United States Department of Agriculture

Government Camp – Cooper Spur 

Land Exchange

Draft Environmental Impact Statement

Forest Service Mt. Hood National Forest Zigzag and Hood River Ranger Districts

October 2016
In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations 

and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering 

USDA programs are prohibited from discriminating based on race, color, national origin, religion, sex, gender 

identity (including gender expression), sexual orientation, disability, age, marital status, family/parental status, 

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

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

Remedies and complaint filing deadlines vary by program or incident. 

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

Braille, large print, audiotape, American Sign Language, etc.) should contact the responsible Agency or 

USDA’s TARGET Center at (202) 720-2600 (voice and TTY) or contact USDA through the Federal Relay 

Service at (800) 877-8339. Additionally, program information may be made available in languages other than 

English. 

To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, 

AD-3027, found online at http://www.ascr.usda.gov/complaint_filing_cust.html and at any USDA office or 

write a letter addressed to USDA and provide in the letter all of the information requested in the form. To 

request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to USDA by: 

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

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

USDA is an equal opportunity provider, employer and lender.
Draft Environmental Impact Statement

Government Camp – Cooper Spur Land Exchange

Draft Environmental Impact Statement

Clackamas and Hood River Counties, Oregon

Lead Agency: USDA Forest Service

Responsible Official: Lisa Northrop 

Forest Supervisor

16400 Champion Way

Sandy, OR 97055

For Information Contact: Michelle Lombardo 

Environmental Coordinator

16400 Champion Way

Sandy, OR 97055

mlombardo@fs.fed.us; 503-668-1796

Abstract: The Forest Service is preparing an Environmental Impact Statement (EIS) to evaluate 

the environmental effects of exchanging approximately 109 acres of National Forest System 

(NFS) lands on the Zigzag Ranger District within the Mt. Hood National Forest for 

approximately 769 acres of private lands in Hood River County (Land Exchange), pursuant to 

congressional direction and subject to several legislative conditions, and consistent with its other 

legal duties and responsibilities. Among other things, the current legislative conditions prescribe 

the reservation of a wetland conservation and trail easements on the Federal parcels to be 

exchanged. 

The overall purpose of the proposed action is to comply with congressional direction and 

conditions prescribed in Section 1206(a) and related provisions of the Omnibus Public Land 

Management Act of March 30, 2009 (Act) (123 Stat. 991, P.L. 111-11). The Act also sets forth 

two related actions that are triggered into effect upon completion of the Land Exchange, namely 

the creation of a Crystal Springs Watershed Special Resources Management Unit (approximately 

2,859 acres) on the non-Federal parcels, as well as existing NFS lands, and a change in 

designation of approximately 1,709 acres of NFS lands to wilderness, the effects of both of which 

are encompassed within the scope of this EIS as connected actions. The analysis in the EIS also 

accounts for potential revisions to the legislative direction applicable to the Land Exchange 

contained in the proposed Mount Hood Cooper Spur Land Exchange Clarification Act (H.R. 3826 

and Sec. 10006 of S. 2012), which, as of the date of publication of this document, has not been 

enacted. As such, there is an underlying need to exchange lands between the Mt. Hood National 

Forest and Mt. Hood Meadows Oregon, LLC, consistent with specific congressional direction and 

the agency’s other legal duties and responsibilities, and subject to particular conditions to the 

implementation and execution of the Land Exchange, whatever their final form may ultimately 

be.

This EIS describes the proposed action, a no-action alternative, and two additional alternatives 

that were considered but not developed or analyzed in detail. While no significant issues that 

drive alternatives were identified, the EIS discloses the potential effects of achieving the purpose 

and need objectives on the following resources or in the following categories of effects: foresttype composition; heritage resources; tribal treaty rights; hydrology; wetlands; water rights; soil 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

ii

productivity; threatened, endangered, and sensitive (TES) species (aquatics, wildlife, and plants); 

non-native invasive species; recreation; visuals; facilities; and socio-economics.

It is important that reviewers provide their comments at designated time periods and in a way that 

is useful to the Agency’s preparation of the EIS. Therefore, comments need to be provided prior 

to the close of the comment period and specific written comments should be within the scope of 

the proposed action, have a direct relationship to the proposed action, and must include 

supporting reasons for the Responsible Official to consider (36 CFR 218.2). The submission of 

timely and specific comments can affect whether and the extent to which a reviewer is able to 

participate in subsequent administrative review or judicial review of the proposed action if and 

when it is adopted. Comments received in response to this solicitation, including names and 

addresses of those who comment, will be part of the public record and may be released per 

request made under the Freedom of Information Act. Comments submitted anonymously will be 

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

standing to participate in subsequent administrative or judicial reviews.

Send comments electronically to: comments-pacificnorthwestmthood@fs.fed.us

Paper or faxed comments to: Michelle Lombardo 

Environmental Coordinator

16400 Champion Way

Sandy, OR 97055

(Fax: 503-668-1423)
Draft Environmental Impact Statement

Summary

Mt Hood National Forest

iii

Summary

Pursuant to congressional direction and subject to certain legislative conditions, the Mt. Hood National 

Forest is proceeding to implement, insofar as it is within its control and authority, the conveyance of 

approximately 1091 acres of National Forest System (NFS) lands on the Zigzag Ranger District in 

exchange for approximately 769 acres of private lands in Hood River County. Among other things, the 

current legislative conditions attached to the Land Exchange prescribe the reservation of a wetland 

conservation and trail easements on the Federal parcels to be exchanged. The Act also sets forth two 

related actions that are triggered into effect upon completion of the Land Exchange, namely the creation 

of the Crystal Springs Watershed Special Resources Management Unit (approximately 2,859 acres) and a 

change in designation of approximately 1,709 acres of NFS lands to wilderness, the effects of both of 

which are encompassed within the scope of this EIS as connected actions. 

The two NFS parcels to be exchanged are timbered, mostly undeveloped, and are physically separated by 

40 acres that are already in private ownership. The NFS parcels are located on the gentle southwest facing 

slope of Mt. Hood at the north end of the village of Government Camp in Clackamas County. Elevations 

range from about 3,760 to 4,120 feet. The Federal parcels have been withdrawn from mineral entry 

through the Bureau of Land Management's segregation process. 

The non-Federal lands that need to be offered in a formal, legally binding manner under the Act in order 

for the Forest Service to convey the NFS lands described above include approximately 251 acres located 

within, and 514 acres located outside, of the current NFS administrative boundary in Hood River County. 

The non-Federal estate is comprised of three diverse property types situated in the vicinity of the Cooper 

Spur Ski Area on the northeast flank of Mt. Hood. The three types are: the structures and personal 

property at the Cooper Ski Area; land and all development at the Cooper Spur Mountain Resort; and 

mostly vacant forest land.

As referenced above, the Forest Service is moving forward with this proposed action to comply with the 

congressional direction and conditions prescribed in the Omnibus Public Land Management Act of March 

30, 2009 (123 Stat. 991, P.L. 111-11), as potentially modified by the proposed Mount Hood Cooper Spur 

Land Exchange Clarification Act2

. As such, there is an underlying need to exchange lands between the 

Mt. Hood National Forest and Mt. Hood Meadows Oregon, LLC, consistent with specific congressional 

direction and the agency’s other legal duties and responsibilities, and subject to particular conditions to 

the implementation and execution of the Land Exchange, whatever their final form may eventually take.

In order to comply with congressional direction, the proposed action also includes a programmatic 

amendment to the Mt. Hood National Forest Land and Resource Management Plan (1990) in order to 

assign management direction to the land the Forest Service would acquire pursuant to a finally executed 

Land Exchange; change the land allocations for the wilderness designation; and create the Crystal Springs 

Watershed Special Resources Management Unit.

The general public was first notified of the proposal in 2010. Notices of Intent to develop an 

Environmental Impact Statement were published in the Federal Register in October 2010, and again in 

 1 For consistency in the analysis, the numbers used throughout this EIS were generated using spatial data (i.e., Geographical 

Information Systems). The land description verification (LDV) forms, which were calculated using legal descriptions, are 

approximately 108 acres for the Government Camp parcels and 764 for the Cooper Spur parcels. Please note that all final acre 

values will be determined by a licensed surveyor at a future date. 

2 Although the proposed Clarification Act has passed both the U.S. Senate and House of Representatives in separate forms, as of 

the date of publication of this EIS, it has not been enacted into law, and thus, whether the Forest Service ends up following the 

proposed legislative amendments it contains depends upon whether and when it ultimately may be.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

iv

February 2016. Through the feedback the Forest Service has received during the scoping process, it has 

determined that the public is primarily interested in the following issues related to the proposed action:

the land equalization process; the type of public interest analysis and determination in which the Forest 

Service intends to engage given that the Land Exchange is congressionally prescribed; future use of the 

trails within the lands to be conveyed; development of the Crystal Springs Watershed Special Resources 

Management Unit; addition to the Mt. Hood Wilderness; the ability of the Forest Service to care for the 

facilities currently on the non-Federal lands that would be acquired; the tram corridor between Timberline 

and Government Camp; and effects on wildlife, wetlands, treaty rights, cultural resources, and recreation. 

No significant issues were identified during review of the scoping process that led the agency to conclude 

that it needed to develop and analyze in detail wholly separate alternatives to the proposed action, 

especially in light of the fact that the proposed action is congressionally prescribed in considerable detail. 

However, the EIS does address and analyze different variations of the proposed action. In addition, the 

Forest Service considered two alternatives but determined that neither warranted evaluation in detail. 

They include:

Direct Purchase: Internal administrative guidance calls for the Forest Service to consider a directpurchase alternative pursuant to Forest Service Handbook 5409.13, Sec. 33.41a, which states, “Land 

exchange evaluations shall consider a purchase alternative in the National Environmental Policy Act 

(NEPA) analysis and document the non-Federal party’s position on the United States’ direct purchase of 

the proposed exchange parcels documented in the administrative record.” Under this alternative, no lands 

would be exchanged; rather 769 acres of non-Federal land would be purchased from the non-Federal 

party by the United States. The non-Federal lands included in the proposed action subject to analysis in 

this EIS, however, cannot be acquired through direct purchase because the landowner is not a willing 

seller; funds are not available for purchase; and exchange is the prescribed mode of acquisition in the Act. 

Deed Restrictions: Consideration of a deed restriction alternative is also ordinarily to be undertaken 

pursuant to guidance in Forest Service Handbook 5409.13, Sec. 33.41a. The purpose of a deed restriction 

is to limit use or development of the Federal lands after conveyance as a means of addressing an 

environmental concern. Deed restrictions controlling future use and development of Federal lands 

conveyed into non-Federal ownership should be used only when required by law, regulation, or executive 

order, or when the intended use of the conveyed Federal land would substantially conflict with established 

management objectives on adjacent Federal lands (FSH 5409.13, Sec. 33.41c). The applicable 

congressional direction pursuant to which the Forest Service is evaluating the proposed action already 

includes provisions regarding the reservation of conservation and trail easements, and thus, appropriate 

restrictions to address environmental and recreational concerns are already included in the proposed 

action as it has been defined and prescribed by the Congress.

As referenced above, because the Forest Service is proceeding with the proposed action in response to 

congressional direction, it necessarily is substantially informed and constrained by applicable legislation, 

in particular the Act prescribing that the agency pursue the Land Exchange and setting forth the 

parameters within which it is to be carried out and certain preconditions that must be satisfied in so doing.

