire would not be used in these areas. These areas are concentrate in the NSO nesting/roosting 

habitat and areas along Ash Creek where there are large trees and snags that provide den sites, abundant down 

wood and 60% or more canopy closure.

In the NSO action area and NGO/fisher analysis areas, private lands are intermixed with NFS lands. The 

harvest practices on industrial timberlands directly west and north of the project area have significantly 

reduced the amount and recruitment of important key habitat features used by late-successional associated 

species, including large diameter snags and down wood. Even-aged management, sanitation, and selection 

harvest has been moderately extensive on the private lands, resulting in a landscape dominated by early-or 

mid seral stands with significantly fewer structural features associated with northern spotted owl, goshawk 

and fisher use. Connectivity to the north is provided in small patches of foraging, or nesting/roosting habitat, 

to federal lands within the Mt. Shasta LSR area (refer to the BA in the online project record for maps).

Table 57. Acres of Suitable, Dispersal, and Capable Habitat and Acres of Critical Habitat (CH) in NSO Action Area

Habitat

ST-215 

0.5-mile 

core^

ST-215 

1.3-mile home 

range^

Treatment 

Unit^

Project 

Area^

Elk Flat

LSR^

Action 

Area

Nesting/Roosting (N/R) 125 126 120 120 120 265

High Quality Foraging (HQF) 24 82 89 89 89 89

Foraging (F) 196 1048 1044 1053 1048 3329
Elk Flat LSR Enhancement Project

168 Shasta-Trinity National Forest

Habitat

ST-215 

0.5-mile 

core^

ST-215 

1.3-mile home 

range^

Treatment 

Unit^

Project 

Area^

Elk Flat

LSR^

Action 

Area

Dispersal (Di) 9 958 301 317 301 3801

Capable (Cap) 96 334 329 331 331 335

Non-Habitat (Non) 50 850 1600 1609 1185 8141

Total NSO Habitat 500 3398 3,483 3,519 3,074 15,960

PCE1 (Cap) 91* 165 165 165* 165 165

PCE2 (N/R) 120* 120 120 120* 120 120

PCE3 (HQF) 13* 22 22 22* 22 22

PCE3 (F) 154* 308 308 308* 308 308

PCE4 (Di) 0* 76 15 15* 15 76

Non-Habitat in CH 46 106 90 90 90 106

Total CH Designation 424 797 720 720 720 797

^ Portions of the core, home range and action area are located on private lands. Acres are reported at varying scales and 

are not meant to be summed (i.e. core habitat acres may overlap with critical habitat designation, treatment and project 

area and the Elk LSR scales). The treatment unit habitat is the existing condition, not the amount proposed for mechanical 

treatment; though all treatment areas are subject to prescribed fire in accordance with resource protection measures.

*Scale of Affected Area Examined for Key Issue #3

Table 58. Acres of Suitable and Capable Habitat in NGO and Fisher Analysis Areas and Project Area

Habitat Analysis Area Project Area

Suitable NGO Habitat

Nesting/Foraging 353 209

Foraging 4,849 1,151

Capable 335 331

Non-Habitat 10,423 1,828

Analysis and Project Area Total 15,960 3,519

Suitable Fisher Habitat

Resting/Denning 649 209

Foraging 4,725 1,577

Capable 935 335

Non-Habitat 3,803 1,398

Analysis and Project Area Total 10,112 3,519

Environmental Consequences

Alternative 1- Modified Proposed Action

Direct and Indirect Effects – Alternative 1

The project’s design features (how the project was designed to minimize or avoid direct effects to individuals 

and habitats, including excluding treatment units and high habitat quality areas from mechanical treatment) 

and the Resource Protection Measures (measures taken during implementation that also minimize the 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 169

potential for direct or indirect effects) are described in Chapter 2. Resource protection measures specific to the 

NSO, northern goshawk and fisher include limited operating periods for habitat altering and noise and smokegenerating activities and limiting the use of direct ignition in high quality habitat areas. The project design 

and RPMs were developed through the interdisciplinary process and discussed during the Streamlined 

Consultation Process with the FWS (Appendix E).

Direct Effects to Individuals

Direct effects to individuals are not expected, as there are no mechanical treatments proposed in the ST-215 

core, the ST-205 northern goshawk territory, suspected or known fisher denning areas, NSO nesting/roosting 

habitat or high quality habitats that may be used as reproductive sites. RPMs in Chapter 2 (31, 32, 33, 34, and 

39) describe the limited operating periods (LOPs) and other measures that will be implemented to minimize 

or eliminate direct effects to breeding individuals during critical periods. These RPMs explain the start times 

for LOPs and the criteria that must be met to lift them. Surveys, activity center searches and spot checks per 

the 2012 NSO survey protocol will be continued prior to, and throughout project implementation. Carnivore 

monitoring and NGO surveys will also be implemented (see the Monitoring Common to All Action 

Alternatives section for wildlife and silviculture at the end of the RPMs in Chapter 2).

Adult and sub-adult NSOs and goshawks, and adult fishers are mobile and able to move away from 

disturbances (noise from heavy equipment use; falling of trees; smoke from pile burning or underburning; 

noise from road actions and hauling of logs and/or chips). These stressors have a higher likelihood of 

affecting adults, juveniles and kits during the breeding season however, when adults are closely associated 

with a core, territory or multiple natal and maternal den sites. Juvenile NSOs and NGOs are not yet able to fly, 

and fisher kits are not mobile enough to travel with their mothers until about 4 months of age (Aubry and 

Raley 2006). Adults expend high amounts of energy defending their territories during the critical breeding 

periods (typically extending from February 1 through 1) the end of July for fisher; 2) mid-August for NGO; 

and 3) mid-September for nesting NSOs. The LOPs and other measures developed in coordination with the 

FWS, and the IDT, are expected to minimize, if not eliminate, the likelihood that project activities will have 

direct effects on single and/or breeding NSOs, goshawks, fisher or their young. The project also includes 

provisions for limiting activities in the event of any new discoveries. Smoke from pile burning and 

underburning may cause foraging or dispersing individuals to move away from smoky areas in the short-term, 

though this potential effect would be of short duration, several days or less in any single location.

All action alternatives include applying a registered borate compound to stumps ≥14 inches diameter within 4 

hours of cutting to reduce or inhibit the spread of Heterobasidion root disease (annosus). The solid Sporax® 

or liquid Cellu-Treat or possibly other brands or formulations may be used. Based on the analysis of where the 

compound may need to be applied (stands with expected stumps >14”), approximately 1,040 acres may 

receive treatment under Alternative 1. If Sporax® is used, it would be applied at a rate of approximately one 

pound/acre under. Application of any compound will follow all state and federal rules as they apply to 

pesticides and will not be applied during precipitation events. The potential toxicity of Sporax® and boron to 

mammals, birds, fish, amphibians and terrestrial and aquatic invertebrates and fungi is discussed in several 

publications (EPA, 1993) (USDA-FS, 2006). Based on this research, Sporax® application to cut stumps is not 

expected to have adverse effects on wildlife or surrounding plants, invertebrates or microorganisms (USDAFS 2006). At high concentrations, it is toxic to plants and measurements of soil, plants and litter at distances 

up to five meters from stumps at various times post-application do not indicate treatment-related increases in 

boron content. While the potential exists for an NSO, goshawk or fisher to consume contaminated prey or 

water, risks to avian and terrestrial species are low with most acute and chronic risk quotients well below 

levels of concern (USDA-FS, 2006). Considering that: 1) it is unlikely for an NSO, goshawk, fisher (or other 

wild animal/livestock) to ingest Sporax® from treated stumps; 2) none of the hazard quotients exceed levels 

of concern for contaminated water (even at application rates 10 times those proposed); and 3) the 2006 risk 

assessment indicates boric acid is practically non-toxic to avian and mammalian species, direct effects to 

wildlife are not expected.
Elk Flat LSR Enhancement Project

170 Shasta-Trinity National Forest

While the current, primary source of NSO habitat loss is high-severity uncharacteristic wildfire (USDI-FWS 

2011, Davis et al. 2015), competition from barred owls is a significant, if not the primary current cause, of 

NSO population decline (Dugger et al. 2015). Due to similar dietary and habitat preferences, the barred owl is 

competitor and known predator (USDI-FWS 2011).76 While details on habitat interactions are not well 

understood, barred owls have a broader diet, may reduce NSO detectability and may occupy former NSO 

activity centers (Irwin et al. 2010, USDI-FWS 2011; Wiens 2012). Their range completely overlaps with the 

NSOs range (Gutiérrez et al. 1995) and they can negatively affect NSO site occupancy, reproduction and 

survival (Livesey et al. 2007). Similar effects may occur on any NSO from barred owls utilizing the action 

area, regardless of project implementation.

NSO populations continue to decline in all parts of their range, even with maintenance and restoration of 

suitable habitat (USDI-FWS 2011, Dugger et al. 2015).77 The recent December 2015 meta-analysis, based on 

the 11 demographic study areas established (or used) for NSO monitoring under the NWFP, indicates a range 

wide average 3.8% annual decline rate of the population. The analysis concludes that the results from 1985 

through 2013 indicate competition with barred owls may be the primary cause of NSO population decline 

across their range. It also concludes that nesting and roosting habitat loss, and climatic patterns, were related 

to survival, occupancy, recruitment, and fecundity. The author’s findings provide support for previous 

recommendations to preserve as much high-quality habitat in late-successional forest as possible across the 

range of the subspecies (Forsman et al. 2011, Dugger et al. 2011). The analysis also cautions that “barred owl 

densities may now be high enough across the NSOs range that, despite continued management and 

conservation of suitable NSO habitat on federal lands (Davis et al. 2011, 2015), the long-term prognosis for 

NSO persistence may be in question without additional management intervention.” Finally, it notes that 

barred owl removal may be able to slow or reverse population declines on at least a localized scale, as was 

observed in the GDR study area (Dugger et al. 2015). The recovery objectives listed in the Recovery Plan for 

dry forests include maintaining sufficient NSO habitat in the short-term to allow NSOs to persist in the face of 

threats from barred owl expansion and habitat loss from wildfires. Appendix B of the Recovery Plan contains 

numerous references regarding known barred owl competitive interactions with NSOs, and is hereby 

incorporated by reference.

At this time, direct effects to NSO from competitive interactions with barred owls are not expected to occur as 

a result of the project. Contributing to this determination is the fact that the ST-215 activity center has been 

unoccupied by NSO since 1990, however with the removal of the barred owl pair in fall 2014, a potential 

exists for the AC to be used by dispersing or territorial NSOs in the future. Barred owls have been observed 

on the SMMU since 1997 and in the project area, an adult male was detected once in 2004. A barred owl pair 

then occupied portions of the project area from 2010-2014, and was removed in fall 2014. This does not mean 

barred owls are not within, or could not re-occupy, the action area or project area. Survey results from the 

action area on NFS lands and private lands have not detected any other barred owl(s) to date (USDA-FS 

1989-2015 NSO survey records).

It is recognized that when barred owls and NSOs do co-occur, a reduction in habitat availability and quality 

may exacerbate interactions between the two species. Dugger and others (2011) suggest that in environments 

where the two species compete directly for resources, maintaining larger amounts of older forest 

 76 Confirmed predation of spotted owls by barred owls is known from one direct observation and predation is not 

considered a significant issue. Note that competition is considered a significant threat per the Revised Recovery Plan for 

the Northern Spotted Owl.

77 One exception was the treatment area within the GDR, where NSO populations started increasing after barred owl 

removals were initiated in 2009.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 171

(nesting/roosting habitat) may help NSOs to persist in the short term. This recommendation was supported 

again in the 2015 meta-analysis described above.

The project is designed in accordance with recommendations from the Recovery Plan for Recovery Action 10 

and 32, through consultation with the FWS (USDI-FWS 2011, Dugger et al. 2011). There are no mechanical 

treatments proposed in nesting/roosting habitat, or high quality foraging habitats in the project area and 

reintroducing low-intensity prescribed fire in these areas is not expected to degrade, downgrade or remove 

habitat function, but benefit it over time and would not exacerbate any competitive interactions between NSO

and barred owl. As described above and in the Chapter 2 RPMs, NSO surveys, spot checks and stand searches 

will be conducted in accordance with the 2012 protocol, or modification of the protocol, as agreed to by the 

US-FWS/STNF Level 1 team. These survey efforts will continue prior to and during implementation in and 

adjacent to the ST-215 core and home range, and habitats likely to contain NSO. The pre, during and postimplementation surveys will be used to evaluate for any NSO individual or pair occupancy or barred owl

presence. While the Recovery Plan concedes there are still substantial information gaps regarding ecological 

interactions between NSOs and barred owls (p. III-62), the effects of forest management their interactions is 

not fully understood at this time (Courtney et al. 2004). Ongoing and future monitoring may provide further 

understanding and no further conclusions are made in regards to barred owl effects on NSOs for the project.

Effects relative to Purpose and Need for Action

Effects of the proposed treatments are detailed in the BA and wildlife BE in the online project record. Effects 

as they relate to the purpose and need for action are summarized below.

As described in the Silviculture and Forest Health section of Chapter 3, and indicator comparison tables in 

Chapter 2 (Table 29), Alternative 1 best meets the purpose and need for action for reducing the continued risk 

of losing early, mid and late-successional habitat, increasing stand resilience, and accelerating development of 

late-successional habitat in the Elk Flat LSR. For the wildlife indicators, meeting the need is measured by the 

amount of capable, foraging, nesting/roosting, resting/denning habitat benefitted, maintained in its current 

condition, degraded, downgraded or removed. Predicted effects to habitat are based on a comparison of pretreatment stand and habitat conditions, the modeled immediate and 20-year post treatment stand conditions, 

and the project design and marking guides that maintain important habitat elements. Conclusions regarding 

post-treatment habitat function are supported by published descriptions of forest structure associated with 

NSO, northern goshawk and fisher habitat in dry forest types and local monitoring data.

Terms used to categorize the degree of predicted change in habitat function and quantify of affected habitat 

include:

• Maintain/Beneficial: Indicates changes in habitat may be neutral or beneficial to habitat function even 

though habitat elements may be modified.

• Degrade: Signifies when treatments have a negative influence on habitat quality due to removal or 

reduction of habitat elements but not to the degree where the existing or pre-treatment habitat 

function is changed.

• Downgrade: Signifies when treatments reduce habitat elements to the degree that habitat will not 

function in the capacity that existed pre-treatment, but activities will not remove habitat entirely (i.e., 

downgrade from nesting/roosting to foraging, or foraging to dispersal).

• Remove: Pertains to treatments that reduce habitat elements to the degree that habitat will no longer 

function as suitable for a species.

Given the range of habitat variability in and between the natural stands described in Chapter 1 and the wildlife 

Affected Environment section, the pre-and post-treatment FVS-FFE stand modeling and measurements in 
Elk Flat LSR Enhancement Project

172 Shasta-Trinity National Forest

suitable habitat may indicate higher or lower values of basal area or canopy closure, but these projections are 

based on averages. While helpful at providing data on general stand conditions, the model represents averages 

and trends and does not account for the high degree of expected post-treatment variability in suitable habitat, 

including tightly grouped clumps of large and small trees, the unthinned patches and high quality habitats 

excluded from thinning and existing large snags. Treatments will be variable at the fine stand scale and 

landscape scale. They will not remove important structural components such as predominant legacy trees, 

dominant trees with old-growth characteristics such as large boles, decadent branching, cavities and flattened 

tops, large snags or large down wood, unless necessary for operational safety.

Table 29 in Chapter 2 summarizes the predicted effects by action alternative to each species’ habitat type. 

Rationale for the treatment effects to suitable habitat is summarized below. Connected actions of hazard 

reduction will not occur in suitable habitats for these three species, so are not discussed here. They are 

discussed in the respective resource reports for wildlife in the online project record.

Effects to High Quality Habitat

NSO nesting/roosting, high quality foraging and fisher resting/denning habitats will be benefitted through the 

reintroduction of low-intensity prescribed fire. Surface and small ladder fuels would be reduced in these 

stands, but overall density or habitat quality and function would not be appreciably reduced. Low-intensity 

prescribed fire is predicted to reintroduce a lacking disturbance element and would be carefully applied and 

monitored. Table 27 in Chapter 2 fully describes the limits of acceptable mortality for tree size classes 4” 

diameter and larger, shrubs and understory. RPMs 24, 25, 38, 42 describe limiting the amount of burning in the 

ST-215 core/home range and the measures taken to reduce injury or mortality to predominant trees and other 

habitat elements (snags, large down wood). Low- intensity prescribed fire in nesting/roosting, resting/denning 

and high quality foraging habitats is expected to result in beneficial effects of increased understory vegetation 

diversity and structure and increases in prey base while reducing surface fuel loading (Anthony, 1997). The 

burning effects would be monitored closely to see if changes in burning prescriptions or seasonal timing are 

needed.

Effects to Foraging Habitat

Foraging habitat would be degraded or downgraded, though will not significantly impact how NSOs, 

goshawk or fisher utilize the landscape for foraging. Foraging habitat for NSO and northern goshawk will 

either be degraded by variable density thinning, or downgraded through variable density thinning combined 

with radial release of black oak and predominant legacy pine. Foraging habitat for fisher would only be 

degraded, as the treatments that downgrade NSO and goshawk habitat result in a reduction in some habitat 

elements for fisher but do not change the stand quality such that fisher could not forage in them posttreatment. This is due to the fisher’s wider range of foraging habitat characteristics (USDI-FWS 2014).

The Recovery Plan for NSO discusses silvicultural practices that promote forest resilience that can be applied 

to various forest types. Short-term decisions to increase a forest ecosystem’s ability to adapt to climate-driven 

drought stresses may include vegetation management around older individual trees to reduce competition for 

moisture. Longer-term strategies may include promoting heterogeneity among and within forest stands. In 

many areas, fire could be encouraged to perform its ecological role of introducing and maintaining landscape 

diversity, though it may be desirable to manage fire severity or return intervals through vegetation 

management at various temporal and landscape scales (pp. III-21). As variable-density thinning is a 

silvicultural technique intended to promote biological diversity and structural heterogeneity characteristic of 

old-growth forests, it induces fine-scale variation in homogeneous second-growth forest canopies (Carey, et 

al., 1995; Muir, et al., 2002). It consists of thinning a forest stand at different intensities in patches at a scale 

of approximately 0.1 to 0.5 ha to mimic the scale of patchiness found in old growth and late-successional 

forests and create a mosaic of overstory and midstory tree densities (Carey, et al., 1999).

In the dry forest landscapes that support NSO habitat, increasing resiliency of a stand or landscape also 

includes reducing conditions that contribute to stand vulnerability. This includes reducing stand density and 
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Shasta-McCloud Management Unit 173

surface and ladder fuels, especially in areas likely to experience fire. Many recent studies in mixed conifer 

forests have found the effectiveness of thinning or fuels treatments designed to modify or change fire 

behavior or suppression efforts is highest when tree thinning is combined with prescribed fire (Agee and 

Skinner 2005, Lehmkuhl et al. 2007, 2015, Prichard et al. 2010). Some of these authors acknowledge the 

potential for direct and indirect effects on resources while recognizing difficulty in balancing what may be 

opposing management objectives. Others debate methodologies that evaluate the actual risk to forests in the 

dry forest regions from high intensity, uncharacteristic wildfires (Spies et al. 2009, Odion et al. 2014).

Efforts that enhance forest resilience to wildfire at the stand level often focus on a set of management 

objectives for fuels, including reducing woody surface fuels, ladder fuels, and crown densities, and retaining 

large trees of fire resistant species. Reducing woody surface fuels helps reduce the potential for surface fire 

intensity (heat release), flame lengths and fire severity (Lehmkuhl et al. 2015). Reducing ladder fuels can also 

disrupt vertical continuity of fuels and reduce the probability of surface fire transitioning to crown fire. 

Retaining large trees of fire-resistant species in seeks to maintain stand structural and compositional stability 

by keeping existing trees that are most likely to persist through future fires and retaining seed sources that 

facilitate regeneration of fire-resistant species.

The variable density thinning, combined with follow-up prescribed fire and other surface fuel treatments meet 

the recommendations in the Recovery Plan for restoring dry forest ecosystems. These treatments would 

degrade foraging habitat function on 697 acres for NSO, 893 acres for northern goshawk and 990 acres for 

fisher. These treatments represent approximately 62 percent of the available foraging habitat for these species 

in the project area.

Where foraging habitat is degraded, it will continue to provide foraging opportunities post-treatment. This 

determination is based on the post-treatment condition of basal areas ranging from 125-200+ sqft/acre (when 

combined with the roost and rest clump retention and unthinned patches), 40-60 percent or more canopy 

cover, a patchy mosaic of burned and unburned areas, including unburned piles where fuels are piled, and mid 

and understory layering. The group selection and small gap creation in white fir (2 to <0.25-acre openings in 

homogenous white fir) would result in increased vertical and horizontal heterogeneity from a younger age 

class and species diversity. These conditions are well within the range of foraging habitat conditions 

frequently used by NSO (Irwin et al. 2007, 2012). Additionally, the retained species diversity, residual large 

trees, snags and down wood would contribute to habitat functioning as foraging post-treatment.

The unthinned patches and larger stand areas set aside for no treatment would continue to provide functional 

and structural elements including thermal and visual cover, dense small trees, pockets of suppression and 

mortality, and undisturbed debris. Higher stand densities would be retained where patches or groups of 

notably large trees occur in order to retain existing desirable late successional characteristics, and provide 

roosting or resting sites. While the unthinned patches and high basal area retention areas would remain at risk 

from density-related and insect and disease mortality, these areas would be smaller and less contiguous than 

the current conditions.

The temporary change in the quality but not function of foraging habitat would last for approximately 5 to 20 

years, depending on treatment location and type. Degraded foraging habitat would continue to function at pretreatment habitat levels as primary habitat elements of at least 40 percent canopy cover, abundant down logs 

and large snags, multi-layering, vertical and horizontal structure are maintained in the post-treatment 

condition. Other important habitat elements such as roosting structure, thermal refugia, shrubs and openings 

for dusky-footed wood rat and other prey base would also be retained in the post-treatment condition. The 

variable density thinning treatments are designed to maintain important habitat elements and benefit foraging 

structure, composition, and variability over the short- and long-term. Degraded habitat generally returns to 

pre-treatment quality levels over a 20-year timeframe as the remaining trees grow larger and canopy levels 

reach and exceed 60+ percent, and the mid- and understory continues to develop. These time estimates bar 
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any events such as another epidemic insect or disease outbreak, or uncharacteristic stand replacing fire that 

can reset the seral stage in a stand, or part of a stand.

27 acres of black oak release and 71 acres of radial thinning to protect and enhance predominant legacy pine 

in NSO and goshawk foraging habitat will downgrade habitat to dispersal function as canopy closure and 

cover would be below the 40 percent and the average basal area would range from 60-120 sqft/acre, on 

average. The effects of this treatment are expected to last for 10 to 30 years as follow-up underburning will 

incrementally reduce remaining under- and mid-story trees, and some down wood and snags, over the 30-year 

time period for the three prescribed fire entries. While there will be patches of dense roosting/resting sites, 

oaks that are not released, large and small trees, and snags and down wood in the post-treatment condition, 

these conditions do not provide enough residual habitat to consider the 27-acre area as ‘foraging’ habitat for 

NSO or NGO post-treatment.

The radial thinning around legacy predominant pine would downgrade foraging habitat function on 71 acres 

to dispersal (based on the prescription of releasing up to two legacy trees per acre, as available). As this 

treatment generally removes all smaller diameter trees within a 50-foot radius of the bole, except for other 

predominant legacy trees of any species or large diameter snags, numerous 0.25-0.30 acre size gaps will be 

spread across the treatment area where little to no understory or midstory vegetation remains. The effects of 

this treatment are expected to last for 20 to 30 years and while the radial release treatment will also provide 

residual foraging opportunities, the habitat condition in these patches will be considered dispersal in 

combination with the other thinning and underburning treatments.

These combined treatments represent 7 to 9 percent of the foraging habitat available in the project area for 

NSO and NGO respectively, and are not expected to result in a significant negative effect to individuals or 

overall habitat function. This determination is based on the: 1) small scale of habitat affected, 2) position of 

the treatment within the outer portion of the ST-215 home range and being outside the ST-205 territory, and 3)

the long-term benefit of increased stand and prey species diversity. However, it is considered a short- and 

long-term adverse effect to critical habitat elements of foraging (PCE3-discussed further below).

There will be no removal of suitable habitat function for NSO, northern goshawk or fisher.

Effects to Capable Habitat

The current dense and uniform stand conditions in older ponderosa pine plantations limit use by most wildlife 

species and the stand variability created by thinning would facilitate access for foraging (fisher, goshawk). 

Group selections would introduce a more diverse species and age class, particularly along plantation edges 

adjacent to higher quality habitat. Long-term benefits would be realized through the increased species and 

structural complexity, improved resilience to mixed severity fire, and eventual long-term development of 

multi-aged, multi-species stands. The other treatments that improve capable habitat, such as young plantation 

thinning and low-intensity fire, combined with older plantation treatments would occur on 329 acres for NSO, 

and 608 acres for northern goshawk and fisher.

Prescribed Underburning

Three prescribed fire entries are proposed over an approximate 30-year timeframe following completion of 

mechanical thinning activities. This treatment is intended to reintroduce a more frequent, natural fire regime 

and to consume natural and activity-generated fuels or reduce small-diameter surface and ladder fuels.

Underburns are intended to mimic low-intensity wildfires, and burn prescriptions will be written and applied 

to minimize consumption of soil cover including duff, litter and coarse woody debris in accordance with 

RPMs and Tables 21 and 22. Prescribed fire typically burns in a patchy mosaic, coincident with the 

distribution of the fuelbed, leaving burned and unburned areas. Small diameter-understory trees are typically 

killed and occasional flare-ups can occur and kill overstory trees.
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Shasta-McCloud Management Unit 175

Conclusions as they relate to the Purpose and Need

Based on the predicted effects of thinning and the stand modeling for tree size classes immediately postthinning and 20 years-post (see the Silviculture and Forest Health section), the treatments under Alternative 1 

facilitate the most acreage toward increased resilience and larger tree size classes, with a corresponding 

reduced risk of habitat loss and increased connectivity for late-successional associated species. In summary, 

1,743 acres of habitat for NSO would be improved over the 20-year modeling period, representing 57 percent 

of the LSR; 1921 acres of northern goshawk habitat would be improved, representing 62 percent of the LSR; 

and 2018 acres would be improved for fisher, representing 66% of the LSR. Fire behavior modeling indicates 

that indirect effects of combined thinning and subsequent fuels treatment would reduce the potential for 

passive crown fire and promote surface fire (see the Fires and Fuels section).

In relation to the northern spotted owl, the project is consistent with six of the eight Recovery Plan’s dry 

forest restoration principles:

• Conserving older stands that contain conditions to support NSO occupancy or high-value NSO 

habitat as described in Recovery Actions 10 and 32 (USFWS 2011 pp. III–43, III–67). On Federal 

lands this recommendation applies to all land-use allocations;

• Emphasizing vegetation management treatments outside NSO territories or highly suitable habitat;

• Designing and implementing restoration treatments at the landscape level;

• Retaining and restoring key structural components, including large and old trees, large snags, and 

downed logs;

• Retaining and restoring heterogeneity within and among stands (USFWS 2011 pp. III-34 to III-35).

Treatments that meet the above principles are expected to result in a variety of effects on NSO habitat in the 

short and long term. The proposed use of low-intensity fire in high quality habitat is expected to have an 

immediate beneficial effect. No mechanical treatments would occur in high value or highly suitable habitat. 

The proposed actions will not reduce nesting, roosting or foraging habitat in a home range with a reproductive 

pair. Treatment types and locations have been prioritized within the unoccupied ST-215 core and home range, 

based on existing habitat levels, occupancy (or lack thereof), the current habitat levels that are <40% in the 

home range (currently at 37%) recommended values and the ability to effect meaningful structural change in a 

<30 year timeframe.

The current ST-215 core and home range likely functions, or would function better over the short-and longterm, for a dispersing subadult or juvenile NSO. However, over the long-term, the current ‘configuration’ of 

habitat types and overall suitability in the home range and core is not expected to support a reproductive pair, 

primarily due to 60% of the home range being within private industrial timberland production and 32% of the 

core in plantations. As NSO home ranges are typically analyzed at the circular scale, this analysis may be 

misleading in some cases. Over time, the project area could function to support a reproductive NSO pair as 

more dispersal and capable habitat transitions to suitable habitat. It is still likely that over the short and long 

term (20-30 years) that this area will primarily function as a temporary location for dispersing individuals 

moving from their natal sits to occupy other territories.

Project-wide, the variable density thinning treatments will maintain a range of basal areas ranging from 125-

200+ sqft/acre (when combined with the roost and rest clump retention and unthinned patches), 40-60 percent 

or more canopy cover, a patchy mosaic of burned and unburned areas, including unburned piles where fuels 

are piled, and mid and understory layering. The group selection and small gap creation in white fir (2-acre to 

<0.25-acre openings in homogenous white fir) would result in increased vertical and horizontal heterogeneity 

from a younger age class and species diversity. These conditions are well within the range of foraging habitat 
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176 Shasta-Trinity National Forest

conditions frequently used by NSO (Irwin et al. 2007, 2012). Additionally, the retained species diversity, 

residual large trees, snags and down wood would contribute to habitat functioning as foraging post-treatment 

– providing prey base habitat and thermoregulation sites.

The treatments are considered consistent with the ecological forestry principles discussed in the Recovery 

Plan and 2012 Final Critical Habitat Rule where long-term NSO recovery will benefit, even if short-term 

impacts may occur (Franklin et al. 2006). The treatments are proposed to improve the resiliency of the 

landscape in light of the threats to NSO habitat from the existing risk conditions in the project area that have 

been exacerbated by prolonged drought. The treatments are intended to promote spatial heterogeneity within 

patches, restore underrepresented species (oak, aspen, Douglas fir) and structural diversity. While some of 

these management actions may degrade habitat in in the short-term, they are considered beneficial in the longterm as they would reduce future losses of ecosystem structure or result in a higher resilience to future 

disturbance events (USDI-FWS 2011 p. III-14).

Effects relative to key issues

The effects of the variable density thinning and other restoration treatments designed to reduce the risk of 

losing, and accelerate development of, late successional habitat summarized above relative to the purpose and 

need are addressed here, in terms of their expected influence on designated critical habitat for the NSO. There 

are 720 acres of critical habitat in the Elk Flat LSR and project area within Unit 8, Subunit 3 (East Cascades 

South [ECS-3]). All critical habitat in the project area is within the ST-215 home range.

Special management considerations or protection are required in this subunit to address threats to the essential 

physical or biological features from current and past timber harvest, losses due to wildfire and the effects on 

vegetation from fire exclusion, and competition with barred owls. The function of this subunit is to provide 

demographic support in this area of sparsely distributed high-quality habitat and Federal land, and to provide 

for population connectivity between subunits to the north and south. The FWS determined that all of the 

unoccupied (and likely occupied) areas in this subunit are essential for the conservation of the species to meet 

the recovery criterion in the Recovery Plan that calls for continued maintenance and recruitment of NSO

habitat (USDI-FWS, 2011 p. ix). The increase and enhancement of NSO habitat in this subunit is especially 

important for providing essential connectivity between currently occupied areas to support successful 

dispersal of NSOs, and may also help to buffer northern spotted owls from competition with the barred owl 

(USDI-FWS, 2012 p. 71931).

The Final Rule describes that in the drier, more fire-prone regions of the NSOs range, habitat conditions will 

likely be more dynamic and active management may be required to reduce the risk to the essential physical or 

biological features from fire, insects, disease, and climate change, as well as to promote regeneration 

following disturbance. While the FWS recommends conservation of high quality and occupied NSO habitat, it 

asserts that long-term recovery could benefit from forest management where the basic goals are to restore or 

maintain ecological processes and resilience (p. 71908). Management actions should be considered to balance 

short-term adverse effects with long-term beneficial effects.

Suggestions regarding active forest management within critical habitat include:

1. Focusing active management in younger forest and lower quality owl habitat, or where ecological 

conditions are most departed from the natural or desired range of variability;

2. In dry forests, following the NWFP guidelines and focusing on lands in or outside reserves most ‘‘atrisk’’ of experiencing uncharacteristic disturbance, and where the landscape management goal is to 

restore more natural or resilient forest ecosystems;

3. Avoiding or minimize activities in active NSO territories (or high-quality habitat in these territories);
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Shasta-McCloud Management Unit 177

4. Ensuring transparency of process, so the public can see what is being done, where it is done, what the 

goal of the action is, and how well the action leads to the desired goal; and 

5. Practicing active adaptive forest management by incorporating new information and learning into 

future actions to make them more effective, focusing on how these actions affect NSOs and their prey 

(pp. 71882-71883).

To ensure the treatments proposed in critical habitat are consistent with recommendations for management 

described in the Final Rule, several field reviews were conducted with the FWS and Forest Service personnel 

to the majority of natural stands designated as critical habitat, and some of the older plantation units in critical 

habitat (see Appendix E that describes the consultation to date). The specific treatments in unit 153 (oak 

release, radial thinning of pine, small gap creation), and other units proposed for thinning and prescribed fire 

were reviewed by both agencies and deemed consistent with management objectives within the East Cascades 

Province (p. 71907).

Effects to Critical Habitat

For the NSO, the Primary Constituent Elements (PCEs) of Critical Habitat are the specific characteristics that 

make areas suitable for nesting, roosting, foraging and dispersal habitat. PCEs are defined as:

1. Forest types that may be in early-, mid- or late-seral stages and that support the northern spotted owl 

across its geographical range (PCE 1);*

2. Nesting/roosting habitat (PCE 2);

3. Foraging habitat (PCE 3); and

4. Dispersal habitat (PCE 4).

*PCE 1 must occur with PCE 2, 3 or 4.

Under Alternative 1, approximately 624 acres of designated critical habitat would be treated (87% of the total 

in the project area). There would be short- and long-term adverse effects to elements of PCE3 from variable 

density thinning, radial thinning around predominant legacy pine and black oak release. While these adverse 

effects would occur, this alternative meets the Final Rule’s recommendations for active forest management on 

the most acres in the project. The ST-215 core/home range is not considered active, and as described in the 

Conclusions section above, treatment locations in the core and home range were prioritized in accordance 

with recommendations for Recovery Action 10. In addition, the project does not mechanically treat any high 

quality NSO habitat, in accordance with recommendations for Recovery Action 32 of the Recovery Plan.

At the project (and ST-215 home range) scale, 164 acres of capable habitat (PCE1) would be moved toward 

stand conditions that support dispersal (PCE4) over the short-term (~10 years) and foraging (PCE3) over the 

longer term (20-30 years). The thinning and group selection treatments in 40+ year old plantations would 

affect 23% of the designated critical habitat in the home range and 100% percent of the core.

All of PCE2 (nesting/roosting habitat;120 acres) would be benefitted and maintained through low-intensity 

prescribed fire, which would reduce surface and ladder fuel loading and contribute toward understory 

diversity, as summarized above. Prescribed fire in critical habitat may affect individual trees and could modify 

canopy cover through creation of gaps. However, due to the low-intensity burn objectives developed 

specifically with the FWS and the IDT fuels specialists (see Table 21 and Appendix E), this treatment is not 

expected to appreciably reduce the function of nesting/roosting, or high quality foraging, habitat at the stand 

or sub-unit level. This treatment represents 17% of the critical habitat in the project area (ST-215 home 
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178 Shasta-Trinity National Forest

range). About of 55 acres of PCE3 would also be benefitted and maintained through low-intensity prescribed 

fire (the higher quality foraging habitat). This treatment represents 23% of the PCE3 in the core and 17% of 

the PCE3 in the home range.

In PCE3 (foraging), 46 acres would be downgraded to PCE4 (dispersal) for an estimated 10-30 years. This 

treatment would not occur in the core, but in the outer portion of the home range, distant from 

nesting/roosting and higher quality habitat areas (southwestern portion of unit 153). This short-and long-term 

reduction in PCE3 habitat quality and stand elements would occur on 14% of the PCE3 in the home range, 

and 6% of the overall critical habitat in the project area. Short- and long-term adverse effects to PCE3 

elements are expected from the oak release (27 acres) and radial thinning around predominant legacy pine (19 

acres) in this unit. There would be a short-term adverse effect to elements comprising PCE3 regardless of 

resource protection measures as the combined treatments of variable density thinning with radial thinning and 

oak release would remove large and small trees that comprise PCE3 over a 10 to 30 year timeframe. With the 

follow up prescribed fire in these areas, regeneration and snags/down logs may also be consumed.

Also in PCE3, about 224 acres in the home range would be degraded (114 acres in the core) through variable 

density thinning treatments and follow-up underburning. Refer to the discussion above in the Purpose and 

Need effects section that describes degraded foraging habitat. While individual habitat elements will be 

reduced or variously affected, the reduction is not at a scale that would significantly reduce their value in 

critical habitat or the overall ability of the foraging habitat PCE to function and foraging habitat functionality 

post-treatment will be retained. However, there will still be some short-term and minor adverse effects to 

elements of critical habitat PCE3 because treatments would result in reductions in canopy closure, basal area 

and habitat layering (vertical and horizontal structure); impacts to snags and coarse wood, shrubs and forest 

floor vegetation from fuels treatments in 68% percent of PCE3 in the project area.

Effects to PCE4 (dispersal) include improvement of one acre in older plantation thinning treatment, and 

modification on 14 acres of natural stand within the home range, outside the core. The modification would 

primarily occur from thinning a ponderosa pine-white fir dominated stand where the thinning treatment would 

reduce the average basal area to 100-125 sqft/ac to attempt maintaining and promoting the residual pine in 

this stand. Given the variable stand conditions in the stand (unit 169) and reductions in current canopy cover, 

which have been and continue to be decreased by mortality in the pine, it is not certain if the stand would 

continue to wholly function as dispersal habitat post-treatment. Given current stand conditions, the average 

canopy cover post-treatment is expected to range from 30-50%. This treatment would affect 93% of the PCE4 

in the home range and 2% of the overall critical habitat in the project area.

Based on the growth modeling, the amount of PCE2/PCE3 (suitable) projected in the project area critical 

habitat, over a 20-year period, is 456 acres. This is an increase over the current levels of suitable by only 6 

acres and represents 63% of the total critical habitat being in “suitable” condition. This is due in part to 

habitat elements being maintained and benefitted through low-intensity prescribed fire; variable thinning

treatments that maintain habitat function and increase individual tree vigor, growth and stand resilience over 

time; and an estimated recovery of the 27 acres of downgraded habitat in oak release toward improved 

suitable foraging/PCE3 conditions. While there would not be a significant change in the amount of suitable 

habitat over the 20-year timeframe, trees would be larger and more resilient and there would be an increase in 

vertical and horizontal heterogeneity in the stands (refer to the Silviculture and Forest Health section for a 

discussion of accelerated diameter growth 20 years after treatment).

There would be an increase of approximately 173 acres of PCE4 (dispersal) in the project area over this same 

time span from the older plantation thinning treatments, residual dispersal habitat in areas where pine was 

radially thinned, and from capable stands that were burned transitioning toward stands that support dispersing 

NSOs. This is an increase over the current levels of dispersal habitat in the home range by 158 acres, and 

represents 24% of the total critical habitat being in conditions that support NSO dispersal. These treatments in 

PCE4 are also not expected to significantly or appreciably reduce the function of dispersal habitat or habitat 
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Shasta-McCloud Management Unit 179

connectivity at the NSO action area, project area or ST-215 home range/core scales, or significantly affect the 

ability of NSO to disperse across the landscape. Conversely, they are an improvement over the long term from 

the existing condition.

As described in the 2012 Final Critical Habitat Rule, some management activities may have short-term 

adverse effects and long-term beneficial effects on physical or biological features of critical habitat. The 

Revised Recovery Plan recommends land managers actively manage portions of both moist and dry forests to 

improve stand conditions and forest resiliency, which should benefit the long-term recovery of the northern 

spotted owl (p. III–11). While a variable thinning treatment in a in single-story, uniform forest stand is 

intended to promote development of multistory structure, it may also result in short-term adverse impacts to 

the habitat’s current capability to support owl dispersal and foraging, but have long-term beneficial effects of 

creating higher quality habitat that could better support territorial pairs. These types of activities would have 

less impact in areas where foraging and dispersal habitat is not limiting, and ideally could be conducted in a 

manner that minimizes the short-term negative impacts.

Some structural components of critical habitat PCE3 will be reduced, but when assessed at the stand scale,

effects are not expected to change the actual function of NSO habitat, with the exception of the oak release and 

radial thinning of pine. The stands providing foraging habitat will continue to provide foraging opportunities 

for NSOs should they occupy or disperse through the home range. The treatments will also facilitate a higher 

likelihood of use by NSO through increases in stand heterogeneity, larger trees over time and the reduction in 

density of small trees.

Over the 20-30 year timeframe, thinning and fuel reduction treatments are expected to enhance the function

of the project area critical habitat by improving long-term quality of roosting, foraging and dispersal

habitat. Fire effects modeling indicates that thinning and subsequent fuels treatment will generally reduce

the potential for crown fire or maintain a surface fire and significantly reduce predicted stand mortality in 

the event of a fire start. While thinned stands will be less dense, average tree diameters would increase and

the basal area ranges and other habitat conditions (canopy closure, down logs, understory, large snags) 

would be retained well within the range of use by foraging NSOs (Irwin et al. 2007, 2012, 2015).

The project will not remove PCEs of critical habitat or result in a measurable change in the ECS-3 

subunit’s ability to provide the functions for which it was designated. PCE 1 would be transitioned toward 

PCE4 and PCE3 by thinning and group selection treatments; PCE 2 would be benefitted through lowintensity prescribed fire; and effects to PCE 3 and PCE 4 are described above. The Alternative 1treatments 

will affect less than one percent of the East Cascades South (ECS-3) Critical Habitat Subunit and the 

project actions do not significantly reduce the value of these primary constituent elements of critical 

habitat. While there will some short-term minor adverse effects on 224 acres of PCE3, and a longer-term 

adverse effect on 46 acres of PCE3, the proposed treatments result in a greater assurance of long-term 

maintenance of suitable and dispersal habitat. They contribute positively to the overall function of the 

ECS-3 subunit, which is to provide demographic support in an area of sparsely distributed high-quality 

habitat and Federal land, and provide for population connectivity between subunits to the north and south.

Other resource effects

There are no other resource effects.

Compliance with Law, Regulation and Policy

The Elk Flat LSR Enhancement Project is in compliance with the Forest Plan standards and guidelines and 

management direction from the Forest Plan and NWFP and is consistent with objectives, recommendations 

and activity design criteria from the LSRA. Because some standards and guidelines between these documents 

differ, in all cases the more restrictive standard and guideline and/or the one most beneficial to TE&S wildlife 
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180 Shasta-Trinity National Forest

species will be implemented. Chapter 2 includes the resource protection measures developed by the 

Interdisciplinary Team to reduce or eliminate impacts to listed, proposed, and sensitive species and their 

important breeding, feeding and sheltering habitats. The predicted effects for all action alternatives are based 

on the implementation of these RPMs.

The project is consistent with all other relevant laws, regulations, policies and plans as they relate to wildlife, 

including the Endangered Species Act of 1973 as amended, Forest Service Manual 2670.12 and 2672.42-

2672.43and the National Forest Management Act requirements to provide for a diversity of animal 

communities (16 USC 1604((g)(3)(B); also see 36 CFR 219.10(b).

Effects to Threatened, Endangered, Proposed and Forest Service sensitive species are analyzed in the wildlife 

BA and BE. Consultation is ongoing with the FWS with respect to effects to listed northern spotted owl and 

gray wolf. As described in the BA, the project is considered to be consistent with the Revised Recovery Plan 

for the Northern Spotted Owl (USDI-FWS 2011), including recovery actions 10 and 32 that are most 

applicable at the project planning and implementation scale. This meets the intent of Forest Plan standard and 

guideline 25.h to “maintain and/or enhance habitat for TE&S species consistent with individual species 

recovery plans” (Forest Plan p. 4-30).

The variable treatments in each land allocation would maintain or enhance habitat for threatened, endangered 

and sensitive species consistent with individual species recovery plans (p. 4-30); would manage habitat for 

sensitive plants and animals in a manner that prevents the species from becoming a candidate for threatened 

and endangered status (p. 4-5); and would continue to provide connecting travel corridors for wildlife, 

particularly late-successional dependent species (p. 4-14).

The project is consistent with management direction in the Forest Plan to protect each known northern 

goshawk nest site during planning and implementation and using limited operating periods adjacent to active 

nest sites until young have fledged (Forest Plan pp. 3-27, 4-30 and 4-44). The project is consistent with the 

goals and direction in the Forest Plan for fisher (Forest Plan p. 3-27). This direction is primarily fulfilled 

through the Forest’s LSR and Riparian Reserve management direction and systems. Riparian areas provide 

important habitat for fisher because of the close proximity of water and structural diversity of the vegetation. 

Wilderness, roadless areas and wild and scenic rivers also contribute to habitat availability and maintaining 

species’ viability.

Cumulative Effects – Alternative 1

A review of ongoing and reasonably foreseeable future activities on federal and private lands in the NSO

action area (and other wildlife cumulative effects analysis areas) was completed and is incorporated by 

reference (Jordan 2015b). There are no state-managed lands in the NSO action area. While there may be an 

overlap in two or more projects’ cumulative effects spatial or temporal bounds, where there are no direct or 

indirect effects that overlap in time and space on the resource considered (e.g., reproductive sites, suitable 

habitat), there are no cumulative effects.

Cumulative effects in the NSO, northern goshawk and fisher analysis areas are considered as the changes

to the existing condition caused by ongoing or reasonably foreseeable future activities when added to the

effects of the Elk LSR project actions. Currently, within the larger fisher analysis area that also addresses 

NSO and northern goshawk, there are no future foreseeable federal actions. There are at least three timber 

harvest plans in progress or submitted for approval on adjacent private lands. Other ongoing actions on 

NFS and private lands that can influence vegetation, create potential noise disturbance and influence

wildlife behavior and habitat include, but are not limited to: fuelwood collection, dispersed recreation, 

implementation of Motorized Travel Management, Oversnow Vehicle Use associated with the Pilgrim 

Creek snowmobile park, and routine road and recreational site maintenance (including hazard tree felling). 

In addition, fire suppression activities, grazing on the Bartle Allotment and noxious weed monitoring are 
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Shasta-McCloud Management Unit 181

also ongoing. Project work authorized under previously completed NEPA includes the Pilgrim Vegetation 

Management project, road closures approved under previously completed NEPA, and Timber Stand 

Improvement work. Remaining activities under the Pilgrim project are limited to manual or mechanical 

release of reforested areas and small diameter (<14”) ponderosa pine tree thinning and these areas do not 

support suitable or dispersal habitat for the NSO, fisher or northern goshawk. Similarly, other TSI work 

does not include habitat for these species. Road closures do not typically affect habitat, but can result in 

beneficial effects to individuals from reduced human access and disturbance. Grazing is not predicted to 

negatively or significantly affect NSO, fisher or northern goshawk habitat if surface vegetation that 

mammalian or avian prey may use is not excessively removed. The other activities on NFS lands do not 

measurably or meaningfully influence wildlife breeding, feeding or sheltering behaviors and are not 

predicted to result in any detectable or meaningfully measurable effects to individuals. Therefore, 

cumulative effects from those activities are considered insignificant in combination with the project’s 

effects.

Activities on private land include commercial thinning, salvage, clearcutting and other forest stand 

treatments. Timber harvest plans (THPs) are subject to the California Forest Practice Rules (Sections 919.9 

and 939.9) which create a process, that when implemented correctly by the State, avoids unauthorized 

‘take’ of NSOs unless authorized by a federal Habitat Conservation Plan. The THP planning and review 

process incorporates survey results into THPs, comparing results with the State’s CNDDB NSO database 

and ensuring adequate amounts of habitat are retained around NSO activity centers. While the FWS does 

not review individual THPs in many cases, it has provided Technical Assistance when requested by 

CALFIRE or the California Department of Fish and Wildlife.78 Extensive hauling on roads and routes 

through the project area and in the analysis areas (to complete THPs) occurs near or through suitable 

habitat for NSO, northern goshawk and fisher. This is considered part of the ambient environment. 

Individuals (goshawk, fisher) occupying the project area, or larger analysis areas, are likely habituated to 

this noise and the disturbance associated with roads or harvest activities and may completely avoid these 

sources of disturbance. The project will cumulatively contributed to ongoing and predicted future road use, 

noise and other habitat disturbance by private land management in ~22% of the NSO and northern 

goshawk analysis area, and ~35%of the fisher analysis area during implementation. As noted above, 

individuals occupying the project area, or larger analysis areas, are likely habituated to haul noise in 

general and the disturbance associated with roads or harvest activities and may completely avoid these 

sources of disturbance. These impacts, should they occur, are not predicted to result in any significant 

cumulative effects to breeding individuals, provided the Project’s LOPs for noise-generating and habitat 

altering activities during the critical breeding period. The LOPs prescribed during the critical breeding 

period for the Elk LSR project would reduce, if not eliminate, the potential for direct, indirect or 

cumulative effects from project noise or habitat disturbance in combination with that from private 

activities (e.g. log haul on cost share roads).

None of the ongoing or submitted THPs are in designated critical habitat for the NSO, as critical habitat is 

not designated on private lands. Private lands in the analysis area currently contribute little toward 

maintaining the viability of the ST-215 NSO home range, or toward contiguous blocks of suitable goshawk 

or fisher habitat. The Elk LSR project will not remove or downgrade NSO habitat in the ST-215 core, or 

significantly downgrade suitable habitat in the home range. It will not degrade, downgrade or remove any 

 78 Private timber harvest plans are reviewed under section 9 of the ESA for the possibilities of prohibited take and private 

take of threatened NSO is prohibited under California State law and prosecutable under both Federal and State law. The 

California Forest Practice Rules also contain requirements for NSO habitat retention.
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182 Shasta-Trinity National Forest

suitable habitat from known northern goshawk territories, or fisher denning or resting habitat. Given that 

private lands in the analysis area contribute little to no habitat viability, the combined effects of the Elk 

LSR project and the ongoing and reasonably foreseeable intensive management of private lands will not 

result in effects that would be greater than the Elk LSR project alone. While future management actions on 

private lands may occur during the 20 to 30 year timeframe established for the Elk project, reasonable 

effects cannot be evaluated in the absence of a proposed THP that provides spatial and treatment data to 

assess potential effects to habitat and NSO, goshawk or fisher. While it is reasonable to base potential 

future actions on private lands on past actions and effects, the cumulative effects analysis under the ESA

and the NEPA is completed based on the best available current information at the time of the analysis.

Modifications to suitable habitat from Alternative 1 are not expected to result in significant changes to 

stand structure or potential use by NSOs, northern goshawk or fisher. The effects to habitat from 

Alternative 1 represent about 34 percent of the suitable, and eight percent of the dispersal habitat in the 

NSO action area. Effects to suitable habitat will not occur in a currently occupied NSO core area, and 

nesting/roosting, and high quality foraging habitats will be benefitted through prescribed fire. The majority 

of the foraging habitat proposed for treatment is considered low to moderate value due to limited moisture, 

species composition, stagnated growth or dense understory and midstory conditions, or a lack of structural 

diversity. No suitable or dispersal habitat will be removed and the structural diversity of thinned stands is 

expected to be enhanced post-treatment. These effects, in combination with the ongoing actions on Federal 

lands are not expected to remove NSO, northern goshawk or fisher habitat and therefore will not result in 

significant cumulative adverse effects to NSO in the action area. The project effects are not expected to 

significantly affect breeding, feeding or sheltering behaviors, or create barriers to dispersal; they are 

expected to retain and enhance habitat quality through the reintroduction of natural ecological processes.

Alternative 2- No New Temporary Road Construction Other Than Those Required 

for Landing Access

Direct and Indirect Effects – Alternative 2

Direct effects to NSO, northern goshawk and fisher are the same as described for Alternative 1and the 

described surveys, LOPs and all other RPMs would still apply. Sporax® application would occur on 

approximately 82 fewer acres under this alternative when compared to Alternative 1, due to reduced 

mechanical thinning treatments.

Compared to Alternative 1, this alternative foregoes mechanical thinning in four natural stands and one older 

plantation due to not constructing temporary roads. 22 fewer acres of suitable foraging habitat for NSO and 

northern goshawk, 27 acres of foraging habitat for fisher, 6 acres of dispersal habitat for NSO, and 9 acres of 

capable habitat for the NSO, goshawk and fisher would not be mechanically thinned. These changes do not 

occur in critical habitat, or the ST-215 core or home range. While tree size classes would not increase as 

quickly and these small stands would remain at higher risk of loss, low-intensity prescribed fire would still be 

utilized on all acres and is expected to benefit these areas by reducing surface and ladder fuels.

Effects relative to Purpose and Need for Action

Compared to Alternative 1, the reduced acreage of increased tree resilience and size classes from reduced 

thinning in small segments of these four natural stands and one older plantation are considered negligible in 

terms of meeting late-successional habitat needs for the NSO, northern goshawk and fisher. These stands 

would receive the same benefits from low-intensity prescribed fire as described for Alternative 1.

Compared to Alternative 1, this alternative transitions a similar amount of the habitat in the LSR toward 

increased resilience and larger tree size classes. In NSO habitat, approximately 13 fewer acres would be 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 183

improved over 20 years from a combination of thinning and low-intensity fire; resulting in 56% of the LSR 

benefiting from this alternative for this species (compared to 57% under Alternative 1). In northern goshawk

habitat, approximately three fewer acres would be improved and for fisher, eight fewer acres would be 

improved. Alternative 2 results in the same amount of LSR benefit as Alternative 1 for the northern goshawk 

(62%) and for fisher, 65% of the LSR habitat would be improved (compared to 66% under Alternative 1). 

These differences are considered negligible to meeting the purpose and need.

Effects relative to key issues

The effects relative to key issues are the same as described for Alternative 1 as no temporary roads are 

proposed in critical habitat.

Other resource effects

There are no other resource effects.

Compliance with Law, Regulation and Policy

As described for Alternative 1.

Cumulative Effects – Alternative 2

As the differences in habitat benefit are so slight, the beneficial cumulative effects are considered the same as 

that described for Alternative 1, though slightly less beneficial for all species with only the return of lowintensity prescribed fire.

Alternative 3 - No Treatments of Natural Stands within Designated Critical Habitat 

for the Northern Spotted Owl

Direct and Indirect Effects – Alternative 3

Direct effects to NSO, northern goshawk and fisher are the same as described for Alternative 1and the 

described surveys, LOPs and all other RPMs would still apply. Sporax® application would occur on 

approximately 270 fewer acres of natural stands under this alternative when compared to Alternative 1, due to 

eliminating mechanical thinning treatments in natural stands of designated critical habitat.

Compared to Alternative 1, this alternative foregoes the reintroduction of prescribed fire on 390 acres of 

suitable NSO habitat (nesting/roosting and high quality foraging), maintaining these acres in their current 

condition. There would be no increase in habitat diversity or risk reduction benefits from the reintroduction of 

low-intensity prescribed fire in these stands. This also results in reduced beneficial effects to fisher and 

northern goshawk habitat, though stands would remain in the current condition, at risk from the ongoing 

trends though likely functional for nesting/roosting, resting/denning or foraging at least in the short-term.

Mechanical thinning in 270 acres of suitable NSO, goshawk and fisher foraging habitat would not occur. 

Black oak would not be released on the planned 27 acres, and the 19 acres of radial thinning of legacy pine 

would not occur. Foraging habitat would not be degraded or downgraded, but as with the higher quality 

habitats above, would remain in its current condition and at risk to loss from the current trends. Black oaks 

would continue to be overtopped in this portion of the project area, and over time, reduced and potentially lost 

as a stand component. There would be no direct or indirect benefits to fisher denning, resting, or prey base 

habitat over time, though fisher (and other species) would be expected to still use this stand for foraging.

Effects relative to Purpose and Need for Action

Compared to Alternative 1, this alternative transitions the least amount of acreage toward increased resilience 

and larger tree size classes in the LSR, with a corresponding increase in the potential for continued habitat 

loss and reduced connectivity. In NSO habitat, approximately 1,346 acres would be improved over 20 years 
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184 Shasta-Trinity National Forest

through thinning and low-intensity fire, resulting in benefits within 44% of the LSR for this species 

(compared to 57% under Alternative 1). In northern goshawk habitat, approximately 1,471 acres would be 

improved over 20 years through thinning and low-intensity fire, resulting in benefits within 48% of the LSR 

(compared to 62% under Alternative 1). In fisher habitat, approximately 1,568 acres would be improved over 

20 years through thinning and low-intensity fire, resulting in benefits within 51% of the LSR (compared to 

66% under Alternative 1).

Effects relative to key issues

Compared to Alternative 1, this alternative meets the active management recommendations described in the 

2012 Final Critical Habitat Rule on 472 fewer acres. Mechanical thinning treatments would not occur in 

natural stands of critical habitat, and prescribed fire would not be utilized anywhere in critical habitat. 224 

acres of natural stands designated as PCE3 will not be degraded. While the function of unthinned PCE3 

habitat will remain as foraging, it will also remain at risk to loss from overstocking and competition for light, 

water and nutrients and insect attacks with some stands remaining stagnant in the understory (e.g., dense 

white fir with little to no diversity in portions will remain until gaps from mortality are likely created. Both 

PCE2 and PCE3 would be maintained in its current condition, at risk of loss from the ongoing trends though 

likely functional for nesting/roosting, resting/denning or foraging at least in the short-term.

Oak release on 27 acres and radial thinning on 19 acres in PCE3 would not occur. Because habitat would not 

be downgraded on these 46 acres, short- and long-term adverse effects to PCE3 would not occur. Conversely, 

long-term benefits from increased foraging habitat diversity and prey base would also not occur. Lowintensity prescribed fire would not be initiated in critical habitat. Compared to Alternative 1, 12 fewer acres of 

PCE1 (capable habitat in younger plantations) would be benefited and transitioned toward dispersal 

conditions, due to eliminating the use of low-intensity prescribed fire in those stands.

Other resource effects

There are no other resource effects.

Compliance with Law, Regulation and Policy

As described for Alternative 1.

Cumulative Effects – Alternative 3

Cumulative effects of Alternative 3 are similar to those described for Alternative 1 with the exception of 

critical habitat treatments. There will be no effect to nesting/roosting habitat (PCE2) under this alternative or 

to 325 acres of foraging (PCE3) under this alternative. Cumulative effects to suitable NSO habitat represent 

about 22 percent of the suitable in the NSO action area.

Alternative 4 - No Action

Under No Action, the proposed management activities would not be implemented. No direct, indirect, or 

cumulative effects are expected. While actions would not be undertaken with this alternative, the ongoing 

trends described in Chapter 1 would continue.

While there would not be project effects, the existing trends of declining forest health and increased risk of 

habitat loss described in Chapter 1 will continue until such time that natural events reset the seral stage, 

similar to what is occurring at present, or other management is approved and implemented. Any change in 

conditions would occur as the natural progression of vegetation and fuels change over time (see the 

Silviculture and Forest Health and Fire and Fuels sections for more detail).

Under no action, stands would continue to exceed recommended stocking levels, resulting in a continued loss 

of diameter growth and reduced resistance to insects and disease in ponderosa and sugar pine. The ability of 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 185

trees to maintain vigor and survive during future drought conditions, especially drought sensitive species such 

as white fir, would decrease. Sugar and ponderosa pine would continue to decline within the mixed-conifer 

stands as they progress towards a higher density of shade tolerant species [white fir and cedar] in the absence 

of management activity.

Habitat conditions for NSO, northern goshawk and fisher are not expected to significantly change under 

Alternative 4 in the short term. The existing conditions in stands proposed for treatment are likely to sustain 

these species and their and prey over the short term. Increases in habitat suitability (i.e. development of larger 

trees, understory composition, heterogeneity and larger snags/logs) is expected to take longer than what is 

modeled under the action alternatives, and would result in fewer assurances of sustaining higher quality 

habitat for a longer time. While stand modeling is used to compare trends across Alternatives and through 

time, it is important to understand the modeling limitations when interpreting results. With continuation of the 

current mortality trends, future stands would be characterized by a dense layer of smaller shade tolerant trees 

with fewer large diameter trees and areas of high concentrations of fuels conducive to high intensity fire. The 

increased risk of further stand loss from large, heavy fuel accumulation, slow growth of large trees due to high 

stand densities, and continued loss of large overstory pine from insects and disease do not meet the purpose 

and need of reducing risk, promoting stand resilience, or accelerating development of late-successional habitat 

characteristics in the Elk Flat LSR.

Dense stands will continue to remain at risk to loss from stocking pressure, drought, disease, insects or 

wildfire effects. Changes in stand structure are expected to result largely from individual tree mortality 

associated with inter-tree competition, blowdown or bark beetle activity. The amount and type of mortality 

would vary by stand type and species, with increased mortality expected to continue in all size classes of 

ponderosa pine. Because there will be no reduction in stand densities, the risk of insect-related mortality 

would also increase, contributing to fuel loading.

The fuels modeling shows surface, ladder and crown fuels would continue to accumulate in the absence of 

fire or mechanical treatment. With no modification of forest stand structure and fuels, fire behavior under 

normal, summer weather (90th percentile) conditions would be as described in Chapter 1 for the existing 

conditions. The standing dead trees will fall over the five to ten years, adding to the current surface fuel 

loading. Once the trees have fallen, surface fuel load is estimated to exceed 100 tons/acre, and are 

characterized as a fuel model 13 where “fire is generally carried by a continuous layer of slash. Large 

quantities of greater than 3 inches material are present. Fires spread quickly through the fine fuels and 

intensity builds up as the large fuels start burning. A wildfire in the mortality pockets with high fuel loading 

will be of high intensity. In the natural stands where mortality is not as extensive as in the ponderosa pinedominated stands, some areas are expected to experience passive crown fire and flame lengths >4 feet.

FVS-FFE modeling of the No Action alternative indicates up to 40 percent mortality from a wildfire in the 

natural stands under 97th percentile weather conditions.

While research indicates spotted owls continue to occupy and may reproduce in burned areas, depending on 

burn severity (Bond et al. 2002, 2009; Lee et al. 2012, Clark et al. 2011, 2013), these findings are strongly 

influenced by small sample sizes and the extent and spatial pattern of fire effects particular to each area 

studied. While it has been shown that California spotted owls show an apparent preference for foraging in 

burned areas of all severities (Bond et al. 2009) the author attributed the majority of these results to the 

likelihood that post-burn use by owls is associated with an ‘increased abundance or accessibility of prey.’ The 

Bond study also notes that while California spotted owls foraged in all burn severity areas (potentially 

preferring high-severity burn areas) they avoided high and moderate severity areas for roosting, and 

presumably nesting.

The NWFP’s 20-year monitoring report summary for the ‘Status and Trend of Late-successional and Oldgrowth Forests’ states that some portions of the NWFP area have been setback by decades from achieving 
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186 Shasta-Trinity National Forest

those outcomes [expectations for older forest abundance, diversity, and connectivity] particularly resulting 

from large wildfires in the fire-prone portions of the NWFP area” (Davis et al. 2015). The 20-year monitoring 

report for the ‘Status and Trend of Northern Spotted Owl Habitat’ also states: “large wildfires continue to be 

the leading cause for loss of NSO habitats on federal lands. Most of these fire-related losses have occurred 

within the network of large reserves that were designed for the protection and restoration of habitat for longterm northern spotted owl conservation” (Davis et al. 2015). The summary report further notes that the loss 

rates in fire prone portions of the NSOs range exceeded the expected 2.5% rate for the 20-year period at rates 

of 3.9 to 7.4% per decade, including the California Cascades area. Most large wildfires and resulting habitat 

losses have occurred in the federally reserved land use allocations [including LSRs] designed for NSO 

conservation (Davis et al. 2015). Climate change is also expected to expand the area of fire-prone landscapes 

and an increased frequency of large wildfires this century has already been observed.

Under no action, 50 percent of the project area will have the potential for flame lengths greater than 4 feet and 

passive crown fire. Though burn severity, extent and post-fire conditions would vary widely and be dependent 

on several factors, snags and CWD would likely be consumed and the existing structure and density of 

understory vegetation and ground fuels would allow for easy transition of fire from the ground into the forest 

canopy; making crown fire more likely and direct suppression less effective. As a result, the potential for high 

severity wildfire impacts to occur and a long-term loss of NSO habitat are increased under this alternative 

with no progress made toward initiating the restoration of ecological processes that promote a natural, low 

intensity, frequent fire regime.

Cumulative Effects

As there are no direct or indirect effects under this alternative, there are no cumulative effects.

Botany

Introduction

This section analyzes effects to federally listed Endangered, Threatened, Proposed or Candidate, or Forest 

Service Pacific Southwest Regional Forester Sensitive Plant Species79 (TES species) and other botanical 

resources pertaining to the Purpose and Need for Action and Key Issues. A Biological Assessment and 

Evaluation for Botanical Species Report was completed and is incorporated by reference and information 

important to the decision is summarized here (Posey, 2015a). Boletus species and unique habitats were 

analyzed in the Compliance Report for Botanical Resources (Posey, 2015). Both reports are incorporated by 

reference. Information most relevant to the decision is summarized here.

Purpose and Need Applicable to Botanical Resources

The restoration of Elk Flat meadow is in part restoration of a unique botanical habitat and effectiveness of the 

Alternatives at meeting the Purpose and Need for Action #3-Restore Meadow Habitat in Elk Flat, and #4-

Retain Hardwoods as a Stand Component at Density Levels Commensurate with Developing LateSuccessional Stands are relevant to botanical resources. The Purpose and Need for Action is not applicable to 

TES plants.

Issues Applicable to Botanical Resources

 79 The 2013 FS R5 RF Species Sensitive Plant Species list is found here: 

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5434326.xlsx
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 187

No key issues were identified related to TES botanical species or unique botanical resources. Issue #4, 

mushroom collection in Elk Flat relates to special forest products; specifically the retention of Boletus habitat. 

Effects to the health and growth of Boletus mushrooms in Elk Flat are considered here.

Methodology

An official list of Threatened, Endangered and Candidate species was requested from the FWS website80 on 

January 5, 2016 for the Elk project area plus a 3.0-mile buffer. This document is included as Appendix 1 of 

the Botanical BA (Posey, 2015a).

81 Four species were listed; however, none have the potential to occur in the 

project area. In accordance with the ESA and regulatory guidance, only those organisms and critical habitat 

listed on the official species list are considered, and only those species under the regulatory jurisdiction of the 

FWS.

Sensitive species habitat was evaluated through review of the GIS layers for known sites of sensitive plants 

for the Shasta-McCloud Management Unit of the Shasta-Trinity National Forest, district files; the National 

Resource Information Systems (NRIS) data base, Soil Survey of Shasta-Trinity National Forest Area

California; CalFlora; and the Consortium of California Herbaria and California Natural Diversity Data Base.82

All habitats in the project area were floristically surveyed; each plant encountered was identified to the degree 

necessary to determine if it was a species of concern.83 The sensitive species identified in the assessment 

process as potentially occurring in the project area were specifically targeted in the surveys.

Results of Surveys

No sensitive plants were known to occur in the project area prior to surveys and no new populations were 

found during surveys.

Indicators and Measures

TES Species

An indicator of effects to TES botanical species would be the presence of individuals or populations and the 

numbers of individuals or populations impacted by activities.

Boletus Habitat at Elk Flat

The indicator of effects for Boletus habitat in Elk Flat meadow is the number of acres of conifer removal 

within unit 402. For the purposes of this indicator, it is assumed that all conifer cover on Elk Flat is boletus 

habitat, although it is not known how much actually supports Boletus.

Unique Habitats

Dry Meadow Ecosystem

 80 https://ecos.fws.gov/ipac/project/IYL3DX7YG5D7LGGY54W4VBV5PU/regulatoryDocuments

81 Document Nos. 140196950-13258, 140196950-1340, 140254377-13424 and 140196950-13448

82 (USDA-FS, 2014b); (NRIS, 2014); (CalFlora, 2012); and (CDFW, 2015)

83 Sensitive plant surveys were done July 7, 8, 14 and 15, 2008 by a botany crew from the Shasta-McCloud Management 

Unit. Visits were also made to the project area in July and October of 2009, June 2012, July 16, 2012, November 5, 2012, 

April 29, 2013, June 13, 2013 and May 5, June 4, August 26 and September 24, 2014. Species of concern include TES, 

Survey & Manage, or Watch List species.
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188 Shasta-Trinity National Forest

Acres of meadow restoration treatment provide the indicator and measure for restoration of the dry meadow 

ecosystem at Elk Flat. (Hydrologic function also influence meadow restoration and is included in the 

hydrology section starting on page 193.)

Hardwoods

Acres of oak release treatment and acres of aspen restoration indicate the effects related to hardwoods.

Riparian Habitat

Riparian habitat is also a unique habitat, but is covered in the hydrology section starting on page 193.

Boundaries

In accordance with CFR § 220.4 (f), spatial and temporal boundaries set the limits for selecting those actions 

that are most likely to contribute to a cumulative effect. The effects of those actions must overlap in space and 

time for there to be potential cumulative effects. This is determined by how long, and how far reaching, direct 

and indirect effects of a project are felt on a given resource area.

Spatial Bounding and Temporal Bounding

Threatened, Endangered and Sensitive Plants

The project area is the boundary for TES plants as that is the area where direct effects have potential to occur

should individuals or populations be located. Any potential impacts to TES botanical species would be direct 

and occur during project implementation.

Unique Habitats

Unit 402 is the boundary for dry meadow habitat at Elk Flat. Any potential impacts to meadow habitat would 

be direct and occur during project implementation. The boundary for unique habitats of hardwoods is the 

project boundary, as that is the area where direct effects have potential to occur. Effects of release and 

restoration treatments are expected to last approximately 20 years as conifer ingrowth will begin to encroach 

again.

Boletus Habitat

The spatial boundary for Boletus habitat is those parts of Elk Flat with conifers; approximately 412 acres. The 

remaining areas of Elk Flat without adequate conifer cover, open areas and areas with widely scattered trees, 

are not habitat for ectomycorrhizal fungi such as Boletus species. Boletus species form mycorrhizal 

associations with many conifer species, hardwoods and other plants. In Elk Flat, associated conifer species 

include ponderosa pine, lodgepole pine, and white fir. Hardwoods include black oak. Boletes, commonly 

found throughout the Cascade Range (Desjardin, et al., 2015) including the McCloud Flats, are collected by 

both personal and commercial collecting permits. The Elk project area is a favorite collection area due to the 

amount of mushrooms present and its close proximity to the towns of McCloud and Mt. Shasta.

How long these effects will last after treatment depends on the treatment. The more aggressive the thinning

and/or burning treatment the fewer mushrooms come back until that area is again providing habitat elements 

necessary for ectomycorrhizal fungi such as Boletus (Smith, et al., 2005). From the research, we can assume 

meadow restoration treatments using tree harvesting through mechanical methods that would create a 

pine/grassland savannah would result in a permanent loss of habitat conditions that support boletus species. 

Boletus habitat in unthinned patches would be underburned in a mosaic fashion leaving areas of Boletus 

refugia to recolonize the area. Depending on burn intensity, season of burning and the number of live trees 

killed by the burning, recovery could take anywhere from three to 20 years.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 189

Affected Environment

Chapter 1 describes the general vegetative conditions in the project area including the existing condition of 

the unique botanical habitat of Elk Flat meadow and hardwood status in the project area.

Threatened, Endangered and Sensitive Plants

The only TES plant with potential to occur in the project area is Cypripedium montanum, or Mountain lady’s 

slipper, which is a Region 5 Forest Service sensitive species. Mountain lady’s slipper inhabits moist areas and 

dry slopes in mixed evergreen or coniferous forest between 760 and 7200 feet. There are no known 

occurrences in the project area.

Unique Habits

Dry Meadow

Dry meadow habitat includes unit 402 at Elk Flat at approximately 518 acres. The existing condition and 

affected environment of Elk Flat are described in more detail in Chapter 1 (starting on p. 29) Vegetation 

consists of sparse perennial forbs and perennial grasses and more densely covered areas by perennial bunch 

grasses with fewer perennial forbs. More developed soils support stands of older conifers. Conifer 

encroachment, as evidenced by the presence of very young conifer species is occurring throughout the 

meadow.

Hardwoods

Aspen

Aspen stands are important to species diversity both plant and animal. Aspen are an early successional species 

and shade intolerant. They need ample sunshine to grow and reproduce. Aspen habitat has declined at a rapid 

rate due to past management such as fire suppression, timber harvest and management practices that favored 

conifers, livestock grazing and site conversions. During the early days when timber was being harvested by 

the McCloud Lumber Company and the early days of the Forest Service, aspen was considered a nuisance 

species and many stands across the flats were converted to pine trees. Livestock grazing was very intense 

until the mid-1940s and stands over-browsed. Livestock grazing declined greatly after WWII. Cattle still 

browse aspen as do deer and elk especially in late summer and fall when protein levels are higher in aspen 

than they are in grasses and forbs.

A few aspen stands throughout the McCloud Flats have been released from competing conifers in past 

projects with great results but many more are still in need of release. The Elk Salvage (2005-2005) and Elk 

Flat LSR Fuels Reduction (2007) Projects released small amounts of aspen within the boundary for this 

Project. 

Aspen is known to occur in several units in small amounts totaling approximately 25 acres (24 of which are 

proposed for release treatment). The largest contiguous aspen stand is approximately 10 acres in unit 175. 

Oak

Black oak is very important in terms of contributing to and maintaining species diversity, especially for latesuccessional wildlife species of concern such as the sensitive fisher and listed northern spotted owl (NSO). 

Oak habitats offer diverse resources to wildlife such as thermoregulation sites (shade in the summer, shelter in 

the winter), perching and resting sites, roost sites, nesting and denning cavities and food items for prey. 

Acorns are an obvious food source that is plentiful and rich in calories. Acorns are very important for 

maintaining the prey base for fisher, Pacific marten, NSOs and northern goshawks. Oak catkins, twig, leaves, 

buds, sap, and galls are also eaten. Acorns are also an important food source for deer and bear during the fall 

months because of the high fat and protein content.
Elk Flat LSR Enhancement Project

190 Shasta-Trinity National Forest

An estimated 30 acres of black oak occur scattered throughout the project area. Negative impacts to Black 

Oak from past activities are the same as for aspen. Encroachment and overtopping by surrounding conifers 

has decreased growth and the expansion of mixed conifer oak habitat. Most oaks are at the sapling stage and 

occur along roads in small openings. Portions of Unit 153 and 178 are an exception in that they have many 

adult oaks scattered throughout portions of the stands. Unit 153 has quite a few smaller and larger oaks 

(diameter classes range from 4 to 16 inches).

Boletus Habitat at Elk Flat

There are at least four species of edible Boletes known to occur on the Shasta-Trinity, the Klamath and the 

Modoc National Forests. These include the king bolete (Boletus edulis var. grandedulis), spring king bolete 

(B. rex-veris), queen bolete (B. regineus) and the butter bolete (B. aff. regius).84. They grow in soils under 

conifers and with oaks and other hardwoods. Only the spring king bolete is not known to occur with 

hardwoods. It grows in small clusters or groups buried in sandy soils under pines (ponderosa and lodgepole) 

and red fir. They fruit in the spring above 3,280 feet elevation in the Sierra Nevada and Cascade Range. All 

four boletus species are described as common. 

Generally, any conifer area having trees over 30 years old and providing enough cover to maintain a cooler 

soil temperature could be habitat. Out of the 518 acres in unit 402, 379 acres will be harvested leaving 

approximately 60 square feet of basal area per acre or less. The unthinned patches provide approximately 33 

acres of conifer with the remaining 106 acres in existing un-encroached dry meadow that does not provide 

boletus habitat. It is not known how much of the 412 acres are of conifer currently provide habitat for Boletus

species, but most if not all has the potential to eventually provide it in the absence of disturbance to reset the 

area to meadow habitat. Some specific areas identified by local boletus collectors as being good habitat were 

incorporated into the unthinned patches.

Environmental Consequences

Direct, Indirect Effects, and Cumulative - Alternatives 1, 2, 3

TES Plant Species

No sensitive plant species are known to occur within the project boundary. Standard operating procedures are 

in place to protect newly discovered populations (see Appendix C # 16, p. D-3). There would be no direct or 

indirect effects on TES botanical species and therefore no cumulative effects.

Determination of Effects to Threatened and Endangered Species

Adequate biological assessment/evaluation has been completed to determine the effects of this project on the 

plant species listed as threatened, endangered or proposed by the US Fish and Wildlife Service and sensitive 

by the USDA Forest Service Region 5. Based on the information summarized above, the project botanist has 

determined that implementation of the Elk Project will not negatively affect any plant species listed by FWS 

or Region 5 or their viability. 

Unique Habitats

Dry Meadow

 84 The butter boletes of California represent a complex of species closely related to the European Boletus appendiculatus 

and B. regius but are most likely undescribed species and in need of taxonomic clarification (Desjardin, et al., 2015 pp. 

348, 349, 350, 354 and 356).
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 191

When combined with the hydrologic restorations, Alternatives 1 and 3 fully implement the meadow 

restoration treatments of meadow enhancement (conifer removal) and underburning. Alternative 2 drops the 

conifer removal on 25 acres, but does provide the underburning. All three action alternatives provide meadow 

restoration with Alternative 2 not meeting the Purpose and Need for Action to the same extent Alternatives 1 

and 3 do. Beneficial effects are expected to be maintained by the periodic underburning with the early seral 

stage maintained for at least 30 years.

Hardwoods

Aspen 

Effects of all action alternatives are the same for aspen because the changed acres in Alternatives 2 and 3 do 

not affect aspen stands. Most living conifers will be removed within 150 feet of tree and/or sprouts and 

conifers will not be replanted in the area. Aspen will be monitored to determine how project activities 

including burning may affect aspen. Photo points as well as some type of vegetation monitoring plan will be 

put into place prior to the start of any activities to have baseline information so the effects of logging activities 

and underburning can be determined over time. Browsing by livestock and wildlife will also be monitored to 

determine if fencing is needed. Aspen stand will be mapped annually as part of the monitoring to see if it is 

expanding each year. All three action alternatives are expected to benefit aspen and meet the Purpose and 

Need for Action. Monitoring and implementation of the adaptive management strategy for aspen restoration if 

needed (see p. B-34) will assure restoration, for beneficial direct, indirect and cumulative effects in the project 

area.

Oak

Thinning around oaks will reduce competition from conifers for sunlight, nutrients and water. As described 

and illustrated on page B-26, oak release removes conifers from within 30 feet of the dripline of healthy black 

oak that will benefit from a release, and increasing the removal out to 60 feet of the dripline within the 

southern aspects. Conifer adding desirable habitat contributions would be retained as described in Appendix 

A. The retained trees contribute to the late-successional habitat within the Elk Flat LSR, and are important 

roosting and foraging resources for northern spotted owl and their prey, as well as potential future nesting 

areas (large cavities or brooms that develop). Planting acorns in openings may also increase black oak over 

time. It is expected that after the oak release work is completed, the portions of stands 153 and 178, and others 

with oak release, will be a mixed conifer/oak stand.

All three action alternatives provide beneficial direct (release), indirect (underburning to help maintain oak in 

the stands), and cumulative effects, but vary in the degree of benefit. Alternative 1 would release 

approximately 30 acres of black oak occur scattered throughout the project area. Repeated underburning 

would help retain oak in in the stands for the next 20 to 30 years. Alternative 2 reduced thinning, and thus oak 

release where oak are encountered, by approximately 98 acres. However the majority of areas dropped do not 

provide substantial oak, and Alternative 2 results in very similar effects as Alternative 1. Alternative 3 drops 

units from thinning that provide greater percentages of oaks than is common throughout the project, resulting 

in approximately 9 acres of oak release. This will create a disproportionately lower response under Alternative 

3 than the other two action alternatives and retaining oak as a stand component will not be achieved.

Boletus Habitat at Elk Flat

Boletus spp. are ectomycorrhizal mushrooms meaning they form symbiotic associations with the fine root 

systems of plants, growing out into the soil matrix. These mushrooms are sensitive to activities that disrupt or 

destroy these fine root systems. They are also sensitive to changes in soil temperature from overstory removal 

and loss of associated species. According to research on the Willamette National Forest, the more aggressive 

the thinning the longer it takes mushroom habitat to rebound (Pilz, et al., 1999).
Elk Flat LSR Enhancement Project

192 Shasta-Trinity National Forest

The unthinned patches providing current Boletus habitat would not be mechanically disturbed. Underburning

may have a negative effect on most ectomycorrhizal mushroom species because it reduces the duff and 

organic layers which is where most of the mycorrhizae occur. The potential negative effects from 

underburning would be reduced through the retention of ground cover (duff and or fine woody debris less 

than 3 inches) across at least 50 percent of all activity areas to maintain soil productivity (see SOP 5 on p. D1). Underburning would be implemented to create a mosaic pattern where burn intensities will range from 

areas not burned at all to areas burned low and at moderate intensely (p. 52, B-35). Burning in a mosaic 

pattern would retain areas of duff and down woody debris, preserving some habitat and reducing impact on 

the remaining habitat. Monitoring will occur once burning has been completed (p. 91).

It isn’t known how much of the 379 acres currently supports Boletus habitat or how much of it outside the 

UTPs would be eliminated; however, it is likely all 379 acres have the potential to eventually provided boletus 

habitat in the absence of disturbance needed to maintain the meadow habitat. Therefore, current or future

Boletus habitat in Elk Flat meadow would be reduced by approximately 379 acres through maintenance of the 

meadow ecosystem with return of more natural disturbance regimes. The 33 acres of UTPs would continue to 

provide boletus habitat.

Treatments in Elk Flat are the same under Alternatives 1 and 3. Alternative 2 would treat 25 fewer acres than 

Alternatives 1 and 3. The effects on Boletus and their habitat in Elk Flat would be much the same for all 

action alternatives, with the possibility that Alternative 2 decreases the effects to boletus on the 25 acres 

dropped from the meadow enhancement treatment (but would still include underburning). If any areas are 

severely burned, mushrooms will likely be lost until favorable soil and duff conditions return to pre-burning 

conditions. Negative effects to habitat may last 20 years or longer. Habitat in Unit 402 outside of the UTPS 

would be substantially decreased or eliminated by the removal of thermal cover and associated species and

ground disturbance. These areas will become habitat for grasses and forbs to restore the unique botanical 

habitat and maintained by repeated underburning activities.

Alternative 4 - No Action

Under No Action, the proposed management activities would not be implemented. No direct, indirect, or 

cumulative effects are expected. Current trends would continue. The unique habitats of dry meadow and 

hardwoods would continue to decline. Boletus habitat in Elk Flat would not be affected, however, natural 

disturbances such as fire or a mudflow event may alter habitat.

Summary and Conclusions

Surveys have identified no TES botanical species in the project area. Adequate procedures are in place to 

protect TES botanical species if newly discovered prior to or during implementation. There would be no 

direct, indirect, or cumulative effects to TES botanical species with any alternative considered in detail, and a 

determination has been made there would be no effect to botanical TES species.

Effects Relative to Purpose and Need for Action

All three action alternatives meet the Purpose and Need for action pertaining to dry meadow habitat at Elk 

Flat. Alternative 2 does not meet it as well as Alternatives 1 and 3 by providing 25 fewer acres of meadow 

enhancement treatment.

All three action alternatives meet the Purpose and Need for action for retaining hardwoods. There is no 

difference between the alternatives for aspen. Alternative 3 meets the Purpose and Need for Action on less 

than 1/3 of the available areas for oak when compared to Alternatives 1 and 2.

Effects Relative to Key Issues
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 193

All three action alternatives reduce boletus habitat at Elk Flat in favor of the unique habitat of dry meadow. 

All three action alternatives retain some boletus habitat at Elk Flat in the unthinned patches, although it may 

be reduced in value for 20 years through underburning. Alternative 2 removes conifer on 25 fewer acres. If 

those acres correspond to current or developing boletus habitat, it may have a slightly reduced negative effect 

when compared to Alternatives 1 and 3.

While the key issue is limited to the habitat at Elk Flat, it is worth noting that boletus are common species 

throughout the forested portions of the west. Elsewhere in the project area the design criteria to protect 

northern spotted owl (NSO) and goshawk habitat will also retain habitat for many fungi species including 

Boletus by retaining tree and shrub species, down woody debris, snags and overstory cover. Using the RPMs 

in place for survey and manage fungi and the Best Management Practices discussed in the project soil report 

will also help retain and improve fungi habitat by retaining 30% to 50% of the duff layer and down woody 

debris.

Compliance with Law, Regulation and Policy

The Elk Flat LSR Enhancement Project is in compliance with the Forest Plan (4.14,4.16), and other relevant 

laws, regulations, policies and plans including the Endangered Species Act of 1973 as amended, USDA Dept. 

Regulation 9500-4, Forest Service Manual 2670.12, 2670.22, 2670.32, 2671.1 and 2672.42.-2672.43.

TES species were analyzed in the BA/BE for this project. None were found during surveys and none were 

known to occur prior to surveys. No plant species including fungi species will be affected by the Elk project 

to the extent that they will need to be listed as a TES species at any time in the future.

The Forest Plan (p.4.81) directs the management of non-timbered areas of Elk Flat primarily for early seral 

stage species. NFMA directs us to manage for diversity of ecosystems across the landscape to provide a 

variety of habitats for numerous species of wildlife, plants and fish. Early seral stages such as grasslands and 

forb/grasslands are not well represented on the Shasta side of the Shasta-Trinity National Forest. Most are 

being affected by conifer or shrub encroachment.

Hydrology

A Hydrology Report (George, 2015) was completed for this project and is incorporated by reference. 

Information relevant to this decision is summarized here.

Introduction

Purpose and Need Applicable to Hydrology

Purpose and Need #5- Increase Streamflow, Raise Water Table Elevation and Improve Water Quality and 

Vegetation Conditions within Riparian Reserves Associated with Elk Flat, Ash and Swamp Creeks and Their 

Tributaries.

, applies to hydrology. This also incorporates the portion of Purpose and Need #3-Restore Habitat in Elk Flat

that is dependent on hydrologic function.

Issues Applicable to Hydrology

Issue #4 expressed concerns regarding the effects of machine piling on watershed health.

Methodology

Methods include qualitative and quantitative analysis at multiple scales from data and information collected 

from field reconnaissance, monitoring and literature review within the cumulative effects watershed, subdrainage and project area (George, 2015)
Elk Flat LSR Enhancement Project

194 Shasta-Trinity National Forest

Incomplete and Unavailable Information

Analysis at the watershed scale incorporates reported past, present and foreseeable activities on public and 

non-public lands. Unreported actions are assumed to occur on non-public land and were not included in the 

analysis.

Indicators and Measures

Table 59 summarizes the indicators and measures used to analyze and disclose effects to hydrology, the 

relevant key issue, and the Purpose and Need for Action. A discussion follows the table providing rationale 

for each indicator and measure.

Table 59. Hydrologic Resource Indicators and Measures

Resource 

Element Indicator Measure

Purpose & 

need, Key 

issue, or 

Resource 

Effect

Source

Water 

Quality

Water quality necessary 

to support healthy riparian

and aquatic ecosystems. 

ACS Objectives (ACSO) - #4. 

Actions meet or Do Not Prevent 

Attainment of ACSO at project and 

watershed scales Purpose and 

Need #5

Forest Plan pp. 

4.53-54, (USDAFS & USDI-BLM, 

2007) (USDAFS, 2011 p. 30)

Range of Natural Variability (RNV)

– Changes to turbidity and water 

temperature falls within the RNV

Riparian

Area

Processes 

and 

Functions

Riparian Vegetation -

Plant species composition 

and structural diversity of 

plant communities

ACS Objective - #8. Actions meet 

or Do Not Prevent Attainment of 

ACSO at project and watershed 

scale

Purpose and 

Need #5, #3

Forest Plan pp. 

4.53-54, (USDA 

USDI, 2007

Floodplain 

and Meadow 

Processes 

and 

Functions

Timing, Variability, and 

Duration of Floodplain 

Inundation

ACS Objective - #7. Actions meet 

or Do Not Prevent Attainment of 

ACSO at project and watershed 

scales Purpose and 

Need #5, #3

Forest Plan pp. 

4.53-54, (USDAFS & USDI-BLM, 

2007) (USDA- W FS, 2011 p. 30) ater Table Elevation in 

Meadows and Wetlands

RNV-Changes to water table 

elevation falls within the RNV

Riparian

Habitat

Connectivity

Riparian Corridor - Habitat 

Conditions in Naturally 

Appearing Riparian 

Corridors

ACS Objective - #9. Actions meet 

or Do Not Prevent Attainment of 

ACSO at project and watershed 

scales

Purpose and 

Need #5, #3

Forest Plan pp. 

4.53-54, 4.81, 

(USDA USDI, 

2007

, 

Key Issue Indicators

Watershed 

Health

Sediment Transport and 

Erosion Rate

RNV-Changes in sediment 

transport and erosion rate fall 

within the RNV as evaluated by 

general disturbance level

Resource 

Effect; Issue #5

(USDA-FS, 2011 

pp. 31,84,85)

BMPs

Ground Disturbance – at 

the Sub-Drainage Scale 

Disturbance – Relative to existing 

condition

Resource 

Effect; Issue #5

Forest Plan,

1995 p. 4.25. 

Ground Disturbance -

Equivalent Road Acre

(ERA)

ERA must fall below the Threshold 

of Concern (TOC) of 18% at the

watershed scale

Resource 

Effect, Issue #5 Forest Plan TOC

Discussion of Indicators and Measures

Water Quality
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 195

Water quality must remain within the range that maintains the biological, physical, and chemical integrity of 

the system and benefits survival, growth, reproduction, and migration of individuals composing aquatic and 

riparian communities. Attaining ACS objective #4 approximates water quality, because the processes that 

maintain water quality must be within their natural range of variability to be in a properly functioning 

condition. Turbidity and temperature are water quality parameters that describe current conditions and further 

characterize the natural range of variability.

Turbidity

Changes in turbidity can indicate the amount of suspended sediment in water introduced by disturbance and 

this can affect water quality. Discerning background from introduced suspended sediment input is difficult but 

by comparing runoff during a range of storm events, upstream and downstream of road crossings, turbidity 

can be used to estimate sources of suspended sediment. Turbidity measures the amount of light passing 

through water and indicates the presence of suspended particles, which interrupt the passage of light, 

sometimes recognized as cloudiness in water, as well as relatively clear water when fine particles cannot be 

actually recognized or seen. 

Water Temperature

Water temperature variability reflects a variety of inputs such as ground water, runoff, amount of shade or 

sunlight near or well above the water surface in overstory canopy, as well as air temperature in adjacent stands 

or whole drainages.

Riparian Area Processes and Functions

Riparian Vegetation

Plant communities in riparian areas and wetlands must be maintained as indicated by ACS Objective #8 to 

provide adequate summer and winter thermal regulation, nutrient filtering, appropriate rates of surface 

erosion, bank erosion, and channel migration and to supply amounts and distributions of coarse woody debris 

sufficient to sustain physical complexity and stability.

Floodplain and Meadow Processes and Functions

Floodplain Inundation

Floodplain inundation indicates stream processes and floodplain interactions are maintained over a natural 

range of variability of runoff timing and duration. Attaining ACS Objective #7 indicates that channels are 

actively flooding onto the floodplain, spreading flow and releasing energy without excessive erosion or 

deposition.

Water Table Elevation and Storage

Increases in water table elevation and storage should result in extended flow duration as exhibited by 

comparing flow duration in the channel, as compared to before and after storms, with flow duration response 

after treatment. An increase in flow duration would indicate that infiltration and groundwater discharge is 

increasing water table elevation and water storage and indicate that ACS Objective #7 is being maintained. 

Other evidence that ACS Objective #7 is maintained or improved would be active flooding on the floodplain, 

meadow saturation and the growth of upland sedges. Increased flooding, infiltration and sediment detention 

should result in the development of floodplain elevations consistent with existing meadow contours and 

establishment of meadow vegetation in areas adjacent to streams in Elk Flat meadow.

Riparian Habitat Connectivity
Elk Flat LSR Enhancement Project

196 Shasta-Trinity National Forest

Riparian Corridor – Habitat Conditions in Naturally Appearing Riparian Corridors

Riparian Habitat Connectivity would increase with riparian vegetation extending along the channel and 

outward away from the channel with linkages from the aquatic to the terrestrial resources. Maintaining or 

improving Aquatic Conservation Objective #9 would be demonstrated by increased riparian habitat 

connectivity over the current condition. 

Key Issue - Watershed Health

Watershed Health can indicate whether natural processes and functions are in equilibrium where background 

sediment transport and erosion rates fall within a range of natural variability resilient to temporary natural 

disturbance, such as dispersing erosive energy and detaining sediment during flooding.

Sediment Transport and Erosion Rate

Watershed drainage area receives precipitation and transports it as runoff according to the erosive and 

depositional processes functioning within the watershed. Where sediment transport and erosion rates fall 

outside their range of natural variability, these processes do not function as contributing towards Watershed 

Health and can be identified by excessive erosion on the landscape or sediment transport from landscapte to 

streams. However, due to the naturally high background sediment transport rate in this watershed changes to 

sediment transport are masked, and direct measurements to detect changes are not measurable at a project 

scale or when evaluated on a watershed scale. Floodplain function and the presence of riparian vegetation is 

assumed to reduce both sediment transport and erosion rate along streams and in the watershed and indicate 

that active erosion and sediment transport in response to temporary natural disturbance falls within a range of 

natural variability. In addition because channel forms adjust through time to a range of runoff conditions, 

where erosive energy is dispersed while maintaining a stable channel form in relation to the ability to flood on 

the floodplain these channels are considered to erode and transport sediment within a range of natural 

variability resilient to temporary natural disturbance. Channels out of adjustment have altered forms such as 

entrenchment. The presence of entrenched channels that cannot flood are assumed to have high rates of 

sediment transport and erosion.

Ground Disturbance at the Sub-Drainage Scale

Monitoring results of past activities within the Sub-Drainages that intersect the project area are used to 

characterize the resilience to ground disturbance by activity and recovery potential (George, 2015). An 

increase in ground disturbance beyond the resilience of the soil to retain its structure, infiltration rate and 

capacity to recover from disturbance may increase erosion, sediment transport, peak flow and a loss of 

infiltration from compaction depending on soil characteristics ( (Rust, et al., 2015). Current recovery by the 

Sub-Drainages from past ground-disturbance is used to describe the resilience of the Sub-Drainages to ground 

disturbance and provide an estimate of the expected response to Sub-Drainage characteristics from future 

ground-disturbing activities. In addition, local observations of ground disturbing activities during monitoring 

on public land and similar activities identified on non-public land are assigned a coefficient based on a given 

ground disturbance activity and acres reported to compare existing condition and future condition for each 

Sub-Drainage (for a complete description see narrative below and (George, 2015).

Equivalent Road Acre at the Watershed Scale

The Ash Creek Watershed boundary identified from the Forest watershed GIS layer is used to analyze effects 

from the project at a large watershed scale. A TOC was developed for 5th field Watersheds during the forest 

planning process and is the only scale used for comparison between existing and proposed activities. 

Equivalent Road Acre (ERA) is used as a surrogate for changes in runoff and any effects to peak flow 

discharge due to ground disturbance, (George, 2015).
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 197

ERA is a measure that compares the disturbance of a given area to that same area of a native road surface 

(Haskins, 1983).This method is used to evaluate effects from all activities that may cause disturbance known 

to occur in the watershed (George, 2015)

To determine relevant past, present, and foreseeable future projects, spatial and temporal boundaries must be 

defined (CFR § 220.4 (f)). For the effects analysis the direct and indirect effects of the Elk project relative to 

hydrology are conditions influencing runoff and sedimentation.

Spatial Bounding

Spatially, the conditions influencing runoff and sedimentation. (e.g. road construction and machine piling) in 

the project affect sedimentation in channels. As such, the spatial context is the project, sub-drainage and 

watershed scales:

1. Project Scale - As defined by the project boundary. 

Sub-drainage Scale –As defined by 2nd to 3rd 2. order watersheds that intersect the project boundary 

(Forest Plan, 1995). The 8th field hydrologic unit code (HUC) Sub-Drainages are used as a proxy for 

the 2nd to 3rd order watersheds as they are the smallest watershed-scale mapping unit available.

The Watershed Scale - The hydrology cumulative effects analysis area is the Ash Creek 5th 3. field 

HUC watershed (Watershed). The TOC for the Ash Creek watershed encompassing the Elk Flat

LSR project boundary is used to compare with the existing condition and the proposed action for 

cumulative effects analysis (Forest Plan).

These scales represent the area potentially influenced by effects from proposed treatment activities.

Temporal Bounding

The temporal context ranges with the type of activities from onset of the activity to a lifespan of decreasing 

disturbance with time, up to 30 years into the future; 30 years is approximately how long the most ground 

disturbing treatments would take to recover, decreasing in ERA and effects to runoff and sedimentation with 

time. Forest Transportation System Roads are considered permanent features and would therefore not recover.

In this analysis, the description of the existing condition includes the accumulation of past activities, which 

have influenced vegetation. In the effects discussion, “short-term” refers to effects over the 10-year period 

from the time the activity was accomplished. Beyond 10 years, effects are considered “long-term.” The 

current environmental conditions reflect the aggregate impact of all prior human actions and natural events 

that have affected the environment and might contribute to cumulative effects and are a proxy for the impacts 

of past actions.85

Affected Environment

Streamflow and Channel Condition

Banks are more susceptible to erosion in the project area in contrast to banks upstream where abundant 

riparian vegetation and in-stream bedload structure is functioning. Intermittent channels carry snowmelt or 

rainfall runoff with either intermittent duration, or as intermittent surface flow migrating across the landscape 

at a frequency controlled by flow volume and timing. Ephemeral channels refer to those channels that flow in 

response to rainfall events (going dry during protracted rainless periods when percolation depletes all flow

(Linsley, 1982). All channels within the project area have intermittent streamflow and some are occasionally 

 85 This approach is consistent with CFR § 220.4 (f) and the Council on Environmental Quality June 24, 2005 

memorandum regarding analysis of past actions.
Elk Flat LSR Enhancement Project

198 Shasta-Trinity National Forest

ephemeral. Along Ash Creek, channel condition varies from properly functioning condition where channels 

are able to flood in unconfined reaches, to where reaches are confined and flooding remains within the 

channel. Swamp Creek is not in a functioning condition. Ash Creek and Swamp Creek are intermittent 

channels that may flow during 100 year recurrence interval runoff events to the McCloud River, although 

downstream of the project area the channels are mostly dry during most years.