Thus, the Responsible Official will decide whether all of the congressionally imposed conditions in the 

Act have been satisfied, whether to require any further terms and conditions under the authority of the 

Act, and whether the proposed action is consistent with all of the other legal duties and management 

direction that apply to it. In this light, if the Responsible Official finds that all of the congressionallymandated and any other requisite conditions that she believes are necessary have been satisfied, and that it 

is consistent with its other legal duties and responsibilities as well, the Forest Service will execute the 

Land Exchange.
Draft Environmental Impact Statement

Summary

Mt Hood National Forest

v

Additionally, the Responsible Official will decide whether or not to amend the Forest Plan as described in 

the proposed action, or make adjustments based on input that emerges as a result of public comment.

Document Organization

In compliance with the National Environmental Policy Act (NEPA), this environmental impact statement 

addresses the direct, indirect, and cumulative environmental impacts that may result from implementation 

of the proposed action under several variations and a no-action alternative.

The information contained in this document will allow the Forest Supervisor to make an informed 

decision about how best to meet the stated purpose of and need for action. The decision will be 

documented in a record of decision when the environmental review process is completed.

Chapter 1: This chapter provides an overview of the legal and administrative parameters applicable to the 

proposed action, and the analysis of effects contained in this EIS, including the purpose of and need for 

the action on which the analysis focuses. It also documents the public-involvement process the Forest has 

used to assist it in identifying issues, concerns, and opportunities associated with the proposed action.

Chapter 2: This chapter describes the alternatives considered for meeting the project purpose and need. It 

includes a description of alternatives considered but not evaluated in detail, and a comparison of 

alternatives to aid in decision-making.

Chapter 3: This chapter describes the environmental effects of implementing the proposed action and 

other alternatives. The no action alternative provides a baseline for evaluation and comparison of the 

other alternatives that follow.

Chapter 4: This chapter provides a list of persons and agencies contacted during the development of this 

environmental impact statement. Resources are also included in this chapter.

Chapter 5: References

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

the project planning record that is located at the Forest Supervisor’s Office in Sandy, Oregon.

Draft Environmental Impact Statement

Contents

Mt Hood National Forest

vii

Contents

Summary.........................................................................................................................................iii

Document Organization...................................................................................................................v

Chapter 1 – Purpose of, Need for, and Decision-making Framework underlying Proposed Action

.......................................................................................................................................................13

Introduction ...............................................................................................................................13

Background................................................................................................................................13

Purpose of and Need for Action ................................................................................................20

Proposed Action ........................................................................................................................21

Decision Framework..................................................................................................................30

Public Involvement....................................................................................................................30

Tribal Consultation....................................................................................................................31

Issues .........................................................................................................................................32

Chapter 2 – Alternatives, Including the Proposed Action .............................................................37

Introduction ...............................................................................................................................37

Alternatives Considered in Detail..............................................................................................37

Alternatives Considered but Eliminated from Detailed Study ..................................................57

Chapter 3 – Affected Environment and Environmental Consequences.........................................61

Introduction ...............................................................................................................................61

Botany........................................................................................................................................68

Climate Change .........................................................................................................................86

Cultural Resources and Treaty Rights.......................................................................................87

Facilities ....................................................................................................................................95

Fisheries...................................................................................................................................101

Hydrology and Water Rights...................................................................................................148

Recreation................................................................................................................................226

Silviculture ..............................................................................................................................243

Socioeconomics.......................................................................................................................251

Soils, Wetlands and Water Rights...........................................................................................271

Visuals.....................................................................................................................................283

Wildlife....................................................................................................................................301

Short-term Uses and Long-term Productivity..........................................................................360

Unavoidable Adverse Effects..................................................................................................360

Irreversible and Irretrievable Commitments of Resources......................................................362

Other Required Disclosures.....................................................................................................362

Incomplete or Unavailable Information...................................................................................364

Chapter 4 – Preparers and Contributors.......................................................................................365

Consultation and Coordination................................................................................................365

Preparers and Contributors......................................................................................................367

Distribution List for DEIS .......................................................................................................369

Chapter 5 – References................................................................................................................371

Botany......................................................................................................................................371

Climate Change .......................................................................................................................373

Cultural Resources and Treaty Rights.....................................................................................373

Facilities ..................................................................................................................................374

Fisheries...................................................................................................................................374

Hydrology and Water Rights...................................................................................................377

Recreation................................................................................................................................382

Silviculture ..............................................................................................................................382
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

viii

Socioeconomics.......................................................................................................................383

Soils and Wetlands..................................................................................................................385

Visuals.....................................................................................................................................385

Wildlife....................................................................................................................................386

List of Tables

Table 1. Parcel name, county tax lot number, acres and legal descriptions of Federal and nonFederal parcels considered in the Government Camp – Cooper Spur Land Exchange. All 

areas and distances are approximate. .....................................................................................18

Table 2. Acreage of each existing land use allocation that would become A2-Wilderness...........56

Table 3. Acreage of each existing land use allocation that would become A14-Crystal Springs 

Watershed Special Resources Management Unit ..................................................................56

Table 4. Proposed action summary................................................................................................56

Table 5. Past, present, and reasonably foreseeable actions considered for cumulative effects......66

Table 6. Number of Region 6 Sensitive botanical species with potential habitat in the land 

exchange parcels....................................................................................................................76

Table 7. Biological evaluation process summary by species (Region 6 Sensitive Species)..........81

Table 8. Estimated cost for accessibility upgrades........................................................................98

Table 9. Corrective action for life and safety.................................................................................99

Table 10. Presence of ESA-listed fish, designated critical habitat, and essential fish habitat within 

the analysis area of the Government Camp-Cooper Spur Land Exchange ..........................105

Table 11. Presence of Region 6 Regional Forester’s special status sensitive and strategic species 

within the action area ...........................................................................................................112

Table 12. A comparison of salmonid management indicator species occupied habitat within the 

Mt. Hood National Forest (total) and the occupied habitat within the action area ..............117

Table 13. Resource indicators and measures for the existing condition that may be affected by the 

land exchange.......................................................................................................................124

Table 14. Change in effect to habitat indicators for alternative 1 (no action)..............................128

Table 15. Change in effect to habitat indicators for alternative 2 (proposed action)...................134

Table 16. Summary of past, present, and reasonably foreseeable future actions which may 

contribute to cumulative effects to aquatic fauna and habitat for all alternatives................135

Table 17. The Government Camp-Cooper Spur Land Exchange Project effects determination 

summary for ESA-listed species, designated critical habitat, and Region 6 Regional 

Forester’s sensitive species present in the action area .........................................................145

Table 18. The Government Camp-Cooper Spur Land Exchange Project effects determination 

summary for ESA-listed species, designated critical habitat, and Region 6 Regional 

Forester’s sensitive species present in the action area .........................................................146

Table 19. Change in effect to habitat indicators which compares both alternatives to the existing 

condition in the Government Camp and Cooper Spur areas................................................147

Table 20. Data from the Mud Ridge SNOTEL Site from 1979 through 2004.............................150

Table 21. Modeled data for the Red Hill SNOTEL site...............................................................152

Table 22. Resource indicators and measures for the existing condition Government Camp Parcels

.............................................................................................................................................153

Table 23. Resource indicators and measures for the existing condition Cooper Spur parcels.....154

Table 24. Predicted peak streamflows for the 2-year 24-hour precipitation event ......................160

Table 25. Current level of hydrologic recovery 7th field watersheds..........................................163

Table 26. Percent increase in the length of the stream channel due to roads ..............................165

Table 27. Hydrologic impact area by 7th field watershed ...........................................................166

Table 28. Water rights summary..................................................................................................167
Draft Environmental Impact Statement

Contents

Mt Hood National Forest

ix

Table 29. Water rights for Camp Creek in the Government Camp area......................................168

Table 30. Water availability in Camp Creek report.....................................................................169

Table 31. Water rights Crystal Springs 7th field watershed ........................................................169

Table 32. Water Quality Status -Oregon's 2012 Integrated Report Assessment Database and 

303(d) List – Streams in Status Categories 4 or 5................................................................171

Table 33. Highest 7-Day average maximum stream temperatures in the analysis area (degrees 

Celsius) ................................................................................................................................174

Table 34. Landslide risk percentages by sub-watershed..............................................................179

Table 35. Natural background levels of sediment yield from mass wasting ...............................179

Table 36. Estimated sediment yield from the existing road system.............................................182

Table 37. Average annual sediment discharge from outlet associated with land use ..................183

Table 38. In-channel fine sediment levels in surveyed streams...................................................185

Table 39. Matrix of pathways and indicators to evaluate properly functioning condition from 

NMFS 1996..........................................................................................................................186

Table 40. Resource indicators and measures for the no-action alternative Government Camp 

Parcels..................................................................................................................................190

Table 41. Resource indicators and measures for the no-action alternative Cooper Spur Parcels 191

Table 42. Predicted peak streamflows for the 2-year 24-hour precipitation event ......................193

Table 43. Hydrologic recovery proposed action .........................................................................194

Table 44. Percent increase in the length of the stream channel due to roads...............................195

Table 45. Water rights summary..................................................................................................196

Table 46. Width of primary shade zone (feet) based on slope (percent) and tree height (average 

height of stand in feet). Widths are measured by slope distance. ........................................199

Table 47. Estimated sediment yield from the existing road system.............................................201

Table 48. Estimated changes in sediment yield from roads associated with the proposed action201

Table 49. Average annual sediment discharge from outlet associated with land use ..................202

Table 50. Estimated changes in sediment yield from land use associated with the proposed action

.............................................................................................................................................202

Table 51. Sediment yield .............................................................................................................203

Table 52. Comparison of background sediment yield to sediment yield associated with the 

proposed action ....................................................................................................................204

Table 53. In-channel fine sediment levels in surveyed streams...................................................206

Table 54. Resource indicators and measures for the proposed alternative Government Camp 

Parcels..................................................................................................................................207

Table 55. Resource indicators and measures for the proposed action alternative Cooper Spur 

Parcels..................................................................................................................................208

Table 56. Resource indicators and measures for the proposed alternative Government Camp 

Parcels..................................................................................................................................210

Table 57. Predicted peak streamflow for the 2-year 24-hour precipitation event with and without 

wetland conservation easements..........................................................................................212

Table 58. Percent change in the predicted Peak Streamflow for the 2-year 24-hour precipitation 

event with and without wetland conservation easements ....................................................212

Table 59. Average annual sediment discharge from outlet with and without wetland conservation 

easements.............................................................................................................................213

Table 60. Percent change in average annual sediment discharge from outlet with and without 

wetland conservation easements..........................................................................................213

Table 61. Cumulative Effects Summary for Hydrology ..............................................................216

Table 62. Hydrologic recovery proposed action..........................................................................222

Table 63. Sediment yield (estimated tons per year).....................................................................224

Table 64. Cooper Spur parcels in Crystal Springs DWPA ..........................................................225

Table 65. Trails with segments inside Government Camp parcels..............................................230
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

x

Table 66. Cooper Spur area trails.................................................................................................232

Table 67. Existing condition ROS classes for Government Camp parcels..................................236

Table 68. Existing condition ROS classes for Cooper Spur Area................................................237

Table 69. Direct effects to trail locations by proposed action......................................................237

Table 70. Comparison of acres of ROS class gained and lost .....................................................240

Table 71. Resource indicators and measures for the existing condition Government Camp Lands

.............................................................................................................................................246

Table 72. Resource indicators and measures for the existing condition Cooper Spur lands .......248

Table 73. Resource indicators and measures for assessing effects..............................................249

Table 74. Resource indicators and measures for alternative 1.....................................................249

Table 75. Resource indicators and measures for alternative 2 direct and indirect effects...........250

Table 76. Summary comparison of environmental effects to silvicultural resource....................250

Table 77. Population, population change, and population density ..............................................252

Table 78. Forest Service county payments, fiscal year 2015.......................................................256

Table 79. Payments in-lieu of taxes, 2015...................................................................................256

Table 80. Estimated repair totals for Cooper Spur Ski Area and Resort facility deficiencies, by 

timeframe required (in 2015 dollars) ...................................................................................258