Water Quality

Water in the Ash Creek Watershed contains a naturally occurring high suspended sediment load from 

upstream glacial outwash, mudflows, volcanic ash, and other sediment sources recruited from stream bank 

erosion and flood events; these are responsible for the range of natural variability for a naturally high 

sediment load in streams in this watershed. Road surface runoff observed entering streams during larger 

rainfall and snowmelt events, adding fines to suspended sediment and streamflow, and comprise the sediment 

entering the stream outside the range of natural variability. Water temperature and turbidity has been 

measured at discrete locations in the Watershed during periods of base flow as well as before, during and after 

storm events give some indication of the existing condition and range of variability.

Turbidity

Turbidity was measured during and after storm events, as well as during periods when equipment was 

working in the channel, for culvert replacement or stream restoration. Turbidity measurements indicate the 

presence of suspended sediment is greatest during storm events and declines sharply to background levels 

soon afterwards. Turbidity increases and decreases rapidly with the onset and termination of disturbance in 

the channel such as from storms, culvert replacement or stream restoration. Due to the ashy volcanic soils and 

naturally high background sediment load in this area, this response characterizes the natural range of 

variability of turbidity as it responds to a range of events, some large, episodic, and random. Soils are 

moderately high to highly resilient to disturbance (See Soils Report Appendix B.) In general, turbidity 

increases during periods of equipment activity and storms shows a recovery time to pre-disturbance as being 

very short-lived, the water typically clears from equipment-work within a few hours or from storm events in a 

few days in streams in the Ash Creek Watershed.

Water Temperature

Water temperature varies consistently with the seasons, warmer in the summer, cooler in the winter, but has 

considerable fluctuation in daily temperatures during the summer months. Near stream, water-surface shading 

from riparian vegetation, known to have the greatest effect on reducing and moderating water temperatures in 

comparison to over-story shading, is absent along Ash Creek. Over-story shading from conifer is the dominant 

shade source and also functions to shade-out riparian plants that would normally occur along the banks.

Riparian Area Processes and Functions

Riparian Vegetation

Sunlight is often limited within riparian areas where past harvest has occurred and natural regeneration of 

conifer species develops dense stands in the project area. Sunlight reaches through the conifer forest in only a 

few places between the uppermost reach of the project area and the crossing of Forest Road 19 upstream of 

the project area in the watershed. These few sunny sites contain the greatest riparian plant numbers and 

diversity with willow and alder forming dense pockets on large mid-stream gravel bars, and the channel has a 

lower width/depth ratio and much higher degree of sinuosity than the other channel reaches. Here, deeper 

water allows higher soil moisture and favorable conditions for riparian plant species.

The project area lies within the Bartle Grazing Allotment. The meadows and riparian areas attract livestock 

and receive livestock use. Trailing is evident along both sides of Ash Creek. Livestock congregate along Ash 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 199

Creek near the junction of U41N96A and U41N97A where the area is trampled and bare of vegetation from

livestock use. Cattle use patterns are managed through the grazing permit.

Floodplain and Meadow Processes and Functions

Floodplains and meadows are very limited within this watershed. They are characterized by finer sediment 

deposited by floods, glacial loess and ash deposits.

Floodplain Inundation

Floodplain inundation occurs in reaches where the channels are not entrenched and streams can reach the 

floodplain and overflow during large storms. Manmade features, such as old landings and unauthorized 

routes, restrict flooding and concentrate energy on floodplains and meadows. (George, 2015). Past activity 

obliterated some intermittent and ephemeral channels, diverted flow and interrupted riparian and floodplain 

function. Along Ash Creek, these remnant features impede and confine flooding. Natural floodplain contours 

are altered and eroded by old landing activities and modify hydrologic processes associated with stream and 

floodplain interaction, such as retention of flood flow, groundwater storage and riparian plant community 

establishment.

Water Table Elevation and Storage

Water table elevation and storage supports intermittent stream flow for both Ash Creek and Swamp Creek, but 

manmade features reduce infiltration on the floodplain and meadows and increase runoff conditions that limit 

ground water storage and flow duration. Areas without channel incision have likely retained most of their 

original water table elevation and storage character within the meadow.

Riparian Habitat Connectivity

A 150-foot Riparian Reserve (RR) on each side of intermittent, non-fish-bearing Ash Creek and Swamp Creek 

is established (per Forest Plan guidance utilizing a RR width established by a site potential tree height of 150 

feet) (Forest Plan, 1995). All other intermittent channels in the project treatment units are have a 100 foot 

buffer as they are characteristically inactive, responding only to 100 year flood events, but are recognized as 

important connective features needing protection. During high flows the contribution of nutrients, woody 

debris and sediment are assumed to be redistributed within the watershed as recognized as important functions 

of intermittent systems by Reid (Reid, 1994). High flows allow plant communities to expand in the 

downstream direction as seed and live plant material from upstream populations are redistributed 

downstream. Instream structure in Ash Creek consequently supports aquatic habitat limited to macroinvertebrates. Swamp Creek does not contain aquatic organisms due to its very short and infrequent flow 

duration. Channels without woody material lack structure to the bedform and often exhibit incision. Incision 

creates entrenched channels that cannot reach the floodplain to disperse floodwater, sediment and erosive 

energy. Aquatic organisms occur only in Ash Creek and are limited to macro-invertebrates. Terrestrial 

organisms supplied by the abundant riparian vegetation upstream of the project, and the limited riparian 

vegetation in the project area, are assumed to be a main food source to macro-invertebrates. Woody debris 

embedded in the channel also functions as important habitat for aquatic invertebrates.

Key Issue - Watershed Health

The Ash Creek Watershed lies within an area that exhibits a low occurrence of surface erosion and mass 

wasting with peak streamflow relatively low per unit area (Haskins, 1983). Topography varies dramatically in 

this watershed; slopes are steep along the highest elevations near the summit of Mount Shasta and 

surrounding volcanic outcrops, becoming intermediate to gentle around the alluvial fans where the Project is 

located. The volcanic soils, low gradient drainages lack of landslide potential and low peak flows indicate the 

Ash Creek Watershed has low sensitivity to disturbance (Haskins, 1983). 
Elk Flat LSR Enhancement Project

200 Shasta-Trinity National Forest

Sediment Transport and Erosion Rates

Ground disturbance from past silvicultural activities such as road-building, disking in plantations, windrow 

construction, site preparation for planting, is evident throughout the project area but monitoring results 

indicate little active erosion and sediment transport. In addition to forest system roads, unauthorized roads not 

designed or maintained for use add to road surface runoff. Many of these roads are hydrologically connected, 

capturing surface runoff that would otherwise infiltrate water into the ground, picking up fine sediment and 

eroding the surface. Elevated road prisms may control flow by intercepting or damming upslope runoff while 

low road prisms may pond water. All channels and ditches may activate during large events and flood road 

areas. Road damage from runoff events and poor drainage can be seen on some unauthorized roads. With 

inadequate road crossings and road alignment across fans, upstream of the project area, this has led to channel 

realignment and shortening, concentration of flow down roads capturing runoff and developing channels.

Road culverts are designed to pass a 100-year recurrence interval size runoff event. 

The Sub-Drainage Scale

This 15,900 acre area is composed of Sub-Drainages that intersect the project boundary. This represents the 

acres from ongoing and past activities within the last 30 years within each Sub-Drainages. (George, 2015).

The current condition of the Sub-Drainages at monitoring sites indicates little erosion, sediment transport or 

impediments to infiltration. Slopes are very low in activity areas and vegetation recovery is evident within 

several seasons (George, 2015).

The following table illustrates the current ERA results range from 5% to 27% for Sub-Drainages adjacent to 

or within the project area. 

Table 60. ERA of Ongoing and Past Activities at the Sub-Drainage Scale

Sub-Drainage Name Current ERA Total Sub-Drainage 

Acres % from Project % of Sub-Drainage 

in ERA

1802000401050301 193.7 3594.73 0 5

1802000401050302 355.2 2295.25 19 15

1802000401050303 416.2 1903.06 9 22

1802000401060101 45.6 1930.55 18 2

1802000401060102 386.7 1826.25 11 21

1802000401060103 744.6 2712.60 11 27

1802000401060104 395.7 1638.16 7 24

Equivalent Road Acre (ERA) at the Watershed Scale

From near the peak of Mount Shasta at 14,179 feet to about 4000 feet in elevation south of the McCloud 

River, encompassing over 10,000 feet of elevation change this watershed has a 113,867 acre drainage area

where climate, topography and past and current management influence surface runoff and ground water.

Watershed and Sub-Drainage boundaries were identified from the Forest watershed GIS layer. A TOC was 

developed for the Ash Creek Watershed during the forest planning process and is only used for comparison 

between the existing and proposed activities at this scale. 

The Ash Creek Watershed has been analyzed in the forest plan for sensitivity to disturbance and assigned a 

TOC of 18%, indicating a watershed with low sensitivity to disturbance (Forest Plan, 1995). Using the most 

readily available data for this watershed scale, the existing Ash Creek Watershed ERA is 8.3%, moderately

lower than the TOC of 18 % (USDA , 2009; USDA-FS, 2014c). 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 201

Past activities in the Ash Creek Watershed include a range of activities on private and federal lands such as 

timber harvest (hazardous fuels reductions, green tree retention, salvage and thinning), road and landing 

construction, grazing and fuels. Road and stream interaction magnify runoff effects where several roads are in 

close proximity to one another resulting in a deleterious effect to water quality as the greater road runoff has 

more energy and picks up more sediment that is then delivered to the stream. Ash Creek interacts with road 

runoff inputs during moderate events such as at the intersection of the Military Pass road (FR 41N19X) with 

FR 41N09. Access along roads that intercept these channels may be disrupted and result in flood debris 

accumulating on roads. Such conditions could occur almost anywhere in the project area but especially in the 

following units and their associated roads: 171, 170, 150, 153, 154, 18, 155, 156-U, 346, 346-U, 224, 14, 218, 

157, 347, 180, 107, 157, 162, 179, 401, 402, 110, 317 and 318.

Environmental Consequences

Alternative 1- Modified Proposed Action

Direct and Indirect Effects – Alternative 1

Water Quality

Turbidity

Water quality will benefit under this alternative from the elimination of a number of road interactions with 

channels that currently divert or capture runoff, decommissioning of roads in Riparian Reserves that will 

reduce sources of road water and sediment to channels and closing of roads that will be completed to 

standards. Little to no sediment transported into Ash Creek, or other intermittent channels, is expected from 

proposed activities, as ground disturbance will primarily occur on nearly flat slopes with a 20-foot buffer 

equipment exclusion zone from the edge of the inner gorge of all channels. However, due to the 

characteristically high natural background sediment load, changes in turbidity from these beneficial actions 

will not be measurable.

All activities follow BMPs and additional RPM’s designed to avoid water quality impacts and additional 

RPMs to ensure that water quality will remain falling within the range of natural variability for the area. 

Decommissioning, and at some locations, recontouring, user-created roads in Elk Flat and old landings in 

floodplains along Ash Creek will prevent future stream capture by roads.

Temperature

Riparian vegetative cover along the stream should increase by harvesting dense conifer and creating openings 

for sunlight needed for growth. Although riparian growth along the channel will increase stream surface 

shading, an overall negligible effect on water temperatures is expected due to the small scale of the treatment 

area relative to the size of the watershed upstream that carries the most influence to stream temperature.

Riparian Area Processes and Functions

Riparian Vegetation

Long-term stand health is expected to increase throughout the project area as the benefits from 

implementation are realized. Thinning forest stands in Riparian Reserves will have a short-term minor 

disturbance. Thinning will favor both forest and riparian vegetation as the change from shaded to open forest 

and openings will promote riparian growth with the increase in available sunlight. Thinning will also have a 

noticeable, but temporary effect on ground temperatures, until understory vegetation grows in. With the 

removal of over-story vegetation, the soil will be heated by direct solar exposure, but this effect will change to 

less solar exposure as the understory vegetation recovers.
Elk Flat LSR Enhancement Project

202 Shasta-Trinity National Forest

The rate of woody debris input will change from the undesirable current state of whole tree failure, causing 

bank erosion and debris dams, to incremental input of woody debris as riparian vegetation stabilizes banks 

and forest stands increase in health and vigor.

Indirect effects expected in the riparian areas include a proliferation in riparian vegetation sprouting, a 

moderate increase in bank strength from riparian vegetation rooting, development of instream structure, such 

as point bars, an increase in sediment detention and bank construction and increased floodplain interaction 

with the channel. Collecting native seed, growing seed for out-planting and planting after disturbance from 

ground-disturbing activity will also serve multiple benefits: promoting riparian plant community 

development, stream bank strength, floodplain function wildlife habitat and appearance of a natural corridor.

Because the area is in an active cattle allotment and livestock graze within the project area and Riparian

Reserves, riparian plant community improvement will be influenced by livestock grazing as managed by the 

grazing permit.

Long-term beneficial effects from an increase in floodplain interaction with streams, riparian vegetation and 

improved bank strength to the plant communities, summer and winter thermal regulation within the riparian 

reserve, nutrient filtering from properly functioning floodplains.

Floodplain and Meadow Processes and Functions

Floodplain Inundation

As natural contours are restored at old landings and meadows, near-stream flooding will resume and flood 

energy will be dissipated on floodplains and meadow areas. Reconnection of floodplain to channels will 

improve timing, variability and duration of floodplain inundation, water table elevation and storage.

Water Table Elevation and Storage

Removing manmade features and restoring natural contours will increase infiltration and 

contributions to groundwater, raise water table elevation and increase water storage. Riparian

Habitat Connectivity

Recontouring old landings in riparian areas along Ash Creek will promote floodplain function and the 

interaction of the channel to carry and distribute nutrients, woody debris and sediment allowing plant 

communities to expand laterally and across the floodplain.

Key Issue - Watershed Health

Sediment Transport and Erosion Rates

Thinning and underburning that increase sunlight will favor the growth of riparian vegetation and sediment 

detention during flooding, and will reduce sediment transport and erosion rates leading to improved 

watershed health over the long term. Although these are incremental benefits, the increase in floodplain 

function allows sediment to be detained and erosive energy to dissipate and will optimize conditions for

sediment detention processes. Increased riparian vegetation will increase stream bank stability leading to 

decreased sediment and erosion rates over time in the project area adding to watershed health. At a watershed 

scale, little measurable change to sediment transport rate from this project will result due to improvements to 

road drainage and reduced road mileage.

The Sub-Drainage Scale

The existing ERA for seven Sub-Drainages that intersect the project area varies from 5% to 27% ground 

disturbance (George, 2015). Results from the ERA analysis at the Sub-Drainage scale shows a general 

increase in disturbance for six of the seven Sub-Drainages from the project, one Sub-Drainage drops to 0% 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 203

while the other Sub-Drainages increase up to nearly 40%. Due to the monitoring results that indicate that a 

27% ERA remains resilient to disturbance in this area, additional activities at other locations from the project, 

but within these resilient Sub-Drainages are expected to continue to be resilient to disturbance and respond 

with similar recovery as the other activity areas. The low slopes and past evidence of little erosion, sediment 

transport or impediments to infiltration from previous activities are used to determine that new activities, 

some designed to improve ground surface conditions and return areas to properly functioning conditions, that 

soil and vegetation will recover within several seasons (George, 2015).

Equivalent Road Area on a Watershed Scale

Existing Condition ERA for the watershed is 8.3%, Alternative 1 increases ERA by 0.7%, additional future 

planned activities modeled for the watershed on public and non-public lands raises ERA by 1.3% totaling 

10.3% ERA for the Ash Creek Watershed.

Effects relative to Purpose and Need for Action

Alternative 1 meets the project purpose and need by restoring riparian vegetation and floodplains in the 

Riparian Reserves, and treating stands to improve resilience to disturbance. Timber harvest, vegetation 

treatment, prescribed burning and floodplain restoration are proposed to attain the ACS objectives (Forest 

Plan pp. 4.54, 4.56). Alternative 1 is expected to increase stand health, vigor and resilience to disturbance by 

treating forest stand density through responsive harvest prescriptions and by reducing fuels. A modest 

increase in acres of riparian plant communities is expected along Ash Creek, especially where vegetation 

treatments will open the dense canopy to sunlight and improve conditions for riparian growth. As sites vary 

along the stream and within the Riparian Reserve, other forest restoration activities will benefit stand densities 

for shade and thermal regulation on stream terraces. Units with greater volume removed will require more 

harvest equipment, skidding and heavy equipment use, although skidding patterns and distances to landings 

are designed to minimize equipment use. Likewise, more landings will result in more ground disturbance. The 

proposed stand thinning within the Ash Creek Riparian Reserve will serve multiple purposes: creating 

openings, increasing sunlight, favoring diversity, health and vigor of riparian vegetation and regulating the 

incremental input of woody debris to enhance instream aquatic bedform structure. 

Effects relative to key issues

Effects to Watershed Health from activities to resource indicators listed in Table 59 are mostly short-term 

disturbance to water-holding properties from site-specific treatments with little if any effects outside of the 

treated units or project area as measured by the amount of equivalent road acre at the project, sub-drainage 

and watershed scales.

Overall, minor direct effects such as slight displacement of surface soils, and minimal ground disturbance, are 

expected to occur. No deleterious effects to resource indicators are expected from harvest activities. All acres 

in Alternative 1 could receive under-burning as described in Chapter 2. Underburning will produce a mosaic 

of fuel consumption on a relatively flat topography with little opportunity to influence stream runoff. 

Underburning is allowed within all Riparian Reserves with the restriction that only 5% of embedded large 

woody debris may experience burning over the project area. Evidence of prescribed fire and a mosaic of ash 

and charring of wood and organic debris are expected.

Cumulative Effects – Alternative 1

In some areas, effects from past activities continue to this day, interrupting and relocating surface and 

subsurface runoff, stream flow and floodplain interaction during large storm events. Incremental positive 

watershed effects from treatment will:

• increase floodplain and meadow function, infiltration and channel stability;
Elk Flat LSR Enhancement Project

204 Shasta-Trinity National Forest

• increase sunlight to understory vegetation;

• reduce unauthorized route runoff and sedimentation to channels;

• reduce the risk and increase resilience to disturbance from of high intensity fire and associated runoff 

and sedimentation to channels;

• return fire to the role of maintaining natural openings in Riparian Reserves and Elk Flat.

Effects vary by the number of entries; more entries will result in potentially more ground-disturbance than 

fewer entries, such as harvest followed by machine piling and burning. Equipment thinning, machine piling 

and burning are considered potentially high ground-disturbing activities from multiple entries of heavy 

equipment followed by fuel treatments. Activities using tractors will result in initial low ground disturbance 

from mechanical harvest and moderate ground disturbance from additional machine piling. However, 

implementing BMPs and project resource protection measures will prevent water quality impacts and 

maintain soil and watershed resources. Short-term disturbance to water-holding properties from site specific 

treatment is expected, with little or no effects outside of the treated units or project area. An overall 

improvement to watershed function from increased vegetative species diversity and vigor and improved

resilience to natural disturbance is expected to follow from this temporary disturbance.

Activities such as road maintenance and fuel treatments will improve watershed functions and processes over 

that of roads and drainages in poor condition and high risk of stand replacing fires.

The Ash Creek Watershed has a TOC value of 18% ERA. The Existing Condition ERA for the watershed 

(8.3%) is 46% of the TOC, Alternative 1 ERA (0.7%) is an additional 0.04% of the TOC, other future planned 

activities modeled for the watershed ERA (1.3 %) is 0.07% of TOC; the existing and future activities on 

public and non-public lands would be approximately 46.7% of TOC for the Ash Creek Watershed.

Alternative 2- No New Temporary Road Construction Other Than Those Required 

for Landing Access

Alternative 2 is the same as Alternative 1 except that it does not meet the purpose and need of the project as 

well as Alternative 1 by having slightly less benefits for some indicators: Water Quality, Water Table 

Elevation, Channel Bank Stability, Floodplain Restoration, Woody Debris and Riparian Corridor Habitat 

Conditions. Access to thinning units is necessary to meet ACS objectives and optimize stand objectives in all 

areas; this reduction in proposed thinning does not meet the stand health objectives as well as Alternative 1 

would.

Direct and Indirect Effects – Alternative 2

Access to some stands will be limited under Alternative 2. With no temporary road construction, some 

portions of some units will not be treated and fewer landings would be needed. Less thinning and associated 

ground disturbance may appear to be less of an effect; however, Alternative 2 ultimately does not address the 

stand health issues that arise from not treating the stands and meeting the objectives identified in the project

purpose and need. 

Riparian Reserve benefits are reduced under this alternative compared to Alternative 1 because the existing 

access to Units 110 and 114 is insufficient, and would limit reaching 3.3 acres of Riparian Reserve treatment 

areas. Similarly, there is insufficient access to 4.3 acres in Units 346 and 347, where recontouring old landings 

in riparian areas to promote floodplain function and riparian habitat connectivity is proposed. Less treatment 

within Riparian Reserves reduces benefits from increased exposure to sunlight, riparian growth, bank 

stability, stand health and woody debris recruitment; Riparian Reserve stand objectives would not be 

addressed without the use of a temporary road for these few acres.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 205

Effects relative to key issues

Without temporary roads, access to some units will lower the total road disturbance, and will slightly increase 

ground disturbance over the unit area from increased skidding distance. However, because of the small unit 

area, the net outcome would be no measurable effect to any resource indicators at the Watershed scale.

Cumulative Effects – Alternative 2

There would be no measureable cumulative effect from reducing 1 mile of road construction to the 

measurement indicators from this alternative; therefore, this alternative would have approximately the same 

cumulative effects as Alternative 1. The ERA remains the same as Alternative 1.

Alternative 3 - No Treatments of Natural Stands within Designated Critical Habitat 

for the Northern Spotted Owl

Alternative 3 reduces the disturbed ground by 716 acres;86 however, it also does not meet the purpose and 

need for maintaining stand vigor and building resilience to disturbance through time as well as Alternative 1 

in the LSR (see Chap. 3, Silviculture and Forest Health).

Direct and Indirect Effects – Alternative 3

No measurable direct or indirect effects are expected to resource indicators. Alternative 3 would reduce 

approximately 31 acres of prescribed fire within the Ash Creek Riparian Reserve (in Units 150 and 171.)

Other Riparian Reserves (approximately 5 acres in Units 214 and 216) would also not receive prescribed fire.

Cumulative Effects – Alternative 3

Reducing the acreage of disturbed ground with Alternative 3 would result in no measureable difference in 

measurement indicators; therefore, this alternative would have approximately the same cumulative effects as 

Alternative 1.

Alternative 4 - No Action

With Alternative 4, the no action alternative, the proposed management activities would not be implemented.

No direct, indirect, or cumulative effects are expected. Although there would be no actions undertaken with 

this alternative, ongoing trends would continue.

No action is expected to continue a trend towards high stand mortality and densities, even-aged stands, 

excessive fuels and associated risk of uncharacteristic fire. Therefore, Alternative 4 does not meet and 

prevents attainment of ACS objectives as restoration activity and unauthorized road decommissioning will not 

occur.

Cumulative Effects

Since there are no direct or indirect effects with Alternative 4, there would be no cumulative effects. However, 

current trends would continue. Any of these outcomes would be detrimental to meeting watershed and 

Riparian Reserve objectives from the loss of hydrologic processes and functions at all scales. Alternative 4 

would continue the lack of floodplain function from old landings within floodplains, unauthorized roads and 

poor sunlight conditions for riparian plant growth.

Summary and Conclusions

 86 This reduction is for underburning. Other ground-disturbing activities are reduced by lower amounts 

depending on the activity, as described in the Chapter 2 summary tables for Alternative 3.
Elk Flat LSR Enhancement Project

206 Shasta-Trinity National Forest

No impacts to aquatic systems would occur with any of the action alternatives.

Although Alternatives 2 and 3 do not optimize Riparian Reserve objectives, they still meet and do not prevent 

attainment of ACS objectives. All alternatives except Alternative 4 meet and do not prevent attainment of 

ACS objectives.

Watershed Scale

The Existing Condition ERA for the Ash Creek Watershed is at moderate risk for exceeding threshold (8.3% 

of 18% ERA); Alternative 1, and other planned activities throughout the watershed on public and non-public 

land would add 2% ERA resulting in a slight addition to the moderate risk of exceeding TOC (10.3 % out of 

18%) TOC (George, 2015 p. Appdx. B). 

Project Scale

A modest increase in acres of riparian plant communities is expected from all action alternatives.

Table 61. Summary of Hydrologic Resource Elements and Indicators: The Expected Response by the Indicator 

from the Proposed Action, Alternatives and Effect to the Resource.

Indicator

Alternative 1

( Modified Proposed 

Action)

Alternative 2

(No New Temporary 

Road Construction)

Alternative 3

(No Treatments in 

CHU)

Alternative 4

(No Action)

Water Quality

Benefits to water quality 

from elimination of road 

interactions with channels 

and road, landings and 

main skid trails,

decommissioning and 

closures. Within RNV

Same as Alternative 

1

Same as Alternative 

1

Current trends 

continue. ACS #4 not 

met

Riparian Area 

Processes and 

Functions

Increase in riparian 

vegetation, rate of woody 

debris input and bank 

stability with reduction of 

dense conifer canopy and 

improved floodplain 

function along the Riparian

Reserve. Short-term minor 

ground disturbance and 

temperature.

Benefit from reduced 

road runoff would be 

offset by longer skid 

distances. Less 

sunlight and riparian 

growth than 

Alternative 1.

Fewer acres of 

riparian vegetation 

improvement. no 

measureable effect at 

Watershed scale

At risk for decline 

from a stand 

replacing fire, high 

rates of erosion, 

sedimentation and 

loss of Riparian

Reserve function.

would not meet ACS

Objective # 7

Floodplain and 

Meadow 

Processes and 

Functions

Reconnection of floodplain 

to channels will 

incrementally improve 

timing, variability and 

duration of floodplain 

inundation, water table 

elevation and storage.

Reduced riparian 

treatment due to 

decreased access.

same as Alternative 

1.

Continued decline in 

floodplain function 

and would not meet 

ACS Objective #8.

Riparian Habitat 

Connectivity

Habitat connectivity within 

the riparian area improves 

as riparian vegetation 

extends along stream 

reaches and from the 

stream to the floodplain

from recontouring old 

landings to natural 

contours.

Natural flooding and 

interaction to promote 

riparian habitat 

connectivity would be 

reduced from 

Alternative 1 due to 

decreased access.

Slightly reduced 

benefits from 

Alternative 1.

Little connectivity of

riparian habitat areas, 

would remain 

ineffective in meeting 

ACS Objective #9.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 207

Indicator

Alternative 1

( Modified Proposed 

Action)

Alternative 2

(No New Temporary 

Road Construction)

Alternative 3

(No Treatments in 

CHU)

Alternative 4

(No Action)

Watershed 

Health 

(Alternative 

meets ACS

objectives or 

does not prevent 

attainment of 

them)

Maintains or improves 

watershed function. From 

a watershed scale, the 

health of the watershed 

would not change.

Same as Alternative 

1

Maintains or 

improves watershed 

function but not as 

well as Alternative 1. 

Approaches the 

benefits of Alternative 

1.

Current trend would 

continue to not meet 

or prevent attainment 

of all 9 ACS

objectives. Nonfunctioning conditions

of sediment runoff

would continue 

degrading the 

watershed and 

riparian areas.

Effects relative to Purpose and Need for Action

All action alternatives would meet Purpose and Need #5- Increase Streamflow, Raise Water Table Elevation 

and Improve Water Quality and Vegetation Conditions within Riparian Reserves Associated with Elk Flat, 

Ash and Swamp Creeks and Their Tributaries.

Alternative 2 does not meet the purpose and need of the project as well as Alternative 1 because although the 

presumed benefit from less road runoff is expected, it is a slight reduction. There would be slightly less 

benefit to the water table elevation, streamflow and vegetation as floodplain restoration of old landings would 

not occur, however, no measurable difference in floodplain inundation or water table elevation would be 

detected due to this small difference in lack of floodplain restoration. A slight reduction in the benefits to 

natural flooding and riparian habitat connectivity would also result, as some riparian treatments would not 

occur. The effects from reduction in temporary road would not be noticeable at the watershed scale.

There is little difference in effects from Alternative 3 compared to Alternative 1. However, Alternative 3 

would limit the extent of prescribed burning as well as other treatments designed to improve vegetation 

conditions; reduced acres of prescribed fire within the Riparian Reserve LSR acres would reduce the benefit 

of removing excess fuel and lowering the risk of wildfire designed to promote resilient riparian vegetation 

conditions. 

All action alternatives would meet Purpose and Need #3-Restore Meadow Habitat in Elk Flat as it applies to 

hydrologic function, to the same extent.

Effects relative to key issues

Machine piling for Alternative 1 would add 0.04% to the ERA existing condition, Alternative 2 and 3 ERA 

results are the same 0.04% shows no difference at a watershed scale. Effects on watershed health from 

machine piling under Alternative 1 compared to Alternative 2 or 3 are not detectable at a watershed scale.

Compliance with Law, Regulation and Policy (includes Forest Plan under NFMA)

All action alternatives (1, 2 and 3) meet and do not prevent attainment of the ACS objectives at the watershed 

and project scales. The degree to which the action alternatives meet all 9 ACS objectives varies with how 

well: a) Overstocked stands and fuels are reduced over the project area; b) How well treatment within riparian 

reserves improves openings for sunlight for riparian vegetation; and c) How well floodplain processes and 

functions are restored. See Appendix H (p. I-13) for a complete discussion of the project effects relative to 

ACS objectives.

Analyzing for effects at the 2nd and 3rd watershed scales (using Sub-Drainages as a proxy for analysis) found 

that all ground disturbance due to any of the action alternatives resulted in slightly ground disturbing effects. 
Elk Flat LSR Enhancement Project

208 Shasta-Trinity National Forest

Recovery would be at rates that would maintain properly functioning condition of the Sub-Drainage, and 

there would be no excessive cumulative impacts on stream channel condition and water quality, rather stream 

channel condition and water quality should improve above the existing condition.

Soils

A Soils Specialist Report (Rust, et al., 2015) was completed for this project and is incorporated by reference. 

Information relevant to this decision is summarized here.

Introduction

Purpose and Need Applicable to Soils

Soils are the basic resource that support or directly influence most, if not all, other resources. This support is 

through soil productivity (Forest Plan p. 3.75). As such, maintaining soil productivity would indirectly 

support purpose and need statements #1 to #4. Purpose and Need #2, “Accelerate Development of LateSuccessional and Old Forest Characteristics”, particularly calls out an existing condition/desired condition 

departure for soils in the windrowed plantations (see Existing Condition section starting p. 28). The loss of 

soil productivity between the windrows directly affects site productivity and sustainability resulting in 

retarded stand development.

Issues Applicable to Soils

Issues #2 and #5 apply to effects on soils (see pp. 44, 46).

• Issue #2 – expresses the concern that road construction directly harms forest health and wildlife and 

results in long-term impacts to soil health and productivity, pertains to the soils resource. This issue 

applies to the Temporary roads that will be constructed to access landings, since no new FTS roads 

are proposed to be constructed for the project.

• Issue #5 – expresses the concern that machine piling has disproportionately harmful impacts on 

watershed and soil resources.

The Environmental Consequences section discusses temporary road construction and machine piling effects 

relative to the soils resource.

Methodology

Soils in the Elk project area were analyzed using several methods. Soils were reviewed using soil survey data, 

data in GIS, and field reconnaissance along with monitoring information and best available science regarding 

soils. Most of the units have been field reviewed by the soil scientist to verify mapping, identify areas where 

soil productivity may be affected by proposed actions, and examine current disturbance on site. The effects of 

each alternative on the soil resource have been assessed using the Region 5 Soil Quality Standards and the 

Forest Plan. Soil quality analysis standards provide threshold values that indicate when changes in soil 

properties and soil conditions would result in significant change or impairment of the productivity potential, 

hydrologic function, or buffering capacity of the soil. Management activities have potential to cause various 

types and degrees of disturbance. Soil disturbance is categorized into compaction, displacement, puddling, 

churning, severe burning, and erosion.

Initial field surveys were conducted by a soil scientist in July 2009. Subsequently ,the National Soil 

Disturbance Monitoring Protocol (NSDMP) (Page-Dumroese, et al., 2009) level one analysis (visual soil 

disturbance indicators) and a level two analysis (validation sampling) using transects to measure erosion, 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 209

disturbance, compaction, displacement, and cover (Rust, 2011) were conducted. More information on 

NSDMP can be found in the soil specialist report.

Assumptions

The soils analysis assumes the following:

• Nonproductive Area - System roads, borrow pits, and utility corridors are a permanent commitment 

of resources and are not counted as detrimental soil disturbance as they are not part of the productive 

land base (Forest Plan pp. O-2).

• Expected New Disturbance Levels from Silvicultural Treatments - Anticipated new disturbance 

from ground based yarding, averages about 9% of an activity area; however, not all new disturbance 

exceeds thresholds for detrimental soil disturbances. The current level of detrimental disturbance is 

9% for the project area. Appendix C of the Soils Specialist Report and Rust (2013a) describes further 

details on disturbance. Newer equipment, effective BMP’s and site specific resource protection 

measures would be utilized.New disturbance would generally overlap old disturbance adding only 

one to three percent cumulative detrimental soil compaction. Disturbance from tractor harvesting in 

winter conditions would be less due to logging on snow or frozen ground. Monitoring following 

winter harvest on the Shasta Trinity National Forest (Rust, 2013) showed a one to two percent 

decrease in porosity over pre-harvest levels of two to four percent. Mastication of biomass material 

accounts for an additional one percent.

• Expected New Detrimental Levels from Fuels Treatments - Detrimental soil disturbances from 

fuel treatments are estimated at an additional one percent for underburning; two percent for 

mechanical slash piling and burning, negligible for hand piling for each unit (Rust, 2013b).

• Erosion Potential - Erosion is predicted to remain low in all units and in all alternatives due to soils 

that are deep to very deep, well drained and gentle slopes. The steepest slopes in the project area were 

used in the erosion modeling.

• Soil Recovery Rates - The effect of management on soil recovery is dependent on soil type, climate, 

moisture, cover and time. By using the Universal Soil Loss Equation (USLE) typical recovery rates 

can be developed that show for erosion, soils with 50 to 70% cover; recovery is in 3 to 5 years versus. 

15 to 30 years for full soil function recovery (litter, duff, and topsoil disturbance recovery) see Table 

62.

Table 62. Soil Disturbance Recovery Rates

Soil Types and Conditions in Project Area Erosion Compaction Fertility

Germany 2-3 years 10-20 years 5-10 years

Shasta 2-5 years 5-10 years 5-15 years

Windrowed soil 2-5 years 5-10 years 20-30 years*

Source: (Rust, 2009) and (Foss, 2010)

* Windrow spreading can hasten recovery considerably.

Indicators and Measures

Table 63 lists resource and key issue indicators and measures used to evaluate effects to soils. All of the 

indicators indirectly affect attainment of meeting Purpose and Need #s 1 to 4. Discussion of the rationale for 

each indicator follows.
Elk Flat LSR Enhancement Project

210 Shasta-Trinity National Forest

Table 63. Indicators and Measures of Effects for Soils

Resource 

Element

Resource 

Indicator Measure

P&N, Key 

Issue, or 

Resource 

Effect

Source

Soil Productivity

Erosion and 

Displacement

Soil Erosion 

Hazard Rating 

(EHR)

The calculated erosion risk based on soil 

texture, depth, infiltration, rock fragments, 

surface cover, slope, and climate is “low” 

unless mitigated. (see Soils Report 

Appendix A) Resource

R-5 FSH 2505.22

Water Erosion 

Prediction 

Project 

(WEPP) Rating

Tons/acre of soil loss USFS WEPP

Resiliency Soil Resiliency 

Index Rating

The soil resiliency to erosion, compaction, 

displacement, burning, puddling, and 

whole-tree removal. The resiliency index is 

based on textures, permeability, depth, 

rock, slope, and cover after the disturbance 

and climate. (See Soils Report Appendix 

B). The measure ranges from slight to 

severe. Effects for elk pertain primarily to 

litter and duff removal.

Resource

Appendix B Soil 

Resiliency Index, 

(Rust, et al., 2015)

Organic 

Matter

Litter and Duff

Litter and duff occurs over 50% of activity 

area (where natural plant community is 

capable), or natural plant community will 

produce enough annually to cover 50% of 

activity area.

Resource, P&N 

#2, and 

component of 

Key Issues #2 

and #5 

indicators

Forest Plan

(Forest Plan pp. O1). LSRA

Large Woody 

Material

Large woody material (in forested areas) –

at least 6-10 logs per acre in 

decomposition classes 3-5.

Compaction Soil Porosity

Percent of the natural porosity in 

undisturbed conditions is at least 90% of 

natural.

Issue Indicators

Issue #2,

Soil Health 

and 

Productivity

Attainment of 

soil quality 

standards 

(SQS) post 

implementation

Acres in comparison to No Action Issue #2 

indicator “d”

see p. 45

(SQS in Appdx. O 

of Forest Plan)

Issue #5, 

Soils 

Resource

Public Issue 

#5,

Soils 

Resource

Machine piling

Acres of machine piling and acres of 

machine-piled areas that meet soil quality 

standards post implementation

Issue #5

indicator “a”

See p. 46

(SQS in Appdx. O 

of Forest Plan

Attainment of 

SQS postimplementation

Issue #5

indicator “b”

Discussion

Soil Productivity

Soil productivity is described on page 4.25 and Appendix O of the Forest Plan. Surface organic matter and 

soil porosity are used as the indicators of soil productivity most likely to be influenced by the project.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 211

Surface Organic Matter

• Litter and Duff –Litter and duff are the organic layers on top of mineral soil consisting of fallen 

vegetative matter in various stages of decomposition. Litter includes woody material up to 3 inches in 

diameter. The presence of living vegetation that could contribute significant annual litter fall to 

compensate for conditions when immediate post disturbance litter and duff coverage is too thin or less 

than 50 percent is counted in this assessment. Litter and duff are not measured in areas incapable of 

producing the required litter and duff.

• Large Woody Material – Residue left after advanced brown-rot decay is a brown, crumbly mass 

composed largely of lignin, an important component in western forests. Since brown rot typically 

affects only heart wood, large trees allowed to die and decompose naturally in the woods serve as an 

important lignin source. Soil wood possesses one key characteristic that makes it important: the 

ability to hold water. This high water-holding capacity provides: 1) Plant-available water, especially 

during the driest months; 2) Excellent underground habitat for all types of soil biological activity, and; 

3) Appropriate conditions that cause a hub of mycorrhizae fungi activity. Wood decay fungi 

(mycorrhizae) contributes to: 1) Breaking down plant residues and recycling carbon to the soil or the 

atmosphere; 2) Releasing mineral nutrients from plant residues and making the nutrients available to 

living organisms, and; 3) Producing the physical character of the soil matrix. This decay by 

mycorrhizae helps promote soil water infiltration rates, soil water-holding capacity, cation exchange

capacity, nutrient availability, nitrogen fixing activity, and other beneficial processes.

When in forested areas (in this project Elk Flat meadow would not be a forested area), desired large 

woody material (also referred to as coarse woody debris) consists of logs in contact with soil. The 

desired logs are at least 20 inches in diameter and at least 10 feet long in various stages of 

decomposition.

Compaction – Soil Porosity

Soil porosity refers to the amount and character of void space within the soil. In a “typical” soil, 

approximately 50 percent of the soil volume is void space. Pore space is lost primarily through mechanical 

compaction. Three fundamental processes are negatively impacted by compromised soil pore space; gas 

exchange, soil water infiltration rates, and water holding capacity. Soil oxygen is fundamental to all soil 

biologic activity. Roots, soil fauna, and fungi all respire, using oxygen while releasing carbon dioxide. When 

gas exchange is compromised, biologic activity is also compromised. Maintaining appropriate soil biologic 

activity is important when considering long-term forest vitality. Severely compacted soils do not allow 

appropriate water infiltration, leading to overland flow and associated erosion, sediment delivery, spring 

flooding, and low summer flows.

The Forest Plan standard calls for at least 90% of the total porosity found under undisturbed or natural 

conditions. Porosity is evaluated between 4 and 8 inches below the surface for soils with tress and shrub 

potential, and between 0 and 4 inches for soils with herbaceous potential (Forest Plan, Appendix O).

Eorosion and Displacement –

• Erosion Hazard Rating - The Erosion Hazard Rating (EHR) was developed to assess the potential 

risk of a given soil to erode. The EHR system is designed to assess the relative risk of accelerated 

sheet and rill erosion. This rating system is based on soil texture, depth, infiltration, rock fragments, 

surface cover, slope, and climate. Erosion is generally low for the project area due to coarse soil 

textures and gentle slopes. Appendix A of the Soils Specialist Report describes further details on EHR 

calculations.
Elk Flat LSR Enhancement Project

212 Shasta-Trinity National Forest

• Water Erosion Prediction Project (WEPP) Rating - The WEPP soil erosion model was developed 

by an interagency group of scientists including the USDA's Agricultural Research Service (ARS), 

Natural Resources Conservation Service, Forest Service, the Dept. of Interior’s Bureau of Land 

Management and US Geological Survey. Scientists from these agencies throughout the United States 

have been working since 1985 to develop this erosion prediction model to replace the Universal Soil 

Loss Equation (USLE) for various land management activities (timber harvesting, roads, grazing, fuel 

reduction, prescribed fire and wildfire).

Soil Resiliency

Soil resiliency is a soil’s ability to resist or recover a healthy state in response to destabilizing influences. The 

index rating calculations looked at erosion, compaction, displacement, degradation by fire, puddling/churning, 

and whole tree removal susceptibility. Appendix B of the Soils Specialist Report describes further details on 

soil resiliency. For the Elk Project, litter and duff removal and recover is the major diving factor of the index 

and how quickly the soils will recover.

Key Issue Indicators

Soil Quality Standards

Soil quality standard measure detrimental disturbance the acres pre and post project that would meet the SQS

as described in Appendix O of the Forest Plan for soil productivity, soil hydrologic function, soil moisture 

regime and soil environmental health assess the projects impacts on soil health. Of these parameters, soil 

productivity measured through the indicators listed above, is the primary measure that has potential for 

effects. Natural processes such as climate, amount of rainfall, soil texture, geomorphology and time, influence 

soil hydrologic function and soil moisture regime. Acres meeting soil quality standards pre and post project 

will assess project effects on soil health.

Machine Piling and Temporary Road Construction

The acres and effects of machine piling and the pre and post piling effect on meeting soil quality standards, 

and a discussion of temporary road use and construction, will also indicate project effects relating to the key 

issues.

Boundaries

To determine relevant past, present, and foreseeable future projects, spatial and temporal boundaries must be 

defined (CFR § 220.4 (f)). Spatial and temporal boundaries set the limits for selecting the actions most likely 

to contribute to cumulative effects (FSH 1909.15, 15.2). The direct and indirect effects of the Elk project 

relative to soil productivity including erosion (surface cover), and resiliency and conditions influencing 

compaction [porosity], surface organic matter (litter and duff and large woody debris) (Forest Plan p. 4.25)

Spatial Bounding

Spatially, the conditions influencing soil productivity, resiliency and erosion in the project are potentially 

ground disturbing or soil modifying activities, such as mechanical tree cutting, skidding and piling, and 

prescribed burning.

Temporal Bounding

The temporal context being considered is activities 2-15 years into the future in non-windrowed areas and 2-

30 years into the future for windrowed areas; 2-30 years is approximately how long proposed treatments 

would affect soil erosion, compaction, organic matter, LWD, and resiliency as discussed in the assumptions 

section).
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 213

The baseline year used for this analysis is the year 2015 as the existing condition. In this analysis, the 

description of the existing condition includes the accumulation of past activities, which have influenced 

vegetation. In the effects discussion, “short-term” refers to effects over the five year period from the time the 

activity was accomplished. Beyond five, effects are considered “long-term.” The current environmental 

conditions reflect the aggregate impact of all prior human actions and natural events that have affected the 

environment, might contribute to cumulative effects, and are a proxy for the impacts of past actions.87

Affected Environment

Existing Condition

The Elk Project is located in the Southern Cascades Ecological Section (M261Dg) of northern California.

This section is dominated by Pliocene volcanic basalt flows buried by Quaternary alluvium. Mass wasting and 

fluvial erosion are the main geomorphic processes. This area is typified by nearly level glacial outwash 

terraces and lava flows. Surface water exists within the project area in Ash Creek and Swamp Creek, which 

flow intermittently throughout the year.

Soils within the project area have predominately formed in volcanic outwash terraces on timbered toe-slopes. 

Soils formed in volcanic outwash are generally deep to very deep (40 to 60 inches) sandy loams to loamy 

sands. Figure 17 shows the treatment units overlaid on general soil map units for the Elk Project indicating 

most treatment units are located on Shasta and Germany soils, which are well drained loamy sands and sandy 

loams. Germany family soils are deep volcanic sandy loam soil. Shasta family soils are a very deep volcanic 

loamy sand soil.

 87 This approach is consistent with CFR § 220.4 (f) and the Council on Environmental Quality June 24, 2005 

memorandum regarding analysis of past actions.
Elk Flat LSR Enhancement Project

214 Shasta-Trinity National Forest

Figure 17. Elk Project Soils Overlaid with Project Units

Surface Organic Matter

Soil cover from organic matter is nearly continuous throughout the project area except old skid trails and 

landings.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 215

Litter and Duff

Even where cover is naturally patchy, such as in woodland and shrub vegetation types, soil cover standards 

are met (well exceeding 50%). Average observed depth of litter is and duff is 6 centimeters with total organics 

ranging from 1 to 13 centimeters. The thinner litter and duff layers are located in the Elk Flat , this is likely 

due to the area having high natural disturbance from the geomorphology (i.e. debris flow, flooding, fire etc.). 

This area is predominately grasses and at this time is not capable of producing 50% litter and duff coverage, 

due to this although the units have 45% and 20% coverage of litter and duff, they still fall within standards. 

Most locations within the project area have a canopy cover of perennial, live vegetation, which serves as a 

relatively continuous source of replenishment for soil organic matter.

Germany and Shasta soils have good soil fertility due to their depth and available water-holding capacities. In 

general, most timber soils have low fertility and most nutrients are recycled from decomposing roots and 

surface duff that gets incorporated into the soil. Since most roots are in the upper one to two feet of soil, it is 

very important to protect topsoil from displacement and erosion.

Legacy monitoring (TEAMS 2009) indicate units 6, 12, 13, 14, 16, 110, and 208 (all plantations) have high 

levels of soil displacement and low LWD counts due to relict windrowing practices of converting brush fields 

to timber plantations. Additionally these plantations have truncated topsoil A horizons due to windrowing. 

Soil displacement windrowing monitoring (Rust, 2012)compared windrowed trees to inter-bay trees to see if 

surface duff and partial topsoil scalping from windrowing has affected soil productivity. In all cases when 

topsoil was scalped from windrowing, the windrow trees benefited (more nutrients, moisture, and space) from 

the topsoil and the inter-bay trees, suffered. These conditions occur on units 6 and 14. The loss of these 

processes, due to windrowing has direct effect on site productivity and sustainability. 

Large Woody Material

The soil wood in the Elk Project area is generally adequate, but was generally more common in units without 

prior disturbance. Currently, LWD greater than 20 inches in diameter is sparse in plantations but for the rest of 

the project levels are adequate (Rust, et al., 2015 p. Appdx. C).

Compaction-Soil Porosity

Skid trails are the longest lasting detrimental disturbance, where many machines travel over the same route 

and compact the soil. Available water holding capacity is compromised as well by compaction since less 

water infiltrates to be held for plant growth on many soil types. Decreases in soil porosity from machine 

traffic may have some positive effect in that increasing the bulk density of these coarse textured soils (which 

results in increased water holding capacity), may provide water for plant growth longer into the growing 

season and promote increased tree growth (Gomez, et al., 2002). This has been observed in silvicultural site 

productivity surveys on McCloud Flats that shows no net decreases in site indexes for sandy soil in areas that 

were compacted (Flemming, 2010).

For the Elk Project, 51 percent is undisturbed (SD0), 34 percent is disturbed (SD1), and 15 percent is highly 

disturbed (SD2 & 3) as topsoil displaced or in skid-trails. Legacy porosity levels for disturbed areas, is 4 

percent decrease in porosity and for skid-trails is six percent decrease in porosity. Units 162, 164, 166 and

206, are over soil quality standard thresholds at or greater than 15 percent of the area, which require measures 

to alleviate compaction in those areas.88With resource protection measures that are planned with the 

alternatives operations will not be adding to legacy levels, in some cases soil productivity will be increased.

 88 The Forest Plan allows 20% in uneven-aged systems (Forest Plan p. 4.25j); however, 15% is used here as a 

conservative approach.
Elk Flat LSR Enhancement Project

216 Shasta-Trinity National Forest

Data from monitoring of soil compaction in projects on the McCloud Flats 2001 to 2013 shows on average 

across all soil types, current mechanical harvesting operations decrease porosity on skid-trails only by one to 

three percent from pre-harvest levels due to better equipment, effective BMPs, use of existing skid-trails, and 

site specific mitigations (Rust, 2013a). Total disturbance increased on an average of 12 to 15 percent using 

new harvest methods but this disturbance was not detrimental. New harvest equipment is lighter on the 

ground and has a bigger footprint. For volcanic soils on average, there is a three percent increase in 

detrimental compaction on skid-trails between pre- and post- harvest with a nine percent larger “footprint”.

Erosion and Displacement - Soil Erosion Hazard Rating

Table 64 summarizes the current composite EHR by soil type. Bare soil refers to soil without cover, current 

refers to current conditions before treatment, and treatment refers to soil cover after treatment. Soil cover is 

canopy (tree, forbes, grass), litter, duff, and rocks greater 3⁄4 inches.

Table 64. Elk Flat LSR Enhancement Project Erosion Hazard Rating (EHR)

Soil, Bare Soil by % Slopes, 

Current EHR, Post-Treatment EHR EHR Rating

Germany

0-20% slope, bare soil 2.3 low

Current 0.5 low

Post treatment 0.9 low

Shasta

0-10% slope, bare soil 0.6 low

Current 0.1 low

Post treatment 0.2 low

10-30% slope, bare soil 4.7 moderate

Current 0.9 low

Post Treatment 1.9 low

Moderate ratings mean that accelerated erosion is likely to occur in most years and water quality impacts may occur, resource 

protection may be applied in certain cases. High to very high EHR ratings mean that accelerated erosion is likely to occur in most years 

and that erosion control measures should be evaluated.

Soil Resiliency

Table 65 summarizes the composite soil resiliency rating derived from Appendix B of the soil report. 

Germany soils have a high resiliency rating which means the soil can withstand many destabilizing impacts 

without decreasing its inherent productivity. Shasta soils have a moderate resiliency rating, which means 

some of its soil properties are more sensitive to destabilizing impacts, and treatments need to consider these 

factors with creation of soil protection measures to protect these soils from those impacts. The RPMS (see p. 

83) and SOPs and BMPs (see pp. D-1, D-4) include soil resources protection for the project.

Table 65. Soil Resiliency Index Rating

Soil Resiliency Rating

Germany 97 High

Shasta 115 moderate
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 217

Key Issue Indicator 

Soil Quality Standards

Currently, 3,336 acres in the project area (about 95%) meet SQS. Estimated acres of machine piling needed 

based on fuel loading is approximately 944 acres. The maximum acreage, pending deadfall, approximates 

1,461 acres. Of the acres to be machine piled 703 currently meet SQS. The acres that meet standards are 

throughout the machine-piling units; however, units 162, 164, 166, and 206 have pre-existing skid trails are 

increasing compaction and do not meet SQS on those compacted areas.

Unauthorized Routes

The existing condition relative to non FTS roads, or unauthorized routes, is described in detail in the 

Transportation section (starting on p. 225). Unauthorized routes are areas of disturbed soil from past vehicle 

use (and possibly current illegal motorized access).

Environmental Consequences

Alternative 1- Modified Proposed Action

Direct and Indirect Effects – Alternative 1

Surface Organic Matter

Surface organic matter may be influenced by the project. Biomass may be thinned through mastication. 

Depending on the market conditions at the time of implementation, biomass material may be treated with a 

combination of mechanical treatments (mastication), hand thinning or prescribed fire during the underburning 

operations. Masticated biomass chipped material would remain on site. Chipped material on the ground can 

decompose more rapidly. As decomposition increases, organic matter and nutrients are added more quickly to 

the soil. Soil temperature can increase from canopy reduction but soil moisture increases from the soil cover 

so decomposition rates will increase. With some soil incorporation of the masticated chips, decomposition 

will be accelerated along with the release of carbon dioxide. Important soils nutrients will be released faster 

(N, P, Ca, Mg, S etc.) and made for plant uptake and for increased microbial activity (Powers, 1983). Burning 

after mastication will further reduce fuels on the ground. There will be a short term N increase and nutrient 

release. Some wood may turn into char, which would increase water holding capacity. There will also be 

needle cast from surrounding trees to provide cover for the soil where fire does burn current litter and duff.

Prescribing burning in Elk Flat will burn off the dead vegetation, invasive encroaching conifers, and releases 

nutrients to the soil that are integral to plant growth which renews old decedent perennial grasses with 

negligible detrimental soil impacts. Meadow grasses are unaffected along with the soil by these low intensity 

fires as observed from the recent prescribed fire in Mud Creek Meadows in November 2013.

Underburning reduces surface slash and thins understory vegetation while releasing short-term nutrients for 

tree growth. Prescribed fires burn at low intensity and create a mosaic burn that is beneficial to soil fertility so 

long as they leave greater than 50% duff and fine litter. Moderate to high intensity underburns can destroy 

litter, duff, and intermediate trees reducing cover to less than 50%. When, underburning in large.

Recent prescribed fire effectiveness monitoring (Rust, 2013c) was conducted on Shasta Lake Northwood’s 

Community Protection Zone (CPZ) for prescribed fires of 2010, 2012, and 2013. Fuel treatments consisted of 

pile burning and broadcast burning in transition conifer/brush from the forest boundary along Packers Bay to 

O’Brien Mountain private homesteads. Northwood’s CPZ prescribed fires overall effect on the soil was 

minimal and after 1 year vegetative recovery was excellent compared to fall burned areas. Fall burned sites 

consumed most soil cover and duff, had loss of soil organic matter, and topsoil exposure was evident. Spring 
Elk Flat LSR Enhancement Project

218 Shasta-Trinity National Forest

burned sites had excellent cover, high levels of soil organic matter, and little loss of topsoil. In areas that 

burned low to moderately-low (prescribed fires in the spring), soils had excellent cover, intact topsoil, good 

organic matter, abundant seed source, adequate duff, and good structure showing how spring prescribed fire 

treatments reduce fuel loading and soil burning. This is due to soil being moist below the duff layer protecting 

critical soil organic matter and surface duff vs. fall burn when soil moisture conditions were dry (in spite of 

duff being moist).

Severely burned soils can reduce soil fertility and decreased biologic activity. Loss of organic matter through 

displacement decreases natural resiliency to disturbance, reduces nutrient cycling and availability, and all 

benefits associated with aggregation (tilth, porosity, bulk density, root penetration, etc.). Prescribed fire can 

increase available nitrogen for one to two years following fire (Choromanska, et al., 2002). Burning slash 

piles can create extremely high temperatures in concentrated areas, leading to volatilization of nitrogen, and 

loss of phosphorus and potassium (DeBano, 1991). If litter layers and organic matter are kept intact 

throughout the stand, nutrient losses are minimized from burning slash. Limitations on pile size in the 

machine piling units (see RPM 4 on p. 83) and low to moderate intensity prescribed fire resulting in a mosaic 

of burn intensities as prescribed (also see RPMS 19, 20, 24, 25, 26, 27, 29, 30), will minimize nutrient losses.

Over all, with the protection measures in place and based on local observation for similar projects, surface 

organic matter will be preserved adequately to meet or exceed forest plan standards by maintaining a post 

implementation percent cover of litter and duff of approximately 60% and CWD of 5 to 35 tons per acre 

Forest Plan standards depending on the location. See also RPMs 11, 24, 26, 27, 40, 41, and 42 and SOPS 5

and 17 in Appendix C.

Compaction-Soil Porosity

Thinning will cause some soil disturbance of displacement, compaction, and rutting but levels of detrimental 

soil disturbance are generally low. Levels are moderate: less than 15% detrimental soil disturbance, 4 to 8% 

decrease in soil porosity, and a 14 to 17% increase in areal disturbance, not exceeding soil quality standard 

thresholds for erosion, compaction, churning, or displacement. For the adjacent Mudflow Project of 2012-3 

soil disturbance was 42% undisturbed, 41% was light disturbance, and 17% was skid-trails with lightly 

disturbed areas having an average of 2.6% decrease in soil porosity (a 1 to 2 percent decrease in porosity over 

pre-harvest levels of 2 to 4 percent)and skid- trails having a 5.4% decrease in soil porosity. Given the above 

data it shows mechanical timber harvesting moderately compacts sandy soils (3 to 5% decrease in porosity) 

with a bigger footprint of soil disturbance (7 to 10% increase).

Research shows that moderate levels of compaction (less porosity) can be beneficial in sandy loam soils like 

McCloud Flats (Gomez, et al., 2002). They found that sandy loam soils have large macro-pores were 

compressed with moderate levels of compaction, available water holding capacity increased favoring tree 

growth.

Thinning around legacy trees where all vegetation will be 50 foot radial removed causing a slight increase in 

soil disturbance but still well below SQS thresholds. Similar impacts can be expected for aspen and oak 

release treatments. Compaction can decrease water infiltration rates, leading to increased overland flow and 

associated erosion causing sediment delivery to streams. Severe compaction decreases gas exchange, which in 

turn degrades sub-surface biological activity and above-ground forest vitality.

With the for-mentioned information, units 162, 164, 166, and 206 have detrimental disturbance levels above 

10 percent mostly in existing landings and skid trails. These units with loamy soils (Germany) are more easily 

rutted and compacted especially during wet weather. The risk of exceeding standards are minimized by 

reusing existing skid trails, only operating during dry weather or frozen soil conditions, minimizing the sizes 

of landings, and rehabilitating sections of skid trails and landings. Mechanical harvesting operations only 

increase compaction by two to four percent due to better operations, equipment, and soil resource protection 

measures as shown by the Shasta-Trinity Monitoring. With the decompaction of units currently above 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 219

threshold, and the protection measures in place (SOPs for wet weather and following BMPs for soil 

protection) the entire project area is expected to meet the soil porosity standard of at least 90% of the natural 

porosity for the soil over at least 85% of the treatment unit. 

(Soil effects specific to machine piling and temporary roads are discussed below in Effects Relative to Key 

Issues.)

Soil Erosion and Displacement

Units 6, 12, 13, 14, 16, 18, 110, and 208 are ponderosa pine plantations with vary degrees of windrowing or 

furrowing. Windrows will be redistributed in units 6 and 14 to increase soil productivity. Areas where 

windrow spacing was less 60 feet (6, 12, 13, 14, 16, 110, and 208) tree height were less affected and DBH of 

trees showed little difference between interbay versus windrow trees.

Windrow respreading method has been used in several locations on the Shasta Trinity National Forest and the 

nearby Black Mountain Experimental Forest near the Elk Vegetation Management Project Area and has been 

found to be effective in restoring soil productivity.

Slopes in within the Elk project are gently sloping and with proposed treatments the likelihood of erosion 

occurring due to slopes are very low. The EHR post-implementation remains low. The WEPP model predicts 

soil losses of approximately 0.23 tons/acre. A No Action proposed treatment predicts a soil loss of 

approximately 0.12 tons/acre.

Soil Resiliency

Harvest and fuel operations that remove excessive biomass and site organic matter can affect nutrient cycling 

(see Table 65. Soil Resiliency Index Rating). Nutrients are lost during harvesting by removing the stored 

nutrients in trees, and additional nutrients are lost if the litter layer, duff, and woody debris is removed. 

Whole-tree harvesting, as compared to conventional sawlog or thinning operations, extracts large amounts of 

biomass and nutrients, especially nutrient-rich foliage, from the site (see Table 65. Soil Resiliency Index 

Rating). The exact amount of nutrients lost from a particular site varies with forest types and particular site 

conditions (Grier, et al., 1989). The amount of nutrients present in the trees also varies with stand age and 

development of the humus layer (Grier, et al., 1989).

Data suggest that nutrient losses from whole-tree harvesting are greater when compared to conventional 

sawlog harvesting for all nutrients. Calcium losses are particularly large for whole-tree harvesting due to the 

high concentrations of calcium present in the wood fiber of twigs, branches, and boles (Adams, 1998) (Mann, 

et al., 1988). There is a general agreement of researchers that multiple bole only harvests would not deplete 

the soil of nutrients; however, multiple whole tree or biomass harvests have the potential to remove nutrients 

at a rate that has a high probability of leading to soil productivity decline within a few tree rotations (Wells, et 

al., 1979). The reduction in site nitrogen, phosphorous, potassium and calcium combined with short rotations 

(50-60 years) has a high probability of resulting in a measurable decline in site productivity (Miller, et al., 

1989). Using longer rotations (such as 100 to 150 years) and less site biomass removed, such as thinning

biomass prescriptions, the negative effects would be less.” Biomass thin “would remove approximately 2.9% 

of the sites nitrogen compared to 8.8% removed from a total biomass harvest (Miller, et al., 1989).

Indirect effects of soil nutrient loss on timber include reduced growth, yield, increased susceptibility to 

pathogens, such as root disease (Garrison, et al., 1998) (Garrison-Johnston, 2003)and insect infestation 

(Garrison-Johnston, 2003) (Garrison-Johnston, et al., 2004). Precipitation (Stark, 1979) and weathering of 

rocks would continue to make additional nutrients available on site, along with annual needle, leaf, and twig 

fall, forbs, and shrub mortality would continue to recycle nutrients as well in most units. 

Since the majority of treatments are thinning, nutrient recruitment by litter-fall would mitigate most nutrient 

losses.
Elk Flat LSR Enhancement Project

220 Shasta-Trinity National Forest

Effects relative to key issues

Soil Quality Standards

As noted above, operating when soils are dry or within the wet weather operations guidelines (see p. D-1),

along with keeping piles free of soil and operating on residual slash will minimize impacts. As described 

above individually for organic matter, compaction, erosion and displacement, and resiliency, soil quality 

standards would be met on the entire project area. The units that are current over thresholds for SQS will have 

resource protection measures that will be followed in the Resource Protection Measure. In units currently over 

thresholds for porosity, skid trails 200 feet out from landings would be subsoiled; porosity should increase, 

improving soil productivity with progress towards meeting SQS (see RPM 14, p. 84). These resource 

protection measures will at a minimum sustain legacy levels and alleviate pre-existing conditions.

Machine Piling

Machine-piling slash in units when soils are dry (or frozen), following the wet weather operations guide 

(Appendix C SOPs), would not likely increase soil compaction in the meadow enhancement unit, but there is 

a risk of displacement. Machine piling may increase compaction to the extent described above under 

Compaction. Planned slash retention (5 to 35 tons/acre) would be in addition to duff and smaller surface 

organics that would remain in the unit.

Machine piling earned a reputation as a harmful practice on soils in the past, from the era where machine 

piling almost exclusively referred to site preparation for planting after a clearcut, and often occurring on 

moderately steep slopes.89 Impacts from tractor piling can be high if done improperly; it is estimated to add 2 

percent detrimental soil disturbance as displacement to the activity units (Young, 2009). However, slash piling 

as practiced in the past no longer occurs on National Forest lands since the mid-1990s. Mechanical operations 

are limited to slopes less than 35%. Much smaller tractors equipped with a brush rake on the blade are used, 

which result is little to no topsoil displacement or compaction that would be of any detrimental degree.90 Piles 

are to be “clean” (without soil), which helps them burn properly. Tractor piling often takes place in thinned 

stands, so there is much less slash generated when compared to regenerated stands. Combined with whole tree 

yarding, the overall results are much less slash material being moved into piles, and much less equipment 

traffic on the soils compared to past practices.

Forest monitoring found machine pile and burning overall effects on the soil were minimal due to clean piles 

that lacked displaced soil (Rust, 2013b). Fall burning consumed most of the slash, and had minimal loss of 

soil organic matter and topsoil. Soil heating was 2 to 4 inches deep had high levels of soil organic matter, 

roots, low to moderate levels of compaction. The areal extent of tractor piling is limited to slash 

concentrations in much if not most of the areas that include machine piling. Some soil displacement may 

occur associated with equipment operations but this should be limited in extent due to flat topography and the 

spatially patchy distribution of activity generated slash. Slash (LWD) and litter/duff remaining on site will

provide for soil cover, erosion control, and provides a source of nutrient supply over time. If done properly, 

machine piling is expected to meet soil quality standards.

 89 Heavy slash accumulations were “straight-bladed” into piles, often also piling large amounts of topsoil into the piles 

(sometimes purposely, to reduce re-growth of sprouting species as competition for planted trees). This practice was 

eventually widely recognized as harmful to soil productivity, and one of a few practices that directly led to topsoil 

displacement standards incorporated in national and regional soil management direction from 1991 to 1995. 

90 The Forest has a long track record of working directly with equipment operators to achieve minimal soil displacement or 

other soil impacts historically associated with this practice.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 221

Temporary Road and Landing Actions

All developed roads (residence access, recreation, and vegetation management) built in the past have a lasting 

effect on soil productivity due to compaction and displacement however, FTS roads are not part of the soil 

resource.

Decommissioning approximately 6.4 miles of existing routes after use as temporary roads would improve 

previously impacted road beds. Although rehabilitation through decompaction and/or recontouring cannot 

restore the roadbed to natural conditions, rehabilitation efforts initiate a long-term recovery process. 

Anticipated results would include improvements in hydrologic function.

The estimated construction and use of 2.9 miles of new temporary roads and landings will have a short-term 

impact to the soil resource. The creation of the temporary roads and landing will slow infiltration rates and 

could slow water flow patterns.

Proposed road maintenance of 17.9 miles includes culvert installation, blading, and brushing; with improved 

drainage and decreases erosion from water channeling down the road surface. For detailed information on 

roads, please see the transportation section (starting p. 225. While roads are not part of the soil resource, in the 

short-term, road reconstruction may have a slight impact to soils, with increased sedimentation, displacement 

of soil, or decreases infiltration. However, in the long-term road reconstruction will improve drainage, 

decrease soil erosion, and improve water flow.

Cumulative Effects – Alternative 1

Silvicultural treatments in unit 401 from the Pilgrim Vegetation Management Project, combined with Elk 

project underburning could have cumulative effects on soil productivity. Some nutrient recruitment by litterfall would address nutrient losses. Detrimental soil disturbances from underburning is estimated to add an 

additional one percent (Rust, 2013c), which will still be within the soil quality standards, therefore the 

cumulative effect will not result in detrimental soil disturbance.

The active Bartle allotment overlaps with the Elk Project. Impacts of grazing to soil are limited to areas where 

the animals bed, lounge, trail, or access water. These areas are generally small in areal extent. Impacts include 

compaction, removal of groundcover, and displacement. Grazing will continue in the foreseeable future on 

these allotments. Generally, these small compacted areas are limited to the grassland portions of the project.

Alternative 2 – No New Temporary Road Construction Other Than Required for 

Landing Access

Direct and Indirect Effects – Alternative 2

Under Alternative 2, there will be no temporary roads (other than to access landings) and therefore, slightly 

less thinning activities (103 fewer unit acres) implemented to accomplish project goals in comparison to 

Alternative 1. There would be a slight decrease in acreage of disturbance versus alternative 1 due to less 

temporary roads (1.3 fewer miles) and landings (8 fewer landings of which none are new landings) and a 

slight decrease in thinning of natural stands and plantations, and approximately 58 fewer acres of potential 

machine piling.

No new adverse effects above Alternative 1 would likely result from this action Soil productivity and 

hydrologic function would be maintained by incorporating soil protection measures.

Under this alternative, soil cover standards would likely continue to be met along with coarse woody debris 

levels. As a result, EHR would likely remain low and soil nutrient cycles would be maintained. The predicted 

WEPP would be 0.20 tons/acre
Elk Flat LSR Enhancement Project

222 Shasta-Trinity National Forest

Effects relative to key issues

This alternative would machine pile and burn an estimated 900 acres, and tree mortality pending, up to about 

1,384 acres. New temporary road construction would drop from 2.9 miles in Alternative 1 to 1.6 miles in 

Alternative 3. Effects would be similar to Alternative 1, except on fewer acres.

Cumulative Effects – Alternative 2

Cumulative effects will be similar to Alternative 1 and because of the lack of adverse effects; the forest is 

likely to continue meeting the Forest Plan soil quality standards. By meeting soil quality standards, it is 

expected that desired conditions pertaining to the soil resource would be achieved.

Alternative 3 - No Treatments of Natural Stands within Designated Critical Habitat 

for the Northern Spotted Owl

Direct and Indirect Effects – Alternative 3

Under Alternative 3, there will be no treatment in Critical Habitat for NSO (with the exception of the 

thinning/other mechanical treatments in plantation units 7, 12, 13, 14, 208, part of 15, and part of 6). 

Therefore, there will be fewer acres of silvicultural treatment (270 fewer acres) implemented to accomplish 

project goals. There would be a decrease in acreage of disturbance in comparison to alternative 1 due to 

decrease in thinning of natural stands and fewer landings.

No new adverse effects above Alternative 1 would likely result from this action. Soil productivity and 

hydrologic function would be maintained by incorporating soil protection measures.

Under this alternative, soil cover standards would likely continue to be met along with coarse woody debris 

levels. As a result, erosion hazards would remain low and soil nutrient cycles would be maintained.

Effects relative to key issues

This alternative would machine pile and burn an estimated 879 acres, and tree mortality pending, up to about 

1,363 acres. New temporary road construction would decrease from 2.9 miles in Alternative 1 to 1.5 miles in 

Alternative 3. Effects would be similar to Alternative 1, except on fewer acres (and fewer acres than 

Alternative 2).

Cumulative Effects – Alternative 3

The treatment for unit 401 is the same as Alternative 1. Because of the lack of adverse effects, the forest is 

likely to continue meeting the Forest Plan soil quality standards. By meeting the soil quality standards, it is 

expected that desired conditions pertaining to the soil resource would be achieved.

Alternative 4 - No Action

Under No Action, the proposed management activities would not be implemented. No direct, indirect, or 

cumulative effects are expected. Although there would be no actions undertaken with this alternative, ongoing 

trends would continue.

Under the no-action alternative, no silvicultural or fuel reduction treatments would be implemented. There 

would be no new disturbance resulting from forest management activities, and existing disturbance would 

persist. No new addition of detrimental compaction would occur and old skid trails would continue to recover 

at natural rates. Freeze-thaw processes, weathering, and soil biota would work slowly to break up compaction 

over time and vegetation would continue to re-establish on the existing infrastructure of trails. No new 

adverse effects would likely result from this action but in some locations, productivity potential in the short 

term may not be as high under this alternative as compared to the action alternatives because historic 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 223

disturbance would not be alleviated. Hydrologic function, such as soil drainage, would be maintained at 

existing rates.

Under the no-action alternative, the forest canopy would not be altered and organic material covering the soil 

would not be disturbed by management. Soil cover standards would likely continue to be met and the 

litter/duff layer would likely continue to thicken and increase in continuity. Coarse woody debris levels would 

also likely continue to increase. As a result, erosion hazards would likely remain low and soil nutrient cycles 

would be maintained.

The probability of a high-severity fire within the project area during a given timeframe is unpredictable. 

However, when a fire breaks out, the chances for high-severity fire effects on soils can be much higher in 

untreated areas with excessively heavy fuel loads compared to those that have been treated, including postharvest logging slash (Certini, 2005), (Cram, et al., 2006), (Gorman, 2003), (Keane, et al., 2002).

A high-intensity wildfire would increase the potential for impacts to soils and soil productivity in severely 

burned areas, especially since the risk of soil erosion increases proportionally with fire intensity (Megahan, 

1990). Other effects would include the potential loss of organics, loss of nutrients, and reduced water 

infiltration (Wells et al. 1979). Fires that create very high soil surface temperatures, particularly when soil 

moisture content is low, almost completely destroy soil microbial populations, woody debris, and the 

protective duff and litter layer over mineral soil (Hungerford, et al., 1991; Neary, et al., 2005). Nutrients 

stored in the organic layer (such as potassium and nitrogen) can also be lost or reduced through volatilization 

and as fly ash (DeBano, 1991; Amaranthus, et al., 1989).

Cumulative Effects

Since there are no direct or indirect effects with No Action Alternative 4 would result in no cumulative 

effects. Because of the lack of adverse effects, the forest is likely to continue meeting, or making progress 

toward Forest Plan soil quality standards. Not treating the project area could result in unknown effects on soil 

productivity in the event of a wildfire.

Summary and Conclusions

Table 66 displays the differences among the alternatives in relation to soil productivity. Alternative 3 would 

have the least impacts on soils followed by alternatives 1 and 2. All action alternatives will meet soil quality 

standards in the Forest Plan.

Table 66. Comparison of Alternatives for Soil Productivity

Indicator Alt 1

(proposed)

Alt 2

(no new rds.)

Alt 3

(no treat. NSO

CHU)

Alt 4

(no action)

Soil Productivity

Erosion Hazard Rating Low Low Low Low

WEPP(tons/acre) Soil Loss 0.23 0.20 0.18 0.12

Soil cover -litter & duff (%) 60 65 75 100

Resiliency

Litter Fall 

Mitigates 

Losses on 

Thinning Acres

Litter Fall 

Mitigates 

Losses. 

Thinning on 

103 Fewer 

Acres

Litter Fall 

Mitigates 

Losses. 

Thinning on 270 

Fewer Acres

N/A

LWD (logs/acre)

(minimum, however RPMs may require more in 

specific locations)

5-10 5-10 5-15 >15
Elk Flat LSR Enhancement Project

224 Shasta-Trinity National Forest

Indicator Alt 1

(proposed)

Alt 2

(no new rds.)

Alt 3

(no treat. NSO

CHU)

Alt 4

(no action)

Compaction-Porosity

(% of undisturbed)

Meets 90% 

Standard

Meets 90% 

Standard

Meets 90% 

Standard

4 Units do 

Not meet

Key Issue

Meets Soil Quality Standards

(Forest Plan Appdx. O)

All Units Meet 

90% Porosity 

Standard

All Units Meet 

90% Porosity 

Standard

All Units Meet 

90% Porosity 

Standard

4 units do 

not meet 

standard

Machine Piling (acres) Up to 1,461 Up to 1,402 Up to 1,365 0

New Temporary Road Construction (miles) 2.9 1.6 1.5 0

Purpose and Need for Action

Decommissioned Existing UA Routes (miles) 6.4 6.4 6.4 0

Windrow Respreading 2 units 2 units 2 units 0 units

Surface Organic Matter

Retention of soil cover (litter and duff) is higher with Alternatives 2 and 3 over Alternative 1 due to less 

harvesting, or no underburning in the case of some units under Alternative 3. With less harvest for 

Alternatives 2 and 3, less soil displacement would occur.

Overall, the intensity of harvesting and fuel reduction activities for most units will minimize any adverse 

effects on soil cover or nutrient cycling. Some units will be near soil quality standard thresholds and will 

require the use of the resource protections to keep them below thresholds. The use of existing skid trails and 

landings minimizes areal effects in addition to these previously disturbed acres. As a result, cover and organic 

matter standards would be met. Soil protection standard operating procedures and RPMs and natural 

processes will also address current shortfalls in coarse woody debris in some plantations through development 

of increased large woody debris recruitment into the future through accelerated development.

Compaction-Soil Porosity

Reusing old skid trails, logging on dry soils or frozen soils in the meadow enhancement treatment unit, or 

elsewhere in compliance with the wet weather operations guide in remaining units, will serve the project goals 

of avoiding new detrimental disturbance and adverse cumulative effects. Decommissioning would focus on 

major skid trails and landings, especially in units with high amounts of old harvest routes that have resulted in 

relatively high levels of compaction. Less-traveled trails would be excluded since they are not expected to 

have detrimental levels of compaction. Where compaction is above porosity standards, sub-soiling will 

effectively relieve most of the compaction. Recommended sub-soiling would be 18 inches deep and only 

occur on high traffic skid trails and on landings in units that are over soil quality standard thresholds. Where 

skid trails would be sub-soiled there should be an adequate overstory that would encourage trees to seed in 

post-harvest. Where only low to moderate compaction exists, leaving soils intact is more desirable. The net 

effect is that the proposed management alternatives will not introduce any meaningful degree of new 

compaction such that soil productivity would not be significantly reduced under any action alternative.

Soil Erosion and Displacement

Erosion modeling (WEPP and EHR methods) for all alternatives show low levels of erosion due to flat 

landscapes and more than adequate soil cover remaining after treatment. Current levels of soil disturbance for 

the Elk project on the average across all units is 15% (topsoil displacement or skid-trails) with 6% decrease in 

soil porosity (less than 10% detrimental compaction threshold). Anticipated increase in soil disturbance due to 

mechanical thinning is 10% with an additional 3% decrease in soil porosity.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 225

Alternative 4 (no treatment) would keep erosion low with, no new compaction or soil disturbance, but canopy 

cover levels would increase to unhealthy levels that pose fire risks and increased outbreaks of diseases and 

insects. In the event of a high intensity wildfire under these conditions, soils would be more likely to be 

severely impacted than under the action alternatives.

Soil Resiliency

This area has a high level of productivity and recovery potential if soils are left intact. Soil resiliency index 

(Table 65 and (Rust, et al., 2015 p. App. B)) shows that Germany soils have a high resiliency index where 

Shasta soils have a moderately high resiliency index. These ratings show Elk project soils have the ability to 

resist degradation from disturbance. The indications are that the sites have a very high growth potential based 

on the field observations. The site potential, together with other soil indicators being met, leads to the 

conclusion that the sites have a very high resiliency to soil disturbance, and it is not expected that soil 

productivity would be adversely affected in the long-term.

Machine Piling

Anticipated increase in soil disturbance by mastication or underburning will be 1% and 2% and for machine 

pile and burning 2% to 3% (Rust, et al., 2015 p. App. C). Units that are over soil quality standard thresholds 

will be mitigated by subsoiling, windrow respreading, or woody debris retention. Alternative 3 has less 

thinning units (270 acres), less machine piling, less underburning, and less mastication versus Alternative 1. 

Alternative 2 also has slightly less thinning units, less machine piling, and less mastication than Alternative 1.

Effects relative to Purpose and Need for Action

By implementing the soil resource protection measures in chapter 2, and following standard operating 

procedures described in Appendix C, all action alternatives in the Elk the project will meet or exceed the 

Forest Plan soil quality standards, maintaining soil productivity in support of healthy forests. In particular, soil 

productivity will be restored in the previously windrowed units that would be respreads, accelerating 

development of late-successional characteristics to help meet Purpose and Need #2 in those units.

Unauthorized routes (6.4 miles) will be decommissioned allowing soil decompaction and return to a natural 

condition.

Compliance with law, regulation and policy 

There will be less than 15 percent of any unit in a non-productive state, adequate cover shall minimize 

erosion, added slash and maintenance of the duff layer shall maintain soil biological process, soil fertility, and 

ultimately soil productivity. Impacts to soil productivity will stay below thresholds and will therefore meet 

provisions in the National Forest Management Act. Soil and slope will not be irreversibly damaged.

Transportation

Introduction

A transportation report (Bonivert, 2015) and a project travel analysis process (TAP) (Bonivert, 2015a) were 

completed for this project and are incorporated by reference. Portions of the road analysis process completed 

for the Pilgrim project overlap the Elk project area and that document is incorporated as well (Huhtala, 2005). 

Information relevant to this decision is summarized here.

In addition to effects on the FTS, this analysis incorporates transportation-related features that are not part of 

the FTS including the use of unauthorized routes as temporary roads and newly constructed temporary roads 

and landings. Chapter 1 introduces the existing and desired condition relating to transportation. Appendix A, 

starting on page B-39, describes site specific road actions including actions pertaining to the unauthorized 

routes and newly constructed temporary roads. Table Appendix B-5 provides road actions by alternative and 
Elk Flat LSR Enhancement Project

226 Shasta-Trinity National Forest

road number and Table Appendix B-6 provides estimated temporary road needs by treatment unit. Chapter 2 

provides summaries by Alternative (see Table 10, Table 15, and Table 20 for Alternatives 1, 2, and 3) and in 

comparison form (see Table 25, p. 80).

Purpose and Need Applicable to Transportation

Purpose and Need #6, National Forest Transportation System (FTS) Management and Decommissioning of 

Unauthorized Routes pertains to transportation. A need exists to increase FTS efficiency and provide access to 

a dispersed recreation area in Elk Flat. The Transportation Analysis Process (TAP) completed for the project 

recommends an approximately 0.10 miles of existing unauthorized route that is currently utilized as public 

access to a dispersed recreation area in Elk Flat should be added to the FTS as an open level 2 road to provide 

legal motorized access (Bonivert, 2015a). A need exists to remove several unauthorized routes in the project 

area from the landscape for restoration to a more natural condition.

Issues Applicable to Transportation

Issue #2, expressing the concern that road construction directly harms forest health and wildlife and results in 

long-term impacts to soil health and productivity, pertains to transportation. This issue applies to the 

Temporary roads that will be constructed to access landings, since no new FTS roads are proposed to be 

constructed for the project.

Methodology

Effects to the transportation system are determined by the existing conditions, the occurrence of past travel

management activities, the proposed actions and transportation specific assumptions. Effects to individual 

roads, the transportation system in the project area and to a limited extent the Forest transportation system are 

considered. Effects to individual roadways can vary depending on the maintenance level, site conditions, 

traffic volumes, weather and extraordinary events. Field verification is conducted to review the effects of

comparable recent and past travel management activities to the activities of the proposed action.

Transportation Specific Assumptions

1. The roads used for the project will be maintained with the project. Road maintenance consists of 

grading, resurfacing, culvert cleaning, hazard tree removal, snow plowing, clearing roadside brush 

and slide removal.

2. Traffic volumes in the assessment area will largely remain the same, increase or decrease slightly to 

meet resource demands.

3. Roads scheduled for maintenance level 1 will be closed to vehicular traffic.

4. State law regulating motor vehicle drivers sets the standard of care for the safety of themselves and 

other users of the FTS.

5. Roads not shown on the Forest Motor Vehicle Use Map (MVUM) are closed to vehicular access 

regardless of field conditions.

Information Sources

The information used for this analysis was collected from 36 CFR 212, 36 CFR 220, FSM 7700, the Forest 

Plan, site reconnaissance, relevant roads analyses, and consultation with other resource specialists. All 

distance figures are approximate values based on the Forest Transportation atlas and INFRA database and are 

limited to the accuracy of those sources, which includes measurements from GIS, GPS, field instruments and 

aerial photography. Mileages have been updated throughout the planning process as better information has 

been made available and may change slightly with additional field verification and project implementation.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 227

Incomplete and Unavailable Information

Road maintenance beyond project implementation is dependent on Forest funding and may not occur every 

year, however it is assumed that it will be conducted to a level and interval that a minimum will allow the 

continued use of roads designated to be open. Unauthorized route use, the occurrence of cross country travel 

and the purposes of these activities can only be speculated considering the evidence of a motorized vehicle 

and known uses of areas, based on season and specialist experience. Landing locations and temporary road 

alignments are determined by the implementation contractor with approval by the Forest Service, the 

approximate locations used for analysis were determined by the location of past landing locations, specialist 

consultation and specialist experience.

Indicators and Measures

Table 67summarizes the indicators and measures used to analyze and disclose effects to the Forest 

Transportation System (FTS), UA routes, temporary roads, as they pertain to the transportation system, the 

relevant key issue, and the Purpose and Need for Action A discussion follows the table providing rationale for 

each indicator and measure.

Table 67. Transportation Resource Indicators and Measures for Assessing Effects

Resource 

Element Indicator Measure P&N, Key Issue, or 

Resource Effect Source

Public Safety Road Conditions

Miles of roads maintained to 

standard, or reconstructed to 

standard

Resource 

Forest Plan

(p.4.4) Miles of UA routes 

decommissioned

Resource, Key Issue #2 

“c”

General 

Accessibility

Open FTS Road 

Density

FTS open road density changes 

(mi./sq. mi.) P&N #6 Forest Plan

(p.4.16)

FTS Efficiency Changes to FTS

Total road density changes

(mi./sq. mi.), 

Resource, Key Issue #2 

indicator “b” Forest Plan

Changes to road MTC levels Resource (p.4.16)

Changes to maintenance costs Resource

Public Issue

New Temporary 

Road 

Construction

Miles of new temporary road 

construction Key Issue #2 indicator “a” N/A

Discussion of Indicators and Measures

Public Safety - Road Conditions

Miles of Maintained Road and Miles of Reconstructed Road

Road maintenance, reconstruction and closures may improve road user conditions and safety in the project 

area. Reconstruction will improve roads to current design and safety standards. Road maintenance will ensure 

roads stay in appropriately safe conditions. Closure is part of the maintenance regime for ML-1 roads. Closed 

roads are not maintained at a level suitable for safe motor vehicle travel. Open roads increase accessibility for 

emergency response and may decrease response times.

Miles of Unauthorized Routes

Unauthorized routes are existing roads on the forest that are not open to vehicular traffic or managed as part 

of the FTS. Prohibition of motorized travel of unauthorized routes and cross-country travel has been 

established by Federal Regulation under the Forest’s Motorized Travel Management (MTM) Record of 

Decision (ROD) (USDA-FS, 2010a).Unauthorized routes are not designated for vehicle travel on the MVUM
Elk Flat LSR Enhancement Project

228 Shasta-Trinity National Forest

but may appear to be an open road. Without a barrier, these routes can be used unintentionally by uninformed 

drivers. Unauthorized routes added to the system will be improved and/or maintained to FTS standards 

designed to address safety concerns. Decommissioning unauthorized routes protects other resources and 

prevents vehicles from leaving designated open roads and improves user conditions and safety in the project 

area.

General Accessibility - Changes to Open FTS Road Density

Changes to the FTS may increase or decrease the amount of NFS land readily accessible by motorized 

vehicle. Road access facilitates all activities on the forest to some degree, including roaded recreation, OHV

use, dispersed camping, hiking, hunting, and fuel wood collection. These activities may be enhanced or 

reduced depending on the changes to the open road density.

Open road density only includes FTS roads that are open to vehicle use as designated on the Forest Motor 

Vehicle Use Map (MVUM). There is no standard threshold for acceptable road density on the Forest, but a 

road density of two to four miles per square mile is generally considered acceptable, with a preference for 

lower road densities in LSR.

FTS Efficiency – Changes to FTS

Changes to the FTS may increase or decrease the amount of NFS land readily accessible for management 

activities on the Forest. Road additions may increase management capabilities and maintenance costs.

Total FTS Road Density Changes (miles per square mile)

Total road density is a general measure of open and closed roads in the project area that are available for 

future management activities. Future management activities may be more or less feasible depending upon 

road access.

Changes to Road Maintenance Levels

Maintenance levels can indicate an approximate average cost of maintenance per mile in order to determine if 

future management costs may be higher or lower with changes to the FTS. Roads closures are typically 

included in a project for resource protection, cost-efficiency and to reduce open road density. Closed roads are 

considered to be in intermittent service, with lower annual maintenance costs, to be made available for 

resource management as needed and closed again. Public The Travel Management regulations at 36 CFR 

212.54 provide for revision of designations as needed to meet changing conditions, including the potential to 

add new routes.

FTS Efficiency – Temporary Road Construction, Landings and Skid Trails

The use of temporary roads facilitates management access in place of permanent system roads where off road 

management access methods, such as log skidding, are limited. Temporary roads provide access to landings 

and allow the landings to be farther from the FTS road to meet .25-mile log skidding limitations. Landings are 

better suited away from the FTS roads and allow roads to remain open to the public during implementation. 

Skidding logs farther than .25 miles can create a skid trail that is more damaging than a temporary road and 

the farther a landing is from a FTS road, the more beneficial it is to have a temporary road. When comparing 

the effects of skidding logs along the ground to conveying logs on a rubber tired log truck along a temporary 

road, the use of a temporary road is preferred and required to meet Best Management Practices (listed starting 

on p. D-4). Another consideration is that one log truck can carry the equivalent of several skidding trips, 

reducing trips required for removal.

Key Issue Indicators
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 229

Key Issue #2 indicator “b” is addressed above in total road density, and “c” is addressed in unauthorized 

routes decommissioned.

Miles of New Temporary Road Construction

Temporary roads connect harvest areas and FTS roads to landings. Unauthorized routes are utilized when 

available and can be used to protect resources. Key Issue #2 indicator “a” - miles of new temporary road 

construction, compares alternatives in response to the Key Issue expressing concern for road construction. 

(The project does not propose new FTS road construction).

Boundaries

To determine relevant past, present, and foreseeable future projects, spatial and temporal boundaries must be 

defined (CFR § 220.4 (f)). For the effects analysis the direct and indirect effects of the Elk project relative to 

transportation are conditions influencing road conditions and management designation.

Spatial Bounding

Spatially, the conditions influencing roads and management designation (e.g. user accessibility, drainage 

functionality, road density) in the project affects the transportation system. As such, the spatial context being 

considered is the project boundary. This is because this represents the approximate area potentially influenced 

by effects from the proposed road actions and treatment activities.

Temporal Bounding

The temporal context being considered is activities five years into the future; five years is approximately how 

long it is expected that the project activities and related traffic would affect road conditions and how long 

proposed project related treatments would affect temporary road use.

The baseline year used for this analysis is 2014 for the existing condition. In this analysis, the description of 

the existing condition includes the accumulation of past activities, which have influenced road conditions and 

unauthorized routes. The current environmental conditions reflect the aggregate impact of all prior human 

actions and natural events that have affected the environment and might contribute to cumulative effects and 

are a proxy for the impacts of past actions.91 Cumulative effects are discussed as changes in the existing 

condition due to present and future activities, including the effects of the alternative being discussed.

Affected Environment

Existing Condition

The project area has a long history of timber management, including the site of a historic mill. Evidence of 

past management activities include FTS Roads and unauthorized routes. Unauthorized routes are existing 

roads on the forest that are not open to vehicular traffic or managed as part of the FTS. The existing FTS 

provides access to old landing locations, plantations and adjacent private inholdings.

The FTS roads include approximately 4 miles of arterial roads and 11 miles of local roads that that receive 

regular traffic and use. The FTS was developed over time to meet a variety of needs in the area including 

timber management, fuel treatment, access to private inholdings, fire control, utility management, special uses 

management, special forest products collection and recreation. Approximately eight miles of road in the 

project area are under cost share agreements. The Pilgrim Creek Road (FA13) and the Military Pass Road 

 91 This approach is consistent with CFR § 220.4 (f) and the Council on Environmental Quality June 24, 2005 

memorandum regarding analysis of past actions.
Elk Flat LSR Enhancement Project

230 Shasta-Trinity National Forest

(FA19) provide the main access to and beyond the project area. Table 68 displays the existing FTS road 

system by maintenance level and functional class.

Table 68. Existing FTS Roads by Maintenance Level and Functional Class

Maintenance Level Existing Miles of 

FTS Road Functional Class

Level 1 - Intermittent service roads closed to vehicular traffic but open for 

non-motorized uses. Basic custodial maintenance is performed to keep 

damage to adjacent resources to an acceptable level and to facilitate 

future management activities. While being maintained at level 1, roads 

are closed to vehicular traffic.

3.69 Local (Closed)

Level 2 - Open for use by high-clearance vehicles. 10.63 Local (Open)

Level 3 - Open and maintained for travel by a prudent driver in a 

standard passenger car. Some roads may be fully surfaced with either 

native or processed material.

2.34 Arterial

Level 4 - Provide a moderate degree of user comfort and convenience at 

moderate travel speeds. Most are double lane and aggregate surfaced, 

some paved or dust abated.

1.98 Arterial

Total 18.64

Public Safety - Road Conditions

Miles of Maintained Road

Road conditions in the project area are generally good with some isolated deteriorating areas and naturally 

blocked segments. Past road maintenance activities in the project area have included project specific 

maintenance activities, utility access, and commercial use maintenance. Higher road maintenance levels 

(maintenance level-3 and -4) are in better condition, and require less annual maintenance, attributable to a 

more durable road surfacing, such as asphalt or rock. Maintenance Level-2 roads can vary widely in condition 

and surfacing and are intended only for high clearance vehicles. Typically, open FTS roads can be considered 

to be in useable condition and safe for the intended use by a prudent driver. Roads that pass through the 

Extensive Mortality Areas are considered unsafe to drive through although fallen trees on the roadway are 

likely to discourage most users.

Miles of Unauthorized Routes

There are approximately 6.5 miles of unauthorized routes in the project area. Most of these routes appear to 

have been created for management access at some point in the past or user created. Most of the unauthorized 

routes are near a suitable condition for project use as a temporary road.

General Accessibility – Open FTS Road Density

The project area contains approximately 15 miles of open FTS roads with an approximate open road density 

of 2.72 miles per square mile.

FTS Efficiency - Total FTS Road Density

The project area contains approximately 18.64 total miles of FTS roads with an approximate total road 

density of 3.39 miles per square mile. 

FTS Road Maintenance Levels

Refer to the table below for current miles of roads by maintenance level.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 231

Temporary roads, Landings and Skid Trails

Existing unauthorized routes may be used as temporary roads. Landings are not a part of the FTS, but are 

features needed to transfer harvested materials for hauling. Currently the project area has approximately 67 

landing locations evident from past activities. Some of these would be available for use under the action 

alternatives; however, not all would be considered useable due to resource concerns or location. Size of 

landings varies typically between 1⁄4 and 3⁄4 acres. Skid trails are not part of the FTS but where a landing 

location is reused it is likely past skid trail locations may be discernable and reused.

Key Issue Indicators

Key Issue #2 indicator “b” is addressed in total road density in FTS efficiency above. Indicator “c” is 

addressed in Public Safety UA routes above.

Environmental Consequences

Alternative 1- Modified Proposed Action

Direct Effects 

Public Safety - Road Conditions

Miles of Maintained Road and Miles of Reconstructed Road

Project generated road maintenance will improve road conditions and roads used for the project should be in 

optimal condition for their intended maintenance level. With approximately 18 miles of roads maintained over 

the life of the project and 0.27 miles of reconstruction road conditions would be improved compared to the 

existing condition.

Miles of Unauthorized Routes

Unauthorized routes, while previously closed via the MVUM only, would now be signed and/or physically 

blocked, providing an engineered solution to prevent unauthorized and unintentional access. Additionally, 

field conditions would more accurately reflect the MVUM, increasing MVUM reliability for navigation. 

Miles of inventoried UA routes in the project area would drop from 6.5 to 0.

General Accessibility - Changes to Open FTS Road Density

Open road density in the project area will increase slightly, from 2.72 to 2.74 miles per square mile, with the 

addition of 0.10 miles of road to the FTS within the Matrix allocation. A slight increase in road density 

reflects an increase in general accessibility. Open road density in the LSR would remain the same. 

Maintenance Level-1 roads needed for the project are currently closed. All 2.86 miles of currently closed ML1 roads would be opened for the project, and then closed again at completion resulting in no additional closed 

FTS roads.

FTS Efficiency – Changes to FTS

Total FTS Road Density Changes (miles per square mimle)

Total road density would increase, from 3.39 miles per square mile to 3.41 miles per square mile, due to the 

addition of 0.10 miles of road to the FTS in the matrix allocation. The density in LSR would remain the same. 

Changes to Road Maintenance Levels

Maintenance Level 2 road mileage will increase from 10.63 to 10.73 miles in the project area. The change is 

from the addition of the 0.10-mile segment at Elk Flat in the matrix allocation. No other FTS roads change 
Elk Flat LSR Enhancement Project

232 Shasta-Trinity National Forest

maintenance level. Cost efficiency will generally remain the same or increase insignificantly given the short 

distance of the road addition.

Temporary Roads,Landings and Skid Trails 

Alternative 1 requires an estimated 2.9 miles of new temporary road construction. Temporary roads would be 

decommissioned at the close of the project and would not affect the FTS. As displayed in Table 10, 

Alternative 1 makes use of approximately 38 existing landings and requires construction of approximately 40

new landings. Landings for the Elk project would be up to approximately 3⁄4-acre each. All landings would be 

decommissioned at the end of the project and do not affect the FTS.

Key Issue Indicators

Key Issue #2 indicator “a” is addressed in Temporary roads, landings and skid trails in FTS efficiency above.

Indicator “b” is addressed in total road density in FTS efficiency above Indicator “c” is addressed in Public 

Safety UA routes above.

Indirect Effects

Public Safety - Road Conditions

Road conditions can change frequently with each season, especially when considering native surfaced roads. 

Any open roads can generally be considered to be in useable condition and safe for the intended use. Roads 

maintained for the project will be in good condition and can be considered to provide better conditions for 

safe use compared to a road that has not been recently maintained. Overall, road user risk will decrease with 

improved road conditions. Beyond road conditions, state law regulating motor vehicle drivers sets the 

standard of care for the safety of themselves and other users of the FTS.

Miles of Unauthorized Routes

With approximately 6.4 miles of unauthorized routes blocked and decommissioned, unmanaged access will be 

prevented over a large portion of the project area.

General Accessibility - Changes to Open FTS Road Density

The addition of .10 miles of road will increase access slightly. This may allow a slight increase of other 

activities, such as recreational use and dispersed camping; however, this road was already used regularly as an 

unauthorized route for these recreation activities.

FTS Efficiency – Changes to FTS

Total FTS Road Density Changes (miles per square mimle)

The slight increase in total road density has the same indirect effects as the changes in open road density since 

the 0.10 mile increase is in a maintenance level 2 road.

Changes to Road Maintenance Levels

Annual maintenance costs will generally remain the same given the short distance of the road addition in 

maintenance level 2.

Temporary Roads, Landings and Skid Trails 

The new temporary road construction is unlikely to cause an indirect effect because they would be 

decommissioned and blocked at the close of the project. Landings and skid trails would have no indirect 

effect on the transportation system and are not part of the FTS.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 233

Key Issue Indicators

Key Issue #2 indicator “b” is addressed in total road density in FTS efficiency above. Indicator “c” is 

addressed in Public Safety UA routes above.

Cumulative Effects – Alternative 1

Past, Present, and Reasonably Foreseeable Activities Relevant to Cumulative Effects Analysis

The Project cumulative effects worksheet was developed by ID Team inputs. Those projects relevant to 

transportation were included in the cumulative effects analysis.

The direct and indirect effects of the proposed action when combined with past, present and reasonably 

foreseeable activities will result in a more effective and better maintained transportation system throughout 

the entire project boundary. 

Road maintenance from past project activities and cost share maintenance has resulted in many miles of roads 

that are currently in good condition. Ongoing and/or future activities that may influence transportation include 

road maintenance, hazard tree abatement, road closures and other actions associated with previously approved 

projects. Recently conducted transportation management actions in the project area include the 

implementation of 3.12 miles of road closures from the Pilgrim Vegetation and Fuels management Project, 

reducing open road density to the current condition. Approximately .22 miles of NFS roads were 

decommissioned in the project area from the Pilgrim Vegetation and Fuels management Project. Recreational 

use and transportation needs for the area may remain the same or increase slightly with population growth and 

economic conditions. Resource management use of the transportation system can be expected to continue. 