Table 81. Race and ethnicity (%).................................................................................................259

Table 82. Percentage of people with Income below poverty level ..............................................260

Table 83. Permit fees required to cover estimated repair costs over 5 years and 10 years..........266

Table 84. Resource indicators and measures for alternative 2 direct and indirect effects...........268

Table 85. Summary comparison of environmental effects to social and economic resources.....270

Table 86. Summary of water rights in the Government Camp Parcels (OWRD 2016)...............275

Table 87. Summary of water rights in the Cooper Spur Parcels (OWRD 2016).........................275

Table 88. Comparison of functional capacity units (FCUs) for wetlands in the exchange parcels 

(WPN 2010).........................................................................................................................279

Table 89. Existing conditions: VQOs of Government Camp area...............................................287

Table 90. VQOs in acres for the Government Camp parcels existing condition.........................287

Table 91. Trails within Government Camp parcels.....................................................................287

Table 92. Designated viewshed in the Cooper Spur area.............................................................289

Table 93. VQOs for proposed Cooper Spur parcels ....................................................................290

Table 94. Existing condition: VQOs in the Cooper Spur area.....................................................290

Table 95. Existing conditions: VQOs of Government Camp area...............................................292

Table 96. Existing condition: VQOs in the Cooper Spur area.....................................................292

Table 97. Trails within Government Camp parcels that would cease to have VQOs..................297

Table 98. Changes in CSWSRMU VQOs between alternatives..................................................298

Table 99. Changes in proposed wilderness addition VQOs between alternatives.......................298

Table 100. Trails with VQOs affected by the proposed wilderness addition ..............................299

Table 101. Comparison of acres of VQOs gained and lost..........................................................300

Table 102. Threatened, endangered, and proposed wildlife species applicable to the project ....303

Table 103. Habitat structure within Government Camp parcels..................................................305

Table 104. Habitat structure within Cooper Spur parcels............................................................307

Table 105. Northern spotted owl suitable habitat within 1.2 mile radius of known owl sites within 

1.2 miles of Cooper Spur parcels.........................................................................................307

Table 106. Northern spotted owl suitable habitat within 0.5 mile radius of known owl sites within 

1.2 miles of Cooper Spur parcels.........................................................................................309

Table 107. Minimum disturbance and disruption distances for activities affecting northern spotted 

owls during the breeding season (USDI Fish and Wildlife Service 2016) ..........................312

Table 108. Fringed myotis habitat features within parcels..........................................................327

Table 109. Townsend’s big-eared bat habitat features within parcels.........................................329

Table 110. Management indicator species and their primary habitats.........................................339
Draft Environmental Impact Statement

Contents

Mt Hood National Forest

xi

Table 111. American marten conservation status........................................................................340

Table 112. Pileated woodpecker conservation status...................................................................343

Table 113. Snag density capabilities, Government Camp Parcels, montane conifer habitat type346

Table 114. Snag density capabilities, Cooper Spur Parcels, eastside mixed conifer habitat type346

Table 115. Snag total capabilities, Government Camp Parcels, montane conifer habitat type ...347

Table 116. Snag total capabilities, Cooper Spur Parcels, eastside mixed conifer habitat type....347

Table 117. Existing acres of deer and elk habitats.......................................................................350

Table 118. Landbird focal species and habitats (Altman 1999, 2000).........................................352

Table 119. Survey and manage species within Oregon Western Cascades Geographic Area 

(December 2003 species list; May 2014 Direction).............................................................354

Table 120. Summary of impacts to wildlife addressed in this analysis.......................................359

List of Figures

Figure 1. Overview map of the Government Camp – Cooper Spur Land Exchange.....................15

Figure 2. Government Camp parcels.............................................................................................16

Figure 3. Cooper Spur parcels .......................................................................................................17

Figure 4. Government Camp tax lots.............................................................................................18

Figure 5. Cooper Spur tax lots.......................................................................................................19

Figure 6. Existing LUAs for Government Camp...........................................................................23

Figure 7. Existing LUAs for Cooper Spur.....................................................................................24

Figure 8. Agreed-upon wetland conservation easements per the Omnibus Act ............................40

Figure 9. Wetland boundaries delineated using Terra Science’s GIS dataset................................42

Figure 10. Trail easements on Government Camp parcels............................................................43

Figure 11. Proposed Cooper Spur Ski Area and Cooper Spur Mountain Resort permit boundary 

area.........................................................................................................................................45

Figure 12. Mt. Hood Wilderness addition......................................................................................48

Figure 13. Proposed Crystal Springs Watershed Special Resources Management Unit ...............50

Figure 14. Clackamas County zoning districts and buffers for the parcels to be conveyed ..........62

Figure 15. Map of action area in the Hood River and Sandy River Basins.................................103

Figure 16. Map of Lower Columbia River steelhead and designated critical habitat in the 

Government Camp action area.............................................................................................107

Figure 17. Map of resident trout and Lower Columbia River steelhead, coho, and Chinook 

designated critical habitat in the Cooper Spur action area...................................................108

Figure 18. Map of Lower Columbia River Chinook salmon and designated critical habitat in the 

Government Camp action area.............................................................................................109

Figure 19. Map of Lower Columbia River coho salmon and designated critical habitat in the 

Government Camp action area.............................................................................................111

Figure 20. Government Camp parcels and associated 7th field watersheds................................149

Figure 21. Cooper Spur parcels and associated 7th field watersheds..........................................151

Figure 22. Overall upslope/riparian condition is based on the combination of 5 process indicators, 

which were in turn derived from a number of finer grained metrics (Miller et al. 2015)....156

Figure 23. Wildcat5 modeled watersheds....................................................................................161

Figure 24. Change in peak flow associated with harvest activities (Grant et al. 2008)...............163

Figure 25. Map from application to appropriate the public waters of the State of Oregon (permit 

#8449, certificate #8919) .....................................................................................................168

Figure 26. Water rights permit application #34196 .....................................................................170

Figure 27. Zigzag Canyon 6th field watershed mean August Stream Temperature (2002-2011)175

Figure 28. Historical composite scenario representing 9 year average August mean stream 

temperatures for 2002 – 2011 ..............................................................................................176
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

xii

Figure 29. Zigzag Canyon 6th field watershed NorWest stream temperatures adjusted to estimate 

daily maximum for 2002 through 2011 ...............................................................................177

Figure 30. Fractional sediment delivery curve used in NetMap’s GRAIP tool (NetMap Tools 

Technical Help Guide).........................................................................................................181

Figure 31. GeoWEPP modeled catchments.................................................................................184

Figure 32. Government Camp conveyance eastern parcel stream network created from overflow 

of 100,000 gallon water tank (OR DSL 2007).....................................................................197

Figure 33. Overflow outlet of 100,000-gallon water tank ...........................................................198

Figure 34. Crystal Springs drinking water source area (DWSA).................................................225

Figure 35. Typical moist mixed conifer area in Government Camp............................................244

Figure 36. Typical lodgepole pine area in Government Camp ....................................................245

Figure 37. Plantation less than 25 years old.................................................................................247

Figure 38. Overstocked plantation over 25 years old ..................................................................247

Figure 39. Typical dense stand with ladder fuels in Cooper Spur ...............................................247

Figure 40. Aerial oblique view of Government Camp West Parcel (looking north) ...................285

Figure 41. Aerial oblique view of Government Camp East Parcel (looking north).....................286

Figure 42. Aerial oblique view of Cooper Spur parcels (looking north) .....................................288

Figure 43. Existing residential development in the Government Camp area (looking northwest)

.............................................................................................................................................293

Figure 44. Existing housing stock in the Government Camp area...............................................294

Figure 45. Existing building height in the Government Camp area.............................................294

Figure 46. Existing lot with forest vegetation in the Government Camp area.............................295

Figure 47. Existing streetscape in the Government Camp area ...................................................295

Figure 48. Government Camp parcels schematic viewsheds.......................................................296

Figure 49. Cooper Spur parcels schematic viewshed map...........................................................299

Figure 50. Known owl sites and habitat within and near Government Camp parcels.................306

Figure 51. Known owl site home ranges and core areas within 0.5 mile of Cooper Spur parcels

.............................................................................................................................................308

Figure 52. Potential Crater Lake tightcoil habitat, Government Camp east parcel (photo source: 

Watershed Professionals Network LCC 2010)....................................................................336

Figure 53. Elk trends, Hood and Santiam Game Management Units (source: ODFW 2016) .....349

Figure 54. Mule deer trends, Hood Game Management Unit (source: ODFW 2016).................350
Draft Environmental Impact Statement

Chapter1 – Purpose of, Need for, and Decision-making Framework

Mt Hood National Forest

13

Chapter 1 – Purpose of, Need for, and Decisionmaking Framework underlying Proposed 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 and indirect environmental 

impacts that would result from different variations of the proposed action and a no-action 

alternative, as well as the cumulative impacts resulting from those of the Proposed Action when 

added to any with which they would combine that arise from other past, present, and reasonably 

foreseeable future actions. The analysis in this EIS also tiers to the 1990 Final Impact Statement 

for the Mt. Hood National Forest Land and Resource Management Plan.

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

found in the project planning record located at the Mt. Hood National Forest Supervisor’s Office 

in Sandy, Oregon.

Background

In 2005, the Board of Commissioners of Hood River County; the Hood River Valley Residents 

Committee; Mt. Hood Meadows Oregon Limited Partnership, Mt. Hood Meadows Development 

Corp., Meadows North, LLC, Meadows Utilities, LLC, and North Face Inn (collectively “Mt. 

Hood Meadows”) signed an agreement wherein they would propose a land exchange to the 

Forest Service. The exchange would consist of the conveyance of 120 acres of land near 

Government Camp from the Forest Service to Mt. Hood Meadows, and the Forest Service’s 

acquisition of 770 acres of privately owned land in the vicinity of Cooper Spur. The parties to the 

agreement stated that they hoped this proposal would resolve public concern about development 

and water quality on the north side of Mt. Hood. The agreement also included a proposal to 

designate land near the Cooper Spur and Tilly Jane area as wilderness, to place protections on 

Forest Service land in the Crystal Springs Watershed, and to convey all private interests in the 

Cooper Spur Ski Area to the Forest Service.

The Congress eventually directed the Forest Service to pursue effectuation of a Land Exchange, 

certain to certain explicit conditions and criteria, in the Omnibus Public Land Management Act 

of March 30, 2009 (123 Stat. 991, P.L. 111-11). The Omnibus Act prescribes the land exchange 

so long as the Forest ensures a series of conditions and legal requirements are satisfied prior to 

its execution. More specifically, the Omnibus Act directs the Forest Service to convey National 

Forest System (NFS) lands in Government Camp to Mt. Hood Meadows, if Mt. Hood Meadows 

offers to convey to the United States certain specified private lands at Cooper Spur, and any 

buildings, furniture, fixtures, and equipment at the Cooper Spur Mountain Resort and the Cooper 

Spur Ski Area (Section 1206(a)), subject to several mandatory conditions and compliance with 

all of the agency's legal obligations applicable to implementing such an exchange. For example, 

the Omnibus Act requires that the exchange be carried out subject to Section 206 of the Federal 

Land Policy and Management Act (FLPMA), except as otherwise provided in the Omnibus Act; 

the Forest Service discusses its interpretation of these and related provisions of these applicable 

statutory provisions it has been tasked with following below, the upshot of which is that, even 

though the Congress has provided a considerable amount of detail concerning the process and 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

14

substance of the Land Exchange, the agency nevertheless retains a reasonable level of discretion 

on the crafting of ultimate details regarding its implementation, including with respect to the 

final mix of lands to be exchanged, depending in part on the outcome of the appraisal being 

conducted in support of the exchange. 