The Military Pass Road and Pilgrim Creek Road will remain an important arterial route to the Forest, the 

public and the timber industry. 

There are no other actions currently occurring or planned within the analysis area that contribute to or 

appreciably contribute to the transportation system in the project area.

The direct and indirect effects of the proposed action when combined with past, present and reasonable 

foreseeable activities will not significantly impact the Forest Transportation System.

Alternative 2- No New Temporary Road Construction Other Than Those Required 

for Landing Access

Direct, Indirect, and Cumulative Effects

Direct and Indirect effects under Alternative 2 would be the same as Alternative 1 except for those effects of

new temporary road construction and decommissioning, and landing construction. Alternative 2 would 

decrease new temporary road construction by 1.3 miles for a total of 1.6 miles of new temporary road, to 

serve as landing access from the FTS road system. Temporary roads mileages are reduced in units 402, 152-1, 

154, 18 and 163where the units were reduced. 6.4 miles of existing unauthorized routes would still be used as 

temporary roads and decommissioned at the close of the project. Nine fewer landings would be needed (eight

fewer existing and one fewer new landing) than in Alternative 1. The effects would be the same but over this 

correspondingly smaller footprint. Cumulative effects would be the same as Alternative 1.

Alternative 3 - No Treatments of Natural Stands within Designated Critical Habitat 

for the Northern Spotted Owl

Direct, Indirect and Cumulative Effects

Direct and indirect effects under Alternative 3 would be the same as Alternative 1 except for those effects of

new temporary road construction and decommissioning, landing construction, and 0.5 fewer miles of FTS
Elk Flat LSR Enhancement Project

234 Shasta-Trinity National Forest

road maintenance. Alternative 3 would decrease new temporary road construction by 1.4 miles for a total of 

1.5 miles of new temporary road, to serve as landing access from the FTS road system. All of the decrease is 

in unit 402, meadow enhancement, because the units in NSO Critical Habitat, that drop out of this alternative, 

are accessed by existing Unauthorized Route in Alternative 1, not new temporary roads. One mile of existing 

unauthorized routes would still be used as temporary roads and decommissioned at the close of the project.

Sixteen fewer landings would be needed (9 fewer existing and 7 fewer new landings) than in Alternative 1. 

The effects would be the same but over this correspondingly smaller footprint. Cumulative effects would be 

the same as Alternative 1 except the 0.5 fewer miles would decrease beneficial cumulative effects very 

slightly.

Alternative 4 - No Action

Under No Action, the proposed management activities would not be implemented. No direct, indirect, or 

cumulative effects are expected. Although there would be no actions undertaken with this alternative, ongoing 

trends would continue. The 44 landings currently in the project area would not be actively decommissioned. 

Current management and ongoing activities, as permitted under NEPA may include road maintenance, hazard 

tree felling, wood-cutting, and over-snow vehicle use associated with the Pilgrim Creek Snowmobile Park, 

dispersed recreation (e.g., sightseeing, hunting), forest products collection and other permitted special uses. 

No treatments or road actions would be implemented to accomplish the purpose and need and project resource 

objectives. Road maintenance would likely only occur as funding allowed or as needed by cost share partners.

Summary and Conclusions

Table 69 summarizes the effects by alternative and resource and key issue indicator. All action alternatives 

will include beneficial road management actions to meet purpose and need #6 and will not significantly 

impact the Forest Transportation System. All action alternatives contribute to improved road conditions. 

Alternative 1 involves the most new temporary road construction (2.9 miles compared to Alternatives 2 and 3, 

at 1.6 and 1.5 miles).

Table 69. Summary comparison of environmental effects

Resource 

Indicator/Measure

Alt 1: Modified 

Proposed Action

Alt 2: No New Temp 

Road Construction

Alt 3: No Treatment 

of Natural Stands in 

CHU

Alt 4: No Action

Public Safety – Road Conditions

Roads Maintained or 

Reconstructed to 

Standard (miles)

17.92 miles 

maintained/

0.27 miles 

reconstructed

17.92 miles 

maintained/

0.27 miles

reconstructed

17.42 miles 

maintained/

0.27 miles 

reconstructed

0 

UA Routes 

Decommissioned* 

(miles)

6.4 6.4 6.4 0

General Accessibility – Open FTS Road Density

Open FTS Road Density

(mi/ sq. mi.)

Increase from 2.72 to 

2.74 

Increase from 2.72 to 

2.74 

Increase from 2.72 to 

2.74 2.72

FTS Efficiency

Total Road Density 

Changes* (mi./sq. mi.)

Increase from

3.39 to 3.41

Increase from

3.39 to 3.41

Increase from

3.39 to 3.41 No Change

Changes to Road MLs

(miles)

Increase of ML 2 from 

10.63 to 10.73 

Increase of ML 2 from 

10.63 to 10.73

Increase of ML 2 from 

10.63 to 10.73 No Change

Changes to 

Maintenance Costs

0.10 miles added = 

slight increase

0.10 miles added = 

slight increase

0.10 miles added = 

slight increase No Change

Key Issue #2*
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 235

Resource 

Indicator/Measure

Alt 1: Modified 

Proposed Action

Alt 2: No New Temp 

Road Construction

Alt 3: No Treatment 

of Natural Stands in 

CHU

Alt 4: No Action

Miles of New Temporary 

Road Construction* 2.9 1.6 1.5 0

*Key Issue #2 indicators

Effects relative to Purpose and Need for Action

Under all action alternatives, the addition of the .10 mile road to access a dispersed recreation site near Elk 

Flat will provide motorized access for recreational use. The decommissioning of over 6 miles of unauthorized 

routes in the project area will inhibit unauthorized cross county travel and allow restoration to a more natural 

condition. All action alternatives meet Purpose and Need #6. No Action would leave the dispersed recreation 

site at Elk Flat without authorized access and leave 6.4 miles of unauthorized routes physically open. 

Effects relative to key issues

Key Issue #2 indicators relative to transportation show the following by alternative:

a. Miles of new temporary road construction –

Alternative 1 has the most at 2.9 miles, followed by Alternatives 2 and 3 at 1.6 and 1.5 miles. The 

additional 0.2 miles in Alternative 1 is all located in unit 402, meadow enhancement. Unit 402 is 

partially in LSR and partially in Matrix.

b. Total open road density post-implementation in comparison to No Action – Increases slightly in all 

alternatives due to addition of 0.1 miles in matrix area.

c. Miles of existing route decommissioning – All action alternatives decommission 6.4 miles.

No new NFS roads are proposed to be constructed for the project. Temporary roads will be decommissioned 

and will have no effect on the FTS. Decommissioning will discourage unauthorized vehicular access, and the 

temporary roads would revegetate. Alternative 1 would have 0.2 additional miles of new temporary road 

construction and decommissioning over the other action alternatives; a difference that is limited to unit 402.

Other resource effects

All three action alternatives use existing and new landings. Alternative 1 uses the most, followed by 

Alternative 3, then Alternative 2. All landings in each action alternative would be decommissioned. The no 

action alternative would leave 44 existing landings.

Compliance with law, regulation and policy (includes Forest Plan under NFMA)

The transportation report provides a summary of the legal framework pertaining to transportation. The project 

complies with all requirements and meets Forest plans forest-wide goal #8 to manage the Forests 

Transportation system and goal #9 to provide and maintain administrative facilities (p.4.4)using applicable 

standards and guidelines in the Forest plan (p.4.16).

Cultural Resources

A Cultural Resources Report (Schmidt, 2015) was completed for this project and is incorporated by reference. 

Information relevant to this decision is summarized here.

Introduction

The purpose of the cultural resources analysis is to identify historic properties potentially affected by the

proposed project, assess the effects of the project, and seek ways to avoid, minimize, or mitigate adverse 

effects. For the purpose of this analysis, the term “historic properties” includes historic properties as defined 
Elk Flat LSR Enhancement Project

236 Shasta-Trinity National Forest

in 36CFR§800.16(l) as well as areas of Native American significance that may not otherwise meet the 

definition for “historic properties.” Archaeological sites that are not eligible to the National Register of 

Historic Places (NRHP) are not included as “historic properties.”

Purpose and Need Applicable to Cultural Resources

There are no Purpose and Needs identified specific to Cultural Resources.

Issues Applicable to Cultural Resources

There are no Key Issues relative to cultural resources.

Methodology

Identification of cultural resources was completed through background research, field survey, and Tribal 

consultation. The effects of the project on cultural resources was determined through site visits, 

Determinations of Eligibility, Tribal consultation, communication with other interested individuals and 

groups, consultation with the State Historic Preservation Office (SHPO), and the development of site-specific 

resource protection measures designed to avoid adverse effects on historic properties. This analysis 

summarizes the results.

Prior to the field survey, records and references were reviewed to determine the extent and quality of previous 

archaeological surveys in the vicinity and the locations of known archaeological sites and other cultural 

resources within or adjacent to the project boundary. Lidar imagery, historic maps, and other documentation 

were reviewed to ensure cultural resources were sufficiently identified. Field survey was then conducted to 

locate additional cultural resources that may not have been previously identified. 

Once the cultural resources were identified, each site was visited to update the documentation, assess the 

current condition, and determine the resource protection measures necessary for each site. All cultural 

resources were visited to ensure documentation is updated and to complete Determinations of Eligibility to 

further refine the list of historic properties that are eligible to or unevaluated for the NRHP. 

Indicators and Measures

The following indicators were used to assess effects to historic properties:

1. Is the proposed project the type of activity that could affect historic properties, if such properties 

were present?

2. Does this project have the potential to cause adverse effects on historic properties?

3. Can adverse direct or indirect effects to historic properties be avoided or minimized through 

Resource Protection Measures?

4. Provided the Resource Protection Measures are implemented, will this project result in “no historic 

properties affected;” “no adverse effect;” or an “adverse effect” to historic properties?

Boundaries

To determine relevant past, present, and foreseeable future projects, spatial and temporal boundaries must be 

defined (CFR § 220.4 (f)). This is determined by how long, and how far reaching direct and indirect effects of 

a project are felt on a given resource area.

Spatial Bounding

The cultural resources “Area of Potential Effects” (APE) is the geographic area within which the project may 

directly or indirectly cause alterations in the character or use of historic properties, if any such properties 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 237

exist. The cultural resources APE for the Elk Flat LSR Enhancement project encompasses the locations of 

project activities including mechanical cutting and hand thinning units, landings, roads identified for 

maintenance, improvements, decommissioning, and closure, prescribed underburning and machine pile 

burning locations, hazard tree abatement areas, areas of traditional or ceremonial use by Native Americans, 

and other areas of Native American significance or concern. Historic properties adjacent to the project 

boundary are included in the APE when they could potentially be affected by nearby project activities –

including effects from noise, smoke, dust, and setting changes.

Temporal Bounding

The temporal context being considered is the duration of project activities, which is projected to occur 

until2021 for initial activities and every 5 to 10 years for two additional entries of underburning.

The baseline year used for the existing condition of this analysis is 2015. In this analysis, the description of 

the existing condition includes the accumulation of past activities that may have affected historic properties, 

The current environmental conditions reflect the aggregate impact of all prior human actions and natural 

events that have affected the environment and might contribute to cumulative effects and are a proxy for the 

impacts of past actions.92

Field Results

No previously unrecorded sites were located during the field survey. One historic site is being evaluated for 

eligibility to the National Register of Historic Places (NRHP) and all six of the historic McCloud River 

Lumber Company (MRLC) railroad grades are being assessed to determine whether they contribute to the 

integrity of the historic MRLC district. Resource protection measures are designed in consultation with, and 

during communication with Tribes and the SHPO to ensure that adverse effects to historic properties will be 

avoided.

Tribal Coordination

In accordance with 36 CFR § 800.3(f) and Section 106 of the National Historic Preservation Act, Native 

American consultation was conducted. A formal consultation letter was mailed to the Redding Rancheria on 

2/22/2013. The Redding Rancheria did not respond. A formal consultation letter was mailed to the Pit River 

Tribe on 2/22/2013. Additional consultation occurred with the Pit River Tribe at quarterly council meetings, 

field trips, and other meetings with individual practitioners and cultural representatives (4/26/2005, 

8/12/2009, 8/4/2010, 7/20/2012, 8/28/2012, 11/30/2011, 3/30/2012, 11/7/2012, 2/6/2013, 8/1/2013, 

6/20/2014, 11/16/2015, 12/10/2015). A draft cultural resources report and effects analysis was sent to the Pit 

River Tribe for consideration on12/3/2015. No response has been received. A scoping letter was mailed to the 

Winnemem Wintu Tribe on 2/22/2013. Additional meetings took place with Winnemem cultural 

representatives in the field and through email communication (7/26/2012, 9/13/2012, 3/20/2013, 4/19/2013, 

4/4/2014, 4/8/2014). A draft cultural resources report and effects analysis was sent to the Winnemem Wintu 

for consideration on 3/4/2014 and again on 6/4/2015. No response has been received.

Affected Environment

Historic Properties

There are two documented historic archaeological sites within the APE. One site is an historic saw mill 

related to early railroad logging that is eligible for the National Register of Historic Places (NRHP) and is 

thus considered an historic property. One site might have been an early trapper’s cabin, but the cabin is 

 92 This approach is consistent with CFR § 220.4 (f) and the Council on Environmental Quality June 24, 2005 

memorandum regarding analysis of past actions.
Elk Flat LSR Enhancement Project

238 Shasta-Trinity National Forest

reduced to a decomposing pile of boards and the entire site has deteriorated to a point that the time of 

construction, use, and function cannot be determined. This site is recommended ineligible to the NRHP and, 

once concurrence is received, will therefore not be considered an historic property.

In addition to the above sites, there is an historic road (the original Military Pass Road, which does not 

overlay the current road of the same name) extending through the APE that is eligible for the NRHP and thus 

is considered an historic property. The APE also encompasses remnants of five historic railroad logging 

grades utilized by the McCloud River Lumber Company (MRLC) that date to 1899-1905. The MRLC railroad 

logging system is eligible to the NRHP, however, these railroad spurs are recommended as non-contributing 

features because they don’t retain the physical evidence necessary to supplement the historic record during the 

period of significance (1896 to 1930). There is no remaining physical evidence of the other two MRLC 

railroad logging grades that historically extended through the APE. Non-contributing railroad features are not 

considered historic properties.

There are two prehistoric lithic reduction sites in the APE. These have not been evaluated for the NRHP and 

thus will be treated as historic properties.

Environmental Consequences

Alternatives-Alternatives 1, 2, and 3

Direct and Indirect Effects

An adverse direct or indirect effect would occur if the proposed project activities altered any of the 

characteristics of an historic property that would qualify it for inclusion in the NRHP in a way that would 

diminish the integrity of the property’s location, design, setting, materials, workmanship, feeling, or 

association (36 CFR § 800.5(a)(1)). Adverse effects to historic properties are outlined in 36 CFR § 800.5 and 

include physical destruction of the property, alteration that is inconsistent with the Secretary of the Interior’s 

Standard (36 CFR § 68), relocation of the property, changes in the character of the property’s use or physical 

features, the introduction of visual, atmospheric, or audible elements that diminish the integrity of the 

property’s significant historic features, neglect resulting in deterioration, or the transfer, lease, or sale out of 

Federal ownership without adequate protections.

The proposed project consists of the types of treatment activities that have the potential to affect historic 

properties unless there are resource protection measures in place. Specifically, physical damage or 

destruction, changes in a property’s use or physical features, and visual, atmospheric, or audible intrusions 

might result from activities associated with mechanical thinning, reforestation, underburning, and/or the 

proposed road work. Design features consist of avoiding historic properties during treatment activities with 

the exception of possibly removing fuels by hand from the edges of site boundaries. Resource Protection 

Measures have been developed to provide site-specific protection from the range of proposed treatment 

activities. Due to the design features and Resource Protection Measures, there will be no adverse direct or 

indirect effects to historic properties.

Cumulative Effects Alternatives 1, 2, and 3

Although there may be other projects that spatially and temporally overlap the Area of Potential Effect for the 

Elk Flat LSR Enhancement project, the lack of adverse direct and indirect effects means that there are also no 

adverse cumulative effects to archaeological historic properties or areas of Native American cultural 

importance.

Compliance with Law, Regulation and Policy

The National Historic Preservation Act of 1966 and Executive Order 11593 of May 15, 1971 require 

stewardship, maintenance and preservation of cultural properties for future generations. The American Indian 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 239

Religious Freedom Act of 1978 and Executive Order 13007 of May 24, 1996 require agencies to 

accommodate access to and ceremonial use of Indian sacred sites by Indian religious practitioners and to 

avoid adversely affecting the physical integrity of sacred sites. In consideration of the management and 

protection measures identified for cultural resources located within the project APE, this project will have no 

adverse effect on historic properties and will be in compliance with the National Historic Preservation Act 

(and 36 CFR Part 800), Executive Order 11593, The American Indian Religious Freedom Act, and Executive 

Order 13007.

Forest Plan

As outlined in the Forest Land and Resource Management Plan, the identification, management and 

protection of archaeological, historical, and religious sites is addressed in Forest Standards and Guidelines 

and in Heritage Resource Management allocations (Prescription XI) where needed. This project complies 

with the Forest Plan. Cultural resources were inventoried and evaluated, resource protection measures were 

developed and adverse effects will be avoided during implementation.

36 CFR Part 800

As addressed in 36 CFR § 800.8, the Section 106 requirements of this project are being fulfilled in 

coordination with the NEPA process.

Region 5 Programmatic Agreement

Resource Protection Measures were developed using Appendix E of the Programmatic Agreement Among the 

U.S.D.A. Forest Service, Pacific Southwest Region (Region 5), California State Historic Preservation Officer, 

Nevada State Historic Preservation Officer, and the Advisory Council on Historic Preservation Regarding the 

Processes for Compliance with Section 106 of the National Historic Preservation Act for Management of 

Historic properties by the National Forests of the Pacific Southwest Region (R5 PA).

Alternative 4 - No Action

Direct and Indirect Effects

Under the No Action alternative, the proposed project activities would not be implemented. No direct or

indirect effects to cultural resources would be expected. Although there would be no actions undertaken with 

this alternative, ongoing trends would continue.

Cumulative Effects

Since there are no direct or indirect effects expected with the No Action alternative, there would also be no 

cumulative effects. Trends described under no action for Silviculture and Forest Health and Fire and Fuels 

would continue.

Summary and Conclusions

Although the proposed project is comprised of the types of activities that have the potential to directly or 

indirectly affect historic properties, the effects will be avoided through project design and the specific 

resource protection measures described in Chapter 2 (“RPMs Common to All Action Alternatives”) and 

Appendix C (“Standard Operating Procedures and Best Management Practices”). Provided these measures are 

implemented, the project will result in no direct or indirect adverse effects to historic properties. (See RPMs 

1and RPMs 2, and SOP numbers 3 and 4 pp.D-1-D-1).

Socio-Economics

A Socio-Economics Report (Glubczynski, 2015) was completed for this project and is incorporated by 

reference. Information relevant to this decision is summarized here.
Elk Flat LSR Enhancement Project

240 Shasta-Trinity National Forest

Introduction

This section provides an assessment of the economic implications of the Elk project. An analysis of the 

existing conditions provides a baseline for comparing the effects of the action alternatives. The Affected 

Environment section presents the demographic, social and economic variables that describe the current state 

of the economic and social environment. This is followed by the environmental consequences section which 

estimates the actual impacts to local economic and social conditions.

Purpose and Need Applicable to Socio-Economics

The purpose and need statement that is related in part to socio-economics is the need to manage the Forest 

Transportation System. Changes to the Forest Transportation System affect public access to Forest lands.

Methodology

Economic Effects Methodology

According to Forest Service Manual (FSM) 1970.62, the analysis should implement “techniques to develop 

the most efficient combination of activities for each decision unit within each alternative.” Given the 

information provided, financial efficiency measures are calculated in this analysis to provide a means of 

comparing the economic feasibility across alternatives. The alternatives are analyzed and compared using the 

Quicksilver program to estimate the Benefit-Cost ratios and the Present Net Values (PNVs). Quicksilver is a 

financial analysis tool developed by the USDA Forest Service to generate measures of financial efficiency. A 

5-year planning horizon is used in this analysis; activities would begin in fiscal year 2017 and end in fiscal 

year 2021.

Economic Impact Analysis

Economic impact analysis looks at the effects of the project alternatives on employment and income in the 

study area. The relative size of the local economy plays an important role in the assessment of impacts on jobs 

and income. Broader and more diverse economies in larger communities are likely to be more resilient to 

changes in jobs and income than smaller, more rural communities. For example, a change of 10 jobs in the 

city of Redding (Shasta County, population ~91,000) would likely have very little impact on the overall health 

of the local economy. However, that same change in jobs could have a much larger impact on the small town 

of McCloud (Siskiyou County, population ~1,100).

Implementing a project can result in economic stimulus to a region, by changing the total level of jobs and 

income in the area (logging companies, sawmills, biomass generation plants), increased demand for related 

products and services, and indirectly affecting the spending habits from individual households due to 

increased income.

Social Effects Methodology

Social Impact Analysis

The social impact analysis looks at the effects of the project action alternatives on public activities on the 

Forest. The availability of the Forest for activities such as recreation, collecting forest products primarily for 

personal use, foraging for food resources, and socializing is important to the local community for maintaining 

residents’ lifestyles and honoring historic uses. The social impact analysis also looks at labor and employment 

opportunities generated by the action alternatives.

Indicators and Measures

The indicators used for comparing the economic effects of the action alternatives are:
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 241

Present Net Value - Present Net Value (PNV) is the standard criterion for deciding whether a project is 

economically justifiable (OMB Circular A-94). PNV is a way of comparing all monetarily valued costs and 

benefits. It is calculated by subtracting the discounted sum of total costs from the discounted sum of total 

benefits. Benefits and costs occurring in the future are discounted back to represent their current value. A 

Federally prescribed discount rate of 4% is used in this analysis (FSM 1971.21). A positive PNV means that 

the discounted sum of benefits is greater than the discounted sum of costs, and vice versa. Due to the 

uncertainty of future inflation, the inflation rate is left at zero for the analysis (OMB Circular A-4).

Benefit/Cost Ratio - The relationship between benefits and costs is further assessed with the benefit-cost 

ratios. Benefit-cost ratio is the discounted sum of benefits divided by the discounted sum of costs. A ratio 

greater than one suggests that the benefits associated with the project are greater than the costs. Benefit-cost 

ratios do not allow an assessment of the aggregate value of benefits associated with a project alternative. The 

alternative with the highest benefit-cost ratio has the highest value of benefits compared to the associated 

costs, but does not necessarily have the greatest value of benefits at the aggregate level. Benefit-cost ratios are 

often utilized in situations when a budget constraint is present (i.e. choose the alternative with the highest 

ratio up to a certain level of total costs). PNV provides a better measure of the overall level of benefits and 

costs since it reports the difference between benefits and costs at the aggregate level.

The indicator used for social effects is:

Access and Safety - Changes in Public Access and Relative Safety of the Access influences community use of 

the forest. Changes are assessed in miles of legal public access in the project area, along with specific 

locations accessed, and changes to current hazards along those access routes.

Boundaries

Spatial Bounding

The spatial area for analyzing the economic effects of the Elk project is the area encompassed by Siskiyou 

and Shasta Counties. Other than contributing to jobs and income in processing facilities that may receive 

materials from this project, the economic effects of the Elk project would be felt primarily in southern 

Siskiyou and northern Shasta Counties. The social effects of community use are limited to the project area.

Temporal Bounding

The temporal bounding for analysis is the 5-year implementation period, because it is during this period that 

the project would be affecting the local economy by providing jobs and income. Other present and reasonably 

foreseeable natural resource extraction and restoration projects in southern Siskiyou/northern Shasta Counties 

during this period will also provide jobs and income, and contribute to the local economy.

Affected Environment

Fundamental components of the economic and social environment for this analysis are population, 

demographics, jobs and income, and local community uses of the Forest. Understanding the conditions and 

trends of such variables allows for a more complete assessment of the social and economic dynamic as it 

pertains to National Forest use. Population, age and racial distributions of Siskiyou County are important 

socio-economic indicators for determining possible uses of forest resources by local residents.

This section highlights demographic trends in the analysis area. Population levels influence the use of natural 

resources, while rate of growth indicates whether there may be the potential for increased pressures on those 

resources in the future. Age distributions provide insights into the economic dynamic of the study area in 

terms of assessing the proportion of individuals in the working age group versus retirees and minors who 

typically have different use patterns on forests and utilize local services in different ways. Similarly, the racial 

composition of the study area may affect the cultural and heritage uses of public lands, as well as having 
Elk Flat LSR Enhancement Project

242 Shasta-Trinity National Forest

implications for the Environmental Justice section below. Employment and income statistics describe the 

economic conditions of the analysis area, as well as aid in the identification of important sectors of the 

economy. The Elk project would likely affect various sectors in different ways. For example, increases in 

recreational use would affect businesses in the recreation and tourism sector differently than businesses in the 

logging sector.

Population and Demographics

Population is an important consideration in managing forest resources. In particular, population structure 

(size, composition, density, etc.) and population dynamics (how the structure changes over time) are 

“essential to describing the effects and consequences of forest management and planning on a social 

environment” (Seesholtz, et al., 2004). This section highlights population trends in the analysis area. Growth 

rates help predict what the population levels may be in the future. These numbers help to indicate whether 

there is the potential for increased pressures for uses and recreational opportunities on the project area. 

Population increases may lead to conflicts over forest uses, recreation activities, and values; these are 

conflicts that Forest Service managers have to contend with and attempt to balance when making resource 

management decisions.

The County has maintained a relatively stable population in recent years. The most noticeable change was 

negative growth between 2008 and 2010. Several factors can lead to a decrease in population, however most 

out-migrations occur due to a change in employment conditions.

Forest management may also influence population growth. Forests offer a wide range of recreational and 

subsistence opportunities. Access to those opportunities could be a deciding factor in where people choose to 

live. In addition, the production aspects of forest resources could draw labor to the area, and thus influence 

local populations.

People moving to an area due to an increase in the demand for labor is referred to as job-led growth, and has 

been common in areas where recent technological advancements have created more jobs than local 

unemployment rates can support. This has not been the case in Siskiyou County in recent years.

Likewise, natural amenities have attracted people to live near forest boundaries in order to have easy access 

for recreational purposes. Such changes in population are referred to as amenity lead growth, and have been 

common in communities located near National Forest System lands. In prior years, the study area experienced 

amenity led growth in the form of retirees relocating from more metropolitan areas, and people searching for 

smaller communities in which to raise their families. However, that trend appears to have subsided due to 

national economic conditions. When conditions improve, it is likely that Siskiyou County will once again 

experience new population growth.

Age distributions also influence use of National Forests. Different age groups are likely to participate in 

different natural resource based activities. The median age in each county is higher than the median age of the 

state. This suggests that residents of the study area are older than residents in more metropolitan areas of 

California. This could be due to a possible lack of adequate higher educational and job opportunities in the 

area to draw a younger demographic.

Likewise, there may also be a greater influence from retirees. The economic structure of the communities 

must evolve to meet the demands of its residents. In areas with a large retiree influence, this may mean 

enhancing service based industries. However, given the current economic environment, it is unlikely that 

major changes to infrastructure and services will occur near the project area.

The vast majority of local residents are Caucasian (white, 87.1%). As a whole, California is much more 

ethnically diverse than Siskiyou County. California’s population is 59.8% Caucasian. Nearly 36% of 

California’s population comes from a Hispanic origin, whereas in Siskiyou County it is only 7.6%. In general, 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 243

the Native American population has a much higher presence in the county than in the state as a whole; it is the 

second most populous race in Siskiyou County at 3.9%.

Employment and Income

Employment and income statistics are important indicators of economic health. In recent years, the study area 

has mirrored the national trend in higher unemployment following the 2008 financial crisis. Table 70 reports 

the percent change in employment levels from the previous year over the period 2002 to 2010.

Table 70. Change in Employment from Previous Year, 2002-2010

Location 2002 2003 2004 2005 2006 2007 2008 2009 2010

Siskiyou County -0.8% -0.1% -0.5% -2.1% 2.0% -0.6% -3.1% -4.0% -3.3%

California -1.0% -0.2% 1.0% 1.9% 1.8% 0.9% -3.2% -5.2% 0.4%

Source: www.bls.gov

It is particularly important to consider the impact to employment in remote areas where jobs supported by the 

affected resources may consist of a large portion of total employment. Such areas may not be as resilient to a 

certain loss in jobs as a more metropolitan area. For example, a loss of 100 jobs in a certain sector in Siskiyou 

County is likely to have a more devastating effect on the local economy than the same loss of jobs in a more 

populated and economically diverse county, where the local economy is likely to be better positioned to 

absorb the loss in employment in one sector with job opportunities in other sectors.

Retail trade, health and social services, and government support the largest percentage of jobs in Siskiyou 

County. As the population continues to evolve there will likely be a transition in economic base. For example, 

as the population ages and if more retirees move into the area, there will likely be an expansion in health and 

social services. Overall natural resource based industries are not a major contributor to employment. 

Agriculture, forestry, fishing, and hunting account for 6.6% of total jobs in Siskiyou County. However retail, 

accommodation, food service and entertainment/recreation sectors total 23%. Retail, accommodation, food 

service and entertainment/recreation are assumed to include National Forest related recreation and tourism at 

least in part.

Another important indicator of economic health is the unemployment rate. Siskiyou County has consistently 

maintained an unemployment rate near or greater than the state average in recent years. In the period 2002 

through 2012, Siskiyou County has had a high presence of unemployment, consistently experiencing rates 

above 8% since 2002. As jobs are created in a region, labor comes from two primary sources: local 

unemployment and in-migration of households. With the higher unemployment rates in the analysis area, it is 

likely that any new demands for labor would be supplied from the local labor market; assuming that qualified 

individuals reside there. Thus, any additional jobs created by the Elk project would likely not affect household 

migration patterns, and may serve to reduce unemployment rates.

Household income is another indicator of economic health. Income available to local residents directly 

impacts their ability to purchase goods and services, including those related to activities taking place on 

National Forests. Per capita personal income is $26,874 in Siskiyou County. Labor income remains the 

primary source of income. Half of the total income in Siskiyou County is generated by transfer payments and 

investments. Siskiyou County also has a high poverty rate, and it is likely that a high proportion of income is 

derived from public assistance sources.

Local Community Use of the Forest

The Elk project area is approximately nine miles from the community of McCloud. Public comments and 

anecdotal evidence indicate that local residents have a relationship with the National Forest that includes 
Elk Flat LSR Enhancement Project

244 Shasta-Trinity National Forest

recreational activities (dispersed camping, hiking, horseback riding, mountain biking, Off Highway Vehicle

(OHV and OSV) riding), use of forest products such as edible mushrooms (including boletes, morels and 

chanterelles), edible plants (including strawberries, currents and gooseberries), game hunting, and fuelwood

gathering. The Bartle range cattle allotment overlays the project with about 10% of the allotment area within 

the project area. The local Native American community also has a special relationship with certain areas 

within and near the project area. Native American use of the project area is discussed in the Environmental 

Justice section.

The existing Forest Transportation System roads and provide access to adjacent private inholdings, 

recreational activities, and forest products. The project area contains approximately 19 miles of open Forest 

Transportation System roads, including approximately 4 miles of arterial roads and 15 miles of local roads 

that receive regular traffic and use. The Pilgrim Creek Snowmobile Park is just outside the project area on the 

Pilgrim Creek Road, and groomed snowmobile trails pass through the project area. The area also contains 

numerous unauthorized (user-created, not part of the Forest Transportation System) routes. While the routes 

may be physically accessible by motor vehicle, they are not included on the motor vehicle use map and 

therefor illegal for motorized use. Currently legal access to a dispersed recreation site on the edge of Elk Flat

is not provided on the MVUM, despite a long term use unauthorized route extending 1/10th of a mile to the 

site. Additionally, many of the areas accessed by the transportation system are experiencing high levels of 

mortality, creating higher than typical risk from falling snags. The roads most affected are mapped in the 

Hazard Reduction treatment areas on the Alternative 1 map. The extensive mortality area in the vicinity of 

206 has experienced extremely high mortality with corresponding increased hazard.

Environmental Consequences

Alternatives 1, 2, and 3 – Action Alternatives

Direct and Indirect Effects

Project Costs and Benefits/Contributions to the Local Economy

Table 71 presents the costs and benefits derived from implementing any of the three action alternatives.

Table 71. Cost Benefit MatrixCost Description

Activity

Unit 

Cost 

(2010$)

Alternative 1 Alternative 2 Alternative 3 Est.

Qty Cost Qty Cost Qty Cost FY

Planning/Prep/Admin (CCF) $30 43,900 $1,317,000 41,600 $1,248,000 37,600 $1,128,000 2016

Stump to Truck (Saw-Timber and 

Biomass Harvest (CCF) $75 43,900 $3,292,500 41,600 $3,120,000 37,600 $2,820,000 2017, 

18, 19

Sawlog Haul Costs 

(Assume 45 Miles to Mill) (CCF) $50 43,900 $2,195,000 41,600 $2,080,000 37,600 $1,880,000 2017, 

18, 19

Landing Plus Skid Trail 

Subsoiling

(Per Landing, 3⁄4 acre ea.)

$157 14 $2,198 14 $2,198 14 $2,198 2021

Site Prep-Mechanical $350 269 $94,150 266 $93,100 269 $94,150 2020

Reforestation Planting 

(includes seedlings) (acres) #400 313 $125,200 309 $123,600 304 $121,600 2020

Reforestation Survival Exam 

(1st Year) (acres) $17 313 $5,321 309 $5,253 304 $5,168 2021

Reforestation Survival Exam (3rd

Year) (acres) $19 313 $5,947 309 $5,871 304 $5,776 2023
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 245

Activity

Unit 

Cost 

(2010$)

Alternative 1 Alternative 2 Alternative 3 Est.

Qty Cost Qty Cost Qty Cost FY

Reforestation Survival Exam (5th

Year) (acres) $21 313 $6,573 309 $6,489 304 $6,384 2025

Post Planting Hand Release 

(acres) $375 313 $117,375 309 $115,875 304 $114,000 2023

Unauthorized Routes 

Decommissioned (miles) $5,000 6.4 $32,000 6.4 $32,000 6.4 $32,000 2021

New Temporary Roads 

Decommissioned (miles) $5,000 2.9 $14,500 1.6 $8,000 1.5 $7,500 2021

NFS Road Closures – Berms

(miles) $1,000 2.9 $2,900 2.9 $2,900 2.9 $2,900 2021

New Temporary Road 

Construction (miles) $5,000 2.9 $14,500 1.6 $8,000 1.5 $7,500 2017

NFS Road Reconstruction (miles) $5,000 0.3 $1,500 0.3 $1,500 0.3 $1,500 2017

Maintain System Roads (miles) $2,000 17.6 $35,200 17.6 $35,200 16.9 $33,800 2017

Fuels Treatment-Machine Pile

(acres) $260 1,461 $379,860 1,402 $364,520 1,365 $354,900 2020

Fuels Treatment-Burn Piles/Burn 

Landings (acres) $150 1,541 $231,150 1,453 $217,950 1,434 $215,100 2020

Fuels Treatment – Underburning 

(acres) $350 3,482 $1,218,700 3,482 $1,218,700 2,961 $1,036,350 2020

Fire Line Construction (miles) $100 9.3 $930 9.3 $930 10.1 $1,010 2020

Total Project Costs $9,088,504 $8,684,086 $7,874,836

Estimated Project Revenue

(Log Delivered Price) $160 43,900 $7,024,000 41,600 $6,656,000 37,600 $6,016,000 2017, 

18, 19

The action alternatives would involve a combination of commercial thinning and ecosystem restoration to 

meet the purpose and need of the project. These activities would impact economic conditions in a variety of 

ways. Direct and indirect effects on the economic environment are addressed through a quantitative 

assessment of the financial and industrial components of the alternative. Financial efficiency and economic 

impact analyses provide the basis for estimating the PNV of monetizable benefits and costs, and levels of jobs 

and income contributed to the local economy.

The PNVs and benefit-cost ratios of the action alternatives are listed in Table 72. When discounted back to 

today’s dollars, the monetary costs of the project for all the action alternatives are much greater than the 

monetary benefits. Of the 3 action alternatives, Alternative 2 has the highest PNV, at -$1,956,841. Alternative 

3 has the lowest PNV at -$2,057,097. Benefit/cost ratios are all less than one (0.71 to 0.75), confirming that 

the monetary costs associated with the project are greater than the monetary benefits.

Table 72 displays the Present Net Value and the benefit/Cost ratios of the action alternatives. 
Elk Flat LSR Enhancement Project

246 Shasta-Trinity National Forest

Table 72. Present Net Values and Benefit/Cost Ratios of Action Alternatives

Alternative PNV Benefit/Cost Ratio

Alternative 1 -$1,999,896 0.75

Alternative 2 -$1,956,841 0.74

Alternative 3 -$2,057,097 0.71

Note that the PNVs and benefit/cost ratios only take into account benefits from the commercial timber harvest 

element of the project. They do not take into account funding to accomplish the project that may come from 

sources other than commercial timber harvest.

Only monetary benefits and costs are accounted for in the financial efficiency analysis. Values that are not 

included are those that cannot be accurately measured through currency. Estimating the value of benefits and 

costs not accounted for in the market place is outside the scope of this analysis. But these non-market benefits 

may include improved ecosystem health, increase in wildlife, and reduced threat of wildfire, etc.; and the 

costs may include reduced recreational values and scenic quality. Thus, the financial measures reported in this 

document should be considered along with any other social and ecological impacts resulting from the 

management activities.

Social Effects to Local Communities/Forest Use, Employment

Employment

In addition to the financial implications of these alternatives, management activities would require human 

labor to be completed. This would affect the level of jobs and income in the study area. Jobs and income 

would be generated directly from the industries performing the tasks, as well as indirectly from the interindustry purchasing habits and household expenditure patterns of the directly affected industries and 

employees. All of the action alternatives would introduce new employment and income to the study area that 

would not occur under the no-action alternative.

Forest Use

Decommissioning will reduce the number of miles unauthorized routes physically available for vehicular use 

in the project area, and will reduce vehicular access to some areas used for recreational activities, forest 

products/food collection, and hunting. However, it should be noted that the routes being decommissioned are 

unauthorized routes that are not on the Forest MVUM. These roads are not legally open to vehicles, even if 

they are physically accessible. While closing roads and routes will reduce the number of miles physically 

accessible by vehicles, decommissioning unauthorized routes would not affect the number of miles of FTS

roads available for vehicular use. Maintenance level 1 FTS roads are currently closed consistent with the 

storage management for ML-1 roads, will be reopened for the project, then closed once the project 

implementation is complete. Closed roads would still be accessible for non-vehicular uses but not for 

vehicular use. The addition of 0.10 miles of road in Matrix to the Forest Transportation System as a 

maintenance level-2 road will ensure access to a portion of the project area to public users by vehicle; nonvehicular access would not be affected. The hazard reduction treatment along key roads as well as the 

extensive mortality treatment will reduce, but not eliminate, risk from falling trees. These effects will be the 

same across action alternatives, as the alternatives all propose the same number of miles of decommissioning 

of unauthorized routes, and addition to the Forest Transportation System.

Portions of the project area will not be available for public use during implementation activities, for public 

safety reasons, but will be available again once implementation is complete. Forest stand treatments may 

temporarily affect habitat for edible mushrooms and other edible plants, and so could affect mushroom and 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 247

plant availability. However, with Resource Protection Measures in place to protect and/or improve habitat, 

mushroom and plant availability and harvesting is not likely to be affected, long-term. Snowmobile trails may 

be temporarily reduced to one lane if winter hauling is necessary.

The availability of game for hunting in the project area may be reduced during implementation activities due 

to noise and other disturbances, as game is likely to move out of the area temporarily. Game for hunting 

would still be available outside the areas undergoing treatment/disturbance, and would be expected return to 

those areas after activities are complete.

The project would not interfere with management of the range allotment (Wenham, 2015). A marginal 

increase in forage would be expected for 10 to 20 years. The nearest water trough is 2.5 miles from the project 

area so the marginal increase in forage would constitute a slight increase in transitory forage, with range 

condition and use remaining substantially the same in no action versus the action alternatives.

Effects relative to Purpose and Need for Action

There are no elements in the project purpose and need that are related to the economic or social environments, 

other than the need to manage the National Forest Transportation System (addition of a portion of an 

unauthorized route to the system to access a known dispersed camping area). All three action alternatives will 

have the same effect of providing legal access for the dispersed recreation area.

Cumulative Effects

A “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).

Cumulative effects include the total change in economic conditions that would result from any of these 

alternatives in conjunction with the direct and indirect effects of other present and reasonably foreseeable 

natural resource related activities. Estimates of the impacts associated with other projects are not readily 

available; however, on the margin, it is expected that they will support additional jobs and income in a similar 

fashion to the Elk Project. In general, the cumulative effects area has low population density, a large 

proportion of the population is in the working age group, and unemployment rates are higher than state 

averages. Thus, new jobs would likely be filled by unemployed residents. This should contribute to reduced 

unemployment rates and increased resident incomes. Cumulative effects should continue to positively 

influence employment and income. Due to the higher unemployment rates, it is not expected that those effects 

will change household migration patterns; therefore the population base should remain unaffected.

Other present, or foreseeable future projects on either Forest or private land are unlikely to affect public 

access to the Elk project area. They will not affect habitat or the presence of mushrooms or edible plants in 

the project area, although if other projects adversely affect the presence of mushrooms or edible plants or 

habitat in their areas, it could have the cumulative effect of resulting in heavier foraging in the Elk project 

area. Additionally other projects, while active, could increase the presence of game species of wildlife within 

the Elk project area as game would be moving temporarily out of areas of disturbance.

Alternative 4 - No Action

Under this alternative no project activities would be carried out in the Elk project area. This alternative 

provides a baseline by which all action alternatives are analyzed for environmental effects.

Direct and Indirect Effects

There would be no direct or indirect effects on the economic or social environments if no actions were to take 

place. Any change in conditions would occur as a natural progression of social and economic activities and 

would occur regardless of this decision.
Elk Flat LSR Enhancement Project

248 Shasta-Trinity National Forest

Cumulative Effects

Given that there are no measurable direct and indirect effects that would occur under the no action alternative, 

there would also be no measurable cumulative effects.

Summary and Conclusions

All three action alternatives will have negative PNVs and benefit/cost ratios less than one. It is expected that 

the monetary costs associated with the project will be greater than the monetary benefits. The project will 

produce jobs and income for local residents, regardless of the action alternative. There may be minor 

temporary effects to public access for recreation, forest products and food gathering, hunting, and social 

activities. Treatments would reduce hazardous conditions along key roads in the project area. Legal access to 

the dispersed recreation area on Elk Flat would be gained. Long term effects would be minimal or none. 

Effects relative to Purpose and Need for Action

There are no elements in the project purpose and need that are related to the economic or social environments, 

other than the need to manage the National Forest Transportation System (addition of a portion of an 

unauthorized route to the system to access a known dispersed camping area). All three action alternatives will 

have the same effect of providing legal access to the dispersed recreation site at Elk Flat.

Other Required Disclosures

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).

Under the Multiple-Use Sustained Yield Act and the National Forest Management Action, all renewable 

resources are to be managed in such a way that they are available for future generations. The harvesting of 

timber can be considered a short-term use of a renewable resource. As a renewable resource, trees can be 

reestablished and grown again if long-term soil productivity is maintained through application of resource 

protection measures described in chapter 2 and the Standard Operating Procedures and Best Management 

Practices in Appendix C.

Short-term use (two to five years during treatment operations) for the Elk Flat LSR Enhancement Project 

would remove forest products and generate revenue for the Federal and State government. Treatment 

activities and resulting forest products would directly support jobs in the forest products and management 

industry. Existing roads would be used to access the treatment units during the timeframe for treatments. 

When treatments have been completed road use would return to the status quo on most roads.

There would be a short-term loss of soil productivity on areas dedicated to landings (up to approximately 58 

acres for Alternative 1, 53 acres for Alternative 2, and 47 acres for Alternative 3.) Of these estimates, some of 

these needs are provided by existing landings in the project area. Currently approximately 50 acres in landings 

exist in the project area, some of which would be used in the action alternatives. Soil in all treatment units in 

all action alternatives would meet Forest Plan soil quality standards with implementation, and less than 15 

percent of any unit would be in a non-productive state. Soil productivity would be restored in the previously 

windrowed units, and improved by decommissioning roads with residual soil compaction Decommissioned 

roads would return to forest or grassland.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 249

Unavoidable Adverse Effects

Implementation of this project may result in some negative effects that are necessary to obtain the benefits of 

reducing the risk of large-scale habitat loss from natural disturbances and stressors such as insects, disease, 

wildfire and drought in the Elk Late-Successional Reserve and accelerating development of late-successional 

and old-growth habitat characteristics in project-area stands. Implementation of any of the alternatives, or no 

action, could cause adverse environmental effects that cannot be effectively mitigated or avoided. 

Unavoidable adverse impacts often result from managing the land for one resource at the expense or condition 

of other resources. Some adverse effects are short-term and necessary to achieve long-term beneficial effects. 

The application of Forest Plan standards and guidelines, RPMs, SOPs, and BMPs are intended to limit the 

extent, severity and duration of potential impacts.

While adverse effects of the action alternatives fall within Forest Plan standards and comply with the 

regulatory framework, some may view these losses as an adverse impact to the environment. Adverse effects 

are discussed in detail by resource throughout chapter 3. Conversely, taking no action at this time would leave 

stands susceptible to continued large scale disturbance that could threaten existing and developing latesuccessional habitat. Under no action, forest stands are less likely to develop into desirable late-successional 

habitat conditions, due to overcrowding and increasing areas of root disease and insect activity.

Irreversible and Irretrievable Commitments of Resources

Irreversible commitments of resources are those that cannot be regained, such as the extinction of a species or 

the removal of mined ore. Irreversible commitments of resources are permanent losses of non-renewable 

resources.

Irretrievable commitments of resources are temporary losses of renewable resources. Irretrievable 

commitments are those that are lost for a period, such as the temporary loss of timber productivity in forested 

areas that are kept clear for use as power line rights-of-way or road access.

With implementation of this project, there are no irreversible commitments of forest resources. The 

irretrievable commitment of resources for the action alternatives include:

• The temporary loss of productive forest lands from creation of landings (Alternatives 1, 

approximately 58 acres; Alternative 2, 53 acres; Alternative 3, 47 acres), skid trails, and temporary 

road uses (of existing unauthorized routes) or construction (Alternatives 1, approximately 8.6 miles; 

Alternative 2, 8.3miles; Alternative 3, 6.2 miles), constitutes an irretrievable commitment of resources 

for the action alternatives. Productivity is expected to return upon decommissioning and revegetation.

• Boletus habitat in Elk Flat meadow will be reduced in favor of returning natural processes that 

produce and maintain the unique dry meadow habitat.

• A temporary reduction in the quantity and quality of northern spotted owl foraging habitat designated 

as critical habitat (PCE 3) will occur under Alternatives 1 and 2 and is an irretrievable commitment of 

resources. There will be no reduction of nesting/roosting habitat treated by any alternative, and no 

treatments or effects will occur within suitable habitat designated as critical habitat under Alternative 

3.

• PCE 3 will be degraded (habitat quality reduced) on approximately 224 acres, and will be 

downgraded to dispersal habitat (PCE 4) on approximately 46 acres under Alternative 1. Under 

Alternative 2, these same effects will occur. While individual elements of PCE 1, PCE 2, PCE 3 and 

PCE 4 will be removed or affected by project treatments, the overall habitat function in the affected 

stands will not be removed. The treatments will affect less than one percent of the ECS-3 Critical 
Elk Flat LSR Enhancement Project

250 Shasta-Trinity National Forest

Habitat Subunit and are considered discountable in terms of reducing the overall intended function of 

this Critical Habitat Subunit.

Degraded Habitat - The temporary change in the quality but not function, of PCE3 would last for 

approximately 5 to 20 years, depending on treatment location and type. Degraded foraging habitat 

still functions at the pre-treatment habitat level since primary habitat elements of at least 40 percent 

canopy cover, abundant down logs, abundant large snags, multi-layering, vertical and horizontal 

structure, and other important habitat elements such as roosting structure, thermal refugia, shrubs and 

openings for dusky-footed wood rat and other prey base are maintained in the post-treatment 

condition. Degraded habitat generally returns to its pre-treatment quality levels over a 20-year 

timeframe as the remaining trees grow larger and canopy levels reach and exceed 60+ percent, and 

the mid- and understory continues to develop. These time estimates are barring any events such as 

epidemic insect or disease outbreaks, or uncharacteristic stand replacing fires that can reset the seral 

stage in a stand, or part of a stand.

Downgraded Habitat – The temporary reduction in the quality of PCE 3 would last for approximately 

10 to 30 years. Downgraded foraging habitat is generally considered dispersal habitat post-treatment 

due to the reduction of overall canopy closure, or the removal or significant reductions in understory 

and midstory layering when combined with a significant removal or loss of large snags or large down 

wood. Downgraded habitat usually returns to pre-treatment levels within 10 to 30 years, and the 

timespan for recovery is usually dependent on the treatment causing the downgrade. Where 27 acres 

of foraging habitat (PCE 3) are downgraded to dispersal habitat (PCE 4) through thinning and 

California black oak release, the stand is expected to continue to provide some foraging opportunities 

for NSO. Canopy closure and cover will be below the 40 percent level and the average basal area will 

range from 60-120 sq ft/acre, on average. Follow-up underburning will incrementally reduce the 

remaining under- and mid-story trees, and some down wood and snags, over the 30-year time period 

for the three prescribed fire re-entries. While there will be patches of dense roosting sites, oaks that 

are not released, large and small trees, and snags and down wood in the post-treatment condition, 

these conditions do not provide enough residual habitat to consider the 27-acre area as ‘foraging’ 

habitat post-treatment. In this case, while the short- and long-term benefits of providing an increase in 

hardwood diversity, improved hardwood condition and increased prey base are all considered 

beneficial, the treatment is a ‘temporary’ loss of foraging habitat function and quality and PCE3 

elements on these 27 acres. Radial thinning around predominant pine may also downgrade PCE3 to 

PCE4 up to 19 acres scattered across an approximate 37-acre treatment area (based on the 

prescription of releasing up to two legacy trees per acre, as available). As this treatment generally 

removes all smaller diameter trees within a 50-foot radius of the bole, except for other predominant 

legacy trees of any species or large diameter snags, numerous 0.25-0.30 acre size gaps will be spread 

across the treatment area where little to no understory or midstory vegetation remains. The effects of 

this treatment are expected to last for 20-30 years and while the radial release treatment will also 

provide residual foraging opportunities, the habitat condition in these patches will be considered 

dispersal in combination with the other thinning and underburning treatments. 

• A potential loss of habitat elements from new landing construction, existing landing enlargement or 

temporary road construction for these landings will occur on approximately 4.25 and 8.75 acres of 

PCE1 and PCE3 under all action Alternatives, and this constitutes an irretrievable commitment of 

resources. The loss and reduction of habitat would be distributed throughout the portion of the project 

area in critical habitat both spatially and temporally (i.e., not all landings or temporary roads would be 

constructed and used at the same time). The project's design and applicable resource protection 

measures will assure that existing landings within the project area are used to the extent feasible.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 251

Energy and Natural or Depletable Resource Requirements and Conservation 

Potential

Consumption of fossil fuels would occur with the action alternatives during treatment activities and timber 

hauling as well as road and fuel treatment actions. There are no unusual energy requirements associated with 

the action alternatives nor is it the type of proposal that provides an opportunity to conserve energy at a large 

scale. Wood is a renewable resource. With the proper application of Forest Plan standards and guidelines and 

resource protection measures described in Chapter 2 for soils, water, wildlife, forest vegetation and other 

resources, the project would conserve resources.

Urban quality, historic and cultural resources and the built environment

Historic and cultural resources will be protected (flagged and avoided), as described in chapter 3, Cultural 

Resources and in the RPMs and SOPs (Appendix C). There would be no changes to urban quality or the built 

environment with this project.

Incomplete or Unavailable Information

Incomplete or unavailable information is discussed in the methodology of each resource report in the project 

record incorporated by reference or described elsewhere in this document if pertinent to the individual effects 

analyses. In general, much of the Forest resource data resides in an electronic database formatted for a 

geographic information system (GIS). The Forest uses GIS software to analyze this data. GIS data is available 

in tabular (numerical) format and as plots displaying data in map format. Knowledge about many of the 

relationships and conditions of wildlife, hydrology, forests, jobs and communities is evolving as research 

continues. The ecology, inventory, and management of a large forest area is a complex and ever-developing 

science. However, the basic data and central relationships are sufficiently established in the respective 

sciences in order for the deciding official to make a reasoned decision to select an alternative and to 

adequately assess and disclose the possible adverse environmental consequences. Given the uncertainty of 

any modeling exercise, the results are best used to compare the relative effects of the alternatives, rather than 

as an indicator of absolute effects.

Compliance and Consistency

Appendix H – Compliance and Consistency, provides detail discussion of compliance and consistency under 

law, regulation, executive order, agreement, and key policies (The legal and policy framework). Forest Plan

consistency not previously provided is detailed under the National Forest Management Act (NFMA) starting 

on page I-12. The Project is consistent with the Forest Plan and all applicable legal and policy framework.

Draft Environmental Impact Statement

Shasta-McCloud Management Unit 253

Chapter 4 –Consultation and Coordination

Preparers and Contributors

The Forest Service consulted the following individuals, Federal, State, and local agencies, tribes and other 

organization and individuals during the development of this environmental impact statement:

Interdisciplinary Team Members

Anna Courtney: Project soil scientist - 5 years of 

experience mapping soil, collecting data, 

field work, and participating on 

interdisciplinary teams. BS in Soil and 

Land Management and Geology: Earth 

Materials, University of Wisconsin 

Stevens Point.

Emelia Barnum: District Environmental 

Coordinator - 13 years of experience in 

environmental planning and project 

development, NEPA environmental 

analysis documentation and team leading. 

BS in Zoology.

Dustin Bonivert: Project transportation planner -

13 years of experience in civil engineering

design, review and inspection.

Cindy Diaz: Team Leader, natural resource 

planner – 20 years of experience forestry, 

recreation, and planning. BS in Forest 

Resource Management, Humboldt State 

University, 1984.

Heidi George: Project hydrologist - 25 years 

Forest Service, two years Calif. Dept. of 

Water Resources. MS in Watershed 

Science, Utah State University, BS in 

Geology, Chico State and Humboldt State 

Universities.

Ann Glubczynski: Project socio-economics and 

climate change specialist, natural resource 

planner – 16 years of environmental 

analysis, permitting, and project planning 

with Federal, State, and local government.

BS and MS in Forestry, University of 

Illinois.

Leslie Johnson: Project archaeologist - 11 years 

working as a field archaeologist. B.A. in 

Anthropology and Archaeology, 2002 and 

MA, 2009.

Christine Jordan: Management Unit Wildlife 

Biologist - 14 years of experience as a 

wildlife and fisheries biologist in County, 

State and Federal natural resources 

capacity, specifically for wildlife and 

fisheries conservation. BS in Wildlife, 

Humboldt State University, 2000.

Stephanie Joyce: Forest Landscape Architect -19

years of experience in scenery analysis, 

recreation planning and design. BS in 

Landscape Architecture, Cal Poly San 

Luis Obispo.

Heather McRae: Project prescribed fire and fuels 

specialist - 15 years of fire, prescribed 

fire, fuels management experience. BS in

Forestry, Northern Arizona University, 

MS in Natural Resources Management, 

Utah State University.

Annette Navarre: Project GIS Specialist - 19

years of experience in Geographic 

Information Systems and 8 years of 

experience in timber sale preparation. BS

in Forestry, U.C. Berkeley, 1984.

Lauren Payne: Project silviculturist, VMS 

Enterprise Unit - 26 years in the Forest 

Service with experience in fire 

suppression, wildlife, reforestation and 

silviculture. BS in Natural Resource 

Management, Humboldt State University, 

graduate work in hydrology at Chico State 

University and completion of the Pacific 

Southwest Region's Natural Resource 

Institute resulting in Silviculture 

Certification.

Rhonda Posey: Project Botanist - 23 years of 

experience working on the Shasta-Trinity 

National Forest. BS from California State 

University, Chico, CA, in Agriculture with 
Elk Flat LSR Enhancement Project

254 Shasta-Trinity National Forest

an emphasis in Range Management and 

Soil Science.

Brad Rust: Forest Soil Scientist – 15 years of 

experience with Natural Resource 

Conservation Service and IS Forest 

Service. BA in Range Management, MS in 

Soil Science.

Reviewers and Other Contributers

Pete Anguin Plant Pathologist, Shasta-Trinity National Forest

Steve Bachman Hydrologist, Shasta-McCloud Management Unit

Julie Cassidy Heritage Program Manager, Shasta-McCloud Management Unit 

Gary Chase Web Manager, Shasta-Trinity National Forest

Steve Clark District Fuels Officer, Shasta-McCloud Management Unit

Juan delaFuente Zone Geologist, Klamath National Forest

Ed Domanski Timber Management Officer, Shasta-McCloud Management Unit

Lara Graham Fuels Planner, Trinity River Management Unit

Kathy Roche Ecosystems Staff Officer, Shasta-Trinity National Forest

Chris Losi Environmental Coordinator, Shasta-Trinity National Forest

Christine Mai Hydrologist, Shasta-Trinity National Forest

Alex McBath Fuels Program Manager, Shasta-Trinity National Forest

Roman Muroff Sale Preparation/Contract Forester, Shasta-McCloud Management Unit

Julie Nelson Forest Botanist, Shasta-Trinity National Forest

Craig Sewell District Silviculturist, Shasta-McCloud Management Unit

Cynthia Snyder Entomologist, Shasta-Trinity National Forest

Hide Wenham Range Program Manager, Shasta-Trinity National Forest

Nisha VanHees Culturist, Shasta-McCloud Management Unit

Consultation and Coordination

Consultation

Section 7 of the ESA

Appendix AThe species list for the Biological Assessment for the Elk

Project, using the legal requirements set forth under Section 7 of the

Endangered Species Act and Forest Service Manual direction (FSM

2672.42), was obtained from the FWS Information for Planning and 

Conservation (IPaC) website on December 22, 2015 (included in s 

Consultation

Appendix E – Threatened and Endangered Species Consultation Record). Between August 2009 and present, the 

Forest has been intermittently consulting with the FWS on this project. Streamlined consultation was initiated in 

December 2011 and Jordan and FWS wildlife biologists David Topolewski, Katherine Fitzgerald and Chad Anderson 

have consulted on the project’s preferred alternative and anticipated effects since that time. Jordan presented a draft 

Project Initiation Form to the FWS, Yreka Office on December 1, 2011, and a final Project Initiation Form was 

presented on March 21, 2013. On January 6, 2016, the Shasta-McCloud Management Unit submitted the draft 

Biological Assessment to the FWS. A formal request for consultation will be made when the Forest and the FWS have 

a mutually agreed-to final Biological Assessment. This is in accordance with the streamlined consultation procedures.

Section 106 of the NHPA
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 255

In accordance with 36 CFR § 800.3(f) and Section 106 of the National Historic Preservation Act, Native 

American consultation was conducted. A formal consultation letter was mailed to the Redding Rancheria on 

February 22, 2013. The Redding Rancheria did not respond. A formal consultation letter was mailed to the Pit 

River Tribe on February 22, 2013. Additional consultation occurred with the Pit River Tribe at quarterly 

council meetings, field trips, and other meetings with individual practitioners (April 26, 2005, August 12, 

2009, August 4, 2010, November 30, 2011, March 30, 2012, July 20, 2012, August 28, 2012, November 7, 

2012, February 6, 2013, August 1, 2013, June 20, 2014). A draft effects analysis was sent to the Pit River 

Tribe for consideration on March 4, 2014. No response has been received.

The State Historic Preservation Office (SHPO) was informally consulted about a non-intensive inventory 

strategy under Stipulation 7.4 (c) of the Region 5 Programmatic Agreement (R5 PA).

Coordination

The Forest Service coordinated with the following individuals, Federal, State and local agencies, tribes and 

non-Forest Service persons during the development of this environmental impact statement.

Federal, State, and Local Agencies

Siskiyou County

California Department of Fish and Wildlife

Central Valley Regional Water Quality Board

Shasta Valley Resource Conservation District, Elk 

Stewardship Working Group

Native American Tribal Organizations

Winnemem Wintu Tribe

Individuals

Jerry Hoertling (local historian)

Distribution of the Draft Environmental Impact Statement

As per FSH 1909.15 (Chapter 20), the following is a list of agencies, organizations, and persons who have 

requested and will receive a copy of the DEIS. Other agencies, organizations and individuals that submitted 

comments during the scoping period will be notified of the online availability of the DEIS via letter or email.

Federal Agencies

U.S. Fish and Wildlife Service, Yreka Office

National Agricultural Library Head, Acquisitions 

& Serials Branch

EIS Review Coordinator, U.S. Environmental 

Protection Agency Region 9 

Director, Office of Environmental Policy and 

Compliance, U.S. Department of the Interior 

Director of NEPA Policy and Compliance, U.S. 

Department of Energy

Organizations

Conservation Congress

Klamath-Siskiyou Wildland Center

Environmental Protection Information Center

Klamath Forest Alliance

Draft Environmental Impact Statement

Shasta-McCloud Management Unit 257

Glossary of Acronyms and Terms

Adaptive Management Adaptive management promotes flexible decision making that can be adjusted in the 

face of uncertainties as outcomes from management actions and other events become 

better understood. Adaptive management does not represent an end in itself, but rather 

a means to more effective decisions and enhanced benefits. Adaptive management 

identifies in advance precisely how, when, and why adaptive management plans will be 

altered.

Aquatic Conservation Strategy

Objectives (ACS)

Aquatic Conservation Strategy was developed to restore and maintain the ecological 

health of watersheds and aquatic ecosystems contained within them on public lands. It 

employs several tactics to approach the goal of maintaining the “natural” disturbance 

regime (NWFP pp. B-10). Aquatic Conservation Strategy Objectives are nine objectives 

to meet the standards and guidelines in the Northwest Forest Plan Record of Decision 

to manage the riparian dependent resources to maintain the existing condition or 

implement actions to restore conditions (NWFP pp. B-11).

Area of Potential Effect

(APE)

The area of potential effects (APE) means 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 APE is influenced by the scale and nature

of an undertaking and may be different for different kinds of effects caused by the 

undertaking.” 36 CFR § 800.16(d). In defining the APE, the potential direct, indirect, and 

cumulative effects to historic properties and all aspects of integrity, including their 

associated settings as applicable is considered.

Basal Area (BA) The cross-sectional area of all stems of a species or all stems in a stand measured at 

breast height (4.5 feet above the ground on the uphill side) and expressed per unit of 

land area (Society of American Foresters, 2008).

Biological Assessment (BA) Biological Assessment refers to the information prepared by or under the direction of the 

Federal agency concerning listed and proposed species and designated and proposed 

critical habitat that may be present in the action area and the evaluation potential effects 

of the action on such species and habitat (50 CFR §402.02)

Biological Evaluation (BE) A Biological Evaluation analyzes and discloses the potential effects of a project on 

sensitive species known or assumed to occur within the project area. The Forest 

Service defines sensitive species as those plant and animal species identified by the 

Regional Forester for which population viability is a concern.

Biological Opinion (BO) A Biological Opinion is the document that states the opinion of the Service as to 

whether or not the Federal action is likely to jeopardize the continued existence of listed 

species or result in the destruction or adverse modification of critical habitat (50 CFR 

§402.02).

Black Stain Black stain is a wilt-like disease of conifers caused by the native, insect-vectored, fungal 

pathogen Leptographium wageneri. Disease centers appear as small groups of dead 

and symptomatic trees but can sometimes be much larger, especially in ponderosa pine 

stands. Susceptible stands are usually densely stocked and consist of either pure or 

predominantly ponderosa pine. Black stain predisposes trees to bark beetle infestation. 

Vigorous trees with adequate spacing are more resistant. Open stands have warmer 

soils that inhibits the fungus with fewer root contacts between susceptible trees.

Communities at Risk (CAR) Communities at Risk in designated Wildland-Urban Interface (WUI) (USDA & USDI, 

2001). To help protect people and their property from potential catastrophic wildfire, the 

National Fire Plan directs funding to be provided for projects designed to reduce the fire 

risks to communities. To achieve this goal communities that are at high risk of damage 

from wildfire were identified. These high risk communities identified within the wildlandurban interface, the area where homes and wildlands intermix, were published in the 

Federal Register in 2001. 

(http://osfm.fire.ca.gov/fireplan/fireplanning_communities_at_risk)

Coarse Woody Debris (CWD) Piece(s) of dead woody material, e.g., dead boles, limbs, and large root masses, on the 

ground in forest stands or in streams —synonyms are large organic debris (LOD), large 

woody debris (LWD) (Forest Plan, Appendix O), down woody debris (DWD) (Society of 
Elk Flat LSR Enhancement Project

258 Shasta-Trinity National Forest

American Foresters, 2008). CWD is often described in size classes by diameter.

Co-dominant A tree whose crown helps to form the general level of the main canopy and receiving full 

sunlight from above and comparatively little sunlight from the sides (Society of American 

Foresters, 2008).

Critical Habitat (CH), Critical 

Habitat Unit (CHU)

Designated critical habitat and critical habitat unit for Northern spotted owl (USDI-FWS, 

2012)

Crown Fire Fire spread through the tree canopy

CVRWQCB Central Valley Regional Water Quality Control Board

Diameter Breast Height (DBH) The diameter of the stem of a tree measured at breast height (4.5 ft or 1.37 m) from the 

ground. On sloping ground the measure is taken from the uphill side. DBH usually 

implies diameter outside bark (DOB) but can be measured as inside bark (DIB) (Society 

of American Foresters, 2008).

Dominant That component of a community, typically a species, exerting the greatest influence on 

its character because of its life form or great abundance or an individual or species of 

the upper layer of the canopy (Society of American Foresters, 2008). Most commonly 

used in this analysis as A tree whose crown extends above the crowns of the tree's 

immediate neighbors and receiving full sunlight from above and complete to partial 

sunlight from the sides.

Early-Seral/

Early-Successional

Potential natural community species are absent or in very low numbers. typically 6-12 

inch dbh with >40% canopy closure comprised of both natural stands and older 

plantations (LSRA, 1999 p. 22)

EIS, DEIS, FEIS Environmental Impact Statement, Draft Environmental Impact Statement, Final 

Environmental Impact Statement

Fire Hazard Fire behavior potential based on fuels and weather (USDA-FS, 2015 p. 49).

Fire Regime A generalized description of the role that fire plays in an ecosystem; the pattern and 

variability of fire occurrence and its effect on vegetation by description of fire frequency, 

predictability, intensity, seasonality and size characteristics of fire in a particular 

ecosystem (Agee, 1993).

Fire Regime Condition Class A fire regime condition class is a classification of the amount of departure from the 

natural regime. Condition class can be utilized to describe the degree of departure (low, 

moderate or high) from historical conditions. The condition class 3 (high departure) is 

defined as “fire regimes have been substantially altered from their natural (historic) 

range. The risk of losing key ecosystem components is high. Fire frequencies have 

departed from natural frequencies by multiple return intervals. Dramatic changes occur 

to one or more of the following: fire size, intensity, severity, and landscape patterns. 

Vegetation attributes have been substantially altered from their natural (historic) range

(NWCG, 2003 p. 1).

Fire Return Interval (FRI) The number of years between two successive fires documented in a designated area 

(USDA-FS, 2015 p. 49).

Fire Return Interval Departure 

(FRID)

A measure of how departed from the natural average fire return interval (USDA-FS, 

2012a).

Fire Risk The probability of a fire occurring in a given area based on historical fire occurrence 

(USDA-FS, 2015 p. 49).

Fire Severity The effect of a fire on ecosystem properties, usually defined by the degree of soil 

heating or mortality of vegetation (Agee, 2007). The severity of a fire depends on the 

fire intensity and the degree to which ecosystem properties are fire resistant. Therefore, 

fire severity is, in part, a function of the ecosystem being burned and is not simply 

indexed from fireline intensity. If a fire has a long residence time, fire severity will usually 

increase.

Forest The Shasta-Trinity National Forest

Forest Plan Shasta-Trinity National Forest Land and Resource Management Plan (Forest Plan, 

1995)
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 259

Forest Transportation System

(FTS)

The designated road and trail network managed by the Shasta-Trinity National Forest 

by maintenance levels (ML)1, 2 and 3. The FTS does not include unauthorized routes. 

Forest Service Handbook 7709.59 (62.32) described maintenance levels (also see 

(Bonivert, 2015a)). Maintenance levels define the level of service provided by, and 

maintenance required for, a specific road. Maintenance levels must be consistent with 

road management objectives and maintenance criteria.

Fuel Model (FM) Fuel models are tools to help land managers estimate fire behavior and are described in 

terms of both expected fire behavior and associated vegetation. Thirteen fuel models for 

fire behavior are utilized for the severe period of the fire season.

Geographic Information 

System (GIS)

A geographic information system (GIS) is a system for managing spatial data and 

associated attributes. In the strictest sense, it is a computer system capable of 

integrating, storing, editing, analyzing, and displaying geographically-referenced 

information.

Heterobasidion Root Disease

or Heterobasidion annosum

A fungus that attacks the root system increasing susceptibility to bark beetles and 

causing mortality. It spreads from root contact and can infect fresh cut stumps, and 

survives in living or dead as well as rotting tree stumps, and can persist long term. The 

fungus spreads via root-to-root contact to adjacent live trees and may survive for many 

years. Infection centers may enlarge until they reach barriers, such as openings in the 

stand or groups of resistant plants. Young conifers established near infected stumps 

often die shortly after roots contact infected roots in the soil.

Historic Properties Any prehistoric or historic district, site, building, structure, or object included in, or 

eligible for inclusion in, the National Register of Historic Places maintained by the 

Secretary of the Interior. This term includes artifacts, records, and remains that are 

related to and located within such properties. The term includes properties of traditional 

religious and cultural importance to an Indian tribe or native Hawaiian organization and 

that meet the National Register criteria” 36 CFR § 800.16(l)(1).

Hydrologic Unit Code (HUC) Watersheds in the United States and the Caribbean are delineated by the U.S. 

Geological Survey using a national standard hierarchical system based on surface 

hydrologic features and are classified into six types of hydrologic units: first-field 

(region), second-field (sub-region), third-field (accounting unit), fourth-field (cataloguing 

unit), fifth-field (watershed) and sixth-field (sub-watershed). Each hydrologic unit is 

identified by a unique hydrologic unit code (HUC) consisting of two to twelve digits 

based on the six levels of classification

(http://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb1042207.pdf).

Intermediate A tree whose crown extends into the lower portion of the main canopy, but that is 

shorter in height than the co dominants and receiving little direct sunlight from above 

and none from the sides (Society of American Foresters, 2008).

Ladder Fuels Fuels which provide vertical continuity between strata, thereby allowing fire to carry from 

surface fuels into the crowns of trees or shrubs with relative ease. They help initiate and 

assure the continuation of crowning. ( (NWCG, 2014).

Late Successional 

Characteristics

Trees with distinct traits common to older overmature trees including large, decadent 

boles and limbs, cavities and forked, broken or flattened tops, sometimes called “wolfy” 

trees. These trees provide unique wildlife habitat not common in most overstory trees. 

Unless stated within a stand specific prescription, trees with these late seral 

characteristics should be retained except where they serve as a public or operational 

safety hazard.

Late Successional Reserve, 

(LSR)

Late-Successional Reserve is a land allocation managed to protect and enhance oldgrowth forest conditions (NWFP p. 8). LSRs are designed to maintain a functional, 

interacting, late-successional and old-growth forest ecosystem (Forest Plan p. 4.37).

Late-Seral/

Late-Successional

Potential natural community species are dominant, but seral species still persist.

Typically greater than 25 inches in diameter with greater than 40% canopy closure. 

Many of these stands tend to be multi-storied. The large overstory trees are spaced 

fairly far apart. The large overstory trees, greater than 25 inches dbh are dominated by 

shade intolerant species while white fir , some Douglas-fir and hardwoods have grown 

up in the understory, increasing the vegetation biomass to a level where competition for 
Elk Flat LSR Enhancement Project

260 Shasta-Trinity National Forest

growing space is becoming a concern. This accounts for an increase in the number of 

trees per acre and high basal area, as compared to historical conditions (LSRA, 1999 p. 

22).

Late-Successional Old Growth 

(LSOG)

Forest or stands consisting of trees and structural attributes and supporting biological 

communities and processes associated with old-growth and/or mature forests (FEMAT 

1993, p. IX-19).

Limited Operating Period 

(LOP)

Restricted time of operations for resource protection

Live Crown Ratio The portion of the tree which is occupied by live healthy crown. Live crown ratio is 

expressed as a percent of the total height of the tree.e.g. 30% live crown ratio means a 

100-foot tall tree has 30 feet of live crown.

LSRA Forest-wide Late-Successional Reserve Assessment (LSRA, 1999)

Maintenance Level-1 (ML-1) Roads that have been placed in storage (e.g. “closed”) between intermittent uses. Basic 

custodial maintenance is performed to prevent damage to adjacent resources and to 

perpetuate the road for future resource management needs (Forest Plan p. Appdx. K).

Maintenance Level-2 (ML-2) Roads open for use by high clearance vehicles. Passenger car traffic, user comfort, and 

user convenience are not considerations (Forest Plan p. Appdx. K).

Maintenance Level-3 (ML-3) Roads open and maintained for travel by a prudent driver in a standard passenger car

(Forest Plan p. Appdx. K).

Maintenance Level-4 (ML-4) Roads that provide a moderate degree of user comfort and convenience at moderate 

travel speeds. Most roads are double lane and aggregate surfaced, but may be one 

lane (Forest Plan p. Appdx. K).

Mature Trees or stands pertaining to a tree or even-aged stand that is capable of sexual 

reproduction (other than precocious reproduction), has attained most of its potential 

height growth, or has reached merchantability standards —note within uneven-aged 

stands, individual trees may become mature but the stand itself consists of trees of 

diverse ages and stages of development (Society of American Foresters, 2008).

Mid-Seral/

Mid-Successional

Potential natural community species are increasing and colonizing the site. Typically 13-

24 inches in dbh with greater than 40% canopy closure. Most of these stands are evenaged and relatively dense, due to the encroachment of shade tolerant species. 

Hardwoods generally make up a minor component within most mid-seral stands. 

Suppressed and intermediate trees are beginning to die out of the stands as competition 

for growing space becomes a factor (LSRA, 1999 p. 22).

NEPA National Environmental Policy Act of January 1, 1970 [42 U.S.C. 4321 et seq.]

NFMA National Forest Management Act of October 22, 1976 [P.O. 94-588, 90 Stat. 2949, as 

amended]

Norther Spotted Owl (NSO) The northern spotted owl is a medium-sized, dark brown owl with a barred tail, white 

spots on the head and breast, and dark brown eyes surrounded by prominent facial 

disks. Males and females have similar plumage, but females typically weigh 10 to 20 

percent more than males. The northern spotted owl is Federally listed under the 

Endangered Species Act as a threatened species in Washington, Oregon and California

(http://www.fws.gov/arcata/es/birds/NSO/ns_owl.html).

Northwest Forest Plan (NWFP) The mission of the Northwest Forest Plan is to adopt coordinated management direction 

for the lands administered by the USDA Forest Service and the USDI Bureau of Land 

Management and to adopt complimentary approaches by other Federal agencies within 

the range of the northern spotted owl (NWFP, 1994)

(http://www.fs.usda.gov/detail/r6/landmanagement/planning/?cid=fsbdev2_026990).

Notice of Intent (NOI) Federal Register Notice of Intent to Prepare and Environmental Impact Statement 

(USDA-FS, 2013)

Old Growth Forest Forest ecosystem that has developed over a long period essentially free of catastrophic 

(including humans) disturbance. In the Pacific Northwest, an old-growth forest generally 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 261

ranges in age from 200 to 750 years or more and contains the following structural 

features: 1) large, live old-growth trees, 2) snags, and 3) large logs on the forest floor 

and in streams (LSRA, 1999).

Predominant

(Remnant, Legacy)

Predominant trees are above the general level of the upper canopy trees. 

Remnant - Trees that remain from a previous management activity or catastrophic 

event. The tree is significantly older than the surrounding vegetation. Remnant trees do 

not form a canopy layer and are usually isolated individuals or small clumps (USDA-FS, 

2010).

legacy tree - a tree, usually mature or old-growth, that is retained on a site after 

harvesting or natural disturbance to provide a biological legacy (Society of American 

Foresters, 2008)

Project Area Project assessment area or project boundary. The boundary within which physical 

implementation will take place.

Project, or project Elk Late-Successional Reserve Enhancement Project

Record of Decision, (ROD) The document that records the decision for the EIS.

Recovery Plan Revised Recovery Plan for the Northern Spotted Owl (USDI-FWS, 2012)

Regional Ecosystem Office, 

(REO)

The Regional Ecosystem Office is tasked with facilitating decision-making and 

prompting interagency issue resolution during the implementation of the Northwest 

Forest Plan (http://reo.gov/).

Resilience Resilience refers to the capacity of an ecosystem to not only accommodate gradual 

changes but to return toward a prior condition after disturbances including fire, extreme 

weather events, and climate change. Ecologically healthy and resilient landscapes, rich 

in biodiversity, will have greater capacity to adapt and thrive in the face of natural 

disturbances and large scale threats to sustainability, especially under changing and 

uncertain future environmental conditions such as those driven by climate change and 

increasing human use (USDA-FS, 2014 p. 12)

Riparian Reserve (RR) Forest Plan management prescription for riparian areas (Forest Plan p. 4.53).

Roost/Rest Clumps distinct groups of tightly spaced overstory trees/snags, often with late seral 

characteristics and with smaller (<10-inch size class) shade tolerant trees growing 

underneath. These clumps can range from a tight group of 3 to 6 trees/snags to an area 

less than1/10 acre. In all natural stands, and as available, retain rest/roost clumps 

throughout the stands. As they are available, ideally retain approximately 4 smaller 

clumps and 2 larger clumps per acre.

Running Crown Fire Crown fire that jumps from tree to tree

SDI Stand Density Index – A widely used measure developed by (Reineke, 1933) that 

expresses relative stand density in terms of the relationship of a number of trees to 

stand quadratic mean diameter. Any index that expresses relative stand density based 

on a comparison of measured stand values with some standard condition (Society of 

American Foresters, 2008)

Seral Stage/Successional 

State.

A stage of ecological process of progressive change in a plant community after 

disturbance leading to a relatively stable potential natural community under existing 

environmental conditions. Succession may be retrogressive after disturbance to a less 

stable plant community. (Hall, et al., 1995).

Silviculture The art and science of controlling the establishment, growth, composition, health, and 

quality of forests and woodlands to meet the diverse needs and values of landowners 

and society on a sustainable basis (Society of American Foresters, 2008).

Site Index Site index is a measure of a forest’s potential productivity. Site index is usually defined 

as the height of the dominant or codominant trees at a specified age in a stand. It is 

calculated in an equation that uses the tree’s height and age. Site index equations differ 

by tree species and region (Hanson, et al., 2002).

Stand A recognizable area of the forest that is relatively homogeneous and can be managed 

as a single unit.
Elk Flat LSR Enhancement Project

262 Shasta-Trinity National Forest

Suppressed (overtopped): A tree whose crown is completely overtopped by the crowns of one or more neighboring 

trees —note the vigor of overtopped (suppressed) trees varies from high to low 

depending on individual circumstances (Society of American Foresters, 2008)

Surface Fire Fire that burns loose debris on the surface, which include dead branches, leaves, and 

low vegetation. Burns only in the surface fuel bed.

The National Register of 

Historic Places (NRHP)

The National Register of Historic Places is the official list of the Nation's historic places 

worthy of preservation. Authorized by the National Historic Preservation Act of 1966, the 

National Park Service's National Register of Historic Places is part of a national 

program to coordinate and support public and private efforts to identify, evaluate, and 

protect America's historic and archeological resources.

Timber Type Classification Timber strata designations (see Forest Plan, p. D-3): M=Mixed Conifer, D=Douglas-fir, 

P=Ponderosa or Jeffrey Pine, R=Red fir, LP=Lodgepole Pine, PL=Plantations, 2=polesized timber (6-12 ft.), 3=small sawtimber (13-24 ft.), 4=medium/large sawtimber (25+ 

ft.), G=good stocking (40-100 percent), P=poor stocking (10-40 percent), N&X=all 

density classes

Torching

(Passive Crown Fire)

Fire that consumes single or small groups of trees or bushes.

Tree Well An area free of snow around the base of the trees created by lower snow accumulation 

directly below the crown of the tree and more rapid melting due to radiant heating from 

the bole.

Unauthorized Routes Existing roads that are not open to vehicular traffic or managed as part of the FTS.

Uncharacteristic Wildfire A fire that does not closely resemble the expected historical natural fire regime in terms 

of fire frequency and effects. The greater the departure from historical natural fire 

regime, the more uncharacteristic is the fire. Typically used when describing fires with 

more extreme behavior resulting in greater effects than what occurred historically.

Underburning Prescribed burning with a low fireline intensity fire under a timber canopy.

Variable Density Thinning Variable-density thinning is a silvicultural technique intended to promote biological 

diversity and structural heterogeneity (biocomplexity) characteristic of old-growth 

forests, by inducing fine-scale variation in homogeneous second-growth forest canopies 

( (Carey, et al., 1995; Muir, et al., 2002). Variable-density thinning consists of thinning a 

forest stand at different intensities in patches at a scale of approximately 0.1 to 0.5 ha, 

mimicking the scale of patchiness found in old growth (Carey, et al., 1999) and creating 

a mosaic of overstory tree densities.

Western Pine Beetle A small black bark beetle that creates egg galleries are winding and packed with frass 

and frequently introduces fungal infections such as blue stain. Western pine beetle most 

commonly attacks trees of reduced vigor. While older, larger trees are generally 

preferred, younger trees can also be infested, especially when they occur in dense 

stands, are infected by pathogens, or are damaged by fire. During periods of drought, 

the western pine beetle can overcome apparently healthy trees as well Western pine 

beetle most commonly attacks trees of reduced vigor. While older, larger trees are 

generally preferred, younger trees can also be infested, especially when they occur in 

dense stands, are infected by pathogens, or are damaged by fire. During periods of 

drought, the western pine beetle can overcome apparently healthy trees. Groups of 

trees are sometimes killed, especially when growing under crowded conditions. Since 

larger trees are generally preferred, the western pine beetle can dramatically alter the 

character of a forest that comes under attack. (Snyder, 2012)

Wildland Urban Interface 

(WUI)

The line, area, or zone where structures and other human development meet or 

intermingle with undeveloped wildland or vegetation fuels. (Guidance for 

Implementation of Federal Wildland Fire Management Policy)
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 263

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Draft Environmental Impact Statement

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Appendices

Appendices Table of Contents

Appendix A - Unit-Specific Information, Treatments and Road Actions...........................................................A-1

Table Appendix A-1 Unit-Specific Existing Condition and Objective Information Pertaining to 

Treatment Prescriptions.........................................................................................................................A-1

Table Appendix A-2. Unit Treatments by Alternative...........................................................................A-6

Silvicultural Prescription Descriptions.........................................................................................................A-22

General Marking Guidelines..................................................................................................................................... A-22

Figure Appendix A-1. Diagram of Oak Release..................................................................................A-27

Plantation Thinning................................................................................................................................................... A-27

Natural Stand Thinning............................................................................................................................................. A-31

Reforestation............................................................................................................................................................. A-33

Adaptive Management.............................................................................................................................................. A-34

Meadow Enhancement.............................................................................................................................................. A-35

Fuels Treatment Descriptions.......................................................................................................................A-35

Table Appendix A-3. Estimation of Actual Machine Piling by Unit...................................................A-37

Hydrologic Restoration Actions...................................................................................................................A-39

Table Appendix A-4. Stream Flow, Water Table Elevation and Riparian Vegetation Restoration.....A-39

Road and Landing Actions...........................................................................................................................A-40

Table Appendix A-5. Proposed Road Actions by Alternative.............................................................A-40

Table Appendix A-6. Estimated Temporary Road Needs by Unit ......................................................A-44

Appendix B -Issue Management.........................................................................................................................B-1

Introduction ....................................................................................................................................................B-1

Analysis Driving Issues/Non-Key Issues/Other Comments ........................................................................................B-2

Fuels/Fire ...............................................................................................................................................B-2

Forestry/Silviculture ..............................................................................................................................B-6

LSR......................................................................................................................................................B-18

Machine Piling.....................................................................................................................................B-25

NEPA...................................................................................................................................................B-27

Soils .....................................................................................................................................................B-30

Transportation......................................................................................................................................B-31

Watershed ............................................................................................................................................B-33

Wildlife ................................................................................................................................................B-36

Other ....................................................................................................................................................B-45

Appendix C -Standard Operating Procedures and Best Management Practices.................................................C-1

Standard Operating Procedures......................................................................................................................C-1

Best Management Practices............................................................................................................................C-4

Appendix D -Maps..............................................................................................................................................D-1

Figure Appendix D-1. Alternative 1 Modified Proposed Action Map ..................................................D-2

Figure Appendix D-2. Alternative 1 Fuels Map ....................................................................................D-3

Figure Appendix D-3. Alternative 2 Map..............................................................................................D-4

Figure Appendix D-4. Alternative 2 Fuels Map ....................................................................................D-5

Figure Appendix D-5. Alternative 3 Map..............................................................................................D-6

Figure Appendix D-6. Alternative 3 Fuels Map ....................................................................................D-7

Figure Appendix D-7. Alternative 1 Aerial Imagery Map.....................................................................D-8

Figure Appendix D-8. Wildland Urban Interface Map..........................................................................D-9

Appendix E - Threatened and Endangered Species Consultation....................................................................... E-1

ESA Consultation and Coordination Section Elk Late-Successional Reserve Enhancement Project ............ E-3

I. Introduction................................................................................................................................................. E-5

Species Dropped from Further Consideration..............................................................................................................E-6
Elk Flat LSR Enhancement Project

280 Shasta-Trinity National Forest

Critical Habitat.............................................................................................................................................................E-6

II. Consistency with Resource Plans and Other Guidance..............................................................................E-8

Northwest Forest Plan and Shasta-Trinity National Forest Land and Resource Management Plan.............................E-8

Late-Successional Reserve Assessment.......................................................................................................................E-9

Other Forest Plan Land Allocations, Forest Plan Direction and Guidance ................................................................E-10

National Fire Plan.................................................................................................................................E-11

Shasta-Trinity National Forest Fire Management Plan ........................................................................E-12

Recovery Plans...........................................................................................................................................................E-12

Revised Recovery Plan for the Northern Spotted Owl.........................................................................E-12

Recovery Plans for Other Species Considered in Detail ......................................................................E-15

III. Consultation to Date................................................................................................................................E-15

Attachment - List of Threatened and Endangered Species ........................................................................................E-27

Appendix F Appendix F-Past, Present and Reasonably Foreseeable Management Activities............................F-1

Table Appendix F-1. Present and Reasonably Foreseeable Future Activities in the Elk Vegetation 

Management Project’s General Cumulative Effects Boundary and the Project Boundary. ...................F-2

Figure Appendix F-1. Cumulative Effects Boundary Map with Past Actions.......................................F-8

(Grouped in 10-Year Increments) ..........................................................................................................F-8

Figure Appendix F-2. Ongoing and Future Projects in General Cumulative Effects Boundary............F-1

Appendix G -Changes in the Proposed Action................................................................................................... G-1

Appendix H – Compliance and Consistency...................................................................................................... H-1

Air Quality Requirements-Local, State and Federal ...................................................................................... H-1

Federal Clean Air Act and Federal Policy .................................................................................................................. H-2

General Conformity Rule ...................................................................................................................... H-2

Environmental Protection Agency Interim Air Quality Policy on Wildland and Prescribed Fires (US-EPA, 1998).. H-2

Federal Clean Air Act Regional Haze Rule (US-EPA, 1999) [and California Regional Haze Plan (CARB, 2009)].. H-3

California Clean Air Act ............................................................................................................................................. H-3

Siskiyou County Air Pollution Control District Requirements................................................................................... H-3

Burn Permit and Smoke Management Plan........................................................................................... H-3

Sensitive Receptors ............................................................................................................................... H-4

Fugitive Dust......................................................................................................................................... H-4

Naturally Occurring Asbestos (NOA)......................................................................................................................... H-5

Forest Plan Compliance – Air Quality ........................................................................................................................ H-5

Climate Change.............................................................................................................................................. H-5

Forest Service Strategic Plan ...................................................................................................................................... H-5

California Assembly Bill 32........................................................................................................................................ H-6

Endangered Species Act................................................................................................................................. H-6

Environmental Justice – Executive Order 12898........................................................................................... H-7

Table Appendix H-1. Poverty Status by State and County, 2000 and 2005.......................................... H-7

Invasive Species-Executive Order, Regulation, Policy.................................................................................. H-8

Executive Order 13112, of February 3, 1999.............................................................................................................. H-8

Departmental Regulation 9500-10: Noxious Weed Management............................................................................... H-8

Forest Service Manual (FSM) 2900............................................................................................................................ H-8

Migratory Birds – Executive Order 13186 of January 10, 2001.................................................................... H-9

Watch List (WL) botanical species - Departmental Regulation................................................................... H-10

Water Quality – Basin Plan.......................................................................................................................... H-11

National Forest Management Act (NFMA) [Forest Plan Consistency]....................................................... H-12

NFMA Findings [16 U.S.C. 1604 (g)(3)(E)]............................................................................................................. H-12

Forest Plan Consistency ............................................................................................................................................ H-12

Aquatic Conservation Strategy Objectives.......................................................................................... H-13

Ethnobotanical Resources/Special Forest Products............................................................................. H-15

Late Successional Reserve .................................................................................................................. H-17

Management Indicator Assemblage .................................................................................................... H-22

Survey and Manage (S&M)................................................................................................................. H-24

Vegetation Diversity............................................................................................................................ H-26
Draft Environmental Impact Statement

Shasta-McCloud Management Unit 281

Table Appendix H-2. Seral Stage Diversity.........................................................................................H-26

Table Appendix H-3. Summary of Silviculture Treatments and Effects to Seral Stage......................H-27

Table Appendix H-4. Summary of the capability of Shasta-Trinity National Forest Land in the Ash 

Creek watershed to support late-successional forest and the current extent of late-successional forest.H-28

Visual Quality Objectives....................................................................................................................H-30

Draft Environmental Impact Statement

Shasta-McCloud Management Unit A-1

Appendix B- Unit-Specific Information, Treatments and Road Actions 

Appendix A - Unit-Specific Information, Treatments and Road Actions

Appendix A provides detailed road and silvicultural and fuels treatment actions. Unit specific information and fuels and silviculture treatments are 

provided in the first 2 tables, Table Appendix B-1 summarizes unit-specific existing conditions that pertain to treatments which are then summarized in 

Table Appendix B-2 starting on page B-6. The summary tables are followed by more detailed discussion of silvicultural treatments and how they are 

applied (starting on page B-22. Fuels treatments descriptions start on page B-35 and road specific actions start on page B-39. 

Table Appendix B-1 Unit-Specific Existing Condition and Objective Information Pertaining to Treatment Prescriptions

Unit LSRA

Objective93

CWHR94

Type

Stand type Stand Age 

Range

Riparian

Reserve in 

Unit

Western 

Pine Beetle 

Activity

High Density

for Pine Notes

LSR 

II, III PPN plantation 20-30 Yes

1-U II, III PPN natural 60-100 No

6 II, III PPN plantation 40-50 high Yes Black stain disease present, 

minimal California black oak

7 II, III PPN plantation 40-50 Yes Predominants present

12 II, III PPN plantation 40-50 Yes

13 II, III PPN plantation 40-50 Yes

14 II, III PPN plantation 40-50 Yes Predominants present, some 

California black oak

15 II, III PPN plantation 40-50 Yes

16 II, III PPN plantation 40-50 Yes Predominants present

18 II, III PPN plantation 40-50 yes Yes Predominants present

106 II, III PPN plantation 20-30 Yes

107 II, III PPN plantation 20-30 Yes

110 II, III PPN plantation 20-30 Yes

93 Refer to Late Successional Reserve (LSR) objectives in the discussion of LSR starting on page 4. 

94 California Wildlife Habitat Relationships vegetation type (CDFW, 2008). Key to habitat types found here: http://www.dfg.ca.gov/biogeodata/cwhr/wildlife_habitats.asp
Elk Flat LSR Enhancement Project

A-2 Shasta-Trinity National Forest

Unit LSRA

Objective93

CWHR94

Type

Stand type Stand Age 

Range

Riparian

Reserve in 

Unit

Western 

Pine Beetle 

Activity

High Density

for Pine Notes

112 II, III PPN plantation 20-30 No

113 II, III PPN plantation 20-30 yes high Yes

114 II, III PPN plantation 20-30 Yes

115 II, III PPN plantation 20-30 Yes

115-16 II, III PPN plantation 20-30 No

116 II, III PPN plantation 20-30 Yes

117 II, III PPN plantation 20-30 Yes

122 II, III PPN plantation 20-30 no

123 II, III PPN plantation 20-30 high Yes

124 II, III PPN plantation 20-30 Yes

125 II, III PPN plantation 20-30 Yes

126 II, III PPN plantation 20-30 Yes

150 I SMC natural 80-120 yes Yes

NSO Nesting/Roosting and 

Foraging habitat; fisher Some 

areas of fisher denning habitat

151 I, II PPN natural 60-100 Yes

Large overstory tree 

concentrations of white fir and 

incense cedar

152-1 I, II PPN natural 80-120 yes high Yes

152-2 I PPN natural 80-120 yes high Yes

153 I, II SMC natural 60-100 Yes Abundant California black oak 

in southeast portion

154 I, II PPN natural 80-120 Yes high Yes

Mix of NSO Nesting/Roosting 

and Foraging habitat; Some 

areas of fisher denning habitat; 

Some California black oak

155 I, II PPN natural 60-100 Yes

Goshawk and NSO foraging 

habitat; some California black 

oak

156 I PPN natural 60-100 Yes Goshawk territory with nesting

and /roosting foraging habitat

156-U1 II, III PPN plantation 20-30 No

156-U2 II, III PPN natural 60-100 No
Draft Environmental Impact Statement

Shasta-McCloud Management Unit A-3

Unit LSRA

Objective93

CWHR94

Type

Stand type Stand Age 

Range

Riparian

Reserve in 

Unit

Western 

Pine Beetle 

Activity

High Density

for Pine Notes

157 I, II PPN natural 80-120 yes high Yes Some areas of fisher denning 

habitat along Ash Creek

157-U I, II PPN natural 80-120 Yes

158 II PPN natural 80-120 high Yes

159 II PPN natural 80-120 high Yes

159-U II PPN natural 60-100 No

160 I, II PPN natural 80-120 high Yes

161 I, II PPN natural 80-120 Yes

162 I, II PPN natural 80-120 high Yes

163 I, II PPN natural 80-120 yes high Yes

164 I, II PPN natural 80-120 high Yes

165 II PPN natural 80-120 Yes

High quality NSO foraging 

habitat mixed with lower 

quality and non-habitat due to 

dense small trees, Some 

California black oak

166 I, II PPN natural 80-120 Yes

167 I, II PPN natural 60-100 Yes

168-1 I SMC natural 60-100 Yes California black oak within 

unit, primarily white fir

168-2 I, II SMC natural 60-100 Yes

High quality NSO foraging 

habitat, trending toward 

Nesting/Roosting; some 

California black oak

169 I, II PPN natural 60-100 Yes

170 II SMC natural 60-100 Yes Some California black oak

171 I, II SMC natural 80-120 yes Yes

172 I, II PPN natural 80-120 Yes

173 I, II PPN natural 80-120 Yes Some California black oak

174 I, II PPN natural 80-120 Yes

175 II, III PPN natural 60-100 high Yes Aspen in portion of unit

176 I, II PPN natural 80-120 high Yes
Elk Flat LSR Enhancement Project

A-4 Shasta-Trinity National Forest

Unit LSRA

Objective93

CWHR94

Type

Stand type Stand Age 

Range

Riparian

Reserve in 

Unit

Western 

Pine Beetle 

Activity

High Density

for Pine Notes

177 I, II PPN natural 80-120 Yes

178 I, II SMC natural 60-100 Yes Some California black oak

179 I, II PPN natural 80-120 high Yes

180 I PPN natural 80-120 Yes Yes

181 I, II PPN natural 80-120 Yes

182 I PPN natural 60-100 Yes Goshawk territory with nesting

and foraging habitat

201 I, II PPN natural 80-120 high Yes Goshawk territory with nesting

and foraging habitat

202 III PPN plantation 10-20 No

203 II, III PPN plantation 10-20 No

204 II, III PPN natural 60-100 high Yes

206 II, III PPN natural 80-120 high Yes

Extensive mortality area with 

few pockets of large standing 

dead ponderosa pine 

intermixed with large live tree 

components

208 III PPN plantation 10-20 Yes

214 III PPN plantation 10-20 No

216 III PPN plantation 10-20 No

217 III PPN plantation 10-20 No

218 III PPN plantation 10-20 No

221 I PPN natural 80-120 Yes

222 III PPN plantation 10-20 No

223 III PPN plantation 10-20 No

224 III PPN plantation 10-20 No

226 III PPN plantation 10-20 No

230 III PPN plantation 10-20 No

231 III PPN plantation 10-20 No

233 II, III PPN plantation 10-20 No

235 II, III PPN natural 60-100 Yes

317 II, III SMC natural 60-100 Yes California black Oak in unit
Draft Environmental Impact Statement

Shasta-McCloud Management Unit A-5

Unit LSRA

Objective93

CWHR94

Type

Stand type Stand Age 

Range

Riparian

Reserve in 

Unit

Western 

Pine Beetle 

Activity

High Density

for Pine Notes

318 II, III PPN natural 60-100 No

346 III PPN natural 60-100 yes No

346-U III PPN natural 60-100 yes No

347 III PPN natural yes Yes

Matrix Rx

402 CWP PGS_PPN meadow No

Table Appendix B-2 summarizes unit specific treatments by alternative. The primary treatment is provided in the second column, with prescription 

element estimated acres in the following columns. 
Elk Flat LSR Enhancement Project

A-6 Shasta-Trinity National Forest

Table Appendix B-2. Unit Treatments by Alternative95

Unit Treatment

Summary Target BA

or TPA

Unit Acres Harvest Acres96 Underburn

Acres

Group Selection 

and Plant

Acres

Radial Thin

Acres

Interplant

Acres

Machine Pile & Pile 

Burn Available

Acres9798

Machine Site 

preparation for 

planting99

Biomass

Removal100

Borax t?