The Federal lands to be conveyed as part of the proposed action are located on the Zigzag 

Ranger District, and the private lands to be acquired are in Hood River County. The Federal land 

proposed for conveyance is located to the north of Government Camp Loop Road in Government 

Camp, Oregon, in T3S, R8E, Sections 13 and 24, and T3S, R8.5E, Section 14 in Clackamas 

County. The land owned by Mt. Hood Meadows that is proposed for acquisition is located 

approximately one-half mile to the west of Highway 35 in the vicinity of Cooper Spur Ski Area 

in T2S, R10E, Sections 6 and 7, T1S, R10E, Sections 30 and 31, and T1S, R9E, Section 36 in 

Hood River County. Maps of the proposed land exchange are found in figure 1, figure 2, and 

figure 3. Also, a list of specific parcels is displayed in table 1, as well as depicted in figure 4 and 

figure 5. 
Draft Environmental Impact Statement

Chapter1 – Purpose of, Need for, and Decision-making Framework

Mt Hood National Forest

15

Figure 1. Overview map of the Government Camp – Cooper Spur Land Exchange
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

16

Figure 2. Government Camp parcels
Draft Environmental Impact Statement

Chapter1 – Purpose of, Need for, and Decision-making Framework

Mt Hood National Forest

17

Figure 3. Cooper Spur parcels
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

18

Table 1. Parcel name, county tax lot number, acres and legal descriptions of Federal and nonFederal parcels considered in the Government Camp – Cooper Spur Land Exchange. All areas and 

distances are approximate.

Parcel Name County Tax Lot Number Acres Legal Description

West Parcel

(P-1) Federal Land

38E00130 67 GLO 7 & 8-13-3S8E

South Loop Road Parcel

(P-2) Federal Land

38E24AB00200 0.5 Pt. Sec. 24-3S8E

East Parcel

(P-3) Federal Land

38Q 00130 41 SE 1⁄4 SE 1⁄4 - Sec. 14-3S8 

1⁄2 E

Tract 1*

Non-Federal Land

01S09E00104 91 Pt. Sec. 36-1S9E

Tracts 2 & 3*

Non-Federal Land

01S10E3100501

01S10E3100100

474 Pt. Sec. 31-1S10E

Tracts 4 & 6*

Non-Federal Land

02S10E0600102 116 Pt. Sec. 6 & 7-2S10E

Tract 5

Non-Federal Land

02S10E0600103 3 Pt. Sec. 6-2S10E

Track 7

Non-Federal Land

02S10E0600100 39 Pt. Sec. 6-2S10E

Track 8

Non-Federal Land

01S10E3001500 38 Pt. Sec. 30-1S10E

*Tract 1 + Tax Lot 01S10E3100501 = 1 Legal Tax Lot.

*Tracts 2 + 3 = 1 Legal Tax Lot.

*Tracts 4 + 6 = 1 Legal Tax Lot.

Figure 4. Government Camp tax lots
Draft Environmental Impact Statement

Chapter1 – Purpose of, Need for, and Decision-making Framework

Mt Hood National Forest

19

Figure 5. Cooper Spur tax lots
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

20

Purpose of and Need for Action

The overall purpose of this project is to comply with the congressional direction and conditions 

in the Omnibus Public Land Management Act of March 30, 2009 (123 Stat. 991, P.L. 111-11) 

and any potential amendments that may eventually be enacted to that Act. As such, there is an 

underlying need to move forward with the exchange of lands between the Mt. Hood National 

Forest and Mt. Hood Meadows Oregon, LLC, consistent with specific congressional direction 

and the agency’s other legal duties and responsibilities, and subject to particular conditions to the 

implementation and execution of the Land Exchange, whatever their final form may ultimately 

take. 

In addition to the need to convey NFS lands in exchange for private lands, there is also the need 

to account for the direction in the Omnibus Act that triggers the congressional designation of 

approximately 1,709 acres of existing NFS lands to wilderness upon completion of the exchange. 

Further, the Omnibus Act directs that, upon completion of the exchange, the Crystal Springs 

Watershed Special Resources Management Unit would be created, which encompasses existing 

NFS lands as well as the acquired lands totaling approximately 2,859 acres.

The Mt. Hood National Forest Land and Resource Management Plan (Forest Plan) (1990), as 

amended, guides all natural resource management activities and establishes management 

standards and guidelines for the Forest. It describes resource management practices, levels of 

resource protection and management, and the availability and suitability of lands for resource 

management. The Forest Plan also includes goals, objectives and desired future conditions for 

each of the management areas on the Forest. Also, the Forest Plan sets forth priorities for the 

disposal and acquisition of NFS lands within the Forest, and in so doing places an emphasis on 

optimizing land ownership patterns. The Forest Plan does not specifically address the nonFederal acres to be acquired, but typically, per Forest Service regulations, acquired lands take on 

the land use allocation (LUA) of the NFS lands adjacent to them. As stated in 36 CFR 254.3(f), 

“Lands acquired by exchange that are located within areas having an administrative designation 

established through the land management planning process shall automatically become part of 

the area within which they are located, without further action by the Forest Service.” 

In this case, the adjacent lands are B2-Scenic Viewshed. The goal for these lands is to provide 

attractive, visually appealing forest scenery with a wide variety of natural appearing landscape 

features; and, to utilize vegetation management activities to create and maintain a long term 

desired landscape character (Forest Plan, page 4-218). The type of management prescribed by 

Congress in the Omnibus Act, however, is different from the management direction associated 

with B2 lands. As such, there is a need to programmatically amend the Forest Plan in order to 

assign LUAs and standards and guidelines (i.e., “management direction”) to the newly acquired

land, which would become designated as the Crystal Springs Watershed Special Resources 

Management Unit upon completion of the Land Exchange. There is also a need to amend the 

Forest Plan in order to change the existing management direction for the NFS lands 

(approximately 2,090 acres) that would become part of the Management Unit. Similarly, the 

management direction for NFS lands that would be part of the wilderness addition 

(approximately 1,709 acres) would need to reflect this change in designation. 

Further, there is a need to evaluate the existing special use permit at the Cooper Spur Ski Area3

to address the conversion of approximately 1,012 acres within the existing permit area to 

 3 The underlying land at the Cooper Spur Ski Area is federally owned and administered; and is currently operated by 

Mt. Hood Meadows under a special use permit. In this exchange, the Agency would acquire the infrastructure and 
Draft Environmental Impact Statement

Chapter1 – Purpose of, Need for, and Decision-making Framework

Mt Hood National Forest

21

wilderness that are currently designated A11-Winter Recreation Area. The newly acquired 

Cooper Spur Mountain Resort also needs to be evaluated for the potential development and 

issuance of a new special use permit. 

Proposed Action

In order to comply with the congressional direction related to the Land Exchange, the proposed 

action includes the conveyance of two parcels totaling approximately 1094 acres of NFS lands in 

Clackamas County in exchange for the acquisition of approximately 769 acres of land owned by 

Mt. Hood Meadows Oregon, LLC, in Hood River County.

The proposed action that was shared with the public in February of 2016 has been further 

developed to address the potential effects of possible legislative changes outlined in the proposed 

Mount Hood Cooper Spur Land Exchange Clarification Act, which has passed both the U.S. 

Senate and House of Representatives in separate forms during the current, 114th Congress (see 

S. 2069 and H.R. 3826), but has not been enacted into law. The potential modifications most 

applicable to this analysis involve the direction requiring the Forest Service to reserve wetland 

conservation and trail easements on the NFS lands to be exchanged. More specifically, the bill 

would change the requirement for the Forest Service to reserve a wetland conservation easement 

to an optional condition that may or may not be applied as part of the Land Exchange, per the 

following language in the proposed Clarification Act: “The Secretary and Mt. Hood Meadows 

may mutually agree for the Secretary to reserve a conservation easement to protect the identified 

wetland in accordance with applicable law, subject to the requirements that the conservation 

easement shall be consistent with the terms of the September 30, 2015 mediation between the 

Secretary and Mt. Hood Meadows.” Further, the trail easement that was for exclusive use and 

would be 32 feet in width, as outlined in the Omnibus Act, would change to nonexclusive use 

and have a narrower width of 24 feet were the Clarification Act to pass in its current form. 

The proposed action that was previously shared with the public has also been updated to address 

comments received from the public and interdisciplinary team regarding the designation of the 

Crystal Springs Watershed Special Resources Management Unit. The description of the Forest 

Plan amendment for the creation of the Crystal Springs Watershed Special Resources 

Management Unit has been more clearly developed. The proposed action is summarized below, 

however, more specific details describing the proposed action are provided in Chapter 2-

Alternatives.

Legal, Regulatory, and Administrative Framework

Management Direction

Mt. Hood Land and Resource Management Plan (Forest Plan)

This EIS is tiered to the Final Environmental Impact Statement (FEIS) for the Mt. Hood National 

Forest Land and Resource Management Plan (hereafter referred to as the Forest Plan) (USDA 

 personal property at the ski area. The land and property at the Cooper Spur Mountain Resort is currently owned and 

operated by Mt. Hood Meadows. As part of this exchange, the infrastructure and personal property at the Cooper Spur 

Mountain Resort, as well as the lands, would become property of the Forest Service. 4 As stated in footnote #1 of the Summary section of this document, the numbers used throughout this environmental 

impact statement were generated using spatial data (i.e., Geographical Information Systems). The land description 

verification (LDV) forms, which were calculated using legal descriptions, are approximately 108 acres for the 

Government Camp parcels and 764 for the Cooper Spur parcels. All final acre values will be determined by a licensed 

surveyor. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

22

Forest Service 1990), as amended. The Forest Plan guides all natural resource management 

activities and establishes management standards and guidelines for the Forest. It describes 

resource management practices, levels of resource production and management, and the 

availability and suitability of lands for resource management. Additional management direction 

for the area is also provided in the following Forest Plan amendments:

• The Northwest Forest Plan (NWFP) – Record of Decision for Amendments to Forest 

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

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

Spotted Owl (USDA and USDI 1994); 

• Survey and Manage5 – Record of Decision and Standards and Guidelines for Amendments 

to the Survey and Manage, Protection Buffer, and other Mitigation Measures Standards 

and Guidelines (US Forest Service et al. 2001); and, 

• Invasive Plants – Pacific Northwest Invasive Plant Program Preventing and Managing 

Invasive Plants Record of Decision (US Forest Service 2005); and Site-Specific Invasive 

Plant Treatments for Mt. Hood National Forest and Columbia Gorge Scenic Area in 

Oregon (US Forest Service 2008).

Existing Forest Plan Land Use Allocations for the Government Camp Parcels

The majority of the Government Camp parcels to be conveyed is within the A11-Winter 

Recreation Area land use allocation (figure 6), as described by the Forest Plan on pages 4-190 

through 4-191. The goal for these lands is to provide for high-quality winter recreation (and 

associated summer) opportunities (Forest Plan, page 4-190). This land use allocation provides 

for the development, administration, occupancy, and use of developed recreation sites and 

facilities so long as it is consistent with management area direction (Forest Plan, page 4-192). 

There is one acre within the Government Camp parcels that is within the A4-Special Interest 

Area for the Historic Barlow Road land use allocation, as described by the Forest Plan on pages 

4-151 through 4-156. The goal for these lands is to protect and, where appropriate, foster public 

recreational use and enjoyment of important historic, cultural and natural aspects of our national 

heritage (Forest Plan page 4-151).

The Northwest Forest Plan (NWFP) land use allocations overlap with the land use allocations 

within the Forest Plan. The NWFP land use allocations included in the Government Camp 

parcels are Riparian Reserve and Administratively Withdrawn. Riparian Reserve includes areas 

along rivers, streams, wetlands, ponds, lakes, and unstable or potentially unstable areas where 

the conservation of aquatic and riparian-dependent terrestrial resources receives primary 

emphasis. Administratively Withdrawn allocations are identified areas in existing plans, 

including recreation/visual areas, back country and other areas not scheduled for timber harvest. 