Salvage101

1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 

1 Plantation 

Thin

75 

TPA 34.1 34.1 34.1 30.0 30.0 30.0 34.1 34.1 34.1

Mast.

95 Acreages are approximate and rounded to nearest 0.1. All acres are estimates used for planning purposes and were generated using the Forest’s Geographic 

Information System (GIS), ground measurements or digitized imagery. Actual sub-treatment acreages may range from this number based on site specific conditions at 

the time of implementation. 

96 Harvest acres are typically the unit acres minus unthinned patches, however some units have smaller harvest areas due to unforested areas within the unit boundary 

from insect and disease activity or from natural openings.

97 Machine piling may be accomplished with a bulldozer and brush rake or an excavator that grapples and piles debris or equivalent.

98 This column shows the maximum estimated need for piling natural and activity-generated surface fuels based on total unit acres minus unthinned patches. Wholetree yarding where feasible will decrease activity slash within the units and decrease piling needs from activity-generated slash. Piling will not take place unless needed 

and is constrained to one entry per unit. Table Appendix B-3 starting on page A-22 provides additional estimates of actual piling needs by unit.

99 Estimated need based on estimated acres of planting needed. Only areas that require site prep to assure seedling/sapling survival will actually be site prepped. 

Mechanical site preparation is most often done using a machine scalp in strips or patches (pods) to peel back thick grasses. All acres are not impacted by site 

preparation.

100 If thinning or removal of trees 4 to 9.9” DBH is included in the treatment, the most likely method is listed here as either mech.=mechanical removal (whole tree is 

chipped and removed for biofuel, or mast.=mastication (tree is shredded and left on site).

101 Salvage adaptive management
Draft Environmental Impact Statement

Shasta-McCloud Management Unit A-7

Unit Treatment

Summary Target BA

or TPA

Unit Acres Harvest Acres96 Underburn

Acres

Group Selection 

and Plant

Acres

Radial Thin

Acres

Interplant

Acres

Machine Pile & Pile 

Burn Available

Acres9798

Machine Site 

preparation for 

planting99

Biomass

Removal100

Borax t?

Salvage101

1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 

1-U Underburn 

Only 0.9 0.9 0.9 0.9 0.9 0.9

6 

Plantation 

Thin: 

Group 

Selection, 

Plant 

Groups

80-

100 

ft2/ac

58.6 58.6 58.6 51.6 51.6 51.6 58.6 58.6 33.8 10.3 10.3 10.3 51.6 51.6 51.6 10.3 10.3 10.3 

Mech.

Y Y 

7 

Plantation 

Thin: 

Radial 

Thin, 

Group 

Selection, 

Plant 

Groups

80-

100 

ft2/ac

9.1 9.1 9.1 8.0 8.0 8.0 9.1 9.1 1.6 1.6 1.6 1.9 1.9 1.9 1.6 1.6 1.6

Mech.

Y 

12

Plantation 

Thin: 

Radial 

Thin

80-

100 

ft2/ac

8.3 8.3 8.3 7.3 7.3 7.3 8.3 8.3 1.7 1.7 1.7 7.3 7.3 7.3

Mech.

Y 

13

Plantation 

Thin: 

Radial 

Thin, 

Group 

Selection, 

Plant 

Groups

80-

100 

ft2/ac 11.1 11.1 11.1 9.8 9.8 9.8 11.1 11.1 2.0 2.0 2.0 2.3 2.3 2.3 9.8 9.8 9.8 2.0 2.0 2.0

Mech.

Y 
Elk Flat LSR Enhancement Project

A-8 Shasta-Trinity National Forest

Unit Treatment

Summary Target BA

or TPA

Unit Acres Harvest Acres96 Underburn

Acres

Group Selection 

and Plant

Acres

Radial Thin

Acres

Interplant

Acres

Machine Pile & Pile 

Burn Available

Acres9798

Machine Site 

preparation for 

planting99

Biomass

Removal100

Borax t?

Salvage101

1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 

14

Plantation 

Thin: 

Radial 

Thin, 

Group 

Selection, 

Plant 

Groups

80-

100 

ft2/ac

108.7 108.7 108.7 95.7 95.7 95.7 108.7 108.7 19.1 19.1 19.1 22 22 22 95.7 95.7 95.7 19.1 19.1 19.1

Mech.

Y Y

15

Plantation 

Thin: 

Radial 

Thin

80-

100 

ft2/ac

5.9 5.9 5.9 5.2 5.2 5.2 5.9 5.9 1.2 1.2 1.2

Mech.

Y 

16

Plantation 

Thin: 

Radial 

Thin, 

Group 

Selection, 

Plant 

Groups

80-

100 

ft2/ac

57.8 57.8 57.8 50.9 50.9 50.9 57.8 57.8 57.8 10.2 10.2 10.2 11.7 11.7 11.7 10.2 10.2 10.2

Mech.

Y Y

115-

16

Underburn 

Only 12.8 12.8 12.8 12.8 12.8 12.8

18

Plantation 

Thin: 

Radial 

Thin, 

Group 

Selection, 

Plant 

Groups

80-

100 

ft2/ac

84.9 68.7 84.9 74.7 60.5 74.7 84.9 68.7 84.9 14.9 12.1 14.9 17.2 14 17.2 74.7 60.5 74.7 14.9 12.1 14.9

Mech.

Y Y
Draft Environmental Impact Statement

Shasta-McCloud Management Unit A-9

Unit Treatment

Summary Target BA

or TPA

Unit Acres Harvest Acres96 Underburn

Acres

Group Selection 

and Plant

Acres

Radial Thin

Acres

Interplant

Acres

Machine Pile & Pile 

Burn Available

Acres9798

Machine Site 

preparation for 

planting99

Biomass

Removal100

Borax t?

Salvage101

1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 

18 Underburn 

Only 16.2 16.2

106 Plantation 

Thin

75 

TPA 9.5 9.5 9.5 8.4 8.4 8.4 9.5 9.5 9.5 8.4 8.4 8.4

Mech.

Y 

107 Plantation 

Thin

75 

TPA 11.2 11.2 11.2 9.9 9.9 9.9 11.2 11.2 11.2 9.9 9.9 9.9

Mast.

110 

Plantation 

Thin: With 

Meadow 

Enhancem

ent

75 

TPA 41.6 41.6 41.6 36.6 36.6 36.6 41.6 41.6 41.6

Mast.

112 Underburn 

Only 14.5 14.5 14.5 14.5 14.5 14.5 14.5 14.5 14.5

113 

Plantation 

Thin: 

Interplant

75 

TPA 37.1 37.1 37.1 32.6 32.6 32.6 37.1 37.1 37.1 15.0 15.0 15.0 32.6 32.6 32.6 15.0 15.0 15.0

Mast.

Y

114 Plantation 

Thin

100 

TPA 12.4 12.4 12.4 10.9 10.9 10.9 12.4 12.4 12.4

Mast.
Elk Flat LSR Enhancement Project

A-10 Shasta-Trinity National Forest

Unit Treatment

Summary Target BA

or TPA

Unit Acres Harvest Acres96 Underburn

Acres

Group Selection 

and Plant

Acres

Radial Thin

Acres

Interplant

Acres

Machine Pile & Pile 

Burn Available

Acres9798

Machine Site 

preparation for 

planting99

Biomass

Removal100

Borax t?

Salvage101

1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 

115 Plantation 

Thin

100 

TPA 15.3 15.3 15.3 13.5 13.5 13.5 15.3 15.3 15.3 13.5 13.5 13.5

Mech.

Y 

116 Plantation 

Thin

100 

TPA 11.7 11.7 11.7 10.3 10.3 10.3 11.7 11.7 11.7

Mech.

Y 

117 Plantation 

Thin

100 

TPA 28.9 28.9 28.9 25.4 25.4 25.4 28.9 28.9 28.9

Mast.

122 Underburn 

Only 5.8 5.8 5.8 5.8 5.8 5.8

123

Plantation 

Thin: 

Interplant

75 

TPA 15.7 15.7 15.7 13.8 13.8 13.8 15.7 15.7 15.7 5.0 5.0 5.0 13.8 13.8 13.8

Mast.

Y

124

Plantation 

Thin: 

Interplant

75 

TPA 33.1 33.1 33.1 29.1 29.1 29.1 33.1 33.1 33.1 10.0 10.0 10.0 29.1 29.1 29.1 10.0 10.0 10.0

Mech.

Y Y

125

Plantation 

Thin: 

Interplant

75 

TPA 10.1 10.1 10.1 8.9 8.9 8.9 10.1 10.1 10.1 3.0 3.0 3.0 8.9 8.9 8.9 3.0 3.0 3.0

Mast.

Y
Draft Environmental Impact Statement

Shasta-McCloud Management Unit A-11

Unit Treatment

Summary Target BA

or TPA

Unit Acres Harvest Acres96 Underburn

Acres

Group Selection 

and Plant

Acres

Radial Thin

Acres

Interplant

Acres

Machine Pile & Pile 

Burn Available

Acres9798

Machine Site 

preparation for 

planting99

Biomass

Removal100

Borax t?

Salvage101

1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 

126

Plantation 

Thin: With 

Meadow 

Enhancem

ent

100 

TPA 21.8 21.8 21.8 19.2 19.2 19.2 21.8 21.8 21.8 19.2 19.2 19.2

Mast.

150 Underburn 

Only 141.6 141.6 141.6 141.6

151

Thinning of 

Natural 

Stand

150

ft2/ac 49.7 49.7 43.7 43.7 0.0 49.7 49.7 43.7 43.7

Mech.

Y 

152-

1 

Thinning of 

Natural 

Stand: 

Radial 

Thin, 

Group 

Selection, 

Skips, 

Plant 

Groups

125-

150 

ft2/ac

107.8 98.7 107.8 94.9 86.9 94.9 108 98.7 107.8 9.5 8.7 9.5 21.8 20.0 21.8 10.5 10.5 10.5 94.9 86.9 94.9 20.0 20.0 20.0

152-

1 

Underburn 

Only 9.1 9.1

152-

2 

Underburn 

Only 8.4 8.4 8.4 8.4 8.4 8.4
Elk Flat LSR Enhancement Project

A-12 Shasta-Trinity National Forest

Unit Treatment

Summary Target BA

or TPA

Unit Acres Harvest Acres96 Underburn

Acres

Group Selection 

and Plant

Acres

Radial Thin

Acres

Interplant

Acres

Machine Pile & Pile 

Burn Available

Acres9798

Machine Site 

preparation for 

planting99

Biomass

Removal100

Borax t?

Salvage101

1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 

153

Thinning of 

Natural 

Stand: 

Radial 

Thin

125-

175 

ft2/ac

103.7 103.7 91.3 91.3 0.0 103.7 103.7 21.0 21

Mech.

Y 

154 

Thinning of 

Natural 

Stand

125-

175 

ft2/ac

118.4 85.1 118.4 104.2 74.9 104.2 118.4 85. 1 118.4 9.0 9.0 9.0 104.2 74.9 104.2

Mech.

Y 

154 Underburn 

Only 33.3 33.3

155

Thinning of 

Natural 

Stand: 

Radial 

Thin

125-

175 

ft2/ac

103.5 103.5 103.5 91.1 91.1 91.1 103.5 103.5 103.5 21.0 21.0 21.0

Mech.

Y 

156 Underburn 

Only 89.9 89.9 89.9 89.9 89.9 89.9

156-

U 

Underburn 

Only 48.8 48.8 48.8 48.8 48.8 48.8

157

Thinning of 

Natural 

Stand: 

Radial 

Thin

125-

175 

ft2/ac

154.5 154.5 154.5 136.0 136.0 136.0 154.5 154.5 154.5 31.0 31.0 31.0 10.0 10.0 10.0 136.0 136.0 136.0
Draft Environmental Impact Statement

Shasta-McCloud Management Unit A-13

Unit Treatment

Summary Target BA

or TPA

Unit Acres Harvest Acres96 Underburn

Acres

Group Selection 

and Plant

Acres

Radial Thin

Acres

Interplant

Acres

Machine Pile & Pile 

Burn Available

Acres9798

Machine Site 

preparation for 

planting99

Biomass

Removal100

Borax t?

Salvage101

1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 

157-

U 

Underburn 

Only 6.1 6.1 6.1 6.1 6.1 6.1

158

Thinning of 

Natural 

Stand: 

Radial 

Thin, 

Interplant

80-

140 

ft2/ac

135.7 135.3 135.7 119.4 119.0 119.4 135.7 135.3 135.7 27.0 27.0 27.0 27.0 26.9 27.0 119.4 119.0 119.4 10.0 10.0 10.0

Mech.

Y Y

158 Underburn 

Only 0.4 0.4

159

Thinning of 

Natural 

Stand: 

Radial 

Thin, 

Interplant

80-

140 

ft2/ac

63.7 63.7 63.7 56.1 56.1 56.1 63.7 63.7 63.7 12.9 12.9 12.9 17.0 17.0 17.0 56.1 56.1 56.1 17.0 17.0 17.0

Mech.

Y Y

159-

U 

Underburn 

Only 2.5 2.5 2.5 2.5 2.5 2.5

160

Thinning of 

Natural 

Stand: 

Group 

Selection, 

Plant 

Groups

125-

150 

ft2/ac

39.0 39.0 39.0 34.3 34.3 34.3 39.0 39.0 39.0 6.9 6.9 6.9 34.3 34.3 34.3 6.9 6.9 6.9 Y Y
Elk Flat LSR Enhancement Project

A-14 Shasta-Trinity National Forest

Unit Treatment

Summary Target BA

or TPA

Unit Acres Harvest Acres96 Underburn

Acres

Group Selection 

and Plant

Acres

Radial Thin

Acres

Interplant

Acres

Machine Pile & Pile 

Burn Available

Acres9798

Machine Site 

preparation for 

planting99

Biomass

Removal100

Borax t?

Salvage101

1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 

161

Thinning of 

Natural 

Stand

150

ft2/ac

33.3 33.3 29.3 29.3 0.0 33.3 33.3 Y 

162

Thinning of 

Natural 

Stand: 

Interplant

80-

140 

ft2/ac

84.0 84.0 84.0 73.9 73.9 73.9 84.0 84.0 84.0 17.0 17.0 17.0 73.9 73.9 73.9 17.0 17.0 17.0

Mech.

Y Y

163

Thinning of 

Natural 

Stand: 

Interplant

100-

150 

ft2/ac

88.9 87.0 88.9 78.2 76.6 78.2 88.9 87.0 88.9 15.0 15.0 15.0 78.2 76.6 78.2 15.0 15.0 15.0

Mech.

Y Y

163 Underburn 

Only 1.9 1.9

164

Thinning of 

Natural 

Stand: 

Interplant

100-

150 

ft2/ac

30.7 30.7 30.7 27.0 27.0 27.0 30.7 30.7 30.7 5.0 5.0 5.0 27.0 27.0 27.0 5.0 5.0 5.0

Mech.

Y Y

165

Thinning of 

Natural 

Stand

125-

175 

ft2/ac

27.8 27.8 27.8 24.5 24.5 24.5 27.8 27.8 27.8 24.5 24.5 24.5 Y 

166

Thinning of 

Natural 

Stand: 

Interplant

125-

175 

ft2/ac

12.1 12.1 12.1 10.6 10.6 10.6 12.1 12.1 12.1 2.1 2.1 2.1 10.6 10.6 10.6 Y 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit A-15

Unit Treatment

Summary Target BA

or TPA

Unit Acres Harvest Acres96 Underburn

Acres

Group Selection 

and Plant

Acres

Radial Thin

Acres

Interplant

Acres

Machine Pile & Pile 

Burn Available

Acres9798

Machine Site 

preparation for 

planting99

Biomass

Removal100

Borax t?

Salvage101

1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 

167

Thinning of 

Natural 

Stand

125-

175 

ft2/ac

4.9 4.9 4.9 4.3 4.3 4.3 4.9 4.9 4.9

Mech.

Y 

168-

1 

Thinning of 

Natural 

Stand

125-

175 

ft2/ac

6.5 6.5 5.7 5.7 0.0 6.5 6.5 5.7 5.7 Y 

168-

2 

Underburn 

Only 15.0 15.0 15.0 15.0 Y 

169

Thinning of 

Natural 

Stand: 

Interplant

125-

175 

ft2/ac

32.2 32.2 28.3 28.3 0.0 32.2 32.2 9.0 9.0 28.3 28.3

Mech.

Y Y

170

Thinning of 

Natural 

Stand

100-

150 

ft2/ac

10.1 10.1 8.9 8.9 0.0 10.1 10.1

Mech.

Y 

171

Thinning of 

Natural 

Stand: 

Radial 

Thin

100-

150 

ft2/ac

16.3 16.3 14.3 14.3 0.0 16.3 16.3 3.3 3.3

Mech.

Y 

172

Thinning of 

Natural 

Stand

150

ft2/ac

4.7 4.7 4.1 4.1 0.0 4.7 4.7 Y 
Elk Flat LSR Enhancement Project

A-16 Shasta-Trinity National Forest

Unit Treatment

Summary Target BA

or TPA

Unit Acres Harvest Acres96 Underburn

Acres

Group Selection 

and Plant

Acres

Radial Thin

Acres

Interplant

Acres

Machine Pile & Pile 

Burn Available

Acres9798

Machine Site 

preparation for 

planting99

Biomass

Removal100

Borax t?

Salvage101

1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 

173 Underburn 

Only 28.3 28.3 28.3 28.3 28.3 28.3

174

Thinning of 

Natural 

Stand

125-

175 

ft2/ac

12.9 12.9 12.9 11.4 11.4 11.4 12.9 12.9 12.9 11.4 11.4 11.4 Y 

175

Thinning of 

Natural 

Stand: 

Interplant

80-

120 

ft2/ac

25.7 21.1 25.7 22.6 18.6 22.6 25.7 21.1 25.7 5.0 5.0 5.0 22.6 18.6 22.6 5.0 5.0 5.0

Mech.

Y Y

175 Underburn 

Only 4.6 4.6

176

Thinning of 

Natural 

Stand: 

Interplant

80-

120 

ft2/ac

32.0 32.0 32.0 28.2 28.2 28.2 32.0 32.0 32.0 6.0 6.0 6.0 28.2 28.2 28.2 6.0 6.0 6.0

Mech.

Y Y

177 

Thinning of 

Natural 

Stand

100-

150 

ft2/ac

12.1 12.1 12.1 12.1 12.1 12.1 12.1 12.1 12.1 12.1 12.1 12.1

Mech.

Y 

178

Thinning of 

Natural 

Stand

125-

175 

ft2/ac

27.5 27.5 24.2 24.2 0.0 27.5 27.5

Mech.

Y 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit A-17

Unit Treatment

Summary Target BA

or TPA

Unit Acres Harvest Acres96 Underburn

Acres

Group Selection 

and Plant

Acres

Radial Thin

Acres

Interplant

Acres

Machine Pile & Pile 

Burn Available

Acres9798

Machine Site 

preparation for 

planting99

Biomass

Removal100

Borax t?

Salvage101

1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 

179

Thinning of 

Natural 

Stand: 

Interplant

80-

140 

ft2/ac

5.4 5.4 5.4 4.8 4.8 4.8 5.4 5.4 5.4 4.8 4.8 4.8

Mech.

Y 

180 

Thinning of 

Natural 

Stand 

80-

120 

ft2/ac

3.5 3.5 3.5 3.0 3.0 3.0 3.5 3.5 3.5

Mech.

Y 

181

Thinning of 

Natural 

Stand: 

Interplant

125-

175 

ft2/ac

2.5 2.5 2.5 2.2 2.2 2.2 2.5 2.5 2.5 2.2 2.2 2.2

Mech.

Y 

182 Underburn 

Only

80-

120 

ft2/ac

36.1 36.1 36.1 36.1 36.1 36.1 N 

201

Thinning of 

Natural 

Stand: 

Interplant

80-

120 

ft2/ac

13.6 13.6 13.6 12.0 12.0 12.0 13.6 13.6 13.6 3.0 3.0 3.0 12.0 12.0 12.0 3.0 3.0 3.0

Mech.

Y 

202 Underburn 

Only 14.9 14.9 14.9 14.9 14.9 14.9

203 Interplant 12.4 12.4 12.4 12.4 12.4 12.4 6.0 6.0 6.0 6.0 6.0 6.0
Elk Flat LSR Enhancement Project

A-18 Shasta-Trinity National Forest

Unit Treatment

Summary Target BA

or TPA

Unit Acres Harvest Acres96 Underburn

Acres

Group Selection 

and Plant

Acres

Radial Thin

Acres

Interplant

Acres

Machine Pile & Pile 

Burn Available

Acres9798

Machine Site 

preparation for 

planting99

Biomass

Removal100

Borax t?

Salvage101

1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 

204

Thinning of 

Natural 

Stand: 

Interplant

80-

120 

ft2/ac

15.3 15.3 15.3 13.5 13.5 13.5 15.3 15.3 15.3 4.0 4.0 4.0 13.5 13.5 13.5 4.0 4.0 4.0

Mech.

Y Y

206

Thinning of 

Natural 

Stand: 

Interplant

80-

120 

ft2/ac

114.2 113.3 114.2 29.3 29.3 29.3 114.2 113.3 114.2 60.0 60.0 60.0 100.5 99.7 100.5 60.0 60.0 60.0

Mech.

Y Y

206 Underburn 

Only 0.8 0.8

208 Plantation 

Thin

100 

TPA 27.2 27.2 27.2 23.9 23.9 23.9 27.2 27.2

Mech.

Y 

214 Underburn 

Only 6.7 6.7 6.7 6.7

216 Underburn 

Only 16.8 16.8 16.8 16.8

217 Underburn 

Only 3.8 3.8 3.8 3.8 3.8 3.8
Draft Environmental Impact Statement

Shasta-McCloud Management Unit A-19

Unit Treatment

Summary Target BA

or TPA

Unit Acres Harvest Acres96 Underburn

Acres

Group Selection 

and Plant

Acres

Radial Thin

Acres

Interplant

Acres

Machine Pile & Pile 

Burn Available

Acres9798

Machine Site 

preparation for 

planting99

Biomass

Removal100

Borax t?

Salvage101

1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 

218 Underburn 

Only 14.5 14.5 14.5 14.5 14.5 14.5

221 Underburn 

Only 9.3 9.3 9.3 9.3 9.3 9.3

222 Underburn 

Only 6.7 6.7 6.7 6.7 6.7 6.7

223 Underburn 

Only 4.6 4.6 4.6 4.6 4.6 4.6

224 Underburn 

Only 6.2 6.2 6.2 6.2 6.2 6.2

226 Interplant 16.0 16.0 16.0 16.0 16.0 16.0 4.0 4.0 4.0 4.0 4.0 4.0

230 Underburn 

Only 10.4 10.4 10.4 10.4
Elk Flat LSR Enhancement Project

A-20 Shasta-Trinity National Forest

Unit Treatment

Summary Target BA

or TPA

Unit Acres Harvest Acres96 Underburn

Acres

Group Selection 

and Plant

Acres

Radial Thin

Acres

Interplant

Acres

Machine Pile & Pile 

Burn Available

Acres9798

Machine Site 

preparation for 

planting99

Biomass

Removal100

Borax t?

Salvage101

1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 

231 Underburn 

Only 26.6 26.6 26.6 26.6

233 Plantation 

Thin

100 

TPA 9.9 9.9 9.9 8.7 8.7 8.7 9.9 9.9 9.9

Mech.

235

Thinning of 

Natural 

Stand

125-

175 

ft2/ac

19.8 19.8 17.4 17.4 0.0 19.8 19.8 17.4 17.4

Mech.

Y Y

317

Thinning of 

Natural 

Stand: 

Oak 

Release

100 

TPA 2.2 2.2 2.2 2.2 2.2 2.2 2.2 2.2 2.2

Mech.

Y 

318 Underburn 

Only 10.0 10.0 10.0 10.0 10.0 10.0

346 Underburn 

Only 54.7 54.7 54.7 54.7 54.7 54.7

346-

U 

Underburn 

Only 3.1 3.1 3.1 3.1 3.1 3.1
Draft Environmental Impact Statement

Shasta-McCloud Management Unit A-21

Unit Treatment

Summary Target BA

or TPA

Unit Acres Harvest Acres96 Underburn

Acres

Group Selection 

and Plant

Acres

Radial Thin

Acres

Interplant

Acres

Machine Pile & Pile 

Burn Available

Acres9798

Machine Site 

preparation for 

planting99

Biomass

Removal100

Borax t?

Salvage101

1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 

347

Thinning of 

Natural 

Stand: 

Interplant

80-

120 

ft2/ac

11.5 11.5 11.5 10.1 10.1 10.1 11.5 11.5 11.5 4.0 4.0 4.0 10.1 10.1 10.1 4.0 4.0 4.0

Mech.

Y 

401 Underburn 

Only 147.4 147.4 147.4 147.4 147.4 147.4

402

Meadow 

Enhancem

ent:

Partial 

Conifer 

Removal, 

Underburn

0-60 

ft2/ac 518.3 493.9 518.3 378.5 354.1 378.5 518.3 493.9 518.3

Meh.

Y 

402 Underburn 

Only 24.4 24.4

Totals

3,4833,4832,9622,2362,1541,9693,4833,4832,767

757175

196191172247247238

1,4611,4021,366

269266269
Elk Flat LSR Enhancement Project

A-22 Shasta-Trinity National Forest

Silvicultural Prescription Descriptions 

The following silvicultural treatment prescriptions for Thinning (Plantation Thinning p. B-27 and Natural 

Stand Thinning p. B-31), Meadow Enhancement (B-35), and Reforestation (B-33), Aspen restoration adaptive 

management (p. B-34) and Adaptive Management Salvage (p. B-34) provide general guidance by treatment. 

The general marking guidelines below provide prescription elements of thinning including designation of 

unthinned patches (UTPs), habitat roost/rest clumps, tree selection, and other treatments for site specific 

conditions (for example, the presence of predominant trees, aspen, oak, or sugar pine) within units. Stands 

may have one to several different prescription elements in order to address site specific conditions and issues 

of density, insects or disease and to develop and retain key late-successional habitat features.

Thinning prescriptions are discussed in two primary treatment groups: natural stands and plantations. Within 

each of these primary groups several prescription elements vary by stand conditions. Table Appendix B-2 

above lists the treatments by unit, and unit-specific detailed information is provided on the stand record cards 

in the project record. 

Variable density thinning would accomplish all thinning treatments for natural stands and some older 

plantations. Variable density thinning does not include a singular density target, and instead is a treatment that 

thins to retain a range of densities by including unthinned patches (UTPs that are also referred to as skips), 

areas of heavy thinning or small openings (radial release, gaps, or group selections), and thinning within a 

target basal area range elsewhere within the stand. More information on the placement of designing the UTPs, 

gaps, group selections and radial release treatments, along with other specifics such as release around oak or 

aspen are included in the general marking guidelines. 

Biomass (4 to 9.9-inch DBH) would be mechanically thinned on a prescribed spacing, or to a prescribed basal 

area, in those natural and plantation thinning units that have a biomass thinning component as listed in Table 

Appendix B-2. As an adaptive management strategy dependent on market feasibility at the time of 

implementation, biomass material may not be mechanically thinned and removed under the implementation 

contract, but instead treated with a combination of mechanical treatments or hand thinning and left on site or 

thinned through prescribed fire.

Borate fungicide such as Sporax® or Cellu-Treat® would be applied to stumps over 14 inches in all harvested 

areas within 4 hours of harvest to prevent the spread of Heterobasidion annosum in all harvested areas as 

listed in Table Appendix B-2. 

General Marking Guidelines

Marking guidelines apply primarily to the natural stands, although they also apply in some plantations, and 

are meant to be used in conjunction with individual stand prescriptions. Table Appendix B-2 summarizes

some of the unit specific information pertaining to how the general marking guidelines are implemented based 

on unit specific conditions and the resulting unit specific treatments. Additional stand-specific marking

instructions are provided on the stand record cards in the project record. 

Tree Selection Criteria for Thinning - Conifers

Tree selection for thinning is a process of identifying those trees that are desirable for the habitat objectives, 

and removing the remaining trees to reduce competition for resources and reduce live ladder and canopy 

fuels. Trees to be retained would include healthy large overstory dominant trees of all species, healthy pine of 

any size where pine is underrepresented, a component of healthy small understory and midstory trees, a 

component of heavily damaged or diseased trees that provide habitat, and all hardwood trees as operationally 

feasible. 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit A-23

While there is no prescribed upper diameter limit for the project, or within specific treatment units, the largest 

oldest trees (predominants and dominants) that exhibit old-growth characteristics such as large boles, 

decadent branching, cavities and flattened tops would be retained as long as they are not a safety hazard. In 

some treatments units, diameter limits are prescribed (e.g., when conducting California black oak release 

within critical habitat for the northern spotted owl, certain species of snags). All predominant trees would be 

retained, regardless of their current health/ condition when marking. Trees to be removed would primarily be 

midstory intermediate and smaller co-dominant trees; primarily the shade tolerant white fir that has grown up 

through the understory over the last several decades because of fire suppression and stand succession. For 

example, white fir that are larger in relation to adjacent healthy trees of other less common mixed conifer 

species such as Douglas-fir and incense cedar would be removed in some cases to promote species diversity.

Desirable (Healthy) Tree - A tree exhibiting no signs of defect, damage or disease. Crown appears full and 

vibrant, bole is regular in form without excessive lean. Live crown ratio is 40 percent or greater. Desirable 

trees should be preferred over acceptable trees as leave trees.

Acceptable tree - A tree that may exhibit some minor defect, damage or disease, but these characteristics are 

not excessive - defect, damage or disease is not expected to appreciably reduce tree growth or its ability to 

survive into the future. Live crown ratio is 30 percent or greater. Where they exist, desirable trees should be 

selected for leave over acceptable trees.

Unacceptable Tree - A tree exhibiting damage, successful insect attack, defect or disease such that the tree is 

not expected to thrive or survive long term, or the tree poses as an undesirable vector for the spread of 

disease. Predominant trees or trees with late-successional characteristics are not included under this definition, 

all large predominant trees are to be retained. Unless exceptions are stated in the unit-specific silvicultural 

prescription, trees with the following characteristics should not be considered for leave trees:

1. A live crown ratio less than 30 percent. 

2. Fading, thinning, off-color foliage dominating the crown appearance.

3. It is suppressed.

4. It is leaning more than 15 degrees from vertical – i.e. showing signs of torn or upheaved roots such

that the tree is likely to become unstable over time.

5. There is Excessive damage – A tree with 50 percent or more of the circumference of the bole

cambium damaged, or occupied by an open and bleeding mistletoe canker, at any location along the

stem is classified as excessively damaged. Trees with broken tops in the lower two thirds are

classified as excessively damaged and should not be considered as a leave tree. Trees with broken

tops in the upper third are not considered excessively damaged if they are not expected to prevent

the tree from reaching maturity. These trees should only be left if no better formed trees meeting

"leave tree" exist to meet prescription objectives.

6. There is Excessive disease/insect attack – the following describes symptoms of the most common

diseases in the project area and western pine beetle activity:

a. Dwarf Mistletoe - The Hawksworth six point rating system is used to determine the level of dwarf

mistletoe infection102 in host trees. Trees bearing visible dwarf mistletoe plants on the trunk or

have a Hawksworth rating of 4 or greater for the tree should be classified as being excessively

damaged. Where dwarf mistletoe is present, select healthy non-infected trees regardless of species

102 Mistletoe "infection" refers to visible dwarf mistletoe fruiting bodies. Damage caused by prior infections, such as 

witches brooms, should not be factored into a dwarf mistletoe rating without seeing fruiting bodies.
Elk Flat LSR Enhancement Project

A-24 Shasta-Trinity National Forest

first, then infected trees with a Hawksworth rating of 3 or less as leave trees in order to meet 

stocking (basal area or spacing) requirements. Infected trees are rated as follows:

1. Divide the crown into thirds

2. Rate each third separately as follows:

0 = No infection 

1 = Less than 50% of the branches infected, or infection on the stem. 

2 = More than 50% of the branches infected.

3 = Add ratings of thirds to obtain rating of total tree. 

7. White Pine Blister Rust - This disease and its accompanying symptoms apply to sugar pine and 

western white pine only. These trees should be considered as excessively blister rust infected if they 

are bearing any visible blister rust cankers on the trunk or branches. Branch cankers can appear as 

"flags" in which all the branch needles turn brown. Dead branches void of needles should not be 

considered blister rust infected unless cankers are visible where the branch extends from the bole.

8. Western Pine Beetle – Successful attacks by beetles are visible by red pitch tubes that have a clear

opening or evidence of red frass on the ground or in bark crevices below. Pitch tubes that are white

or clear are signs of unsuccessful attack. Western pine beetle typically attack near the center of the

tree bole. Large patches of exposed inner bark from woodpeckers feeding on beetle larvae are

another indicator of successful beetle attack. Trees crowns typically begin to fade from pale green to

red usually within one year of a successful attack. Within the Elk project area and with extended

drought conditions, it is unlikely that trees with successful pine beetle attacks will survive long term.

With the exception of predominant trees, trees showing signs or symptoms of successful beetle

attack should be removed unless they are to be counted towards snag retention objectives.

Density/Fuels Thinning

Thin the portions of the stands not retained as unthinned patches or treated under the other prescription 

elements described below, to a range of stand-specific basal areas provided (see individual stand 

prescriptions). Generally retain the largest healthiest trees and remove suppressed and intermediate trees with 

exceptions (see below). Recognizing that historically most stands in the eastern and southeastern portions of 

the project area were pine dominated with a mix of species; promote pine health and survival and emphasize 

removal of encroaching shade tolerant trees while retaining structural and species diversity in these areas.

Basal area can vary by locale to select the healthiest trees and promote diversity while maintaining the desired 

stand average basal area. Most stands have a target basal area range rather than a single basal area value, to 

meet the variable density thinning objectives. The stand specific prescriptions describe when to thin to a lower 

or higher basal area, depending on the presence of disease, species mix and average tree diameter. As a 

general rule of thumb, consider varying the basal area by 20% of the target average at any locale to achieve 

stand health and habitat objectives. Objectives of variable density thinning include reducing overstocking 

while promoting stand structure variability, biological diversity and characteristics of old-growth forests by 

inducing fine-scale variation in homogeneous second-growth forest canopies and is expected to facilitate the 

development of the structural and functional characteristics of late-successional forests. Retain all large 

predominant trees of any species and health, as operationally feasible and where not a safety hazard. 

Unthinned Patches

Retain at least ten percent of a unit proposed for thinning within LSR allocation in an unthinned condition. 

Unthinned patches would be selected based on the presence of features that provide processes and conditions 

such as thermal cover, natural suppression and mortality. These features include dense pockets of trees (large 

or small), trees with cavities, trees with deformed or decadent limbs, large snags, large down logs, 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit A-25

undisturbed debris, and dense or multi-layered forest attributes. They may also include openings with dense 

brush, small trees, or other vegetation that contributes to natural size differentiation.

Unthinned patches would vary in size and placement across the LSR and while fire (during underburning) 

would be allowed to creep into these areas, there would be no direct ignition within some unthinned patches 

(RPM 24 p. 85).

Snag retention areas may comprise some of the unthinned patches in heavy mortality areas when the other 

features are not available to achieve the minimum ten percent threshold. Where safely feasible in LSR, snag 

retention areas (ranging from 5 to 10 acres) will be strategically located within or adjacent to existing 

mortality pockets. Snag retention areas will be at least 150 feet from System roads that will remain open after 

project completion or 300 feet from private property boundaries. Snag retention areas will consist of a range 

of size classes and species with a preference for areas that contain larger diameter snags (≥24 inches) with a 

live tree component for wind-throw protection and little to no understory regeneration in known black stain

infection areas. Retention areas will be delineated by the project wildlife biologist. Units 158, 162, 175,176, 

204 and 206 are known to be affected by mortality and likely to have snag retention areas. No piling, 

reforestation or other mechanical activities will occur in these areas under the project.

Habitat Roost/Rest Clumps

These are distinct groups of tightly spaced overstory trees/snags, often with late-successional characteristics 

and with smaller (<10-inch size class) shade tolerant trees growing underneath that provide avian and bat 

roosting or fisher or Pacific marten rest and potential den sites. Clumps would be composed of white fir, 

cedar, sugar pine or Douglas-fir, or any combination thereof and usually consist of a grouping of 3 to 6 

trees/snags growing tightly spaced, with decadent branching, cavities, defect, or broken tops with smaller 

(<10-inch size class) trees surrounding the larger live or dead trees. Clumps can range from a tight grouping 

of trees/snags to an area about 1/10 acre or larger. These clumps would be retained at the rate of at least 4 to 6 

small clumps per acre and at least 3 larger clumps per acre and These habitat features are one element of 

consideration when marking for the low or high end of a variable density basal area target.

Radial Release – Predominant Pine

Conduct radial thinning around large legacy pine to reduce density, remove fuels and promote tree vigor and 

long term survival. Large "legacy" predominant trees are trees that are distinctly older and larger than trees in 

the main canopy layer of a stand. Radial thin around a maximum of two legacy pine per acre, except unit 157 

which is a maximum of four trees per acre, where specified in the stand prescription. Generally remove all 

smaller diameter trees within a 50 foot radius of the bole except for other predominant legacy trees of any 

species. Select legacy pine that appear the most healthy and likely to survive long term (refer to attachment 1 

as an aid in determining tree health and selection priority). Focus radial release where thinning can have the 

greatest beneficial effect: on pine that are relatively healthy and are crowded by advanced second growth 

trees, often shade tolerant white fir.

Sugar pine and hardwood retention

Retain healthy sugar pine that do not show symptoms of white pine blister rust, are not suppressed or heavily 

damaged and otherwise are expected to survive long term. In unique instances of sugar pine aggregates, sugar 

pine may be thinned to reduce density and achieve target basal area, but otherwise healthy sugar pines are 

priority for retention.

Retain and promote oak and aspen as described below (p. B-26 to B-27), unless as otherwise prescribed 

within critical habitat for the northern spotted owl. Thin overtopping conifers not otherwise designated for 

retention (for example do not remove predominant trees or trees with late-successional characteristics).
Elk Flat LSR Enhancement Project

A-26 Shasta-Trinity National Forest

Snag Recruitment

Live trees with decadent late-successional characteristics may count towards the snag retention objective (see 

RPM 40a, page 89) where snags are not available. 

Black stain or western pine beetle (WPB)

Pockets of western pine beetle mortality ranging from a few trees to large expanses occur throughout the 

project area. In this project area and vicinity, pine beetle mortality is frequently tied to black stain root disease 

– a vascular disease that weakens the trees and predisposes them to insect attack. Where black stain root

disease is detected or deemed likely, basal area retention is lower than prescribed elsewhere.

Map and notify the Silviculturist or project coordinator of any areas of suspected black stain root disease. 

Symptoms of black stain disease include reduced growth and fading of crowns, slow or rapid decline (slower 

in old trees and faster in young trees), and crown wilt. Another indicator of black stain is trees in different 

stages of mortality, typical of root disease infection centers, instead of a uniform onset of mortality, typical of 

mass attacks by bark beetles.

Western pine beetle mortality in ponderosa pine occurs throughout the project area and is expected to be 

ongoing. Trees (other than large predominant pine) that are recently dead, or have been successfully attacked 

and are dying or likely to die should be removed to reduce future fuel loadings, when they are not needed to 

meet wildlife snag retention needs.

Because of rapid decay, these trees may have little or no merchantable value at the time of harvest. These 

trees would be designated for removal.

Riparian Reserves

Equipment may not enter into Riparian Reserves except for designated crossings, but trees may be removed 

that can be reached from the edge of the Riparian Reserve, or the edge of the equipment exclusion zone (such 

as equipment using a boom arm). Do not designate trees for removal that cannot be reached by equipment 

from the edge of the Riparian Reserve or equipment exclusion zone. This generally means trees may be 

removed that are 20’ or less from the Riparian Reserve or equipment exclusion zone edge. 

Gaps and Group Selections in Dense White Fir

Group selection is the creation of small openings (or gaps) to provide for regeneration of a new age and often 

species class, while leaving most of a stand's overstory intact. Group selection is a tool to develop species and 

age/size diversity in stands that lack heterogeneity. Group selection is also a tool to regenerate pine, which 

requires high amounts of direct sunlight if they are to thrive and survive to grow into the overstory. Young 

pine in contrast to white fir are not shade tolerant and do not survive well in a shaded understory environment. 

In order to regenerate pine in areas of dense homogenous white fir that have developed because of past 

management practices and the exclusion of natural frequent fire, group selection and gap creation would 

occur in several natural stands. To a limited extent, create group selections of 1 to 2 acres for pine 

regeneration and in stands with homogenous white fir create small gaps in the canopy openings of 1/10 to 1⁄4 

acre to develop structural heterogeneity for natural understory vegetation development. 

Unit-specific installation of groups and gaps in dense even-aged white fir are further described in the stand 

specific prescriptions in the project record and pertain to LSR natural stands 151, 152-1, 153, 160, 170, and 

178. 

Oak Release

Release oaks 4 inches DBH and greater by removing adjacent conifers. Do not remove predominant (legacy) 

trees, dominant trees that have late-successional characteristics or healthy sugar pine (not infected with blister 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit A-27

rust) when releasing oaks. Using a quadrant system, remove all conifers within 30’ of the dripline of oaks 4

inches DBH and greater to the west, north and east, remove all conifers within 60’ of the dripline in the south 

quadrant.103 Use directional felling away from oaks to 

minimize damage to oak (especially when interlocking 

crowns). This in effect makes an egg-shaped clearing around 

the released oak – see diagram in Table Appendix B-2. Units 6, 

14, 153, 154, 165, 168, 173, 178, and 317 are known to contain 

oak. (unit 318 is also known to contain oak however it is not a 

thinning unit therefore the oak release treatment would not be 

applied). 

Oak Release in Critical Northern Spotted Owl

Habitat

In units 6, 14, 153, 161, 168-1, 169, 170, 171, 172, 178 and 

235, do not remove Douglas-fir, sugar pine or incense cedar 

≥24 inches DBH within the oak prescription radius. In addition, 

some conifers would be retained around oak that have cavities 

or good resting or denning structure for fisher, roosting 

structure for NSO, or where release would damage the oak. 

This occurs primarily in units 153 and 178, but also in155, 165 

and 154. 

Aspen Release

Thin around aspen clones to remove conifer encroachment. Remove conifers for a distance of 150 feet from 

the most distal live aspen tree or sprout. Retain large predominant conifers regardless of species or health or 

density. Additionally retain healthy sugar pine 10 inches DBH or larger for a combined total of up to 10 trees 

per acre (waive the 10 conifer tree maximum only if large predominant trees are in excess of 10 TPA.) Ten 

trees per acre equates to approximately 70 foot spacing to reflect estimated pre-settlement forest conditions. 

Favorably select trees with late-successional characteristics for retention where available. Aspen are known to 

occur in units 157, 175, 402 and 318 (although 318 is not prescribed for release except through 

underburning). The 150 foot buffer may extend into joining units if near a boundary, but would be truncated at 

project area boundaries. The release treatment would be applied to other areas if additional aspen are located.

Plantation Thinning

Plantation thinning prescriptions are prescribed by age of the plantation then further divided by variations 

based on site specific conditions. The age division is made for younger plantations at 39 or younger and older 

plantations at 40 or older. Within older pine plantations, group selections are proposed in dense homogenous 

stands to facilitate development of multiple-canopied and multiple-species stands that will be more resilient to 

stocking pressure, drought stress and disease and insect impacts. Group selections would comprise up to 20 

percent of a stand and would be re-planted with a mix of conifer species to increase diversity. Group 

selections may range from approximately one to two acres.

103Jerry Franklin described that success has been observed when you remove conifers from 2 times the individual 

oak's dripline distance; and then on Southwest / South aspects, remove conifers within 1/2 the dominant tree height. 

(Franklin, 2013). In order to provide uniformity and feasibility the oak release treatment described was developed for the 

Elk project based on this information.

Figure Appendix B-1. Diagram of Oak Release
Elk Flat LSR Enhancement Project

A-28 Shasta-Trinity National Forest

Biomass material would be thinned through mastication or thinned mechanically and removed as noted for 

each unit in Table Appendix B-2. Tree selections will be made per the general marking guidelines as described 

starting page B-22 and as applicable for each unit conditions.

Table Appendix B-2 also lists borax applications for stumps greater than 14 inches to inhibit the spread of 

Heterobasidion root disease.

The thinning prescription for plantations varies not only by age and conditions, but also by site-specific 

features such as bordering the Elk Flat meadow or the presence of black stain root disease or western pine 

beetle.

Young Plantation Thin

Young Plantation Thinning is prescribed for units 1, 106, 107, 114, 115, 116, 117, 208 and 233 which are 

ponderosa pine plantations ranging from 10 to 39 years since establishment with scattered residual pole to 

young mature overstory. The objective is to reduce density for stand plantation development, remove ladder 

fuels and retain and promote species diversity as available. Trees within some of the 20 to 30 year-old 

plantations, pre-commercial thinning of trees less than 8 inches DBH would be removed by either mechanical 

thinning, hand thinning or mastication. utilized to reduce future stand density. If treatments of larger size 

material (8 to 9.9 inches) are warranted, this material would be harvested as biomass. Black stain root disease 

has been observed in some of the younger plantations (e.g., unit 113) and appears to be spreading. The

thinning prescription varies by site specific features such as bordering the Elk Flat meadow or the presence of 

black stain or western pine beetle. This prescription would: 

• thin trees 4 inches DBH and larger to75 trees per acre (TPA) to an average 24 foot spacing (+- 4 feet)

(units 1, 106, 107), or to 100 TPA to an average 21 foot spacing (+- 4 feet) (units 114, 115, 116, 117,

208, 2330,

• retain generally the healthiest larger trees,

• promote species diversity and structural heterogeneity through favoring minor species while

considering tree health for diversity, and crown position (e.g. suppressed, dominant, etc.),

• remove ladder fuels adjacent to healthy residual larger trees,

• apply borax fungicide to stumps greater than 14 inches in those units likely to have stumps above 14

inches (106, 115, 116, and 208.)

Young Plantation Thin with Meadow Enhancement

Plantation stands 110 and 126 would be thinned as described in the young plantation prescription described 

above (thinning to 75 TPA and 100 TPA, respectively), and will be thinned more heavily to enhance meadow 

habitat within 100 feet of the Elk Flat meadow. The meadow enhancement would: 

• create a “feathered” effect near the meadow edge by thinning to approximately 25 TPA on an average

spacing of approximately 42 feet (+-8 feet),

• favor leaving pine near the meadow edge, and

• leave a few small groups (2 to 4 trees) of naturally clumped healthy co-dominant trees to reflect

natural stand development, while staying near 25 TPA average.

Young Plantation Thin with Interplant in Areas with Black stain or Western Pine Beetle 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit A-29

(WPB) Mortality

The “young plantation thin with interplant” prescription applies to those young ponderosa pine plantations 

with recent mortality from black stain root disease or Western Pine Beetle activity. These plantations have

moderate/WPB varying to high levels of mortality, and often include scattered residual pole to young mature 

overstory trees (e.g. units 113104, 123, 124 and 125). This prescription would: 

• thin trees 4 inches DBH and larger to create buffer zones around mortality pockets and promote

survival and growth of remaining pine,

• favor retention of non-susceptible species especially adjacent to areas of pine mortality,

• remove ladder fuels adjacent to healthy residual larger trees,

• remove all pine symptomatic of black stain and remove pine within 100 feet of symptomatic trees and

mortality pockets,

• retain any healthy non-susceptible trees within buffer zones,

• outside of mortality pockets and the 100’ buffer zones, thin pine to an average 50’ spacing to avoid

root-to-root contact and maximize growth,

• retain healthy non-susceptible trees within these thinning areas up to an average of 24’ spacing. In

other words, there should be 50’ spacing between pine but other tree species can be retained in

between the pine as they are available,

• select the healthiest largest trees for retention, favoring minor species for diversity,

• interplant mixed species in existing mortality openings to increase diversity and provide a disease

barrier, and

• apply borax fungicide to stumps greater than 14 inches in those units likely to have stumps above 14

inches (unit 124.)

Young plantations that are not excessively dense and are not showing signs of disease would be treated with 

prescribed underburning. In most instances, these plantations do not contain heavy surface fuel loadings; 

rather, fire would creep through some areas and naturally extinguish in others. Including these plantations in 

prescribed underburning treatments makes for efficiency of implementation, reducing ground disturbance 

impacts from creation of fire lines and more closely reflects the frequency of a natural fire disturbance.

Older Plantation Thinning

The “older plantation” prescription applies to plantations that are currently 40 to 50 years old (units 6, 7, 12, 

13, 14, 15, 16 and 18). Stocking is very dense and these plantations are at high risk for bark beetle attacks. 

Basal areas generally range from 180 to 240 square feet with average diameters of 16 to 22 inches DBH. The 

prescription reduces stand density to reduce risk of future beetle attacks, breaks up fuel continuity and 

promotes species and structural diversity and encourages the healthy growth of residual trees. Group 

104 Unit 113 includes a Riparian Reserve and the guidelines for Riparian Reserves included in the general marking 

guidelines would be applied.
Elk Flat LSR Enhancement Project

A-30 Shasta-Trinity National Forest

selections would contribute toward development of a second age class and increases species diversity by 

interplanting a mix of conifer species. This prescription would:

• Retain species and structural diversity with trees that are expected to survive long term into the future

while meeting fuels and stand density objectives.

• Retain an average basal area between 80 to 100 square feet (can vary by locale from approximately

60 to 120 square feet. Generally, basal area should not exceed 120 square feet except within

unthinned patches or natural aggregates of mixed species composition with generally larger trees

sizes.) Where black stain root disease is detected or deemed likely, basal area retention would be

lower than prescribed elsewhere.

• Retain all healthy sugar pine that do not show symptoms of white pine blister rust, are not suppressed

or heavily damaged and otherwise are expected to survive long term.

• Retain and promote all oak. Thin conifers from oaks 4 inches DBH or larger as described on page B26.

• Retain all large predominant trees of any species and health. Implement radial thinning around

residual larger pines in units 12, 13, 14, 15, 16 and 18 as described on page B-25.

• Install unthinned patches as described on page B-25.

• Conduct radial thinning only around large healthy predominant pine (per general marking

guidelines).Thin all trees except for other predominant trees (any species) for a distance of 50’ from

the bole of healthy large predominant pine.

• Remove trees in group selections in units 6, 7, 13, 14, 16 and 18 to further promote vegetation

structural and species diversity to create openings for natural and planted reforestation to promote a

second layer of mixed conifer species. Plant only in group selection areas and with mixed species for

diversity and to serve as a disease barrier. The thinning and group selections would also promote

shrub, forb and grass growth to a small extent given the created openings.

• Promote diversity through selection of minor species. A healthy smaller conifer (not pine) may be

selected as a leave tree over larger adjacent healthy pine only when it is a minor species, is not

suppressed, does not appear damaged or diseased and is expected to thrive after thinning. Minor

species within the plantations include Douglas-fir, white fir, and incense-cedar.

• Remove trees (other than large predominant pine) to reduce future fuel loadings, that have been

successfully attacked and are dying or likely to die when they are not needed to meet Forest Plan,

wildlife and LSRA snag retention requirements.

• Apply borax fungicide Borate fungicide such as Sporax® or Cellu-Treat® would be applied to stumps

over 14 inches in diameter in all thinned areas within 4 hours of harvest to prevent the spread of

Heterobasidian root disease.

Variation for Habitat

As available, the retention of roost/rest clumps for wildlife use and habitat structure, as described for Natural 

Stand Thinning, would also be retained within older plantations. During the release of California black oak, 

no sugar pine, Douglas-fir, or incense cedar that are 24 inches DBH or larger would be removed. While these 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit A-31

species are less likely to be present within these older ponderosa pine plantations, the plantation units are 

adjacent to natural stands that may have these species/size classes.) 

Natural Stand Thinning

Natural stands prescribed for thinning range from approximately 60 to 120 years old. Natural stand thinning

includes a summary of the prescriptions for units 151, 152-1, 153, 154, 155, 157, 158, 159, 160, 161, 162, 

163, 164, 165, 166, 167, 168-1, 169, 170, 171, 172, 174, 175, 176, 177, 178, 179, 180, 181, 201, 204, 206, 

235, 317, and 347. Natural stand thinning prescriptions are prescribed primarily by target basal areas as listed 

by unit in Table Appendix B-2 starting on page B-6, and further divided by variations based on site specific 

characteristics such as northern spotted owl foraging or dispersal habitat, the presence of aspen, oak or insect 

or disease activity.

The prescriptions in natural stands do not purely thin-from-below as some lower and mid-story trees would be 

retained (as is consistent with the thin-from-below technique). Residual density in the natural stand thinning 

units would vary from an average 125 to 175 square feet of basal area per acre, but may be higher or lower 

depending on species composition and current habitat function for NSO. Depending on the average tree 

diameter, this equates to approximately 60 to 100 trees per acre. Lower densities would be retained in areas 

that are predominantly dominated by ponderosa pine, higher densities would be retained in mixed conifer, and 

white fir dominated stands. Higher densities would also be retained where clumped groups of large trees, and 

smaller biomass sized (trees <10 inches DBH), occur to provide for age class and structural variability. 

Instead of applying one target basal area across a stand, the variable density thinning prescription would help 

promote within-stand structural heterogeneity that contributes to habitat function for late-successional species 

while providing the needed growing space, nutrients and water for the remaining trees. Biomass thinning 

would occur in some units through mastication or thinned mechanically and the material removed by means 

listed in Table Appendix B-2. 

In all natural stand thinning units in LSR, and as available, structural components (or clumps) that provide 

avian or bat roosting or mammal fisher or Pacific marten rest and potential den sites would be retained at the 

rate of at least four to six small clumps per acre and at least three larger clumps per acre. Clumps would be 

composed of white fir, cedar, sugar pine or Douglas-fir, or any combination thereof and usually consist of a 

grouping of three to six trees/snags growing tightly spaced, with decadent branching, cavities, defect, or

broken tops with smaller (<10-inch size class) trees surrounding the larger live and or dead trees. Clumps can 

range from a tight grouping of trees or snags to an area about 1/10 acre or larger. 

Borate fungicide such as Sporax® or Cellu-Treat® would be applied to stumps over 14 inches in all harvested 

areas within 4 hours of harvest to prevent the spread of Heterobasidion root disease. 

Thinning of Natural Stand - Variation for Critical Northern Spotted Owl Habitat

Thin from below to a target basal area of 150 applies to units 151, 161 and 172 with the following stand 

specific guidelines. Species retention priority is SP, DF, IC, PP, WF, LP, KP, which is slightly different from

the “standard” retention priority in the general marking guidelines. 

Unit 151

• Thin smaller understory/midstory and co-dominant trees 4 inches DBH and greater. Focus on

removing and retaining the healthiest largest trees.

• On up to 10% of the treatment unit create small gaps between 75 – 115 feet across in areas of white

fir dominated smaller trees (gaps would not be installed in areas of healthy pine or large predominant

trees) at the rate of no more than one gap on any one acre to develop structural heterogeneity and

small openings for natural understory development.
Elk Flat LSR Enhancement Project

A-32 Shasta-Trinity National Forest

• In addition to unthinned patches, no thinning would occur where pockets or areas of large overstory

white fir and cedar occur; these areas may also have a pine component but the key feature is distinct

large overstory trees of mixed species, with generally white fir predominant.

Units 161 and 172 

• Outside of leave islands, thin from below trees 10 inches DBH and greater up to some codominant

trees, as needed (generally 24 inches DBH or less) to retain a fairly closed overstory and understory.

Retain all predominant trees and dominant trees that meet the desirable or acceptable 

leave tree criteria (see p. B-22) 

Thin from below to a target basal area of 150 applies to units 151, 161 and 172 with the following stand 

specific guidelines. Species retention priority is: Sugar pine (SP), Douglas-fir (DF), incense cedar (IC), 

ponderosa pine (PP), white fir (WF), lodgepole pine (LP), knobcone pine (KP), which is slightly different 

than the “standard” retention priority in the general marking guidelines. 

Unit 151 

• Thin smaller understory/midstory and co-dominant trees four inches DBH and greater. Focus on

retaining the healthiest largest trees.

• On up to 10% of the treatment unit create small gaps of 75 to115 feet across in areas of white fir

dominated smaller trees (gaps would not be installed in areas of healthy pine or large predominant

trees) at the rate of no more than one gap on any one acre to develop structural heterogeneity and

small openings for natural understory regeneration and development.

• In addition to unthinned patches, no thinning would occur where pockets or areas of large overstory

white fir and incense cedar occur; these areas may also have a pine component but the key feature is

distinct large overstory trees of mixed species, with generally white fir predominant.

Units 161 and 172 

• Thin from below trees 10 inches DBH and greater up to some codominant trees as needed (generally

24 inches DBH or less) to retain a fairly closed overstory and understory.

• Retain all predominant trees and dominant trees that meet the desirable or acceptable leave tree

criteria (see B-22) which may cause target basal area to be exceeded.

• Leave undesirable overstory trees to meet snag requirements if needed.

Thinning of Natural Stand, Radial Thin, Group Selection, Skips, Plant Groups - Variation for 

Group selection for Heterobasidion root Disease

In order to regenerate pine in areas of dense homogenous white fir that have developed as a result of past 

management practices and the exclusion of natural frequent fire, group selections would be installed in units 

152 -1 and 160 (natural thinning stands) where Heterobasidion root disease has been observed and reforested 

with pine. Group selections would generally range from one to two acres but would not exceed one acre in 

natural stand 152-1 in order to retain larger areas of existing late-successional habitat function.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit A-33

Thinning of Natural Stand, Interplant - Variation for Natural Stand Thinning to Trees per 

Acre or Hardwood Release

Unit 317 would be thinned from below per the tree selection criteria (page B-22) to a target of 100 TPA 

(average spacing 20 feet +- 4 feet) with a primary objective of oak release per the oak release prescription on 

page B-26. 

Unit 175 has an aspen component that will be treated per the aspen release prescription (page B-27).

Reforestation 

A combination of planting and natural seed fall would provide regeneration. Openings created by mortality 

pockets approximately one acre or larger would be evaluated for the need to site prep and interplant following 

thinning or fuels treatments. Pockets of mortality less than one acre are expected to regenerate naturally from 

seed fall of nearby residual trees. 

Planting would promote stand resiliency by planting a mix of species that include non-host trees for black 

stain and Heterobasidion root disease, and help assure pine reestablishment in areas where it is lacking. Hand 

planting would be conducted in mortality openings and in group selections where: 

• Natural regeneration is not expected to sufficiently establish within five years of thinning or fuels

treatments, typically from a lack of nearby seed source or ground conditions not favorable to natural

seedling establishment.

• A mix of tree species is desired to discourage the spread of disease (for example, interplanting nonsusceptible pine in pockets of white fir Heterobasidion root disease).

• A mix of tree species is desired to promote diversity or certain species are not expected to establish

naturally. These may include ponderosa pine, sugar pine, Douglas-fir, incense cedar and hardwoods

such as black oak.

All group selections regardless of size, and openings created by mortality pockets two acres or larger would 

be planted. Openings created by mortality pockets between one and two acres would be evaluated posttreatment for planting needs.

Table Appendix B-2 (starting p. B-6) lists approximate acres of group selections and mortality openings in 

applicable units.

Mechanical site preparation would be implemented as needed to remove competing understory vegetation, 

such as grass, prior to planting. Planting areas would be evaluated for site preparation needs after completion 

of thinning and fuels treatments. Where the need is determined, mechanical site preparation would be 

conducted in group selections and in large expanses of mortality (generally five acres or larger such as units 

113 and 206) or areas of numerous concentrated smaller mortality gaps. Mechanical site preparation is 

typically completed with a small tractor with a wildland rototiller or drum masticator. Competing vegetation 

would be treated down to a soil depth of 4 inches to 6 inches to effectively sever grass/forb roots below the 

root crown and brush below the first lateral root. Where mortality openings are smaller (generally less than 5 

acres) and less contiguous, site preparation would be conducted as needed by hand scalping using hand tools. 

Planting in areas generally five acres or larger would occur in a pattern of widely spaced clusters or groups of 

three to five seedlings for a total of approximately 250 trees per acre, otherwise known as cluster planting. 

Cluster planting helps establish seedling dominance in the vicinity of the cluster. Typically one or two 

seedlings establish dominance over the others. Later excess smaller saplings may be removed adjacent to the 

dominant conifers within the clusters. Smaller openings, generally less than 5 acres, would be planted with up 

to approximately 150 trees per acre scattered as individuals throughout the planted area.
Elk Flat LSR Enhancement Project

A-34 Shasta-Trinity National Forest

Reforestation treatments would be monitored for the need to control competing vegetation such as grasses, 

forbs, brush and dense naturally seeded in conifers from the surrounding stand (typically white fir in an area 

where ponderosa pine is being reestablished) that could inhibit the survival and growth of desirable seedlings. 

Hand or mechanical cutting of competing vegetation may be implemented within the first one to five years 

following reforestation, depending on monitoring results. Hand treatments would be most anticipated in the 

areas of less than five acres that where mechanical site preparation was not utilized. 

Interplanting-Only - Units 203 and 226 do not have thinning treatments but mixed species would be 

interplanted as described above in existing openings after the first entry of prescribed underburning. 

Adaptive Management

Aspen Restoration Adaptive Management 

Aspen restoration would be completed through the marking guidelines for release of aspen during thinning 

(see p. B-27). If aspen monitoring indicates clumps or stands are not actively suckering within three years of 

conifer removal or fuels-only treatments, underburning or mechanical soil disturbance treatments (such as 

disking) may be used to stimulate suckering. Use and timing of burning or mechanical treatments will depend 

on readiness indicated by:

a. An overstory and understory made up primarily or completely of aspen, with few competing conifers

present. The overstory condition ranges from vigorous to declining aspen,

b. Newly regenerated trees below or around the edges of a more mature overstory of aspen. Where

overstory aspen are declining and dead, lack of a vigorous aspen understory indicates very poor aspen

health, and

c. An understory including a diverse plant community of native shrubs, grasses, sedges, rushes and forbs

(non-grass flowering plants), free of noxious weeds.

The need for removal of new conifer encroachment or enhancement of aspen age class variability through 

application of underburning will be assessed on a site-specific basis once the initial objective of aspen

establishment as described above is achieved.

If aspen monitoring indicates browse damage at a level that may prevent achievement of healthy aspen 

establishment, the appropriate type and size of fencing will be installed and maintained until monitoring 

indicates it is no longer necessary:

a. Deer/Elk fencing constructed of poly mesh on T-posts, with a height of 6 feet or greater.

b. Cattle fencing constructed as a 36 to 48 inch 4-wire let-down fence on T-posts, with the top wire

being barbed.

Salvage Adaptive Management

Under adaptive management, salvage of dead and dying trees would be included in units experiencing 

excessive ongoing mortality in the pine or white fir component (defined as more than 50% of the unit). The 

total potential on the harvest acres are listed in Table Appendix B-2 (starting page B-6) and represent what 

could be subject to salvage in the event conditions deteriorate further post-decision and post- marking.

Salvage treatment areas would be defined by white fir and ponderosa pine trees showing symptoms of rapid 

decline such as: chlorotic foliage and poor needle retention; insect damage (white frass or pitch tubes on white 

fir; multiple pitch tubes on 3⁄4-bole circumference or with signs of successful attacks on pine). Areas would 

typically be within or adjacent to larger mortality areas which are signs of an ongoing stocking, insect or 

disease problem. During any salvage, the snag and CWD retention levels prescribed in would be in 

accordance with the project’s design and resource protection measures would be met (as would all RPMs and 

standard operating procedures). The adaptive management would extend only until the area was closed under 

the implementation contract.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit A-35

Meadow Enhancement

The meadow enhancement prescription applies to unit 402. Thinning for meadow enhancement is different 

from thinning a forested stand in that there is no target density level such as a desired basal area or spacing. 

Rather than manage for a forested stand, the intent is to create conditions more reflective of those found 

historically; namely few scattered pine within an otherwise open meadow. A tree’s size, age and position –

within the meadow and in relation to adjacent trees, are considerations when selecting trees for retention or 

removal.

Predominant trees would be retained. All other trees that have grown into and along the meadow edges would 

be removed. A basal area of approximately 60 square feet per acre of the largest diameter trees would be 

retained where the meadow transitions into conifer stands along the edge. This thinning prescription, 

combined with the plantation thinning prescription in units 110 and 126 described above, would create a 

‘feathered’ effect of few trees within the meadow, transitioning to an open forest stand along the meadow’s 

edge. Prescribed burning would be utilized every five to ten years after initial treatments to maintain the 

meadow, mimicking the effects of a historic natural fire regime and serving as an important tool in restoring 

and enhancing ecological function and processes by promoting soil nutrients, perennial grass and forb 

regeneration. While prescribed fire would be employed across Elk Flat, it is recognized that vegetation varies 

some areas of the meadow will carry fire readily while other areas may not. 

Borate fungicide such as Sporax® or Cellu-Treat® would be applied to stumps over 14 inches in all harvested 

areas within 1 4 hours of harvest to prevent the spread of Heterobasidion annosum. 

Fuels Treatment Descriptions 

The fuel treatments described below would comply with the Resource Protection Measures Common to All 

Action Alternatives (RPMs) (starting on page 81), Standard Operating Procedures (SOPs) (starting p. D-1) 

and Best Management Practices (starting p. D-4) for all applicable resources. The Standard Operating 

Procedures for Silviculture and Fuels (SOP 17, p. D-3) describe the required burn plan that would be 

completed prior to implementation to prescribe the onsite burning conditions, public safety, and measures to 

implement the project objectives and resource protection measures. Also, see the Standard Operating 

Procedures for Air Quality on page D-1 for routine practices pertaining to prescribed fire to comply with air 

quality requirements.

Underburn

Underburning or broadcast burning (burning in a stand with little or no overstory, such as the meadow 

restoration units) involves a prescribed burn utilizing a low to moderate intensity fire, often under a timber 

canopy.105 Underburning would be phased in incrementally over the project area (unless restricted by RPMs). 

Table Appendix B-2 (starting p. B-6) lists units where underburning-only would be implemented without prior 

thinning. The alternative maps for fuels (Appendix D – Maps) show the fuels prescriptions. Due to the high 

degree of departure from the natural fire regime, one burn entry is unlikely to achieve the objective of 

returning the natural role of fire to the ecosystem. Instead, 2 to 3 incremental underburns, repeated every 5 to 

10 years would be implemented. The entire area would not be burned in any one year, contributing to a 

diverse mosaic of treated area conditions. Achieving underburning treatments would require the following 

connected actions:

105 The terms underburning and broadcast burning may be used interchangeably in this document.
Elk Flat LSR Enhancement Project

A-36 Shasta-Trinity National Forest

• Heavy concentrations of natural or activity-generated coarse woody debris would be machine piled as

a pretreatment before underburning to limit adverse fire severity effects to soils, wildlife and

overstory trees.

• Fire containment methods such as hose lay, sprinkler system, hand line, or mechanical fire line

construction may be utilized to reduce impacts to resources of concern including but not limited to

cultural sites, visual resources, sensitive plant populations or wildlife habitat. Existing roads would be

the primary control lines where practical, resulting in fire moving across unit boundaries. In some

unthinned patches, no direct ignition would occur (RPM 24 (p. 85). Control lines to prevent

prescribed fire from entering private lands or to manage the fire within the project area would be

constructed by hand crews or small to medium crawler tractors where existing barriers are not

available. Where resource protection is required, such as to retain large down logs, within sensitive

Riparian Reserve areas, or near cultural sites or plant populations, line may be constructed in

accordance with the developed resource protection measures.

• New fire control lines are approximately 2 feet wide when constructed by hand and up to 8 feet wide

where constructed by machine. Construction entails pushing the litter to the outside of the area to be

burned, resulting in a small berm of material alongside the line. Some small trees (typically smaller

than 10 inches DBH) and brush may be removed where there are limited openings to place the lines.

Alternatives 1 and 2 would require up to approximately 9.3 miles of control line with Alternative 3

requiring approximately 10.1 miles as shown in the fuels Alternative 3 map in Appendix D (Figure

Appendix E-6).

• Natural and activity-generated fuels would be ignited by ground crews or aerial ignition and burned

with a low to moderate intensity surface fire. When underburning within unthinned patches, vary the

ignition pattern to achieve minimal heat and scorching of residual trees and downed wood and the

levels of acceptable mortality for non-thinned areas listed in Table 27 and Table 28 and per RPM 24

(p. 85)

• Prescribed burning will be implemented to provide a result in a mosaic of retained levels of live

understory vegetation and will be in accordance with the prescribed levels of mortality listed in Table

27 and Table 28, as developed by the resource specialists and as agreed to with the U.S. Fish and

Wildlife Service and as described in (see RPM 24.)

• Rehabilitation of control lines post-burning includes dragging the bermed material, brush, and small

trees back over the line.

• Naturally ignited fires would be utilized and managed to accomplish underburning objectives as

appropriate.

Machine Pile and Pile Burn

Where there are heavy concentrations of coarse woody debris, typically more than 40 tons/ac (or as specified 

by the Project RPMs), machine piling will be utilized as a pretreatment before underburning to increase 

consumption of excess fuels over what underburning would accomplish and to limit adverse effects to wildlife 

habitat. 

Treatment-generated and natural fuels in excess of desired retention levels would be piled with mechanized 

equipment such as an excavator or tractor with a mounted brush rake or grapple designed to minimize soil 

disturbance. 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit A-37

Post-harvest piling will focus on the high fuel load/mortality pockets and machine piling passes will be 

limited to the extent needed to reduce fuel loads to the levels described in the resource protection measures. 

Treated areas would not be rigorously cleaned of slash material, and duff materials would be largely left in 

place for soil cover and erosion protection consistent with Forest Soil Quality Standards (Forest Plan p. 

Appdx. O), RPMs and BMPs. 

Piles would be burned when there is low fire danger and per the project burn plan specifications. 

Table Appendix B-3 list units where machine piling and pile burn treatments may occur to address potentially 

high fuel loading from ongoing mortality. The table lists the maximum potential piling acres (unit acres minus 

the unthinned patches) and the percentage and acres actually estimated to need piling. Monitoring would 

determine the actual need and extent of piling at the time of implementation. 

Table Appendix B-3. Estimation of Actual Machine Piling by Unit

Unit Treatment Summary

Alternative 1 Alternative 2 Alternative 3

Maximum 

Piling 

Acres

Highest % 

Estimated 

Need

Estimated 

Piling 

Acres

Maximum 

Piling 

Acres

Highest % 

Estimated 

Need

Estimated 

Piling 

Acres

Maximum 

Piling 

Acres

Highest % 

Estimated 

Need

Estimated

Piling 

Acres

6 Plantation Thin: Group 

Selection, Plant Groups 51.6 15% 7.7 51.6 15% 7.7 51.6 15% 7.7

12 Plantation Thin: Radial 

Thin 7.3 5% 0.4 7.3 5% 0.4 7.3 5% 0.4

13

Plantation Thin: Radial 

Thin, Group Selection, 

Plant Groups

9.8 5% 0.5 9.8 5% 0.5 9.8 5% 0.5

14

Plantation Thin: Radial 

Thin, Group Selection, 

Plant Groups

95.7 10% 9.6 95.7 10% 9.6 95.7 10% 9.6

18

Plantation Thin: Radial 

Thin, Group Selection, 

Plant Groups

74.7 15% 11.2 60.5 15% 9.1 74.7 15% 11.2

106 Plantation Thin 8.4 20% 1.7 8.4 20% 1.7 8.4 20% 1.7

107 Plantation Thin 9.9 20% 2.0 9.9 20% 2.0 9.9 20% 2.0

112 Underburn Only 14.5 100% 14.5 14.5 100% 14.5 14.5 100% 14.5

113 Plantation Thin: Interplant 32.6 10% 3.3 32.6 10% 3.3 32.6 10% 3.3

115 Plantation Thin 13.5 15% 2.0 13.5 15% 2.0 13.5 15% 2.0

123 Plantation Thin: Interplant 13.8 20% 2.8 13.8 20% 2.8 13.8 20% 2.8

124 Plantation Thin: Interplant 29.1 30% 8.7 29.1 30% 8.7 29.1 30% 8.7

125 Plantation Thin: Interplant 8.9 30% 2.7 8.9 30% 2.7 8.9 30% 2.7

126 Plantation Thin: With 

Meadow Enhancement 19.2 15% 2.9 19.2 15% 2.9 19.2 15% 2.9

151 Thinning of Natural Stand 43.7 70% 30.6 43.7 70% 30.6

152-

1

Thinning of Natural 

Stand: Radial Thin, Group 

Selection, Skips, Plant 

Groups

94.9 80% 75.9 86.9 80% 69.5 94.9 80% 75.9

154 Thinning of Natural Stand 104.2 80% 83.4 74.9 80% 59.9 104.2 80% 83.4

157 Thinning of Natural 

Stand: Radial Thin 136.0 100% 136.0 136 100% 136 136.0 100% 136.0
Elk Flat LSR Enhancement Project

A-38 Shasta-Trinity National Forest

Unit Treatment Summary

Alternative 1 Alternative 2 Alternative 3

Maximum 

Piling 

Acres

Highest % 

Estimated 

Need

Estimated 

Piling 

Acres

Maximum 

Piling 

Acres

Highest % 

Estimated 

Need

Estimated 

Piling 

Acres

Maximum 

Piling 

Acres

Highest % 

Estimated 

Need

Estimated

Piling 

Acres

158

Thinning of Natural 

Stand: Radial Thin, 

Interplant

119.4 80% 95.5 119.0 80% 95.2 119.4 80% 95.5

159

Thinning of Natural 

Stand: Radial Thin, 

Interplant

56.1 80% 44.9 56.1 80% 44.9 56.1 80% 44.9

160

Thinning of Natural 

Stand: Group Selection, 

Plant Groups

34.3 100% 34.3 34.3 100% 34.3 34.3 100% 34.3

162 Thinning of Natural 

Stand: Interplant 73.9 70% 51.7 73.9 70% 51.7 73.9 70% 51.7

163 Thinning of Natural 

Stand: Interplant 78.2 80% 62.6 76.6 80% 61.3 78.2 80% 62.6

164 Thinning of Natural 

Stand: Interplant 27.0 80% 21.6 27.0 80% 21.6 27.0 80% 21.6

165 Thinning of Natural Stand 24.5 30% 7.4 24.5 30% 7.4 24.5 30% 7.4

166 Thinning of Natural 

Stand: Interplant 10.6 80% 8.5 10.6 80% 8.5 10.6 80% 8.5

168-

1 Thinning of Natural Stand 5.7 10% 0.6 5.7 10% 0.6

169 Thinning of Natural 

Stand: Interplant 28.3 80% 22.6 28.3 80% 22.6

174 Thinning of Natural Stand 11.4 60% 6.8 11.4 60% 6.8 11.4 60% 6.8

175 Thinning of Natural 

Stand: Interplant 22.6 100% 22.6 18.6 100% 18.6 22.6 100% 22.6

176 Thinning of Natural 

Stand: Interplant 28.2 60% 16.9 28.2 60% 16.9 28.2 60% 16.9

177 Thinning of Natural Stand 12.1 40% 4.8 12.1 40% 4.8 12.1 40% 4.8

179 Thinning of Natural 

Stand: Interplant 4.8 100% 4.8 4.8 100% 4.8 4.8 100% 4.8

181 Thinning of Natural 

Stand: Interplant 2.2 100% 2.2 2.2 100% 2.2 2.2 100% 2.2

201 Thinning of Natural 

Stand: Interplant 12.0 100% 12.0 12.0 100% 12.0 12.0 100% 12.0

204 Thinning of Natural 

Stand: Interplant 13.5 100% 13.5 13.5 100% 13.5 13.5 100% 13.5

206 Thinning of Natural 

Stand: Interplant 100.5 100% 100.5 99.7 100% 99.7 100.5 100% 100.5

235 Thinning of Natural Stand 17.4 40% 7.0 17.4 40% 7.0

347 Thinning of Natural Stand 10.1 75% 7.6 10.1 75% 7.6 10.1 75% 7.6

Total 1,461 944 1,402 906 1,365 884

Extensive Mortality Area

An approximately 79-acre area of contiguous pine mortality within units 112, 158, 175, 204 and 206 was 

identified with little to no opportunity remaining to conduct thinning (see the fuel maps for alternatives in 

Appendix D). Hazardous conditions from the numerous snags present a safety hazard to project implementers. 

The Extensive Mortality Area would instead be burned (see discussion of underburning above) to reduce treat 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit A-39

heavy fuels, most likely utilizing aerial ignition techniques since it is unsafe to put firefighters on the ground 

or conduct other machine-based fuels reduction within this area. The Extensive Mortality Area fuels subunit 

overlays the underlying thinning units, however, no thinning will take place within it. This has been reflected 

in the greatly reduced harvest acres for unit 206 shown in Table Appendix B-2. The harvest acres for the other 

underlying units were not adjusted since the acres occupied by the extensive mortality area were not as 

substantial.

If conditions at the time of treatment are unsafe for thinning operations in all or portions of the remainder 

(outside of the Extensive Mortality Area) of these units, prescribed fire employed with felling and machine 

piling as feasible to provide operational safety, would be employed as an adaptive management strategy. The 

Extensive Mortality Area is not listed separately in Table Appendix B-2 or Table Appendix B-3, but enhances 

the treatments already described for the underlying units. 

The unthinned patches within the underlying units primarily consist of the larger snags, as described above in 

the Unthinned Patch section. The ignition patterns would vary within and around the snag retention areas to 

reduce impacts to standing snags as well as the natural regeneration and live tree components within and on 

the periphery of the units. 

Hydrologic Restoration Actions 

Recontouring

Heavy equipment such as an excavator would be used to contour old landings followed by seeding to restore 

floodplains, channels and meadows to pre-disturbance conditions. Recontouring would improve features to 

allow sheet flow, infiltration and groundwater storage across Elk Flat meadow and Ash and Swamp Creek 

Floodplains. Recontouring would improve or maintain water table depth. Buried large woody debris would 

add structure to meet natural contours.

Decommissioning of Unauthorized Routes

Routes would be decommissioned as described in the transportation section to remove stream/road 

interactions, and improve infiltration and function of intermittent channels. Decommissioning near stream 

interactions would involve recontouring as described above.

Riparian Revegetation

After initial activities are complete follow-up treatments will include planting and seeding of native riparian 

and upland (mesic) species that support riparian function. Areas will be planted with riparian vegetation along 

the channel banks and seeded with shrub species where needed, including within UTP areas. Several old 

landing areas (outside of UTP areas) will be recontoured and planted within the Ash Creek Riparian Reserve. 

Road decommissioning in Elk Flat will remove stream crossings along Swamp Creek Riparian Reserves 

where road runoff has eroded the channel. Recontouring activities will be followed by planting and seeding. 

Thinning in Riparian Reserves

Thinning as described starting on page B-22 within the Riparian Reserves would increase instream structure.

The table below lists the actions proposed for hydrologic function restoration. 
Elk Flat LSR Enhancement Project

A-40 Shasta-Trinity National Forest

Table Appendix B-4. Stream Flow, Water Table Elevation and Riparian Vegetation Restoration

Unit Feature Location RR Acres RR Length 

(ft.) Notes

Stream channel and floodplain Restoration: Unauthorized Route Decommission with Contour Stream and 

Floodplain

402 Swamp Creek U41N10A 3.7 800 UA route parallel to, 

and crosses channel.

347 Ash Creek

U41N02YB, 

U41N02YBA, 

U41N02YBB

4.4 900 Includes old landings in 

floodplain.

Subtotal 8.1 acres 1,700 ft

Stream Channel and Floodplain Restoration: Contour Stream and Floodplain, Add Low Profile/Embedded 

Woody Debris Structure

402 Swamp Creek 41N01YC 7.2 1569 Channel Parallel to 

Road no restoration

Riparian Reserve Revegetation

106 Ash Creek 1.11 42 No route.

107 Ash Creek tributary 41N97,

U41N97A 1.23 1000

113 Ash Creek U41N338 1.77 125 100 ft. decommission

150 Ash Creek 30.40 4241 No routes, 2641 ft.

plant, 1600 ft. no plant

154 Ash Creek 11.81 3220 No routes.

157 Ash Creek 10.45 330 No routes.

163 Ash Creek 7.46 2800 No routes.

180 Ash Creek 3.40 575 No routes

346 Ash Creek 17.06 780 No routes

152-1 Ash Creek 5.00 1800 No routes

152-2 Ash Creek U41N19XD 3.86 1100 190 ft. route 

decommission

346-U Ash Creek 1.33 115 No route

Subtotal 94.9 acres 16,127 feet

Road and Landing Actions 

Road actions are those necessary to directly respond to the Purpose and Need for Action or needed to 

implemented the other actions designed to meet the Purpose and Need for Action. Existing roads and 

temporary roads would provide access for harvest operations. Most roads are suitable for hauling forest 

products with pre-haul maintenance, and maintenance level 1 roads now closed to vehicles would be reopened 

for the project then closed again upon completion. Table Appendix B-5 lists actions by individual road or 

unauthorized route number. The alternative maps in Appendix D display the road actions, and descriptions of 

the actions follow the table below. All road and landing actions would conform to all resource protection 

measures (starting p.81). RPMs specific to roads and landings include 13 (p. 84), 14 (p. 84). 15 (p. 84), 16

(p. 84) and 17 (p. 84). Also see Standard Operating Procedures numbers 2 (p. D-1), 14 (p. D-2), 15 (p.D-3), 

18 (p. D-3), and 19 (p. D-3) and BMPs starting on page D-4. 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit A-41

Table Appendix B-5. Proposed Road Actions by Alternative

Route 

Number

Maint. 

Level

Road 

Name Miles Land Allocation

Alternatives 1 & 2

Action

Alternative 3

Action

Alternative 3 

Miles

41N01Y 2 Elk Flat 1.83 LSR Maintenance No Change No Change

41N01YB 1 Elk Flat 0.27 LSR 

Reconstruction, 

Use and Maintain 

for Project, Close

No Change No Change

41N02Y 1 Ash 0.88 LSR 

Open, Use and 

Maintain for Project, 

Close

No Change No Change

41N06Y 2 Flat 0.38 Matrix Maintenance No Change No Change

41N09 2 Thicket 0.55 LSR Maintenance No Change No Change

41N12 2 Cramer 

Springs 1.13 Matrix Maintenance No Change No Change

41N12D 2 Cramer 

Spring 0.10 Matrix Addition to the 

System No Change No Change

41N13 2 Swamp 

Creek 1.66 LSR Maintenance No Change 1.37

[-0..29] 

41N14 2 

Widow 

Spring 

East 

1.04 LSR Maintenance No Change No Change

41N19X 3 

FA -19 

Sugarpine/

Military

2.34 LSR Maintenance No Change 2.22

[-0..12] 

41N26Y 2 Sugarpine 

Intertie 0.24 LSR Maintenance No Change No Change

41N33 2 Coonrod 

Flat 0.69 LSR Maintenance No Change No Change

41N33A 2 Coonrod 

Flat 0.91 LSR Maintenance No Change No Change

41N33A 2 - 0.08 LSR Maintenance No Change No Change

41N46 2 Sugar Pie 1.12 LSR Maintenance No Change 0.79

[-0..33] 

41N54 2 Grey Eagle 0.45 LSR Maintenance No Change No Change

41N64 2 Elk Horn 0.88 LSR Maintenance No Change No Change

41N77 1 Ash Flat 0.47 LSR 

Open, Use and 

Maintain for Project, 

Close

No Change No Change

41N96 1 Ash Pot 0.58 LSR 

Open, Use and 

Maintain for Project, 

Close

No Change No Change

41N96A 1 - 0.66 LSR 

Open, Use and 

Maintain for Project, 

Close

No Change No Change

41N97 2 Deer Alley 0.37 LSR Maintenance No Change No Change

42N13 4 

Pilgrim 

Creek

(FA13) 

1.06 LSR Maintenance No Change No Change

42N13 4 

Pilgrim 

Creek

(FA13) 

0.92 Matrix Maintenance No Change No Change
Elk Flat LSR Enhancement Project

A-42 Shasta-Trinity National Forest

Route 

Number

Maint. 

Level

Road 

Name Miles Land 

Allocation

Alternatives 1 & 2

Action

Alternative 3

Action

Alternative 3 

Miles

U41N02YA - - 0.13 LSR 

Existing Temporary 

Road and 

Decommission

No Change No Change

U41N02YB - - 0.23 LSR 

Existing Temporary 

Road and 

Decommission

No Change No Change

U41N02YBA - - 0.02 LSR 

Existing Temporary 

Road and 

Decommission

No Change No Change

U41N02YBB - - 0.03 LSR 

Existing Temporary 

Road and 

Decommission

No Change No Change

U41N06YA - - 0.16 Matrix

Existing Temporary 

Road and 

Decommission

No Change No Change

U41N09A - - 0.04 LSR Decommission No Change No Change

U41N09B - - 0.19 LSR 

Existing Temporary 

Road and 

Decommission

No Change No Change

U41N10A - - 0.56 Matrix

Existing Temporary 

Road and 

Decommission

No Change No Change

U41N10A - - 0.07 LSR 

Existing Temporary 

Road and 

Decommission

No Change No Change

U41N10AB - - 0.08 LSR 

Existing Temporary 

Road and 

Decommission

No Change No Change

U41N10AC - - 0.19 Matrix

Existing Temporary 

Road and 

Decommission

No Change No Change

U41N12A - Cramer 

Spring 0.22 Matrix

Existing Temporary 

Road and 

Decommission

No Change No Change

U41N13A - - 0.23 LSR 

Existing Temporary 

Road and 

Decommission

No Change No Change

U41N13B - - 0.25 LSR 

Existing Temporary 

Road and 

Decommission

No Change No Change

U41N19XD - - 0.05 LSR Decommission Only No Change No Change

U41N19XE - - 0.05 LSR Decommission Only No Change No Change

U41N19XF - - 0.05 LSR Decommission Only No Change No Change

U41N19XG - - 0.05 LSR Decommission Only No Change No Change

U41N33 - - 0.62 LSR 

Existing Temporary 

Road and

Decommission

No Change No Change

U41N33B - - 0.66 LSR 

Existing Temporary 

Road and 

Decommission

No Change No Change
Draft Environmental Impact Statement

Shasta-McCloud Management Unit A-43

Route 

Number

Maint. 

Level

Road 

Name Miles Land 

Allocation

Alternatives 1 & 2

Action

Alternative 3

Action

Alternative 3 

Miles

U41N46A.1 - Sugar PieWidow 0.05 LSR 

Existing Temporary 

Road and 

Decommission

No Change No Change

U41N46A.2 - Sugar PieWidow 0.45 LSR 

Existing Temporary 

Road and 

Decommission

Decommission 

Only No Change

U41N46B - - 0.56 LSR 

Existing Temporary 

Road and 

Decommission

Decommission 

Only No Change

U41N46C - - 0.09 LSR Decommission No Change No Change

U41N52A - - 0.14 Matrix

Existing Temporary 

Road and 

Decommission

No Change No Change

U41N77A - - 0.35 LSR 

Existing Temporary 

Road and 

Decommission

No Change No Change

U41N96A - - 0.09 LSR 

Existing Temporary 

Road and 

Decommission

No Change No Change

U41N97A - - 0.19 LSR 

Existing Temporary 

Road and 

Decommission

No Change No Change

U43N19H - - 0.34 Matrix

Existing Temporary 

Road and 

Decommission

No Change No Change

U43N19HC - - 0.23 Matrix

Existing Temporary 

Road and 

Decommission

No Change No Change

Road actions include: 

Addition to the System

A 0.10 mile segment of unauthorized road U41N10A in the Matrix land allocation needed for current and 

long-term management objectives as recommended by the Travel Analysis Process completed for the Elk 

Project (Bonivert, 2015a p. Appdx. X) would be added to the system as a maintenance level 2106 road and 

maintained under all action alternatives. The road will remain open after completion of the project. 

Maintenance

Over the course of the project approximately 17.9 miles of road (includes roads described in all FTS road 

actions) would be actively maintained to standard as described in Standard Operating Procedures number 18 

on page D-3. Approximately 15 miles would require only road maintenance. Maintenance activities can 

106Forest Service Handbook 7709.59 (62.32) described maintenance levels (also see (Bonivert, 2015a)). Maintenance 

Level 1 roads are placed in storage between intermittent uses. The period of storage must exceed 1 year. Basic custodial 

maintenance is performed to prevent damage to adjacent resources and to perpetuate the road for future resource 

management needs. A maintenance level 2 road is open to high clearance vehicles. Maintenance levels define the level 

of service provided by, and maintenance required for, a specific road. Maintenance levels must be consistent with road 

management objectives and maintenance criteria.
Elk Flat LSR Enhancement Project

A-44 Shasta-Trinity National Forest

include grading, resurfacing, culvert cleaning, hazard tree removal, snow plowing, and slide removal (36 CFR 

220.6(d)4). After a road has been restored to its original condition, typical maintenance activities consist of 

dust abatement (watering) and administrative monitoring. The volume of road maintenance conducted on 

individual roads is directly proportional to unit size, treatment type and removal volume. Road adjacent to

larger units will require more truck trips over more days for treatment, increasing maintenance frequency and 

intensity.

Closed roads, classified as level 1 maintenance, are included in the total maintenance mileage. Typical 

maintenance activities for level 1 roads include maintaining the road barricade, signage and administrative 

monitoring for effectiveness. 

Reconstruction

Approximately 0.27 miles of existing FTS level 1 road (41N01YB) would be reconstructed to bring the road 

to standard, then maintained for the project and closed. Reconstruction is required when the existing road 

condition will not accommodate chip vans and logging trucks for removal of wood products and equipment 

transport and the work is beyond the scope of road maintenance. Road Reconstruction for this project consists 

of clearing and brushing, and installing, upgrading or replacing drainage structures, increasing road width and 

turn radius widening to restore the road to a useable condition. 

Temporary Roads and Landings

Temporary roads in harvest units across the project area would be used or constructed to provide access for 

harvest operations. Temporary roads provide access to landings, facilitate treatments and to comply with log 

skidding limitations where access is needed beyond 1⁄4 mile from a FTS road. Temporary roads provide a 

minimal road bed to direct operational traffic within harvest treatment units to protect resources. Previously 

created skid trails and the unauthorized routes in the project area would serve as temporary roads rather than 

constructing new temporary roads when possible to avoid new disturbance. Sections of unauthorized routes 

used as haul routes would be improved for equipment access and hauling as needed. Once project operations 

are completed temporary roads would be decommissioned. 

Landings averaging approximately 0.75 acres each would be utilized as available or constructed if needed to 

facilitate transfer of forest products to haul trucks. Actual landings would be approved on an individual basis 

based on the operator’s requests at the time of implementation and consistency with RPMs. 

Temporary roads, and landings would be decommissioned after project activities are concluded (see 

“Decommission” below). Given the generally flat terrain, temporary road construction will be minimal and 

the extent of decommissioning activities will be determined by the construction of the road. Typically, the 

entrance will be blocked, drainage patterns will be restored and the temporary road surface will be disturbed 

to break down compaction and allow the reestablishment of vegetation. 

Table Appendix B-5 lists unauthorized routes that would be available for use as a temporary road then 

decommissioned at the end of the project.

The table below displays the estimated temporary road needs by estimated landing within each unit, whether 

the temporary road utilizes an existing unauthorized route or is new construction, and by Alternative. 

Table Appendix B-6. Estimated Temporary Road Needs by Unit

Units 

Alternative 1

(feet) 

Alternative 2

(feet) 

Alternative 3

(feet) 

New Temporary Roads Associated with Existing Landings

6 100 100 100
Draft Environmental Impact Statement

Shasta-McCloud Management Unit A-45

Units 

Alternative 1

(feet) 

Alternative 2

(feet) 

Alternative 3

(feet) 

6 100 100 100

16 200 200 200

18 900 0 0 

106 200 200 200

123 200 200 200

124 50 50 50

154 50 50 50

154 425 0 0 

158 125 125 125

158 50 50 50

159 175 175 175

159 100 100 100

160 150 150 150

162 50 50 50

162 200 200 200

162 125 125 125

163 125 125 125

163 750 0 0 

174 125 125 125

178 75 75 75

208 50 50 50

402 700 0 0 

110, 158 75 75 75

110, 402 150 150 150

115, 154 50 50 50

117, 181 75 75 75

14, 153 700 0 0 

152-1 750 0 0 

153, 13 100 100 0 

154, 18 1175 0 0 

155, 226 50 50 50

157, 124 100 100 100

177, 402 200 200 200

179, 125 75 75 75

204, 402 175 175 175

206, 175 600 0 0 

318, 317, 402 200 200 200

Subtotal New Temporary Roads from 

Existing Landings

9,500 ft.

(1.8 miles)

3,500 ft.

(0.7 miles)

3,400 ft.

(0.6 miles)

New Temporary Roads from New Landings

6 125 125 125

6 125 125 125

7 0 0 250
Elk Flat LSR Enhancement Project

A-46 Shasta-Trinity National Forest

Units 

Alternative 1

(feet) 

Alternative 2

(feet) 

Alternative 3

(feet) 

14 125 125 125

14 125 125 125

16 125 125 125

18 125 125 125

107 125 125 125

151 125 125 0 

153,13 125 125 350

155 125 125 125

157 125 125 125

157 125 125 125

157 200 200 200

158 125 125 125

158 125 125 125

165 125 125 125

166 125 125 125

167 125 125 125

170 125 125 0 

172 125 125 0 

174 125 125 125

178 125 125 0 

206 125 125 125

206 125 125 125

402 125 125 125

402 700 0 0 

12,178 125 125 125

151,15 125 125 125

153, 14 125 125 125

157, 164 125 125 125

16, 152-1 125 125 125

165, 115 125 125 125

165, 117 125 125 125

169, 235 125 125 0 

170, 171 125 125 0 

201, 157 125 125 125

206, 175 125 125 125

169 125 125 0 

6, 154 125 125 125

6, 154 125 125 125

Subtotal New Temporary Roads from New 

Landings

5,650 ft.

(1.1 miles)

4,950 ft.

(0.9 miles)

4,550 ft.

(0.9 miles)

Total New Temporary Roads 15,550 ft.

(2.9 miles)

10,150 ft.

(1.6 miles)

7,950 ft.

(1.5 miles)
Draft Environmental Impact Statement

Shasta-McCloud Management Unit A-47

Closure

Five roads, totaling approximately 3 miles, are currently closed and will need to be opened for project related 

activities and closed again once project operations are complete. Approximately 0.27 miles of the 41N01YB 

road will also be reconstructed prior to project related use and closure. Road closure methods consist of 

physically blocking the road entrance, and may include installing water bars, removing and restoring drainage 

structures and stabilizing drainage features depending on site conditions. Maintenance Level-1 closed roads 

are not open to motorized vehicles but are considered to be in storage, retained for future management 

activities. Road closures would be implemented after project treatments are complete. Table Appendix B-5 

lists road-specific actions including closure.

Decommissioning

Decommissioning involves the demolition, dismantling, removal, obliteration107 or disposal of a deteriorated 

or otherwise unneeded road including the necessary cleanup work. Decommissioning eliminates the deferred 

maintenance needs for the road. Portions of a road or component may remain if they do not cause problems 

nor require maintenance. Decommissioning reestablishes vegetation and, if necessary, initiates restoration of 

ecological processes interrupted or adversely impacted by the unneeded road. Decommissioning includes 

applying various treatments, including one or more of the following 36 CFR 212.1 and as described in 

(USDA-FS, 2014a p. FSM 7734.1 ): 

1. Reestablishing former drainage patterns, stabilizing slopes, and restoring vegetation;

2. Blocking the entrance to a road or installing water bars;

3. Removing culverts, reestablishing drainages, removing unstable fills, pulling back road shoulders,

and scattering slash on the roadbed;

4. Completely eliminating the roadbed by restoring natural contours and slopes; and

5. Other methods designed to meet the specific conditions associated with the unneeded road.

In the Elk project, decommissioning methods for unauthorized routes will be determined on a route by route 

basis and may include seeding or mulch consistent with RPMs 15 and 12 in addition to the actions listed 

above. 

107 Obliteration is to unbuild, decommission, deactivate, or dismantle a road; the denial of use, elimination of travel way 

functionality, and removal of the road from the forest development road system; return of the road corridor to resource 

production by natural or designated means (Moll, 1996)

Draft Environmental Impact Statement

Shasta-McCloud Management Unit B-1

Appendix C-Issue Management 

Appendix B - Issue Management 

Introduction 

The Notice of Intent (NOI) was published in the Federal Register on February 28, 2013 (USDA-FS, 2013). 

The NOI asked for public comment on the proposal by April 1, 2013. In addition, as part of the public 

involvement process, the agency prepared a scoping document that was mailed or emailed to interested 

individuals, organizations and agencies on February 14, 2013 (USDA-FS, 2013b). A Notice of Intent was 

published in the Redding Record Searchlight on February 27, 2013 and March 3, 2013. Public meetings were 

held March 5 and March 26, 2013 in McCloud and Mt. Shasta. The Forest Service received 11 comment 

letters or emails.

The following individuals/groups responded to scoping: 

1. Richard Artley, email dated 3/4/13 and 3/8/13

2. Rich Svilich, American Forest Resource Council, letter dated 3/21/13

3. Phil Fesheen, phone call 3/1/13 and 4/1/13

4. Robert Hoover, Sierra Pacific Industries, letter dated 3/22/13

5. Doug Heiken, Oregon Wild, email dated 3/26/13

6. George Sexton, Klamath-Siskiyou Wildlands Center, letter dated 3/26/13 and email on 3/27/13

7. Denise Boggs, Conservation Congress, letter dated 3/28/13

8. Steve Holmer, American Bird Conservancy, email dated 3/29/13

9. Kimberly Baker, Environmental Protection Information Center, letter dated 4/2/13

All comments were reviewed. Issues were identified from public scoping comments. Issues are statements of 

cause and effect, linking environmental effects to actions. Issues serve to highlight effects or unintended 

consequences that may occur from the proposed action and alternatives, giving opportunities during the 

analysis to reduce adverse effects and compare trade-offs for the decision maker and public to understand 

(FSH 1909.15 Ch. 12.4). 

The Council on Environmental Quality regulations for the National Environmental Policy Act explains 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)....” As such, issues were 

categorized into two groups for this proposal: key and non-key issues. Key issues will be carried forward in 

the environmental analysis process as a way to develop alternatives (alternative driving issues) or analyze 

alternatives (analysis driving issues) (FSH 1909.15 Ch. 12.4). Key issues were defined as those directly or 

indirectly caused by implementing the proposed action. Non-key issues were identified as those that are: 1) 

outside the scope of the proposed action; 2) irrelevant or unrelated to the decision to be made; 3) already 

decided by law, regulation, Forest Plan, or other higher level decision; or 4) conjectural and not supported by 

scientific or factual evidence. Other Comments were non-issues (e.g. no cause effect) or were identified as a 

question or a general statement (general in nature). They will be addressed in this document. 