 5 Page 22 of the 2001 Survey and Management Record of Decision states that land exchanges are not themselves 

habitat-disturbing activities and for this reason do not trigger Survey and Manage pre-disturbance surveys. However, 

the land exchange may alter the mix of opportunities for future management of Survey and Manage species and, 

therefore, a discussion and disclosure of currently available information and likely impacts to these species is included 

in chapter 3 of this document.
Draft Environmental Impact Statement

Chapter1 – Purpose of, Need for, and Decision-making Framework

Mt Hood National Forest

23

Figure 6. Existing LUAs for Government Camp

Existing Forest Plan Land Use Allocations for the Wilderness Addition and the Crystal 

Springs Watershed Special Resources Management Unit

The 1,709 acres of NFS lands that would be designated as part of the Mt. Hood Wilderness are 

currently designated in the Forest Plan as A4-Special Interest Area for the Cloud Cap-Tilly Jane 

Historic District (492 acres), A11-Winter Recreation Area (1,109 acres), and B2-Scenic 

Viewshed (108 acres) (figure 7). These acres are also designated as Administratively Withdrawn, 

Riparian Reserves, and Matrix under the Northwest Forest Plan.

The 2,090 acres of NFS lands that would be designated as part of the Crystal Springs Watershed 

Special Resources Management Unit are currently designated in the Forest Plan as A4-Special 

Interest Area for the Cloud Cap-Tilly Jane Historic District (660 acres), A11-Winter Recreation 

Area (236 acres), B2-Scenic Viewshed (1,160 acres), and C1-Timber Emphasis (34 acres). These 

acres are also designated as Administratively Withdrawn, Riparian Reserves, and Matrix under 

the Northwest Forest Plan.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

24

Figure 7. Existing LUAs for Cooper Spur

Best Management Practices

Best management practices (BMPs) are defined as “methods, measures or practices selected by 

an agency to meet its nonpoint source control needs. BMPs include, but are not limited to, 

structural and nonstructural controls, operations, and maintenance procedures. BMPs can be
Draft Environmental Impact Statement

Chapter1 – Purpose of, Need for, and Decision-making Framework

Mt Hood National Forest

25

applied before, during, and after pollution-producing activities to reduce or eliminate the 

introduction of pollutants into receiving waters” (EPA Water Quality Standards, Regulation, 

40 CFR 130.2). Appendix H of the Forest Plan provides management direction on the BMP 

implementation process and format for project specific BMP requirements.

According to the Northwest Forest Plan, BMPs would be incorporated into the implementation 

of the project. BMPs are drawn from General Water Quality Best Management Practices, Pacific 

Northwest Region (November 1988); Draft Environmental Protection Agency Region 10 Source 

Water Protection Best Management Practices for USFS, BLM (April 2005); Mt. Hood National 

Forest Standards and Guidelines, Northwest Forest Plan Standards and Guidelines and The 

National Best Management Practices for Water Quality Management on National Forest System 

Lands - Volume 1: National Core BMP Technical Guide (April 2012) and professional judgment. 

Land exchanges convey land, interests in land, and the resources associated with them. Of itself, 

the specific act of conveyance does not have environmental effects. Therefore, the Forest Service 

Handbook provides direction that states that the NEPA analysis should focus on the future use 

and management of the lands being conveyed (5409.13, Chapter 30, Section 33.14). For this 

reason, the NEPA analysis is largely focused on the potential development of the Government 

Camp parcels. Because no specific development plans have been finalized and/or approved by 

Clackamas County or any other applicable State permitting authorities, the interdisciplinary team 

identified a general list of assumptions about the development and use of the Government Camp 

parcels (see the list of Analysis Assumptions in chapter 3). These assumptions are primarily 

based on zoning regulations required by Clackamas County.

The U.S. Environmental Protection Agency has delegated the implementation of the National 

Pollution Discharge Elimination System (NPDES) program to the state of Oregon. The Oregon 

Department of Environmental Quality (DEQ) administers the NPDES program through Oregon 

Revised Statute (ORS) 468B and associated Oregon Administrative Rules (OAR). ORS 

468B.025 explicitly prohibits the discharge or placement of wastes into waters of the state, 

prohibits the discharge of waste that causes violations of water quality standards, and prohibits 

violations of permit conditions. It is the local jurisdiction’s goal to comply with all conditions of 

the NPDES permit. In addition, erosion and sediment control measures must be installed prior to 

any disturbance. Water Environment Services, which is a department of Clackamas County, is a 

designated local agent for issuing and administering DEQ permits. Once the Government Camp 

parcels have been conveyed to Mt. Hood Meadows, it will be the responsibility of Mt. Hood 

Meadows to ensure its actions implement conservation measures consistent with meeting the

requirements for the Clean Water Act. 

Since the assumptions made for the development of the Government Camp parcels are not sitespecific (i.e., the analysis assumes the amount and type of development, but the specific 

locations are not known), it is infeasible to apply project-specific BMP requirements, as outlined 

in Appendix H of the Forest Plan. Also, once the lands have been conveyed to a private entity, 

the Forest Service will no longer have management authority for these lands. For these reasons, 

the management direction regarding the BMP implementation process included in Appendix H 

of the Forest Plan is not applicable to this land exchange. 

This proposed action does not call for and would not authorize any ground-disturbing activities 

for the lands to be acquired, nor is there any way to know with any degree of certainty or 

specificity just what any such activities in the future might entail; as a result, no effects to water 

quality are projected to result from the mere acquisition of the Cooper Spur parcels, and thus, 

there is no need to include project-specific BMPs. In the future, if any ground-disturbing 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

26

activities are proposed for the acquired lands, then the corresponding NEPA analysis will include 

project-specific BMPs as described in Appendix H of the Forest Plan.

Legal Requirements and Guidance for Exchanges involving 

Federal Land

Numerous acts of Congress provide authority to acquire and dispose of National Forest System 

land or interests in land. For more information regarding the laws, regulations, and Executive 

Orders that apply to the land exchange process for the Forest Service, please refer to Forest 

Service Manual 5400-Landownership, Chapter 5430-Exchanges; Forest Service Handbook 

5409.13-Land Acquisition Handbook, Chapter 30-Land Exchange; and Forest Service Handbook 

5409.12-Appraisal. Also, the regulations governing the exchange of National Forest System land 

are at Title 36, Code of Federal Regulations, part 254, subpart A (36 CFR part 254, subpart A).

Reconciling Direction in the Act with the Federal Land Policy and Management 

Act of 1976

Section 1206(a)(2)(B) of the Act requires that the Land Exchange be carried out subject to 

Section 206 of the Federal Land Policy and Management Act of October 21, 1976 (90 Stat. 2743; 

43 U.S.C. 1715, 1716) (FLPMA), except as otherwise provided in subsection 1206(a) of the Act. 

This exception puts the Forest Service in the position of needing to determine if, and how, there 

are any conflicts or textual tension between the direction in Section 206 of FLPMA and that in 

subsection 1206(a) of the Act. After having carefully considered this issue, the Forest Service 

has identified two ways in which specific direction in subsection 1206(a) of the Act overrides or 

at least substantially dilutes the more general direction in Section 206 of FLPMA.

First, a portion of Section 206(a) of FLPMA, 43 U.S.C. is displaced insofar as it limits the 

authority of the Forest Service to dispose of Federal lands by exchange so situations in which it 

“determines that the public interest will be well served by making [a particular] exchange” 

43 U.S.C. § 1716(a). Here, however, the Congress already has effectively determined that the 

Land Exchange is in the public interest by directing the Forest Service to carry it out, and has 

also specifically delineated the conditions to which it is subject. To make the agency’s “public 

interest” determination outlined in Section 206(a) of FLPMA an additional condition to 

proceeding with the Land Exchange would essentially be to assume that the Congress wanted the 

Forest Service to “second-guess” its legislative judgment that the Land Exchange is a 

worthwhile endeavor that will inure to the benefit of the United States, which the Forest Service 

believes would be an insupportable assumption based on an unreasonable reading of the 

language in the Act. 

At the same time, however, although the Forest Service does not believe the Act would allow it 

to simply decline to execute the Land Exchange were it to make its own independent 

determination that the exchange would not well serve the public interest given the foregoing 

analysis, the Forest Service does believe that it may consider the public interest, as defined in 

Section 206(a) of FLPMA, in determining how to implement the Land Exchange. Indeed, the 

agency believes that in doing so is the best way to harmonize the Act and Section 206(a) of 

FLPMA. Thus, for example, the Forest Service retains a reasonable level of discretion as to the 

final mix of lands to be exchanged, depending in part on the outcome of the appraisal, per the 

direction to that effect in FLPMA. The agency’s interpretation in this regard is also bolstered by 

Section 1206(a)(2)(C)(ii), which confers on the Forest Service rather open-ended authority to 

subject the Land Exchange to such terms and conditions as it may require, in addition to the 

explicit conditions specifically imposed by the Act. For similar reasons, the Forest Service does 
Draft Environmental Impact Statement

Chapter1 – Purpose of, Need for, and Decision-making Framework

Mt Hood National Forest

27

not believe that it may exercise the authority that 43 U.S.C. § 1716(d)(3) otherwise would 

provide for it to simply withdraw from the Land Exchange following any arbitration that may 

ensue on the appraisal that is being carried out on the parcels involved in the Land Exchange 

(although it may determine along with Mt. Hood Meadows to modify the Land Exchange “to 

reflect the findings of the arbitration or any other factors.”

In accordance with the foregoing, the Forest Service will include an analysis of factors related to 

the public interest in the FEIS consistent with its regulations at 36 C.F.R. § 254.3(b)(1). This 

analysis will be informed by relevant direction in Forest Service Handbook 5409.13, Chapter 30, 

Section 33.41b, which states: 

The authorized officer has the responsibility to determine if the proposed exchange 

serves the public interest (36 CFR 254.3 (b)(2)) and supports the direction and guidance 

in the forest land management plan. Factors that must be considered in a public interest 

determination for a proposed land exchange are listed in Title 36, Code of Federal 

Regulations, section 254.3(b)(1) (36 CFR 254.3(b)(1)). The public interest determination 

must show that the resource values and the public objectives of the non-Federal lands 

equal or exceed the resource values and the public objectives of the Federal lands and 

that the intended use of the conveyed Federal land would not substantially conflict with 

established management objectives on adjacent Federal lands, including Indian trust 

lands.

Second, the direction in Section 1206(a)(2)(D) of the Act is somewhat at odds with that in 

Section 206(d)(1) of FLPMA with respect to the time frame for and certain other particulars 

concerning the selection and execution of the appraisal to be conducted of the lands involved in 

the Land Exchange. More specifically, that subparagraph of the Act states that, “[a]s soon as 

practicable after the date of enactment of [the] Act, [the Forest Service and Mt. Hood Meadows] 

shall select an appraiser to conduct an appraisal of the Federal land and non-Federal land.” This 

provision has been complied with, as the Forest Service solicited bids for the appraisal and 

determined that [two] of the respondents were qualified, and then conferred with Mt. Hood 

Meadows before executing a contract for the appraisal to be carried out on June 30, 2016.