The following are issues and comments identified from public scoping. Comments/issues were paraphrased 

from sometimes lengthier or duplicative comments. Comments are also grouped by subject. The number 

preceding the comment indicates the commenter. For example, (1) = Richard Artley. 
Elk Flat LSR Enhancement Project

B-2 Shasta-Trinity National Forest

Analysis Driving Issues/Non-Key Issues/Other Comments 

Fuels/Fire

Comment-1 - Even though severe wildfire can be a significant CO2 emissions event, its chance of occurring and 

reaching a given stand relative to where the wildfire started is still very low, with or without fuel treatments on the 

landscape.(5)

In spite of what we often hear, that federal forests are not at imminent risk of destruction by wildfire. Fire return 

intervals remain relatively long, due to both natural factors and active fire suppression policies. Wildfire severity 

also remains moderate. Most wildfires are NOT stand replacing. Most fires are in fact low and moderate severity. 

(5) 

In an effort to advance the discussion and help the agencies conduct better risk assessments in the NEPA

context we have prepared a white paper in an attempt to clarify the critical considerations in a probabilistic risk 

assessment that compares the risk of logging versus wildfire. This report is most relevant in SW Oregon but the 

proposed evaluative framework is applicable in the east Cascades, northern California, and elsewhere. (5)

The probabilistic element of the risk equation demands careful consideration. Both logging and fire have 

meaningful consequences, so the issue really boils down to a comparative probabilistic risk assessment where 

risk is characterized by two quantities: (1) the magnitude (severity) of the possible adverse consequence(s), and 

(2) the likelihood (probability) of occurrence of each consequence. (5)

Discussion: See also the response to Comment-122 that addressed carbon and fire effects in the Northwest 

Forest Plan area over the last 20 years, including to late-successional old growth and northern spotted owl 

habitat. While fire occurrence has been very low in the Elk Flat LSR, fire hazard/fire risk in the 1999 LSRA

was determined to be moderate/moderate due to several large pockets of standing dead trees. Lightning 

caused fires accounted for 92 percent of the recorded fire occurrences. Due to the ongoing beetle outbreak, the 

incidence of dead trees has increased substantially. While snags and large down logs are an important habitat 

component in the project area, they also serve as a high fire hazard at the current densities. Widespread high 

concentrations of snags and down wood create a fuel hazard. With the current and projected fuel loads, the 

risk of human caused starts has increased, notably along roads, due to public firewood cutting. 

If a wildfire were to start during the summer fire behavior, current modeling (based on stand exam data) 

predicts rates of spread, flame lengths, and resistance to control that would lead to high acreage burned and 

significant post-fire adverse effects on resources. The high heat and potential for torching and spotting that 

would result from a fire in the heavy mortality areas presents a risk to current and developing latesuccessional habitat, adjacent private lands and WUI. Without action, the density-related mortality, further 

exacerbated by drought, disease and future insect attacks will continue to increase and spread throughout the 

project area, contributing to higher levels of standing and dead fuels and increasing the risk of high severity, 

stand-replacing fire. The high incidence of tree mortality leads to a high safety hazard for suppression 

activities. If no actions are taken, the tree mortality leads to our inability to safely place firefighters in these 

areas during a growing incident. This difficulty can lead to larger fires (Titus, 2015). 

This is the fourth year of drought in California. The United States Drought Monitor- California, classifies the 

area where the Elk project is located as “severe” (U.S. Drought Monitor, 2015). The severely dry local 

conditions resulted in unusual pre-fire season wildfires on the Shasta-McCloud Management Unit as well as a 

relative high number of fires on the unit that spread fairly rapidly, though were contained at relatively small 

acreages due to aggressive initial attack and availability of necessary resources. There were 82 total wildfires 

on the Shasta McCloud Management Unit this year, 48 of which were lightning caused ignitions. Some 

notable fires on the Unit include the following: 

• February 24th- Stevens Fire 200 Acres

• July 31st- Water Fire 30 Acres

• October 10th- Military Fire 58 Acres
Draft Environmental Impact Statement

Shasta-McCloud Management Unit B-3

The 10-year historical average of total fires in the United States has been 63,790 fires for a total acreage of 

6,571,723 acres. Total fires in the United States for 2015 to date have been 54,493 for a total acreage of 

9,753,465 acres. Overall, the number of fires has somewhat decreased across the United States but the fires 

we are having are getting larger (Titus, 2015). 

Comment-2 - We urge the USFS to aggressively treat areas in the McCloud Flats that are unhealthy due to various 

issues such as Annosus, overstocking, hazardous fuel loading, etc. Previous efforts by the Forest to treat only 

“Red & Dead” have proved unsuccessful and the Flats are now primed for catastrophic mortality from fire, 

insects, or both. (4)

Sierra Pacific Industries urges the Forest Service to continue proposing and implementing similar projects aimed 

at improving forest health and restoring fire adapted ecosystems. (4)

Discussion: The Elk project was designed to treat current mortality (red and dead), along with the 

surrounding forest stands to increase the resilience of the late-successional reserve and reduce the risk of 

further stand and late-successional habitat loss. Treatments in natural stands and plantations are designed to 

reduce stocking levels, increase tree size (thereby contributing to larger snags and down wood in the LSR), 

and increase diversity and within-and between-stand heterogeneity making the stands more resilient to 

uncharacteristic fire or epidemic insects and disease. 

The goal for the U.S. Forest Service’s Pacific Southwest Region is to retain and restore ecological resilience 

of the National Forest lands to achieve sustainable ecosystems that provide a broad range of services to 

humans and other organisms. A portion of the Forest’s ecological resilience strategy includes the Integrated 

Vegetation Management Strategy. The dominant Forest values emphasized for restoration and protection 

through enhancing wildfire resiliency were water, wildlife, and wildland-urban-interface. Key components of 

implementing the strategy include designing and developing treatments that meet multiple resource objectives 

and taking advantage of large contiguous areas for landscape scale (USDA-FS, 2013c p. SHF p. 99). The 

Forest is also operating in compliance with direction and standards and guidelines from the Northwest Forest 

Plan (NWFP), Forest Plan and Forest’s Late-Successional Reserve Assessment (LSRA) with the project 

where the balance between improving forest health, restoring fire-adapted ecosystems needs to be carefully 

weighed with the intent of the LSR’s function.

Comment-3 - Yarding tops and lopping and scattering should take care of most of the fuels issues within the treated 

stands. (2)

Discussion: Yarding tops and lopping and scattering is expected to minimize contributions to existing fuel 

loading in treated stands. To the extent possible, felled trees would be whole-tree skidded to designated 

landings for processing. Some slash would remain in the woods due to branch and top breakage during felling 

and skidding, or because of mechanical felling and yarding equipment limitations. For example, some trees 

that are over 24 inches at the stump may be hand felled with chainsaws, with the first two logs getting limbed 

to protect the residual stand from undue damage. The need for fuels treatment is based primarily on the 

existing natural fuels.

In areas with high levels of mortality (50-80% of more of a stand), the size and volume of fuels are too great 

to safely and effectively pile by hand or underburn only and thus are proposed for machine piling. Where 

there are heavy concentrations of surface and standing dead fuels that exceed the desired conditions as 

specified in the resource protection measures (typically more than 40 tons per acre), machine piling and 

burning of some piles would be utilized as a pretreatment before underburning. This would increase 

consumption of excess fuels over what underburning would accomplish, and would limit adverse effects to 

overstory trees, soils and wildlife habitat. Prescribed burning would help reduce excess fuels, but is also 

proposed to begin returning the natural role of fire to the ecosystem. 

Comment-4 - The location, timing, and severity of future fire events cannot be predicted making it difficult to 

determine which forests will benefit from treatment - consequently fuel treatments must be extensive and many 
Elk Flat LSR Enhancement Project

B-4 Shasta-Trinity National Forest

stands will be treated unnecessarily, thus incurring all the costs of fuel logging, but receiving none of the 

beneficial effects on fire behavior. (5)

Discussion: The commenter is correct that it is not possible to know exactly where, when, how many acres, or 

what the effects would be from a wildfire in the analysis area. As part of the No Action analysis, modeling of 

existing conditions and a fire start on 90th and 97th percentile weather days, and projected mortality, will be 

completed. As described in Comment-1, the project area conditions are such that if a wildfire were to start, the 

results could lead to high burned acreage and substantial resources effects. Project treatments are intended to 

reduce the risk of large-scale disturbance and increase stand resiliency to natural disturbances such as 

wildfire, insects, disease, and drought. Returning the natural role of fire to landscape is also an objective.

Treatments will promote stand structure and variability, biological diversity and characteristics of old-growth 

forests, while reducing overcrowding and fuel levels, allowing these stands to persist and/or grow into latesuccessional habitat (Franklin, et al., 2007; Blate, et al., 2009; Franklin, et al., 2002; Kennedy, et al., 2009; 

Stephens, et al., 2008; Stephens, et al., 2010). Restoring these features would also further allow disturbance 

processes to play their inherent role in maintaining these features (Noss, 2006). 

Comment-5 - Both the habitat and the NSO evolved with fire and can live with fire; the LSRA states wildfire is 

expected to occur in LSRs; and we are not persuaded by the WUI arguments. McCloud is 9 miles away and can’t 

be considered a WUI under any definition. The McCloud sub-division is 1.25 miles away and that area too is not 

considered a WUI by FS wildland fire researcher Bechsta. (7)

Discussion: LSRA desired conditions do indicate it is desirable to have low to moderate intensity fires burn in 

LSRs/MLSAs (p. 163). The LSRA also includes that the greatest threat to further loss and degradation of 

habitat for late-successional associated species is catastrophic wildfire within the California Klamath and 

California Cascades Provinces. It goes on to explain that fuel reduction treatments within LSR/MLSAs will 

be necessary given the extent of LSRs on the Forest landscape. Furthermore, fuel reduction activities within 

stands of late-successional and old-growth forest habitat will be essential to maintaining and protecting them. 

Low and moderate intensity fire is one of the important ecological processes that is essential for the 

development and maintenance of late-successional and old-growth forest ecosystems (LSRA p. 174). If 

meeting the LSR objectives, fuel reduction treatments are not considered incompatible with the LSRA. While 

NSO evolved with fire, the Revised Recovery Plan for Northern Spotted Owl includes, among other 

important range wide threats to spotted owl, “... ongoing loss of spotted owl habitat as a result of...habitat 

loss or degradation from stand replacing wildfire and other disturbances...” (USDI-FWS, 2011 pp. viii, II-2). 

The “Guidance for Implementation of Federal Wildland Fire Management Policy” (USDA-FS, 2009) defines 

WUI as “The line, area, or zone where structures and other human development meet or intermingle with 

undeveloped wildland or vegetation fuels”. Generally, the WUI on the Shasta-Trinity is concentric rings 

around structures, or groups of structures up to 1.5 miles, as described in the Fire Reference System. Within 

the Elk project boundary, the WUI is not associated with the community of McCloud, or the Mount Shasta 

Forest subdivision, but private land, with infrastructure to the southwest of the project boundary. WildlandUrban interface overlays land allocations and is displayed in Appendix D – Maps (Figure Appendix E-8). 

The project area incorporates approximately 1,135 acres of WUI within the Zone 4-Threat Zone as defined in 

the Forest’s Fire Reference System (USDA-FS, 2015). Zone 4 is the area beyond the 1⁄4-mile defense zone 

surrounding structures out to an approximate distance of 1.5 miles. The goal is to achieve an environment 

where crown fires, headed towards communities, become surface fires within this zone before encountering 

the “defense zone”. The wildfire behavior goal is to develop a fuels profile that will have moderate wildfire 

intensities determined by flame length of 4 to 8 feet or less on a 90th percentile fire weather day over most of 

the land base.”

Comment-6 - The project should carefully look at fuels reduction options. Hand piling should be the last option as it is 

very expensive and can lead to a nonviable project. (2)
Draft Environmental Impact Statement

Shasta-McCloud Management Unit B-5

Discussion: Fuel reduction options will be carefully assessed. As noted in Comment-3, some fuels are too 

large and thus hand piling is not a feasible option. In sensitive areas, hand piling may be used as long as it is 

safe to do so (material size, amount).

Comment-7 - The FS continues to trumpet the risk of wildfire which is virtually non-existent in the SMMU due to all 

the roads and clearcuts on private lands, and FS lands. In fact, the ‘risk’ of wildfire is driving this entire project. 

Again, we are curious to see the BAS the Forest is using in light of virtually all of the science in the past 5 years 

refuting the FS assertions, including papers researched by the FS. (7)

Discussion: Project area stand conditions indicate that wildland fire hazard is high for the project area even 

though historical starts (risk) are relatively low. As noted in Comment-1, the fire risk/hazard was identified in 

1999 as moderate/moderate due to the mortality pockets which have since substantially increased. As 

discussed in Comment-1, if a wildfire were to start during the summer, modeling predicts a high acreage 

burned and significant post-fire adverse effects on resources. High heat and potential torching and spotting 

from a fire in the heavy mortality areas presents a risk to current and developing late-successional habitat, 

adjacent private lands and WUI. This EIS and the fire and fuels analysis cite scientific literature relied upon.

Comment-8 -.The entire project area is proposed for underburning after thinning treatments are completed. Multiple 

similar projects have been proposed and implemented throughout the eastside of the Shasta-Trinity National 

Forest. Please provide timelines for fuel treatments and analyze and disclose; how successful or unsuccessful 

follow-up fuels treatments have been on forest timber sales, the likelihood of such treatments happening and 

how treatment goals and objectives would be affected if fuels treatments are not carried out. (9) 

Discussion: Fuels treatments can begin as soon as the timber sale is released by the timber sale administrator. 

We would typically burn the landing piles in the first winter after they are released. Any machine piling within 

post-harvest units, or other areas with high fuel accumulations, would typically begin the summer after is the 

area is available/released from the timber sale. Piling is typically done during the summer to ensure the 

material is dry, making for better consumption during burning. Machine piles would typically be burned the 

winter after they are piled, and the project may include protection measures for leaving some piles unburned. 

Underburning only could potentially occur at any time (depending on LOPs), but would be contingent on the 

timber sale operator and contract agreement. Underburning in harvest units could begin in the spring or fall 

(depending on LOP’s) after pile burning is completed. The SMMU fuels department also typically waits for 

an entire “burn block” to be available in order to take advantage of using roads as control lines. 

The SMMU fuels department also utilizes our own employees and our own equipment to complete all of the 

fuels treatments. We do not need to wait on funding to become available, or follow timelines for contracting. 

Our employees and our equipment are funded every year.

The SMMU fuels department has completed all of the piling that is available from past timber sales and 

restoration projects. We have approximately 1000 acres of underburning to complete. In fall 2015, we were 

able to complete second entry underburning. 

The SMMU has been very successful in completing follow-up fuels treatments quickly, and in accordance 

with any protection measures and new information by working with staff (soils, wildlife, botany and 

hydrology). Based on monitoring, most treatments have been very effective in reducing surface fuel loading 

and returning fire back to the landscape. In other cases, timing of burns or soil/duff conditions either resulted 

in too hot of a burn in certain areas (aspen), or inadequate fuel consumption in other areas. The SMMU will 

continue to monitor underburning, piling/burning and any other fuels treatments on a project-by-project basis 

and incorporate any lessons into an adaptive management program.

If follow-up fuels treatments are not completed for the Elk project in those areas where they are deemed 

necessary (machine piling, hand piling, underburning), the stands will not be entirely resilient for 

uncharacteristic wildfire, insects and disease. Surface fuel loading within the project area is currently well 

above Forest Plan standards. Fire exclusion has resulted in overstocking of white fir, cedar and pine 
Elk Flat LSR Enhancement Project

B-6 Shasta-Trinity National Forest

regeneration in the understory in some areas, excessive surface fuel loading and reduced nutrient cycling. 

Follow-up fuels treatments are essential for meeting the objectives of the Elk project. 

Forestry/Silviculture

Comment-9 - We urge the planning team to consider the following findings from your colleagues in the Rogue River 

Siskiyou National Forest contained in the 2012 Bybee timber sale EA indicating that proposed logging activities 

in the LSR may increase the impacts of existing pathogens:

A-15: Armillaria Root Disease “is often associated with trees under stress or where human caused disturbance is 

evident.”

A-15: Annosus Root Disease “fungus can be found fruiting in scuffed white fir and western hemlock 

stumps...infection and mortality are much greater in true fir stands that have been entered more than once than 

in stands that have not been entered...”

A-16: Black Stain Root Disease is “associated with roadsides, skid trails, landings, [and] with trees on compacted 

soils, recently cut thinning stumps and slash.”

A-17: Pine engravers are associated with logging slash and windthrow material.

Discussion: We recognize the insects and disease are important components of LSR, and that activities 

intending to reduce large scale risk can in fact contribute to changes in existing pathogens. The project 

includes design features or resource protections to limit undesired increases.

Armillaria is a root disease typically associated with sites that have been converted from oak stands to 

plantations. It can also be found around dead oaks that have died from suppression or other causes and are 

spreading the root disease to the surrounding conifers. Since this disease is more damaging in stressed stands, 

thinning to avoid overcrowding, and not cutting or killing oaks near conifers are recommended. 

Black stain root disease usually is found in areas where there has been significant site disturbance or 

substantial amounts of tree injury. Stands with black stain are usually densely stocked and consist of either 

pure or predominantly ponderosa pine. The largest and most rapidly expanding disease centers are often in 

cool, low lying sites with high soil moisture levels in the spring. Thinning to reduce the frequency of harvest 

entries and opening stands for warmer soils would inhibit black stain and reduce root contact between 

susceptible trees. Trees that are not hosts to black stain would be retained. Thinning generally from late June 

to early September would help limit impacts when insect vectors are most active. When establishing new 

stands near areas where black stain has been a concern, a mix of species should be planted. Reintroducing 

frequent low intensity ground fires into the landscape also disfavors black stain.

Annosus infection centers start when airborne spores produced by the conks land and grow on freshly cut 

stump surfaces of all species. Infection in true fir may also occur through fire and mechanical wounds on the 

butt. Fresh basal wounds on species other than true fir are rarely colonized. Treating freshly cut conifer 

stumps greater than 14” across with a borate compound will help reduce the infection sites created by the 

newly made stumps.

Pine engraver beetle (Ips) is most easily recognized by the rows of spines on the posterior ends of their wing 

covers. In standing trees, fading tops of large trees or whole crowns in small trees can be indicators of Ips 

infestation. Other external evidence consists of accumulations of boring dust in bark crevices and at the base 

of the tree. Thinning activities should be concentrated between the months of August and December so slash 

will dry out and will no longer be suitable for the first generation of beetles flying in April. An alternative 

approach is to generate enough additional fresh slash in mid-summer to absorb the emerging second 

generation and provide the beetles with an alternative to standing trees. Also, slash less than 3 inch diameter is 

of little consequence in terms of brood production for Ips. 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit B-7

Comment-10 - Ground-based logging causes higher incidences of root damage and scarring of residual trees 

(compared to skyline systems). (6) 

Discussion: The DEIS will disclose the effects of the proposed activities relative to forest health. Logging can 

create tree scars, which become potential infection sites for diseases, and insects can be attracted to the 

wounds. Tree wounds and root damage are kept to a minimum by discouraging operators from damaging 

trees. Mechanical and staged falling operations, proper skid trail design and contract provisions that limit tree 

damage (e.g. B6.32 Protection of Residual Trees) can address root damage and tree scarring as well as onsite 

sale administration of the contract. Project RPMs also help to minimize disturbance of soil and other 

resources values. Skidding and landing use will be restricted to existing skid trails and landings where 

possible. Adhering to BMPs will minimize erosion, compaction and subsequent root damage. The sale 

administrators work with operators to minimize disturbance and damage.

Comment-11 - Logging to control insects and disease is controversial and scientifically debatable. It has not proven 

to work in these watersheds. Please include and make available all science used to support any conclusions in 

the forthcoming NEPA document. (9)

There is even less evidence that we can control insects once an outbreak starts. Citing several sources Hughes 

and Drever (2001) assert that the weight of opinion seems to be that most control efforts to date have had little 

effect on the final size of outbreaks, although they may have slowed beetle progress and prolonged outbreaks in 

some cases. (6)

Bark beetles are always widespread and quite common. Even if an agency can control them in a stand of trees it 

is likely to have little impact on infestation on a landscape scale. According to Wilson and Celaya (1998), removal

of infested trees may provide some protection to surrounding trees, but these insects [Western pine beetle] are 

very common, so removal of a few infested trees is not a guarantee of protection. (6)

Although the Forest Service often asserts that the most effective means of reducing losses to the western pine 

beetle is by risk rating trees with subsequent removal of those that are high-risk. There is no evidence that this 

works to protect trees in a diverse forest.(6)

In some situations, removal of infested trees prior to emergence of brood is recommended in an attempt to 

protect surrounding trees. However, the overall effectiveness of this strategy is unproven (Wilson and Celaya 

1998). Further, in most forest situations, it is not feasible to locate and remove all trees prior to emergence. 

(Wilson and Celaya 1998) (6)

A recent report by the Xerces Society includes a summary of relevant studies on the importance of insects to 

forest function and the methods used to control forest ""pest"" insects, and a compilation of summaries of over 

150 scientific papers and Forest Service documents. The report may be downloaded in .pdf format from 

http://www.xerces.org/Forest_Pest_Myths/Logging_to_Control_Insects.htm" 

Key findings in the report include:

Native forest pests have been part of our forests for millennia and function as nutrient recyclers; agents of 

disturbance; members of food chains; and regulators of productivity, diversity, and density.

Fire suppression and logging have led to simplified forests that may increase the risk of insect outbreaks.

Forests with diverse tree species and age classes are less likely to develop large insect outbreaks.

There is no evidence that logging can control bark beetles or forest defoliators once an outbreak has started.

Although thinning has been touted as a long-term solution to controlling bark beetles, the evidence is mixed as to 

its effectiveness. The report also outlines general guidelines to follow when considering pest insects and forest 

management.

A review of over three hundred papers on the subject reveals that logging is not the solution to forest insect 

outbreaks and In the long run, logging could increase the likelihood of forest insect epidemics. (6) 

Even more striking is the paucity of studies that have examined the consequences of human intervention on pest 

movement patterns. In fact, we know of no studies that have experimentally evaluated the effects of 

management strategies on the dispersal of insect pests in forest systems. (6)
Elk Flat LSR Enhancement Project

B-8 Shasta-Trinity National Forest

As in the Elk project, logging is often recommended to control outbreaks of bark beetles but there is little direct 

evidence that this works. Much relies on the assumption that as tree vigor increases the trees are able to ward of 

infestation by insects. Some scientists have suggested caution in using thinning to control bark beetles as 

geographic and climactic variables may alter the effect. (Hindmarch and Reid 2001). Hindmarch and Reid (2001) 

found that thinned stands exhibited a higher attraction rate of mates by males of Ips pini, while females had 

longer egg galleries, more eggs per gallery and higher egg densities. Warmer temperatures in thinned stands 

also contributed to a higher reproduction rate. The number of males and females setting on logs was also higher 

in thinned stands. However, pine engravers in Arizona responded differently to thinning (see Villa-Castillo and 

Wagner 1996).(6)

Wickman (1990) detailed the effort to control the Mountain pine beetle (Dendroctonus ponderosae) at Crater 

Lake National Park from 1925 to 1934. Although he did not calculated how many trees in the areas were treated 

(cut down and then burned) in the nine year period, over 48,000 were treated in a three year period alone. The 

main lesson learned was that once a mountain pine beetle population erupts over a large area of susceptible 

forest type, and as long as environmental conditions remain favorable, there really is no way to stop it until 

almost all the susceptible trees are either killed or removed by logging. Treating trees perhaps slows the 

progress of the outbreak, but the outcome is inevitable. (Pg 38) Wickman (1990) The report goes on to state 

“Perhaps the cold winter in 1932-33 helped, but most importantly, the depletion of susceptible trees ended the 

outbreak rather than the annual control efforts for 10 years. Wickman (1990)"(6) 

"In 1984, lodgepole pine stands in central Oregon were once again infested with mountain pine beetle. By 1985 a

severe outbreak covered thousands of acres and extended south nearly to the park boundary. In 1986, beetlekilled trees were found in the northern end of the park (Wickman 1990). In the end the control methods did not 

work."(6) 

Discussion: Logging to control insects and disease is not proposed. The proposed treatments are aimed at 

reducing inter-tree competition and increasing the resiliency of these stands, which will increase the tree’s 

resistance to insect attacks when they occur.

Diseases, insects, and other natural disturbance factors are important shapers of landscapes. As described in 

the purpose and need, it is desired that levels of mortality from these natural disturbance factors are closer to 

endemic levels; about 0.2 to 0.5 percent of standing live biomass mortality per acre per year, with occasional 

spikes of 1.0 to 1.5 percent during drought periods. The project does call for providing conditions in treated 

stands that increase the capacity of remaining stands to respond to and withstand natural disturbances so that 

large habitat losses are not sustained (USDA-FS, 1999). 

Researchers began to recognize the importance of tree stocking control to reduce bark beetle activity in about 

1941 (Eaton 1941 in (Oliver, 1995). Within the last several decades, a number of studies examined the 

relationships between tree thinning to reduce bark beetle activity and risk. Many of the studies observed 

decreased bark beetle activity with decreased tree stocking required to prevent endemic and epidemic levels 

of bark beetle mortality in even-aged pine stands in Northern California levels ( (Fettig, et al., 2007; Cochran, 

et al., 1995; Cochran, et al., 1999; Schmid, et al., 2005; Oliver, et al., 1997; Fiddler, et al., 1989; Oliver, 

1995). They considered stand density index of 230 to be the “zone of imminent bark beetle mortality.” 

Variable density thinning does not include a singular density target, and instead is a treatment that thins to 

retain a range of densities by including areas of heavy thinning or small openings (radial release, gaps, or 

group selections), unthinned patches (UTPs that are also referred to as skips), and thinning within a target 

basal area range elsewhere within the stand. In any case, the thinning reduces stand densities. Scientific 

literature supports the use of thinning in ponderosa pine to lessen disease viability and spread ( (Kliejunas, 

1992; Otrosina, et al., 2007; Woodruff, 2002). Silvicultural treatments can be used to create conditions that 

increase stand resilience (promoting sustainability) and accelerate the rate at which larger tree sizes are 

attained. It can also be used to introduce spatial and species heterogeneity within stands. 

Comment-12 - While the Forest Service should examine, incorporate and respond to all of the relevant peerreviewed citations regarding insects and disease contained in the Xerces Report, we hereby especially highlight 

four papers for your consideration. 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit B-9

Schowater, T.D. 1990. Consequences of insects. In Symposium Proceedings. Forests –Wild and Managed: 

Differences and Consequences. January 19-20, 1990, pp. 91-106. University of British Columbia, Vancouver, 

BC. Franklin, J.F., D.A. Perry, T.D. 

Schowalter, M.E. Harmon, A. McKee, and T.A. Spies. 1989. Importance of ecological diversity in maintaining 

long-term site productivity. In Maintaining the Long-Term Productivity of Pacific Northwest Forest Ecosystems, 

ed. By D.A. Perry, pp 82-97. Timber Press, Portland Or.

Schowater, T.D. 1995. Canopy arthropod communities in relation to forest age and alternative harvest practices 

in western Oregon. Forest Ecology and Management 78: 115-25.(6)

Discussion: (Schowalter, 1990)and (Schowalter, 1995) are discussed in the Xerces Report. As summed in 

Xerces, the 1990 paper discuss that healthy trees and diverse forests, including old growth forest, are resistant 

to potential pests. The 1995 paper indicated that arthropod community structure diversity and abundance for 

several taxa was significantly lower in plantations than older forests and concluded that reduced predator 

diversity could lead to a greater likelihood of pest outbreaks. We were unable to locate Scholwalter et. al 

1989. 

The project maintains the largest oldest trees (predominants and dominants) that exhibit old-growth 

characteristics such as large boles, decadent branching, cavities and flattened tops would be retained as long 

as they are not a safety hazard. All predominant trees would be retained, regardless of their current health/ 

condition when marking. The preponderance of the activity is in thinning; reforestation of the groups/gaps is a 

small proportion of the treatment areas. Where that occurs though, the gaps will be planted with a mix of 

species to promote diversity.

The mixed conifer types in the project area support a variety of species in the overstory, while the ponderosa 

pine does to a lesser degree. Variable density thinning includes promoting stand structure variability, 

biological diversity and characteristics of old-growth forests by inducing fine-scale variation in homogeneous 

second-growth forest canopies. As noted about, the groups/gaps would be planted with a mixture of species. 

These may include ponderosa pine, sugar pine, Douglas-fir, incense cedar and hardwoods such as black oak. 

The assessment area also exhibits a mixture of age classes.

Comment-13 - AFRC wants to go on record of not supporting alternatives that set diameter limits within any land 

allocation. Concerned about diameter limited being counterproductive to meeting the purpose and 

need/hindering ability to meet identified desired conditions, incompatible with land management goals for this 

project area, arbitrary and capricious, not scientifically supported (e.g. why one particular diameter is more 

appropriate than another diameter. (2) 

Instead of setting arbitrary diameter limits it is much better to describe the desired stand conditions following 

treatment. Meeting those desired conditions can easily be monitored following implementation. (2)

It is critical as part of the NEPA analysis that desired stand characteristics for late-successional habitat is 

displayed. We ask that you display the desired levels of trees per acre by size class, desired stocking levels, 

desired snag and down log levels, and desired species makeup.(2)

The FS disclosed age classes but not diameter limits for the units proposed for logging. We specifically request 

this information be disclosed in the DEIS. (7)

Discussion: The Forest Plan has no standard and guideline pertaining to diameter limits for timber 

management. While there is no prescribed upper diameter limit for the project, or within specific treatment 

units, the largest oldest trees (predominants and dominants) and those that exhibit old-growth characteristics 

such as large boles, decadent branching, cavities and flattened tops would be retained as long as they are not a 

safety hazard. In some treatment units, diameter limits are prescribed to meet certain habitat objectives (e.g., 

when conducting California black oak release within critical habitat for the northern spotted owl, certain 

species of trees that are 24” or larger would not be cut to release oak). All predominant trees would be 

retained, regardless of their current health/condition when marking. We recognize the importance of large 

trees on the landscape for a variety of reasons including fire resiliency, various species’ habitat needs 
Elk Flat LSR Enhancement Project

B-10 Shasta-Trinity National Forest

(including NSO, northern goshawk, fisher and Pacific marten) and stand structural legacies, particularly in 

LSR. Desired stand conditions are described in the Purpose and Need in Chapter 1. 

Comment-14 - Note that the Thom Seider FEIS acknowledges that the diameter of conifer trees acts as a “measure 

of resistance to fire.” Hence the forest health and fire resiliency goals of the Elk LSR timber sale project may be 

best achieved by retaining such trees where they still exist in the watershed. (2)

Discussion: Fuel reduction actions designed to reduce fuels are based on several principles of forest fuel 

reduction in dry forests: reducing surface fuels, increasing the distance between surface fuel and the live tree 

crown (i.e. reducing ladder fuels), decreasing the density of tree crowns, and retaining fire-resistant trees

(Agee, et al., 2005). Trees to be thinned would primarily be midstory intermediate and smaller co-dominant 

trees; primarily the shade tolerant white fir. See also Comment-13 regarding retention of the largest oldest 

trees. 

Comment-15 - As a forest industry and being professional foresters we are very concerned that good forestry be 

practiced on the Forest Service land base. (2)

Discussion: The prescriptions were developed by a Certified Silviculturist. Best available science has been 

reviewed in addressing project conditions and for methods to reach desired conditions and to meet direction 

for the LSR and habitat recommendations for late-successional dependent species.

Comment-16 - Much of the area is currently experiencing extreme mortality due to black stain root disease and 

subsequent bark beetle attacks. Hundreds of acres are currently dying because of these conditions. It is 

imperative to control the spread of this mortality before the entire project area becomes affected. (2)

The Province Forest Pest Management (FPM) personnel have spent a considerable amount of time evaluating 

the current mortality. The FPM staff has prepared recommendations on what should be done to control the 

spread of the insect and disease problem. Many of these treatments are aggressive in terms of spacing 

treatments and tree removal. These treatments will be a cause concern by groups and individuals who do not 

have a concept of what it takes to deal with these disturbance factors or what it takes to responsibly manage the 

forest. It is imperative the Interdisciplinary Team fully utilize the findings of the FPM staff in order to fully meet the 

purpose and need of the project and stem the continued spread of mortality. It is also important because private 

lands are being affected by the lack of treatment occurring on the Forest Service land base. (2)

There have been enough public meetings for this project. This project has been on the radar since 2009. Given 

the dire conditions found across a large part of the project area, it is imperative that implementation occur very 

rapidly. The drought outlook highlighted by the Province Entomologist at the meeting re-emphasized the 

importance of enough talking and switching to emphasizing implementation. (2)

Discussion: As described in Chapter 1, there has been a marked increase in pine mortality over the past five 

years within the project area. Expanded areas of mortality were observed in 2010 and 2012 and have 

continued to expand. Mortality is occurring in the larger diameter (20-inch, plus) ponderosa pine as well as 

spreading throughout plantations of varying ages. The primary purpose of the Elk LSR project is to reduce the 

risk of stand and habitat loss in early, mid and late- successional habitat and to increase stand resilience to 

disturbance. Project actions were designed to address this need as well as other secondary needs, in order to 

meet the overarching objective for LSRs to protect and enhance conditions of late-successional forest 

ecosystems.

Comment-17 - Much of the area within the project area cannot be maintained as dense stands over the long-term. 

They are not resilient and historically never contained those types of stand conditions. The current insect and 

disease problem clearly highlights what will happen if dense stands are desired for the future. We ask that the 

analysis clearly display what type of late-successional habitat is sustainable for the long-term within this project 

area. (2)

The document states that stand composition is shifting from predominantly pine to mixed conifer. This is actually 

desirable for LSR/CHU and should not be a concern of the Forest. (7)

Discussion: As described in Chapter 1, approximately 75% of the 3,519-acre project area is classified as 

Ponderosa pine (Pinus ponderosa) forest. Southeast of Elk Flat, stands transition to a drier East Side Pine 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit B-11

forest type. In the northwest and western portions, approximately 10% is classified as Sierra Mixed Conifer 

(SMC) and 15% is perennial grassland (PGS). These designations for the project area are based on the 

California Wildlife Habitat Relationship (CWHR) System (CDFW, 2008) and cross-walked into the Forest’s 

2007 Existing Vegetation Layer from the Regional Office’s Remote Sensing Lab. While ponderosa pine is the 

primary stand component in the majority of the project area, it is also nested within mixed-conifer pine, and 

white fir-pine stands. The ponderosa pine-dominated stands are located within the eastern and southeastern 

portions of the project area, and the majority of the 20-40+ year old plantations. The younger plantations have 

a wider range of species mix. Ponderosa pine cannot sustain in the long term at high stand densities that 

provide over 70% canopy cover, and ponderosa pine-dominated stands do not provide for NSO nesting, 

roosting or foraging habitat. They can provide dispersal habitat, depending on specific stand conditions and 

other abiotic factors. 

Comment-18 - Radial thinning as disclosed is completely subjective and inappropriate in LSR/CHU. Discretion 

should not be given to either the FS or the timber contractors based on past performance. Trees must be marked 

for cut and that information disclosed to the public. (7)

Discussion: The described radial thinning is consistent with the goals and objectives of the Northwest Forest 

Plan, LSRA and recommendations for dry forest restoration principles within the Revised Recovery Plan. 

This type of treatment can help assure that legacy structures remain on the landscape and also contribute to 

increased heterogeneity and younger age classes. This type of treatment is primary proposed around the 

predominant legacy pine in the project area that remains at risk. How and where these pine will be released 

will be worked out through coordination and consultation with the public, the project silviculturist and 

wildlife biologist and the FWS during consultation. Based on the future prescription details of “how many” 

trees per acre or what species to radially thin, or areas to not use this treatment, the marking guides will 

dictate what trees are retained or removed. Additionally, LSRA activity design criteria 4 objectives, leave tree 

criteria, provide for culturing individual trees specifically for large crowns and limbs. The activity design 

criteria 4 treatment standards include up to 15 percent of the area in heavily thinned patches, or in openings 

up to 1/4 acre in size, to individual tree development. 

Comment-19 - There are many plantations planned for treatment within the project area. We believe the proposed 

Rx’s developed for these plantations fully meet the purpose and need for the project. Very wide spacing, creating 

openings for age class diversity, and promoting species diversity are clearly needed for these plantations. We 

will continue to support your proposals for treating the plantations within the project area and ask that you not 

modify those proposed Rx’s because of other unwarranted concerns. (2)

We ask you to develop prescriptions that truly meet the particular needs of the stands and land base. We have 

recently seen too many instances where prescriptions are developed to address public concerns from entities 

that have personal agendas and biases and have no background or knowledge of the forest environment and 

ecosystem. Prescriptions developed in these instances do not meet the needs of the stands, land allocation 

standards and guides, project purpose and need, and long term forest protection and health. (2)

We feel this project needs to treat as many acres as possible in order to fully meet your designated purpose and 

need. We encourage you not to reduce the project any further. (2)

Discussion: The general proposed actions that were developed and scoped were fully intended to address 

differences between Forest Plan and LSR desired conditions and existing ground conditions. This includes 

maintaining and protecting late-successional habitat. It is recognized that 24 percent of the project area is 

within plantations (10-40+ years old) where thinning and other mechanical treatments would occur, they were 

developed to reduce stocking and increase diversity, tree size and resilience. Part of the project’s design, given 

existing conditions, also includes precluding treatment in certain areas that are functioning as quality latesuccessional habitat. Part of the NEPA process however, does involve scoping. Public scoping is used in 

several ways but includes refining issues, establishing analysis criteria, and exploring possible alternatives 

and their probable environmental effects (FSH 1909.15 ch.10 [11]). Issues derived from public scoping serve 

to highlight effects or unintended consequences that may occur from the proposed action and alternatives, 

giving opportunities during the analysis to reduce adverse effects and compare trade-offs for the decision
Elk Flat LSR Enhancement Project

B-12 Shasta-Trinity National Forest

maker and public to understand. As such, there may be instances when alternatives, project design features or 

resource protection measures are proposed to address issues and compare tradeoffs for better decision making. 

See also Comment-15. 

Comment-20 - I am concerned about proposals to log snags in the Elk Flat LSR. (8)

Discussion: Generally, logging snags is not proposed. In the event conditions deteriorate post-decision and 

post marking, salvage of dead and dying trees may occur in conjunction with harvest in 12 ponderosa-pine 

dominated treatment units. The extensive mortality area would be prescribed burned to reduce heavy fuels. If 

safe, a combination of felling and machine piling may be used in this area. We recognize the importance of 

snags (and logs) on the landscape for a variety of reasons species’ habitat needs (including NSO) and stand 

structural legacies. The project includes specific criteria for retaining or protecting snags. For example, RPM 

40a requires that within all thinning and fuels treatment units in LSR, 7 snags per acre ranging from 15 to 20+ 

inches diameter with a preference for snags larger than 20 inches or the largest size class available would be 

retained, on average. RPM 40b requires retention of Douglas fir, sugar pine and incense cedar snags larger 

than 20 inches diameter, safety and species ID permitting. Groups of snags would also be retained, where 

safely feasible, in existing mortality pockets.

Comment-21 - The proposed action calls for creating a “buffer” of 50 feet around pockets of disease to prevent rootto-root contact as a means to thwart the spread of black stain and/or annosus. Does this mean you will thin 50 

feet past the most distal tree exhibiting mortality characteristics or signs of infection? What exactly is your 

definition of “buffer” in this situation? (4)

Discussion: The “young plantation thin with interplant” prescription applies to those young ponderosa pine 

plantations with recent mortality from blackstain root disease or Western Pine Beetle activity. These 

plantations have moderate/WPB varying to high levels of mortality, and often include scattered residual pole 

to young mature overstory trees (e.g. units 113 , 123, 124 and 125). Among other things, this prescription 

would remove all pine symptomatic of black stain and remove pine within 100 feet of symptomatic trees and 

mortality pockets (dead and dying trees) and outside of mortality pockets and the 100 foot buffer zones, thin 

pine to an average 50 foot spacing to avoid root-to-root contact and maximize growth, 

Comment-22 - We were somewhat amused at the Elk Flat 1944 photo that allegedly shows open space. The FS 

forgot to also state that the forested area in the 1944 photo no longer exists and has largely been clearcut. This 

isn’t 1944. We have climate change as well as a threatened species with designated critical habitat that didn’t 

exist in 1944. That photo is irrelevant to the discussion today. (7)

Discussion: It is not entirely clear what the commenter meant by “the FS forgot to also state that the forested 

area in the 1944 photo no longer exists and has largely been clearcut.” Based on 1998 aerial photography, the 

extent of the meadow at Elk Flat was less than 50 percent of its extent in 1944 (see also the 2012 and 1944 

aerial photography comparison, which shows continued meadow area loss from encroaching conifer, Figure 

12 in Chapter 1 for more information on Elk Flat). 

Elk Flat appears to be in a drying phase which is allowing tree encroachment to occur (in combination with 

other factors such as fire suppression). Currently, the water table is greater than a meter below ground surface 

in most years. In the past, sufficient seasonal runoff likely provided a higher water table with adequate soil 

moisture to support perennial grasses and forbs. Due to the current gully confinement, and lower seasonal 

water table, Swamp Creek is no longer able to hydrate the meadow. Although, during periods of snowmelt 

and rainfall, relict multiple channels on the meadow experience minor flooding and transport of sand and 

gravels, this is a minor contribution to the larger-scale disturbance required to maintain the natural opening. In 

addition to reducing conifer encroachment to restore the dry meadow system, restoration of the natural water 

table is also important to restoration of the Elk Flat dry meadow ecosystem. 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit B-13

While it is not specific to the treatment proposed in and around the edges of the meadow at Elk Flat, there is 

no designated critical habitat for the NSO in this area, and this area largely does not function as suitable or 

dispersal habitat for the NSO. See also the response to Comment-123 that addresses climate change.”

Comment-23 While it is not specific to the treatment proposed in and around the edges of the meadow at Elk Flat, 

there is no designated critical habitat for the NSO in these area, and this area largely does not function as 

suitable or dispersal habitat for the NSO.- The fact the FS would consider salvage logging of large dead trees, 

preferred by late-successional species; with regeneration harvesting and planting in an LSR and CHU speaks 

volumes to the fact this project is nothing more than a timber grab of old growth and late-successional trees. 

There is simply no legitimate science to back-up this method of logging in LSR/CHU. (7)

I am concerned about proposals to conduct regeneration logging and proposals to log large trees in the Elk Flat

LSR. (8)

Discussion: There is no regeneration logging or mechanical regeneration treatments proposed with the Elk 

project. The primary purpose of the project is to reduce the risk of stand loss in early, mid and latesuccessional habitat and increase stand resilience to disturbance. Other objectives include accelerating 

development of late-successional and old-growth forest characteristics and promoting connectivity; restoring 

Elk Flat meadow habitat; retaining and promoting hardwoods, etc., as described in Chapter 1. As described in 

the response to Comment-13, the largest, oldest trees are proposed for retention. Additionally, unthinned 

patches, designated no-treatment areas, and habitat roost/rest clumps would retain small and large tree 

patches, often with late-successional characteristics. Project actions and potential effects to habitat and species 

were and will be weighed seriously against the need for long-term habitat resilience and persistence. Best 

available science on restoring dry forest ecosystems and balancing those activities with species habitat and 

life-history needs was utilized to develop the project, including that provided by the public during scoping. 

The proposed silvicultural methods that increase resilience and restore heterogeneity within and between 

stands, and also maintain existing late-successional habitat elements (legacy structures such as large trees, 

snags, down wood) support the project’s intent (Franklin, 2002; Franklin, 2013; USDI-FWS, 2011; Blate, et 

al., 2009; Franklin, et al., 2007; Kennedy, et al., 2009) (Stephens, et al., 2008; Stephens, et al., 2010; Bull, et 

al., 1980; Marshall, et al., 2003a; Marshall, 2003; Lehmkuhl, et al., 2003; Wisdom, et al., 2000). The 

proposed action overall is consistent with the goals and objectives of the Northwest Forest Plan and LSRA, 

though certain actions will be reviewed by the Regional Ecosystem Office for consistency. For example, 

LSRA activity design criteria 6 addresses hazard reduction relative to blowdown, insects or wildfire (LSRA, 

1999 p. 189). LSRA activity design criteria #9 addresses fuel reduction and prescribed burning (LSRA, 1999 

p. 192).

Comment-24 We did not see any numbers regarding canopy closure? What is the canopy closure pre-project and 

post-project? This information needs to be disclosed in the DEIS. (7) 

Discussion: A suite of attributes relative to wildlife habitat, including canopy closure will be summarized in 

the affected environment portion of the Chapter 3 wildlife section in this EIS. The Biological Assessment will 

also include the pre- and post-canopy closure/cover information for proposed thinning stands. The reported 

post-treatment information is based on FVS modeling however (combined with monitoring of similar 

treatments), and should not be considered an absolute representation of post-treatment stand conditions. For 

example, the thinning that is modeled will not account for the retained unthinned patches and retained 

rest/roost habitat within thinning units that would continue to contribute to canopy closure and 

thermoregulatory sites closures within the stand. 

Comment-25 -. All treatments should be aggressive enough in order to maintain effectiveness for at least 30-40 

years.(2)

The analysis needs to display time frame effectiveness for the proposed treatments in terms of meeting the 

designed purpose and need and long-term desired condition. (2)
Elk Flat LSR Enhancement Project

B-14 Shasta-Trinity National Forest

Discussion: For the majority of natural stands, depending on the stand objective, the thinning prescriptions 

were developed to remain effective for about 20 years. Prescribed burning would be effective for about ten 

years and with the repeated burn entries (up to 3), would be effective for about 30 years. While not the 30-40 

year timeframe as suggested, it is consistent with direction from the Regional Forester (Blackwell, 2004). 

Timeframe effectiveness is discussed in Chapter 3.

Comment-26 The current stand conditions are in dire need of treatment. The NEPA analysis needs to state whether

the proposed action will meet the desired long-term stand and project objectives. If it doesn’t we want to know 

how many more entries will be required to meet the desired long-term stand characteristics. (2)

Discussion: The DEIS will discuss the alternatives achievement of purpose and need. A description of 

anticipated entries is included in Chapter 2, as needed (e.g. number of prescribed fire entries to meet desired 

conditions). See also Comment-25. 

Comment-27 - We also request how much old growth remains in the LSR and how much this project will log. We 

also request how much old growth acreage (NOT general late-successional habitat) that remains in the 5th field 

watershed for this project. On the STNF, old growth is defined as trees 180 years old and above. The project will 

log 150 year old trees, well on their way to old growth status. How many of these trees will be cut? We request 

stand exam data be included in the DEIS or Silviculture Report that documents the exact units and number of 

trees 80 years old and above, that will be logged and their diameter limits. This information must be disclosed 

since the Forest states that variable density thinning will be based on “average tree diameter.” We are also 

opposed to this method of thinning since basal areas for units can’t be disclosed. The Forest can’t ensure 

adequate basal area will be maintained in late-successional habitat without disclosing the pre and post project 

basal areas for each unit. (7)

Discussion: The project will not treat old growth stands (there are none). Scattered, individual trees, remnants 

from historic stands, are occasionally present. Within treated stands, all predominant and most dominant trees 

would be retained, regardless of their current health/condition when marking. The largest oldest trees that 

exhibit old-growth characteristics such as large boles, decadent branching, cavities and flattened tops would 

also be retained as long as they are not a safety hazard. The stand age range for the oldest treated stands in the 

project is 80-120 years old, though there are remnant trees that are older within these stands and these fit into 

the ‘predominant’ and late-successional trees with old-growth characteristics. Common Stand Exam data was 

collected in 2007 and will be included in the project record. It was and will be utilized to model the estimated 

tree growth and snag development post-treatment and 20 years post-treatment. Stand age ranges are also listed 

by unit in Appendix A, Table Appendix B-1. The seral stage information for the 5th field watershed will be 

included in the vegetation diversity report, the silviculture report or included in the EIS. 

The scoping document does not state that “variable density thinning will be based on “average tree diameter””

as noted in the comment. Rather, it states: “Forest stand species diversity, hardwood diversity, existing 

openings, large down logs, snags and other structural components of suitable NSO habitat have been 

documented and these areas are either targeted for retention in variable density thinning prescriptions, or 

would be included in the 10 percent unthinned areas within LSR treatment units....Residual density in the 

natural stand thinning units would vary from an average 125 to 175 square feet of basal area per acre, but may 

be higher or lower depending on species composition and current habitat function for NSO. Depending on the 

average tree diameter, this equates to approximately 60 to 100 trees per acre. Lower densities would be 

applied in areas that are predominantly dominated by ponderosa pine and higher densities would be retained 

in mixed conifer and white fir dominated stands. Higher densities would also be retained where clumped 

groups of large trees, and smaller biomass sized (trees <10 inches DBH), occur to provide for age class and 

structural variability. Instead of applying one target basal area across a stand, the variable density thinning 

prescription would help promote within-stand structural heterogeneity that contributes to habitat function for 

late-successional species while providing the needed growing space, nutrients and water for the remaining 

trees.” While tree diameters are mentioned, it is not as a function of tree selection during the variable density 

thinning treatment, but as a measure to describe the estimated residual trees per acre.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit B-15

Comment-28 - The agency must carefully review and document their consideration of all the reasons not to log 

mature forests set forth in this paper: To address this short-fall of old-growth forests it is necessary to protect 

mature forests and trees because (a) they are already provide some values associated with old growth forests 

and b) they are poised to become old growth more quickly. This paper also urges not just conservation of 

existing old growth but also the ecological processes that sustain and continuously recruit old growth. (5)

If mature forest is left unprotected, some members of the environmental community will distrust the agencies and 

oppose them on many fronts. (5)

Leaving mature forests unprotected would leave substantial areas of roadless lands subject to future conflict. 

Many westside roadless areas may not qualify as old-growth, but still provide important values as roadless and 

mature forests. (5) 

"Why Mature Forests Must be Protected. “As recognized by FEMAT, a conservation strategy for the Pacific 

Northwest must consider mature forests as well as OG. Forests are considered to enter maturity when their 

mean annual increment culminates, following which time they begin developing the characteristics that ultimately 

produce OG. Mature forests serve various important ecologic functions. They serve as future replacements for 

old-growth, help protect existing OG by reducing the starkness of age-class boundaries, and provide landscape 

connectivity and transitional habitat that compensate to some degree for the low levels of OG. Moreover, they 

are almost certainly more resistant to crown fires than younger forests, and hence contribute to buffering the 

landscape.” (5)

Mature forests provide essential habitat for the species we are most concerned with such as: spotted owl, 

marbled murrelet, Pacific salmon, and most of the “survey and manage” species.

There is a serious region-scale deficit in mature and old-growth forest habitat. Over time, the Northwest Forest 

Plan seeks to re-establish 3.44 million acres of mature and old-growth forest 

(http://web.archive.org/web/20030402090844/http://www.fs.fed.us/land/fm/oldgrow/oldgrow.htm) (Accessed 

7/31/2012).

By continuing to log mature forests we are significantly delaying this recovery. If we are going to make a timely 

recovery from that deficit, and give struggling species a chance to survive the habitat bottleneck that we have 

created, we must protect mature forests so that they can become old-growth, and we must manage young forest 

so they can become mature. (5)

The transition from mature forest to old growth is a process that takes time and varies depending on factors such 

as location and species and disturbance events. In a mature forest, all the ingredients are there to make old 

growth (e.g., large trees) and the scientists agree that these forests need protection to help meet the current oldgrowth forest deficit. (5)

Protecting mature and old-growth forest leads to a real ecological solution, while protecting only old-growth is 

merely a partial solution to an ecological problem that is bigger than just old-growth. (5)

Cutting mature forest will remain controversial and socially unacceptable. If we seek to resolve conflict over 

management of older forests, protecting the old-growth while leaving mature forests unprotected would be only 

half a solution and would lead to more conflict. Shifting to a restoration paradigm gets everyone at the table 

working toward the same goal. (5)

The architects of the Northwest Forest Plan found that many of our best large intact forest landscapes are 

mature forests, not old-growth. Some large forest fires burned westside forests between 1840 and 1910 and 

many such areas were skipped over by the timber harvest planners because they were more intent on converting 

the very old forests to tree plantations. These former fire areas, now mature forests, offer some of our best hopes 

of recreating large blocks of intact older forest. (5)

The agency must protect mature forests because they are the best candidates to grow and develop into oldgrowth habitat in the shortest time frame. (5)

Discussion: Initial logging occurred in the project area in the late 1800s and early 1900s. Large overstory 

ponderosa pine and sugar pine as well as Douglas-fir were preferentially removed, with smaller trees and less 

marketable species being left. Selective overstory cutting has occurred over roughly the last 20 to 40 years.

The average measured age of the natural stands is approximately 55 to 95 years (while the estimated stand 

ages in natural stands are 60-90 or 80 to 120), with a minor scattered component of older remnant trees (see 

also Comment-27).
Elk Flat LSR Enhancement Project

B-16 Shasta-Trinity National Forest

Mature forests are defined as stands are generally greater than 80-100 years old and less than 180-200 years 

old (USDA-FS, 1994 pp. FEIS Glossary p. F-4, VIII-II) (FEMAT, 1993 pp. IX-20). Old-growth forests are 

defined as forest stands usually at least 180-220 years old (USDA-FS, 1994 pp. FEIS Glossary p. F-4, VIII-II)

(FEMAT, 1993 pp. IX-24)in wet climates, on productive sites, old-growth characteristics can begin to develop 

as early as 150 years. On dry sites (such as the project area), stands may be well over 180 years before these 

characteristics develop (LSRA, 1999 p. 1). As described at Comment-36, per the Forest Plan (pp. 4-37) and 

Northwest Forest Plan (pp. C-13), while risk reduction efforts should generally be focused on young stands, 

activities in older stands may be appropriate if: (1) the proposed management activities will clearly result in 

greater assurance of long-term maintenance of habitat, (2) the activities are clearly needed to reduce risks, and 

(3) the activities will not prevent the LSR from playing an effective role in the objectives for which they were 

established. The Northwest Forest Plan indicates younger stands are stands less than about 80 years old 

(USDA-FS & USDI-BLM, 1994 pp. C-12). 

See Comment-13 for retention of the largest, oldest trees. The project specifically retains (does not treat) 

unthinned patches and habitat roost/rest clumps. 

The project area is well roaded; containing an approximate road density of 3.32 miles per square mile (does 

not meet the criteria of a roadless area)108. 

Comment-29 - Cutting mature forests is not needed for ecological reasons. These forests are already exhibiting the 

characteristics that provide excellent habitat and they continue to develop and improve without human 

intervention. As recognized in the Northwest Forest Plan standards and guidelines for Late Successional 

Reserves, stands over 80 years old do not need to be manipulated to become old-growth. All the ingredients are 

there, they just need time. (5)

Discussion: Many of the natural stands in the Elk LSR contain elements of late successional habitat and 

provide stand structural conditions suitable as either spotted owl nesting/roosting or foraging habitat. These 

stands generally meet all of the Forest Plan classification elements of older late-seral stands except for canopy 

closure. Currently, there is a shortage of high quality late-successional habitat in the Elk Flat LSR. Many latesuccessional stands are deficient in structural diversity. 

As described in the Chapter 1 however, these stands are at risk of loss from large-scale disturbance events 

such as insect outbreaks, diseases, and fire. The project was designed to enhance and protect important late 

successional habitat and components in the project area in the short term while addressing objectives to 

reduce large-scale risk, accelerate development of late successional habitat, and other stated project needs.

Comment-30 - Complicated environmental analysis will be required for logging mature forests compared to thinning

plantations. Wildlife surveys will be needed. Environmental Impact Statements will more often be needed instead 

of abbreviated Environmental Assessments. Formal consultation under the Endangered Species Act will more 

often be triggered. (5)

Discussion: The DEIS and/or supporting specialist reports will address Forest Plan and other laws, 

regulations, and policy including regulatory consultation requirements. 

Comment-31 - The FS states there are currently 46% late-successional habitat, 30% mid-successional habitat, and 

24% early-successional habitat in the project area. What will these figures be post project? This information 

needs to be disclosed in the DEIS. The document states it takes several hundred years to grow old growth and 

late-successional habitat required by late-successional species. In our view this project will return the area to 

mostly early-successional habitat. How does that improve the LSR/CHU and old growth habitat? (7)

108 Undeveloped areas typically exceeding 5,000 acres that met the minimum criteria for wilderness consideration under 

the Wilderness Act and that were inventoried during the Forest Service’s Roadless Area Review and Evaluation

(RARE II) process, subsequent assessments, or forest planning.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit B-17

Discussion: None of the action alternatives would reduce the percentage of late-successional forest in the 

watershed or project area, though the no action alternative is actively reducing late-successional ponderosa 

pine forest (units 204, 206) and portions of this stand element in other parts of the LSR. Thinning treatments 

would retain all of the predominant trees as well as the majority of the dominant and most of the codominant 

trees within the stand (provided they are not a safety hazard). Thinning treatments would also result in lower 

basal areas overall by thinning from below the suppressed, intermediate and some codominant trees, but 

would not change the age classes that remain on the landscape. The thinning treatments would increase the 

average stand diameter and concentrate site growth potential on the residual trees maintaining, while 

enhancing, mature late-successional forest characteristics that are more resilient over time. In the long term, 

this would accelerate development of old growth late-successional forest characteristics in the thinned stands 

of larger diameter trees, larger diameter snags and larger down wood. 

Comment-32 - We do not need to log mature forest to provide jobs. Less than 2% of the jobs in Washington and 

Oregon are in the lumber and wood products sectors, and only a small fraction of those are on federal land and 

only a fraction of those are related to mature forest logging. Many more environmentally benign jobs are 

available in restoring roads, streams, thinning young plantations, and managing fire and recreation. (5)

We do not need to log mature forest to prop up the economy. The NW economy has greatly diversified in the last 

decade. Our economy typically creates more new jobs every year than exist in the entire lumber and wood 

products sectors (5). 

We do not need to log mature forest to prop up the timber industry. Less than 10% of the logging in Oregon and 

Washington in recent years has been on federal lands. Only a fraction of that is mature forest. Much more 

environmentally benign and socially acceptable timber can be derived from thinning young plantations or small 

diameter fuel reduction where it is appropriate. (5)

Discussion: The project actions were developed to address the gap between existing and desired conditions 

(and not to prop up the economy). Proposed treatments would be accomplished through a variety of methods, 

which may include service contacts, stewardship contracts, commercial timber sale contracts, force account 

crews, etc., which may result in jobs and economic benefits to the local area. 

Comment-33 - Since managing these stands is not "needed" for any ecological reason or any economic or social 

reason, what would be the objective? (5)

Discussion: The project objectives are described in chapter 1, under the Purpose and Need section, which are 

based on an ecological need and direction from the NWFP, Forest Plan and Forest’s Late-Successional 

Reserve Assessment.

Comment-34 - When developing measurement standards for NEPA implementation do not use crown closure. There 

is no one set way to measure crown closure before or following treatment. No method has been developed that 

gives the same or an accurate measurement. (2)

The measurement standards need to be something that can be measured correctly before and following 

treatment; basal area, trees per acre, stand density index, spacing, etc.(2)

Discussion: Overall, crown closure will not be used as a target measure for purpose and need achievement. It 

may be used to describe certain effects or nuances, however in terms of qualifying and quantifying habitat 

changes from the treatments. It is also often used as a measure of connectivity, and to define dispersal, 

foraging, nesting/roosting, and resting/denning habitat for the NSO, northern goshawk, fisher and other 

species, such as rare plants and mosses. 

Comment-35 - It is essential that that public and the Decision Maker know via NEPA the number and size of trees to 

be logged prior to a decision being made to implement the timber sale. This is particularly relevant for older trees 

>30”dbh. Please estimate the number mature trees (20-30” dbh) and the number of “old growth” trees >30” dbh 

that would be logged from each unit. The most informative way of disclosing this data would be to report the prelogging number of trees in these size classes and the post-logging number and size of trees in these size 

classes. We have previously reviewed modeled results of these data for other timber sales thus the data is 

available for NEPA purposes and the Forest Service is required to disclose for comment and analysis prior to 
Elk Flat LSR Enhancement Project

B-18 Shasta-Trinity National Forest

issuing the decision to implement the project. The proposed action must demonstrate that this standard is being 

met for each unit logged. (6)

Discussion: Please refer to Comment-13 for retention of the largest oldest trees.

LSR

Comment-36 - Regen harvest in a LSR will have significant effects including: land allocation conflicts, precedence 

setting significant and long-term loss and degradation of forest cover and habitat, Forest Plan violation, public 

and scientific controversy, impacts to listed species, impacts to ecologically critical areas, etc. (5) 

Discussion: There is no regeneration logging or mechanical regeneration treatment proposed with the Elk 

project. The DEIS and supporting analyses will disclose the effects of the proposed activities. Thinning or 

other silvicultural treatments inside LSRs may occur in stands up to 80 years of age if the treatments are 

beneficial to the creation and maintenance of late-successional forest conditions (USDA-FS & USDI-BLM, 

1994 pp. 8, C-12, C-13, C-26). In addition, while risk-reduction efforts should generally be focused on young 

stands, management activities may be appropriate under the Northwest Forest Plan to reduce the risk 

associated with large-scale disturbance in existing late-successional habitat East of the Cascades and in the 

Oregon and California Klamath Provinces. These activities are considered appropriate -if: 1) the proposed 

management activities will clearly result in greater assurance of long-term maintenance of habitat; 2) the 

activities are clearly needed to reduce risks, and 3) the activities will not prevent the LSR from playing an 

effective role in the objectives for which they were established (USDA-FS & USDI-BLM, 1994 pp. C-13). 

The project will be reviewed by the Regional Ecosystem Office and/or Regional Interagency Executive 

Committee where thinning or other silvicultural activities in LSR are neither consistent with the LSRA nor 

fall under a specific REO review exemption. 

Comment-37 - Logging old growth, dominant and co-dominant trees over 80 years of age is a violation of the NWFP

and 2011 Recovery Plan and will adversely modify habitat and adversely impact NSO. (7) 

Discussion: The DEIS will disclose the effects of the proposed activities relative to consistency with direction 

from the NWFP, Forest Plan and the Forest’s Late Successional Reserve Assessment.. Large-scale disturbance 

risk reduction activities may occur in stands older than 80 years of age if they meet the three criteria described 

in Comment-36. The 2011 Revised Recovery Plan for the Northern Spotted Owl also does not provide a

definition of an old-growth tree, but instead discusses the suite of conditions that characterize old-growth 

forest, stating that “[o]ld-growth forests are forests that have accumulated specific characteristics related to 

tree size, canopy structure, snags and woody debris and plant associations....Old-growth forests support 

assemblages of plants and animals, environmental conditions, and ecological processes that are not found in 

younger forests (younger than 150-250 years) or in small patches of large, old trees,” (USDI-FWS, 2011). 

Recovery Plans are also non-regulatory (USDI-FWS, 2011 pp. I-3), and the Recovery Plan for the NSO 

includes recommendations for a recovery strategy and recovery actions. The Forest designed the Elk project 

to be consistent with applicable recovery actions (10 and 32). An in-depth analysis of treatment prioritization 

and rationale to support the Forest’s contention that it is consistent with the recommendations will be included 

in the project record. Certain proposed treatments may result in an adverse effect to elements of critical 

habitat, but are not expected to adversely affect any NSOs (e.g., oak release in critical habitat, radial thinning

depending on amount of area and species affected). At present, there are no NSOs occupying the project area, 

or the historic activity center associated with the project. We kindly refer the reader to the Final Rule (USDIFWS, 2012 p. 71939) for a description of what may potentially constitute an adverse effect to NSO critical 

habitat. If it is determined by the Forest Service that the project will adversely affect critical habitat elements, 

that determination will be disclosed and supported with the best available scientific rationale in the Biological 

Assessment. If that determination is made, then the FWS will make a determination during formal 

consultation on whether the project has an adverse modification on the entire designated critical habitat (also 

see the Final Rule (USDI-FWS, 2012 p. 71940) for a description of adverse modification and destruction of 

critical habitat and what the FWS’ responsibilities entail). 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit B-19

Comment-38 - A considerable part of the LSR is not conducive to growing dense stands of conifer trees that are 

more representative of Northern Spotted Owl (NSO) habitat commonly found on the western portions of the

Shasta Trinity National Forest. This area is more conducive to growing open grown forest stands, especially 

where ponderosa pine is the dominant species. (2)

We understand the US Fish and Wildlife Service (FWS) have canopy closure requirements for various habitat 

classifications (nesting/roosting, foraging, and dispersal) for the NSO. We are not sure whether there is research 

that shows 60% canopy closure can be sustained for nesting/roosting habitat in this forest type. (2)

The current stand characteristics are artificial only having developed over the last 100-150 years. These kinds of 

stand conditions did not exist prior to that time frame. Any treatment done to meet standard NSO canopy closure 

levels will only have short term effectiveness, 10 years or less, in terms of meeting the objectives of stand 

development and protection. Historically, old growth stands within this forest type did not have the levels of 

canopy closure required by the FWS. It will be absolutely necessary to articulate to the FWS what kind of 

vegetative conditions should be grown for long term sustainability and resiliency. (2)

Discussion: See the response to Comment-17. The Elk Flat LSR was identified as an area of important latesuccessional habitat during the late-successional mapping effort (LSRA p. 124). Stands that meet all of the 

Forest Plan classification elements of older late-seral stands do so except for canopy closure.

Comment-39 - It must be remembered the LSR network was not just set up to grow NSO habitat. It was designed to 

grow late-successional habitat that can be resilient and sustained on any given vegetative type and ecosystem. 

The intent of the Northwest Forest Plan was to grow long-term late-successional habitat based on land 

capability. (2)

Discussion: Within the Elk Flat LSR, 2,836 acres are capable of supporting late-successional habitat (LSRA 

p. 125). Of lands capable of supporting-late successional habitat, 1,306 acres (46% of capable acres within the

LSR) were in late-successional habitat as of the publication of the LSRA. Currently, there is a shortage of 

high quality late-successional habitat in the Elk Flat LSR. Many late-successional stands are deficient in 

structural diversity. See also Comment-29. 

Comment-40 - We believe that retaining large diameter trees and snags where they still exist would benefit the 

project in a number of ways. Large trees are a primary element of late successional habitat function, which this 

project seeks to retain. Retaining large trees in the project would greatly reduce the scientific and social 

controversy regarding the harvest prescription. Large trees provide disproportionate hydrological benefits to 

these watersheds. The crowns of such trees help moderate peak flow events via canopy cover. Large live and 

trees are the primary source of future large down wood, which also helps to filter and moderate water flow 

throughout the year.(6)

Discussion: Please refer to Comment-13 for retention of the largest oldest trees. The project includes design 

features and protection measures to assure that predominant trees, trees with late-successional characteristics, 

and large/small snags are retained during operations and prescribed fire. Due to the epidemic level of 

ponderosa pine snags in the area of extensive mortality (units 204, 206, 158, 159, parts of 163), not all snags 

will be retained. Some will fall naturally prior to project implementation, and some will fall during the 

treatment of this area. Snag retention patches in these areas of extensive mortality will be designated however, 

and they will be focused away from roads, private property boundaries and in areas where there is a 

component of large live trees to provide some protection from windthrow. 

Comment-41 - The document states desired late-successional and old growth characteristics includes multi species 

and multilayered assemblage of trees; moderate to high accumulations of large snags and logs, moderate to 

high canopy closure, moderate to high numbers of trees with physical imperfections such as cavities, broken 

tops, and large deformed limbs, and moderate to high accumulations of fungi, lichens, and bryophytes . How 

much of each of these criteria will be left post-project in the LSR and CHU when 90% of the habitat will be logged 

including all of these criteria? (7)
Elk Flat LSR Enhancement Project

B-20 Shasta-Trinity National Forest

Discussion: The project analysis and DEIS will discuss the desired conditions and retention standards which 

meet Forest Plan direction and best available science recommendations for snags,

109 coarse wood, decadent 

trees, vertical and horizontal heterogeneity, etc. The Biological Assessment will describe where mechanical 

thinning treatments will occur in natural stands (and plantations), underburning, other fuels treatments within 

the project area, and critical habitat. 

Comment-42 - The fact this project will log old growth and “pre-dominant” trees makes this project a non-starter from 

the beginning. There is simply no legitimate reason to log any tree over 100 years old in the LSR. (7)

Discussion: Please refer to Comment-13 for retention of the largest oldest trees, Comment-14 regarding 

variable density thinning, and Comment-28 regarding stand age and LSR guidelines.

Comment-43 - The current levels are endemic at 7% not epidemic. Both insects and disease such as beetles and 

mistletoe are good for late-successional habitat and the species that rely on it. The LSR/CHU could benefit from 

MORE insect and disease, not less. We are not persuaded by Figure 4 in the document showing pine mortality. 

What we are persuaded by are the clearcuts, fragmentation and lack of habitat connectivity in the southern 

portion of the Elk LSR. The LSR was never intended to be a pine plantation for logging. Just what exactly does 

the Forest not understand about this simple concept? The only reason to log these areas is for timber production. 

We remind the FS once again that timber emphasis areas include Matrix lands – not LSR/CHU. (7)

Discussion: Please refer to Comment-11 regarding insects and disease and endemic levels, Comment-23 

regarding the project’s objectives, and Comment-103 regarding clearcutting. The levels occurring in the 

southeastern, eastern and various pockets in the remainder of the LSR are considered epidemic for the stand 

loss that is occurring, which was described in the scoping document at about 15%, not 7% (it is not clear 

where the comment’s 7% figure originates from). This is notably a concern when the 15% or higher mortality 

is compared to the LSRA determination that 2% of the LSR would be subject to lethal effects (p. 125). The 

levels of mortality at scoping were approximated at 15% based on review of pockets and stands of dead and 

dying trees. By the time implementation occurs, these levels are likely to be steady or potentially higher, 

pending a stochastic event such as uncharacteristic or high-severity fire, extensive blowdown or subsequent 

bark beetle flights and attacks that stress the trees further.

Comment-44 The authors of the Northwest Forest Plan accounted for large-scale disturbance in the design (and 

function) of the LSR system (e.g. Dr. Jerry Franklin’s comments regarding the proposed Biscuit Fire Salvage 

timber sale within Late Successional Reserves on the Rogue River-Siskiyou National Forest,) (6)

The LSR network was designed to accommodate large, intense natural disturbances and allow for natural 

recovery processes. This is one reason that the FEMAT report and PNW Forest Plan provide for conservative 

direction with regards to salvage in LSRs and direct that activities should enhance or at least not interfere with 

natural recovery processes. Chapter and verse are cited in the text of these comments.

Salvage logging of large snags and down boles does not contribute to recovery of late successional forest 

habitat; in fact, the only activity more antithetical to the recovery process would be removal of surviving green 

trees from burned sites. Large snags and logs of decay resistant species, such as Douglas-fir and cedars, are 

109 The Forest Plan Management Prescription 7 (Late Successional Reserve) standard and guideline D5 states, “Maintain 

dead/down material, hardwoods, and snags at naturally occurring levels” (Forest Plan p. 4-44). The LSRA describes 

desired conditions (desired naturally occurring levels) for Late Successional Reserves (and Managed Late Successional 

Areas). The LSRA describes that desired future conditions will vary according to the primary vegetative species, site 

class, topography and other site factors and these condition descriptions are to be used to guide the development of the 

prescriptions, with development and maintenance of late-successional habitat as the ultimate objective of the treatment. It 

further describes that the levels and ranges of various attributes should allow for long term viability of late-successional 

characteristics. For mixed conifer habitat, the average number of snags at least 20 inches in diameter is 2-4, per acre and 

6-7, 20+ inch diameter down logs on north and east aspects and less on south and west aspects and the McCloud Flats 

(LSRA p. 166). The desired levels identified in the vegetative descriptions represent an average for a landscape or 

treatment area (i.e., 100 acres). Numbers of snags and down logs can vary on any particular acre (LSRA p. 164).
Draft Environmental Impact Statement

Shasta-McCloud Management Unit B-21

critical as early and late successional wildlife habitat as well as for sustaining key ecological processes 

associated with nutrient, hydrologic, and energy cycles. (6)

Discussion: As described in Comment-37 and Comment-36, the project was designed to reduce the risk of 

loss of LSR habitat from large scale disturbance as permitted by the Northwest Forest Plan (pp. C-12, C-13). 

Snags are being retained (see Comment-20) as well as the largest oldest trees that exhibit old-growth 

characteristics such as large boles, decadent branching, cavities and flattened tops (as they are not a safety 

hazard) (Comment-13). 

Comment-45 - The ecological differences between biologically rich stands that result from natural disturbance and 

stands that are subject to regeneration logging, skid trail establishment, machine piling and road construction are 

well known and pronounced. Early-successional forest ecosystems that develop after stand-replacing or partial 

disturbances are diverse in species, processes, and structure. Post-disturbance ecosystems are also often rich 

in biological legacies, including surviving organisms and organically derived structures, such as woody debris. 

These legacies and post-disturbance plant communities provide resources that attract and sustain high species 

diversity, including numerous early-successional obligates, such as certain woodpeckers and anthropods... (6)

Discussion: There is no regeneration logging or mechanical regeneration treatments proposed with the Elk 

project. The Forest agrees that biological legacies are important, the project would retain important elements 

such as snags, CWD, shrubs, small trees /large trees, and untreated stands (e.g. unthinned patches, deferred 

units/areas, habitat roost/rest clumps). The project’s design follows guidelines for the Management 

Prescription that are intended to protect and enhance conditions of late successional and old-growth forest 

ecosystems, of which early seral habitat is an important component to provide for prey base in certain areas 

(e.g., whitethorn, other shrub habitats, hardwoods for dusky-footed woodrats and other potential NSO, fisher 

and northern goshawk prey).

Comment-46 - The disturbances occurring within the Elk LSR are considered more than small-scale in nature. (2)

The Elk proposal is dealing with reducing the risk of a large-scale disturbance that is currently occurring. Your 

project proposal is in complete compliance with the NWFP and Land and Resource Management Plan based on 

this direction/guidance. Nowhere is found direction or guidance to allow 100’s of acres of mortality to continue to 

spread across the landscape. (2)

Discussion: Please refer to Comment-23. 

Comment-47 - "The following highlights direction/guidance from the NWFP concerning treatments within LSR’s. All of 

the following quotes are found in the ROD within the Standard and Guidelines section. (2)

Page B-1: “In Late-Successional Reserves, standards and guidelines are designed to maintain late-successional 

forest ecosystems and protect them from loss due to large-scale fire, insect and disease epidemics, and major 

human impacts.”

Page B-1: “These standards and guidelines encourage the use of silvicultural practices to accelerate the 

development of overstocked young plantations into stands with late-successional and old-growth characteristics, 

and to reduce the risk to Late-Successional Reserves from severe impacts resulting from large-scale 

disturbances and unacceptable loss of habitat.”

Page B-4: “In the warmer, drier physiographic provinces (i.e., the Washington Eastern Cascades, the California 

Cascades, and the Oregon and California Klamath Provinces), fire is more frequent, less intense, and is an 

integral part of the internal dynamics of a typical stand (tens of thousands of acres). In the drier provinces, fire 

control and timber harvest have decreased the abundance of some types of old growth, such as ponderosa pine, 

that are dependent on frequent, low-intensity fires. Other types of late-successional forest that are less fire 

resistant or are less desirable for harvest have become more widely distributed. In these areas, the potential for 

stand-replacing wildfires has increased, resulting in a higher risk to the stability of current stands reserved for 

late-successional species.”

Page B-5: “Silvicultural systems proposed for Late-Successional Reserves have two principal objectives: (1) 

development of old-growth forest characteristics including snags, logs on the forest floor, large trees, and canopy 

gaps that enable establishment of multiple tree layers and diverse species composition; and (2) prevention of 

large-scale disturbances by fire, wind, insect, and diseases that would destroy or limit the ability of the reserves 
Elk Flat LSR Enhancement Project

B-22 Shasta-Trinity National Forest

to sustain viable forest species populations. Small-scale disturbances by these agents are natural processes, 

and will be allowed to continue.” 

Discussion: Thank you for the comment. Chapter 1, any LSR indicator analyses and sections of Chapter 3 of 

the DEIS, along with the supporting analyses, will disclose how the project meets the management direction 

and standards and guidelines. Please also refer to Comment-23. 

Comment-48 - The document states the current project area is 25% 10-50 year old plantations and another 20%s of 

plantations will be logged in the project. That adds up to 45%. The document also states there is 46% latesuccessional habitat and 90% of the project is in LSR so it’s appears that ALL of the late-successional habitat will 

be logged except for 380 acres. Again we are curious as to how the Forest believes this is “protecting” late 

successional habitat. Instead of actually protecting and maintaining the habitat, the Forest is proposing to return 

the entire LSR to early-successional habitat. We believe this is a violation of the LRMP, NWFP, LSRA, and 

Recovery Plan. Please show us how we are incorrect. (7)

Discussion: The preponderance of activities proposed within the Elk Flat LSR consist of thinning and 

prescribed fire. There is no regeneration logging or mechanical regeneration treatment proposed with the Elk 

project. Limited group selections are proposed in some thinning stands that would create small openings (up 

to about 2 acres) within older plantations and natural stands, due to root disease or stagnated tree growth from 

density. Meadow enhancement treatments will also aim to restore the dry meadow habitat in Elk Flat by 

removing encroaching conifers. Silviculture treatments in the project will not appreciably change the current 

seral distribution in the Ash Creek 5th field watershed under any action alternative. Thinning will shift some 

stands from seral stage 4b to 4a for approximately one to two decades until residual tree canopies reoccupy 

thinning space. Thinning will also increase the 3b and 3c seral stage classes. Please also see Comment-23, 

Comment-28, and Comment-29. LSR protection and enhancement includes the Guidelines to Reduce Risks of 

Large-Scale Disturbance in forests in the California Cascades Provinces. 

Comment-49 - The Forest intends to leave a 380 acre island of late-successional habitat for the NSO AC stating it

will “contribute” to late-successional processes. Where does the BAS document that leaving a small island of 

habitat surrounded by clearcuts benefit the NSO? The Forest is mandated to maintain and improve LSR habitat 

– not simply contribute to it. The Forest also intends to burn the 380 acres and expects to lose 5-10% of it to the

burn. So in reality the project would lose between an additional 19 to 38 acres of the 380 acres. (7)

Discussion: The Proposed Action that was scoped deferred approximately 380 acres of stands in the project 

area from mechanical treatment and thinning. This acreage may increase, or decrease, depending on 

additional stand review and treatment prioritization. There will be untreated areas throughout the project area 

(in the form of the unthinned patches, roost/rest clumps, whole units deferred from treatment and other areas 

of high quality NSO, northern goshawk and fisher habitat). These stands would be excluded from silviculture 

treatments because they are not currently at risk, or they are at a density-related risk, but are being left 

untreated or unthinned at this time to maintain current nesting, roosting and foraging habitat for these species. 

As described in the February 2013 scoping document, this is “one element of an overall spatial and temporal 

strategy to retain high quality habitat function on the landscape and address forest change over time in the 

advent of disturbance events”. Also as described in Comment-48, the unthinned blocks and areas of habitat 

will not be surrounded by clear cuts but rather will be mostly within a mosaic of variably thinned stands. 

Comment-50 - Since the Northwest Forest Plan was adopted there are even more reasons to protect and restore 

mature & old-growth forests, including: 1. to alleviate barred owl/spotted owl competition (even though there are 

not owls there now, there could be anytime in the future, and the LSR should be managed to accommodate 

them); 2. to store carbon and mitigate climate change; 3. to mitigate for the significant cumulative loss of snags

and dead wood habitat from extensive logging on public and private lands.(5)

"The Northwest Forest Plan requires that: The Watershed Analysis] will serve as the basis for developing projectspecific proposals, and determining monitoring and restoration needs for a watershed...Hence the following 

findings of the McCloud Flats Ecosystem Analysis should be addressed in project development and 

implementation.:

Distribution of snags and deadwood is spotty because large areas of plantations have almost no deadwood or 

snags. This reduces the average below forest minimums. Page 22.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit B-23

[Habitat] connectivity among the LSR’s and MLSA’s will be a continuing problem. Page 61.

Goshawks populations are in a similar situation to the spotted owls, limited by lack of habitat and harassed by 

human activity. Page 62.

In Late-Successional Reserves and Managed Late Successional Areas, late successional forest stands are to 

maintain health and diversity components through the use of prescribed fire and thinning from below. Patches of 

dead trees are scattered throughout the landscape. Page 66.

A possible relationship between soil disturbance and black stain incidence has been reported. Disease incidence 

appears to be higher adjacent to recently constructed roads and old railroad beds. Page 67.

Roads have altered groundwater flowpaths in riparian meadows. Page 81.

Four priority areas have been identified for road closures. They are the Elk Flat LSR... Page 86.

Continue nesting and occupancy surveys for goshawks. Coordinate monitoring with Klamath NF. Page 87.

Minimize soil disturbance during thinning operations. Page 88.

Youngest stands have the highest priority for silvicultural treatment. Page 101.

Reduce road density. Page 102.

No silvicultural activities should be undertaken in current or recently active goshawk nesting territories. Page 

102." (6)

Discussion: The Elk LSR project is guided by direction in the NWFP, the Forest Plan, and the LSRA as 

described earlier in this DEIS. In addition, the need for action was determined by comparing existing 

conditions with the desired condition relative to the identified purposes. Existing conditions, causal 

mechanisms and needs for action in relation to the Forest Plan desired conditions were identified in Step 5 of 

the Edson WA and Chapter 5 of the Mount Shasta WA (both which overlap portions of the project and the 

1995 McCloud Flats Watershed Analysis). Many of the watershed analysis recommendations have been 

incorporated or addressed in the project’s design. In regards to the comment and the project being used to “1. 

alleviate barred owl/spotted owl competition (even though there are not NSOs there now, there could be 

anytime in the future, and the LSR should be managed to accommodate them); 2. to store carbon and mitigate 

climate change; 3. to mitigate for the significant cumulative loss of snags and dead wood habitat from 

extensive logging on public and private lands,” the proposed and refined treatments all aim to meet some of 

these objectives, while remaining in accordance with the management direction. The Forest Service’s 

direction does not include “mitigating” for actions taken on private or public lands or climate change. The 

activities proposed are to increase stand and LSR habitat resilience to stressors however, such as prolonged 

drought, fire and insect attacks. 

Comment-51 - Snags are currently at 10 snags, 20” dbh per acre. This is excellent for late-successional species. The 

document states “excess” snags will be taken. The amount of “excess” snags must be disclosed considering it is 

equally important habitat along with old growth for late-successional species. (7)

Discussion: Please see Comment-20. The project discusses retention standards which meet Forest Plan

direction for snags.

110

110 The Forest Plan Management Prescription 7 (Late Successional Reserve) standard and guideline D5 states, “Maintain 

dead/down material, hardwoods, and snags at naturally occurring levels” (Forest Plan p. 4-44). The LSRA describes 

desired conditions (desired naturally occurring levels) for Late Successional Reserves (and Managed Late Successional 

Areas). The LSRA describes that desired future conditions will vary according to the primary vegetative species, site 

class, topography and other site factors and these condition descriptions are to be used to guide the development of the 

prescriptions, with development and maintenance of late-successional habitat as the ultimate objective of the treatment. It 
Elk Flat LSR Enhancement Project

B-24 Shasta-Trinity National Forest

Comment-52 - A commenter present at a public meeting on March 26, 2013 stated there should be nothing wrong 

with leaving 100’s of acres of dead trees within the Elk LSR. It was stated this was expected in the Northwest 

Forest Plan. We don’t believe that was the full intent of what the authors of the Northwest Forest Plan had 

envisioned for LSR’s. (2)

Discussion: The NWFP includes information on the basis for the standard and guidelines including ecological 

principles for management of late-successional forests (USDA-FS & USDI-BLM, 1994 p. Section B). Dead 

trees are an important component in LSRs. Simultaneously, there is direction to protect and enhance LSRs 

(including reducing risks of large-scale disturbance in this province). 

Comment-53 The document states that due to 100 years of fire suppression stands are dense and risk of wildfire is 

high. The need to “protect” late-successional habitat is great. We believe the proposed action is not a rational 

response to these assumptions that are not based on the best available science. The Forest wants to log 90% of 

the LSR leaving only 10% in un-thinned units and then burn it. The FS also intends to reduce basal area to a 

maximum of 150 ft/sq.ac. and in some areas much less. ... log a majority of 80-150 year old trees, including 

stands of old growth with trees 30” dbh and greater. ...convert the LSR to another pine plantation and regenerate 

Ponderosa pine rather than maintain the preferred mixed conifer species by late-successional animals. This will 

require REO approval because it violates the NWFP....also the LSRA, the 2011 Recovery Plan, and the 2012 

Critical Habitat designation. (7)

Discussion: See also Comment-27, Comment-28 and Comment-48. The Elk LSR project is designed to move 

the landscape toward the desired condition for the Elk Flat LSR as guided by the visions, goals, strategies and 

design criteria embodied in the NWFP, the Forest Plan, and the LSRA as described in the scoping document 

and Chapter 1 of this EIS. It is consistent with general objectives from the LSRA, all of which fall under these 

LSRA Activity Design Criteria: 1 (Reforestation and revegetation), 4 (Thinning in early successional pole and 

mid-successional stands - Hazard Related), 5 (Thinning in early successional pole and mid-successional 

stands -Development of Late-Successional Habitat), 7, 9 and 10 (Fuel Reduction, Hazard Reduction - 

Prescribed Burning and Manual and Mechanical Fuels Reduction) and Miscellaneous Activity 7 (Maintaining 

Hardwood Stands, forest openings, meadows, and glades) (LSRA pp. 182-195). The proposed treatments 

require REO review to ensure consistency with the NWFP and LSRA (see also Comment-36). The proposed 

action was also designed to be consistent with recommendations from the 2011 Revised Recovery Plan for the 

NSO (see Comment-37) and the 2012 Critical Habitat designation. This information will be included in the 

project record and the project Biological Assessment.

Comment-54 With treatments planned in an LSR one would expect the decision maker to limit the number of entries 

required to fully achieve the desired stand characteristics. The intent of the Northwest Forest Plan was to 

minimize the number of entries within LSRs. One would also think the FWS would welcome proposals that limit 

the number of disturbance entries in order to achieve long term desired conditions. (2)

Discussion: See Comment-25 for thinning effectiveness (which can be roughly translated to expected reentry). Due to the high degree of departure from the natural fire regime, one prescribed burn entry is unlikely 

to achieve the objective of returning the natural role of fire to the ecosystem. Instead, 2 to 3 incremental 

underburns, repeated every 5 to 10 years would be implemented. The entire area would not be underburned in 

any one year, contributing to a diverse mosaic of treated area conditions.

Comment-55 - Please also take a hard look as to the ecological contribution that snag forest habitat is providing this 

LSR and the possibility of spreading disease through logging, road and landing construction.(9)

further describes that the levels and ranges of various attributes should allow for long term viability of late-successional 

characteristics. For mixed conifer habitat, the average number of snags at least 20 inches in diameter is 2-4, per acre and 

6-7, 20+ inch diameter down logs on north and east aspects and less on south and west aspects and the McCloud Flats 

(LSRA p. 166). The desired levels identified in the vegetative descriptions represent an average for a landscape or 

treatment area; i.e., 100 acres. Numbers of snags and down logs can vary on any particular acre (LSRA p. 164). 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit B-25

Discussion: Please refer to Comment-20 and Comment-51 regarding snags, and Comment-10 and Comment11 regarding disease spread.

Comment-56 - The LRMP also encourages the agency to use prescribed fire and thinning from below, focus on 

younger stands, and accelerate development of late-successional characteristics in the LSR. None of these 

objectives will be furthered by removing large snag habitat from over 1,500 acres of the LSR.(6)

Discussion: Please refer to Comment-28 regarding treatment in mature stands, and comments Comment-20 

and Comment-51 regarding snags. See also Comment-53 regarding consistency with the LSRA management 

direction. 

Machine Piling

Comment-57 - Do not be forced into dropping the option of machine piling. This technique has been used effectively 

for decades with no detrimental effects to the soils resource. (2)

Discussion: The Forest Service will determine, based on review of the existing conditions prior to 

underburning and after thinning treatments, what type of surface fuels reduction methods to use that limit the 

most disturbance to soils, CWD, snags and residual vegetation. Where heavy concentrations of CWD exceed 

the desired conditions as specified in the resource protection measures (typically more than 40 tons per acre), 

machine piling and burning of some piles would be utilized. This method would reduce surface and activity 

fuels, and would be pretreatment before underburning to increase consumption of excess fuels over what 

underburning would accomplish and to limit adverse effects to overstory trees, soils and wildlife habitat (see 

also Comment-3). Piling would focus on the high fuel load/mortality pockets and machine piling passes 

would be limited to the extent needed to reduce fuel loads to levels described in the resource protection 

measures. Treated areas would not be rigorously cleaned of slash material, and duff materials would be 

largely left in place for soil cover and erosion protection consistent with Forest Soil Quality Standards, RPMs 

and BMPs. 

Comment-58 - Manual piling is a reasonable alternative to the avoidable impacts associated with machine piling 

while mechanical piling is universally recognized as an outdated practice that has disproportionately harmful 

impacts on watershed and soil resources. Please see: Evelyn Bull et al. Trees and Logs Important to Wildlife in 

the Interior Columbia River Basin PNW-GTR-391 (1977). BLM, USGS, Biological Soil Crusts: Ecology and 

Management (Technical Reference 1730-2(2001) (Available from BLM Publication Management Distribution 

Service, Bldg 41, E-16 (BC-650B) Denver, CO 80255 (6)

Our organizations remain convinced that manual piling is far preferable to tractor piling. Manual piling has none 

of the negative impacts to soils associated with tractor piling, provides an increased opportunity for local 

employment and significantly reduces long term damage to soil health and productivity. Hence manual piling 

would better achieve the stated forest health purpose and need for the project.(6)

I am concerned about proposals to conduct machine piling in the Elk Flat LSR. (8)

Discussion: Machine piling was identified as a significant issue for this project and is discussed in Chapter 3. 

As described in Comment-6, as well as the existing condition section of Chapter 1, many of the surface and 

standing dead fuels are too large and too abundant to safely or effectively pile by hand. See also Comment-3 

and Comment-57 that address when machine piling may occur.

Bull et al. 1977 (and 1997) discusses the importance of trees and logs to wildlife, including downed coarse 

wood. USDI BLM and USGS discuss biological soil crusts (in arid and semi-arid regions) as indicators of 

ecological health. The project incorporates project measures to retain and/or protect large CWD that is an 

important habitat component for wildlife (and soils). For example: 

• Piling would focus on the high fuel load/mortality pockets and machine piling passes would be

limited to the extent needed to reduce fuel loads to the levels described in the resource protection

measures;
Elk Flat LSR Enhancement Project

B-26 Shasta-Trinity National Forest

• Treated areas would not be rigorously cleaned of slash material, and duff materials would be largely

left in place for soil cover and erosion protection consistent with Forest Soil Quality Standards

(Forest Plan p. Appdx. O), RPMs and BMPs;

• Existing CWD would be maintained and protected from disturbance to the greatest extent possible

within all thinning and fuels treatment units in LSR and matrix land allocation;

• An average of 6 to 10 large down logs per acre in a variety of decay classes with a preference for 20-

inch diameter logs, or the largest size class available would be retained;

• Where piling and burning is conducted within NSO and NGO foraging habitat, two unburned slash

piles per acre would be left to provide small mammal habitat.

No biological soil crusts were observed during soil surveys (Courtney, 2015). Machine piling earned a 

reputation as a harmful practice on soils in the past, from the era where machine piling almost exclusively 

referred to site preparation for planting after a clearcut, and often occurring on moderately steep slopes.111

However, slash piling as practiced in the past has not occurred on National Forest System lands since the mid1990s. Mechanical operations are limited to slopes less than 35%. Much smaller tractors equipped with a 

brush rake on the blade are typically used, which result is little to no topsoil displacement or compaction that 

would be of any detrimental degree.112 In some areas of the project, an excavator may also be utilized to pile 

(see Chapter 2 description of machine piling and burning, and EIS Appendix A). Piles are to be “clean” 

(without soil), which helps them burn properly. Tractor piling often takes place in thinned stands, so there is 

much less slash generated when compared to regenerated stands. Combined with whole tree yarding, the 

overall results are much less slash material being moved into piles, and much less equipment traffic on the 

soils compared to past practices.

Forest monitoring found machine pile and burning overall effects on the soil were minimal due to clean piles 

that lacked displaced soil (Rust, 2013d). Fall burning consumed most of the slash, and had minimal loss of 

soil organic matter and topsoil. Soil heating was 2 to 4 inches deep had high levels of soil organic matter, 

roots, low to moderate levels of compaction. The areal extent of tractor piling is limited to slash 

concentrations in much if not most of the areas that include machine piling. Some soil displacement may 

occur associated with equipment operations but this should be limited in extent due to flat topography and the 

spatially patchy distribution of activity generated slash. Slash (LWD) and litter/duff remaining on site will 

provide for soil cover, erosion control, and provides a source of nutrient supply over time. If done properly, 

machine piling is expected to meet soil quality standards. The size of the material being piled is too large for 

manual methods. 

Comment-59 Forest monitoring found machine pile and burning overall effects on the soil were minimal due to clean 

piles that lacked displaced soil (Rust, 2013d). Fall burning consumed most of the slash, and had minimal loss of 

soil organic matter and topsoil. Soil heating was 2 to 4 inches deep had high levels of soil organic matter, roots, 

low to moderate levels of compaction. The areal extent of tractor piling is limited to slash concentrations in much 

if not most of the areas that include machine piling. Some soil displacement may occur associated with 

equipment operations but this should be limited in extent due to flat topography and the spatially patchy 

distribution of activity generated slash. Slash (LWD) and litter/duff remaining on site will provide for soil cover, 

111 Heavy slash accumulations were “straight-bladed” into piles, often also piling large amounts of topsoil into the piles 

(sometimes purposely, to reduce re-growth of sprouting species as competition for planted trees). This practice was 

eventually widely recognized as harmful to soil productivity, and one of a few practices that directly led to topsoil 

displacement standards incorporated in national and regional soil management direction from 1991 to 1995. 

112 The Forest has a long track record of working directly with equipment operators to achieve minimal soil displacement 

or other soil impacts historically associated with this practice.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit B-27

erosion control, and provides a source of nutrient supply over time. If done properly, machine piling is expected 

to meet soil quality standards. The size of the material being piled is too large for manual methods. - We 

continue to emphasize the need to carefully look at all fuels reduction options. We highly encourage you to keep 

all options open for treating fuels within the project area. Hand piling should be the last option as it is very 

expensive and can lead to a nonviable project. Do not be forced into dropping the option of machine piling. Given 

the current mortality conditions within many of the stands, machine piling is the only feasible option. This 

technique has been used effectively for decades with no detrimental effects to the soils resource.(2)

Discussion: See also the responses to Comment-3, Comment-6, Comment-57, and Comment-58. Machine 

piling is being evaluated for use in the Elk project. This activity would be limited to the areas where it is 

needed to reduce surface fuel loading to Forest Plan standards for the LSR and matrix lands, and the resource 

protection measures. The SMMU currently employs several equipment operators and owns various pieces of 

equipment, including . two dozers and an excavator that may be used for piling. Hand piling is a less safe and 

viable option due to the size of the material to be piled, though this option may be used in sensitive areas. 

Comment-60 - The Six Rivers National Forest recently concluded: “Machine piling/burn piles would increase ground 

disturbance and soil displacement when the machine turns.” -Little Doe and Low Gulch Timber Sale DEIS p 110. 

(6) 

Discussion: It is difficult to compare a timber sale on the Six Rivers with one on the SMMU. The topography 

is greatly different. See also the discussion for Comment-71, Comment-3, Comment-6, Comment-57, and 

Comment-58. The description of proposed machine piling in EIS Chapter 2 and Appendix A, and the resource 

protection measures, describes the equipment and protection measures that would be used during piling 

activities. 

NEPA

Comment-61 - Blending 36 CFR 215 and 36 CFR 218 is a NEPA violation. (7) 

Discussion: There is no blending of these regulations in the scoping document, or other elements of the 

project. 36 CFR 218.16 addressed the effective dates for the 218 pre-decisional objection process as well as 

provisions for the process transition. This was fully described in the scoping document to assure that the 

Public was aware of the process transition.

Comment-62 - A proper consideration of the cumulative impacts of a project requires “some quantified or detailed 

information;...[g]eneral statements about some possible effects and some risk do not constitute a hard look 

absent a justification regarding why more definitive information could not be provided.” 1998)). The analysis 

“must be more than perfunctory; it must provide a useful analysis of the cumulative impacts of past, present and 

future projects.” (6)

It appears that much of the LSR and surrounding Forest Service lands have been subjected to logging, road 

construction and fire exclusion. We have also observed implementation of regeneration logging, large tree 

logging, large snag logging, tractor yarding and machine piling activities in the matrix land use allocation in the 

Pilgrim and Mayflower timber sales on the McCloud District. These prescriptions have turned public forestlands 

into highly compacted dirt fields largely devoid of vegetation. See attached photos. The cumulative impacts of 

these practices are severe and significant."

"The many severe cumulative impacts from timber sale activities, road construction, fire suppression, and 

machine piling for this planning area must meet the requirements of NEPA such that: A proper consideration of 

the cumulative impacts of a project requires “some quantified or detailed information;...general statements about 

possible effects and some risk do not constitute a hard look absent a justifications regarding why more definitive 

information could not be provided.” The analysis “must be more than perfunctory; it must provide a useful 

analysis of the cumulative impacts of past, present, and future projects.”"

Given the repeated acknowledgements in the watershed analysis regarding the impacts of past logging and road 

activities on the hydrological and terrestrial health of the project area, it is vital that the Forest Service analyze 

and disclose the cumulative impacts of past activities and its future plans.

Please disclose and analyze all previous projects in the LSR that were mentioned in general in the document. 