Other than as outlined above, the Forest Service intends to follow the legal requirements 

applicable to exchanges involving Federal land in FLPMA, which amended all exchange 

authorities that had been in effect prior to its adoption in 1976. For example, FLPMA requires 

that the value of exchanged lands be equal, but the exchange can be adjusted for any difference 

in value by cash equalization payments of up to 25 percent of the value of the Federal lands. It 

also advises the Secretary of Agriculture to reduce the amount of cash payment to as little as 

possible. Though there are provisions for the waiver of cash equalization payments, the Secretary 

is specifically excluded from waiving payment of money to the United States. Waiver of 

payments to the non-Federal party is limited to three percent of the value of the land transferred 

out of Federal ownership or $15,000, whichever is less.

Additional Direction regarding Manner in which Appraisal will be Conducted

Currently, a qualified, licensed appraiser is appraising the Federal and non-Federal lands. The 

appraisal will be conducted in compliance with the Uniform Appraisal Standards for Federal 

Land Acquisitions. Forest Service regulations require that values for exchange purposes be 

determined by appraisal. Forest Service appraisal guidelines and policy are provided in Forest 

Service Handbook 5409.12. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

28

Because FLPMA requires that the value of exchanged lands be equal, the Forest Service and Mt. 

Hood Meadows have engaged in preliminary discussions to at least tentatively identify a list of 

priority parcels for exchange. A letter dated July 5, 2016, provides documentation of the parties’ 

prioritization discussions to the Forest Service’s Regional Appraiser to aid in meeting the 

objectives of the appraisal services and facilitate its timely and effective completion. Those 

choices6 are reflected in the appraisal instructions contained in the contract Statement of Work. 

The appraiser will first appraise all of the Federal and non-Federal property. If the values of the 

Federal and non-Federal property described in the Act are not equal, the appraiser will refer to 

the prioritization schedule provided in the assignment instructions for direction regarding 

priorities for conveyance and will value only those parcels. If equal values are not possible, the 

Agreement to Initiate states that cash payment may be required by either party to equalize 

exchange values. As stated above, the final mix of lands that will ultimately be exchanged will 

then necessarily turn at least in part on the outcome of the appraisal, which will be disclosed in 

the FEIS.

Additional Laws, Regulations, and Agency Guidance

The Forest Service is completing this environmental analysis and decision-making process in 

accordance with regulations issued under the National Environmental Policy Act of 1969 as well 

as the Council on Environmental Quality. The agency is also completing this project in 

accordance with the National Forest Management Act of 1976 and the implementing regulations. 

Furthermore, the Forest Service is completing this EIS in accordance with the National Historic 

Preservation Act, Clean Water Act, Endangered Species Act and other applicable laws, policies 

and regulations.

36 CFR 219 Planning Regulations: Forest Plan Amendment and Objections

A proposed project that includes a programmatic plan amendment is subject to 36 CFR 219, 

Subparts A and B. As stated in 36 CFR 219.17(b)(3), a plan amendment initiated before May 9, 

2012, may be completed in conformance with the provisions of the prior planning regulation. 

Scoping for this project initially began in 2010; therefore, the Responsible Official has decided 

to follow the amendment procedures under the 1982 planning regulations. An evaluation of the 

significance of the proposed Forest Plan amendment is documented throughout chapter 3. The 

determination of whether the Forest Plan amendment is significant or not significant will be 

documented in the Record of Decision per agency guidance outlined in Forest Service Manual 

1926.5

At 36 CFR 219.17(b)(3), the Responsible Official can choose to allow for an objection rather 

than an administrative appeal, if following the provision of a prior planning rule. In this instance, 

the Responsible Official has decided to follow the objection process in 36 CFR 219 subpart B. 

The objection notice and filing will adhere to the requirements outlined at 36 CFR 219.52-56.

Because this project also includes a project-level decision, the regulations at 36 CFR 218 

(Predecisional Administrative Review Process) will also apply.

 6 If the Cooper Spur parcels exceed the value of the Government Camp parcels, then Mt. Hood Meadows would like to 

retain the following in order of preference: 1) Part of Cooper Spur Mountain Resort (Tax Lots 100 and 103); 2) All of 

the Cooper Spur Mountain Resort property; and, 3) Tax Lot 100 in 1S 10E 31. If the Government Camp parcels 

exceed the value of the Cooper Spur parcels, then the Forest Service would like to retain the following in order of 

preference: 1) western half of Section 14; 2) Government Lot 7; 3) eastern half of Section 14; and, 4) Government Lot 

8. 
Draft Environmental Impact Statement

Chapter1 – Purpose of, Need for, and Decision-making Framework

Mt Hood National Forest

29

Endangered Species Act 

Section 7(a)(2) of the Endangered Species Act of 1973, as amended (ESA), requires Federal 

agencies to review actions authorized, funded, or carried out by them, to ensure that such actions 

are not likely either to jeopardize the continued existence of Federally-listed species or to result 

in the destruction or adverse modification of listed species’ officially designated critical habitat. 

Such consultation is not required where the action agency, which is the Forest Service for this 

proposed action, lacks any meaningful discretion to modify the proposed action so as to benefit 

listed species in a manner otherwise obligated under the ESA. This issue deserves brief 

discussion in the context of the proposed action being analyzed in this EIS because the Forest 

Service has been directed to carry it out pursuant to congressional direction. Notwithstanding the 

fact that the proposed action is a congressionally prescribed Land Exchange, the Forest Service 

believes that it retains sufficient discretion under the Act such that consultation is at least 

warranted, if not legally required. For example, as noted above, Section 1206(a)(2)(C)(ii) of the 

Act authorizes the Forest Service to subject the Land Exchange to any further terms and 

conditions that it may require, which, presumably could be based on the results of its 

consultation under the ESA. Therefore, for this project, the Forest Service will consult pursuant 

to the ESA with the National Marine Fisheries Service and U.S. Fish and Wildlife Service. 

Consultations will be completed on this project before the Record of Decision is signed by the 

Responsible Official.

Magnuson-Stevens Fishery Conservation and Management Act 

The Magnuson-Stevens Fishery Conservation and Management Act, as amended by the 

Sustainable Fisheries Act of 1996, requires Federal action agencies to consult with the Secretary 

of Commerce regarding certain actions. Consultation is required for any action or proposed 

action authorized, funded, or undertaken by the agency that may adversely affect essential fish 

habitat (EFH) for species identified by the Federal Fishery Management Plans. For this project, 

there is no EFH present in the project area. 

National Historic Preservation Act of 1966, Executive Order 11593, 36 CFR 800.9 

(Protection of Historic Properties)

Section 106 requires documentation of a determination of whether each undertaking would affect 

historic properties. The Mt. Hood National Forest operates under a programmatic agreement 

between the Oregon State Historic Preservation Office (SHPO) and the Advisory Council on 

Historic Preservation for consultation on project determination. Consultation with SHPO will be 

completed on this project before the Record of Decision is signed by the Responsible Official.

Clean Water Act

The Clean Water Act of 1977 (CWA) and subsequent amendments established the basic structure 

of regulating discharges of pollutants into waters of the United States. The Environmental 

Protection Agency (EPA) has the authority to implement pollution control programs and to set 

water quality standards for all contaminants in surface waters. The EPA delegated 

implementation of the CWA to the States; the State of Oregon recognizes the Forest Service as 

the Designated Management Agency for meeting CWA requirements on National Forest System 

lands.

Federal Executive Order 11990 (Protection of Wetlands)

This executive order ended the official policy of Federal assistance for wetlands conversion and 

directed all agencies to minimize wetland impacts in their regulations. Specifically, the 

Executive Order requires agencies “to avoid to the extent possible the long and short-term 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

30

adverse impacts associated with the destruction or modification of wetlands and to avoid direct 

or indirect support of new construction in wetlands wherever there is a practicable alternative.” 

Depending upon the ultimate congressional direction in effect at the time the Responsible 

Official issues the Record of Decision for this proposed action, it may include the reservation of 

a wetland conservation easement on the Government Camp parcels, which would be consistent 

with the direction in this Executive Order.

Decision Framework

As explained above, this proposed action is necessarily informed and constrained by legislation, 

in particular the Act prescribing that the Land Exchange be carried out and setting forth the 

congressional direction and preconditions that must be satisfied in doing so. The Responsible 

Official will therefore decide whether all of the congressionally imposed conditions in the Act

have been satisfied, whether to require any further terms and conditions under the authority of 

the Act, and whether the proposed action is consistent with all of the other legal duties and 

management direction that apply to it. If the Responsible Official finds that all of the 

congressionally-mandated and any other requisite conditions that she believes are necessary have 

been satisfied, and that it is consistent with its other legal duties and responsibilities, the Forest 

Service will execute the Land Exchange. 

As part of the decision, and consistent with the Forest Service’s interpretation of the applicable 

legal direction for the proposed action, the Responsible Official will address factors related to if 

and how the proposed land exchange serves the public interest. In doing so, she will look to 

those factors that are to be considered as part of a public interest determination for a wholly 

discretionary proposed land exchange in the Code of Federal Regulations, as follows: 

To determine that an exchange serves the public interest, the authorized officer must find that—

• The resource values and the public objectives served by the non-Federal lands or interests 

to be acquired must equal or exceed the resource values and the public objectives served 

by the Federal lands to be conveyed; and, 

• The intended use of the conveyed Federal land will not substantially conflict with 

established management objectives on adjacent Federal lands, including Indian Trust lands 

(36 CFR 254.3(b)(2) (2011)).

An analysis of each of these public interest factors in the context of the proposed action will be 

disclosed in this environmental impact statement. The Responsible Official will include a final 

public-interest analysis, and explain how it influenced the final decision within the scope of the 

discretion the agency has to shape that decision as outlined above, in the Record of Decision. 

Additionally, the Responsible Official will decide whether or not to amend the Forest Plan as 

described in the proposed action, or make adjustments to the management direction for the 

Crystal Springs Watershed Special Resources Management Unit based on input that emerges as a 

result of public comment.

Public Involvement

The public was first notified of the land exchange proposal in 2010. The project was first 

published in the Mt. Hood National Forest’s Schedule of Proposed Actions in June 2010. A 

notice of intent to prepare an environmental impact statement was first published in the Federal 

Register on October 13, 2010. A 45-day comment period was provided. The notice asked for 
Draft Environmental Impact Statement

Chapter1 – Purpose of, Need for, and Decision-making Framework

Mt Hood National Forest

31

public comment on the proposal from October 13 through November 27, 2010. Comments were 

accepted if mailed, hand-delivered, faxed, or e-mailed. Information packages were sent to 158 

agencies, individuals, and organizations. A public open house regarding the proposal was held on 

October 26, 2010, at the University Place Hotel in Portland, Oregon. The Forest Service received 

input from 25 individuals and organizations in response to the 2010 scoping effort.

The public was most recently notified of the proposal in February 2016. An updated notice of 

intent to prepare an environmental impact statement was published in the Federal Register on 

February 16, 2016, initiating another 30-day period for the public to provide input to help inform 

the Forest Service’s scoping process, and asking for such input to be submitted by March 17, 

2016. An information package was also posted online and mailed to 300 agencies, individuals, 

and organizations on February 11, 2016. Scoping input was accepted if mailed, hand-delivered, 

faxed, or e-mailed. The Forest Service received 18 scoping letters from individuals and 

organizations. For the most part, commenters expressed similar concerns and interests as in 

2010. They were primarily concerned or interested in the following: learning more about the 

fairness and accuracy of the land appraisal process; the financial ability of the Forest Service to 

care for and manage the facilities on the private lands that would be acquired pursuant to the 

Land Exchange; whether the land exchange serves the public interest; the length of time it is 

taking to complete an environmental impact statement; the connection between this project and 

the Polallie Cooper Hazardous Fuels Reduction Project as it relates to the Crystal Springs 

Watershed Special Resources Management Unit; the Forest Plan amendment process and 

development; changes to summer range habitat for wildlife species; future use of the trails on the 

Government Camp parcels; the aerial tram corridor between Timberline and Government Camp; 

treaty rights and cultural resources protection; and wetland protection. 