How are these previous projects impacting habitat, species, soils and water quality in the project area?
Elk Flat LSR Enhancement Project

B-28 Shasta-Trinity National Forest

Please provide a thorough cumulative impacts analysis of the proposed logging in combination with other federal 

logging and early 50% of this watershed has been commercially logged in the last 15 years. 480 acres of mature 

forests have been removed from this watershed. Please honestly analyze and disclose how continued grazing 

and additional logging, road and landing construction will affect wildlife, soils, recreation, late successional 

characteristics and heritage resources.(6)

Discussion: The analysis will follow regulations and policy regarding NEPA cumulative effects, which are 

described in the DEIS. The IDT reviewed information from the past 30 years for activities that are contained 

within or intersect with the Elk project general cumulative effects review area. The specialists reviewed past 

actions to: (1) determine if past actions are relevant and useful in analyzing whether the reasonably 

foreseeable effects of the agency proposal for action and its alternatives may have a continuing, additive and 

significant relationship to those effects, and (2) determine if past actions help illuminate or predict direct and 

indirect effects of the proposed action or its alternatives. This approach is consistent with the Council on 

Environmental Quality (CEQ) letter “Guidance on the Consideration of Past Actions in Cumulative Effects

Analysis” of June 24, 2005. Ongoing and future actions were also considered in this boundary. The wildlife 

analysis will also consider cumulative effects as they are defined under the ESA, pending the determination 

(formal vs. informal consultation).

Spatial and temporal boundaries are the two critical elements to consider when deciding which actions to 

include in a cumulative effects analysis. Spatial and temporal boundaries set the limits for selecting those 

actions that are most likely to contribute to a cumulative effect. The effects of those actions must overlap in 

space and time for there to be potential cumulative effects (FSH 1909.15 (15.2)). This is determined by how 

long, and how far reaching direct and indirect effects of a project are felt on a given resource area ((FSH 

1909.15 (15.3)). Therefore, relevant boundaries and projects assessed for cumulative effects vary by resource. 

Each resource’s cumulative effect area can be different and possibly larger or smaller. Details are described in 

individual resource analyses . The boundaries used for the resource analyses are described in Chapter 3. 

Comment-63 - We are submitting four maps with our scoping comments that document all the timber sales in the 

SMMU by the FS as well as industry (THPs), owl ACs, and the Elk project in relation to the Pilgrim project. We 

included 10 major FS timber sales that fit together like a jigsaw puzzle. In fact the Elk project units are actually 

units left by the Pilgrim project. All 10 projects include designated critical habitat for the NSO yet the FS keeps 

insisting this “death by a thousand cuts” is not harming the owl. We also note there are approximately 40 THPs in 

the SMMU. We expect the FS will conduct a NEPA analysis of cumulative effects that considers the broader 

implications to owls. 

Discussion: Please see Comment-62 for discussion of cumulative effects. A NEPA cumulative effects analysis 

will be completed for the NSO, as well as other species considered in the project analysis. The DEIS will 

summarize the cumulative effects relative to the NSO. Regarding overlap of Elk and Pilgrim treatment units, 

the DEIS describes that unit 401 overlaps with the Pilgrim project. Unit 401 will receive underburning under 

the Elk project to further enhance meadow characteristics, and implement the thinning treatments that were 

assessed under the Pilgrim project, and that is why it is included in the Project area and analysis. 

Comment-64 - The document states that stands that are deferred from treatment (the 380 acres) will provide 

heterogeneity at the larger project area scale; therefore the Forest needs to analyze fragmentation and 

connectivity at the larger project scale. It also needs to disclose when it intends to log the 380 acres not treated 

in this project. The units in the Elk LSR are basically part of the Pilgrim project which logging began in 2010. So 

that analysis claimed units were also deferred and apparently they were only deferred for 2 years. If the only 

habitat the Forest intends to leave in late-successional condition is 380 acres, and states they were deferred, 

then the cumulative effects analysis must disclose when they are planned for treatment as a foreseeable impact.

Discussion: See also the response to Comment-48 and Comment-49. The scoping document states: “In 

addition to retaining a minimum 10 percent of the proposed thinning treatment units in LSR allocation

[footnote omitted] in an unthinned condition to retain features such as thermal cover, dense pockets of trees, 

trees with cavities, deformed and/or decadent limbs and openings with dense brush, small trees, or other 

vegetation for size differentiation, approximately 380 acres of natural stands have been excluded from 

thinning treatments as field review shows they are either not currently at a high risk of loss or to maintain 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit B-29

certain current late-successional habitat for northern spotted owl and northern goshawk.” When scoped, the 

380 acres was deferred from mechanical treatment, but planned for underburning and that amount may 

increase, or even decrease, during additional project planning and consultation with the FWS and other 

resource agencies and as conditions change in the stands. At this time, there is no plan to thin the stands that 

will not be mechanically thinned under the Elk project. Connectivity within the LSR will be assessed and 

discussed in the EIS and Biological Assessment/Biological Evaluation as it relates to treatment objective 4 of 

the LSRA, and late-successional habitat and dependent species. 

Comment-65 - All of the units have been identified and have associated prescriptions. We looked at the Elk LSR 

project in 2012 and it’s marked. We have photographs and videos documenting this. The purpose of scoping is 

to notify the public that a project is being considered and to request general information prior to a proposed 

action. (7)

Discussion: The scoping document for the proposed action was detailed with maps and draft prescriptions for 

the existing conditions to permit the public an opportunity to comment on, contribute to, and identify issues 

with the proposed action. Responses to the proposed action and scoping document, as discussed in the 

Introduction to this Appendix, will be used to identify key issues, alternatives and indicators. In regards to the 

2012 review noted in the comment, there had been no designation of timber (painted) in the project area. The 

national standard for surveyed property lines are blazes and portions of these trees are painted red to 

differentiate land ownership between private property and Forest Service property. The preliminary flagging 

(orange/blue), orange paint (draft unit boundaries) or tagging (yellow) that may have been observed in 2012 is 

used on the ground to assist resource specialists during the planning phase of most projects. It is not the final 

treatment boundary designation, but is a preliminary identification to help with development of different 

alternatives, resource protection measures, location of potential suitable landing locations, assessing logging 

systems, designating wildlife leave areas and identifying mortality areas. Unit boundaries and/prescriptions 

are also sometimes marked prior to a decision being made. This allows for a better visual representation of 

what is proposed with thinning and other treatments. It permits FS specialists and other agency staff (FWS, 

NOAA’s National Marine Fisheries Service, SHPO, Water Board), county personnel and landowners the 

opportunity to review what the proposed or draft treatments are and visualize what conditions would be like 

post-thinning or harvest. It is not possible to pre-mark areas of underburning, but the SMMU has several postburning examples that the public is able to review. If changes result during the NEPA analysis and decision 

process for mechanical thinning operations, or no-treatment areas (unthinned patches are modified, additional 

timber is designated for retention or removal, exclusion of units, etc.), marking, and cruise data, changes are 

made prior to implementation to ensure consistency with whatever decision is made.

Comment-66 - The document states “If you reference scientific literature in your comments, you must provide a copy 

of the entire cited reference and include rationale as to how you feel it is pertinent to the project.” The 36 CFR 

215 regulations have no such requirement. Generally scientific literature is submitted during the draft stage 

because of the assumption the FS is actually drafting alternatives and has not already come up with a “Proposed 

Action”. (7)

Discussion: Providing the scientific literature that is cited in scoping comments and response letters helps us 

understand the public’s and other agency’s concern(s). . Often literature or other information is cited in 

scoping (and other comment) response letters and we are not able to locate it. 

Comment-67 - Regardless, we want to document this NEPA violation up front prior to the actual “comment period.” 

We are puzzled why the Forest is asking for public input when it already has a proposed action that is fully 

developed. We don’t see how a reasonable range of alternatives can be met considering the action is developed, 

units identified, and stands marked. (7)

Discussion: See also Comment-65. The IDT developed a draft proposed action that addresses the purpose and 

need, and law, regulation and policy. It was the Agency’s best effort at putting forth a draft proposal to close 

the gap between existing and desired conditions. Public comments on the draft proposed action and proposal 

are meant to help refine the proposal and identify preliminary and key issues. The results of scoping (usually 

transmitted through written or verbal comments or at the public meetings) are used to clarify public 
Elk Flat LSR Enhancement Project

B-30 Shasta-Trinity National Forest

involvement methods, refine issues, select an interdisciplinary team, establish analysis criteria, and explore 

possible alternatives and their probable environmental effects (FSH 1909.15 ch.10 [11]).

Comment-68 - It would have been far more prudent to develop an action alternative that retained all Old Growth 

(predominant trees) and dominant and co-dominant trees. Instead, it intends to leave all trees under 10” dbh, and 

leave the current pine plantations that are only 10-20 years alone. We fail to see how regeneration harvest and 

planting in a late-successional reserve is preserving late-successional habitat? We also fail to see how creating a 

Ponderosa pine plantation that requires an open canopy and a lot of sunshine in an LSR is protecting latesuccessional habitat? (7)

Discussion: A s described in Comment-13 and Comment-27, the project proposes to retain predominant trees 

and most dominant trees, and trees with late-successional attributes. There is no old growth in the project 

area, but legacy trees (predominants) would be retained. See also Comment-23, Comment-38 and Comment39 regarding natural regeneration and pine. There is no regeneration logging or mechanical regeneration 

treatment proposed with the Elk project. The project does not propose to retain all trees <10” dbh; it would 

retain and thin this size class mechanically, depending on stand and habitat conditions, and this size class 

would also be affected during underburning operations. 

Soils

Comment-69 - New road construction, landings, machine piling and tractor yarding have significant (and cumulative) 

impacts to forest soils. (6)

Discussion: The DEIS discloses the direct, indirect, and cumulative effects of the proposed activities on forest 

soils (see Chapter 3, Soils).

Comment-70 - Soil loss with respect to method of harvest is directly related to the amount of soil disturbed and bared 

by harvest activity, especially the density of skid trails and roads required to access the timber. Megahan (1981) 

found tractor logging on granitics to result in 28 percent of the soil disturbed, ground cables with 23 percent, 

suspended cables with five percent and helicopter logging with two percent. Similarly, Swanston and Dyrness 

(1973) found tractor yarding in granitics to result in 35.1 percent bare soil, hi-lead in 14.8 percent and skyline in 

12.8 percent. In a Trinity County study on mixed soil types, skid trails averaged four to eight percent (6-12 

km/sq.km) for clearcut areas (Scott et al., 1980). (6)

Discussion: The project area is composed of generally deep to very deep (40 to 60 inches) sandy loams to 

loamy sands rather than granitics. The project is on flat terrain and will utilize ground based logging systems 

to accomplish most of the project. Slopes in within the Elk project are gently sloping and with proposed 

treatments the likelihood of erosion occurring due to slopes are very low. The EHR post-implementation 

remains low. The soils analysis indicates that all action alternatives in the Elk the project will meet or exceed 

the Forest Plan soil quality standards, maintaining soil productivity in support of healthy forests (see Chapter 

3, Soils). 

Comment-71 - We further encourage the agency to examine the soil compaction monitoring reports from 1985 

through 1997 on the Payette National Forest. While the Payette contains different ecotypes and soil types than 

does the Trout Creek project area, the monitoring reports clearly show long-lasting and significant soil damage 

from tractor piling activities. 

Similar monitoring in the Idaho Panhandle (Jerry Niehoff) and the Kootenai National Forest (Lou Kuennen) 

demonstrate significant impacts to soils. We also encourage the agency to review the findings of Geppert, R.R., 

Lorenz, C.W., and Larson, A.G., 1984. Cumulative Effects of Forest Practices on the Environment: A State of the 

Knowledge. (6)

Discussion: Copies of the referenced monitoring reports were not available, but the comment refers to the 

First Creek project area on the Klamath National Forest (USDA Forest Service, 2007), so the response of Tom 

Laurent (Soil Scientist, Klamath National Forest) for First Creek is included: Soil compaction monitoring on 

the Payette National Forest focused on tractor logged units that were on steep ground and tractor piled 

(referenced within USDA 2007: Dean Pacific martens, Soil Scientist, Payette National Forest, pers. comm. 

March 6, 2007). Pacific martens indicated that the monitoring units selected were those that had a high 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit B-31

probability of not meeting soil disturbance guidelines, and the data concluded that post-treatment conditions 

in these steep units did indeed not meet the guidelines. This caused the Payette Forest to change its slope 

limitations for tractor piling from <45% to <35%. This monitoring indicates that tractor piling on slopes 

between 35 and 45% on the Payette National Forest has a high probability of exceeding soil disturbance 

guidelines. Tractor piling proposed as part of the Elk project activities would occur on slopes <20%, so the 

Payette monitoring is not relevant to specific activities proposed. Other “similar monitoring” referenced is 

similarly dated and not relevant to specific activities proposed for this project.

Comment-72 - Edson Watershed Analysis (WA) page 28, “Overall, based on monitoring results using the Soil 

Disturbance Monitoring Protocol (Page- Dumroese, et al., 2009) and anecdotal evidence on pumice soils, Edson 

watershed soils show low levels with only one to four percent of the area with high levels of disturbance. Only 

relict converging main skidtrails on fine to medium fine-grained soils are over the soil quality standard threshold 

bulk density levels. With most soils being medium to coarse grained, soil compaction levels are low throughout 

the watershed along with soil disturbance.”(9)

Discussion: See also Comment-70. With protection measures in place (SOPs for wet weather and following 

BMPs for soil protection) and decompaction of units currently above threshold (4 units), the entire project 

area is expected to meet the soil porosity standard of at least 90% of the natural porosity for the soil over at 

least 85% of the treatment unit (see Chapter 3, Soils). 

Comment-73 - "The Forest Service may only yard timber if the activity will be ""carried out in a manner consistent 

with the protection of soil."" 16 USC §1604(g)(3)(F)(v); 36 CFR §219.27(c)(6). Management plans and projects 

must ""insure that timber will be harvested from National Forest System lands only where-""soil, slope, or other 

watershed conditions will not be irreversibly damaged."" (6)

Discussion: The EIS discloses evaluation of project actions for compliance with the Forest Plan soil quality 

standards and for National Forest Management Act compliance.

Comment-74 - Medford District BLM: Resource management plans call for limiting compaction in harvested areas in 

order to minimize soil productivity losses. Therefore, no additional use of mechanical equipment for fuels 

reduction was proposed, as ground-based logging would compact up to 12 10 percent of the harvest units. This 

is particularly important in the Cottonwood planning area as the majority of soils contain high rock content. It was 

identified that ripping the soils in this area would bring rocks and cobbles to the surface. The priority was given to 

minimizing the soil area compacted instead of trying to mitigate the effects. Additionally, the harvest prescription 

resulting in relatively few trees per acre being cut minimizes the slash, and consequently, also reduces the need 

for mechanical fuel treatment. (6) 

Discussion: As described in Comment-3, there are areas of already high fuel loadings that are too large or too 

many to be addressed by hand piling or burning alone. The DEIS evaluates project actions for treatments, 

including mechanical fuel reduction, in the Soils section of Chapter 3. 

Comment-75 - Soil integrity is a key issue for this timber sale. Please address soil chemistry, productivity, hydrology, 

and biological integrity on a site-specific (i.e., unit-by-unit) basis. Please map soil types and composites using 

field reconnaissance data and include the maps in the NEPA document. Include a qualified, journey-level soil 

scientist on the ID Team. Design actions and mitigation after you have collected field reconnaissance data on 

soils at every site proposed for action. (6)

Discussion: The project was field evaluated by a qualified soil scientist. Information relative to the analysis is 

described in the specialist report and summarized in the Soils section of DEIS Chapter 3. 

Transportation 

Comment-76 - Numerous road segments are proposed for Closure or Decommission conflict with the MVUM (the 

development of which included participation by recreation groups and the public); these closures infringe upon 

the Public’s ability to recreate on THEIR national forest. (4) 

Discussion: A project travel analysis process (TAP) (Bonivert, 2015a) was completed for the project. Portions 

of the road analysis process completed for the Pilgrim project overlap the Elk project area and that document 

was incorporated as well. A need exists to increase Forest transportation system efficiency and provide access 
Elk Flat LSR Enhancement Project

B-32 Shasta-Trinity National Forest

to a dispersed recreation area in Elk Flat. The TAP completed for the project recommends an approximately 

0.10 miles of existing unauthorized route that is currently utilized as public access to a dispersed recreation 

area in Elk Flat should be added to the FTS as an open level 2 road to provide legal motorized access. A need 

exists to remove several unauthorized routes in the project area from the landscape for restoration to a more 

natural condition. 

Travel Management is an on-going effort that will continue to evolve as work is done to analyze and modify 

the transportation system to meet the recreational and access needs of local citizens and visitors, while 

protecting important resources. Subsequent decisions will be made using the National Environmental Policy 

Act (NEPA) process which allows the public to be involved in the decision making process. These decisions 

will result in changes to route designations on the forest. Route designations are reflected on the Motor 

Vehicle Use Maps (MVUM). The MVUM will be revised annually to reflect modification and improvements 

to the Forest transportation system.

Comment-77 - Decommissioning temporary roads can result in sedimentation so they should be obliterated and

seeded instead. (1) 

Discussion: The DEIS discloses the effects of the proposed activities relative to hydrology. Temporary roads 

would be decommissioned following Forest Service policy and/or timber sale contract provisions, which 

include blocking normal vehicular traffic. The roads will be located in relatively flat areas with no streams or 

waterways nearby. Obliteration, which includes scarifying the road and re-contouring the road prism back to a 

properly functioning condition, is the highest level of decommissioning. Depending on ground conditions, 

obliteration is one of the decommissioning options for temporary roads. 

Comment-78 - Roads at 4.6 -> 3.1 miles per square mile cause significant impacts to habitat by fragmentation and 

increase of fire risk by humans. (7) 

Discussion: The DEIS discloses the effects of the proposed activities relative to connectivity and fuels and 

fire effects. 

Comment-79 - We are very aware there will be undue pressure put on the decision maker to not develop any 

temporary roads for this project. We take the opposite view point. Temporary roads can allow for more effective 

and efficient management of the public’s land. They can provide for better economics and in many cases reduce 

environmental impacts as compared to alternative treatments such as long skids. (2)

Discussion: The need for temporary roads was carefully evaluated for the project. Temporary roads in 

thinning and meadow enhancement units across the project area would be used or constructed to provide 

access for harvest operations. Approximately 1.5 to 2.9 miles of new temporary road are proposed to facilitate 

the project’s proposed actions. About 4.7 to 5.7 miles of existing unauthorized routes may be used for the 

project and then decommissioned. 

Comment-80 - I am concerned about proposals to build roads in the Elk Flat LSR.(8) 

Discussion: There is no new permanent road construction proposed for the project or in the LSR. Temporary 

roads are proposed and would be decommissioned after project completion, as discussed in Comment-79. 

Comment-81 - Edson WA page 74, “Transportation System -The current GIS transportation layer (4/09) shows the 

Edson watershed contains approximately 505 miles of road, including forest development roads, private 

timberland roads, and other unclassified roads. Approximately 212 miles of routes in the analysis area are 

designated for vehicle travel on national forest. Approximately 23.9 miles of unauthorized routes exist where 

motorized travel is prohibited.” Edson WA page 75, “Current road density in the watershed is approximately 4 

miles of road per square mile of land.” Given that the current road density in the watershed is approximately 4 

miles of road per square mile of land, we are curious to know how soils standards are being met in this 

throughout the Edson watershed. Please disclose the cumulative impacts to soils caused by reconstruction of 

four miles of road, construction of two miles of “temporary” roads, landing construction and machine piling. 

Please note that road closure does not substitute for decommissioning nor does it eliminate the negative 

environmental effects.(9)
Draft Environmental Impact Statement

Shasta-McCloud Management Unit B-33

Discussion: Please refer to Comment-62. The DEIS (Chapter 3, Transportation) describes the direct, indirect 

and cumulative effects of transportation.

Comment-82 - It is important an adequate road system be developed and utilized in order to effectively and 

efficiently harvest the timber from this project. (2)

Discussion: As noted in Comment-76, a TAP was prepared. The project area was evaluated for project 

facilitation as well as recreational and access needs and protection of important resources. 

Comment-83 - While decommissioning unneeded roads is understandable and supportable we also ask that serious 

consideration be made for including temporary road construction that will assist with the implementation of this 

project. We encourage the building of temporary spurs where feasible to reduce the harvest costs and more 

effectively treat the land base. (2)

Discussion: The project utilizes existing unauthorized routes as well as limited temporary road construction 

to facilitate project actions. Temporary roads would be decommissioned post project.

Comment-84 - Careful analysis should be done for those roads earmarked for decommissioning. Make sure they 

have been identified in your travel management planning efforts and that no roads are planned for closure that 

have been designated as open in the travel management plan.(2)

Discussion: Please refer to Comment-76. 

Comment-85 - "Trombulack, S.C. and C.A. Frissell. 2000. Review of ecological effects of roads on terrestrial and 

aquatic communities. Conservation Biology 14(1): 18-30. “Various studies (e.g., Ortega and Capen 1999; Marsh

and Beckman 2004) show that the negative impacts of roads to wildlife habitat are not limited to the road prism –

there is a zone of influence that extends into the adjacent habitat. For example, Marsh and Blackman (2004) 

found that some terrestrial salamanders decreased in abundance up to 80 meters from the edge of a forest road 

due to soil desiccation for the edge effects. Ortega and Capen (1999) found that ovenbird (a forest-interior 

species) nesting density was reduced within 150 meters of forest roads. This study suggests that even narrow 

forest roads fragment habitat and exert negative effects on the quality of habitat for forest-interior species.”(6)

Discussion: The article by Stephen C. Trombulak and Christopher A. Frissell (2000), “Review of Ecological 

Effects of Roads on Terrestrial and Aquatic Communities” is a general accounting of how road construction 

and maintenance can impact terrestrial and aquatic organisms through habitat fragmentation, compaction of 

soils, collision/construction related mortality, invasive species introduction/spread and chemical 

contamination. 

The project will not construct new permanent roads. To avoid new disturbance, unauthorized routes (existing 

routes) will be utilized when available (about 5.7 miles for Alternative 1). New temporary road construction is 

limited (about 2.9 miles for Alternative 1). All temporary roads would decommissioned post project. The 

proposed temporary roads will allow access for necessary equipment to accomplish the prescribed treatment 

of the units and will also alleviate the need for long skid trails that could impact soils resources and existing 

vegetation. Best Management Practices will be used to minimize or eliminate soil or hydrologic impacts. The 

assessment of the anticipated effect of the proposed roads on air quality, noxious weed spread, fisheries, 

wildlife and hydrology has been completed and is found in each respective section of Chapter 3.

Watershed

Comment-86 - The Forest Service is proposing temporary road and landing construction; gap creation and 

regeneration logging; ground-based yarding and machine piling, which will increase the hydrological and 

terrestrial impacts of the equivalent roaded acres in the planning area. (6) 

Discussion: The DEIS (Chapter 3) discloses the effects of the proposed activities relative to hydrology

including ERA at the project scale.

Comment-87 - Timber harvest and road building can cause sediment and turbidity problems even when these 

activities take place outside of the reserves. (6, 7)
Elk Flat LSR Enhancement Project

B-34 Shasta-Trinity National Forest

Discussion: The DEIS (Chapter 3) discloses the effects of the proposed activities relative to hydrology inside 

and outstide of the Riparian Reserves. 

Comment-88 - Proposed riparian reserve thinning would not achieve aquatic conservation strategy objectives. (6) 

There are already impacts to soils, water quality, and RR in Ash Creek from previous logging. We don’t believe 

this project will meet ACS objectives. Again, we would expect substantive analyses of these issues that meet the 

requirements of NEPA. (7)

Discussion: The DEIS discloses the effects of the proposed activities relative to the aquatic conservation 

strategy. The Forest Plan Standards and Guidelines for timber management in Riparian Reserves allow for the 

application of silvicultural practices and salvage in Riparian Reserves when they are needed to control 

catastrophic events, control stocking, reestablish and manage stands, and acquire desired vegetation 

characteristics needed to attain Aquatic Conservation Strategy objectives (USDA Forest Service 1995, p. 4-

54). 

Comment-89 - With regard to “large wood” (EA p. 50), NMFS 2010:9 states that “[a]lthough NMFS included this [24 

inch diameter] value in NMFS (1996), and did not advocate changing the value during negotiations on the AP 

document, we recognize now that (1) it does not provide a target that is based on reference conditions for 

Westside forests, (2) this target is not sensitive to site-specific conditions (e.g., stream size and power), and (3) 

use of this target exclusively results in analyses that do not adequately address other sizes of wood that provide 

important ecological functions in streams” Thus the size standards used for the desired condition are not 

appropriate because all sizes wood entering small streams would improve channel function. NMFS 2010 p.6 

states: “[a]ll wood and other organic material, whether large or small, is important to the proper functioning of 

streams; none of it is unimportant.” NMFS further states that “[o]f particular note is that large wood that cannot 

singly form pools will form pools in combination with other pieces of wood and other obstructions by forming 

“wood jams.” The NMFS 2010:4 state: “[w]hile thinning increases tree diameters, it does not increase tree 

heights; thus, it will not increase the length of tree boles entering streams.” (6)

Discussion: The Forest Service recognizes the need for and benefits of large woody debris within riparian 

systems. The project would retain an average of 6 to 10 large down logs per acre as described on page 88. 

Retained logs are to be in a variety of decay classes with a preference for 20-inch diameter logs, or the largest 

size class available. Within all Riparian Reserves, embedded downed logs, stumps and riparian plants and root 

systems will be retained during burning operations with minimal (up to 5%) damage. The project area does 

not contain anadromous fisheries that NMFS is the regulatory and resource agency for. It is not located within 

an anadromous watershed. While the comments included from NMFS (2010) are valuable in terms of overall 

LWD benefits in stream systems, these comments are also out of context. The comments are clearly 

addressing the AP document (which is the 2004 Analysis Process for assessing impacts to anadromous fish 

and habitats within the NWFP area).

Comment-90 - The USFS and BLM should leave more thinned trees on the ground in riparian areas, particularly 

close to streams, on floodplains, and on steep sideslopes where some trees are likely to slide down into streams, 

than are required to meet wildlife needs.(6)

Discussion: The Forest Service does recognize the need for and benefits of large woody debris within riparian 

systems. Currently within the project area there are places (along Ash Creek) where large amounts of woody 

debris have caused debris dams and channel widening. This has resulted in an increased rate of bank erosion 

as water moves around the log jams (see existing condition for a description and photo). After treatment, the 

Forest Service expects the rate of woody debris input would change from the undesirable current state of 

whole tree failure, causing bank erosion and debris dams, to incremental input of woody debris as riparian 

vegetation stabilizes banks and forest stands increase in health and vigor.

Comment-91 - In order to better portray environmental baseline conditions and to understand the likely effects of 

thinning proposals, the USFS and BLM should develop stand data separately for riparian and upland forests.(6)

Discussion: The comment is noted and the Silviculture and Forest Health section and specialist report 

describe the stand inventory methods. Data was collected based on stands – areas with similar tree species, 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit B-35

density, seral stage, canopy cover, overstory tree diameter and stand development characteristics. However, 

the project hydrologist, wildlife biologist and silviculturist conducted field reviews in the Riparian Reserves 

to better describe the existing conditions and develop treatments and resource protection measures. There was 

not a sole reliance on the 2007 Common Stand Exam data and inventory plots for describing the baseline 

conditions in the Riparian Reserves. 

Comment-92 - The document states the No Action alternative would result in continued impacts to water quality and 

stream channel floodplain function and Elk Flat meadow from existing unauthorized routes. This statement is 

telling because it demonstrates that past mitigation from past projects has failed causing water quality problems; 

past activities have likely altered the stream channel floodplain; and illegal OHV use is occurring and the Forest 

has not acted to stop it. The Forest uses this project as a red herring to “fix” these problems. The Forest could 

correct these problems without a timber sale. (7)

Discussion: The Purpose and Need for Action and Proposed Actions recognizes the needs in this Project. 

Currently, there are not other proposals that would also address the identified needs; therefore, No Action 

does not address them. 

Comment-93 - "A copy of the National Marine Fisheries Service 84 page memo (NMFS 2010) supports our 

contention that commercial thinning the riparian reserve is not appropriate and is likely harmful for achieving 

aquatic conservation objectives. NMFS 2010 p. 8 states that “In examining forest thinning proposals designed to 

accelerate the development of late-successional forest conditions and restore instream fish habitat, NMFS is 

finding that, in many cases, they are likely to do neither. NMFS 2010: 31 states “our results suggest that the 

thinning regimes proposed by the Siuslaw National Forest will delay the development of key structural elements 

of forest and stream habitat by more than a century. The delay in stream habitat recovery can be minimized by 

creating a no cut buffer of 150 feet or more in width between streams and any forest thinning operations.” The 

NMFS 2010: 4 states that “[t]he tradeoff of getting a few more large standing live trees sooner at the expense of 

a continuous supply of both large and small trees over the long term period always needs to be considered.”" (6)

Discussion: The DEIS describes the specific thinning treatments proposed for the Riparian Reserves. The 

treatments are designed to address site-specific variation within the Riparian Reserves. Thinning would be 

implemented to both retain current stand densities for shade and thermal regulation on terraces, and reduce 

shade to promote riparian vegetation development for near-stream shade, water temperature, thermal 

regulation, stream bank strength, and stream bank stabilizing vegetation such as willow (Simon, et al., 2002). 

Resource protection measures are included in chapter 2 of the DEIS to ensure that the activities are consistent 

with the ACS objectives and Riparian Reserve function. See also Comment-89 regarding NMFS. Again, while 

the comments included from NMFS (2010) are relative to the ACS objectives and late-successional reserves, 

they are also placed out of context. The Elk project will have site-specific protection measures and treatments 

for the Riparian Reserves associated with Elk Flat, along Ash Creek and other portions of the project area (see 

Figure 2 in Chapter 1). 

Comment-94 - The forthcoming NEPA document must analyze and disclose the impacts of road construction, 

landing construction, timber haul and soil compaction on peak flows, flow timing, and sediment loading.(6)

It appears the Forest Service is proposing logging activities within designated riparian reserves. Aquatic 

conservation is therefore a significant issue for this action. Direct, indirect, and cumulative effects of proposed 

activities on hydrologic function, sediment regimes, stream temperatures, nutrient cycling, pH, and habitat 

connectivity should be evaluated in detail. Consider both positive and negative impacts. Implement the ACS at 

the site scale and meet its objectives immediately after the project’s implementation, not in the “long-term” 

several years out.(6)

Discussion: The purpose and need recognizes old landings and unauthorized routes exist on Ash Cr 

floodplains and recontouring floodplains is needed to promote the Aquatic Conservation Strategy. The DEIS

(Chapter 3, Hydrology section) discloses the effects of the proposed activities relative to hydrology. 

Comment-95 - The USFS and BLM should include all sizes of wood in describing environmental baseline conditions 

and in analyzing the effects of its proposed actions, not just pieces of wood that are greater than 24 inches in 

diameter and greater than 50 ft in length.D137(6)
Elk Flat LSR Enhancement Project

B-36 Shasta-Trinity National Forest

Discussion: In the DEIS, Chapter 3, Methodology for fire and fuels, as well as the fuels specialist report, the 

inventory is described. Surface fuel data collection was completed using the Brown’s method. This inventory 

accounts for all down wood from less than 1⁄4” to the largest log. The 2007 Common Stand Exams, and follow 

up field reviews in 2011-2015, documented the coarse wood size classes. As fuel accumulations have 

increased since 2007, the data collected at that time should only be seen as a general representation of size 

classes. The majority of additional CWD recruitment has occurred in the ponderosa pine-dominated stands 

located in the eastern and southeastern portions of the project area. However, additional pockets of mortality 

scattered across all natural stands and older plantations, and diseased white fir, have also contributed.

Comment-96 - The USFS and BLM should adjust their tree diameter targets based on stream size. Database curves 

are available for both functional-sized and key pieces of wood (e.g., Fox and Bolton 2007).I134(6)

Discussion: See the discussion for Comment-93 for the thinning prescriptions developed near streams. 

Comment-97 -We urge the Forest Service to propose and implement a vegetation management project that 

implements the ACS of the Northwest Forest Plan and the findings and recommendations of the Watershed 

Analysis by:

Avoiding and deferring new road construction;

Minimizing new landing construction; and

Decommissioning unneeded roads.(6)

Discussion: No new permanent roads are proposed for construction. Limited temporary road construction is 

proposed (with decommissioning post-project). Existing landings will be used where feasible and if in 

compliance with all RPM’s (legacy landings in Riparian Reserves will not be utilized and all new landings 

will be constructed outside of Riparian Reserves), minimizing new landing construction. Decommissioning 

existing unauthorized routes, new temporary roads, landings and skid trails is included in the action 

alternatives considered in detail. 

Comment-98 - Please analyze and disclose the cumulative effects from past, current and future logging, cattle 

grazing and other land management activities and their effect on Riparian Reserves and riparian dependent 

species.(9)

Discussion: Please refer to Comment-62. The hdrology analysis in the DEIS discloses cumulative effects.

Wildlife

Comment-99 - Reducing basal area down to 150 square/feet acre does not maintain high quality foraging habitat or 

nesting/roosting habitat. (7) 

Thinning to 50-70 foot spacing with a basal area of 60 square/foot per acre would not retain foraging habitat for 

the owl. The proposed action will destroy the entire function of the LSR and the CHU. (7) 

Discussion: The wildlife Biological Assessment will address the predicted effects of the variable density 

thinning treatments and prescribed basal areas, prescribed fire, and other treatments on NSO habitat 

(including critical habitat) in the short and long term. This information will be summarized in Chapter 3 of the 

EIS. The analysis will also discuss the proposed activities effects and compliance with LSR direction and the 

Final Rule for NSO critical habitat (December 2012). 

Comment-100 - Logging for fuel reduction impacts owl and prey habitat, e.g. reduction of complex woody structure, 

and the long-term reduction in recruitment of large snags and dead wood. Fuel reduction logging also has 

complex effects on fire hazard with potential to increase fire hazard, especially when fuel reduction efforts involve 

removal of canopy trees. (6) 

Discussion: The predicted effects of the proposed activities, such as fuel reduction, on the northern spotted 

owl and its prey will be described in the wildlife Biological Assessment. This information will be summarized 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit B-37

in Chapter 3 of the EIS. The project-level fuels report and EIS will also asses and summarize the expected 

effects of fuel reduction relative to fire behavior and intensity effects.

Comment-101 - We would expect a legitimate BE be prepared for this project that discloses all direct and indirect 

impacts to sensitive species. We already know the Forest’s determination for all sensitive species is “may affect, 

not likely to adversely affect” because that is the determination made for each and every project in the SMMU. 

But now that we have documented at least 10 major FS projects and 40 THPs in the SMMU – that are all logging 

late-successional habitat, increasing fragmentation, and decreasing connectivity, we would ask that a 

substantive rationale be provided for MANLAA determination for each species. 

Discussion: The Forest will prepare a Biological Evaluation that addresses the proposed project activities and 

their predicted direct, indirect and cumulative effects on sensitive wildlife species.

Comment-102 - When all this evidence is put together, it becomes clear that "saving" the spotted owl by logging its 

habitat to reduce fuels often does not make any sense. (5)

Discussion: The project does not propose to ‘save the spotted owl by logging its habitat to reduce fuels’. The 

proposed action was designed based on direction in the NWFP, Forest Plan and Forest-wide LateSuccessional Reserve Assessment (LSRA) treatment objectives. Without action, continued losses in early-, 

mid- and late-successional stands and existing and developing structural composition are expected to result 

from the combination of tree overstocking and density-related mortality, root disease, epidemic insect attacks 

and predicted lethal fire effects. Then “No Action” alternative and its effects on overall tree growth, stand 

health (approximated using Stand Density Indices based on tree species composition) and fire behavior (of 

unplanned/natural ignitions) will be modeled and summarized in the EIS. The expected general results of “No 

Action” are a continued loss of late-successional tree species (i.e., the pine component), continued stagnation 

of habitat development for late-successional dependent wildlife species (as well as a decline in habitat 

quantity and quality), and failure to maintain or meet Forest Plan and LSRA objectives for the Elk Flat LSR 

and surrounding stands. While NSOs can make use of some post-fire landscapes, fire also reduces the 

function of some habitat and likely removes important habitat (nesting/roosting) from immediate usability, 

particularly in areas of high-severity fire.

The proposed action includes risk reduction treatments in early-, mid- and late-successional habitat, consistent 

with the NWFP, Forest Plan and LSRA. The variable density thinning treatments that will thin trees to varying 

stand basal areas (dependent on species composition); retain unthinned patches of large and small trees, whole 

stands and microsite habitat elements (e.g., patches or small groups of small and large trees for 

roosting/resting sites); install small ~1⁄4-acre and large (~2 acre) gaps in homogenous plantations or white firdisease centers; and radial thin around legacy pine and black oak are also consistent with several of the dry 

forest restoration principles and ecological forestry approaches discussed in the Revised Recovery Plan for 

the Northern Spotted Owl (USDI-FWS 2011) and the Final Rule for NSO Critical Habitat (USDI-FWS 2012). 

Strategic treatment of surface and ladder fuels where they exceed Forest Plan standards and guidelines and to 

meet wildlife habitat capability models, and reintroducing fire, are also included in the proposed action. The 

proposed action will not log within nesting/roosting and higher quality foraging habitat for the NSO (or 

important reproductive habitats for the Forest Service sensitive northern goshawk and fisher). Prescribed fire 

will be implemented in these areas however, with the mechanical thinning and fuels reduction treatments 

discussed above strategically placed to better protect these habitat areas from loss. The Forest Service expects 

that implementing these treatments would reduce the risk of further stand loss and increase resiliency in the 

treated stands so they are better able to withstand and survive disturbances like prolonged drought, root and 

other diseases, insect attacks and low to moderate-severity fire conditions. 

Comment-103 - We note the north side of the project area is clearcut as well as the south side. There is one THP 

that appears to be inside the project area. How is the FS maintaining dispersal habitat and connectivity with this 

significant level of current forest fragmentation? The loss of forest habitat and the dramatic increase in 

fragmentation is obviously impacting NSO that continue to decline by 5.5% in N CA. (7)
Elk Flat LSR Enhancement Project

B-38 Shasta-Trinity National Forest

Discussion: It is not clear what the comment is referring to in terms of the north side of the project area being 

clearcut. There is private land immediately north and west of the project area, but not within the project area. 

There are planned and ongoing Timber Harvest Plans on the private lands in these areas where regeneration 

harvest has been used in the past, and is also planned in the future. There has been no regeneration harvest in 

the northern portion of the project area however. The comment’s reference to clearcuts in the south side of the 

project area is also not clear. A clearcut is defined as “a stand in which essentially all trees have been removed 

in one operation (Society of American Foresters 2010). The Pilgrim Vegetation Management Project treated 

three units (305, 453, 456) southeast of the project area with a regeneration harvest that retained 15% of the 

treatment stand and it may appear to be a ‘clearcut’. Prior salvage treatments within the south-central portion 

of the project area also occurred (see EIS Appendix G that discusses cumulative effects). These treatments 

were deemed appropriate for those projects and the existing conditions within the ponderosa pine-dominated 

and white fir stands of root disease and insect attacks, though each treatment retained reserve trees that were 

healthier or a different species than ponderosa pine. Directly south of the project area is Coonrod Flat, and 

this area is a natural opening and may appear to be a ‘clearcut’. 

Regardless, the habitat typing for NSO in the project area and action area (including private lands and NFS 

lands outside the project area) will be completed for the Elk LSR Enhancement project. From field reviews, 

portions of areas to the north, west and east (and all areas south and southeast) of the project area are not 

considered suitable or dispersal habitat for the NSO. Additionally, portions of the eastern/southeastern portion 

of the project area are also not considered suitable or dispersal habitat, primarily due to the ponderosa pinedominated stands, lack of prey base and low water availability. With the Elk LSR Enhancement project, the 

Forest aims to maintain dispersal and connectivity where it occurs within the LSR through various treatments 

that will maintain adequate canopy cover, tree size classes, perching and roosting structure, large and small 

down wood, small trees, shrubs and prey base that support dispersing NSOs, fisher, and northern goshawk. 

The Riparian Reserve network along Ash Creek would also contribute to connectivity within the LSR and its 

varied successional habitats, in accordance with the Forest Plan (USDA-FS 1995 pp. 3.27, 4.14, 4.41). The 

Forest Service currently has no influence on management of surrounding private lands and maintaining 

connectivity, though privately managed timberlands are required to comply with the California Forest Practice 

Rules and often include protection measures along streamcourses and to maintain habitat elements in 

proximity to NSO and other federally listed and state-protected species. The wildlife Biological Assessment, 

Biological Evaluation and Draft and Final EIS will evaluate connectivity within and outside of the Elk Flat

LSR in relation to other LSRs. 

The Forest is aware of the range-wide annual population decline of NSO, which was reported as 2.8% in the 

2012 meta-analysis (Forsman, et al., 2011; Forsman, et al., 2012). That meta-analysis was based on annual 

survey data from 1985-2008 in the 11 demographic study areas under the NWFP. In regards to the 5.5% 

decline noted in the comment, it is not clear what this number refers to as there are no “5.5% declines for N 

CA [northern California]” noted in any of the recent literature, 2011 Revised Recovery Plan, 2012 Critical 

Habitat Rule, the 2011/2012 meta-analysis or any other NSO study area reports for northern California. The 

Northwestern California demographic study area’s estimated population decline (based on annual survey 

results and response rates) has been less than 3% since monitoring began in 1985 (Franklin et al. Various 

Years). That specific demographic study area is located ~65 miles west of the project area in a much different 

habitat type. There are no demographic study areas on the Shasta-McCloud Management unit; however local 

species status information for NSO on the SMMU and the project area (extending from 1989 to current year), 

as well as any updated rangewide population information, will be discussed in the project’s wildlife 

Biological Assessment.

Comment-104 We look forward to reviewing the voodoo science the FS used to claim that Recovery Actions 10 and 

32 will be met in this project. (7)

Discussion: How the Forest interprets the proposed action, project design and the project’s overall 

consistency with the Revised Recovery Plan, including prioritization under Recovery Action 10 and habitat 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit B-39

conservation and enhancement under Recovery Action 32, will be addressed in an appendix to the Biological 

Assessment.

Comment-105 - The document states there are only 720 acres of designated critical habitat in the project area. 

Please break down the amount of N/R/F habitat that makes up these 720 acres. We also request the amount of 

N/R/F habitat in the owl AC and LSR. What are they pre project and post project? How does thinning ALL 

foraging habitat in the LSR/CHU benefit the owl and other late-successional species. Every project on the maps 

we included have logged virtually ALL remaining owl foraging habitat. We fail to see how this benefits the owl 

when its population continues to decline on the Forest. (7)

Discussion: Under the 2012 Final Rule that designated critical habitat for the NSO, there are 720 acres within 

the project area (wholly in the western portion). The PENDING-Wildlife section in Chapter 3 of the dEIS and 

the Biological Assessment (to be included as an appendix to the EIS) will address the existing 

conditions/acres of nesting/roosting, foraging, dispersal, capable and non-habitats for the NSO. This baseline 

information for the project area (and NSO action area) will also be included for the ST-215 activity center 

core and home range, and any additional activity centers in the action area, critical habitat and the LSR 

allocation. Effects to these habitat types will also be discussed, including the beneficial, discountable, 

insignificant, adverse short-term, and short- and long-term beneficial effects. 

Comment-106 - The document states NSO have been detected in the project area since 2003, but in 2012 a Barred 

owl pair was discovered. How will this project decrease the value of habitat for NSO and increase the value of 

habitat for Barred owls? How will NSO prey be affected? (7)

Discussion: The proposed action scoping document states “The last nesting at the ST-215 activity center 

occurred in 1990 and no NSOs have been detected during the surveys completed over the nine years of 

surveys since 2003 (District NSO Survey Records).” Information was provided to the Forest on May 9, 2013 

(after the scoping document was released) by a local contract biologist regarding the find of a probable NSO 

feather in the ST-215 activity center in June 2011 and this information will be included in the species status 

and survey section of the Biological Assessment. A barred owl pair was detected in 2012 and NSO survey 

efforts based on the most recent (January 2012) survey protocol will be continued through and after project 

implementation, per annual discussion and coordination with the FWS. Effects to prey that NSO may utilize 

in the project area, and the potential for competitive barred owl/NSO interactions will also be discussed in the 

project Biological Assessment. -. In the map we included documenting all the owl ACs that CalFire lists in the 

SMMU, there is only one AC in the project area. However, the Elk LSR has at least 6 other ACs nearby that 

are being impacted by the other FS TS and THPs. How is the FS working to recover the NSO on the STNF 

when it is logging all CHUs, logging all remaining foraging habitat, and nesting/roosting habitat is below 

threshold levels in every AC throughout the SMMU. (7) 

The Biological Assessment and EIS will address connectivity within the Elk Flat LSR (and outside of it to 

other LSRs which typically either had or have an NSO occupied activity center). An appendix to the 

Biological Assessment will also discuss the Forest’s interpretation of the project’s consistency with Recovery 

Plan’s recommendations for Recovery Actions 10 and 32 (see Comment-104). It is beyond the scope of this 

project to assess other treatments on private lands or National Forest System lands within critical habitat and 

those effects (unless they fall within the action area as defined under the ESA or the established cumulative 

effects analysis area for NEPA). Effects to the East Cascades Critical Habitat Unit, specifically Subunit 3-East 

Cascades South [ECS-3], will likely be addressed in the project Biological Opinion however, pending the 

determination for critical habitat. Treatments in other project areas in close proximity to the Elk LSR 

Enhancement project that affected NSO critical habitat (e.g., Mudflow, Algoma) and those that are more 

distant (Porcupine) were designed to maintain foraging and dispersal habitat function post-treatment while 

increasing overall tree and stand resilience. Those projects were also designed to not treat within 

nesting/roosting habitat or higher quality subsets of NRF habitat. While the Algoma project may have shortterm adverse effects to critical habitat elements of foraging (PCE3), the other three projects were found to 

have beneficial and insignificant effects. Annual stand searches at activity centers (as time, staff and funding 

permit) and project-level surveys in these areas have continued and will continue, providing the SMMU with 
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B-40 Shasta-Trinity National Forest

additional data on NSO occupancy and annual reproduction, though survey results may not always be 

conclusive given the potential presence of barred owls. 

Comment-107 - The regional decline of migratory birds is a significant issue for this project. Numerous studies have 

reported local and regional trends in breeding and migratory bird populations throughout North America (e.g., 

DeGraaf and Rappole 1995, Sauer et al. 2004). These studies suggest geographically widespread population 

declines that have provoked conservation concern for birds, particularly neotropical migrants (Askins 1993). (6)

Discussion: The project was designed in accordance with Forest Plan and LSRA management direction 

LSRA and recommendations from the Watershed Analysis. Opportunities to promote conservation of 

migratory birds and their habitats in the project area were considered during project and resource protection 

measure (RPM) development. This is in accordance with the December 2008/June 2014 Memorandum of 

Understanding, specifically Section C: item 1, and Section D: items 3a-3d, and 6. The migratory bird report 

for the project will address the bird species of management concern for the Forest. This includes those that are 

listed under the Endangered Species Act as threatened or endangered, those designated by the Regional 

Forester as sensitive, those associated with management indicator assemblages (MIAs) affected by the 

project, and those species of conservation concern within the Great Basin Bird Conservation Region (BCR-9; 

(USDA-FS & USDI-FWS, 2008). The project and specific treatments were designed to help ensure that 

treated areas continue to provide habitat necessary to maintain a diversity of species at both the stand and 

landscape scale after the project is completed. This includes development and implementation of specific 

RPMs that limit operations in important breeding areas at critical reproductive times and that retain shrubs, 

trees, down logs and snags that provide habitats for migratory birds. Treatments were designed to reducing 

reduce the risk of continued tree and stand loss and increase stand resilience; accelerate development of latesuccessional and old growth forest; restore meadow habitat at Elk Flat; retain (and enhance) black oak and 

aspen habitats; improve water table elevation, streamflow and water quality and vegetation conditions within 

riparian reserves; and decommission unauthorized routes. The RPMs and treatments are intended to reduce 

the potential for adverse effects to, and enhance habitats for, individuals that are part of local and regional 

populations. But they are not considered significant at the scale of affecting local or regional population 

patterns that may be more threatened in other parts of their range or the region due to climatic and weather 

patterns, predation, or other threats. 

Comment-108 - Simply concluding that the scale of the project is small, relative to the size of the nation, hence 

migratory bird populations will not be affected, will not suffice. As you know, the Spotted Owl was driven into 

threatened status by lots of “little clearcuts” that individually were insignificant, but cumulatively resulted in 

extensive habitat loss. (6)

The project includes numerous RPMS aimed at reducing the potential for adverse effects to individuals that 

are part of local and regional populations. It is designed to enhance and protect late-successional habitat and 

restore riparian and meadow habitat within the project area and provide for a variety of migratory bird 

habitats in a variety of stages (see also Comment-107).

Comment-109 - Please consider and disclose how logging, particularly group selection and regeneration in 80-120 

year old natural stands would effect cavity nesting birds. The Northwest Forest Plan Standards and Guidelines at 

pages C-45-47 requires specific protection buffers for certain bird species including the White-headed 

Woodpecker, Black-backed Woodpecker, Pygmy Nuthatch and Flammulated Owl. Three of these cavity-nesting

birds, with the exception of the Black-backed Woodpecker, have home ranges within Siskiyou County. (9)

Discussion: The 2001 ROD (USDA-FS & USDI-BLM, 2001) and Forest Plan include standards and 

guidelines and management recommendations for white-headed woodpecker, black-backed woodpecker, 

pygmy nuthatch and flammulated owl. There are no ‘protection buffers’ but the standard and guideline is: “To 

ensure that the distribution and numbers of all four species do not decline on BLM Districts and National 

Forests within the range of the northern spotted owl, adequate numbers of large snags and green-tree 

replacements for future snags in appropriate forest types within the range of these four species will be 

maintained in sufficient numbers to maintain 100 percent of potential population levels of these four species” 

(pp. 33-34). The project area is located within the range of all four species and all species, as of the writing of 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit B-41

this Appendix response, have been observed during the wildlife fieldwork for the project (point counts; snag 

and habitat quality assessments; NSO, northern goshawk and carnivore surveys; project field trips). Where 

safely feasible and available, the project’s design addresses the standard and guideline and subsequent 

management recommendations in the 2001 ROD. This is achieved by: retaining Douglas fir, sugar pine and 

incense cedar snags larger than 20 inches diameter; retaining groups of snags in existing mortality pockets; 

retaining, on average, 7 snags per acre ranging from 15 to 20+ inches diameter with a preference for snags 

larger than 20” or largest size class available; within the forested portions of the meadow unit 402- 

maintaining 15” or larger diameter snags; retaining all predominant trees as well as the majority of the 

dominant and most of the codominant trees within thinning and meadow enhancement stands. The wildlife 

analysis will consider and disclose how the variable density thinning treatments, including planned group 

selections in 40+ year old ponderosa pine plantations and white fir disease infection centers in two 80-120 

year old natural stands (152-1, 160), may affect cavity nesting birds. There is no regeneration logging or 

mechanical regeneration treatment proposed. The wildlife analysis will also disclose other project effects on 

these species’ habitats (underburning, hazard reduction treatments along roads/private property lines). The 

silviculture report and EIS will include modeling data for the variable density thinning treatments that 

describes the existing condition, and the expected post and 20 years post-thinning conditions for tree size 

classes per acre, trees larger than 24” in diameter, and snags. Modeling limitations and assumptions will be 

included in the silviculture, fuels and wildlife reports and the relevant EIS Chapter 3 methodology sections.

Comment-110 - Limited operating periods (LOP’s) can have significant negative impacts to implementing a proposed 

action. LOP’s have serious implementation economic affects. Many of these restrict operations between 

February 1 and September 15. This does not allow much time for harvest activities to occur prior to the wet 

weather period. These restrictive LOP’s will significantly increase logging costs as contractors cannot afford to 

utilize very expensive equipment for such a short time period. It is also more difficult to hire employees with such 

a short guarantee for work. These factors need to be included in your logging cost assessment. (2)

Discussion: Limited operating periods will be used as a resource protection where necessary to reduce the 

potential for adverse effects to breeding and rearing individuals. This includes listed, proposed listed and 

Forest Service sensitive species and their habitats. In the case of the NSO or goshawk, an LOP would offer a 

measure of protection to a known nest site that may reduce or eliminate disturbance during critical periods. 

For fisher or migratory birds or other species of concern, an LOP may be used to protect habitat features that 

may be used or removed. The Forest Plan mandates limited operating periods for listed and sensitive species, 

including northern goshawks (USDA-1995 p. 4.30). It should also be noted that not every LOP and RPM that 

may be needed is currently in the project, and in the event of a new discovery an additional or modification of 

an existing LOP may be required, in accordance with timber sale contract provisions. 

The current proposed LOPs will also be considered during stumpage appraisal. An appraiser can account for 

the added cost of LOP’s in four ways: 1) Extend the length of the contract term. This would allow more time 

for operations; 2) increase the number of times an operation moves in and moves out to address increased 

number of operating seasons. This would increase the moving costs and help reduce the minimum bid for the 

sale; 3) Increase the amount of equipment used. Appraising for increased equipment will increase the overall 

logging cost; and 4) Using a cell on the R5 Log Cost Spreadsheet on the moving tab to “Input the estimated 

days the operation (system wide) is likely to be shut down (without a move-out) over the general operating 

season.” For example: Fire hazard, soil moisture, wildlife. The cost of the shut-down will be added to the sale 

as a whole cost. The appraiser’s experience and knowledge will help them determine the number of days that 

will be affected in LOP and make sure that the proper adjustments are made. 

Comment-111 - We ask that owl surveys be done to protocol prior to sale advertisement in order to eliminate any 

unnecessary LOP’s. (2)

Discussion: The Forest’s ability to conduct annual and pre-project surveys for NSOs, and other species, is 

dependent on annual budgets, the approved Program of Work for the Forest and Management Unit, and 

staffing levels. Surveys have been ongoing and are planned for NSO and are in accordance with the January 

2012 FWS survey protocol. The protocol does include provisions for flexibility and modified surveys (stand 
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B-42 Shasta-Trinity National Forest

searches, spot checks, modified visits) and annual coordination with adjacent landowners and the FWS is also 

planned. The LOPs that are currently proposed for the project are not considered unnecessary (see Comment110) and are a requirement under the Forest Plan or are minimization measures that were agreed to during 

streamlined consultation with the FWS, and technical assistance, to help the Forest Service meet its 

responsibilities under Section 7a(1) of the Endangered Species Act. In any given year, activities may occur 

during the proposed LOPs if NSO stand searches and spot checks, or nest assessments done after June 1 for 

northern goshawk determine there are NSO are no breeding individuals or young. 

Comment-112 - When logging intended to benefit habitat will also reduce the quality of habitat, the NEPA analysis 

must include some evaluation of ecological costs and benefits — e.g., the probability that logging will degrade 

habitat vs. the probability that fuel reduction treatments will interact favorably with fire and thus benefit habitat. 

This evaluation requires an estimate of the probability of future wildfire. To assume, as many analyses do, a 

100% chance of future wildfire over-estimates the likelihood of treatments will interact with fire, thus overestimating the ecological value of fuel treatments, and under-estimating the ecological effects of logging on 

habitat. (5)

Discussion: The project proposes various silvicultural techniques intended to increase the resilience of early-, 

mid-, and late-successional forest stands in the Elk Flat LSR. In the case of a wildfire during the summer 

season, fire behavior modeling predicts rates of spread, flame lengths, and resistance to control that would 

lead to high acreage burned and significant post-fire adverse effects on resources. The Forest Vegetation 

Simulator and Fire and Fuels Extension tool are used to model No Action and what fire behavior would be 

with treatment. This modeling approach is based on data collected from the project area stand exams in 2007 

and from the local Remote Automated Weather Station. Models are typically run under 90th and 97th 

percentile weather conditions and the project’s purpose and need (and the modeling) do not assume a 100% 

chance of future wildfire, but assess what might occur within stands in terms of fire behavior and intensity 

(measured by rates of spread, flame lengths, severity) under those weather conditions. 

Comment-113 - There is a strong interest among the federal land management agencies to conduct widespread 

logging in suitable spotted owl habitat in order to reduce the effect of fire. The agencies view fuel reduction 

logging as beneficial to owl habitat because modeling shows that fire behavior is moderated by fuel reduction, 

but proponents never seem to conduct a careful evaluation of the relative probability, and the relative harms, of 

logging versus wildfire. Strangely, the probabilistic aspects of this issue have been largely ignored in the owl 

science literature, but recently explored in the forest-carbon literature which recently showed that although 

thinning can modify fire behavior, logging to reduce fire effects is likely to remove more carbon by logging than 

will be saved by modifying fire. (5)

Discussion: The comment is noted. See also the responses to Comment-1 and Comment-102. 

Comment-114 - The Agency Must Quantitatively Disclose Future Snag Reductions and How this Will Impact Wildlife, 

Especially Woodpeckers and Cavity Nesters. Large numbers of mature trees and snags will be removed from 

proposed logging units. All of these trees would have died and created snags and down wood for wildlife. (6)

Discussion: There is no realistic method available to “quantitatively disclose” future snag reductions, as tree 

mortality prior to, during and after the project will contribute to snags. In regards to the project’s effects on

current snags and future snag development, as described in Comment-13, the project will retain largest, oldest 

trees as predominant and most dominant trees would be retained, regardless of their current health/condition. 

The project also includes specific criteria for retaining or protecting individual snags and groups of snags as 

described in Comment-20, and Chapter 2 of the EIS (resource protection measures). The UTPs and roost/rest 

clumps will also retain snag habitat. Where safely feasible in LSR, snag retention areas (ranging from 5 to 10 

acres) will be strategically located within or adjacent to existing mortality pockets. Snag retention areas will 

consist of a range of snag size, decay and species classes with a preference for areas that contain larger 

diameter snags (≥24 inches) that also have a live tree component for wind-throw protection and little to no 

understory regeneration in known blackstain infection areas. Retention areas will be delineated by the project 

wildlife biologist and trained marking crew/timber preparation staff. Units 158, 162, 175,176, 204 and 206 are 

known to be affected by high levels of mortality and will likely have snag retention areas. No piling, 

reforestation or other mechanical activities will occur in these areas under the project. In regards to “future 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit B-43

snag reductions”, the analysis for the project is limited to the timeframe that proposed activities would be 

occurring and the timeframes that thinning and fuels treatments are expected to have an effect on the stand 

development (e.g., thinning, landing/road construction, route decommissioning, machine piling/burning piles, 

underburning). This timeframe typically spans 20 to 30 years, and all of these activities may remove trees, 

remove snags, fall trees or snags and leave in place, or create snags. The modeling of the thinning and fuels 

treatments for No Action and Action is expected to show the anticipated tree growth, and snag recruitment, 

over this time period. 

Comment-115 - "Snags are an essential element of forest health, forest structure, and late-successional habitat. 

Thomas et al (1990) and the Fish and Wildlife Service (1990) defined Spotted Owl (old-growth) habitat as 

including “numerous large snags.” Similarly, the Shasta-Trinity National Forest LRMP directs the agency to 

“protect and enhance late-successional characteristics” in LSRs. Large snags are a key late-successional 

characteristic. Hence snags should be retained as essential habitat elements in a Late Successional Reserve." 

(6) 

Discussion: The project was designed to be compliant with the management direction, standards and 

guidelines and LSRA desired conditions for snags. See also the Discussion for Comment-20 and Comment114. 

Comment-116 . The Forest must disclose how much forested habitat will be lost due to these activities. We also 

request that placement of landings be disclosed. Stating those decisions will be made post decision is a violation 

of NEPA. If the Forest has actually ground-truthed each unit as it claims it should be able to disclose where the 

landings will be placed. (7)

Discussion: Chapter 3 will disclose effects from the proposed action and alternatives considered in detail, 

including effects to forested habitat. Landing needs have been reviewed on the ground and estimated by 

alternative.

Comment-117 - The pacific fisher, northern spotted owl, long-legged myotis, fringed myotis, Yuma myotis (all 

bats),western bluebird and pileated woodpecker may all be affected by reduction of forest stand structure, 

canopy closure and/or snag density in planning area. Please address and disclose the cumulative impacts of 

your activities on these species. (6)

Discussion: See also the response to Comment-62. In accordance with the NFMA and Forest Service Manual 

direction, the project’ Biological Evaluation will assess direct, indirect and cumulative effects to Forest 

Service sensitive species (this includes, but is not limited to the fisher, northern goshawk, fringed myotis). In 

accordance with the ESA, the project’s Biological Assessment will assess direct, indirect and cumulative 

effects under the ESA for the northern spotted owl. A separate cumulative effects analysis under NEPA will be 

completed for this subspecies. The information from these analyses that is relevant to the Issue Indicators and 

Purpose and Need for the project will be summarized in Chapter 3 of the EIS. The other species listed in the 

comment are not federally listed or designated by the Regional Forester as sensitive, nor are they special 

status species under the NWFP. The project-level management indicator assemblage and migratory bird 

compliance reports will address representative species for the assemblages (as guided by Forest Plan

direction); and birds of conservation concern within the Great Basin Bird Conservation Region (BCR-9; 

USDI-FWS 2008). See also the responses to Comments 108, 109, 120 and 121. 

Comment-118 - The forthcoming NEPA document should also address the impacts of the proposed logging and road 

construction on Goshawks. A peer-reviewed survey of Goshawk habitat use suggests that current management 

of the bird’s habitat may be inadequate to provide for its persistence in viable populations. Greenwald et al, A 

review of northern goshawk habitat selection in the home range and implications for forest management in the 

western United States. Wildlife Society Bulletin 2005, 33(1): 120-129. (6)

Discussion: The Forest has prepared a wildlife Biological Evaluation according to NFMA and Forest Service 

Manual regulations, which includes the project’s predicted effects to northern goshawks (direct, indirect and 

cumulative effects). A summary of the effects relevant to any Issue Indicators and the project’s purpose and 

need will be disclosed in Chapter 3 of the EIS. 
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B-44 Shasta-Trinity National Forest

Comment-119 - "The forthcoming NEPA document for this project should analyze and disclose the potential impacts 

of conifer thinning operations and brush removal on neotropical bird population trends." (6)

Discussion: Please also see Comment-107 and Comment-119. The compliance section in the EIS will 

summarize the project’s compliance with current direction for migratory birds.

Comment-120 Comment 121 "The cumulative effects analysis on migratory birds should not rely exclusively on 

Wilderness, Riparian Reserves and LSRs to provide for species viability into the future, because many Forest 

Service and BLM Districts are actively logging those land use allocations, regardless of the effects on migratory 

birds, despite their reserve status. We refer you to this very timber sale as one of many examples." (6)

Discussion: Cumulative effects for migratory birds are not assessed under NEPA. Please also see Comment107 and Comment-108 that discuss migratory bird compliance. The project will include a Migratory Bird 

report that discloses the Forest’s compliance with the diversity requirements and direction under NFMA, and 

the December 2008/June 2014 Memorandum of Understanding between the Forest Service and FWS to 

promote the conservation and reduce take of migratory birds. 

Comment-121 - Please develop and implement seasonal operational restrictions to avoid project impacts while land 

birds are nesting in the project area. (6)

Discussion: The project includes protection measures for NSO and northern goshawk during critical breeding 

periods. The project also includes protection measures designed to limit the potential for adverse effects to 

ground-nesting and riparian-obligate migratory bird species in Elk Flat meadow and along the Ash Creek 

Riparian Reserve when underburning. These protection measures will be implemented through use of LOPs, 

managing smoke dispersal, and varying ignition patterns.

Comment-122 - Both carbon and spotted owl habitat tend to accumulate in relatively dense forests with intermediate 

or longer fire return intervals. Thus, we can likely read these studies and replace the word "carbon" with the word 

"spotted owl habitat" and the results will likely hold. (5)

Discussion: The comment is noted. Spotted owl habitat develops over time, and is typically based on tree and 

shrub species composition, tree and snag size classes and conditions, down wood (large, decaying), and soil

types that support these conditions. Prey base is also required. It is not disputed that NSO habitat can be 

shaped by fire, and low to moderate intensity fires can be beneficial due to increases in prey base. But as 

evidenced in recent fires on and near the Shasta-Trinity National Forest (2008 Complexes, 2012 Bagley Fire, 

2014 Complexes), high severity fire removes habitat that is suitable for nesting and roosting NSOs, which is a 

required habitat element for NSO survival and population growth. Abiotic factors such as aspect, elevation 

and slope position also all contribute to habitat development (as well as predicted NSO use). While dense 

forests can provide spotted owl habitat, fires have been more severe in the past decade (see also the response 

to Comment-1). The 2011 Revised Recovery Plan for the NSO describes that while thinning activity removes 

carbon from the forest system in the short-term, it may reduce risk of subsequent carbon release through fire 

or disease outbreak. It states that “Thinning can also encourage carbon being concentrated in fewer, larger 

trees that approximate old-growth structure of pre-fire suppression forests (Hurteau et al. 2008)” though also 

concedes that where, when and how such treatments occur needs to be carefully examined (USDI-FWS, 2011 

pp. III-11). 

The 20-year monitoring report summary for the ‘Status and Trend of Late-successional and Old-growth 

Forests’ states: “some portions of the NWFP area have been setback by decades from achieving those 

outcomes [expectations for older forest abundance, diversity, and connectivity] particularly resulting from 

large wildfires in the fire-prone portions of the NWFP area” ( (Davis, et al., 2015). Also, the summary report 

for the 20-year monitoring of the ‘Status and Trend of Northern Spotted Owl Habitat’ states: “large wildfires 

continue to be the leading cause for loss of NSO habitats on federal lands. Most of these fire-related losses 

have occurred within the network of large reserves that were designed for the protection and restoration of 

habitat for long-term northern spotted owl conservation” (Davis, et al., 2015). This summary report further 

notes that the loss rates in fire prone portions of the NSOs range exceeded the expected 2.5% rate for the 20-
Draft Environmental Impact Statement

Shasta-McCloud Management Unit B-45

year period at rates of 3.9-7.4% per decade. Climate change is expected to expand the area of fire-prone 

landscapes and an increased frequency of large wildfires this century has already been observed. Most large 

wildfires and resulting habitat losses have occurred in the federally reserved land use allocations. Monitoring 

future trends of both wildfire and habitat will be important. 

The 2011 Revised Recovery Plan for the NSO also states habitat loss from wildfire as one of the three main 

threats to its recovery (USDI-FWS, 2011 pp. vii, II-2). It also discusses regional warming and consequent 

drought stress as the most likely drivers of increased mortality rates of trees in recent decades in the western 

United States, noting the increase was evident across the Pacific Northwest and California regions, elevations 

(i.e., topography), tree size, type of trees, and fire-return-intervals (USDI-FWS, 2011 pp. III-9). 

Comment-123 - To justify such fuel reduction logging in suitable owl habitat on ecological grounds requires several 

findings: (1) that wildfire is highly likely to occur at the site of the treatment, (2) that if fire does occur it is likely to 

be a severe stand-replacing event, and (3) that spotted owls are more likely to be harmed and imperiled by 

wildfire than by logging at a scale necessary to reduce fire hazard. Available evidence does not support any of 

these findings, which raises serious questions about the need for and efficacy of logging to reduce fuels in 

western Oregon and other forests lacking frequent fire return intervals. (5)

Discussion: Please see the responses to Comment-4, Comment-5,Comment-100 Comment-102, Comment112and Comment-122 regarding fire and NSOs and NSO habitat.

Other

Comment-124 - Are there grazing allotments that overlap the proposed aspen treatments? (6)

Discussion: The Bartle grazing allotment overlaps the project area.

Comment-125 - "Coarse woody material densities should support the natural range of biota for the site. Snags and 

down logs build soil and provide habitat for a variety of organisms critical to ecosystem recovery after natural 

disturbance. The adaptive management direction of the NFP encourages site-specific research and planning for 

CWM retention." (6)

Discussion: See Comment-23 and Comment-51. 

Comment-126 - Economic consideration is very important for successful implementation of this project. It will be very 

important to assess the feasibility of each logging system in relation to volumes per acre, size of trees being 

removed, distance to landing, species of tree being removed, current delivered log prices, etc. (2)

We ask that you do an in-depth economic analysis in order to make sure your proposal is economically viable. 

Logging costs, fuel costs, and haul costs have all increased dramatically over the last few years. We ask that you 

take these recent increases into consideration in your economic analysis. (2)

Carefully assess and review proposed restrictions and mitigation items. It must be clearly documented they are 

needed. Additional mitigation items will require contractors to incur additional costs for a project that may have 

marginal economics.

Discussion: See Comment-23. Effects relative to economics have been assessed for the project (DEIS 

Chapter 3, Socio-Economics). Although the project objectives are large scale disturbance risk reduction, 

commercial timber sales and stewardship are recognized as a primary mechanism for moving the project area 

toward the desired condition. The project may use a variety of methods including commercial timber harvest, 

service contacts and mechanical fuel treatment to fulfill the purpose and need. A commercial timber sale is 

one implementation mechanism planned for a portion of the project. Depending on the market conditions at 

the time of implementation, biomass material that is 4 to 6.9 inches DBH may not be mechanically thinned 

and removed, but instead would be treated on site with a combination of mechanical treatments, hand thinning 

or thinned with prescribed fire during the underburning operations. The impact of requirements and 

restrictions on timber sale operations is recognized by the Agency. That said, requirements and restrictions are 

a cost of doing integrated resource management on National Forest System lands. This was considered during 
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B-46 Shasta-Trinity National Forest

the development of the project actions and alternatives. Economic viability of timber offerings is considered 

during appraisal and contract preparation processes.

Regardless of the implementation method or funding source, project actions were designed to address and 

enhance environmental conditions that are not monetary to meet the purpose and need. The effects analysis in 

Chapter 3 provides environmental effects of the proposed actions.

Comment-127 - The current industry infrastructure is very important in terms of implementing your projects. This 

needs to be a consideration when assessing economics and project design. As project size and volumes shrink 

during the NEPA analysis it may not individually seem to have any impact on industries ability to implement. But 

cumulatively, as all projects shrink, it has a major impact on the ability to maintain adequate infrastructure to 

accomplish your land management activities. (2)

Discussion: While the Forest Service does recognize industry infrastructure is an important factor in project 

implementation, it is beyond the scope of this analysis to consider the cumulative effect of individual project 

sizes across a wide region on industry infrastructure.

Comment-128 -. The use of Stewardship or even Service Contracts may be necessary to complete the objectives 

outlined for the mortality issues in/around Elk Flat. Please look closely at the economics of the entire project area 

to determine if a commercial timber sale could possibly achieve your purpose & need. A Stewardship will not 

generate receipts for Siskiyou County. We encourage projects that generate a positive cash flow for the Agency 

when possible.(4)

Discussion: A stewardship sale is a method of achieving the ecological objectives of the project, from which 

renewable forest byproducts are expected. A stewardship sale will not be the sole method used to implement 

project actions, however.

Comment-129 - Please disclose and analyze the effects from the proposed activities on heritage resources. (9)

Discussion: A Cultural Resources Report (Johnson, 2015) was completed for this project. The EIS Chapter 3 

summarizes the effects relative to heritage resources.

Comment-130 - Please disclose how all treatment activities would increase the potential for the spread of non-native 

invasive species. (9)

Discussion: Executive Order 13112 addresses preventing the introducing invasive species, their control, and 

minimizing the economic, ecological, and human health impacts of the invasive species. The required 

compliance with this order is discussed in Appendix H. 

Comment-131 - If whole tree yarding/top yarding is proposed make sure landings can accommodate the 

merchantable and unmerchantable material. (2)

Discussion: The proposed mechanical treatment areas were reviewed for implementation viability using 

existing roads, routes, corridors and landings. Landings ranging from 0.5 to 0.75 acres each would be utilized 

as available or constructed if needed to facilitate transfer of forest products to haul trucks. Actual existing 

landing use and new locations of landings would be approved on an individual basis based on the operator’s 

requests at the time of implementation and consistency with RPMs (e.g., some existing landings in the 

project’s Riparian Reserves would not be used). 

Comment-132 - We strongly encourage the Forest to choose the No Action alternative. It can and should also

develop action alternatives that would actually improve late-successional habitat and decrease fire risk by taking 

only the trees 10” dbh and below, and closing roads. While this may not make an economic timber sale, it isn’t 

supposed to. Timber production for the sake of timber production is not permitted in LSR and CHU. (7)

Discussion: The No Action alternative is evaluated in the EIS (Chapter 3). Two alternatives are responsive to 

this issue: Alternative 6-Limit Harvest to Trees Less than 10 Inches in Diameter, and Alternative 8-Limit 

Harvest to Trees Less Than 20 Inches in Diameter within the Elk Flat Late-Successional Reserve. See also 

Comment-68. The project does not propose timber production in LSR and CHU for the sake of timber 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit B-47

production. The project’s purpose and need are clearly outlined in Chapter 1 of the EIS, along with how the 

project aims to meet the direction set forth under the NWFP, Forest Plan, and LSRA. The Forest expects the

network of land allocations that are withdrawn from active timber management113 (e.g., wilderness,

administratively withdrawn areas, wild and scenic rivers, others) to provide habitat adequate to maintain

viable, well-distributed populations of federally listed or proposed and Forest Service sensitive species

(USDA-FS 1995 p. 3-27). Where active management occurs in Late-Successional Reserves and Riparian

Reserves, standards and guidelines and project design features for snags, logs, hardwoods, biodiversity, and 

protection and enhancement of habitats also contribute towards this goal. The use of best available science, 

recommendations form the 2011 Revised Recovery Plan for the NSO, and information from the Final Critical 

Habitat Rule for the NSO regarding active management and special management considerations in the East 

Cascades Critical Habitat unit (and East Cascades South subunit) will be addressed. These recommendations 

and considerations will be summarized in the project’s wildlife Biological Assessment, and relevant portions 

of the EIS.

Comment-133 - Please keep us on the mailing list for this project and forward the DEIS to our office immediately 

upon release. We request that all specialist reports, including the FWS consultation, be posted on the Forest’s 

website. (7)

Discussion: Your name is on the project mailing list. Specialist reports are often posted to the project’s 

website, though those with sensitive information may not be posted, or would be posted with information 

redacted in accordance with the relevant law, regulation or policy. 

113 Including those land allocations such as Late-Successional Reserves or Riparian Reserves that may be treated to

reduce the risk of losing habitat, to enhance habitat, and to contribute to Aquatic Conservation Strategy objectives but that

do not regularly contribute to allowable sale quantity.

Draft Environmental Impact Statement

Shasta-McCloud Management Unit C-1

Appendix D-Standard Operating Procedures and Best Management 

Practices 

Appendix C - Standard Operating Procedures and Best 

Management Practices 

While not meant to be all inclusive, the following practices listed by resource are some of the most pertinent 

compliance items, standard operating procedures (starting page D-1) and Best Management Practices (starting 

page D-4) apply to all similar activities as those proposed in the Elk Project. Site specific Resource Protection 

Measures Common to All Action Alternatives are listed in Chapter 2 (starting p. 81).

Standard Operating Procedures 

The following practices are commonly implemented in similar projects to comply with Forest Plan standards 

and guidelines, Forest Service Policy, Regulation or law. These practices do not represent all standard 

operating or routine compliance procedures. In particular, timber harvest implemented through timber sale 

contracts or stewardship contracts have standard provisions beyond those listed here to protect the 

environment. 

Air Quality

1. All prescribed burning will be consistent with the provisions of the Siskiyou County Air Pollution 

Control District (APCD) rules and regulations through the permit process. The smoke management 

plan would adhere to air quality regulations, and restrictions set forth and approved by the North 

East Air Alliance. A Smoke Management Plan will be completed and submitted to the Siskiyou 

County Air Pollution Control District with the project burn plan. The county would issue a burn 

permit upon approval of the smoke management plan. 

2. During harvest activities, dust will be abated in accordance with Road Maintenance Contract

requirements. If surface water drafting is utilized for watering roads and landings, BMPs (starting p.

D-4) will be required to maintain water quality and prevent the loss of road and landing surface

material.

Cultural Resources

3. If new cultural resources are discovered during project activities, all work in the vicinity will cease

until the Heritage Program Manager or a delegated archaeologist examines and assesses the

resource. Appropriate measures will be undertaken to protect the new resource as activities resume.

4. If ground disturbance is proposed outside of treatment units, a management unit archaeologist will

be contacted to ensure that no historic properties will be affected.

Hydrology and Soils

5. Maintain ground cover (duff and or fine woody debris less than 3 inches) across at least 50 percent

of all activity areas to maintain soil productivity.

6. Prior to entering the harvest units with equipment, the sale administrator will verify ground

conditions are such that operations will not cause resource damage, using the current standard for

soil conditions and operability (e.g. “Wet Weather Operation” guide and “Field Guide to Soil

Moisture Conditions Relative to Operability”). The timber sale administrator will consult with the

unit soil scientist and hydrologist if there is any doubt as to whether ground conditions are
Elk Flat LSR Enhancement Project

C-2 Shasta-Trinity National Forest

satisfactory for operation.114 An earth scientist or hydrologist may be requested by the sale 

administrator to review ground conditions prior to operations in seasonally wet areas. 

7. Implement Best Management Practices (BMPs) and Forest soil quality standards for all activities. 

Best Management Practices will be used to prevent or mitigate project-associated effects related to 

soil erosion, compaction, and productivity and to prevent or mitigate any project-associated effects 

related to water quality. The complete list of BMPs is found in a Water Quality Management for 

Forest System Lands in California (USDA-FS, 2000).115 Follow all BMPs listed (starting on page D4). These BMPs are incorporated into the project design to ensure that potential impacts to soils and 

water quality would be prevented or effectively mitigated and include general and wet weather 

operation schedule information.

8. Standard timber sale contract provisions for landing location would apply to all units containing

seasonally wet areas and intermittent streams.

Invasive Species116

9. Use standard timber sale contract provisions to ensure appropriate equipment cleaning, which

addresses cleaning of ground-disturbing equipment, in the contracts to help prevent the introduction

and spread of weed species into and out of the project area. Similar requirements would apply to

Forest Service operations.

Prior to implementation, exclusion areas (high priority weeds117 10. ) will be flagged with orange and

black “noxious weed” flagging and will be included on contractors' maps. Staging of equipment will

be done in weed free areas.

11. Equipment operating in areas known to be infested with noxious weeds will be washed prior to

leaving the infested area. If new occurrences of noxious weeds are identified during treatment

implementation, equipment used will be washed prior to leaving an infested area.

12. If project implementation calls for mulches, gravel, or fill, they would be certified weed free as these

products become available.

13. Forest Service personnel or contractors will report any new invasive weed populations by calling the

range department at (530) 226-2432 or the district botanist at (530) 926-9665.

Landings and Skid Trails

14. All skid trails and landings will be flagged and approved by the sale administrator in advance of

skidding operations. If it is determined that landings or skid trails need to be constructed outside of a

114 The extent of the wet weather and snowmelt season in Northern California can be very unpredictable, therefore a fixed 

LOP for wet weather conditions will not be set for any of the proposed actions. Standard timber sale contract provisions 

can be used to close down operations because of wet weather, high water, or other considerations in order to protect 

resources.

115 http://www.fs.usda.gov/Internet/FSE_DOCUMEFTS/stelprdb5362512.pdf

116 Per Forest routine practice, if new populations of noxious weeds are found, treatment (will be implemented in 

accordance with priorities set by the Shasta-Trinity National Forest noxious weed program. Other weed infestations will be 

treated by according to District and Forest priorities.

117 Invasive species are rated by the Shasta-Trinity National Forest and may not be listed by the State of California or CalIPC. High priority depends on the species and its location.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit C-3

thinning treatment unit boundary, the appropriate agency resource specialists will be consulted prior 

to construction. 

15. Limit no more than 15 percent of a treatment unit to non-productive purposes such as roads, skid 

trails and landings (Forest Plan pp. 4.25, O-2).118 The objective is to design a skidding pattern that 

best fits the terrain and limits soil impact and pre-designated skid trails, felling to the lead and end 

lining are methods that achieve the objective. Re-use previously created skid trails, yarding 

corridors, temporary roads and landings to the extent feasible to avoid new ground disturbance, 

minimizing soil displacement and concentrated surface flow. 

Sensitive Vascular and Non-Vascular Plants119

16. If new populations of any plant species needing special protection are discovered during project

implementation, an agency botanist will be notified to develop protection measures to maintain

population viability, such as altering or dropping proposed units from activity; modifying the

proposed activity; flagging and avoiding plant occurrences, or restricting the operating period in a

specific area. A limited operating period would depend on the species and phenology at the time of

discovery, and could last four to six months to allow for seed to set. Sensitive species are usually

protected by flagging and avoiding the plant occurrences

Silviculture and Fuels

17. All prescribed burning would follow the guidelines set forth in a prescribed burn plan developed

specifically for this project. Prescribed burning will only be initiated when relative humidity,

temperature and soil moisture conditions are optimal for meeting treatment unit fuel objectives. The

prescribed burn plan will address parameters for weather, air quality, contingency resources,

potential escapes, and personnel and public safety. See also RPMs 24 on page 85, 25 (p. 86), 27(p.

87), 28 (p. 87), 34 (p. 87), 37 (p. 88), 42 (p. 89), and 43 (p. 90).

Road Management

18. All System roads used for the project would be maintained, including installation of rolling dips

where appropriate, to provide adequate drainage and minimize runoff concentrations.

19. BMP 2.21Water Source Development, maintenance activities associated with drafting surface water

for dust abatement includes implementing water quality protection measures such as “drainage or

surfacing measures, limits on location or size, etc.”

Wildlife

20. Standard contract provisions will be included in all implementation contracts for project

implementation to extend protection to any federally threatened or endangered or sensitive wildlife

and plant species listed on the Regional Forester’s sensitive species list. Provisions will provide for

halting operations in the vicinity of newly listed or discovered individuals or populations after

completion of the biological assessment or evaluation, NEPA document or Issuance of Decision.

118 System roads and other dedicated areas are not included in the percentage.

119 At the present time there are no known sites for any sensitive plant species in the Elk project area.
Elk Flat LSR Enhancement Project

C-4 Shasta-Trinity National Forest

Best Management Practices 

Best Management Practices (BMPs) are incorporated into this analysis for application during implementation. 

BMOPs are compiled from Forest Service manuals, handbooks, contract and permit provisions, and policy 

statements to directly or indirectly maintain or improve resource qualities or to abate or mitigate impacts 

while meeting other resource goals and objectives (USDA-FS, 2000 pp. 21-22). The IDT selects BMPs 

necessary to protect or improve the covered resources for specific sites and identifies the appropriate methods 

and techniques for their implementation. While all or portions of individual BMPs may not specifically apply 

to all or portions of the Elk Project, they would be implemented as applicable and per the project design and 

resource protection measures. The following BMPs are particularly applicable to the Elk Flat LSR

Enhancement Project (USDA-FS, 2000):120

Practice 1.4 – Use of Sale Area Map for Designating Water Quality Protection Needs

The Contract would delineate the location of protection areas and insure their recognition and proper 

protection. Protection areas include, but are not limited to; stream courses, meadows, harvest unit boundaries, 

available water sources, Riparian Reserves and roads where hauling is restricted.

Practice 1.10 – Tractor Skidding Design

Skid trails would be designed to fit the terrain, minimize erosion, and keep water from concentrating. The 

Forest Service prior to use by the Purchaser would approve all skid trails. On-site evaluations would be 

documented during implementation. 

Practice 1.12 – Log Landing Location

To locate new landings or reuse old landings in such a way as to avoid watershed impacts. The Purchaser and 

the Sale Administer must mutually agree upon landing locations. 

Practice 1.13 – Erosion Prevention and Control Measures During Timber Sale Operations

To ensure that the purchasers’ operations will be conducted reasonably to minimize soil erosion. 

Practice 1.16 – Log Landing Erosion Control

Contract specifications require the Purchaser to install erosion control measures on landings. Erosion 

prevention and control measures would be designed to insure that landings have proper drainage. This may 

include ditching, outsloping, water barring, and ripping. 

Practice 1.17 – Erosion Control on Skid Trails

Contract specifications require the timber sale operator to install erosion control measures on skid trails. 

Closure work may include mulching, outsloping, water barring, ripping, removal of berms and road barrier 

construction. 

Practice 1.18 – Meadow Protection during Timber Harvesting

As a minimum, meadow protection requirements specified in the Forest Plan would be implemented. The 

Timber Sale Contract prohibits unauthorized operation of vehicular or skidding equipment in meadows or in 

protection zones designated on the sale area map and marked on the ground. 

Practice 1.20 – Erosion Control Structure Maintenance

120 USDA Forest Service, Pacific Southwest Region, September 2000 lists all BMPs and is available at 

http://www.fs.usda.gov/Internet/FSE_DOCUMEFTS/stelprdb5362512.pdf
Draft Environmental Impact Statement

Shasta-McCloud Management Unit C-5

During the period of the Timber Sale Contract, the Purchaser would provide maintenance of soil erosion 

control structures constructed by the Purchaser until they become stabilized, but not more than one year after 

their construction. 

Practice 1.21 – Acceptance of Timber Sale Erosion Control Measures before Sale Closure

Onsite evaluations during operations would be monitored and documented (BMEP AE-1: Timber Sales and 

Roads) and the first winter after the completion of the project (BMPEP T05-Timber Sale Administration). 

Incorporation of this BMP into Timber Sale Contract Provisions is as follows: C6.6, B6.6, B6.63, B6.64, 

B6.65, and B6.66. 

Practice 1.25 – Modification of the Timber Sale Contract

The Timber Sale Contract can be modified or terminated if new circumstances or conditions indicate that the 

timber sale would damage soil, water, or watershed values.

Practice 2.2 – Erosion Control Plan

The Timber Sale Contract requires that a general plan of operations, including planned periods and methods 

of erosion control be developed by the purchaser and presented to the Forest Service. This plan would set 

forth erosion control measures and discuss mitigation required by the Timber Sale Contract. Operations 

cannot begin until the Forest Service has given written approval of the plan. 

Practice 2.12 – Servicing and Refueling of Equipment

Purchasers are required to take all reasonable precautions to prevent pollution of air, soil, and water. 

Purchaser shall furnish oil absorbing mats for use under all stationary equipment or equipment being serviced. 

A Spill Prevention, Containment and Counter Measures Plan is required if the volume of oil or oil products 

fuel exceeds 1,320 gallons in containers of 55 gallons or greater. 

Practice 2.21 – Water Source Development Consistent with Water Quality Protection

Water source development is normally needed to supply water for road construction and maintenance, dust 

control, and fire control. At no time would downstream water flow be reduced to a field that would be 

detrimental to aquatic resources, fish passage, or other established uses. 

Practice 2.22 – Maintenance of Roads

Roads would be maintained in a manner that provides for water quality protection by minimizing rutting, 

failures, side casting, and blockage of drainage facilities. The purchaser and the Forest Service would agree to 

an Annual Road Maintenance Plan that outlines responsibilities and timing of maintenance. This would be 

done before the beginning of the operating season. 

Practice 2.24 – Traffic Control during Wet Periods

Roads that must be used during wet periods should have a stable surface and sufficient drainage provided to 

allow such use while at the same time maintaining water quality. Where wet season field operations are 

planned, roads may need to be upgraded or use restricted. 

Practice 2.25 – Snow Removal Controls to Avoid Resource Damage

When roads are used in the winter, snow removal would be done in a manner to protect roads and adjacent 

resources. Snow berms would be removed where they result in concentration of snowmelt runoff on the road. 

The Purchaser and the Forest Service would agree to measures prior to snow removal activities.
Elk Flat LSR Enhancement Project

C-6 Shasta-Trinity National Forest

Practice 2.26 – Obliteration or Decommissioning of Temporary Roads

Contract specifications would include language that requires all temporary roads and landings to be 

decommissioned as soon as the purchaser has completed work and before the seasonal rain begins. Closure 

work may include mulching, outsloping, water barring, scarifying, removal of berms and road barrier 

construction. 

Practice 5.6 – Soil Moisture Limitations for Mechanical Equipment Operations

The Contract shall require winter shutdown whenever the Forest Service determines that the soil moisture or 

physical conditions have become unsuitable for equipment operation on any area. 

Practice 6.1 – Fire and Fuel Management Activities

Fuel management projects would have management requirements, mitigation measures, and multiple resource 

protection prescriptions documented in the project planning and decision documents. 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit D-1

Appendix E-Maps 

Appendix D – Maps 
Elk Flat LSR Enhancement Project

D-2 Shasta-Trinity National Forest

Figure Appendix E-1. Alternative 1 Modified Proposed Action Map
Draft Environmental Impact Statement

Shasta-McCloud Management Unit D-3

Figure Appendix E-2. Alternative 1 Fuels Map
Elk Flat LSR Enhancement Project

D-4 Shasta-Trinity National Forest

Figure Appendix E-3. Alternative 2 Map
Draft Environmental Impact Statement

Shasta-McCloud Management Unit D-5

Figure Appendix E-4. Alternative 2 Fuels Map
Elk Flat LSR Enhancement Project

D-6 Shasta-Trinity National Forest

Figure Appendix E-5. Alternative 3 Map
Draft Environmental Impact Statement

Shasta-McCloud Management Unit D-7

Figure Appendix E-6. Alternative 3 Fuels Map
Elk Flat LSR Enhancement Project

D-8 Shasta-Trinity National Forest

Figure Appendix E-7. Alternative 1 Aerial Imagery Map
Draft Environmental Impact Statement

Shasta-McCloud Management Unit D-9

Figure Appendix E-8. Wildland Urban Interface Map

Draft Environmental Impact Statement

Shasta-McCloud Management Unit E-1

Appendix F- Threatened and Endangered Species 

Consultation 

Appendix E – Threatened and Endangered Species 

Consultation Record

Draft Environmental Impact Statement

Shasta-McCloud Management Unit E-3

ESA Consultation and Coordination Section 

Elk Late-Successional Reserve Enhancement 

Project 

Shasta-Trinity National Forest

Shasta-McCloud Management Unit

T 40N R 1W Sections 4 and 5; T 41N R 1W Sections 27-34 

Mt. Diablo Meridian

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

activities on the basis of race, color, national origin, age, disability, and where applicable, sex, 

marital status, familial status, parental status, religion, sexual orientation, genetic information, 

political beliefs, reprisal, or because all or part of an individual's income is derived from any public 

assistance program. (Not all prohibited bases apply to all programs.) Persons with disabilities 

who require alternative means for communication of program information (Braille, large print, 

audiotape, etc.) should contact USDA's TARGET Center at (202) 720-2600 (voice and TDD). To 

file a complaint of discrimination, write to USDA, Director, Office of Civil Rights, 1400 

Independence Avenue, S.W., Washington, D.C. 20250-9410, or call (800) 795-3272 (voice) or 

(202) 720-6382 (TDD). USDA is an equal opportunity provider and employer.

Draft Environmental Impact Statement

Shasta-McCloud Management Unit E-5

I. Introduction 

The purpose of this ESA Consultation and Coordination section is to provide the reader with the 

consultation background and regulatory framework for the Elk Late-Successional Reserve 

Enhancement Project. 

The Biological Assessment prepared for the project (BA) provides the analysis of effects that are 

expected to occur from implementing the Preferred Alternative (Alternative 1). The DEIS examines the 

other action alternatives. The BA was prepared in accordance with the legal requirements set forth 

under Section 7 of the Endangered Species Act (ESA) of 1973, as amended [16 U.S.C. 1536 (c) et seq. 

50CFR 402] (ESA), and its implementing regulations and follows the standards established in the 

Forest Service Manual direction (FSM 2672.42; USDA-FS 1991) and the guidance provided in the 

Consultation Handbook (USDI-FWS and National Marine Fisheries Service 1998). The BA is available 

in the online project record. 

The Shasta-Trinity National Forest (Forest) obtained a list of threatened, endangered, proposed and 

candidate species for the 7.5-minute USGS quadrangles that comprise the project’s action area121 from 

the United States Fish and Wildlife Service (FWS) Arcata Field Office species portal on February 10, 

2015 (http://arcata.fws.gov). The Forest Service was notified about the FWS’ planned transition to 

utilizing the IPaC system for obtaining official species lists in March 2015 (Fitzgerald 2015) and the 

Forest Service and FWS began providing trainings for the IPaC system in June 2015 (Krueger and 

Nicolaysen 2015). 

Based on the revised methods for obtaining official species lists and new information regarding listed 

species that may be near the Project, a subsequent list that comprises the project’s action area122 was

obtained December 22, 2015 from the Yreka Fish and Wildlife Service field office through IPaC123 at 

https://ecos.fws.gov/ipac/gettingStarted/index. The official list, though truncated to reduce pages in this 

EIS, is attached to the end of this section. The complete list, which includes a listing of the County 

FWS offices in California, a list of potential migratory birds and other non-relevant information is 

included in the BA.

It is important to understand that the IPaC system allows project proponents to input a proposed 

project's location (including estimated or exact boundaries) or an action area so they may instantly 

receive a list of FWS trust resources that may occur within the boundary identified. The list identifies 

potential trust resources that may occur or that may be affected by the project and is not, and should not 

be confused with, a list of species that ‘may be affected’ in terms of an ESA effect determination. An 

ESA effect determination is made through site-specific analysis of a project’s activities in combination 

with the particular species’ known range and habitat requirements, its biology, and the timing, 

magnitude, duration and proximity of project activities. It is also important to understand that many of 

121 For the northern spotted owl, the action area is based on a 1.3-mile radius of proposed activities. It is 15,960 acres; 52% on

National Forest System lands and 48% on private lands managed for timber production.

122 For the gray wolf, the action area is based on a 5-mile radius of proposed activities. It is 86,759 acres; 48% on National

Forest System lands and 52% on rural residential lands and lands managed for timber production.

123 IPaC refers to the USDI Fish and Wildlife Service’s Information for Planning and Conservation. It is a tool meant to assist

project proponents in increasing the compatibility of activities with the conservation of FWS trust resources. It is meant to

assist in implementation of all activities proposed under section 7 or 10 of the ESA. 
Elk Flat LSR Enhancement Project

E-6 Shasta-Trinity National Forest

the FWS field offices generate species lists within the IPaC system based on County-level lists; not 

specific species or habitat polygons. The FWS has been further refining this information and as time, 

data and field office capabilities allow, the IPaC system will move from including species that may be 

within a County to using more specific species and habitat polygons (USDI-FWS 2015). 

In accordance with the ESA and regulatory guidance, only those organisms and critical habitat listed on 

the official species list are considered. The listed species and designated critical habitat considered in 

detail in the BA (and proposed species considered in the project-level Biological Evaluation) are:

Endangered 

• Gray wolf (Canis lupus)

• Critical Habitat is not designated in California at this time (USDI-FWS 1978)

Threatened

• Northern spotted owl (Strix occidentalis caurina)

• Critical Habitat Unit 8, Subunit 3 East Cascades South [ECS-3]

Proposed for Listing as Threatened (considered in project-level Biological Evaluation) 

• West Coast Distinct Population of fisher (Pekania pennanti)

• Critical habitat is not proposed at this time

Species Dropped from Further Consideration 

There are 16 threatened, endangered, proposed or candidate species124 on the official species. Based on 

a review of this list, it is my determination that the project will have no effect on the listed California 

red-legged frog, Oregon Spotted frog, yellow-billed cuckoo (Western U.S. DPS), conservancy fairy 

shrimp, vernal pool fairy shrimp, vernal pool tadpole shrimp, delta smelt or valley elderberry longhorn 

beetle as there is no suitable or potential habitat within the project area, or the project area is wholly 

outside the species’ known or expected range. A detailed consideration for these species is included in 

the BA and they will not be further discussed in this document. The remaining six species are also 

dropped from detailed consideration in this document as they are listed plants that are likely addressed 

in the botanical Biological Assessment (Posey 2015), candidate species that do not require analysis 

(USDI-FWS and NMFS 1998 pp. 1-5 to 1-6) or proposed listed species that are addressed in the 

project’s Biological Evaluation (Jordan 2015c). 

Critical Habitat 

The FWS revised critical habitat for the northern spotted owl (NSO) on December 4, 2012 and the Rule 

became final January 3, 2013 (USDI-FWS 2012). The action area for the NSO contains approximately 

797 acres of critical habitat within Unit 8, Subunit 3 (East Cascades South [ECS-3]). There are 720 

acres within the project area, wholly in the western portion of the Elk Flat Late-Successional Reserve. 

Critical habitat is not designated on surrounding private lands or within the project area’s ponderosa 

pine-dominated stands and meadow at Elk Flat. The remaining 77 acres are located approximately four 

124 Terrestrial wildlife, amphibians, aquatic invertebrates, fish and plant species.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit E-7

miles east of the project area critical habitat, along the base of Black Fox Mountain (see the EIS for a 

general map of critical habitat in the project area, and the BA for the action area map). 

In the Final Rule, the FWS describes that in the drier, more fire-prone regions of the owl’s range, 

habitat conditions will likely be more dynamic, and active management may be required to reduce the 

risk to essential physical or biological features of critical habitat from fire, insects, disease and climate 

change. While the Rule recommends conserving high-quality and occupied habitat in accordance with 

recommendations from the Revised Recovery Plan for the Northern Spotted Owl (USDI-FWS 2011), it 

also describes that long-term recovery for the owl could benefit from forest management actions that 

restore or maintain ecological processes and resilience (USDI-FWS 2012 p. 71908). The Rule’s 

discussion of active management in the East Cascades Unit, and balancing short-term adverse effects 

with long-term beneficial effects in dry forests, relies heavily on recommendations from the Revised 

Recovery Plan. The dry forest restoration principles are highlighted as management options in the Final 

Rule, and federal land managers are also encouraged to consider the range of management flexibility 

contained in the NWFP (USDI-FWS 2012 pp. 71910, 71889). The FWS also supports vegetation and 

fuels management within dry and mixed-dry forests where treatment goals are to conserve or restore 

natural ecological processes, including fire, where they have been modified or suppressed (USDI-FWS 

2012 pp. 71882). 

While the Rule recommends active management, it also describes that treatment activities should be 

focused on lower quality habitat with lower relative habitat sustainability and based on ecological 

restoration and application of ecological forestry principles; or where ecological conditions are most 

departed from the natural or desired range of variability. The Rule recommends following NWFP

guidelines and focusing on lands in or outside LSRs where uncharacteristic disturbance has occurred, or 

where the landscape management goal is to restore more natural or resilient forest ecosystems; avoiding 

or minimizing activities in active NSO territories (or high-quality habitat in those territories); and using 

an active adaptive forest management framework to assess effects of activities on NSOs and their prey 

(USDI-FWS 2012 pp. 71882-71883). 

The East Cascades Critical Habitat Unit is described in the Final Rule (pp. 71930-71931). The ECS-3 

subunit consists of approximately 112,179 acres of land managed by the USDA Forest Service under 

the NWFP, and respective Forests that overlay the subunit (Shasta-Trinity, Klamath, Modoc National 

Forests). The subunit’s function is to provide demographic support in an area of sparsely distributed,

high-quality habitat and Federal land and to provide population connectivity between subunits to the 

north and south. Special management considerations in the subunit are “required to address threats to 

the essential physical or biological features of critical habitat from current and past timber harvest, 

losses due to wildfire and the effects on vegetation from fire exclusion, and competition with barred 

owls” (USDI-FWS 2012 p. 71931). The Final Rule states that “the increase and enhancement of 

northern spotted owl habitat in this subunit is especially important for providing essential connectivity 

between currently occupied areas to support the successful dispersal of northern spotted owls, and may 
Elk Flat LSR Enhancement Project

E-8 Shasta-Trinity National Forest

also help to buffer northern spotted owls from competition with the barred owl” (USDI-FWS 2012 p. 