The project has remained on the Schedule of Proposed Actions each quarter since it was first 

published in 2010. The Forest’s website has been updated since the project was initiated with the 

project description and status, as well as downloadable files such as the scoping letters, Notices 

of Intent, maps, and other documents. Details regarding the public comments received are 

described in the Scoping Report, which is posted online and filed in the project record at the 

Forest Supervisor’s Office in Sandy, Oregon.

Scoping comments received, including names and addresses of those who commented, are 

considered part of the public record for this project, are available for public inspection and will 

be released if requested under the Freedom of Information Act.

Tribal Consultation

Tribal governments have a special and unique legal and political relationship with the United 

States government as reflected in the United States Constitution, treaties, statutes, court 

decisions, executive orders, and memoranda. This relationship imparts a duty on all Federal 

agencies to consult, coordinate, and communicate with American Indian Tribes on a governmentto-government basis.

Indian Tribes can be affected by the policies and actions of the Forest Service in managing the 

lands and resources under its jurisdiction. Therefore, the Forest Service has a duty to consult 

with them on matters affecting their interests. The government-to-government relationships will 

be honored by involving local tribal representatives and soliciting their input regarding the 

proposed action. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

32

On December 4, 2009, both the Confederated Tribes of Warm Springs (CTWS) and 

Confederated Tribes of Grand Ronde (CTGR) were sent cultural resources reports for the 

project. A response was received from the CTWS in the form of a formal letter citing tribal 

concerns. A draft Memorandum of Agreement (MOA) was developed between the Oregon State 

Historic Preservation Office, US Forest Service and Mt. Hood Meadows. At this time, no 

response was provided by CTGR. 

In 2016, the CTGR cultural resources staff were provided a copy of the initial cultural resources 

report. Forest Service staff met informally with cultural resources staff at CTGR to re-introduce 

the project on April 19, 2016. Comments pertaining to the cultural resources report were 

received by the Forest Service and documented. On June 17, 2016, Forest Service staff visited 

the CTWS and discussed the project. CTWS provided the Forest Service with comments relating 

to treaty rights. On July 11, 2016, both CTWS and CTGR were mailed revised cultural resources 

reports. CTGR responded with comments and a request for a meeting, which was held on August 

3, 2016. Additional coordination with the Tribes will continue before a decision is issued on this 

project to ensure that Tribal interests are considered

Issues

Using the scoping input from the public, other agencies, and the Tribes, and its own knowledge 

of and experience with the values and resources within the project area or to be affected by the 

proposed action, the interdisciplinary team developed a list of issues or resources of interest to 

address. 

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 or 

eliminate and compare trade-offs for the decision maker and public. An issue should be phrased 

as a cause-effect statement relating actions under consideration to effects (FSH 1909.15, 12.4). 

Issues are typically separated into two groups: significant and non-significant. The term 

“significant issue” is only used when referring to significant environmental effects, and in the 

context of an EIS. Non-significant issues are identified as those: (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 NEPA regulations explain 

this delineation as a process by which the agency is to “...identify and eliminate from detailed 

study the issues which are not significant or which have been covered by prior environmental 

review (1506.3) narrowing the discussion of these issues in the statement to a brief presentation 

of why they will not have a significant effect on the human environment or providing a reference 

to their coverage else ware (40 CFR 1501.7(a) (3))” 

No significant issues were identified by the IDT during their review of the scoping comments 

received.

Non-significant Issues

The following resources were evaluated to determine the impacts of the proposed action and to 

determine consistency with laws, regulations, and policies. 
Draft Environmental Impact Statement

Chapter1 – Purpose of, Need for, and Decision-making Framework

Mt Hood National Forest

33

Heritage Resources and Treaty Rights

The Confederated Tribes of Grand Ronde and the Confederated Tribes of Warm Springs would 

lose access to 109 acres of ceded land for traditional uses through the conveyance of the 

Government Camp parcels. Since the laws regarding Section 106 do not apply to private entities, 

the assumption is that the land conveyance would result in an adverse effect to this cultural 

resource. The potential for mitigation is currently under discussion with the State and Tribal 

Historic Preservation Offices. Effects will be disclosed through a comparison of how heritage 

resources would be protected and the availability of traditional use areas. The analysis of 

mitigation options and disclosure of effects is presented in the Heritage Resources section in 

chapter 3 of this document. 

Threatened, Endangered, and Sensitive Species

The 109 acres of Federal land near Government Camp includes suitable habitat for several 

threatened, endangered, and sensitive aquatic, wildlife, and plant species. While the land 

exchange itself would not result in effects to these species or habitat, the future development of 

the conveyed lands could. Threatened, endangered, and sensitive species and/or their habitat 

could be directly and indirectly affected as a result of future land development. Since Federal 

laws pertaining to the protection of these species and their habitat do not apply at all or at least to 

the same extent to private entities, we reasonably project for purposes of our analysis that there 

would be adverse findings during the biological evaluation process, although it is not feasible of 

course to know with any degree of specificity or certainty the scope or depth of any such effects. 

Nevertheless, adverse effects could result from the loss of habitat in the conveyed parcels as well 

as indirect impacts to the adjacent Federal lands. Biological evaluations have been prepared for 

all threatened, endangered, and sensitive species that are present or have habitat within or 

adjacent to the 109 acres that would be developed as a result of the conveyance. Potential 

mitigations to offset or reduce any such potentially adverse effects have been evaluated during 

this process and disclosed in chapter 3, and this analysis is designed in part to assist the 

Responsible Official in determining if the Land Exchange needs to be subject to any additional 

terms and conditions beyond those specifically denoted in the applicable legislation prescribing 

its implementation.

The indirect and cumulative effects to threatened, endangered, and sensitive species and/or 

habitat as a result of the acquisition of the 769 acres near Cooper Spur, the reassignment of 

1,709 acres to wilderness, and the creation of the Crystal Springs Watershed Special Resources 

Management Unit is also described in chapter 3.

Hydrology, Water Rights, Wetlands and Soil Productivity

The 109 acres of land to be conveyed north of Government Camp is currently fully vegetated by 

a mature, conifer overstory, and lush understory. Wetlands are interspersed throughout the 

property, and the headwaters of Camp Creek pass through the northeast portion of the eastern 

parcel. The assumed future development of the property would include the removal of overstory 

and understory vegetation, excavation of building sites, roads, and driveways; and the 

construction of housing, and associated supporting infrastructure. This development and 

associated conversion of forested land to non-forest would result in soil displacement, an 

increase of impervious surface, increased peak flows, and a high likelihood of erosion, 

sedimentation, and wetland loss on the conveyed lands. Aquatic and fish species would be 

indirectly affected on the adjacent lands by the increased peak flows, sedimentation, and 

increased water temperatures created on the conveyed lands. The intensity and scale of effects 

would likely vary over short and long term timeframes. Hydrologic, soil, and aquatic species 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

34

evaluations were prepared for the 109 acres that would be developed and the indirect and 

cumulative effects that would likely occur on the adjacent Federal lands. These evaluations have 

been conducted based on the following assumptions, in addition to those listed above: 

• Effects analysis assumes full build-out of the Government Camp parcels.

• Development on the parcels to be conveyed will be subject to State and County laws, 

building codes, and zoning regulations.

• Water rights in the name of the Forest Service will be either “canceled” or remain as 

outstanding to a third party after conveyance. Water rights in the name of a private or 

municipal identity that have not been in use for five years or more will be ‘cancelled’ or 

transferred to the Forest Service. 

• Wetland easements include locally inventoried wetland delineations plus geomorphic 

functional contributing areas. The latter was determined using bare earth LiDAR and 

ArcGIS hydro tools to define stream initiation zones and provincial topographic 

contributing areas which were then refined based upon field validation.

Potential mitigations to offset or reduce adverse effects have been evaluated during this process 

and disclosed in chapter 3.

The indirect and cumulative effects on hydrology, aquatics, and soils resulting from the 

acquisition of 769 acres near Cooper Spur, the re-assignment of 1,709 acres of NFS lands to 

wilderness, and creation of the Crystal Springs Watershed Special Resources Management Unit 

will be disclosed in chapter 3 as well.

Recreation and Visuals

The 109 acres of land to be conveyed north of Government Camp is currently fully vegetated by 

a mature, conifer overstory, and lush understory. Two segments of a non-motorized trail system 

pass through the parcels. These trails are used for hiking and biking in summer and for Nordic 

skiing, winter fat biking and snow-shoeing in winter. The assumed future development of the 

property would include the removal of overstory and understory vegetation, excavation of 

building sites, roads, and driveways; and the construction of housing, and associated supporting 

infrastructure. 

Under the Omnibus Act, the Forest Service is required to reserve a trail easement on the Federal 

land that allows non-motorized use by the public of existing trails; roads, utilities, and 

infrastructure facilities to cross the trails; and improvement or relocation of the trails to 

accommodate development of the Federal land. Forest Service Trails 755, 755A, and 755B cross 

the Federal parcels and were included in the easement. This is an exclusive easement that would 

provide the Forest Service full authority to manage the location and maintenance of the trails per 

NFS standards. An exclusive easement would enable the Forest Service to retain a 32-foot-wide 

trail easement, enforce Forest Service regulations, and keep the easement in a fixed location. 

However, under the Clarification Act the easement size is changed to 24-feet, and is nonexclusive, meaning the landowner holds the authority to change the location of the trails, and to 

cross the trails at any location they choose with roads, utilities, and other infrastructure (within 

the conveyed parcels). While retaining a 24-foot-wide, non-exclusive trail easement may be a 

condition of the conveyance, the Forest Service would have limited ability to manage the trail in 

the same manner and level as on the adjacent NFS lands because it would not have full authority 

of the trails. This in turn would affect the public use and enjoyment of the trails. 
Draft Environmental Impact Statement

Chapter1 – Purpose of, Need for, and Decision-making Framework

Mt Hood National Forest

35

The County zoning regulations do not require a buffer between the parcels to be conveyed and 

NFS lands. The visual quality objectives as viewed from the adjacent NFS lands would change 

with the development of the property.

A recreation and visual analysis has been prepared for the 109 acres that would be developed and 

the indirect and cumulative effects that would likely occur on the adjacent Federal lands. These 

evaluations have been conducted based on the following assumptions, in addition to those listed 

above: 

• Lots are 10,890 square feet (1/4 acre).

• Lot coverage (impervious surface) will not exceed 40%.

• Building type is residential.

• Building heights will not exceed 50 feet. 

• No buffer (setbacks) along boundaries with NFS land.

Potential mitigations to offset or reduce adverse effects have been evaluated during this process 

and disclosed in chapter 3.

The indirect and cumulative effects on recreation and visuals resulting from the acquisition of 

769 acres near Cooper Spur, the re-assignment of 1,709 acres of NFS lands to wilderness, the 

Cooper Spur Ski Area Special Use Permit boundary change, the acquisition of the Cooper Spur 

Mountain Resort, and the creation of the Crystal Springs Watershed Special Resources 

Management Unit are disclosed in chapter 3 as well. 

Facilities at the Cooper Spur Resort and Ski Hill

Depending on the outcome of the appraisal equalization process, the Forest Service may acquire 

a significant number of structures that comprise the Cooper Spur Ski Area and Mountain Resort.

Because of that eventuality, the operating assumption the Forest Service has reasonably adopted 

for this analysis that it would acquire the structures along with the lands. The following 

described infrastructure at the ski area is considered in the estate to be conveyed: ski lift system 

comprised of one double chair, one rope tow and two tube tows; a day lodge, A-frame cabin, 

first-aid station, four multi-purpose buildings, instructor's hut, and pump house. The resort site 

consists of 11 different structures, including five log cabins of 1,200 square feet, each with a 

kitchen area, living room and fireplace, two bedrooms and one bath on the main floor. The resort 

also includes spas, storage, tennis court, equipment storage and shop, and a single-family 

residence. 