71931). How the forest interprets the project’s treatments meeting the intent of the Final Rule, the 

management considerations for ECS-3 and the recommendations in the Recovery Plan is addressed in 

the Critical Habitat section of the BA. 

There is no designated critical habitat for the gray wolf in California; critical habitat for the gray wolf is 

only designated in Minnesota and Michigan (USDI-FWS 1978). Therefore, effects to critical habitat for 

the listed gray wolf will not be discussed further in this document. 

There is no proposed critical habitat for the West Coast DPS of fisher at this time. The FWS has “found 

the designation of critical habitat to be ‘not determinable’ for the West Coast DPS of fisher” (USDIFWS 2014 p. 60420). Therefore, effects to critical habitat for the proposed listed fisher will not be 

discussed further in this document.

II. Consistency with Resource Plans and Other Guidance

The content of the project BA complies with the legal requirements set forth under Section 7 of the ESA 

[19 U. S. C. 1536 (c), 50 CFR 402] and standards established in Forest Service Manual direction (FSM 

2672.42). It used the best scientific and commercial information available at the time of preparation to 

determine the likely effects of the preferred alternative on federally listed species and designated critical 

habitat. The Elk LSR Enhancement Project is guided by management direction found in the ShastaTrinity National Forest’s Land and Resource Management Plan, which incorporated the Northwest 

Forest Plan (NWFP), as amended.

Northwest Forest Plan and Shasta-Trinity National Forest Land and Resource 

Management Plan

The Forest is operating in full compliance with the Record of Decision for Amendments to Forest 

Service and Bureau of Land Management Planning Documents within the Range of the Northern 

Spotted Owl (NWFP ROD; USDA-FS and USDI-BLM 1994).The Regional Forester approved the 

Forest’s Land and Resource Management Plan (Forest Plan) on April 28, 1995 and it became effective 

June 5, 1995 (USDA-FS 1995).The Forest integrated direction from the NWFP ROD into its Forest 

Plan through reproduction of its Standards and Guidelines. The NWFP standards and guidelines were 

subsequently updated in 2001 (USDI-FS and USID-BLM 2001). The Forest Plan adopts the NWFP as 

the Federal contribution to the recovery of the northern spotted owl and this Project has been designed 

to be consistent with all applicable Forest Plan and NWFP guidance. The Forest expects the network of 

land allocations that are withdrawn from active timber management125 (e.g., wilderness, 

125 Including those land allocations such as Late-Successional Reserves or Riparian Reserves that may be treated

to reduce the risk of losing habitat, to enhance habitat, and to contribute to Aquatic Conservation Strategy 

objectives but that do not regularly contribute to allowable sale quantity.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit E-9

administratively withdrawn areas, wild and scenic rivers, others) to provide habitat adequate to

maintain viable, well-distributed populations of federally listed or proposed and Forest Service sensitive

species (USDA-FS 1995 p. 3-27). Where active management occurs in Late-Successional Reserves and 

Riparian Reserves, standards and guidelines and project design features for snags, logs, hardwoods, 

biodiversity and protection and enhancement of habitats also contribute towards this goal.

Forest-wide direction, which applies to all management areas, is described on pages 4-11 through 4-30 

of the Forest Plan. Management Prescriptions are described on pages 4-33 to 4-71 and Management 

Area direction is on pages 4-80 through 4-85. Project activities will occur in Late-Successional Reserve 

(LSR) and matrix, including the Riparian Reserves that also overlap these allocations. Land allocations, 

management areas and matrix prescriptions within the project area are displayed in Table Appendix F-1 

below. Refer to Chapter 1 of the EIS for additional details regarding specific Forest Plan land 

allocations and direction applicable to the project, including maps.

Late-Successional Reserve Assessment

Late-Successional Reserves or LSRs were established under the NWFP and are intended to provide oldgrowth forest habitat, provide for populations of species that are associated with late-successional 

forests, and to help ensure that late-successional species diversity will be conserved. The management 

objective within LSRs is to protect and enhance conditions of late-successional forest ecosystems, 

which serve as habitat for late-successional and old-growth related species, including the northern 

spotted owl (USDA-FS and USDI-BLM 1994; USDA-FS 1995 pp. 4-37 to 4-43; USDA-FS 1999 p. 1). 

Forest Plan goals describe that the network of LSRs are designated to provide for a viable population of 

northern spotted owls throughout their historic range (USDA-FS 1995 p. 3-27). Protection of LSRs 

includes reducing the risk of large-scale disturbance, including stand-replacing fire, insect and disease 

epidemics, and major human-caused impacts (USDA-FS 1999 p. 1). Both protection and enhancement 

can include application of silviculture and other treatments designed to reduce the risk of loss and/or 

accelerate development of late-successional stand characteristics (USDA-FS 1995 pp. 4-37 to 4-39; 

USDA-FS 1999 pp. 174-203). 

In accordance with NWFP Standards and Guidelines (C-11), the Forest prepared a Late-Successional 

Reserve Assessment or LSRA (USDA-FS 1999). The purpose of the LSRA was to develop 

management strategies for the LSRs, determine their sustainability, and provide information to decision 

makers for managing LSRs to meet Forest Plan goals and objectives. Approximately 87 percent of the 

project area is within the Elk Flat Late-Successional Reserve, designated as RC-360 in the LSRA 

(USDA FS 1999 pp. 124-129). The LSRA describes four objectives that guide the development and 

application of treatments in LSRs. The Elk Flat LSR is described as a priority for treatment objective II, 

which is to “promote the continued development of late-successional forests/characteristics” (USDA-FS 

1999 p. 178). The Project is also designed to meet the other three treatment objectives (USDA-FS 1999 

p. 175):
Elk Flat LSR Enhancement Project

E-10 Shasta-Trinity National Forest

I. Protect existing late-successional habitat from threats (of habitat loss) that occur inside and 

outside LSRs. 

III. Protect mid and early-successional vegetation from loss to large-scale disturbance events.

IV. Promote connectivity of late-successional habitat within LSRs.

As described in the LSRA and NWFP, where levels of risk in LSRs are particularly high (East of the 

Cascades and in the Oregon and California Klamath Provinces), they may require additional measures. 

Consequently, management activities designed to reduce risk levels are encouraged in those LSRs even 

if a portion of the activities must take place in current late-successional habitat. While risk reduction 

efforts should generally be focused on young stands, activities in older stands may be appropriate if: the 

proposed management activities will clearly result in greater assurance of long-term maintenance of 

habitat, the activities are clearly needed to reduce risks, and the activities will not prevent the LSR from 

playing an effective role in the objectives for which it was established (USDA-FS and USDI-BLM 

1994; USDA-FS 1999 p. 174). 

Other Forest Plan Land Allocations, Forest Plan Direction and Guidance 

Approximately 445 acres of the project area are classified as matrix with a commercial wood products 

emphasis along the eastern edge of the project area near and within Elk Flat meadow (units 177, 317, 

318, 401 and a portion of unit 402). Per the Forest Plan, Commercial Wood Products lands are managed 

to obtain an optimum timber yield of wood fiber within the context of ecosystem management. 

Investments will be made in road construction, fuels management, reforestation, vegetation 

management and timber stand improvement and timber stands are managed to obtain optimum growth 

and yields using cultural practices (USDA-FS 1995 p. 4-67). The majority of matrix lands are 

considered non-suitable, or dispersal habitat for NSO. 

Riparian Reserves associated with Ash and Swamp Creeks, and their tributaries, comprise 

approximately 245 acres in the project area. Ash Creek bisects the Elk Flat LSR, flowing intermittently 

from late spring through early fall, depending on Water Year126 conditions. The ephemeral channel of 

Swamp Creek cuts across the eastern section of the project area within and along the Elk Flat meadow. 

Riparian Reserves are managed to maintain or enhance riparian areas, wildlife and fisheries habitat, and 

water quality by emphasizing streamside and wetland management and their Standards and Guidelines 

supersede underlying land allocations. The riparian management prescription also emphasizes retention 

and/or enhancement of old-growth vegetation, and the retention and/or enhancement of habitat for listed 

and sensitive wildlife species, as these corridors provide connective habitat for migration, dispersal and 

foraging for several wildlife species (USDA-FS 1995 p. 4-59). All management activities in Riparian 

Reserves must also meet, or not prevent attainment of, the Aquatic Conservation Strategy Objectives 

126 A Water Year is the time period of 12 months for which precipitation totals are measured between October 1 of 

one year and September 30 of the following year to account for spring/summer runoff of the winter’s snowpack 

(USGS). 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit E-11

(USDA-FS and USDI-BLM 1994 pp. B-9 to B-17; USDA-FS 1995 p. 4-53). The Forest Plan Standards 

and Guidelines for timber management in Riparian Reserves allow for salvage and silvicultural 

practices when they are needed to control catastrophic events, control stocking, reestablish and manage 

stands, and/or acquire desired vegetation characteristics to attain ACS Objectives (USDA-FS 1995 p. 4-

54). Three Watershed Analyses (WA) have been completed that include all or portions of the project 

area. They are the Mount Shasta WA (USDA-FS 2012), Edson WA (USDA-FS 2011) and the McCloud 

Flats Ecosystem Analysis (USDA-FS 2004). As described in the EIS and hydrology report, the 

management activities proposed in Riparian Reserves are consistent with management opportunities 

recommended in these Watershed Analyses.

The Project’s design also incorporates supplemental management direction from the Forest Plan for the 

McCloud Flats and Mount Shasta Management Areas. This includes managing the non-timbered 

portion of Elk Flat primarily for earlier seral stage vegetation (p. 4-81) and managing existing 

hardwoods as a stand component to maintain or improve stand health and wildlife habitat (pp. 4-82, 4-

86). 

Table Appendix F-1. Forest Plan land allocations and management areas within the Elk LSR Enhancement 

project area

Forest Plan

Land Allocation

Project Area

3,519 acres

Forest Plan Management Areas 

McCloud Flats (MA2) 

 (2,208 acres; 63%)

Mount Shasta (MA3) 

 (1,310 acres; 37%)

Acres Percent of 

Project Area Acres Percent of MA2 Acres Percent of MA3 

LSR 3,074 87% 1,821 83% 1,253 96%

Matrix

Commercial Wood 

Products emphasis

445 13% 387 18% 57 4% 

Riparian Reserves

Overlaps LSR 

allocation

204 6% 184 10% 20 2%

Riparian Reserves

Overlaps matrix 

allocation

36 1% 36 8% 0 0%

Total 3,519 Acres 2,208 Acres 1,310 Acres

National Fire Plan 

Under the National Fire Plan (USDA and USDI 2000) Federal agencies, working with their State, 

Tribal, and local partners, must accurately assess the level of wildfire risk and types and extent of 

treatments required to mitigate this risk. One approach is to conduct fuels reduction in and around the 

Wildland Urban Interface (WUI) to reduce the risk of stand-replacing wildfire to people, communities 

and natural resources while restoring forest ecosystems to more closely match their historical 

characteristics. The National Fire Plan prioritizes fuel treatments near Communities at Risk (CAR) that 
Elk Flat LSR Enhancement Project

E-12 Shasta-Trinity National Forest

are listed in the Federal Register as urban interface communities within the vicinity of Federal lands 

that are at high risk from wildfire (USDA and USDI 2001). The nearest listed CAR is the town of 

McCloud. While the project area is not within the designated McCloud CAR, it is bounded on the east 

and west by private lands and is approximately 1.25 miles east of the Mt. Shasta Forest subdivision. 

This distance, combined with the Forest’s additional designations of WUI, results in the project area 

containing 1,135 acres of Forest-designated WUI (see below).

Shasta-Trinity National Forest Fire Management Plan 

The Forest is operating under the “Guidance for Implementation of Federal Wildland Fire Management 

Policy” (2009), which defines WUI as “the line, area, or zone where structures and other human 

development meet or intermingle with undeveloped wildland or vegetation fuels”. Generally, the 

Forest-designated WUI is comprised of concentric rings around structures, or groups of structures, up to 

1.5 miles. Within the project area, the 1,135 acres of Forest-designated WUI is associated with private 

lands and infrastructure south of the project boundary (refer to Figure 3 in the EIS). While not 

considered direction, the Forest’s April 2014 Fire Management Plan (USDA-FS 2014) outlines fuels 

treatment goals for four WUI Zones. The 1,135 acres is within Zone 4-the Threat Zone (USDA-FS 

2014 p. 35). This is the area beyond the 1⁄4-mile defense zone (which surrounds structures) out to an 

approximate distance of 1.5 miles. The goal within Zone 4 is to achieve an environment where crown 

fires that are headed toward a community become surface fires before encountering the defense zone. 

The wildfire behavior goal within Zone 4 is to develop a fuels profile that will have moderate wildfire

intensities determined by flame lengths (a measure of fire intensity) of four to eight feet or less on a 

90th percentile (mid to late summer or hotter) fire weather day over most of the land base. The 

mechanical thinning and fuels treatments, combined with follow-up prescribed fire, are intended to

create stand and fuel loading conditions that would allow a natural ignition to be managed for multiple

objectives. While a fire directly adjacent private property may be suppressed, a natural ignition within

the interior of the project area would be a prime candidate for managed fire, under the right conditions. 

Recovery Plans 

Recovery plans often identify tasks that will benefit listed species which may be carried out on or near a 

project site. While listed species’ recovery plans are not considered regulatory documents (USDI-FWS 

2015, 2011 pp. I-3 to I-4) and are not required to be addressed as a part of Section 7 consultation under 

the ESA, the Forest Plan states that “T[hreatened] &E[ndangered] species will continue to be managed 

under existing recovery goals identified in individual species recovery plans” (USDA-FS 1995 p. 3-28) 

and the Standards and Guidelines require the Forest to “[M]aintain and/or enhance habitat for 

TE&S[enstive] species consistent with individual species recovery plans” (USDA-FS 1995 p. 4-30). 

The only recovery plan currently published and in effect for a listed species in the Action Area is the 

Revised Recovery Plan for the Northern Spotted Owl (see below). In order to provide decision makers 

and the FWS with relevant information, and to address general requirements listed under Section 

7(a)(1) of the ESA, the Forest’s interpretation of the Project’s consistency with the Forest Plan standard 

and guideline is included in Appendix C of the BA. 

Revised Recovery Plan for the Northern Spotted Owl
Draft Environmental Impact Statement

Shasta-McCloud Management Unit E-13

In June 2011, the FWS released the Revised Recovery Plan (Recovery Plan) for the Northern Spotted 

Owl (USDI-FWS 2011). It replaced the 1992 Draft Recovery Plan which had been used as a 

foundation, in part, for the NWFP. The Recovery Plan is an important reference for the biology and 

management of the NSO, providing the best overall guidance currently available in regards to the 

survival and recovery of the subspecies. It identifies the primary range-wide threats to the NSO as 

competition with barred owls; ongoing loss of spotted owl habitat as a result of timber harvest, habitat 

loss or degradation from stand-replacing wildfire and other disturbances; and the loss and reduced 

distribution of spotted owl habitat due to past activities (p. vii). It describes a Recovery Strategy which 

includes habitat conservation and active forest management as necessary steps to address these threats, 

including conserving more occupied habitat and unoccupied high-value habitat; and encouraging and 

initiating active management actions that restore, enhance and promote development of high value 

habitat, consistent with broader ecological restoration goals (pp. III-4 to III-5). 

Specific to the dynamic, disturbance-prone, drier forests of the California Cascades physiographic 

province where the project is located, the Recovery Plan recommends active management “in a way 

that reconciles the overlapping goals of spotted owl conservation, responding to climate change and 

restoring dry forest ecological structure, composition and processes, including wildfire and other 

disturbances” (USDI-FWS 2011 pp. III-20 to III-21). The California Cascades also scores high in terms 

of threats from ongoing habitat loss as a result of wildfire, and the effects of fire exclusion on 

vegetation change (USDI-FWS 2011 p. I-8). Management within dry forest ecosystem is described in 

the Recovery Plan, including seven principles that should be part of any dry forest restoration treatment 

(USDI-FWS 2011 pp. III-20 to III-40). 

It also describes that short-term impacts to provide for long-term benefits may occur, and that “land 

managers should not be so conservative that, to avoid risk, they forego actions necessary to conserve 

forest ecosystems necessary to the long-term conservation of the spotted owl. But they should also not 

be so aggressive that they subject spotted owls and their habitat to treatments where long-term benefits 

do not clearly outweigh short-term risks. Finding the appropriate balance to this dichotomy will remain 

an ongoing challenge for all who are engaged in spotted owl conservation and all Federal actions will 

be subject to section 7 consultation allowing for site-specific analyses of the effect on spotted owls” 

(USDI-FWS 2011 pp. II-11 to II-12). 

This BA fully describes the Section 7 consultation process, how recommendations for management of 

dry forests were utilized to develop the silvicultural treatments, and how the project meets the dry forest 

restoration principles. The specific Recovery Actions related to vegetation management on National 

Forest System lands include Recovery Actions 10 and 32. In summary:

• Recovery Action 10 states “Conserve spotted owl sites and high value spotted owl habitat to

provide additional demographic support to the spotted owl population.” The intent of RA 10 is

to protect, enhance and develop habitat in the quantity and distribution necessary to provide for

the long-term recovery of NSO. Where forest stands can be enhanced or developed through

vegetation management activities, they should generally be encouraged, particularly where

long-term goals outweigh short-term impacts. As a general rule, forest management activities

that are likely to diminish an NSO’s home range capability to support NSO occupancy, survival

and reproduction in the long-term should be discouraged. The FWS recognizes, however, that

active forest management may be necessary to maintain or improve ecological conditions. It

supports projects that intend to provide long-term benefits to forest resiliency and restore
Elk Flat LSR Enhancement Project

E-14 Shasta-Trinity National Forest

natural forest dynamic process, notably when implemented in a landscape context with 

carefully applied prescriptions that promote long-term forest health. The FWS also recognizes 

these projects may have both short- or long-term effects to NSOs and suggests treatments be 

designed to minimize impacts as much as possible while keeping with a project’s intent (USDIFWS p. III-46). The Recovery Plan does provide prioritization guidance for treatments in 

current and historic NSO home ranges (USDI-FWS pp. III-44 to III-47), and the Forest 

consulted with the FWS on more specific home range treatment prioritization for this Project. 

• Recovery Action 32 states “Because spotted owl recovery requires well distributed, older and

more structurally complex multi-layered conifer forests on Federal and non-federal lands

across its range, land managers should work with the Service...to maintain and restore such

habitat while allowing for other threats, such as fire and insects, to be addressed by restoration

management actions. These high quality spotted owl habitat stands are characterized as having

large diameter trees, high amounts of canopy cover, and decadence components such as

broken-topped live trees, mistletoe, cavities, large snags, and fallen trees.” The intent of RA 32

is to provide additional support for NSOs while reducing key threats, particularly negative

competitive interactions with barred owls that likely occur where the two species’ home ranges

overlap. Forest stands or habitat patches that meet the described conditions of RA32 are a

subset of nesting, roosting, foraging habitat and actual stand conditions will vary across the

NSOs range. The FWS recognizes these stands or patches may be relatively small (but

important in a local area), may not be easily discernable using remote sensing techniques and

likely require project-level analysis and field verification. The Project biologist completed field

reviews and identified RA32 areas and at the site-potential level, habitat that meets the intent of

RA32 is not proposed for mechanical treatment. While the greater proportion of RA32 stands

and patches are not considered “high quality” NRF habitat, they are the best of what is

available in the project area. These stands and patches either encompass entire “treatment”

units, a portion of a unit (ranging from 10 to 20 acres in size), or are incorporated into the

unthinned patches prescribed in the Forest’s LSRA (USDA-FS 1999 pp. 185, 188). Refer to

Appendix C of the BA for more detail.

The Project’s treatments and overall design were developed to protect, enhance and help ensure longterm sustainability of late-successional habitat in the Elk Flat Late-Successional Reserve, including 

NSO habitat, and contribute toward meeting the goals and objectives of the Recovery Plan while also 

meeting the need for action in the project area. Where applicable, treatments were specifically designed 

to be consistent with the intent of Recovery Actions 10 and 32 and the dry forest restoration principles, 

while following management direction from the Forest Plan, LSRA and best available science on 

thinning and fuels treatments. The Project incorporates recommendations from Recovery Action 11 

(monitoring) and indirectly addresses several other Actions. A detailed description of Forest Plan 

consistency with Recovery Actions 10 and 32, as well as all other Recovery Actions, is included in 

Appendix C of the BA. 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit E-15

Recovery Plans for Other Species Considered in Detail

There are no recovery plans for any other listed species considered in this document, or the proposed 

listed West Coast Distinct Population of fisher, at this time.

III. Consultation to Date

The focus of the consultation for the Elk LSR Enhancement Project is the threatened northern spotted 

owl (NSO) and its designated critical habitat, and the endangered gray wolf. The life history of both 

species dictates the habitat characteristics and spatial scales considered in this analysis (summarized in 

the Species Status section of the BA. Streamlined consultation offers action agencies like the Forest 

Service an opportunity to address their conservation responsibilities under section 7(a)(1) of the ESA, 

similar to the early consultation process described at 50 CFR 402.11. Region 5 of the Forest Service has 

a Memorandum of Understanding with the Pacific Southwest Region of the FWS (USDA-FS and 

USDI-FWS 2013) that outlines procedures for streamlining consultation. This includes early 

involvement by FWS biologists on FS Interdisciplinary Teams (IDTs), FWS participation in FS IDT 

meetings and field reviews, FWS providing feedback to the FS on prescriptions and minimization 

measures that reduce or avoid adverse effects to species and their habitat, and discussions about 

preliminary effect determinations. 

The Forest, through a TEAMS enterprise unit127 initiated consultation for the Project on August 25, 

2009 with the Red Bluff FWS field office. In October 2011, the responsibility for Section 7 consultation 

on the Forest transitioned from Red Bluff to the Yreka FWS field office. What follows is a summary of 

the consultation process between TEAMS and the Red Bluff office, and the detailed streamlined 

consultation process between the Forest and the Yreka office. Throughout the planning process, 

potential treatment units or areas have been added or numbering changed. The units listed here 

correspond to the current Preferred Alternative however. This information is based on IDT meeting 

notes and field reviews, email correspondence, phone conversations, Level 1 meetings, and FS-FWS 

consulting biologist discussions: 

August 25, 2009: Initial IDT meeting with TEAMS wildlife biologist Rick Baxter and fuels specialist 

David Riegle and other TEAMS specialists; silviculturist Lauren Payne from Vegetation Management 

Solutions enterprise unit (VMS); SMMU counterparts, resource specialists, and applicable staff; and 

FWS biologists Keith Paul and Michelle Havens from the Red Bluff FWS field office. Discussions 

relevant to NSO center on the: past, ongoing and future surveys; 2000 NSO Baseline habitat map 

(USDA-FS 2000) that requires field verification and updating; 2008 critical habitat rule [vacated]; 

importance of retaining vertical structure and tree height diversity at 10 and 15 feet for NSO 

127 Enterprise Units are Forest Service resources that offer an internal choice for the accomplishment of the 

agency’s work. The teams operate as independent, financially self-sustaining units funded by Forest Service 

clients. See http://www.fs.fed.us/enterprise/ for more information.
Elk Flat LSR Enhancement Project

E-16 Shasta-Trinity National Forest

roosting/thermoregulation sites; and retaining understory (brush, small trees), the majority of large 

snags and logs, and 0.25-0.5 acre mortality patches for prey base. FWS made a recommendation for notreatment patches every 3-5 acres. The Team discussed balancing the short and long term impacts for 

both the short and long term needs to provide (maintain) and develop habitat for NSO use. Existing 

stand conditions, Common Stand Exam results (USDA-FS 2007), preliminary growth modeling by the 

Forest Vegetation Simulator (FVS), and cumulative effects from private and Forest Service projects 

were also discussed. 

August 26, 2009: Field review in portions of project area by Baxter, Riegle, Payne, other IDT 

members, and Paul and Havens. Field discussions relevant to NSO focused on mortality in the pine 

component and ongoing loss of foraging habitat (unit 162); and the high stand density and habitat value 

in nesting/roosting habitat (unit 150 in ST-215 core). The group discussed the potential to thin this area, 

now since it was not being used by NSO, or to leave the stand to grow/stagnate while treating all around 

it. The potential to underburn only with some hand thinning pre-burning, or creating fuelbreaks along 

the roads surrounding unit 150 was also discussed. Group reviewed a mixed conifer stand with some 

legacy pine and cedar and dense understory of white fir, determining thinning would be beneficial in 

order to develop better quality foraging and nesting/roosting habitat for the future (unit 161 in ST-215 

core).

September 2009: Baxter and Paul visit 22 stands to verify and update the 2000 NSO Baseline habitat 

map (Baxter and Paul 2009). They review initial thinning prescriptions from Payne and Paul provides 

feedback on what treatments would be beneficial for NSO habitat, and the integrity and progression of 

the LSR (Baxter and Paul 2009a). These ideas are presented to Payne and Riegle at the October 20, 

2009 IDT meeting to adjust certain thinning and fuels prescriptions. 

October 2009: IDT conference call. Discussions include the preliminary Arc-based fuels modeling for 

no action where 90th percentile weather condition runs show a fair amount of the project area in passive 

crown fire (see Map 6 data in the BA). Baxter discusses the September 2009 field work and describes 

the updated proposed treatments and NSO habitat map to the IDT. He shares Paul’s recommendations 

that non-NSO habitat should be treated aggressively, low-quality foraging habitat should be treated 

somewhat less aggressively, and nesting/roosting habitat has little or no mechanical treatment. The IDT 

discusses potential for prescribed burning, including opposing objectives in the project area where 

ladder fuels and down woody material are desirable for NSO habitat and the need to find an appropriate 

compromise to reduce the risk of loss while maintaining and enhancing habitat function. Baxter 

describes Paul’s support for prescribed burning in some areas to reduce fine fuel accumulations, but is 

not generally supportive of burning in high-quality habitat. The need for new temporary roads is also 

discussed and protection measures to reduce these in high quality habitat.

June 2010: Payne, Greg Casselberry (IDT lead), Riegle and Debbie Derby (SMMU wildlife biologist 

counterpart) meet to discuss the modified thinning prescriptions provided by Baxter and Paul. 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit E-17

October 2011: Section 7 ESA consultation responsibility for the Forest is transferred to the Yreka FWS 

field office. All prior consultation records for the Project were transferred to the Yreka field office.

November 2011: Project is assigned to a SMMU IDT, with continued support from VMS silviculturist 

Payne, and TEAMS fuels specialist Riegle and biologist Baxter who continued consultation with FWS. 

December 1, 2011: Christine Jordan presents the Draft Project Initiation Form (PIF) at the December 

Level 1 meeting on behalf of Baxter (general discussion of project planning since August 2009, 

estimated acreage of suitable, dispersal and non-habitat for NSO in project area per 2000 Baseline and 

September 2009 field verification by Baxter and Paul). The NSO survey history, existing stand 

conditions and increasing mortality in the southeast and eastern portions of project area’s pinedominated stands, and the planned December 6, 2011 field review, are discussed. Jordan described that 

habitat typing in the action areas (including private lands) needs refinement and will be completed in 

2012, along with continued left side planning by the IDT. This meeting starts the streamlined 

consultation process between the Forest and the Yreka FWS field office, as described in the 

Streamlining MOU (USDA-FS and USDI-FWS 2013).

December 6, 2011: Brief field review of project area by Jordan, Forest Biologist Kelly Wolcott, SMMU 

staff (District Ranger Carolyn Napper, Planning Officer Emelia Barnum, Timber Management Officer 

Ed Domanski) and FWS biologists Brian Woodbridge, Karen West, Dave Topolewski and Michelle 

Havens. Reviewed the extensive mortality area in units 158, 204, 206 to demonstrate ongoing and past 

mortality in ponderosa pine-dominated stands. Reviewed along Ash Creek near the NR habitat block 

(unit 150) to review mortality and fading condition of pine component in a mixed conifer stand. At unit 

206, the group discussed NSO habitat use and the value of this area as prey base, but not as suitable 

NRF due to species composition, nor as functional dispersal due to the lack of overstory canopy cover. 

At the Ash Creek area, the group discussed the potential for salvage (as safely feasible) or machine 

piling and burning some of the dead trees, combined with follow-up prescribed fire in the NR habitat of 

unit 150.

January 12, 2012: Jordan and Derby coordinated with the FWS on SMMU’s annual NSO surveys, per 

recommendations in the survey protocol (USDI-FWS 2012a pp. 4-6). For this Project, the 2012 survey 

year is the start of implementing the revised survey protocol. We discussed that the last documented 

NSO nesting attempt in 1990 failed, and that recent logging had occurred on private lands in the ST-215 

home range. We discussed NSO survey history, that the last verified aural and visual detection of NSO 

in ST-215 was in 2003 (single female), and the adult barred owl detection in 2004. We mutually agreed 

to a 6-visit survey protocol in 2012 and 2013, and to revisit the survey plan in year three, depending on 

results. Adjacent landowners had not granted survey access to date, and Derby contacted Sierra Pacific 

Industries/Hancock to discuss data sharing and coordination. 

December 7, 2011-June 8, 2012: Various IDT meetings, but no fieldwork with FWS. Both agencies 

identify/discuss information gaps and other NSO issues (Revised Recovery Plan, habitat typing, stand 
Elk Flat LSR Enhancement Project

E-18 Shasta-Trinity National Forest

data) and discuss the proposed fall 2009 treatments. In May 2012, the SMMU biologist role transitioned 

to Jordan, who continued consultation with FWS biologist Topolewski. Jordan transmitted the draft 

proposed treatment unit and ST-215 activity center maps with 2012 NAIP to Topolewski on June 8, 

2012. 

June 12, 2012: IDT meeting and field visit to discuss proposed prescriptions, habitat and refinements: 

Reviewed units 150, 152, 153, 155, 160, 161 and 166 (Payne, Craig Sewell-SMMU silviculturist, 

Jordan, Topolewski, Steve Clark-SMMU fuels specialist and Domanksi). Given unit 160’s location 

outside the home range (near Elk Flat meadow), lower quality foraging habitat, Heterobasidion root 

disease in white fir and dying ponderosa pine, group decided to change the proposed thinning treatment

of 150 sqft/ac of basal area to 125-150, but to not thin biomass and retain it as feasible. The original 

prescription also included ≤2-acre group selections to reduce root disease and promote age class and 

species diversity, and this element was retained. Discussed that within groups, foraging and dispersal 

elements (primarily dying trees and stagnant conditions) would be removed, but the overall stand would 

continue to function as foraging habitat (degrade). In unit 161 (in ST-215 core, foraging and critical 

habitat with pockets of dense white fir and roosting sites) the group decided to implement the proposed 

thinning treatment of 150 sqft/ac of basal area, retain biomass, not machine pile/burn and drop the

proposed radial thinning, which could remove roosting elements. Discussed incorporating roost site 

element retention in marking guides and that the overall treatment, followed by prescribed fire, would 

degrade foraging habitat function. In unit 153 (part in ST-215 core/home range), discussed the foraging 

habitat quality (moderate to low), black oak, and pine mortality where it was occurring. The proposed 

treatment of thinning to 150 sqft/ac basal area was modified to a more variable prescription of 125-175 

sqft/ac, species dependent. The need for and benefits of black oak release were discussed, but not in 

detail for treatment design or protection measures. Within the stand portions that have a legacy pine 

component, and ~12-18” dbh dense white fir, radial thinning and the potential for small (<0.25-acre) 

gap creation was discussed, given that small gaps could increase diversity and heterogeneity over time 

(no replanting of gaps). The variable thinning and gap creation would degrade foraging habitat function. 

Topolewski and Jordan noted that more specific measures for radial thinning around pine and oaks need 

to be developed (e.g., limit the trees per acre or TPA, add protection measures to retain certain 

species/size classes) and that these treatments could likely downgrade habitat, depending on specifics. 

The group discussed prescribed fire use in unit 150 and a portion of unit 152 (NR habitat in ST-215 

core) and the benefits. In unit 152, discussed radial thinning around legacy pine, large tree and biomass 

retention, group selection in dense white fir, and modified the 150 sqft/ac basal area to a variable 

density of 125-175. Group noted that complex marking guides are needed here (and elsewhere) to 

assure habitat function is maintained. In units 155 and 166, discussed the dense understory and 

overstory stand conditions and using variable density thinning here and similar stands. In general, the 

group discussed trade-offs of thinning or retaining dense biomass (fire effects); the need to develop 

some measures for mortality during prescribed fire and retaining understory and CWD for prey base; 

the location of and impacts to then-designated critical habitat (2008); the potential for dbh limits; and 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit E-19

developing oak/ and pine radial thinning measures. Decision point that Jordan would continue 

reviewing each natural stand to prioritize where treatments were needed and determine if biomass 

retention, radial thinning pine, prescribed fire, or machine piling would contribute to or hinder habitat 

function. 

June 26, 2012: Jordan transmitted Payne’s initial draft prescriptions to Topolewski, noting the June 12 

modifications had not been incorporated. Jordan also conducted field reviews for habitat typing and 

treatment effects in units 151, 154, 156, 165, 168, 173, 182, and a separate portion of 155. Some units 

should be excluded from mechanical treatment either by deferring entirely (156, 173, 182) or including 

portions in unthinned patches (per the LSRA) or using marking guides to direct ‘skipping’ treatment in 

a stand given existing large or small trees, decadence and vertical/horizontal structure and heterogeneity 

(151, 154, 165, 168). Also reviewed areas of private land in home range to update the NSO habitat map.

July 2 and 9, 2012: IDT meetings and field reviews with FWS participation, primarily to discuss 

Riparian Reserve conditions, potential mechanical thinning and prescribed fire, and consistency with 

the Aquatic Conservation Strategy objectives in Reserves (George-hydrologist, Snyder-Forest 

entomologist, Jordan, Topolewski and other IDT specialists). Reviewed units 152 and 157 along Ash 

Creek and discussed Heterobasidion root disease impacts, no treatment and treatment areas to maintain 

cool-air refugia along the creek, the existing large down wood that benefits fisher, and the likely effects 

of prescribed fire without pre-treatment of machine piling/burning. Decision point to likely develop a 

linear area along the creek where no mechanical treatments would occur, and measures for prescribed 

fire and CWD retention. Within rest of unit, thinning to 125-175 sqft/ac basal area, maintaining biomass 

and radial thinning a limited number of legacy pines would degrade foraging habitat function. Group 

also reviewed units 162 and 176 to discuss Heterobasidion and blackstain root disease in these

ponderosa pine-dominated stands, NSO habitat (non-habitat with pockets of potential dispersal at that 

time) and snag retention feasibility. The treatment of thinning to 80-140 sqft/ac basal area (what could 

be thinned at time of implementation), interplanting and retaining snag pockets in the interior away 

from roads was also discussed. Snyder reiterated that where blackstain vascular wilt occurs, opening the

pine stand to direct sunlight can warm and dry the soil and greatly reduce progression of the disease 

within residual trees.

July 26, 2012: Stewardship Collaboration Field Trip 1 of 2: The Shasta Valley Resource Conservation 

District, several local participants, Project IDT, SMMU staff members and Topolewski reviewed five 

locations in the project area to discuss existing conditions and potential treatment options. The second 

field trip occurred August 9, 2012 but FWS did not attend. The feedback from the FWS (and other 

participants) that was not already being considered was integrated into the Project’s design. 

July 27 and 31, 2012: Jordan and Topolewski emailed regarding his comments from the July 26th field 

trip on designing the project to treat 30% or less of the foraging habitat designated as critical habitat. 
Elk Flat LSR Enhancement Project

E-20 Shasta-Trinity National Forest

This discussion clarified that the recommendation was for “mechanical treatments that would notably 

degrade or downgrade/remove [foraging] habitat quality”. 

August-November 2012: Jordan continued habitat typing and stand identification for Recovery Action 

32, biomass and treatment assessments, and several field reviews with various IDT members.

August 27-31, 2012: Jordan transmitted to Topolewski the September 2009 NSO habitat map and 

spreadsheet from Baxter and Paul regarding treatments in NSO habitat; Jordan’s updated NSO habitat 

notes for key areas in the core (150, 151, 153, 161, 168) and home range (155, 165, 169, 173) and 

updated habitat map (to date); and the 2007 Common Stand Exam summary, data and inventory maps. 

September 6-7, 2012: Jordan conducted additional habitat typing on private lands in the ST-215 core 

and home range, and a field visit with FWS and FS biologists Derby and Susan Thomas to treatment 

and no –treatment areas in the core and home range (units 14, 151, 153, 165, 168, 173, 178). The group 

reviewed the updated NSO habitat map (to date) and discussed capable, dispersal, and non-habitat and 

treatments, suitable habitat treatment prioritization, RA10 prioritization guidance from the Yreka FWS 

for home ranges (see Appendix C of the BA), and variable density thinning approaches. Topolewski and 

Jordan also discussed separating habitat typing by Roosting and Nesting/Roosting, given the variability 

of this habitat type within portions of the project area. It was mutually decided that because potential 

roosting habitat was dispersed throughout potential treatment areas that were: 1) either not functioning 

as quality foraging (i.e., habitat elements are present, but stands are too dense for owls to fly through), 

or 2) were in an area of more dispersal or capable habitat, that a project design feature that retains roost 

site habitat components would be a better approach. Jordan and Topolewski also mutually agreed that 

habitat typing for the Project would consist of Nesting/Roosting, High Quality Foraging, Foraging, 

Dispersal, Capable and Non-Habitat due to the variability and proposed treatments in older plantations 

that are ‘capable’ of becoming dispersal or suitable foraging. Topolewski agreed with the proposal to 

not treat units 156, 173, 182, portions of 151, 165 and 168 (based on Jordan’s field work on June 26, 

2012) and to move forward with the previously-discussed thinning, small gap creation and groups in 

natural stands and the ‘capable’ habitat in older plantations (14, 16, 18, 6, etc.). 

September 19 and 29, 2012: Jordan received a PDF file of an NSO habitat map and GIS shapefiles 

from Jim Wolter of Hancock Forest Management (adjacent private lands owner) and Stu Farber, 

consulting biologist for Hancock Forest Management for the ST-215 core and home range. This 

map/data was shared with Topolewski and utilized by Jordan, in combination with field reviews for 

habitat characterization of private lands in the NSO action area. During the field reviews, and GIS work 

by Jordan for the final NSO habitat map, it was noted that on private lands, some typing differed in their 

core and home range. They primarily had low quality foraging for what is mostly dispersal habitat, and 

several polygons that are barren (based on 2009 and 2012 NAIP) were typed as foraging, potential due 

to their proximity of foraging. For the most part, where they had designated non-habitat and foraging 

habitat in the home range on private lands matched with the FS typing that was done. 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit E-21

October 2012: Jordan, Topolewski and other FWS biologists (Fitzgerald, Hellekson), Payne, Sewell 

and Clark re-reviewed NSO habitat in units 165 and 168 to provide the new FWS staff familiarity with 

the Project and habitat conditions. We discussed that portions of these units would be deferred, as they 

are considered high quality foraging trending toward NR of cedar, fir, and pine, ~10+ TPA >26” dbh, 

abundant large down wood and snags, tree size differentiation, understory perching structure, and small 

openings of bush chinquapin, manzanita and whitethorn. These areas would not be mechanically 

thinned, but would be underburned. Reviewed unit 154 to discuss variable stand conditions (mixed 

conifer with dying pine), dense incense cedar biomass in portions of the stand, large tree retention, notreatment areas, and radial thinning. Decision made that radial thinning would not be used (similar 

rationale for unit 161 as the majority of roost habitat could be removed with this treatment). Group 

discussed that thinning to 125-175 sqft/ac basal area and thinning biomass would degrade foraging 

habitat. Biomass thinning was not excluded, given the dense conditions of small <4-4-9” understory 

cedar and fir in 70% of the unit. Other portions of this unit are going to be excluded from mechanical 

treatment due to NR characteristics, higher quality foraging and fisher habitat near Ash Creek. 

Reviewed the extensive mortality areas in units 158, 159, 204 and 206 to discuss habitat (non/some 

dispersal of ponderosa pine with prey base due to abundant down wood and natural regeneration), snag 

retention as feasible, radial thinning around predominant legacy pine, and thinning to 80-140 sqft/ac 

basal area where it could be safely done during implementation. The group also discussed oak release 

treatments and how release distances would be larger on southern aspects, that predominant trees would 

not be cut and how diameter limits would be used in critical habitat. October 12, 2012, Topolewski 

transmitted the Northwest Forest Plan NSO relative habitat suitability map (completed by Raymond 

Davis) to Jordan for a comparison. 

December 4, 2012: Revised Final Rule for NSO Critical Habitat was published in the Federal Register, 

resulting in 720 acres of critical habitat in the northwestern and western portions of the project area.

February 26, 2013: Jordan meets with FWS staff and adjacent private landowners to discuss annual 

survey coordination on the SMMU. 2013 is the second year of 6V surveys for the Project, and private 

landowners and the FS will continue data sharing and coordinating stand searches for ST-215. 

March 21, 2013: Jordan presented the Final PIF at the March 2013 Level 1 meeting with a broad-scale 

project area habitat map, an estimated project timeline and details from the February 2013 proposed 

action and scoping document. Jordan provided the meeting participants with stand photos and maps and 

discussed the proposed variable density thinning, biomass retention, gap creation, and the process for 

prioritizing treatments under RA10 and RA32. General protection measures for LOPs, snag and CWD 

retention, and roost/rest site retention were described. At this time, specifics on machine piling and 

burning had not been worked out by the IDT, nor had some of the finer-scale protection measures. 

Discussed the field work and treatment modifications in 2012 by the IDT and FWS; the coarse levels of 

habitat in the project area, core and home range based on revised habitat typing; the preliminary effects 

determinations made in the field with FWS and the IDT; and the preliminary effects within the ST-215 
Elk Flat LSR Enhancement Project

E-22 Shasta-Trinity National Forest

core, home range and critical habitat. Discussed that the current unoccupied status, 32% plantation

stands on NFS lands in the core and 15% in the home range and ability to affect change in the ST-215 

core and home range in less than 30 years with treatment make this a prime candidate for treatment 

prioritization under RA10. Noted concerns included the large proportion of the home range in private 

lands (~60%), the logical shift of home range use to be within more of the LSR should NSOs re-occupy 

the activity center, and the timing and cumulative effects of proposed treatments (i.e., thinning, 

followed by potential piling and burning in some areas, followed by prescribed fire entries). Concerns 

were noted by Jordan regarding the wide range of habitat variability in stands (169, 235) and the effects 

of proposed treatments to foraging and dispersal. Both FS and FWS personnel contributed input (e.g., 

suggested a finer scale GIS representation of NSO habitat, additional reviews to discuss treatment 

concerns, and finalizing areas that would be subject to machine piling and burning). There was 

sufficient data available for the FS to present a draft determination that the Project was not likely to 

adversely affect the NSO (based on occupancy) and that it would have an adverse effect on designated 

critical habitat (primarily PCE3). 

March 26, 2013: Second public meeting for Project scoping (Robert Carey of the Yreka FWS office 

attended as FWS could not attend the initial public meeting on March 5, 2013). No comments were 

provided at or after this meeting by the FWS regarding the scoping document/proposed action. 

May 9, 2013: Jordan receives ST-215 stand search information from Stu Farber that dates back to June 

16, 2011. It includes information about a probable NSO feather found in the core area (unit 150) that 

same day (Farber 2013). This information is transmitted to Topolewski on May 10, 2013. 

November 2013: FWS Level 1 consulting biologist role transitioned to Katherine Fitzgerald. Jordan 

provided a list of draft project design features that were developed and discussed with Topolewski. 

These include LOP dates and survey/spot check plans, unthinned patch design, RA32 stands/elements, 

roost/rest habitat retention, diameter limits in oak release areas and NSO critical habitat and damage 

minimization measures for oak, limits on annual prescribed fire within a home range and general tree 

mortality levels during underburning (~10%), snag and down wood retention and CWD piling measures 

and monitoring. These measures were discussed, revised as needed (e.g., the FS desired specifics for 

underburning-see below) and fully incorporated into the Project’s design features and resource 

protection measures. All measures are included in Chapter 2 of the EIS, and those specific to NSO are 

in Table 6 of the BA. 

November 12, 25 and 26, 2013: Field reviews with Fitzgerald, Sewell and IDT leader Cindy Diaz; and 

Clark, Sewell and Heather McRae (project fuels specialist). Re-briefed Fitzgerald on purpose and need 

and natural stand/plantation thinning prescriptions and discussed habitat types and prior agreements on 

effects determinations in suitable and critical habitat (degrade for majority, downgrade in oak release 

areas, short-term adverse effects in critical habitat PCE3-similar to the March 2013 PIF presentation). 

Discussed variable density thinning, group selection, radial thinning and underburning-only in detail; 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit E-23

established a realistic percentage of acceptable mortality for the <4-10, 10-15, 16-20 and >20-inch dbh 

tree size classes during prescribed fire and how this would maintain/benefit habitat function; discussed 

existing project design features and RA10/RA32 and how the Forest perceives meeting 

recommendations; and discussed the NSO survey plan. In addition to re-verifying habitat conditions in 

units 150, 151, 152, 153, 161, 168-2 and 178 with Fitzgerald, and discussing preliminary 

determinations for effects in nesting/roosting (maintain/benefit), foraging (degrade or downgrade, 

treatment dependent), and dispersal habitat (improve/modify), the group also reviewed units 169 and 

235. These areas are in critical habitat and the southwestern portion of the home range, and consist of a 

mix of dispersal and foraging habitat with a dying pine component. Review was needed to clarify 

concern over treatment effects raised during the March 2013 PIF presentation and the strong variation 

in these units of mixed conifer, pine pockets, dying pine and legacy trees. It was determined that within 

dispersal and foraging habitat, the treatments of thinning to 125-175 sqft/ac basal area would degrade 

foraging, and maintain/improve dispersal. Marking began in the plantations and continued through early 

winter 2015. While thinning, groups and radial thinning are planned in these non-suitable or capable 

NSO habitat areas, the measures developed for the natural stands to retain unthinned patches and 

roost/rest sites as they occur carried over to the plantations. Jordan, Sewell and the TEAMS marking 

crew met in unit 6 to discuss the thinning prescription, roost/rest clumps, and retention of larger 

decadent trees in plantations that contribute to late-successional habitat objectives for the Project. A 

sample mark was completed and reviewed, with few adjustments needed. 

February 19, 2014: Field review with Fitzgerald, Sewell and Domanski to discuss treatment 

modifications and Jordan’s concern regarding prescribed fire in RA32 stands. Reviewed units 161, 165 

and 167 (all within core/home range) for this purpose. Also discussed unthinned patch designation and 

mapping, which includes RA32 stands and elements. In unit 165, discussed the potential for an oak 

release-only treatment and prescribed fire, and consistency with RA32 when using prescribed fire. 

Decision made to thin portions of this stand in lower quality foraging (~10-18” dense white fir along the 

edges and oak release) and retain, unthinned, the central higher quality foraging habitat of 26-30”+ dbh 

trees of mixed species, abundant down wood, large snags and shrub openings. Reaffirmed with 

Fitzgerald that prescribed fire, depending on timing and ignition patterns, is a beneficial treatment. Rereviewed unit 161 and Sewell’s inquiry to utilize radial thinning. As discussed by Jordan, Topolewski 

and others on June 12, 2012, unit 161 is in the core and critical habitat and radial thinning would 

significantly remove roost site elements (contributor to PCE2). The stand has numerous roost/rest 

microsites and radial thinning around the trees that comprise those sites would effectively remove them. 

Radial thinning will not be included as a prescription element in unit 161. Where white fir is dense in 

unit 161, the proposed thinning would improve foraging function, and in remaining portions, degrade it. 

Reviewed unit 167 to discuss prescribed fire and downed wood conditions (~28 tons/acre of jackstrawed 10-20” diameter, 20’ long white fir, pine and cedar in this 5-acre unit). Decision made that as 

long as underburning occurs within the parameters developed November 25, 2013, that foraging habitat 
Elk Flat LSR Enhancement Project

E-24 Shasta-Trinity National Forest

function would be maintained. Fitzgerald and Jordan also discussed survey history and the (still) 

unknown location(s) of the barred owls. 

March 20, 2014: Jordan, FWS and private landowners participated in the annual survey coordination 

for the SMMU. Fitzgerald and Jordan mutually decided that due to barred owl presence (detections in 

last two seasons) that a third year of 6V surveys is appropriate. Jordan coordinated survey plans with 

private landowners and both parties will continue sharing data and coordinating ST-215 stand searches. 

July 30, 2014: Marking started in natural stands and Jordan invited FWS. Jordan, Payne, Sewell and the 

TEAMS marking crew met in unit 161 to discuss variable density thinning prescriptions and its 

application, roost/rest clump identification within natural stands as compared to plantations, the ST-215 

core and home range area, critical habitat and to discuss overall late-successional habitat objectives for

the Project. A sample mark is completed and reviewed, with few adjustments needed. Jordan also talked 

with the crew about oak release treatments in units 153 and 178 and diameter limits in critical habitat. 

August 26, 2014: Jordan completed a post-marking field review of unit 153 (foraging habitat with oak 

release element in critical habitat) with Fitzgerald and FWS biologist John Morris, the project botanists 

(Rhonda Posey and Brenna Montagne), Sewell and Domanski. This review was to identify if there were 

additional leave trees for wildlife use in the mixed conifer/oak stand area within critical habitat. The 

group discussed trade-offs and benefits to oaks, prey base, critical habitat function, NSO and fisher and 

agreed on the overall effect determination that foraging habitat would be downgraded to dispersal 

habitat where oak is released. Additional leave trees and cut trees were identified by the group, 

including oaks/clumps of oaks. The group (minus Posey and Montagne) continued to another portion of 

unit 153 to review the marking for small (~0.20-acre) gaps in white fir, and overall variable density 

thinning from 125-175 sqft/ac basal area. Here, the determination was also re-affirmed that thinning 

would degrade foraging habitat function. While the small gaps would remove habitat elements (12-18” 

dbh white fir trees with short limbs and infection), the gaps do not downgrade the habitat function for 

the stand. One gap location was adjusted to be more centrally located in stagnant white fir, similar to the 

other gaps. The group also reviewed the initial marking in units 154 and 161. It was re-agreed that 

based on the mark in unit 161, foraging habitat function would be degraded post-thinning and 

underburning. For this stand, and stands similar to unit 153 that have similar conditions and variable 

density thinning treatments, the same determination of ‘degrading’ foraging habitat was agreed to. In 

portions of unit 154, the mark did not match the prescription that was developed in October 2012 and 

the group discussed these concerns. The stand was reviewed and areas were mapped that should have 

been left untreated. In other portions of unit 154, the mark met the prescription of variable density 

thinning to 125-175 sqft/ac basal area (combined with roost/rest habitat clumps, unthinned patches and 

biomass that will leave some areas at >200 sqft/acre post-thinning). It was re-agreed that these 

treatments would degrade foraging habitat function. 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit E-25

September 23, 2014: Additional leave tree marking was completed by Jordan, Sewell and the SMMU 

timber preparation shop in the previously-reviewed portions of unit 154. 

November 10, 2014: Jordan is notified by Robert Feamster of Sierra Pacific Industries that the barred 

owls that were detected in the project area (and on private lands) during 6V surveys the past three 

seasons were removed. This information was discussed with the FWS at the November 20, 2014 Level 

1 meeting. 

March 3, 2015: Jordan met with FWS to discuss annual survey coordination for the SMMU (private 

landowners were contacted later). Jordan and Jan Johnson (FWS wildlife biologist) agreed that due to 

the barred owl removal in fall 2014, and the barred owl detections over the last three years of 6V 

surveys, that Project-level surveys for 2015 could consist of three “modified” spot check visits (USDIFWS 2012a pp. 17-18). This consisted of three visits in and within a 0.25 mile of suitable habitat in the 

project area. Jordan coordinated survey plans and the stand searches for ST-215 with private 

landowners, who continued to survey portions of the action area due to planned and ongoing THPs. 

March 31, 2015: Jordan met with Fitzgerald, Carey and Laura Finley (FWS wildlife biologist) to 

discuss the proposed fisher128 analysis area and home range estimates based on previously collected 

home range data in similar habitat types. Since there are no telemetry studies in this part of the fisher’s 

range to base an average female home range size upon, the group agreed to use a habitat-based 

approach. The analysis would include: 1) the local population area on the SMMU; 2) an analysis area 

encompassing the entire project area. Then to the north, up to 6,500-foot elevation range, and to the 

west, east and south, delineating the extent there is likely reproductive habitat based on stand 

conditions, age class, species composition and cover. This approach would be biologically meaningful 

for this species, and is an estimated 10,100-acre analysis area which is likely adequate to support 

approximately three female home ranges. The “fine-scale” analysis would consist of the treatment unit, 

stand and resting/denning structure. 

April-August 2015: Additional unit and marking reviews were completed by Jordan to verify that the 

prescription and habitat objectives were being met with the mark. Jordan emailed Fitzgerald on July 9, 

2015, summarizing the season’s surveys, field review of the current marking and plans for adjustments, 

the IDT’s progress and treatment changes for machine piling/burning acre estimates, reforestation plans 

and methods, road action modifications and protection lines/methods during prescribed fire.

August 20, 2015: Forest Ecosystem Staff Officer, Kathy Roche, participated in a telephone 

conversation with Klamath National Forest staff, Klamath Falls Oregon FWS staff, and Yreka FWS 

Supervisor Erin Williams regarding the new information on the Shasta Pack. They discussed that only a 

few staff members and biologists from CDFW have the exact location information for the cameras that 

128 Project effects to the fisher are assessed in the project-level Biological Evaluation.
Elk Flat LSR Enhancement Project

E-26 Shasta-Trinity National Forest

photographed the Shasta Pack, and that CDFW is not sharing specific location information at this time. 

No information was provided to FWS by CDFW on a den site, only a rendezvous site (photographs 

from August 9, 2015; CDFW 2015). They discussed typical den site timing restrictions as April 1-June 

30, and that none of the animals are collared, so day-to-day information is lacking. They also discussed 

that while there is no conclusive genetic information to date; Shasta Pack individuals are not considered 

part of an experimental population. Draft conservation measures for range allotment permits were also 

discussed.

August 27, 2015: Jordan, Emelia Barnum (SMMU Natural Resource Planning Officer) and Roche 

participated in a telephone conversation with Williams and Nadine Kanim (Yreka FWS fish and 

wildlife biologist) to discuss a separate project and its ongoing treatments. Jordan inquired if FWS 

could share information on the Shasta Pack’s general location, or an estimated distance to known 

activity areas, from the separate project. Williams shared that CDFW staff had requested the locations 

of the remote cameras and Pack not be shared at this time, but did state that if the FS provided an action 

area map, FWS could likely share an approximate distance range from the action area to the Pack’s 

potential use area(s) and detection area(s). The group also discussed accepted distances and time 

periods for den site LOPs. 

October 7 and 13-14, 2015: Additional leave tree and cut tree marking completed by Jordan and the 

SMMU timber preparation shop in units 151, 152-1, 153, 154, 163, 166 and 169 to meet the project’s 

purpose and need and design features in critical habitat, overall LSR objectives, and to assure that the 

NSO foraging habitat/fisher habitat treatment objectives would be met. No other units in NSO or fisher 

habitat required marking modifications. Additional leave trees in unit 402 that contribute to LSR 

function (though outside suitable/dispersal NSO habitat) need to be marked for retention prior to 

implementation.

November 30, 2015: Per the August 27, 2015 telephone conversation, Jordan emailed Kanim and 

Morris the Project’s NSO survey map and proposed gray wolf action area map, requesting if an 

estimated distance to CDFW’s detection areas could be provided, and if the CDFW had provided any 

new releasable information to the FWS.

December 1 and 2, 2015: Kanim emailed Jordan, describing the distance from the detection area to the 

project area and the action area, based on the detection area maps provided by CDFW (Kanim 2015). 

Kanim also noted the wide error bars included on the CDFW detection area maps. Kanim also noted 

that CDFW had not provided any additional information to the FWS. 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit E-27

Attachment - List of Threatened and Endangered Species

Draft Environmental Impact Statement

Shasta-McCloud Management Unit E-29
Elk Flat LSR Enhancement Project

E-30 Shasta-Trinity National Forest
Draft Environmental Impact Statement

Shasta-McCloud Management Unit E-31
Elk Flat LSR Enhancement Project

E-32 Shasta-Trinity National Forest
Draft Environmental Impact Statement

Shasta-McCloud Management Unit E-33
Elk Flat LSR Enhancement Project

E-34 Shasta-Trinity National Forest
Draft Environmental Impact Statement

Shasta-McCloud Management Unit E-35
Elk Flat LSR Enhancement Project

E-36 Shasta-Trinity National Forest
Draft Environmental Impact Statement

Shasta-McCloud Management Unit E-37

Draft Environmental Impact Statement

Shasta-McCloud Management Unit F-1

Appendix GAppendix F-Past, Present and Reasonably 

Foreseeable Management Activities 

Appendix F-Past, Present and Reasonably Foreseeable 

Management Activities

This appendix describes the overall approach to the Elk project cumulative effects analysis and 

summarizes a list of potentially relevant ongoing and reasonably foreseeable futures actions. 

Past, present, and reasonably foreseeable future management activities were considered for this project, 

in order to assess accumulated impacts. According to the Council on Environmental Quality NEPA

regulations, a “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). 

Spatial and temporal boundaries are the two critical elements to consider when deciding which actions 

to include in a cumulative effects analysis. Spatial and temporal boundaries set the limits for selecting 

those actions that are most likely to contribute to a cumulative effect. The effects of those actions must 

overlap in space and time for there to be potential cumulative effects (FSH 1909.15 (15.2)). Spatial and 

temporal boundaries are the two critical elements to consider when deciding which actions to include in 

a cumulative effects analysis. Spatial and temporal boundaries set the limits for selecting those actions 

that are most likely to contribute to a cumulative effect. The effects of those actions must overlap in 

space and time for there to be potential cumulative effects (FSH 1909.15 (15.2)). Therefore, relevant 

boundaries and projects assessed for cumulative effects vary by resource. Each resource’s cumulative 

effect area can be different and possibly larger or smaller.

With respect to already completed (past) actions, this cumulative effects review does not attempt to 

quantify the effects of past human actions by adding up all prior actions on an action-by-action basis. 

There are several reasons for not taking this approach. First, a catalogue and analysis of all past actions 

would be impractical to compile and unduly costly to obtain. Current conditions have been impacted by 

innumerable actions over the last century (and beyond), and trying to isolate the individual actions that 

continue to have residual impacts would be nearly impossible. Second, providing the details of past 

actions on an individual basis would not always be useful to predict the cumulative effects of the 

proposed action or alternatives. In fact, focusing on individual actions may be less accurate than 

looking at existing conditions, because there is limited information on the environmental impacts of 

individual past actions, and one cannot reasonably identify each and every action over the last century 

that has contributed to current conditions. 

The cumulative effects analysis for each environmental component or resource area is guided by and 

consistent with the Council on Environmental Quality letter “Guidance on the Consideration of Past 

Actions in Cumulative Effects Analysis” of June 24, 2005. The current environmental conditions on the 

landscape reflect the aggregate impact of all prior human actions and natural events that have affected 

the environment and might contribute to cumulative effects and can be used as a proxy for the impacts 

of past actions (CFR § 220.4 (f)).

For each resource area, direct and indirect effects of the proposed action were reviewed, in accordance 

with the Forest Service Handbook 1909.15 (15.2), and relevant spatial and temporal boundaries for 

cumulative effects analysis were determined. For the Elk project, the longest relevant temporal 

boundary in this review was 30 years. The largest relevant spatial boundary in this review encompasses 

the 5th field watershed that intersects the project area, Ash Creek, modified to expand the boundary 
Elk Flat LSR Enhancement Project

F-2 Shasta-Trinity National Forest

where any other resource cumulative effects boundary extends past it. All other spatial and temporal 

boundaries either fell within the expanded 5th field HUC boundary, or were unneeded.129 130The Elk 

project area boundary was the most common cumulative effects spatial boundary used. Additionally, 

most specialists considered existing conditions as the aggregate of past actions in lieu of designating a 

specific temporal boundary.

Once this “general review area” was identified (Elk Project general cumulative effects review area), 

activities were reviewed for data contained within or intersecting this largest boundary within the last 

30 years to generate a list of potentially relevant actions. The interdisciplinary team reviewed for past, 

present, ongoing and future activities that are contained within or intersect with the Elk Project general 

cumulative effects review area from the following sources: Forest Activities Tracking (FACTS) 

database for the Shasta-Trinity and Klamath National Forests, CALFIRES’s timber harvesting plan 

(THP) status table (for THPs submitted to CALFIRE) and CALFIRE’s Forest Practice Geographical 

Information System timber harvest data in ERSI formats (for THPs approved, completed, etc.), the 

Schedule of Proposed Actions (SOPA) for the Shasta-Trinity and Klamath National Forests (January 1-

March 31, 2015 Quarterly SOPA, and the Current SOPA January 1, 2015).131 The information is 

characterized in the Cumulative Effects Worksheet for each resource as applicable (in the project 

record).

Potentially relevant present and reasonably foreseeable future actions is summarized in Table Appendix 

G-1. A column is included in the table indicating the estimated acreage or mileage within the project 

area boundary because it is the most common cumulative effects boundary used by specialists. Refer to

the cumulative effects worksheet summary of past actions assessed. Relevant cumulative effects are 

documented for the resource in the project specialist reports and are summarized in Chapter 3. 

Following the tables, two figures are shown displaying this information. Figure Appendix G-1 displays 

the locations of past actions in 10-year increments. Figure Appendix G-2 displays the ongoing and 

future projects. 

Table Appendix G-1. Present and Reasonably Foreseeable Future Activities in the Elk Vegetation 

Management Project’s General Cumulative Effects Boundary and the Project Boundary. 

Activities within the General 

Cumulative Effects Boundary 

(Expanded Ash Creek 5th Field 

HUC) 

Estimated Acres/miles Within CE 

Boundary

59,184 NFS, 

116,461 Total

Estimated Acres/miles 

Within Project Area 

Boundary

Past-Ongoing 

or Future 

Foreseeable

Forest Service Activities

Firewood cutting 59,184 acres NFS

490 acres of Matrix and 

downed wood within 100 

feet of open system roads 

in LSR.

Past-Ongoing

129 A few resources such as socio-economic had larger spatial boundaries but because of the nature of the 

resource and/or effects, a cataloguing of actions was not necessary to the analysis.

130 Rationale for selection of boundaries as well as analysis can be found in individual specialist reports and are 

summarized in chapter 3. 

131 There may be a slight overestimate of the amount of activity conducted because activities 

intersecting the boundary were used in addition to those contained completely within the boundary. 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit F-3

Activities within the General 

Cumulative Effects Boundary 

(Expanded Ash Creek 5th Field 

HUC) 

Estimated Acres/miles Within CE 

Boundary

59,184 NFS, 

116,461 Total

Estimated Acres/miles 

Within Project Area 

Boundary

Past-Ongoing 

or Future 

Foreseeable

Mushroom picking, 59,184 NFS 

acres (116,461 total acres) in 

the 5th field CE boundary

59,184 acres NFS 3,520 acres Past-Ongoing

Dispersed recreation, (including: 

driving for pleasure, 

snowmobiling, camping and 

hunting)

59,184 acres NFS 3,520 acres Past-Ongoing

Cattle Camp Campground & 

Picnic Area – operation, 

maintenance, use

~ 5 acres 0 Past-Ongoing

Trout Creek Meadow dispersed 

area camping - use ~ 5 acres 0 Past-Ongoing

Inconstance Trailhead, 

maintenance and use ~ 1 acre 0 Past-Ongoing

Brewer Creek Trailhead, 

maintenance and use ~ 1 acre 0 Past-Ongoing

Pilgrim Creek Snowmobile Park, 

operation (snow grooming), 

maintenance and use

~ 2 acres 0 Past-Ongoing

Fire suppression Variable, unknown within 

116,461 acres

Variable, unknown within 

3, 520 Acres Past-Ongoing

Noxious weed control 

(monitoring of noxious weeds, 

prevention and control 

measures [hand methods, no 

herbicides)] 

Unknown (variable, localized) Unknown Past-Ongoing

Snowmobile Trail 

60 miles of groomed and .15 

miles of ungroomed trail in the 

CE boundary

3.8 miles in project 

boundary (groomed) Past-Ongoing

Road maintenance Unknown (variable, localized) Unknown (variable, 

localized) Past-Ongoing

Special use permit - tribal 

ceremonies ~ 5 acres 1 event approximately 

2.5 acres Past-Ongoing

Special use permit - Caltrans 

easement (Highway 89 right of 

way)

~ 1 mile None Past-Ongoing

Special use permit -PacifiCorp 

powerline along Highway 89. 

Includes vegetation 

management maintenance (e.g.

hazard tree felling).

~ 1 mile None Past-Ongoing

Special use permit- McCloud 

Railway Company permit for 

14.92 miles (156.41 acres) to 

maintain/operate a common 

carrier railroad; however, the 

rails have been removed. The 

majority of the railroad is under 

a purchase agreement with 

Shasta Land Trust and will be 

converted into a trail system. 

~ 2 miles (0.7 miles under 

special use permit) None Past-Ongoing
Elk Flat LSR Enhancement Project

F-4 Shasta-Trinity National Forest

Activities within the General 

Cumulative Effects Boundary 

(Expanded Ash Creek 5th Field 

HUC) 

Estimated Acres/miles Within CE 

Boundary

59,184 NFS, 

116,461 Total

Estimated Acres/miles 

Within Project Area 

Boundary

Past-Ongoing 

or Future 

Foreseeable

Special use permit - two road 

permits for permit holder’s 

access to their private land. 

Unknown None Past-Ongoing

Recreation special use permitsfour permits for guided 

mountaineering and skiing on 

Mt. Shasta

N/A None Past-Ongoing

Recreation special use permitpermit for guided hiking, 

snowshoeing, backcountry 

skiing, scenic vehicle tours, 

step-on bus tours many of which 

include meditation and on-site 

counseling. 

N/A None Past-Ongoing

Recreation special use permitpermit for guided snowmobile

tours (administered by the 

Klamath National Forest). 

Authorized for use on the TriForest Snowmobile Trails. 

Variable 

If used, there are 3.8 

miles in project boundary 

(groomed)

Past-Ongoing

Recreation special use permitpermit for conducting crevasse 

and glacier travel training 

classes

N/A None Past-Ongoing

Recreation special use permitpermit for an annual recreation 

event, a rendezvous, at Trout 

Creek Campground but 

sometimes held at Elk Flat if 

Trout Creek Campground is 

closed due to snow. 

~ 5 acres Elk Flat Past-Ongoing

Recreation special use permitpermit for annual recreation 

event, “Biktoberfest” along the 

Pilgrim Creek Road to the Harris 

Spring Road. 

~ 13 miles ~ 2 miles Past-Ongoing

Hazard tree abatement (roads, 

campgrounds, administrative 

sites) - variable

Unknown variable Unknown variable Past-Ongoing

Bartle Grazing- 240 cattle (185 

USFS permit, 55 permitted 

on/off private permit), 6/1-10/30.

~ 30,404 acres 3,520

Past-OngoingFuture 

Foreseeable

Toad Grazing- 112 cow/calf 

pairs and 3 bulls from July 16 to 

October 30. (1994-2000 grazed 

200 cattle-200 permitted USFS, 

60 permitted on/off private land 

permit-6/16-9/30. 2000-2003 

grazed 125 cattle (115 permitted 

USFS, 10 permitted on-off 

private land permit-7/16-10/15.

Vacant 2004 to present).

~ 4,786 acres None Past-Future 

Foreseeable
Draft Environmental Impact Statement

Shasta-McCloud Management Unit F-5

Activities within the General 

Cumulative Effects Boundary 

(Expanded Ash Creek 5th Field 

HUC) 

Estimated Acres/miles Within CE 

Boundary

59,184 NFS, 

116,461 Total

Estimated Acres/miles 

Within Project Area 

Boundary

Past-Ongoing 

or Future 

Foreseeable

McCloud/Hambone Grazing- 

(1994-2000 grazed 1280 sheep5/15-10/15. Vacant 2001-to 

present). 

~ 2,150 acres None Past-Future 

Foreseeable

Timber Stand ImprovementThe work planned may include 

one or more of the following; 

release and weeding, 

precommercial thinning of 

conifers, hazardous fuels 

reduction and understory 

vegetation control, pruning, 

chipping, and/or pullback of 

contractor-generated fuels along 

roads and around leave trees. 

The work may be accomplished 

by manual or mechanical 

means. 

~ 2,414 acres (0-300 acres per 

year depending on funding and 

other factors)

~ 641 acres in 22 

plantations approved in 

NEPA decisions – 

however these are now 

incorporated into the Elk 

Proposed Action 

Past-Ongoing

Underburning – Trout Creek and 

Pilgrim 374 acres None Past-Ongoing

Machine piling and burning 134 acres None Past-Ongoing

Precommercial thinning 18 acres None

Motorized Travel ManagementPlanning, MVUM N/A N/A Past-Ongoing

Special Forest Products-Bough, 

Cone Collection - variable Unknown, variable Unknown Past-Ongoing

Permitted rock collectionobsidian, pumice - variable Unknown, variable Unknown Past-Ongoing

Road closures authorized under 

previously approved NEPA

~22 miles (ML1)

~6 miles decommissioning 2.6 ML1 Past-Ongoing

Gravel, cinder pits Unknown None Past-Ongoing

Highway 89 Safety 

Enhancement and Vegetation 

Management Project - 

Vegetation and Fuels 

Management

480 acres None Future 

Foreseeable

Trout Creek Stream 

Restoration- meadow and 

stream restoration.

90 acres None

Past-Ongoingfuture 

foreseeable 

Algoma Vegetation 

Management Project-South-A 

portion of thinned units would be 

underburned.

~ 290 acres thinning with some 

underburning

~ 180 acres pile burning

None

PastOngoing/Futur

e 

Foreseeable*

Algoma Vegetation 

Management Project-EastThinning - A portion of thinned 

units would be underburned 

and/or machine piled/burned.

~615 acres of thinning with 

some burning None

PastOngoing/Futur

e Foreseeable
Elk Flat LSR Enhancement Project

F-6 Shasta-Trinity National Forest

Activities within the General 

Cumulative Effects Boundary 

(Expanded Ash Creek 5th Field 

HUC) 

Estimated Acres/miles Within CE 

Boundary

59,184 NFS, 

116,461 Total

Estimated Acres/miles 

Within Project Area 

Boundary

Past-Ongoing 

or Future 

Foreseeable

Algoma Vegetation 

Management Project-West, 

thinning and pile burning. A 

portion of thinned units would be 

underburned.

~ 1,712 acres of thinning, 

~ 175 acres of pile burning None

PastOngoing/Futur

e 

Foreseeable*

Pilgrim Plantations Insect and 

Disease Project - thinning and 

underburning 3 years after 

harvest

~ 555 None Ongoing/future 

foreseeable

Pilgrim Project: ~ planting and 

mulching, and planting and 

manual release associated with 

the Pilgrim project (2014 and 

2015) [planting completed in 

2014]. Completion of thinning in 

unit 401 

~ 3 acres plant/mulch

~ 150 acres plant/release

~ 147 acres completion of 

thinning

~ 147 acres completion of 

thinning (unit 401)

Past- future 

foreseeable

Timber Harvest Plans on Private Land

2-05-144-SIS (Approved)

Alternative Prescription (68 ac)

Shelterwood Removal Cut (6 

ac)

None

PastOngoing/Futur

e 

Foreseeable**

2-09-073-SIS (Approved)

Clear Cut (9 ac)

Shelterwood Removal Cut (19 

ac)

None

PastOngoing/Futur

e 

Foreseeable*

2-10-063-SIS (Approved)

Alternative Prescription (355 ac)

Clear Cut (413 ac)

Commercial Thin (37 ac)

No Harvest Area (19 ac)

Rehabilitation (19 ac)

Sanitation Salvage (286 ac)

Shelterwood Removal Cut (355 

ac)

Shelterwood Seed Cut (40 ac)

Selection (106 ac)

None

PastOngoing/Futur

e 

Foreseeable*

2-11-001-SIS (Approved)

Alternative Prescription (636 ac)

Commercial Thin (394 ac)

Group Selection (1902 ac)

Sanitation Salvage (135 ac)

Shelterwood Removal Cut (77 

ac)

Seed Tree Seed Cut (14 ac)

None

PastOngoing/Futur

e 

Foreseeable*

2-12-049-SIS (Approved)

Alternative Prescription (2881 

ac)

No Harvest Area (53 ac)

Seed Tree Seed Cut (20 ac)

None

PastOngoing/Futur

e 

Foreseeable*

2-12-065-SIS (Approved)

Alternative Prescription (528 ac)

Commercial Thin (318 ac)

Group Selection (628 ac)

Seed Tree Seed Cut (12 ac)

None

PastOngoing/Futur

e 

Foreseeable*
Draft Environmental Impact Statement

Shasta-McCloud Management Unit F-7

Activities within the General 

Cumulative Effects Boundary 

(Expanded Ash Creek 5th Field 

HUC) 

Estimated Acres/miles Within CE 

Boundary

59,184 NFS, 

116,461 Total

Estimated Acres/miles 

Within Project Area 

Boundary

Past-Ongoing 

or Future 

Foreseeable

2-13-003-SIS (Approved) Alternative Prescription (155 ac) None

PastOngoing/Futur

e 

Foreseeable*

2-13-016-SIS (Approved)

Alternative Prescription (444 ac)

Commercial Thin (455 ac)

Group Selection (128 ac)

No Harvest Area (357 ac)

Rehabilitation (234 ac)

Sanitation Salvage (189 ac)

Shelterwood Removal Cut (4 

ac) 

Selection (78 ac)

None

PastOngoing/Futur

e 

Foreseeable*

2-13-027-SIS (Approved) Alternative Prescription (156 ac)

No Harvest Area (12 ac) None

PastOngoing/Futur

e 

Foreseeable*

2-04-112-SIS (Unlogged) Sanitation Salvage (31 ac) None

PastOngoing/Futur

e 

Foreseeable*

2-04-149-SIS (Unlogged) Alternative Prescription (17 ac)

Clear Cut (6 ac) None

PastOngoing/Futur

e 

Foreseeable*

2-04-168-SIS (Unlogged)

Alternative Prescription (25 ac)

Clear Cut (67 ac)

Shelterwood Removal Cut (76 

ac)

None

PastOngoing/Futur

e 

Foreseeable*

2-05-172-SIS (Unlogged) Commercial Thin (80 ac) None

PastOngoing/Futur

e 

Foreseeable*

2-05-173-SIS (Unlogged)

Alternative Prescription (9 ac)

Shelterwood Removal Cut (191 

ac)

None

PastOngoing/Futur

e 

Foreseeable*

2-06-127-SIS (Unlogged) Alternative Prescription (155 ac) None

PastOngoing/Futur

e 

Foreseeable*

2-98-329-SIS (Unlogged) Clear Cut (15 ac) None

PastOngoing/Futur

e 

Foreseeable*

2-99-241-SIS (Unlogged) Clear Cut (266 ac)

Commercial Thin (113 ac) None

PastOngoing/Futur

e 

Foreseeable*
Elk Flat LSR Enhancement Project

F-8 Shasta-Trinity National Forest

Activities within the General 

Cumulative Effects Boundary 

(Expanded Ash Creek 5th Field 

HUC) 

Estimated Acres/miles Within CE 

Boundary

59,184 NFS, 

116,461 Total

Estimated Acres/miles 

Within Project Area 

Boundary

Past-Ongoing 

or Future 

Foreseeable

2-99-304-SIS (Unlogged) Clear Cut (266 ac)

Commercial Thin (113 ac) None

PastOngoing/Futur

e 

Foreseeable*

*a portion of units have been treated in Algoma West. They are not shown as completed yet in FACTS so acreage may be

overestimated .

**Approved or unlogged THPs that are not indicated to be completed on Calfire THP website. Because a THPs status is not 

marked completed until all actions are accomplished, the THP actions on a unit-by-unit basis are in various states of completion.

Figure Appendix G-1. Cumulative Effects Boundary Map with Past Actions 

(Grouped in 10-Year Increments)
Draft Environmental Impact Statement

Shasta-McCloud Management Unit F-9

Figure Appendix G-2. Ongoing and Future Projects in General Cumulative Effects Boundary

Draft Environmental Impact Statement

Shasta-McCloud Management Unit G-1

Appendix H-Changes in the Proposed Action 

Appendix G-Changes in the Proposed Action 

The Proposed Action for the Elk Flat Late Successional Reserve Enhancement Project (Alternative 1, the 

Modified Proposed Action) was incrementally modified since the project was originally scoped and noticed in 

2013 (USDA-FS, 2013; USDA-FS, 2013b).132

The original Proposed Action described the Purpose and Need for Action in terms of the primary purpose to 

reduce the current and future risk of large-scale disturbance events within early, mid and late-successional 

habitat within the Elk Flat LSR and nearby stands per LSRA Objectives III and I. Additional benefits of the 

project were to increase resilience and promote continued development and connectivity of late-successional 

forest habitat in the Elk Flat LSR (LSRA Objectives II and IV); restore and maintain meadow habitat in Elk 

Flat, increase hardwood diversity across the project area, and improve streamflow and vegetation conditions 

within Riparian Reserves associated with Ash and Swamp Creeks and their tributaries. To clarify that they 

were part of the Purpose and Need for Action, the “additional benefits” are now identified as secondary 

purposes under Alternative 1. The primary purpose was slightly rephrased for consistency with wording in the 

LSRA Objectives. Additionally, the original Proposed Action noted road decommissioning in support of the 

meadow habitat and streamflow aspects. It did not explicitly include management of the transportation system 

as a purpose, whereas Alternative 1 lists it as a secondary purpose for clarity.

In summary, the most substantial modifications to the original proposed treatments in Alternative 1 are:

• Radial Thinning – Radial thinning trees per acre were modified from 5 trees per acre on average to 2

trees per acre, except for unit 157, which is a maximum of 4 trees per acre (see pp. B-25). The higher

level of radial thinning as originally proposed would thin the canopy more than is desired for wildlife

habitat.

• Reforestation – The original proposed action did not refine the interplanting and group selection

planting needs by acres and specific units and did not include specific site preparation techniques and

acres, or the potential for release treatments. The modification discloses the action more specifically

and incorporates the potential for release as needed in order to assure growth to accelerate

development per the Purpose and Need for Action. Alternative 1 provides this more detailed

information on pages B-33, 50, and 61.

• Underburning – The original Proposed Action did not specify that repeated entries for underburning

would be 2 to 3 prescribed fire entries on a 5 to 10 year interval within the project area boundary may

occur to fully restore the natural fire regime as described for Alternative 1 (see p. B-35, 52, and 62).

Some areas between treatment units and existing barriers were originally left untreated. The original

proposed action did not include underburning units 1-U, 156-U, 157-U, 159-U, 346-U. Alternative 1

increases underburning to take advantage of existing barriers to minimize fireline construction and to

full restore the project area to the natural fire regime consistent with the Purpose and Need for Action.

• Mortality Levels During Underburning – Mortality in the residual stands from underburning are

refined for site-specific conditions in Alternative 1 (see RPMs 25-27).The original Proposed Action

132The responsible official may modify the proposed action and alternative(s) under consideration prior to issuing a draft 

EIS. In such cases, the responsible official may consider the incremental changes as alternatives considered. The 

documentation of these incremental changes to a proposed action or alternatives shall be included or incorporated by 

reference in accord with 40 CFR 1502.21. (36 CFR 220.5(e)) 
Elk Flat LSR Enhancement Project

G-2 Shasta-Trinity National Forest

included mortality from underburning between 5% and 10%. The refinements inform the effects 

analysis.

• Oak and Aspen Release Treatment and Aspen Adaptive Management – Alternative 1 modified the

original Proposed Action to more thoroughly describe the oak and aspen release treatments and sets a

diameter or canopy class limit within the release areas and adds Aspen Restoration Adaptive

Management to provide a strategy to adjust future treatments based on release success (see pp. B-27

and B-34).

• Hazard Reduction Treatment – Alternative 1 provides a description of hazard reduction as a

connected action to the thinning and fuels treatments (see pp. 56, and 64) to accommodate the

concern of ongoing mortality on safety in specific areas.

• Extensive Mortality Area Treatment – Alternative 1 adds the Extensive Mortality Area treatment (see

pp. B-38, 53, and 61) due to ongoing and contiguous mortality and a concern for safety in the area.

• Salvage Adaptive Management – Alternative 1 adds a salvage adaptive management of salvage of

dying trees in units 6, 14, 16, 18, 113, 123, 124, 125, 158, 159, 160, 161, 162, 163, 164, 175, 176,

204, and 206 in the event conditions deteriorate further post-decision and post marking (see pp. B-34,

51, and 61). Salvaging the trees would reduce the safety and hazard concern post-project from

continued mortality.

• Follow-up Mechanical Fuels Treatment - The original Proposed Action described that the entire suite

of fuels treatments could be employed and the decision on appropriate method would be made based

on post-thinning activity and surface fuels levels. Alternative 1 clearly defines where machine piling

and pile burning would take place (see p. Table Appendix B-3 and p. 62) to inform the effects

analysis.

• Road Actions –Road Actions in the original proposed action are shown in Table 4 of the Scoping

document (USDA-FS, 2013b). Table 10 on page 63 summarizes the road actions in Alternative 1 and

the specific road action list is on page B-41. Changes occurred as analysis of the existing condition

and connected actions refined the proposed action since scoping. For the most part mileages of all

road actions decreased; for example, the proposed reconstruction of 4 miles in the original Proposed

Action down to 0.3 miles in Alternative 1. Additionally, the original Proposed Action did not include

addition of 0.10 miles of unauthorized route to the FTS to provide legal access to an existing

dispersed recreation site near Elk Flat meadow.

• Adaptive Management for Biomass Thinning – Alternative 1 added adaptive management for

biomass thinning (see pp. 51 and 58) to address potential market fluctuations and provide an

alternative method of thinning material 4 to 6.9 inches DBH.

• Meadow Enhancement dropped in Unit 401 - The original Proposed Action included unit 401 as a

meadow enhancement unit. Review of the stand history revealed the prescription for treatment under

the Pilgrim Vegetation Management Project was for a transition zone between meadow and forest

with widely spaced overstory (80 square feet of basal area per acre) and all understory removed to

resemble a pine savannah. That treatment has been partially completed under Pilgrim. Alternative 1

drops the meadow enhancement prescription in favor of fully implementing the Pilgrim project’s

treatment of the unit. Underburning unit 401 remains in Alternative 1. See footnote 25 on page 58 for

more information.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit G-3

• Unthinned Patches – the original Proposed Action included approximately 10% of units included as

unthinned patches. Alternative 1 includes a minimum of 10% but most units having between 12% and

50% UTPs. The original Proposed Action included no burning in UTPs. Alternative 1 instead

prescribes no direct ignition in some UTPs (RPM 30) and has other protections to prescribe mortality

limits throughout the project area (starting p. 85). Alternative 1 adds snag retention areas as part of the

unthinned patch prescriptions in areas of heavy mortality. This primarily affects units 158, 162,

175,176, 204 and 206. These were added due to ongoing mortality reducing the options for unthinned

patches consisting of mostly live trees. See pages B-24, Table Appendix B-2). Table 7 (p. 59) for

acres of unthinned patches.

• Borax Treatment – The connected action of Borate fungicide treatment to inhibit the spread of

Heterobasidion root disease may include different formulations based on changing market

availability. The solid Sporax® or liquid Cellu-Treat® or possibly other brands or formulations may be

used. Additionally, it is clarified that borax may be applied to stumps meeting the requirement (over

14 inches in diameter) in all harvested areas, including equipment exclusion zones in Riparian

Reserves where equipment may reach in to thin trees without entering the exclusion zone.

• Acreages of Treatments – Alternative 1 provides refinements, corrections and display of acres by

treatments and prescriptions elements. See Table Appendix B-2 for unit acres by treatment.

Draft Environmental Impact Statement

Shasta-McCloud Management Unit H-1

Appendix I– Compliance and Consistency 

Appendix H – Compliance and Consistency 

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.” Compliance with the legal and policy framework at the federal, state, and local level (applicable 

Forest Plan standards and guidelines, principle laws, regulations, executive orders and policies) that has not 

been previously discussed, are addressed here by resource topic or by the guiding authority. When there are 

multiple requirements from different authorities the discussion is introduced by resource topic. When the 

requirement is confined to a single authority, the discussion is introduced by that authority. Topics are listed 

here in alphabetical order except the National Forest Management Act (NFMA) is presented last to provide 

the Forest Plan consistency evaluations for those items not previously included. 

Air Quality Requirements-Local, State and Federal

The project area is within the Northeaster Plateau Air Basin consisting of Siskiyou, Modoc, and Lassen 

Counties in a Class II airshed. Air Quality at the local level is regulated by the Siskiyou County Air Pollution 

Control District (APCD). The California Air Resources Board (CARB) has noted that Siskiyou County 

adequately represents the air basin as a whole (CARB, 2010 p. 15). 

The major project activity relative to the decision with respect to air quality is smoke produced from 

prescribed burning. Other project actions that have the potential to affect air quality include dust from heavy 

equipment and trucks using native surface and gravel roads, and emissions from mobile equipment for 

implementation operations, hauling, and road actions. Projected vehicle emissions, including those from 

timber harvest activities, are already accounted for in the emissions inventory for Siskiyou County.133

Maximum vehicle emissions are regulated through state and federal mobile source emissions standards with 

which all vehicles and equipment must comply.134 Therefore, the compliance evaluation for air quality 

primarily concerns smoke and dust emissions. 

Since air quality is transient; air quality impacts from activities prior to the project will have dissipated. 

Similarly, air impacts from the project would dissipate before future projects begin, so there is no potential for 

past or future projects, in conjunction with the proposed action, to cumulatively affect the air resource. For 

that reason, they are not catalogued specific to air quality. 

133 The emissions inventories for various years by County or air basin are provided online at the California Air Resources 

Board website. See http://www.arb.ca.gov/app/emsinv/emssumcat.php

134 Vehicle emissions would vary in both timing and quantity produced based on the actual complement of equipment and 

strategy of implementation employed. It is assumed that given similar equipment and timing, more acres treated using 

heavy equipment, including thinning, machine piling, road maintenance and decommissioning, would produce 

correspondingly higher vehicle emissions to accomplish the treatments. Therefore Alternative 1 is likely to produce more 

vehicle emissions than Alternatives 2 and 3, with Alternative 3 producing the least.
Elk Flat LSR Enhancement Project

H-2 Shasta-Trinity National Forest

Federal Clean Air Act and Federal Policy

General Conformity Rule 

The conformity provisions of the Federal Clean Air Act (Section 176c) prohibit federal agencies from taking 

any action that causes or contributes to any new violation of the National Ambient Air Quality Standards, 

increases the frequency or severity of an existing violation or delays the timely attainment of a standard. The 

federal agency responsible for the action is required to determine if its actions conform to the applicable State 

Implementation Plan. 

There are eight criteria pollutants for the federal standards (CARB, 2015). No criteria pollutants are in a 

federal nonattainment status for Siskiyou, Modoc or Lassen Counties, which comprise the Northeastern 

Plateau Air Basin (CARB, 2013). Because Siskiyou County and the air basin are in federal attainment, a 

conformity determination is not required for this project. 

While fires managed for resource benefits generally are not subject to a preconstruction review and the 

issuance of a prevention of significant deterioration (PSD) permit, the emissions from such activities may 

affect the air quality in a PSD area. Under adverse conditions, the combined particulate matter (PM) 

emissions from increased fire activities and from other sources could possibly result in ambient 

concentrations that exceed the allowable PSD increments for PM. Historically, EPA has often regarded fires 

managed for resource benefits to be temporary activities (US-EPA, 1998 p. 32). The PM emissions resulting 

from fire activities differ from the PM emissions generated by most other sources because they are generally 

short-lived. That is, the burning generally is carried out infrequently at a specific location (once every 5-20 

years) and the duration tends to be short (approximately 1-2 days).

Environmental Protection Agency Interim Air Quality Policy on Wildland and 

Prescribed Fires (US-EPA, 1998) 

Under air quality regulations, prescribed burning is usually considered a temporary, intermittent source of air 

pollution and therefore is not subject to the same visibility requirements as a major “Prevention of Significant 

Deterioration” (PSD) source. The interim policy (US-EPA, 1998) integrates two public policy goals, (1) to 

allow fire to function, as nearly as possible, in its natural role in maintaining healthy wildland ecosystems, 

and (2) to protect public health and welfare by mitigating the impacts of air pollutant emissions on air quality 

and visibility. The document provides guidance on mitigating air pollution impacts caused by fires in the 

wildlands and the wildland/urban interface. It identifies the responsibilities of wildland owners/managers and 

State/tribal air quality managers to work together to coordinate fire activities, minimize air pollutant 

emissions, manage smoke from wildland and prescribed fires managed for resource benefits, and establish 

emergency action programs to mitigate the unavoidable impacts on the public. The indicators of effects under 

the policy are ambient air quality impacts above National Ambient Air Standards, visibility impairment and 

regional haze. 

Air quality managers are urged to help evaluate the potential impacts of alternative resource treatments and 

assure that air quality concerns (also visibility and regional haze concerns, where appropriate) are adequately 

addressed in the public land use planning process. It allows flexibility in regulating fire managed for resource 

benefits when a smoke management plan is being implemented in that EPA will use its discretion not to redesignate an area as nonattainment when fires cause or significantly contribute to federal particulate matter 

standards violations. The policy also encourages collaboration and communication among land managers and 

integration of air quality into planning processes, describes analysis of air quality impacts in planning 

processes, and lays out basic requirements of smoke management plans.

The project complies with the policy through the smoke management plan process and burn permit process, 

the NEPA process, and compliance with the Regional Haze Rule.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit H-3

Federal Clean Air Act Regional Haze Rule (US-EPA, 1999) [and California Regional 

Haze Plan (CARB, 2009)] 

The nearest Class I airshed, Lava Beds National Monument, is within the Northeastern Plateau air basin. 

States prepare Regional Haze Plans to meet the Haze Rule. The latest California Regional Haze Plan Progress 

Report indicates Lava Beds visibility exceeds the 2018 goals (CARB, 2014 p. 12). Prescribed burning is a 

common practice in the air basin. The Elk project area is roughly 33 miles southeast of Lava Beds National 

Monument. At this distance, the class I airshed would likely be minimally impacted during burning because of 

the favorable atmospheric conditions present during permissible burn days. No significant deterioration of 

visibility would be expected with the action alternatives.

California Clean Air Act 

In general, the California standards are stricter than the federal standards. The California Air Resources Board

(CARB) directly regulates mobile sources of pollutants, while delegating regulation of nonmobile source to 

local air districts. None of the 11 State criteria pollutants (CARB, 2015) are in a nonattainment status in 

Siskiyou County (CARB, 2013). Burning activities on several projects could occur within the same season; 

however, burning over any period would be limited to assure air quality is maintained. Potentially cumulative 

simultaneous burning projects are not possible to catalogue at this time because the information for the exact 

years and days burning will occur is not available for this project or other projects. Under the Siskiyou 

County Air Pollution Control District Rules, the control officer may restrict burning to selected permittees on 

designated burn days if total tonnage to be ignited would discharge a volume of contaminants into the 

atmosphere sufficient to cause State ambient air quality standards to be exceeded (APCD, 2014 pp. 7.5-1.N). 

The project would not cause a State criteria pollutant to be reclassified into a nonattainment status.

Siskiyou County Air Pollution Control District Requirements

The Siskiyou County APCD handles the day-to-day field operation of agricultural burning: issuing burn 

permits and informing growers and land managers of when and how much burning can be undertaken. 

Burning would be done only on designated “burn days” as designated by the APCD when predicted weather 

conditions are favorable for good smoke dispersal. 

Burn Permit and Smoke Management Plan

Consistent with SOPs (see p. D-1), a prescribed burn plan, including a Smoke Management Plan in 

compliance with the EPA Smoke Management Program, would be submitted to the Siskiyou County APCD 

per their rules.135 The Siskiyou County APCD requires burn permits for all burns over 50 acres136 or burn 

more than 3,000 tons material to be consumed, or are within 5 miles of a sensitive receptor (APCD, 2014 p. 

7.6). 

The Northeast Air Alliance (NEAA) has developed a standard Smoke Management Plan template (NEAA, 

2012). As part of the Smoke Management Plan for the prescribed burn, the Forest must provide a detailed 

meteorological prescription to be met prior to ignition. The prescription must include acceptable wind 

direction. Other considerations include: wind speed, temperature profile, winds aloft, humidity, temperature, 

135 Regardless of local requirements, the Forest Service Manual Chapter 5140 requires that all burning on National Forest 

System lands have an approved prescribed fire plan prior to any ignitions. Burning activities will be coordinated with 

affected landowners and control agencies.

136 While the APCD rules require approval for all burns over 50 acres or within 5 miles of a sensitive receptor, the Forest 

Service has agreed as a member of the Northeast Air Alliance to submit plans for approval when more than 10 acres are 

planned for prescribed fire.
Elk Flat LSR Enhancement Project

H-4 Shasta-Trinity National Forest

actual and predicted inversions, burn day status and forecast, precipitation forecast, and any other 

meteorological conditions that may affect smoke dispersion and/or fire behavior. Projects exceeding 100 acres 

must include a map showing smoke sensitive areas (or Sensitive Receptors) likely to be impacted. 

Prescribed burning takes place on permissive burn days137 and is managed in real time to avoid cumulatively 

significant effects through the issuance and administration of burn permits including smoke management 

plans. The NEAA provides an effective communication forum for land managers and regulators to discuss 

ongoing impacts throughout burning processes and make adjustments locally and regionally to avoid 

significant cumulative effects. Forest staff would coordinate burn ignitions to ensure smoke from any one 

project has dissipated prior to additional ignitions. The NEAA has proven to be an excellent forum to discuss

ongoing burns, new burns planned, air quality issues, marginal burn days, fuel loadings, etc. This process 

strengthens agencies’ commitments to cooperate and makes for a more efficient smoke management program. 

Local districts have the authority to suspend all or some burning operations should conditions change or 

monitoring indicates standard thresholds are being exceeded. 

Sensitive Receptors

Smoke sensitive areas include but are not limited to Class I airsheds, populations centers, hospitals, schools, 

daycare centers, nursing homes, shopping centers, populated recreation areas, well attended public events, 

major roads, airports, campgrounds and trails (NEAA, 2012). 

Sensitive receptors within relatively close proximity to the project area includes the Shasta Forest subdivision 

approximately 1.25 miles southwest and the Pilgrim Creek Snowmobile Park and dispersed use areas adjacent 

to the project area. Use at the snowmobile park is unlikely during burning operations. Prescribed fire would 

not occur during times of more concentrated use at the dispersed area in summer. Smoke may potentially 

impact dispersed use during the burning season and residents of the Shasta Forest subdivision. However, the 

Forest Service will follow Siskiyou County ACPD requirements138 in order to avoid creating a nuisance, 

visibility impairment or impacts to public health. Public education and information release are part of the 

prescribed burning procedures and will be followed. A severe smoke-created nuisance from prescribed fire is 

unlikely to occur due to the conditions under which burning is conducted (burn days). 

Fugitive Dust 

Rule 4.2 of the Siskiyou County APCD rules (APCD, 2014) regulates creation of dust that could pose a 

nuisance. Numerous native surface and gravel roads cross the project area. Fugitive dust can become airborne 

through ground disturbance and the spatial boundary for effects is actual treatment units and road actions, and 

sensitive receptors directly adjacent to ground disturbance areas. Low levels of fugitive dust are created by the 

public accessing the National Forest and administrative use. Fugitive dust from unpaved roads is included in 

the emissions inventories for the County under “Miscellaneous Processes.” St

Vehicular travel on paved and unpaved roads and logging operations will produce some dust, primarily from 

tractor skidding of log bundles and hauling over earth surface (dirt) roads. When materials are being 

137 Atmospheric conditions (smoke dispersal) and air quality determine the amount of burning that can take place on a 

given day without adverse impacts to air quality. CARB determines Permissive Burn Days and the number of acres 

allocated for agricultural and open burning based on meteorological and air quality factors. CARB Meteorologists utilize 

specific criteria such as mixing heights and wind speeds in conjunction with air quality data to determine the daily burn 

day status for the air basin. Weather forecasts will be reviewed and a spot forecast requested that specifies predicted 

transport winds and mixing heights. Burning on days when conditions are favorable for transport and dispersion will 

reduce the impacts of smoke. Ignition can be stopped where practical to hold the fire until conditions improve.

138 Siskiyou County APCD List of Current Rules (APCD, 2014)
Draft Environmental Impact Statement

Shasta-McCloud Management Unit H-5

transported from the sale area, all dirt roads are required to be watered by the timber sale purchaser to abate 

dust that would be created by the increased road usage. Dust generated and the resultant particulate matter is 

directly related to vehicle miles traveled on un-surfaced roads in the project area. It can also be attributed to 

tractor work on harvest units. 

Standard Operating Procedures (see p. D-1) require dust abatement, which is most often water applied to the 

road surface at regular intervals. If agreed upon, a temporary road surface material especially made for dust 

reduction may be applied to the roads instead of water. A Forest Service Timber Sale Administrator oversees 

all such operations, ensuring they adhere to contract specified requirements. With the above constraints in 

place and enforced, fugitive dust from logging equipment will have little measurable impacts on the airshed. 

There might be periods of localized impacts from created dust by logging and recreational activities 

conducted on both public and private lands within the analysis area. Logging operations are generally done 

over several years and localized dust from skidding and hauling dissipates rapidly. The project will comply 

with the APCD rules for a dust nuisance. 

Naturally Occurring Asbestos (NOA) 

California Final Regulation Order 2002-07-29 regulates construction of roads associated with timber 

harvesting in areas that have naturally-occurring asbestos, serpentine, or ultramafic rock (CARB, 2002). 

Although NOA is documented in Siskiyou County, it is not known to occur in or near the Elk project area 

(Churchill, et al., 2000), therefore no protective measures are needed to comply with the NOA regulation.

Forest Plan Compliance – Air Quality

The Forest plan directs air quality to meet or exceed applicable standards and regulations (4.4), and directs 

coordination with affected landowners and control agencies, and smoke management controls be incorporated 

into smoke management and prescribed fire plans. The proposed action and action alternatives are consistent 

with the Forest Plan. The project meets applicable air quality standards and regulations. Burning will be 

coordinated with the local air district in conjunction with CARB meteorological forecasts for burn days. The 

Northeast Air Alliance facilitates coordination and communication between area land managers. Smoke 

management controls are incorporated into the NEPA design and SOPs and will be incorporated into burn 

plans, smoke management plans, and part of the burn permit. 

Climate Change

Forest Service Strategic Plan 

The USDA Forest Service Strategic Plan for FY 2015-2020, Strategic Objective “A” calls for fostering 

resilient, adaptive ecosystems to mitigate climate change. This is accomplished by improving the ability of 

forests to remain healthy and resilient, despite stresses and disturbances such as drought and wildfire, and 

using information from climate change vulnerability assessments to inform adaptive management strategies. 

The strategy is to develop and apply detection, prediction, prevention, mitigation, treatment, restoration, and 

climate adaptation methods, technologies, and strategies for addressing disturbances such as changing 

climatic conditions (USDA-FS, 2015a).The purpose of the Elk project is in part to increase forest stand

resilience to large scale disturbances attributed to climate change (such as drought).

Although future climate change at the local level is uncertain, the Elk project action alternatives will improve 

the ability of the forest to withstand drier or seasonally drier conditions by maintaining stand densities that 

promote forest health, and by favoring drought resistant species in appropriate residual stands. By promoting 

healthier stands, the project treatments will reduce the susceptibility of trees to insect attack during prolonged 

drought periods. If the local climate shifts towards wetter conditions, these measures would not have a 
Elk Flat LSR Enhancement Project

H-6 Shasta-Trinity National Forest

detrimental effect, because treatments would still promote healthier stands for other reasons than climate 

change such as through less competition for sunlight and nutrients. 

California Assembly Bill 32 

In 2006, California enacted Assembly Bill 32, The Global Warming Solutions Act, which required a scoping 

plan for achieving reductions in greenhouse gas (GHG) emissions by 2020. The 2020 Scoping Plan target for 

California’s forest sector is to maintain the current 5 million metric tons of carbon dioxide (CO2) equivalent 

of sequestration through sustainable management practices.

With the removal of trees via thinning, oak release, and aspen release under the action alternatives, there 

would be an immediate reduction in the capacity of the remaining standing forest to store carbon. The carbon 

storage capacity of thinned stands will increase as trees grow and forest stocking (density) increases. The 

action alternatives will reduce the risk of a mass release of a large volume of carbon to the atmosphere as a 

result of catastrophic, stand-replacing wildfire in the project area by modifying vegetation and fuel conditions. 

There will be short-term releases of carbon to the atmosphere during prescribed burning. Emissions would 

most likely occur over a period of several years, as actual burning activities will be spread over the project 

implementation period.

On the global scale, the Elk project will have a negligible effect on climate change from any action alternative

in terms of GHG. GHG from the project would mix readily into the global pool of GHG, and so it is not 

currently possible to determine the cumulative effects of emissions from single or multiple sources (projects). 

Carbon storage (both in the standing forest and as wood products resulting from project timber harvest), the 

use of energy from biofuel displacing energy from fossil fuel consumption, and the reduced risk of losing 

large volumes of carbon to the atmosphere due to catastrophic wildfire indicate that the project will likely not 

have an adverse net effect on carbon cycling.

Endangered Species Act 

A thorough analysis of potentially affected federally listed species has been completed. Refer to the Wildlife 

section (starting page 158) and the Botany section (starting page 186). These sections address endangered and 

threatened species and their designated critical habitat. Resource specialists determined that the project would 

have no effect to endangered, threatened, or proposed plant, fish or other aquatic species or their designated 

critical habitats due to the lack of suitable habitat or the project area being outside of a species known or 

expected range. The project would have no effect to federally listed wildlife species, with the exception of the 

northern spotted owl and its designated critical habitat and the gray wolf. There is no critical habitat 

designated for the gray wolf in California at this time.

The Yreka FWS field office and the Forest have been consulting on the project’s effects to listed wildlife 

species since December 2011 and the Draft Biological Assessment was transmitted to the Yreka FWS field 

office on January 6, 2016. Consultation on the effects to the northern spotted owl and its critical habitat, and 

effects to the gray wolf, is ongoing with the U.S. Fish and Wildlife Service (FWS) and is yet to be completed. 

Once completed, the consultation will fulfill Section 7 of the Endangered Species Act’s consultation 

requirements ((19 U.S.C. 1536 (c)). Refer to the ESA Consultation and Coordination section for additional 

detail (p. 254). 

The West Coast Distinct Population Segment (DPS) of fisher is proposed for federal listing (USDI-FWS, 

2014). The fisher is a Forest Service sensitive species and the project effects are evaluated in the project 

wildlife Biological Evaluation. This evaluation determined that the project may have an adverse effect on 

individuals in the project area, but not contribute to a loss of viability of the local population, and no 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit H-7

meaningful effects at the range of the DPS. Refer to the Wildlife section of this EIS and the wildlife 

Biological Evaluation (Jordan, 2015c) in the project record for more detail. 

Environmental Justice – Executive Order 12898

As stated in Executive Order 12898 (Office of the President, 1994) all Federal actions are required to consider 

the potential of disproportionate effects on minority and low-income populations in the local region. The 

principals of environmental justice require agencies to address the equity and fairness implications associated 

with Federal land management actions. The Council on Environmental Quality (CEQ) provides the following 

definitions in order to provide guidance with the compliance of Environmental Justice requirements: 

• “Minority population: Minority populations should be identified where either: (a) the minority

population of the affected area exceeds 50 percent or (b) the minority population percentage of the

affected area is meaningfully greater than the minority population percentage in the general

population or other appropriate unit of geographic analysis...”

• “Low-income population: Low-income populations in an affected area should be identified with the

annual statistical poverty thresholds from the Bureau of the Census' Current Population Reports,

Series P-60 on Income and Poverty. In identifying low-income populations, agencies may consider as

a community either a group of individuals living in geographic proximity to one another, or a set of

individuals (such as migrant workers or Native Americans), where either type of group experiences

common conditions of environmental exposure or effect.” (CEQ, 1997).

According to the American Community Survey and US Census data, it is suggested that the Native American 

population meets the Environmental Justice criterion as a minority population meaningfully greater than the 

general population of the state. Therefore, decision makers should pay careful attention to the potential 

impacts of management actions on Native Americans.

Table Appendix I-1 reports the number of individuals below the poverty level and poverty rates in 2000 and 

2008. Both counties have higher poverty rates than the state. Shasta County experienced a 3% increase in 

poverty during the specified period, while Siskiyou County experienced a slight decline. These poverty rates 

suggest that a substantial proportion of the existing population should be considered as a low income group. 

Therefore, decisions regarding future management actions should carefully assess the effects on low income 

populations in the study area.

Table Appendix I-1. Poverty Status by State and County, 2000 and 2005

Location

2008 2000

Number Percent Number Percent

Siskiyou County 7,182 16.4% 7,235 16.7%

Shasta County 31,309 17.7% 24,195 14.7%

California 4,781,201 13.3% 4,304,909 12.7%

Source: www.census.gov

In cases where the management decisions are expected to create jobs and income in the local economy, it is 

unlikely that there would be a disproportionate adverse effect on minority and low income populations. 

Individuals in that population may benefit from any increase in jobs and income in the area. There are 

expected to be no disproportionate adverse effects on low income or minority populations because of 

implementation of any of the Elk Project action alternatives.
Elk Flat LSR Enhancement Project

H-8 Shasta-Trinity National Forest

Historically, Native Americans collected edible berries such as strawberries, currents and gooseberries. 

Manzanita flowers and berries were eaten and the leaves were used medicinally. Manzanita berries can also be 

used to make a sugar. Many of these plants are still collected today by Native Americans and others. Most of 

these plants are common throughout the project area. Edible fungi species may be the most important species 

being collected in the project area. Prince’s pine (Chimaphila umbellatum) and wintergreen (Pyrola picta) are 

plants that occur in the project area that are important culturally for the Pit River Tribe. Concerns have been 

voiced by the Pit River Tribe regarding the retention of Prince’s pine and wintergreen in the project area. 

These are important cultural plants for the tribe and they can be sensitive to ground disturbance and burning 

(Posey, 2015). There are specific areas within and near the Elk project area that are of importance to local 

Native American tribes, and some ceremonial activities that occur periodically in the vicinity. The Forest has 

worked with local tribes to protect or avoid special areas and coordinate the timing of implementation 

activities to avoid disrupting traditional and ceremonial activities. There are expected to be no 

disproportionate adverse effects on Native Americans because of implementation of any of the Elk Project 

action alternatives.

Invasive Species-Executive Order, Regulation, Policy 

Executive Order 13112, of February 3, 1999

Executive Order 13112 addresses preventing the introducing invasive species and provides for their control 

and minimization of the economic, ecological, and human health impacts the invasive species causes. The 

order states that Federal Agencies should:

Identify actions that may affect the status of invasive species.

Use relevant programs and authorities to: (a) prevent the introduction of invasive species; (b) detect and 

respond rapidly to and control populations in a cost-effective and environmentally sound manner; (c) monitor; 

(d) restore; (e) research; and (f) promote public education on invasive species.

Not authorize, fund, or carry out actions that it believes are likely to cause or promote the introduction or 

spread of invasive species.

Coordinate these duties with the National Invasive Species Council that coordinates Federal strategies to 

address the problem of noxious weeds. 

This project is compliant with the executive order because project actions that may affect the status of 

invasive species have been identified. Relevant programs and authorities will be used to prevent the 

introduction of invasive species, and measures to minimize risk and harm caused by invasive species (see 

RPM 15 (Chapter 2) and Invasive Species Standard Operating Procedures 9 to 13 (Appendix C) will be taken 

in conjunction with this project. 

Departmental Regulation 9500-10: Noxious Weed Management

USDA Regulation 9500-10 directs the Agency to integrate noxious weed management into all programs and 

activities and to develop, demonstrate, and apply the essential science, technology, and stewardship to 

effectively manage and prevent the spread of these plants. As described under FSM 2900 and Executive Order 

13112, the Elk project also complies with this regulation. 

Forest Service Manual (FSM) 2900 

Forest Service Manual Chapter 2900 – Invasive species Management sets forth National Forest System 

policy, responsibilities and direction for the prevention, detection and restoration of effects from aquatic and 

terrestrial invasive species (This new chapter replaces FSM Chapter 2080 – noxious weed management).
Draft Environmental Impact Statement

Shasta-McCloud Management Unit H-9

Section 2902 strategic objectives include prevention, early detection and rapid response, control and 

management, restoration, and collaborating with other organizations. Section 2903 established policy at the 

project level. The Shasta-Trinity National Forest has placed a high priority on management of invasive weed 

species. This includes reducing management-related introduction and spread of invasive weeds on the Forest. 

Initial implementation of the Elk Project any of the action alternatives would involve increased ground 

disturbance and vehicle travel in the short-term, increasing the opportunity for invasive plant introduction, 

spread, and establishment. In the long-term, the action alternatives would result in a healthier more resilient 

forest environment and a smaller road system with lower erosion risk and requiring less maintenance, 

resulting in decreased opportunity for invasive plant introduction, spread, and establishment. Implementation 

of mitigation (ore resource protection measures (see RPM 15 in Chapter 2) and Invasive Species Standard 

Operating Procedures 9 to 13 (Appendix C) to prevent the introduction and spread of invasive plants during 

project implementation would minimize the risk involved with any of the action alternatives considered in 

detail.

There are no known populations of any weed species rated moderate or high by the Forest within the Elk 

project area. If any new populations are found before or during implementation, these populations will be 

incorporated into any contract maps implementing the project. They will be flagged on the ground as 

exclusion areas.

Migratory Birds – Executive Order 13186 of January 10, 2001

Under the National Forest Management Act (NFMA), the Forest Service (FS) is directed to “provide for 

diversity of plant and animal communities based on the suitability and capability of the specific land area in 

order to meet overall multiple-use objectives.” (P.L. 94-588, Sec 6 (g) (3) (B)). The January 2000 Landbird 

Conservation Strategic Plan , Executive Order 13186 (Office of the President, 2001), the Partners in Flight 

specific habitat conservation plans for birds, and the January 2004 Partners in Flight North American 

Landbird Conservation Plan (Rich, et al., 2004), all reference goals and objectives for integrating bird 

conservation into forest management and planning. On December 2008, a Memorandum of Understanding 

(MOU) between the FS and the FWS to promote the conservation and reduce take of migratory birds was 

signed, and was reaffirmed in 2014 (USDA-FS & USDI-FWS, 2008; USDA-FS & USDI-FWS, 2014c). The 

intent of the 2008/2014 MOU is to strengthen migratory bird conservation by identifying and implementing 

strategies that promote conservation and avoid or minimize adverse impacts through enhanced collaboration 

and cooperation between the FS and the FWS as well as other federal, state, tribal and local governments.

On National Forest System lands, conservation of migratory birds focuses on providing a diversity of habitat 

conditions at multiple spatial scales and ensuring that bird conservation is addressed when planning for land 

management activities. A Migratory Bird Report was completed for the project and is incorporated by 

reference (Jordan, 2015f). Information relevant to the decision to be made is summarized here. Opportunities 

to promote conservation of migratory birds and their habitats in the 3,519-acre project area were considered 

during project development per the 2008/2014 MOU, specifically Section C: item 1, and Section D: items 3a3d, and 6. 

For the Shasta-Trinity National Forest, the bird species of management concern are those listed under the 

Endangered Species Act as threatened or endangered, those designated by the Regional Forester as sensitive, 

those associated with management indicator assemblages (MIAs) affected by the project, and those of 

conservation concern (USDA-FS & USDI-FWS, 2008). 

Effects to the federally threatened northern spotted owl are discussed in Chapter 3, starting on page 158, and 

effects to the sensitive northern goshawk are discussed starting on page xxx. Effects to MIAs and 

representative species are summarized above on page I-17 and described in detail in the project-level MIA 
Elk Flat LSR Enhancement Project

H-10 Shasta-Trinity National Forest

report. Project effects to other bird species of conservation concern within the Great Basin Bird Conservation 

Region (BCR-9) are assessed in the project-level Migratory Bird report (Jordan, 2015f). 

The need to maintain, enhance and restore habitat components important to migratory birds and reduce the 

potential for take and adverse effects in the project area was emphasized throughout project development, in 

accordance with MOU Section D, item 3b and items 3c1-3c4. The project’s design, specific treatment 

prescriptions and resource protection measures will help ensure that treated areas continue to provide 

necessary habitat to maintain a diversity of species at both the stand and landscape scale during and after the 

project is completed, and that the potential for adverse effects to individuals and project-level populations is 

reduced if not eliminated. 

The project’s design and resource protection measures preclude mechanical treatments in certain high quality 

habitat areas, known breeding sites, and near riparian zones that provide habitat for listed, sensitive and 

species of management concern. Treatments will maintain large and small trees; trees with old-growth and 

late-successional characteristics such as large branching, cavities, flattened tops; variable canopy cover of 

trees and shrub species; large and small snags and down logs; and shrubs that provide breeding, roosting and 

foraging habitat. Treatments will increase oak, aspen and open meadow habitats, and limited operating 

periods are in place for thinning and burning actions during critical breeding periods. 

The FS has also assessed the potential for environmental contaminants and other stressors relevant to 

migratory bird conservation in accordance with MOU Section D, item 3c5 through the Human Health and 

Risk Assessment for Borax (USDA-FS, 2006). While the potential exists for migratory birds to consume prey 

exposed to borax application, the risks to terrestrial species are low, with most acute and chronic risk 

quotients well below levels of concern (USDA-FS, 2006). Considering it is unlikely for birds to ingest borax 

from treated stumps, that none of the hazard quotients exceed the level of concern for contaminated water 

(even at application rates 10 times the rate proposed), and that the 2006 risk assessment indicates boric acid is 

practically non-toxic to avian species, borax application is not expected to have measurable effects on 

migratory birds or their prey.

Implementation of the project is expected to maintain as well as enhance the existing functional habitat used

by migratory birds over the short- and long-term, contributing to long-term sustainability and resilience of 

foraging and reproductive habitat that may be used by migratory birds (Jordan, 2015f). 

Watch List (WL) botanical species - Departmental Regulation 

USDA Regulation 9500-4 directs the Forest Service to manage habitats for all existing native and desired

nonnative plants, fish, and wildlife species in order to maintain at least viable populations of such species, and 

to avoid actions that may cause a species to become threatened or endangered. Forest Service objectives 

further state that viable populations of all species must be maintained in habitats distributed throughout their 

geographic range on National Forest System lands (Forest Service Manual [FSM] 2670.22). The Compliance 

Report for Botanical Species (Posey, 2015) provides information specific to Watch List species and 

information most relevant to the decision and compliance with 9500-4 is summarized here.

The California Native Plant Society’s Inventory of Rare and Endangered Plants of California describes a 

watch list (WL) species as species that do not meet all the criteria to be included on the Regional Forester’s 

Sensitive List, but are of sufficient concern that we need to consider them in the planning process. These 

include species that 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 or distribution. The creation of the sensitive species and watch lists are key steps in meeting the 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit H-11

commitment to maintain biologically diverse and healthy ecosystems.” 139 The Shasta-Trinity National Forest 

does not maintain a Watch List (WL), but instead considers all CNPS Inventory taxa of lists 1-4 (CNPS, 2015) 

[that are not already managed as Regional Forester’s Sensitive Species or Forest Plan Endemics] to be eligible 

for mitigation at the project level if needed.

A WL perennial bunchgrass, Muhlenbergia jonesii (Jones’ muhly), occurs within the project area throughout 

parts of Elk and Coonrod Flats, All areas combined cover many acres. The populations are in more open areas 

with few trees. Generally, grasses of this type are more robust and more nutritious after burning. Burning in a 

mosaic pattern will reduce the loss of soil biota. Removal of conifers will create habitat for this species. 

Decommissioning unauthorized routes may improve habitat for Jones’ muhly by discouraging illegal 

vehicular use. The project will benefit the species through removal of dead thatch during burning. Equipment 

disturbance may crush, uproot and possibly cause mortality of individual plants; however, the sparse conifer 

cover near these populations will minimize disturbance from equipment. Burning may kill some individual 

plants. The population as a whole will benefit as disturbance, especially burning, is generally important for 

maintaining healthy grasslands.

Resource Protection Measures, SOPs, and BMPs in place for protecting soils, and improving and protecting 

hydrological function will provide protection for this species in compliance with DR-9500-4 and Forest 

Service Policy.

Should other watch list species be found before or during project implementation, protection measures will be 

put into place to protect the species and its habitat. Protection measures will depend on the species. However, 

many watch list species require disturbance especially fire to maintain their habitat. Many early seral species 

respond favorably to mechanical disturbance. In this case, it may not be necessary to protect the sight from 

either mechanical or fire disturbance. If the species is one that does not respond favorably or require 

disturbance, the site would be flagged and avoided. 

Water Quality – Basin Plan 

Designated beneficial uses, water quality objectives (standards), and a policy statement regarding maintaining 

high quality waters in California are within the Board’s Water Quality Control Plan (Basin Plan) 

(CVRWQCB, 2011). Under section 303(d) of the 2006 Clean Water Act where water quality is limited, state 

agencies develop plans to improve water quality to support the beneficial uses of water (US-EPA, 2002). This 

information was reviewed in context of the project area boundary and proposed treatment units. According to 

the Section 303(d) list of water quality limited segments for the State of California, there are no water quality 

limited waterbodies related to the project area (CVRWQCB, 2011). 

There are no municipal watersheds within the 5th field watershed of the Project Area; A municipal watershed 

is a community water system “that serves at least 15 service connections used by year-round residents of the 

area served by the system; or regularly serves at least 25 year-round residents” (Safe Drinking Water Act, 

Section 1401, 42 U.S.C.A. 300f.(15)). 

Through a memorandum of understanding with the State of California, and in compliance with the Clean 

Water Act for controlling non-point pollution sources, the U.S. Forest Service will implement Best 

Management Practices (BMPs) on ground disturbing activities that are approved by the U.S. Environmental 

Protection Agency (USDA-FS, 2000). All timber sales that may have the potential to impact water quality are 

139 Watch List species are discussed under the heading of “Rare Plant Management on the National Forest and 

Grasslands in California on page 33 of the “California Native Plant Society’s Inventory of Rare and Endangered Plants of 

California” (CNPS, 2001). 
Elk Flat LSR Enhancement Project

H-12 Shasta-Trinity National Forest

evaluated, identified, monitored, and reported by the forest service and the state under a Conditional Waiver 

of Waste Discharge Requirements to assure BMPs are applied to prevent impacts to water quality 

(CVRWQCB, 2010). 

National Forest Management Act (NFMA) [Forest Plan Consistency] 

The National Forest Management Act (NFMA) requires specific findings and the development, maintenance, 

amendment, and revision of land and resource management plans [Forest Plan(s)] for each unit of the 

National Forest System. The Forest Plans help create a dynamic management system so that an 

interdisciplinary approach to achieve integrated consideration of physical, biological, economic, and other 

sciences will be applied to all future actions on the unit [16 U.S.C. 1604(b), (f), (g) and (i)]. A Forest Plan 

consistency discussion follows the NFMA finding provided below. 

NFMA Findings [16 U.S.C. 1604 (g)(3)(E)] 

1. Soil, slope, or other watershed conditions will not be irreversibly damaged - None of the alternatives 

would irreversibly damage soil, slope or other watershed conditions. See the soils section (p. 225) and 

hydrology section (starting on p. 201).

2. There is assurance that such lands can be adequately restocked within five years after harvest -

Reforestation will occur within five years of final harvest. Any stand that receives any harvest activity

will not be maintained as a permanent opening and will be fully stocked, or can be adequately restocked

with natural regeneration within five years of final harvest. Live green trees retained on each unit will

serve as seed sources where regeneration is inadequate. Minimum stocking levels are defined in the

Forest Plan (p. 4.27). All areas proposed for artificial reforestation have been reviewed by a certified

silviculturist and a soil scientist to ensure adequate soils for planting and growth of conifer seedlings.

3. Protection is provided for streams, streambanks, shorelines, lakes, wetlands and other bodies of

water from detrimental changes in water temperatures, blockages of water courses and deposits of

sediment, where harvests are likely to seriously and adversely affect water conditions or fish habitat

- Hydrologic function, water quality and fish habitat will not be adversely affected. See Resource

Protection Measures Common to all Action Alternatives, Chapter 2 (starting p. 81) and the hydrology

effects section (starting p. 201).

4. The harvesting system to be used is not selected primarily because it will give the greatest dollar

return or the greatest unit output of timber - Harvesting systems were selected based on a variety of

factors. The systems used to accomplish the purpose and need were proposed to most efficiently achieve

project objectives, minimize impacts to resources and took into account a variety of factors, including

reduced impacts to soils and reduced activity fuels, topography, cost and efficiency.

Additionally, the Project is consistent with 36 CFR 219.27c1 since all stands proposed for harvest treatment 

under all alternatives are classified as suitable for timber harvest, and with 16USC 1604 (g)(3)(B) by 

providing for diversity of plant and animal communities based on the suitability and capability of the specific 

land area in order to meet overall multiple-use objectives. The project also provides diversity of tree species 

similar to that existing in the region because species such as quaking aspen, black oak, ponderosa pine, 

incense cedar, white fir and sugar pine will be retained, and a variety of treatments are proposed. Also, see 

Executive Order 13186 on page I-9. 

Forest Plan Consistency
Draft Environmental Impact Statement

Shasta-McCloud Management Unit H-13

In addition to the discussions of Forest Plan consistency previously presented in the individual resource 

effects discussions, the incorporated resource reports, and in the compliance topics listed above, the project 

meets the Forest Plan for the following presented in alphabetical order:

Aquatic Conservation Strategy Objectives140

This section describes how the Elk Flat LSR Vegetation Project meets the objectives under the Aquatic 

Conservation Strategy of the NWFP.

141 

In summary, all action alternatives meet and do not prevent attainment of the ACS objectives. Differences to 

the degree that the action alternatives meet these objectives varies with how well a) overstocked stands and 

fuels are reduced over the project area; b) how well treatment within Riparian Reserves improves openings 

for sunlight for riparian vegetation and c) how well floodplain processes and functions are restored. Although 

Alternatives 2 and 3 do not optimize Riparian Reserve objectives as well as Alternative 1, they still meet and 

do not prevent attainment of ACSO objectives. 

The nine Aquatic Conservation Strategy (ACS) objectives follow with a description of likely effects from 

each alternative.

1. Maintain and restore the distribution, diversity, and complexity of watershed and landscape-scale features

to ensure protection of the aquatic systems to which species, populations and communities are uniquely 

adapted. 

Alternative 1: The proposed treatment promotes stand health, open meadow and riparian plant 

species distribution, diversity and complexity adding to a positive contribution towards watershed and 

landscape-scale features.

Alternatives 2 and 3: Less ground disturbance from these alternatives would result in less slight soil 

displacement to the ground surface. However, fewer stand and riparian health objectives will be met 

by reducing access as fewer acres will be treated that would meet the purpose and need of the project.

2. Maintain and restore spatial and temporal connectivity within and between watersheds. Lateral,

longitudinal, and drainage network connections include floodplains, wetlands, upslope areas, headwater 

tributaries, and intact refugia. These network connections must provide chemically and physically 

unobstructed routes to areas critical for fulfilling life history requirements of aquatic and riparian-dependent 

species.

Alternative 1: All treatments proposed in and surrounding floodplains are designed to benefit spatial 

and temporal connectivity of streams. Some road closures and a 1⁄4 mile of road decommissioning will 

reduce road and stream interaction. Routes in Elk Flat cross the Swamp Creek intermittent channel 

and will be decommissioned and floodplains restored. 

140 1994 ROD, Attachment B, p. B-10. The 2007 ACS Compliance Memo direction resulting from the Pacific Coast Fed. of 

Fishermen’s Assn. et al v. Natl. Marine Fisheries Service, et al and American Forest Resource Council, Civ. No. 04-

1299RSM (W.D. Wash)( (PCFFA IV) requires a finding of consistency with the NWFP, 1994 ROD, Attachment B, p. B-10. 

Page B-10 requires the decision maker to find that the proposed management activity is consistent with the ACSO by 

finding that a project “meets” or “does not prevent attainment” of the ACSO. 141 1994 ROD, Attachment B, p. B-10. The 2007 ACS Compliance Memo direction resulting from the Pacific Coast Fed. of 

Fishermen’s Assn. et al v. Natl. Marine Fisheries Service, et al and American Forest Resource Council, Civ. No. 04-

1299RSM (W.D. Wash)( (PCFFA IV) requires a finding of consistency with the NWFP, 1994 ROD, Attachment B, p. B-10. 

Page B-10 requires the decision maker to find that the proposed management activity is consistent with the ACSO by 

finding that a project “meets” or “does not prevent attainment” of the ACSO.
Elk Flat LSR Enhancement Project

H-14 Shasta-Trinity National Forest

Alternatives 2 and 3: Spatial and temporal connectivity may be slightly beneficial under Alternative 

2 if no new temporary roads are constructed. However, the scale of new construction is so small that 

likely there would be no measurable results.

3. Maintain and restore the physical integrity of the aquatic system, including shorelines, banks, and bottom

configurations. 

Alternative 1: The aquatic system will be maintained and restored to increase the physical integrity 

of instream structure and floodplain interaction. With the exception of restoration activity, there will 

be no direct entry or effect upon channel banks or beds from harvest activity. Improvements to 

aquatic system features are expected from restoring riparian plant vegetation and increasing bank 

strength. 

Alternatives 2 and 3: These alternatives will provide the same benefits to the aquatic system as

Alternative 1 for this objective.

4. Maintain and restore water quality necessary to support healthy riparian, aquatic, and wetland ecosystems.

Water quality must remain within the range that maintains the biological, physical, and chemical integrity of 

the system and benefits survival, growth, reproduction, and migration of individuals composing aquatic and 

riparian communities. 

Alternative 1: Negligible effects to water quality are expected from project implementation with 

BMP’s in place. Water quality should remain unaltered by harvest or fuel reduction activities, falling

within the known range of natural variability, as all activities are guided by BMPs designed to avoid 

water quality impacts. 

Alternatives 2 and 3: Some areas along Ash Creek would not benefit from the reduced surface 

runoff resulting from reduced temporary road length under Alternative 2, as skid trail length would 

increase. The No Action Alternative would show no improvements to water quality, as the current 

condition is not supporting riparian vegetation productivity. 

5. Maintain and restore the sediment regime under which aquatic ecosystems evolved. Elements of the

sediment regime include the timing, volume, rate, and character of sediment input, storage, and transport. 

Alternative 1: Aside from increase in fine sediments likely to occur from increased traffic, no other 

significant source of sediment from the proposed action alternatives is expected. The current regime 

will continue.

Alternatives 2 and 3: Some areas along channels would not be accessed by temporary roads, 

however, because of the small road area and proximity to creeks there would be relatively small 

benefits from reduced surface runoff potentially carrying sediment under Alternative 2 as compared to 

Alternative 1. 

6. Maintain and restore instream flows sufficient to create and sustain riparian, aquatic, and wetland habitats

and to retain patterns of sediment, nutrient, and wood routing. The timing, magnitude, duration, and spatial 

distribution of peak, high and low flows must be protected. 

Alternative 1: The project is designed to improve riparian and floodplain function, however, effects 

on flow regime will probably be neutral due to the larger watershed-scale influences being so much 

greater than project results. Project disturbances, particularly road actions, are expected to be 

insufficient to affect peak flow yield or timing. 

Alternatives 2 and 3: Similar to Alternative 1, with slightly less ground disturbance, but due to the 

scale, any benefits to instream flow would not be measurable.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit H-15

7. Maintain and restore the timing, variability, and duration of floodplain inundation and water table elevation

in meadows and wetlands. 

Alternative 1: Flow timing and yield will not be measurably altered, as stated under ACSO 6. 

Floodplain processes and function should improve on a site-specific basis. A detectable change in 

floodplain inundation should result from this alternative, and should benefit water table elevation 

adjacent to the floodplain and channel. 

Alternatives 2 and 3: Without temporary road construction, some slight benefit from treating a small 

portion of the stands adjacent to channels would not be realized under this alternative; however, no 

measurable difference in floodplain inundation or water table elevation would be detectable at this 

small difference in lack of treatment resulting in shade retention inhibiting riparian plant growth. 

8. Maintain and restore the species composition and structural diversity of plant communities in riparian areas

and wetlands to provide adequate summer and winter thermal regulation, nutrient filtering, appropriate rates 

of surface erosion, bank erosion, and channel migration and to supply amounts and distributions of coarse 

woody debris sufficient to sustain physical complexity and stability. 

Alternative 1: This alternative proposes to treat the Riparian Reserves to improve stand health, create 

openings to increase sunlight and restore floodplains. These efforts should result in many benefits to 

ACSO 8. Channel bank integrity should improve with an increase in riparian root strength. Plant 

diversity is expected to increase and eventually plant community should be improved in those riparian 

areas treated, because of increased sunlight reaching the forest floor.

Alternatives 2 and 3: Similar to Alternative 1 with negligible differences from no temporary road

construction. 

9. Maintain and restore habitat to support well-distributed populations of native plant, invertebrate and

vertebrate riparian-dependent species.

Alternative 1: Restoration of meadow, floodplains and stand health should maintain and restore 

habitat as described under this ACSO objective. Most dense stands will be treated to improve 

understory conditions and increase habitat for native plant, invertebrate and vertebrate ripariandependent species.

Alternatives 2 and 3: Similar to Alternative 1, there would be slightly more short-term benefit to 

leaving the existing ground without temporary road construction to treat stand-health, however, these 

are not the alternatives that would optimize the objectives that would meet the purpose and need of 

the project and therefore would not optimize maintaining or restoring habitat under ACSO 9. 

Ethnobotanical Resources/Special Forest Products

A Forest Plan Goal (p. 4.4) is to integrate multiple resource management on a landscape level to provide and 

maintain diversity and quality of habitats that support viable populations of plants, fish and wildlife. The need 

to promote community stability is addressed through the integration of multiple resource standards and 

guidelines. Forest-wide Standards and Guidelines, Management Prescriptions and Management Area direction 

help provide for safe use and enjoyment of various resources and production of goods and services (Forest 

Plan p. 2.3). Additionally, the Forest has entered into a Memorandum of Understanding (MOU) with the Pit 

River Tribe regarding communication and consultation protocol. The Forest has agreed to integrate cultural 

resource considerations and traditional ecological knowledge into land and resource management decisions to 

promote sustainable ecosystems (USDA-FS & Pit River Tribe, 2007). Ethnobotanical species/Special Forest 

Products and unique habitats are considered at the project level in relation to the Forest Plan and in the spirit 

of this agreement. The compliance Report (Posey, 2015) provides the analysis for Ethnobotanical 
Elk Flat LSR Enhancement Project

H-16 Shasta-Trinity National Forest

Resources/Special Forest Products and Unique Habitats. Information relevant to this decision is summarized

here.

Historically, Native Americans and settlers collected edible fruit such as strawberries, serviceberries, wild 

plums, currents, gooseberries and mushrooms. Manzanita flowers and berries are edible and a tincture made 

from the leaves used medicinally. Crushed, dried manzanita berries make a sweetener. Edible and medicinal 

plants collected by Native Americans and others are mostly common throughout the project area, and 

continue to be collected. Black oaks provide acorns, which are culturally important to Native Americans. 

Most of these plants, except for black oak, are common throughout the project area. Effects of the project on 

black oak are discussed in the Botany section starting on page 186. 

Fungi are an important commercial special forest product. Spring collection permits are available late spring 

or early summer depending on the weather and continue until the summer heat arrives and mushrooms are no 

longer available. Fall collection permits are available in mid-October depending on the weather and continue 

until it freezes or snows. Spring mushrooms include boletes and morels. Analysis for Boletus mushrooms in 

Elk Flat begins on page 186. Morels (Morchella species) known to occur on the McCloud District include 

Morchella sextelata and M. septimelata (black, black burn, pink and green morels). Habitat is solitary to 

scattered, gregarious, or clustered, on burned soil in lightly to moderately burned montane coniferous forests; 

common, sometimes fruiting in abundance in spring following a forest fire the previous year, in smaller 

quantities in subsequent years, widely distributed (Desjardin, et al., 2015).

 142 Morels are saprophytic 

mushrooms meaning they decompose dead and dying material. 

The design criteria to protect northern spotted owl (NSO) and goshawk habitat will also retain habitat for 

many fungi species by using a variable density thinning prescription designed to retain tree and shrub species, 

down woody debris, snags and overstory cover. The meadow prescription for Elk Flat will contain unthinned 

patches and retain predominant conifer species. Prescriptions designs for underburning will produce a mosaic 

pattern. This means that areas will burn in a way that produces a variety of burn intensities. These intensities 

will range from areas that do not burn at all to areas that burn very hot. Some habitat for ectomycorrhizal 

fungi will be degraded while other habitat may be improved. In either case, it will take time to reestablish the 

mycorrhizal associations destroyed or disrupted. Morels benefit from disturbance especially fire.

Special forest products collected, besides mushrooms, include firewood, fence posts, tepee poles, cedar 

boughs, collecting of plants for scientific study, wild-crafting of herbs, roots etc. for the health supplement 

industry, cones and other plant parts for craft and floral industries. Cones are also collected for seeds. Permits 

are required for the collection of special forest products. Collected species are mostly early seral, such as fruit 

producing shrubs and Indian tobacco, and benefit from disturbance. More shade-loving species such as 

Prince’s pine and wintergreen are more sensitive to the removal of overstory cover, ground disturbance and 

underburning. Recovery time could take up to 20 years or longer depending on the treatment. 

Thinning and burning will improve habitat for most species. Historically, all plant species coexisted with fire. 

Most ethnobotanical plants have the ability to resprout after being damaged or have seeds in the soil that can 

germinate. Effects to plants would be short lived (one to five years). The project design includes variable 

silvicultural and fuels prescriptions, which would help maintain diverse stand characteristics. Resource 

Protection Measures, SOPs and BMPs designed to provide protection for soils, maintain or improve 

hydrological functions and improve and maintain wildlife habitat address ethnobotanical and special forest 

products, consistent with the intent of the Forest Plan. 

142 These are the most common mushrooms collected. There may be other species collected within the Elk project area.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit H-17

Late Successional Reserve

Introduction

As described in Chapter 1, the NWFP describes that thinning or other silvicultural treatments143 inside LSRs 

may occur in stands up to 80 years of age if the treatments are beneficial to the creation and maintenance of 

late-successional forest conditions. In reserves east of the Cascades and in Oregon and California Klamath 

Provinces, additional management activities are allowed to reduce risks of largescale disturbance. Thinning or 

other silvicultural activities must be reviewed by the Regional Ecosystem Office (REO) and the Regional 

Interagency Executive Committee (RIEC). (NWFP page 8 and pages C-12, 13, and 26). 

The NWFP describes that a management assessment should be prepared for each large LSR (or group of 

smaller LSRs) before habitat manipulation activities are designed and implemented. In 1999, the Forest 

prepared the Forestwide Late-Successional Reserve Assessment (LSRA), which met this requirement. The 

LSRA activity design criteria identify specific objectives and criteria to ensure consistency with LSR 

objectives. In their August 26, 1999 letter that documents review of the LSRA, the REO determined that the 

silvicultural activities described in the LSRA were consistent with the standards and guidelines of the NWFP 

and were exempted from further project-level REO review, which met the obligation of REO/RIEC review of 

thinning or other silvicultural activities. In 2009, REO corrected and clarified portions of Activity Design 

Criteria (ADC) #4 and #5. 

The Elk LSR Enhancement project is designed to move the landscape toward the desired condition for the Elk 

Flat LSR as guided by the visions, goals, strategies and design criteria embodied in the NWFP, the Forest 

Plan, and the LSRA as described earlier in the EIS. The project is consistent with general objectives from the 

LSRA, all of which fall under LSRA ADC 1 (Reforestation and revegetation), 4 (Thinning in early 

successional pole and mid-successional stands - Hazard Related), 7, 9 and 10 (Fuel Reduction, Hazard 

Reduction - Prescribed Burning and Manual and Mechanical Fuels Reduction) or Miscellaneous Activity 7 

(Maintaining Hardwood Stands, forest openings, meadows, and glades). One of the proposed treatments in the 

Elk LSR project requires REO review to ensure consistency with the NWFP due to Activity Design Criteria 

#4 treatment standard “c”. 

• ADC #4 “c” calls for the treatment to increase diversity in relatively uniform stands by including

areas of variable spacing including up to 15% of the area to be in heavily thinned patches, or in

openings up to 1/4 acre in size. The Elk LSR Project proposes groups selects (“openings”) up to

about 2 acres

144 in six 40 to 50 year-old ponderosa pine plantations and two natural stands that

range from 80 to 120 years old.

In addition, some of the proposed treatments in the Elk LSR project will be evaluated against NWFP criteria 

for risk reduction treatments in older stands. 

• The Elk LSR Project proposes to treat numerous stands 60-100 or 80-120 years old in order reduce

risks of large-scale disturbance. NWFP p. C-14 states that silvicultural activities aimed at reducing

risk shall focus on younger stands in LSR; younger stands are stands less than about 80 years old

(NWFP pp. C-12, 13). While risk-reduction efforts should generally be focused on young stands,

activities in older stands may be appropriate if: (1) the proposed management activities will clearly

result in greater assurance of long-term maintenance of habitat, (2) the activities are clearly needed

143 Stand and vegetation management of any kind, including prescribed burning, is considered a silvicultural treatment (NWFP S&G 

p. C-12).

144 In natural stand units 160, 152-1 and plantation units 6, 7, 13, 14, 16, and 18.
Elk Flat LSR Enhancement Project

H-18 Shasta-Trinity National Forest

to reduce risks, and (3) the activities will not prevent the LSR from playing an effective role in the 

objectives for which they were established (NWFP pp. C-12, 13). 

The NWFP “Ecological Principles for Management of Late-Successional Forests” describes stand 

management in LSRs: “Stand management in Late-Successional Reserves should focus on stands that have 

been regenerated following timber harvest or stands that have been thinned. These include stands that will 

acquire late-successional characteristics more rapidly with treatment, or are prone to fire, insects, diseases, 

wind, or other disturbances that would jeopardize the reserve. Depending on stand conditions, treatments 

could include, but should not be limited to: (1) thinning or managing the overstory to produce large trees; 

release advanced regeneration of conifers, hardwoods, or other plants; or reduce risk from fire, insects, 

diseases, or other environmental variables; (2) underplanting and limiting understory vegetation control to 

begin development of multistory stands; (3) killing trees to make snags and coarse woody debris; (4) 

reforestation; and (5) use of prescribed fire. Thinning prescriptions should encourage development of diverse 

stands with large trees and a variety of species in the overstory and understory. Prescriptions should vary 

within and among stands.” The LSRA identifies criteria, objectives, stand attributes and/or treatment stands to 

meet these goals.

Openings Greater Than 1⁄4 Acre within Thinned Stands

LSRA activity design criteria (ADC) #4 identifies objectives, stand attributes and treatment stands to meet the 

NWFP goals and principles. ADC #4 treatment standard “c” calls for treatment to increase diversity in 

relatively uniform stands by including areas of variable spacing including up to 15% of the area to be in 

heavily thinned patches, or in openings up to 1/4 acre in size. The Revised Recovery Plan for the Northern 

Spotted Owl (USDI-FWS, 2011) and the Revised Critical Habitat Rule for the Northern Spotted Owl (USDIFWS, 2012) both discuss utilizing ecological forestry techniques in the dry forest ecosystems to increase 

stand resilience to stressors and potential influences from a changing climate. These techniques include 

retaining and/or restoring spatial heterogeneity, species and structural diversity, and ecological processes 

(Recovery Plan p. III-14, Final Rule, p. 71910). Other recent scientific research and literature science 

describes the ecological forestry concept (Franklin, et al., 2007; Churchill, 2013; Franklin, et al., 2013; North, 

et al., 2012). In line with the overall management direction contained in the LSRA and NWFP and 

recommendations from recent science, the Elk LSR Project proposes various ecological forestry-based 

treatments including variable density thinning (Carey, 2003; Franklin, et al., 2013; Franklin, et al., 2012; 

Franklin, et al., 2013; Carey, 2003; North, et al., 2009; North, et al., 2012; Franklin, et al., 2012). Variable 

density thinning does not include a singular density target, rather it retains a range of densities by including 

unthinned patches (“ skips”), areas of heavy thinning or small openings or “gaps” (radial release of legacy 

trees, structures or minor species, or group selections), and thinning within a target basal area range elsewhere 

in the stand. Group selection treatments are proposed with the Elk LSR project that would create openings up 

to about 2 acres within several of the stands proposed for thinning, which is larger than the 1⁄4 acre openings 

identified in the LSRA ADC 4 treatment standard “c”.

Two types of stands are proposed for thinning with group selection treatments: 40-50 year old ponderosa pine 

plantations that primarily function as capable habitat for the northern spotted owl, and 80-120 year old natural 

stands. The plantations consist of dense homogeneous stands of medium- and small-sized ponderosa pine 

trees and in the natural stands, groups are proposed in dense homogeneous stands of white fir.145 The six 

plantation units have a minor amount of residual mixed-conifer that would either are placed in unthinned 

patches. Units 152-1 and 160 contain areas of dense, homogenous white fir infected with Heterobasidion root 

disease.

145 Purpose and Need #1, Density, Existing Condition; Stand Record Cards.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit H-19

This Purpose and Need section discusses why treatment activities are needed now to improve stand 

composition, structure, density (in particular to develop species and age/size diversity in stands that lack 

heterogeneity), and resilience with supporting analysis in the Chapter 3 Silviculture and Forest Health, Fire 

and Fuels and Wildlife sections. Permitting the no action alternative to continue clearly results in further risk 

to and loss of developing and existing late-successional stands in the Elk Flat LSR.

The group selections will allow the stands to develop and contribute a diversity component of species and to 

increase vertical and horizontal complexity. Stand structure, tree size, layering and species composition, 

presence of edges and small openings, and landscape position are all influential in habitat selection for the 

northern spotted owl (Zabel, et al., 1995; Irwin, et al., 2012). The group selections would also help break up 

the spread of Heterobasidion by reducing root-to-root contact and introducing other non-host species to the 

stand (application of borate compound is also expected to reduce the overland infection of Heterobasidion). 

The gaps and heterogeneity created by the groups will also help the stands better sustain natural disturbances

through higher resilience while increasing wildlife habitat heterogeneity and ecosystem function (North, et al., 

2012; Churchill, 2013). It is documented that irregular tree patterns, large openings, and resulting variation in 

surface fuels can also reduce the potential for the spread of crown fire and help perpetuate variable post-fire 

patterns (Churchill, 2013). Heterogeneous stand structures typically impede the buildup of epidemic insect 

outbreaks (Churchill, 2013) and the variable density thinning treatments should also improve prey base and 

foraging habitat for northern spotted owl, fisher and northern goshawk associated with various forest 

conditions (North, et al., 2009). 

Risk Reduction in Stands Older Than 80 Years Old

Introduction

The NWFP states that silvicultural activities aimed at reducing risk shall focus on younger stands in LSR and 

younger stands are stands less than about 80 years old (NWFP pp. C-12, 13). While generally focused on 

young stands, risk-reduction activities in older stands may be appropriate if they meet the three criteria listed 

above and examined below. The Elk LSR Project proposes risk reduction treatments in stands ranging from 

about 60 to 120 years of age. 

Activities Are Clearly Needed To Reduce Risks and Clearly Result in Greater Assurance of 

Long-Term Maintenance of Habitat

The EIS discusses how the activities are clearly needed to reduce risk and how proposed activities will result 

in greater assurance of long term maintenance of habitat, particularly in the Purpose and Need, Silviculture 

and Forest Health, Fire and Fuels and Wildlife sections; but also in the Hydrology and other areas. For 

example, the Elk LSR has already experienced loss of overstory ponderosa pine trees ranging from 80 to 120 

years old in the extensive mortality area and other smaller mortality patches and units, which has 

continuously expanded since 2009. A fire start in the extensive mortality area and certain units in the 

southeastern portion of the LSR (units 162, 176) would be of high intensity. Without action, further stand and 

structural composition loss will result from the combination of continued overstocking and density-related 

mortality, root disease, insect attacks and the predicted lethal fire effects with a resulting loss or decline in 

habitat and failure to maintain or meet objectives for the LSR and surrounding stands. The same conditions 

affecting successional development are also reducing the value of these stands as connectivity between and 

within existing late-successional forest.

Based on the stand and fire effects modeling of no action vs. action, monitoring and results of similar 

treatments in dry forest ecosystems and available research, the proposed project activities clearly result in 

greater assurance of (short and) long-term protection and maintenance of late-successional habitat. Treatments 

are expected to produce variable short-term reductions in tree density, canopy cover and layering, shrub cover, 

snags down logs and coarse wood. However, the range of conditions that would provide utility for late 

successional-associated species would be retained and enhanced post-treatment.
Elk Flat LSR Enhancement Project

H-20 Shasta-Trinity National Forest

Stand-level spatial pattern exerts an influence on key aspects of resilience and ecosystem function, such as 

disturbance behavior, regeneration, snow retention, and habitat quality in frequent-fire pine and mixed-conifer 

forests (Churchill, 2013). After treatment, the plantations and natural stands in the LSR would have a greater 

capacity to adapt and thrive in the face of natural disturbances and large scale threats to sustainability (North, 

et al., 2012; Churchill, 2013). The specific kinds of treatment, and their placement, in these early and midsuccessional stands are intended to help develop late successional habitat and mid-to-late successional stands 

persist and mature into late successional/old growth.

Under Alternative 1, thinning, underburning, key group selections (described above) and radial thinning 

would occur in the LSR, intermixed with areas that will not be mechanically treated (unthinned patches or 

high quality habitats set aside, with exception of underburning). Treated stands would emphasize retention 

and promotion of under-represented species such as Douglas fir, sugar pine, black oak and aspen. Douglas fir 

and black oak are known to provide high habitat utility for northern spotted owl (Irwin et. al 2013) and are 

considered important for fisher denning, resting and prey base; “with their often broken tops or large cavities, 

oaks are used by small mammals, forest carnivores, and raptors for resting, denning and nesting” (North, et 

al., 2009). 

Fisher, northern goshawk and spotted owls depend on a forest structure and setting usually dominated by 

large trees, snags, and down logs that provide suitable substrate for nesting, roosting, denning and rest sites. 

Snags and large tree-fall that create canopy gaps enable establishment of multiple tree layers and diverse 

species composition. Trees with physical imperfections such as cavities, broken tops and large deformed 

limbs are also desired for late-successional characteristics (NWFP p. B-5) and specific species reproductive 

and rearing needs (North, et al., 2009). The thinning prescriptions in the Elk LSR project emphasize leaving 

all predominant and most dominant trees; healthy large overstory dominant trees of all species; healthy pine 

of any size where pine is underrepresented; a component of healthy small understory and midstory trees; a 

component of heavily damaged or diseased trees that provide habitat; and all hardwood trees as operationally 

feasible. Large snags and down logs and multiple canopy layers (where conditions allow) will be retained 

consistent with the project’s design and resource protection measures, which were specifically tailored to meet 

the desired future condition in the LSR, and based on LSRA guidance and best available science regarding 

species’ habitat requirements. Variable density thinning will retain a range of densities by including skips, 

gaps, and thinning within a range of basal areas, promoting resilience and heterogeneity. As displayed in 

Table 36 (p. 132) and described in the Silvicultural and Forest Health and Wildlife sections of this EIS, 

thinning will accelerate individual tree growth and increase crown width and depth,146 as well as foliage 

density and needle length. This will contribute to desirable wildlife tree characteristics by providing 

conditions such as fuller crowns, larger boles and branches, and over time, larger trees with cavities or that 

contribute to larger snags and down wood. Combined, these components will provide important decadence 

and late-successional/old-growth habitat characteristics in the LSR.

Within the LSR thinning units, the unthinned patches, larger high-quality foraging areas, and rest/roost 

clumps would retain thermal and visual cover, natural suppression and mortality, small trees, natural size 

differentiation, and undisturbed debris, as well as large trees, decadent trees, large snags, large downed logs, 

and dense and/or multilayered forest attributes. Other larger areas of no-mechanical thinning have been 

prioritized for retention, though would be underburned in accordance with the design criteria (e.g. units 150, 

154, 156, 182 and others, and areas in the Ash Creek riparian reserve.). Retention of these areas will help 

146 “Width and Depth” - Increased light or space among trees enables the lower branches on the crown to remain alive and not be

shaded out by adjacent trees. Thus, tree crowns expand in width as branches grow longer and thicker. Tree crown length increases 

as low branches remain alive and height growth continues. Growth in the stem and branches of trees is also accelerated by thinning

because foliage density or leaf area within the crown increases and crown length is maintained or increased. This increase in leaf 

area enables trees to increase their photosynthesis; consequently, they have the resources to increase stem and branch diameter or 

volumes.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit H-21

retain diverse forest structure and functioning at the stand and landscape scale. This is one element of an 

overall spatial and temporal strategy to retain high quality habitat function on the LSR landscape and address 

forest change over time in other portions of the LSR in the advent of disturbance events. 

For example, in most thinned foraging habitat for the northern spotted owl, when combined with the roost/rest 

clump retention and unthinned patches, basal areas of 125-200+ sqft/acre, conifer and hardwood species 

diversity, large trees and snags, down wood, 40-60 percent or more canopy cover, mid and understory 

layering and vertical and horizontal heterogeneity will be well within the range of stand conditions frequently 

used by owls (Irwin, et al., 2012; Irwin, et al., 2007). In 27 acres of black oak release in foraging habitat, basal 

area would be lower with a short-term adverse effect to foraging habitat elements of critical habitat (PCE3), 

and a long-term benefit to species diversity and stand complexity. The project design and resource protection 

measures retain the largest oldest trees (predominants and dominants) that exhibit old-growth characteristics 

such as large boles, decadent branching, cavities and flattened tops, safety permitting. In treated and untreated 

areas of stands, large decadent trees, snags, and down logs (including those that may be used for denning 

and/or resting furbearers, nesting northern spotted owl or northern goshawk); large and small down wood that 

contributes to subnivean areas for fisher and Pacific marten in the winter to find prey and cover, plucking 

posts for northern goshawk and prey species habitat; and shrub and ground cover for prey species would be 

maintained and promoted. 

Activities Will Not Prevent the LSR from Playing an Effective Role in Established Objectives 

The Elk Flat LSR was identified as an area of important late-successional habitat during the mapping efforts 

undertaken for the Northwest Forest Plan (Johnson, 1991; LSRA, 1999). The LSR’s origins are as a habitat 

conservation area under the Interagency Scientific Committee’s northern spotted owl management strategy 

(LSRA, p. 124). At the time the LSR was established, it was occupied by one pair of northern spotted owls in 

the ST-215 activity center. This activity center has not been occupied by a single territorial individual or pair, 

or a reproducing pair since 1990 (see the Wildlife section for a summary, and the project wildlife Biological 

Assessment in the online project record for a detailed survey account).

The project treatments will affect 100 percent of the suitable (nesting, roosting, foraging) and capable habitat 

in the home range and core of the ST-215 activity center. These effects are a combination of: habitat benefit in 

nesting/roosting from the reintroduction of low-intensity prescribed fire and transitioning capable stands 

toward more resilient dispersal and foraging habitat; maintaining foraging habitat function with a reduced 

quality over an approximate 10-20 year timespan; and downgrading foraging habitat to dispersal quality over 

a 10-30 year timespan in a minor percentage of the home range to increase hardwood diversity and retain 

predominant legacy pine. 

Prioritization for treatment types and locations within the home range of this ‘historic unoccupied’ activity 

center closely followed the prioritization criteria recommended under Recovery Action 10 in the Revised 

Recovery Plan USDI-FWS pp. III-44 to III-47. The Forest also consulted with the FWS on more specific 

prioritization for this Project to meet the intent of Recovery Action 10, as well as Recovery Action 32 (in 

accordance with the Forest Plan standards and guidelines at p. 4-30). Similarly, prioritization of treatment 

types and location (or designating no-treatment areas) was done for the northern goshawk and the fisher, two 

species known to occur and reproduce in the Elk Flat LSR. Though not stated in the LSRA, the Elk Flat LSR 

is expected to only provide for one pair of northern spotted owls in the future, or more likely, to provide an 

important area for dispersing young northern spotted owls to reside in temporarily. This is largely driven by 

the fact that 60 percent of the home range is situated in private land ownership managed for timber production 

and the overall ponderosa-pine dominated stands in the LSR. 

The ability to move across the landscape is important to the long-term persistence and viability of some 

wildlife species, and is particularly important to these late-successional habitat-associated species. As 

described in the NWFP, movement or dispersal across the landscape is provided by large blocks of late-
Elk Flat LSR Enhancement Project

H-22 Shasta-Trinity National Forest

successional habitat in the LSR/MLSA network, and through management objectives and various land 

allocations between them. Those management objectives and land allocations include riparian reserves, 

administratively withdrawn areas, and management prescriptions for retention of old-growth fragments in 

Matrix allocation and 100-acre LSRs. Connectivity is a measure of the extent of which the landscape pattern 

of the late-successional and old-growth ecosystem provides for biological and ecological flows that sustain 

late-successional and old-growth associated animal and plant species. It does not necessarily mean that latesuccessional and old-growth areas have to be physically joined in space, because many late-successional 

associated species can move across areas that are not in late-successional ecosystem conditions. Within the 

Elk Flat LSR, the treatments are expected to protect and enhance connectivity within and between stands. The 

surrounding private lands and large areas of pine-dominated forests (plantations and natural stands) on NFS 

lands do not provide highly suitable connective habitat for the northern spotted owl, though individual 

dispersing young from other LSRs or activity centers may be able to access the LSR (map 4 in the Biological 

Assessment displays habitat in the action area, including dispersal and connective habitat on private and NFS 

lands). Conversely, the northern goshawk and fisher are less dependent on species composition and cover 

requirements for dispersing (and foraging), and the areas within and outside the LSR; forest stands, shrub 

habitats, riparian reserves and streamside protection zones on private lands are expected to continue 

contributing to connectivity. 

Late-successional habitat in the Elk Flat LSR in 1999 comprised a relative large proportion of the capable 

land base, 46 percent (LSRA p. 125). Again as described in Chapter 1, and the relevant resource sections of 

Chapter 3, delaying or taking no action in the project area leaves the LSR at continued risk of substantial 

habitat loss. The project’s thinning and fuels treatment designs, areas delineated for no mechanical treatment 

and measures to maintain and protect important habitat components will contribute to: 1) continued function 

for late-successional associated species use occurring now or in the future, 2) increased diversity and 

resilience of existing and developing early and mid-successional habitat, and 3) reduced risk of loss and 

increased connectivity within and between stands.

As such, the project activities will not prevent the Elk Flat LSR from playing an effective role for which it 

was established. The proposed actions in the LSR will help accelerate development of late-successional

characteristics, will contribute to increased connectivity and resilience of late-successional habitat in the LSR, 

and will help reduce the risk of large scale habitat loss while maintaining important current habitat areas, 

attributes, and functions. This will be achieved by not treating current high quality late-successional habitat 

stands and patches within stands that provide cover, layering and density; retaining important legacy 

components such as roosting and resting structures, large snags, large down wood, and large trees with 

cavities and decadence; retaining multiple canopy layers (where these conditions currently exist); and varying 

the thinning prescriptions within and between stands based on species composition to increase individual tree 

and stand resilience and to promote spatial heterogeneity through openings contrasted with dense forest areas. 

These treatments are expected to protect and enhance the current habitat function and quality for the northern 

spotted owl, fisher and northern goshawk in approximately 70 percent of the LSR, and 100 percent of the 

areas where habitat for these species currently exists. Actions taken under the preferred alternative will 

increase the probability that large-scale habitat loss will not continue, but also retain stand elements and 

conditions more representative of endemic insects, disease and mortality.

Management Indicator Assemblage 

The Forest Plan directs resource managers to monitor assemblage habitat trends at the National Forest scale 

(Forest level; Forest Plan 1995 page 5-16). The Forest Plan identifies management indicator assemblages for 

monitoring; it does not identify management indicator species but does list examples of representative species 

for each assemblage. The Forest has selected specific species to represent the management indicator 

assemblages. These species were selected based on research concerning their habitat preferences (California 

Wildlife Habitat Relationship system and Birds of North America online), the range of the species, and the 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit H-23

availability of good quality data on the Forest. These three factors had to be met for the Forest area in order 

for a species to be selected.

A project-level Management Indicator Assemblage (MIA) Report was completed and is incorporated by 

reference (Jordan, 2015e). Information relevant to the decision to be made is summarized here. The projectlevel analysis reviews the Forest Plan requirements for monitoring management indicators and analyzes 

project effects on management indicator assemblages for a representative species of each assemblage affected. 

The analysis addressed Alternative 1 in detail, which is the modified proposed action and preferred 

alternative, as it affects the most assemblage habitat.

The project-level report determined that Alternative 1 (and all action alternatives considered in detail) would 

affect five assemblage habitats: openings and early seral, late seral, snag and down log, hardwood, and 

riparian (defined in Table 1 of the MIA Report). The Nashville warbler was analyzed as a representative 

species of the openings and early seral assemblage because it is found in all of the openings and early seral 

assemblage CWHR types and is strongly associated with specific habitat components that define the 

assemblage. The brown creeper was analyzed as a representative species of the late seral assemblage because 

it is found in all of the late seral assemblage CWHR types and is strongly associated with specific habitat 

components that define the assemblage. The red-breasted nuthatch was analyzed as a representative species of 

the snag and down log assemblage because it is strongly associated with specific habitat components that

define the assemblage (i.e., snags). The white-breasted nuthatch was analyzed as a representative species of 

the hardwood assemblage because it is strongly associated with specific habitat components that define the 

assemblage. The yellow warbler was analyzed as a representative species of the riparian assemblage because 

it is strongly associated with specific habitat components that define the assemblage. All of these species 

occur in the project area147and additional population data of high reliability are available for these species, 

which is tracked and compiled at the Forest level.148

The other three wildlife management indicator assemblages would not be affected by the project because it 

either does not occur within project units or the project contains measures to not treat elements of the 

assemblage (chaparral; cliffs, caves, talus, and rock outcrops) or there would be no effect to the proportion of 

assemblage habitats available (multi-habitat). There are no aquatic management indicator assemblages or 

species (MIS) that would be affected by the project, as there is no suitable habitat and the project area is 

outside the Forest’s fish MIS range (Forest Plan, 1995 p. 3.11). 

While treatments would result in changes to five management indicator assemblage habitats by reducing 

canopy closure and cover, tree densities and snag/down log density (notably in the Extensive Mortality Area

and Hazard Reduction Zones on approximately 166 acres), treated areas would continue to provide the same 

quantity and distribution of each assemblage type after the project is completed. Hardwood quantity and 

quality (approximately 78 acres of California black oak and aspen) and riparian vegetation within the riparian 

assemblage component along Ash Creek (approximately 30 acres) are currently found intermixed within the 

late seral and openings and early seral assemblages. While the quality of these assemblages would be 

increased over the short-term, the quantity would not change. Even with the short-term reduction in snag and 

down log assemblage, and slight increase in hardwood and riparian quality, the project is not likely to result in 

147 Point count surveys for migratory and resident bird species were conducted in the project area in 2013 and 2014. These surveys

will be continued in 2016 and after implementation. 

148 The Forest compiles Breeding Bird Survey data (BBS) for the representative species, and reports them at the regional 

(BBS strata), California, and range-wide scales. Four BBS strata occur on the Forest. BBS data have varying degrees of 

reliability based upon sample size. Representative species selected for Forest level tracking have data with the highest 

reliability in at least one of the four strata that occur on the Forest.
Elk Flat LSR Enhancement Project

H-24 Shasta-Trinity National Forest

any meaningful change to population trends or habitat availability for the red-breasted nuthatch or whitebreasted nuthatch at the project or Forest scale.

As described in the existing condition section of Chapter 1, and the MIA report, the 3,519-acre project area 

contains abundant snag and down log assemblage habitat due to overstocking, ongoing root disease and insect 

outbreaks. Reducing the current snag and down log assemblage on 166 acres in the short-term is considered 

discountable when compared to the existing snag and down log assemblage habitat within the project area that 

would not be treated. The short-term reduction of this habitat in the specific areas of the project will also not 

limit the availability of the snag and down log assemblage in the project area for the red-breasted nuthatch. 

Over the short- and long-term, additional snags are expected to remain and develop in this area and will 

remain on the landscape until they fall, contributing to the down log assemblage. Over the short-term, habitat 

suitability is expected to increase for the white-breasted nuthatch and yellow warbler as the thinning, release 

and riparian vegetation planting treatments increase the quality and quantity of hardwood components of 

black oak and aspen, and riparian assemblage habitat along Ash Creek. 

The affected assemblages will not be modified such that there is an immediate shift to another assemblage 

(e.g., late seral will not be treated such that it becomes openings and early seral post-treatment, snag and 

down log assemblage will not be wholly eliminated, and while hardwood and riparian assemblages will 

increase, they will not replace another assemblage). As there will be no conversion from one assemblage to 

another, there are no cumulative effects. Even if potential indirect effects are realized, they are not expected to 

meaningfully influence project-level habitat trends for the assemblages. Considering the best available 

population data and Forest-level habitat trends, as well as ongoing habitat influences from wildfire and private 

timber harvest, the project is not likely to result in any meaningful change to population trends or habitat 

availability for the Nashville warbler, brown creeper, red-breasted nuthatch, white-breasted nuthatch, or 

yellow warbler at the Forest-wide scale (Jordan 2015e).

Survey and Manage (S&M) 

Guidance under the Northwest Forest Plan and Forest Plan require the Forest Service to analyze projects for 

potential impacts to Survey and Manage species. Survey and Manage requirements were originally 

established to address little-known species believed to be associated with old-growth and late-successional 

forest microsite habitats, and for which species experts were unsure that the Late-Successional Reserve (LSR) 

network would be sufficient to provide for the conservation of the species. 

All project activities are compliant with direction regarding the Survey and Manage standards and guidelines 

issued by Regional Foresters’ Connaughton and Moore (Connaughton, et al., 2014). This direction was issued 

pursuant the district court’s remedy order issued on February 18, 2014 (Conservation Northwest v. Bonnie, 

W.WA No. C08-1067-and other Mitigation Measure Standards and Guidelines (USDA-FS & USDI-BLM, 

2001) [or 2001 ROD]. 

Certain project activities are exempt from the May 13, 2014 direction, as stipulated by Judge Pechman 

(Pechman, 2006). These include activities that: (a) thin stands younger than 80 years old; (b) replace culverts 

on roads that are in use and part of the road system, or remove culverts if the road is temporary or to be 

decommissioned; (c) riparian and stream improvements where the riparian work is riparian planting, 

obtaining material for placing in-stream, and road or trail decommissioning, and where the stream 

improvement work is the placement large wood, channel and floodplain reconstruction, or removal of channel 

diversions; and (d) the portions of a project involving hazardous fuel treatments where prescribed fire is 

applied. Any portion of a hazardous fuel treatment project involving commercial logging will remain subject 

to the survey and management requirements except for thinning of stands younger than 80 years old under 

subparagraph (a) above.
Draft Environmental Impact Statement

Shasta-McCloud Management Unit H-25

Survey and Manage Fauna

A Survey and Manage Report for terrestrial wildlife and aquatic species was completed for the project and is 

incorporated by reference (Jordan, 2015d). Information relevant to the decision to be made is summarized 

here. The project area falls outside the range, or contains no suitable habitat for, all Survey and Manage fauna 

species listed on the 2003 Annual Species Review list except for the Shasta hesperian, Chace sideband snail 

and great gray owl (Burke, et al., 1999; Duncan, 2005; Quintana-Coyer, et al., 2004). 

Based on extensive protocol surveys for terrestrial and aquatic mollusks (Furnish, et al., 1997; Duncan, et al., 

2003) conducted on 33,000 acres between 1999 and 2010 on the Management Unit, the Shasta hesperian was 

only found within riparian habitat and the chace sideband snail was only observed within the Shasta and Little 

Shasta River Drainages (Crumpton, et al., 2011). Surveys completed in the Elk Flat LSR Enhancement 

Project area for these two species between 2007 and 2010 did not detect either species and there are no known 

sites in the project area.

The project area lacks perennial streams and the preferred riparian vegetation for the Shasta hesperian, though 

the intermittent channel of Ash Creek may provide some level of potential suitable habitat. There will be 

treatments in Riparian Reserves under all action alternatives. The project includes design features and 

protection measures that limit disturbance to potential habitat and maintain microsite habitat conditions for 

this species (e.g., riparian canopy cover and large coarse wood will be maintained, water quality BMPs, 

limited disturbance to riparian areas/riparian vegetation during thinning and burning operations, and 

equipment exclusion within 20 or more feet of Ash Creek). This is consistent with the species management 

recommendations (Burke, et al., 1999). 

The project area contains potential suitable habitat for the Chace sideband of dry conifer and mixed conifer 

with oak. There are limited talus piles and outcrops within Elk Flat that may provide refugia. The project 

includes protection measures that either prohibit equipment use on talus slopes or maintain microsite habitat 

conditions such as large coarse wood and uncompacted forest litter. This is consistent with the species 

management recommendations (Duncan, 2005). 

Pre-disturbance surveys are not required for the great gray owl (GGO) in the California Cascades (QuintanaCoyer, et al., 2004) and no project-level surveys have been completed. There have been no aural or visual 

detections of this species in the project area during the 14 years of active survey efforts between 1990-2015 

for the northern spotted owl or other fieldwork done for the project. There are no verifiable observations 

recorded in or near the project area ( (NRIS, 2014; CDFW, 2015). While transient GGOs may utilize the Elk 

Flat area for foraging or potential nesting, on average, deep snows likely limit use and access to prey. The 

project includes provisions for nest site protections in the event of a new discovery and this is consistent with 

management recommendations for this species.

Within the project area, there are no known sites of any Survey and Manage wildlife species on the 2003 

Annual Species Review list. The project design and resource protection measures include management 

guidelines for the two terrestrial mollusks with suitable habitat, and the project contains measures for any new 

discoveries of great gray owl. These measures are consistent with the May 13, 2014 direction and these 

species’ management recommendations. 

Survey and Manage Vascular Plants, Bryophytes, Lichens and Fungi

A Supplemental Botany Report was completed for project (Posey, 2015) and is incorporated by reference.

Surveys were completed for S&M bryophytes including Ptilidium californicum (Pacific fuzzwort), a Category 

A bryophyte. There are seven known tree sites for Pacific fuzzwort in units 150, 157 and 159. Pacific 

fuzzwort sites will be buffered to protect them from underburning. RPMs in place for maintaining and 

improving wildlife habitat, protecting soils and maintaining or improving hydrological function will also help 

to maintain and improve habitat for survey and manage fungi species.
Elk Flat LSR Enhancement Project

H-26 Shasta-Trinity National Forest

Predisturbance Surveys for Category B fungi are not required because old growth stands will not be affected 

by this project. Random grid S&M fungi surveys were done in the NW Forest Plan national forests, including 

the Shasta-Trinity, in 2001 and 2002. Fungi known site revisits were completed for permanent plots in the 

California NWFP area from 2005-2010. Additional purposive surveys for Category B S&M fungi were done 

in the California Cascades physiographic province, which includes the Shasta-McCloud Management Unit, 

from 2011-2013 (Hoover, et al., 2015). 

There is one known site for Mycena overholtsii, a Category B fungi in unit 150 and one site for Cantharellus 

subalbidus (white chanterelle), a Category D fungi, in unit 165. The site in unit 150 is protected from all 

activities including underburning and the site in unit 165 is within an unthinned patch and will have a cool, 

light underburn. Individual legacy old growth trees and large woody debris will be retained. 

Should new S&M bryophyte, fungi, lichen or vascular plant species be found before or during project 

implementation, protection measures will be put into place to protect the species and its habitat. Generally,

this will involve the “flag and avoid” approach. If monitoring after burning shows damage to a Pacific 

fuzzwort population, the buffer distance for other populations will increase depending on the type and extent 

of the damage. 

Vegetation Diversity

The Forest Plan (p. 4.14) directs provision for and maintenance of at least five percent of each timber/type

seral stage combination shown in the Forest Plan on Table 4-3. The Forest Plan also has special direction for 

Matrix Lands for fifth field watersheds in which federal forest lands are currently comprised of 15 percent or 

less of late-successional forest (p. 4.63). The Elk project area is located within the Ash Creek 5th-order 

watersheds. The Silviculture Report (Payne, 2015b) provides a vegetation diversity analysis. Information 

relevant to this decision is summarized here.

Seral Stage Diversity

As Table Appendix I-2 illustrates, there is less than five percent vegetation in seral stage: 1 - grass/forb, 4a - 

Large tree, less than 40 percent canopy closure, and 4c – large tree, older, greater than 40 percent canopy 

closure. Silviculture treatments in the project will not appreciably change the current seral distribution in the 

Ash Creek watershed under any action alternatives. Thinning will shift some stands from seral stage 4b to 4a 

for approximately one to two decades until residual tree canopies reoccupy thinning space. Treatments will 

promote stand resiliency and accelerate development of larger overstory trees, promoting the development of 

4c/older stands over time.

Table Appendix I-2. Seral Stage Diversity

Seral Stage Watershed Acres % of Watershed

Nonforested (rock etc.) 3,136 4%

1 Grass & forbes with or without shrubs and seedlings 2,297 3%

2 Shrub/seedling/sapling mixed or pure stands up to 20 feet in 

height 11,525 15%

3a Medium tree, <40% canopy closure 10,983 14%

3b, 3c Medium tree, >40% canopy closure 35,542 42%

4a Large tree , <40% canopy closure 777 1%

4b, 4c Large tree, >40% canopy closure 16,848 21%

4c - older Large tree, >40% canopy closure 97 0%

Total 79,205 100%
Draft Environmental Impact Statement

Shasta-McCloud Management Unit H-27

Acreages and percentages reflect all Shasta-Trinity National Forest Land within the Ash Creek watershed. Other ownerships in the 

watershed (including 8,207 acres on the Klamath National Forest) are not reflected.

Silviculture treatments in the Elk LSR Enhancement project will not appreciably change the current seral 

distribution in the Ash Creek watershed. Thinning will shift some stands from seral stage 4b to 4a for 

approximately one to two decades until residual tree canopies reoccupy thinning space. Treatments will 

promote stand resiliency and accelerate development of larger overstory trees, promoting the development of 

4c/older stands over time.

Thinning from below would not change the vegetation type in Alternatives 1 through 3. The majority of 

dominant and co-dominate trees would be retained and average tree diameter would increase with the removal 

of smaller diameter trees from the understory. Thinning treatments would reduce canopy cover sufficient to 

warrant a change in the density classification for some stands. 

Radial thinning around large predominant pine would reduce canopy cover in small areas and create more 

variable density within treatment units, but would not change stand seral class. 

Oak release treatment in Alternatives 1 through 3 would occur in seral stage 4b. Given the limited removal to 

overstory conifer and retention of predominant and some dominant conifers within the oak release radius, the 

successional or seral stage classification would not be changed. 

Aspen release would occur on approximately 18 acres in seral stage 4a stand in Alternatives 1 through 3. 

Removal of most conifers within the aspen release would reduce canopy cover in the short term but not 

change the seral stage or vegetation type. 

Recent pine mortality from insects and disease in the project area in all age classes is reverting areas up to 

several acres in size to a seral stage 1. Most mortality is occurring in seral stage 4b stands. Larger mortality 

pockets (generally 5 acres or larger) and group selections in Alternatives 1 through 3 would be reforested. 

Because they are few, scattered and small (2 acres or less), group selections do not cause a change in seral 

stage at the stand level. Reforestation would occur on approximately 228 acres in Alternatives 1 and 2, and on 

219 acres in Alternative 3. 

Table Appendix B-1 summarizes the effects to seral stages as a result of treatments in Alternative 1 (the 

Alternative with the most amount of treatments) as identified in the seral stage analysis of existing conditions. 

Table Appendix I-3. Summary of Silviculture Treatments and Effects to Seral Stage

Treatment Change to Seral Stage

Natural Stand Thinning -1526 acres (density reduction, stand resilience, 

accelerate development of late successional characteristics) Approx. 47 acres of 3a/b change to 4a/b 

Plantation Thinning – 664 acres (density reduction, stand resilience, 

accelerate development of late successional characteristics) No change

Radial Thin (embedded in natural stand thinning and plantation thinning) – 

197 acres No change

Group Selection (embedded in natural stand thinning and plantation 

thinning) – 75 acres

A portion to seral stage 2, no change at 

the stand level

Oak and Aspen Release (embedded in natural stand thinning and plantation 

thinning) – 48 acres estimated

Localized canopy cover reduction, no 

change at the stand level

Meadow Enhancement (remove conifer encroachment) – 379 acres No change
Elk Flat LSR Enhancement Project

H-28 Shasta-Trinity National Forest

Watershed Level Late Successional Forest

This section provides an assessment of the current condition of late-successional forest on Shasta-Trinity 

National Forest land within the Ash Creek watersheds.

There are 5,555 acres (7%) of National Forest land within the watershed that have been identified as not 

capable of supporting late-successional forest (see table A4). These areas are mostly occupied by lava flows 

and rocky areas that support few to none scattered conifers. Meadows and sagebrush vegetation are included 

in this category.

There are 73,650 acres (93%) of Shasta-Trinity National Forest land within the watershed that have been 

identified as capable of supporting late-successional forest (see table A4). Of this acreage of capable land, a 

total of 41,959 acres (57%) are currently occupied by forest types that meet the criteria of late-successional 

forest.

For purposes of this assessment, the determination of late-successional forest follows definitions used in the 

FEMAT report149. Late-successional forest status was assigned into two subsets by correlating CalVeg forest 

typing with the following descriptions and criteria:

• Mature forest – those forest stands generally greater than 80 years of age but not meeting the old-growth

definition. For this assessment, all current 3N and 3G stands not planted after 1940 as well as 4N and 4G

stands were classified as mature forest.

• Old-growth forest – Forest stands 5N and 5G (overstory tree class 40). Large overstory diameter and

high canopy cover correlated to old-growth characteristics including: large trees, multi-layered canopies,

decadence, large snags and down logs.

Table Appendix I-4 summarizes the categorization of the watershed into capable and non-capable lands in 

terms of ability to support late-successional forest. The table further separates late-successional forest into 

mature and old-growth forest subsets. 

Table Appendix I-4. Summary of the Capability of NFS Lands in the Ash Creek Watershed

Land Capability for Supporting Late-Successional Forest Acres Percent of 

Watershed

Percent of 

Capable Land

Total Shasta-Trinity National Forest land in Ash Creek Watershed 79,205 100%

Lands not capable of supporting late-successional forest (Barren 

lava, scattered trees on lava, powerline, dry meadows, etc.) 5,555 7%

Lands capable of supporting late-successional forest. 73,650 93% 100%

Not currently occupied by late-successional forest Includes grass, 

brush, size class 1 and 2, density class S and P, knobcone pine, 

lodgepole pine. Also includes all stands planted after 1940 (these 

are assumed to be less than 80 years old today).

31,691 40% 43%

Currently occupied by mature late-successional forest. Includes all 

current 3N, 3G, and 4N, 4G stands. Generally 80 - 150 years old 41,862 53% 57%

149 U.S. Department of Agriculture, Forest Service; U.S. Department of the Interior, Fish and Wildlife Service; U.S. 

Department of Commerce, National Oceanic and Atmospheric Administration, National Marine Fisheries Service; [and 

others]. 1993. Forest ecosystem management: an ecological, economic, and social assessment, report of the Forest 

Ecosystem Management Assessment Team [generally called the FEMAT report]. Portland, OR: U.S. Department of 

Agriculture, Forest Service and U.S. Department of the Interior, Bureau of Land Management. page 12 . 
Draft Environmental Impact Statement

Shasta-McCloud Management Unit H-29

Land Capability for Supporting Late-Successional Forest Acres Percent of 

Watershed

Percent of 

Capable Land

Currently occupied by older late-successional forest All 5N, 5G, 6N, 

and 6G stands. Generally, greater than150 years old however, ages 

not field verified.

97 0% 0%

Mature Forest

Mature late-successional forest occurs on 41,862 acres or 53 percent of Shasta-Trinity National Forest land 

within the watershed. This represents 57 percent of all lands capable of supporting late-successional forest.

Left unmanaged and in light of roughly 100 years of active fire suppression, mature late-successional forest 

conditions within the watershed tend to develop dense, overstocked forest conditions. Under these conditions, 

trees grow increasingly stressed for resources and high fuel loads develop making forests increasingly 

susceptible to catastrophic events such as wildfire and insect attack. Present day active timber management is 

used to reduce stand densities to healthy, more sustainable levels and to reduce fuel loads. As a result, most 

forest stands classified as mature late-successional forest have had some form of timber harvest in the past.

Old-Growth Forest

Old-growth forests are estimated to occur on 97 acres or less than 0.2 percent of Shasta-Trinity National 

Forest land within the watershed. Field surveys within the project area indicated that some mature stands 

contain isolated elements of older late-successional forest (for example, few scattered “remnant” trees over 

150 years old) and it’s inferred there may be some older successional components in other mature stands in 

the watershed however these stands do not meet overall criteria as old-growth. 

Most existing old-growth late-successional forest in the watershed occurs on rough or steep terrain that was 

difficult to access or harvest in the past. Due to the lack of past management activities, existing old-growth 

forest stands are typically overstocked with dense understory vegetation and heavy fuel loads. These stands 

are susceptible to catastrophic events such as wildfire, insect attack and disease.

Compliance

Thinning in dense mid and late successional natural stands would reduce canopy cover and increase average 

stand diameters at the project level. While there is a minor component of distinct older trees with old-growth 

characteristics within some treatment stands, overstory trees are generally between 60 – 120 years old with 

most trees being less than 100 years old. Canopy reduction from thinning would shift approximately 400 

acres of stands currently typed as a density 4N to 4P for the near term. Many of these stands are near the 

division between density class 4N and 4P; thinning would drop the density to 4P in these stands for 

approximately 10 to 20 years until residual tree canopies expand. 

Treatments would increase the percent of mature (and old growth) late-successional forest faster over the long 

term by promoting the growth of large diameter overstory trees within a mosaic of variable density and 

structural diversity. Additionally, treatments would increase stand resiliency to natural disturbances, 

increasing the likelihood that residual overstory trees would persist and develop into late successional stands. 

Thinning treatments would retain all of the predominant trees as well as the majority of the dominant trees.

While trees would be retained in all size classes to retain and promote structural diversity, removal would be 

focused on suppressed and intermediate trees as well as codominant trees adjacent and subsidiary to retained 

overstory trees. Thinning would increase average stand diameters but not change the age classes on the 

landscape. 
Elk Flat LSR Enhancement Project

H-30 Shasta-Trinity National Forest

Overall, for Alternatives 1 through 3 the percent of capable land occupied by forest types that meet the criteria 

of late-successional forest will remain at approximately 53 percent in the Ash Creek watershed.

Visual Quality Objectives

The Forest Plan provides standards and guidelines for the visual (scenery) resource utilizing the Visual 

Management System (VMS) to reduce impacts to visual resources (scenery) caused by management activities. 

Visual Quality Objectives (VQO’s) were established for areas seen from travel routes and management areas 

indicate allowable changes to scenery resulting from management activities.

A Scenery Analysis Report (Joyce, 2014) was prepared for the project and is incorporated by reference. The 

proposed silviculture treatments and fuel activities were analyzed as seen from Pilgrim Creek Road [Forest 

Road 13 (41N13)] and Forest Road 19 (41N19). The routes are not sensitive for scenery per the Forest Plan, 

but both routes may be socially sensitive since they are used by winter recreationists and visitors accessing 

some of the Mt. Shasta trailheads. The VQO indicator for Pilgrim Creek Road is “Modification” and the VQO 

indicator for Forest Road 19 is “Modification to Maximum Modification.” To reduce visual impacts of the 

proposed project in the foreground views of Pilgrim Creek Road due to the high number of people who use 

the route, a RPM will be implemented:

The following design features are prescribed within a 150-foot visual corridor adjacent to Pilgrim Creek 

Road. This visual corridor would apply to units 16-115, 106, 107, 123, 125, 157, 159, 180, 162, 176, 179, 

347, and 401.

• Use existing landings and locate new landings out of view as seen from the roads where feasible.

• Stump height will be 6 inches or less (if a landscape feature obstructs the view between the road and

the cut trees, stump height maybe higher).

• Cut and/or leave trees will be marked on the sides facing away from the roads. Prior to treatment,

further measures such as flagging of individual leave trees may be implemented to assure operators

can clearly identify leave trees.

• The goal within the visual corridor is to have a clean look by removing the majority of the slash and

woody debris with the least amount of ground disturbance. This may be accomplished by: lopping

and scattering if there are not large amounts of residual slash, as generally occurs with whole treeyarding; hand piling and burning excess slash and scattering the burn pile residue that is not fully

consumed and/or machine piling the slash outside of the visual corridor.

The proposed treatments for Alternatives 1, 2 and 3 are very similar from a scenery perspective; differences

are comparatively negligible. All action alternatives would be consistent with the Forest Plan VQO map.
Draft Environmental Impact Statement

Index

Alternative 1, Modified Proposed Action, i, 

v, xiii, xvii, 44, 45, 46, 57, 63, 68, 69, 74, 

75, 80, 94, 96, 97, 98, 100, 101, 104, 105, 

109, 110, 111, 112, 114, 117, 118, 121, 128, 

152, 168, 201, 206, 217, 231, 234, 279, D-2, 

E-5, E-15, G-1

Alternatives

Alternative 4, 57, 132, 133, 144, 223, H-14

Animals

American Marten, 189, A-25, A-31, B-10, H21

California Red-legged Frog, E-6

Great Gray Owl, 272, H-25

Northern Goshawk, xii, 20, 28, 34, 87, 88, 92, 

107, 108, 109, 158, 159, 161, 162, 163, 164, 

167, 169, 171, 172, 173, 174, 175, 180, 181, 

182, 183, 184, 185, 189, 270, A-2, A-4, B10, B-17, B-21, B-22, B-29, B-37, B-38, B-41, 

B-42, B-43, B-44, H-9, H-19, H-20, H-21, H-22

Northern Spotted Owl, i, iv, xiii, xiv, xvi, 1, 7, 

8, 9, 11, 20, 22, 28, 34, 39, 44, 45, 46, 48, 49, 

50, 57, 70, 73, 74, 75, 77, 79, 80, 87, 88, 89, 

90, 92, 94, 96, 97, 98, 100, 101, 104, 105, 

106, 107, 109, 110, 111, 112, 113, 114, 117, 

140, 155, 158, 159, 160, 161, 162, 163, 164, 

165, 166, 167, 168, 169, 170, 171, 172, 173, 

174, 175, 176, 177, 178, 179, 180, 181, 182, 

183, 184, 185, 186, 189, 193, 205, 222, 223, 

233, 234, 250, 258, 260, 261, 265, 266, 268, 

270, 271, 274, 276, 280, A-2, A-3, A-27, A31, B-4, B-10, B-11, B-12, B-13, B-14, B17, B-18, B-19, B-21, B-22, B-24, B-26, B-28, 

B-36, B-37, B-38, B-39, B-40, B-41, B-43, B-44, 

B-45, B-47, E-6, E-7, E-8, E-10, E-12, E-13, E14, E-15, E-16, E-17, E-19, E-20, E-21, E-22, 

E-23, E-24, E-26, H-16, H-18

Pacific Fisher, iv, 20, 28, 34, 48, 50, 88, 89, 

92, 108, 109, 158, 159, 161, 162, 163, 164, 

167, 168, 169, 171, 172, 173, 174, 175, 180, 

181, 182, 183, 184, 185, 189, 276, A-2, A-3, 

A-25, A-27, A-31, B-10, B-17, B-21, B-22, B37, B-38, B-41, B-43, E-6, E-8, E-15, E-19, E21, E-24, E-25, E-26, H-6, H-19, H-20, H-21, 

H-22

Aquatic Conservation Strategy, xvi, 1, 6, 7, 

34, 35, 98, 99, 100, 119, 194, 195, 203, 204, 

205, 206, 207, 257, 274, 280, B-34, B-35, B36, B-47, E-8, E-10, E-19, H-13

Ash Creek, v, viii, ix, 4, 33, 34, 35, 36, 37, 

82, 83, 84, 88, 90, 96, 98, 99, 100, 123, 149, 

166, 167, 196, 197, 198, 199, 200, 201, 202, 

203, 204, 205, 206, 213, 281, A-3, A-39, A40, B-22, B-34, B-35, B-38, B-44, E-10, E-17, 

E-19, E-21, F-1, F-2, H-14, H-20, H-23, H-24, 

H-25, H-26, H-27, H-28, H-30

Basal area, 175 

Best Management Practices, iii, 39, 52, 56, 

81, 83, 93, 115, 118, 120, 122, 193, 194, 

201, 204, 209, 216, 219, 228, 239, 248, 249, 

279, A-35, A-37, A-40, B-7, B-25, B-26, B31, B-33, C-1, C-2, C-3, C-4, C-5, H-11, H-14, H16, H-25

California Air Resources Board, 263, 264, 

280, H-1, H-3, H-4, H-5

California Wildlife Habitat Relationships, 

iii, 3, 4, 20, 126, 264, A-1, B-11, H-23

Critical Aquatic Refuges, 257, E-11

Cumulative Effects, ii, v, vi, 123, 135, 140, 

144, 153, 154, 155, 157, 180, 183, 184, 186, 

203, 205, 221, 222, 223, 233, 238, 239, 247, 

248, 268, 280, B-28, B-30, F-1, F-2, F-8, F-1

Cumulative Watershed Effects, 274, 276 

Elk Flat, i, ii, iii, iv, v, vii, viii, ix, x, xi, xii, 

xiii, xiv, xv, xvi, xvii, 1, 3, 4, 7, 8, 9, 10, 11, 

13, 14, 20, 21, 25, 27, 28, 29, 30, 31, 32, 33, 

34, 36, 37, 38, 40, 41, 42, 44, 46, 49, 53, 54, 

83, 90, 97, 98, 100, 104, 112, 117, 118, 119, 

120, 124, 125,127, 136, 140, 149, 150, 151, 

161, 165, 166, 167, 171, 176, 179, 185, 186, 

187, 188, 189, 190, 191, 192, 193, 195, 197, 

201, 204, 207, 211, 215, 216, 217, 226, 231, 

235, 237, 238, 244, 248, 249, 268, 273, A28, A-35, A-39, A-41, B-2, B-10, B-12, B13, B-16, B-19, B-22, B-23, B-24, B-25, B-32, 

B-35, B-37, B-38, B-39, B-40, B-42, B-44, B-46, 

C-4, E-6, E-9, E-10, E-11, E-14, E-18, F-4, G-1, 

G-2, H-13, H-16, H-17, H-19, H-21, H-22, H-25

Environmental Justice, 114, 242, 244, 264, 

271, 280, H-7

Equivalent Road Acres, iv, 100, 105, 194, 

196, 197, 200, 202, 203, 204, 205, 206, 207, 

274, 276, B-33
Elk Flat LSR Enhancement Project

32

Extensive Mortality Area, 53, 61, 62, 68, 74, 

79, 80, 88, 230, A-38, A-39, G-2, H-23

Forest Transportation System, i, iv, ix, xi, 

xiii, xvi, 10, 37, 38, 39, 42, 45, 55, 62, 63, 

64, 69, 75, 80, 100, 101, 121, 122, 197, 208, 

217, 221, 225, 226, 227, 228, 229, 230, 231, 

232, 233, 234, 235, 240, 244, 246, 247, 248, 

259, 262, A-43, A-44, B-32, G-2

Hardwood, 173 

Hydrologic Unit Code 7, 259 

INFRA Database, 226 

Late Successional Reserve Assessment, 

iii, vii, viii, x, xv, 1, 4, 6, 7, 9, 10, 11, 13, 

17, 18, 20, 24, 27, 28, 30, 32, 39, 89, 94, 96, 

125, 131, 133, 136, 142, 157, 179, 210, 260, 

269, A-1, A-30, B-2, B-3, B-4, B-11, B13, B-18, B-19, B-20, B-22, B-23, B-24, B-25, B29, B-37, B-40, B-43, B-47, E-9, E-10, E-14, E19, G-1, H-17, H-18, H-20, H-21, H-22

Management Indicator Species, H-23

Motor Vehicle Use Map, ix, 38, 226, 227, 

228, 231, 244, 246, B-31, B-32, F-5

Naturally Occurring Asbestos, 264, 280, H-5

Northwest Forest Plan, iii, vii, xiii, 1, 6, 7, 

8, 10, 11, 17, 28, 39, 44, 119, 124, 125, 164, 

170, 176, 179, 185, 257, 260, 261, 265, 266, 

267, 268, 271, 272, 280, B-2, B-3, B-11, B13, B-15, B-16, B-17, B-18, B-19, B-20, B-21, 

B-22, B-23, B-24, B-34, B-36, B-37, B-38, B-40, 

B-43, B-44, B-47, E-7, E-8, E-9, E-10, E-13, E21, H-13, H-17, H-18, H-19, H-20, H-21, H-24, 

H-26

Notice of Intent, xii, 43, 57, 117, 260, 275, 

B-1

Proposed Action, i, ii, iii, iv, v, vii, ix, x, xi, 

xiii, xiv, xvii, 38, 39, 43, 44, 45, 46, 47, 57, 

63, 68, 69, 74, 75, 77, 79, 80, 81, 91, 94, 96, 

97, 98, 100, 101, 104, 105, 109, 110, 111, 

112, 114, 117, 118, 120, 121, 128, 152, 168, 

201, 206, 217, 231, 234, 275, 279,280, B-22, 

B-29, B-35, D-2, F-2, F-5, G-1, G-2, G-3

Range of Natural Variability, 194, 206 

Regulations

American Indian Religious Freedom Act, 

239 

Clean Air Act, 280, H-2, H-3

Clean Water Act, 115, H-11

Endangered Species Act, 114, 159, 160, 162, 

163, 180, 181, 182, 187, 193, 254, 260, 279, 

280, B-16, B-28, B-39, B-40, B-42, B-43, E-3, 

E-5, E-6, E-8, E-12, E-15, E-17, H-6, H-9

National Environmental Policy Act, i, vii, xiv, 

1, 37, 44, 76, 117, 123, 160, 163, 164, 181, 

182, 234, 239, 248, 253, 255, 260, 264, 268, 

279, B-1, B-2, B-7, B-9, B-11, B-14, B-17, 

B-27, B-28, B-29, B-31, B-32, B-34, B-35, B-39, 

B-42, B-43, B-44, B-46, C-3, F-1, F-5, H-1, H-2, 

H-5

National Forest Management Act, 1, 93, 115, 

149, 180, 193, 207, 225, 235, 248, 251, 260, 

280, B-31, B-43, B-44, H-1, H-9, H-12

National Historic Preservation Act, 237, 238, 

239, 254, 262 

Safe Drinking Water Act, H-11

Riparian, i, v, vii, xi, xii, xiii, xvi, 4, 6, 7, 10, 

28, 33, 34, 35, 37, 39, 41, 42, 44, 54, 55, 64, 

70, 76, 81, 83, 89, 98, 99, 100, 118, 119, 

124, 158, 161, 166, 180, 188, 193, 194, 195, 

196, 198, 199, 201, 202, 203, 204, 205, 206, 

207, 261, 273, 279, A-1, A-26, A-29, A-36, 

A-39, A-40, B-34, B-35, B-36, B-38, B-44, B46, B-47, C-4, E-8, E-9, E-10, E-11, E-19, G-1, 

G-3, H-13, H-15, H-25

Roadless Area Review and Evaluation, B-16

Shasta-Trinity National Forest Land and 

Resource Management Plan, iii, v, vii, 

viii, xii, xiii, xv, 1, 4, 5, 6, 9, 10, 17, 19, 20, 

23, 24, 28, 30, 32, 33, 34, 38, 39, 43, 44, 45, 

56, 69, 75, 81, 89, 92, 95, 112, 113, 115, 

117, 119, 122, 124, 125, 135, 140, 144, 149, 

150, 153, 154, 155, 157, 179, 180, 193, 194, 

199, 207, 208, 210, 211, 212, 215, 218, 222, 

223, 224, 225, 226, 227, 235, 239, 248, 249, 

251, 257, 258, 260, 261, 262, 265, 266, 267, 

268, 272, 275, 280, A-30, B-1, B-2, B-3, 

B-5, B-9, B-11, B-13, B-15, B-16, B-17, B18, B-19, B-20, B-21, B-22, B-23, B-24, B-25, B-
Draft Environmental Impact Statement

26, B-27, B-30, B-31, B-34, B-36, B-37, B-38, B40, B-41, B-42, B-43, B-47, C-1, C-4, E-8, E-9, 

E-10, E-11, E-12, E-14, E-21, H-1, H-5, H-11, 

H-12, H-13, H-15, H-16, H-17, H-21, H-22, H23, H-24, H-26, H-30

Sierra Pacific Industries, 165, 266, B-1, B3, E-17, E-25

Snags, i, iv, xiii, xvi, 6, 17, 18, 20, 21, 22, 

24, 26, 27, 28, 44, 48, 49, 50, 53, 56, 64, 87, 

88, 89, 96, 101, 107, 118, 119, 120, 124, 

125, 126, 127, 133, 136, 139, 140, 142, 143, 

144, 146, 148, 152, 158, 160, 161, 162, 165, 

166, 167, 172, 173, 174, 175, 176, 178, 179, 

185, 186, 193, 244, 250, 260, 261, 263, 269, 

A-23, A-24, A-25, A-26, A-30, A-31, A32, A-34, A-38, A-39, B-2, B-3, B-9, B12, B-13, B-14, B-17, B-18, B-19, B-20, B-21, 

B-22, B-23, B-24, B-25, B-27, B-36, B-40, B-42, 

B-43, B-44, B-45, B-47, E-9, E-14, E-16, E-19, 

E-21, E-22, E-23, G-3, H-10, H-16, H-18, H-19, 

H-20, H-21, H-22, H-23, H-24, H-28

Soil Quality Standards, 52, 208, 210, 212, 

217, 218, 220, 224, A-37, B-25, B-26

Special Aquatic Features

Aspen Clones, 41, A-27

Marshes, B-33

Vernal Pools, E-6

Wetlands, vii, 7, 35, 194, 195, E-10, H-12, H13, H-14, H-15

Threshold of Concern, 194, 196, 197, 200, 

204, 206, 274 

Transportation Analysis Process, 37, 225, 

226, B-31, B-33

Vegetation Treatments

Clearcutting, 167, 181, 269, B-5, B-20, B-22, B38, B-40

Hazard Tree Removal, 55, 226, A-44

Shelterwood, F-6, F-7

Thinning, i, iv, x, xi, xii, xiii, xiv, xvi, 10, 27, 

39, 40, 41, 42, 47, 48, 49, 50, 51, 53, 54, 55, 

57, 58, 59, 60, 61, 62, 64, 65, 66, 67, 68, 70, 

71, 72, 73, 74, 76, 77, 78, 79, 81, 85, 86, 87, 

88, 89, 91, 98, 99, 100, 103, 106, 107, 108, 

109, 110, 113, 118, 119, 120, 121, 124, 125, 

126, 128, 129, 130, 131, 132, 133, 134, 135, 

136, 137, 138, 139, 140, 141, 142, 143, 145, 

148, 152, 153, 154, 156, 158, 160, 162, 163, 

164, 166, 172, 173, 174, 175, 176, 177, 178, 

179, 181, 182, 183, 184, 188, 191, 201, 202, 

203, 204, 217, 218, 219, 221, 222, 223, 224, 

225, 237, 238, 245, 250, 262, 265, 266, 267, 

271, 277, 279, A-6, A-11, A-12, A-13, A-14, 

A-15, A-16, A-17, A-18, A-20, A-21, A-22, 

A-23, A-24, A-25, A-27, A-28, A-29, A-30, 

A-31, A-32, A-33, A-34, A-35, A-37, A-38, 

A-39, B-5, B-6, B-7, B-8, B-9, B-11, B-12, 

B-13, B-14, B-16, B-17, B-18, B-20, B-22, B23, B-24, B-25, B-26, B-28, B-29, B-32, B-34, 

B-35, B-36, B-37, B-39, B-41, B-42, B-43, B-44, 

B-45, C-3, E-12, E-14, E-16, E-18, E-19, E-20, 

E-21, E-22, E-23, E-24, F-5, F-6, G-1, G-2, H1, H-6, H-10, H-16, H-17, H-18, H-19, H-20, 

H-22, H-24, H-25, H-26, H-27, H-29

Vehicles

Off Highway Vehicle, 228, 244, B-35

Over snow vehicle, xiv, 76, 84, 180, 234, 244, 

247, F-3, F-4, H-4

Visual Quality Objectives, 45, 121, 281, H30

Wildland/Urban Interface, vii, 7, 27, 150, 

257, 262, B-2, B-4, B-5, E-11, E-12

Wildlife Habitat Relationship, 3, 19, 20, 30, 

126, 264, A-1, B-11, H-22