Condition assessments for the facilities to be acquired have been conducted. A number of 

inadequacies were identified that would need to be addressed before they could be opened for 

public use. A special use permit would also need to be developed for the future operation of the 

Cooper Spur Mountain Resort. A prospectus would be sent out for review and response by 

interested citizens. If there was no interest or the respondent could not prove their ability to 

maintain the facility to specific standards as outlined in the prospectus, the resort and/or ski area 

would be decommissioned.

The effects of the Agency acquiring new properties is included in chapter 3. Also, an evaluation 

of the facilities at the Cooper Spur Ski Area and Cooper Spur Mountain Resort are provided in 

chapter 3. The scenario of issuance of special use permit(s), as well as decommissioning either or 

both sites from a facilities standpoint, is in included in chapter 3. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

36

Socio-Economics

Social and economic analyses are conducted by the Forest Service to determine what effects the 

agency has on local communities and people using natural resources. A social impact is a change 

in social and cultural conditions that directly or indirectly results from a Forest Service action. 

Social and economic impacts are closely linked and interdependent. However, social impacts 

focus on cultural and lifestyle changes that may occur, while economic impacts occur when 

Forest Service actions directly or indirectly change the employment and/or income in the area.

The indirect and cumulative effects on socio-economics resulting from the acquisition of 

769 acres near Cooper Spur, the re-assignment of 1,709 acres of NFS lands to wilderness, the 

Cooper Spur Ski Area Special Use Permit boundary change, the acquisition of the Cooper Spur 

Mountain Resort, and the creation of the Crystal Springs Watershed Special Resources 

Management Unit are disclosed in chapter 3.
Draft Environmental Impact Statement

Chapter 2 –Alternatives, Including the Proposed Action

Mt Hood National Forest

37

Chapter 2 – Alternatives, Including the Proposed 

Action

Introduction

This chapter describes the alternatives considered for this project, including the proposed action 

itself. This section also presents the alternatives in comparative form, sharply defining the 

differences between each alternative and providing a clear basis for choice among options by the 

decision-maker and the public. Some of the information used to compare the alternatives is 

based upon the design of the alternative and some of the information is based upon the 

environmental, social and economic effects of implementing each alternative. 

Alternatives Considered in Detail

The Forest Service developed the No Action (Alternative 1) and Proposed Action (Alternative 2) 

in response to the direction in the Omnibus Act, and in light of the potential revisions to such 

direction that could ultimately result if the Congress eventually enacts the Clarification Act.

Alternative 1: No Action 

Under the no-action alternative, current management plans would continue to guide management 

of the project area. The land exchange would not be implemented and the purpose and need 

would not be met. Specifically, the 109 acres north of the village of Government Camp would 

remain under NFS ownership and continue to be designated in the Forest Plan as A11-Winter 

Recreation Area, A4-Special Interest Area for the Historic Barlow Road; and it would continue 

to be designated in the Northwest Forest Plan as Administratively Withdrawn and Riparian 

Reserves. Also, the 769 acres in the Cooper Spur area would remain under private ownership.

The existing 1,172-acre Cooper Spur Ski Area special use permit area would remain the same. 

No new special use permit prospectus would be advertised. The current nonexclusive permit 

expires in 2021, and may be extended an additional 20 years if it is in compliance with the site 

development schedule in the Master Development Plan. Nonexclusive means the Forest Service 

reserves the right to use or permit others to use any part of the permitted area for any purpose, 

provided such use does not materially interfere with the rights and privileges authorized by the 

permit. The lands and waters within the permit area would remain open to the public for all 

lawful purposes. The Master Development Plan encompasses the entire winter sports resort 

envisioned for development in connection with the NFS lands authorized by the permit. The nine 

structures and ski lifts on the ski hill (located on NFS lands) would remain under private 

ownership. 

The Cooper Spur Mountain Resort, including the land and buildings, would remain under private 

ownership. No special use permit prospectus would be advertised. 

The 1,709 acres to be included as part of the Mt. Hood Wilderness would remain designated in 

the Forest Plan as A4-Special Interest Area for the Cloud Cap-Tilly Jane Historic District (492 

acres), A11-Winter Recreation Area (1,109 acres), and B2-Scenic Viewshed (108 acres). These 

would also remain designated as Administratively Withdrawn, Riparian Reserves, and Matrix 

under the Northwest Forest Plan.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

38

The Crystal Springs Watershed Special Resources Management Unit would not be created. The 

2,090 acres of NFS lands that are currently designated in the Forest Plan as A4-Special Interest 

Area for the Cloud Cap-Tilly Jane Historic District (660 acres), A11-Winter Recreation Area 

(236 acres), B2-Scenic Viewshed (1,160 acres), and C1-Timber Emphasis (34 acres) would 

continue to be designated as they are now. These would also remain designated as 

Administratively Withdrawn, Riparian Reserves, and Matrix under the Northwest Forest Plan.

Alternative 2: Proposed Action

As described in chapter 1, the proposed action would exchange approximately 109 acres of NFS 

lands on the Zigzag Ranger District for approximately 769 acres of private lands in Hood River 

County. More specifically, the proposed action also includes the following elements:

• Two separate parcels (Sections 13 and 14) located adjacent to Government Camp in 

Clackamas County, totaling approximately 109 acres of NFS lands, would be conveyed to 

Mt. Hood Meadows. 

• In exchange for the 109 acres of NFS lands adjacent to Government Camp, the Forest 

Service would acquire approximately 769 acres of land located in Hood River County, 

which is currently owned by Mt. Hood Meadows.

• For the Government Camp parcels, a wetland conservation easement will or may be 

reserved to protect functions and values of existing wetlands, and trail easements either 32 

or 24 feet in width would be applied to existing non-motorized trails.

• Special use permit(s) would be issued for the operation and maintenance of the Cooper 

Spur Ski Area and Cooper Spur Mountain Resort. The term of the permit(s) would be for 

up to 20 years.

• Approximately 1,709 acres of existing NFS lands would become part of the Mt. Hood 

Wilderness.

• Approximately 2,090 acres of existing NFS lands plus 769 acres of the acquired lands 

would become designated as the Crystal Springs Watershed Special Resources 

Management Unit.

• The Forest Plan would be amended to change the land use allocations and standards and 

guidelines for the wilderness addition as well as the proposed management direction for 

the Crystal Springs Watershed Special Resources Management Unit. Also, the conveyed 

lands near Government Camp would be removed from the Forest Plan. 

The proposed action that was shared with the public in February of 2016 has been further 

developed to address the potential effects of possible legislative changes outlined in the proposed 

Mount Hood Cooper Spur Land Exchange Clarification Act, which has passed both the U.S. 

Senate and House of Representatives in separate forms during the current, 114th Congress (see 

S. 2069 and H.R. 3826), but has not been enacted into law. The potential modifications most 

applicable to this analysis involve the direction requiring the Forest Service to reserve wetland 

conservation and trail easements on the NFS lands to be exchanged. More specifically, the bill 

would change the requirement for the Forest Service to reserve a wetland conservation easement 

to an optional condition that may or may not be applied as part of the Land Exchange, per the 

following language in the proposed Clarification Act: “The Secretary and Mt. Hood Meadows 

may mutually agree for the Secretary to reserve a conservation easement to protect the identified 

wetland in accordance with applicable law, subject to the requirements that the conservation 

easement shall be consistent with the terms of the September 30, 2015 mediation between the 
Draft Environmental Impact Statement

Chapter 2 –Alternatives, Including the Proposed Action

Mt Hood National Forest

39

Secretary and Mt. Hood Meadows.” Further, the trail easement that was for exclusive use and 

would be 32 feet in width, as outlined in the Omnibus Act, would change to nonexclusive use 

and have a narrower width of 24 feet were the Clarification Act to pass in its current form. In this 

light, this EIS will address the effects of the different variations of the specific congressional

direction relating to the Land Exchange given that it is not known yet what the final substance of 

that direction will yet be at the time of conveyance.

The proposed action that was previously shared with the public has also been updated to address 

scoping comments received from the public and the relevant expertise and specialized 

knowledge of the interdisciplinary team regarding the designation of the Crystal Springs 

Watershed Special Resources Management Unit. The description of the Forest Plan amendment 

for the creation of the Crystal Springs Watershed Special Resources Management Unit has been 

more clearly developed. All of the elements of the proposed action that are outlined above are 

further described in detail below.

Lands to be Conveyed

The NFS lands to be conveyed comprise two separate parcels reserved from the public domain 

and reacquired land with reserved public domain status totaling approximately 109 acres located 

adjacent to Government Camp in Clackamas County. The western parcel is approximately 

68 acres; and the eastern parcel is approximately 41 acres. The NFS lands to be exchanged are 

timbered, mostly undeveloped, parcels of land. The tracts are physically separated by 40 acres 

private land. The parcels are located on the gentle southwest facing slope of Mt. Hood at the 

north end of Government Camp. Elevations range from about 3,760 to 4,120 feet. The Federal 

parcels have been withdrawn from mineral entry through the Bureau of Land Management's 

segregation process.

Once the Federal parcels are conveyed, the land would be available for development subject to 

the requirements in the Government Camp Village Revitalization Plan and the Clackamas 

County Comprehensive Land Use Plan (see http://www.clackamas.us/planning/ for more 

information). The Clackamas County Comprehensive Land Use Plan states that development of 

parcels in Government Camp formerly owned by the Forest Service must comply with the 

provisions of the county plans, which includes visual resource policies, such as limiting building 

height to fifty feet and integrating development with the natural environment. County land use 

policy in "distinctive resource areas," such as Government Camp, also directs the landowner to 

minimize adverse effects to vegetation, fisheries, and wildlife.

Section 13

The westerly parcel in Section 13 lies mostly north of Government Camp Loop Road and is 

accessed from a street on the east end. A creek traverses from northeast to southwest at the 

southeast comer of the property. The area around the creek is predominately wetlands. There are 

two parallel cuts through the timber for the Skyway Trail, a former gondola tram that ran from 

Thunderhead Condominiums to Timberline Lodge. A transmission line also cuts through the 

timber from the southwest to the northeast. Wally's Trail leads from the southern terminus of the 

Skyway Trail to the northwest comer of the parcel. The Forest has issued numerous special use 

permits for a water storage tank and water lines, transmission lines, trails, and a telephone line. 

These permits would be converted into easements at the conclusion of the exchange. Mt. Hood 

Meadows has negotiated long-term leases to allow the Mt. Hood Ski Patrol Building and the 

Hoodland Fire District #74 Fire Station to remain in use on these lands.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

40

Section 14

The easterly parcel in Section 14 lies at the north end of Government Camp with subdivision 

development to the south and west and with a Summit Ski Area run to the east. Access is 

provided by East Lige Lane that lies on the southern border of the parcel. The Crosstown Trail 

enters the property at the southeast comer and exits at the midpoint of the northern border. The 

Forest has issued special use permits for a water tank and water lines, electric and power lines. 

These permits would be converted to easements upon execution of the exchange. Although no 

water rights would be conveyed or reserved, the status report states there are three water rights 

issued to private parties, with at least one associated with this parcel.

Easements

The Omnibus Act includes a provision to the Government Camp parcels that the Forest Service 

and Mt. Hood Meadows shall agree for the Secretary to reserve a conservation easement to 

protect identified wetlands (Section 1206(a)(2)(G)). More specifically, the Omnibus Act required 

the Forest Service to reserve a conservation easement on the Federal land to protect existing 

wetland, as identified by the Oregon Department of State Lands that allows equivalent wetland 

mitigation measures to compensate for minor wetland encroachments necessary for the orderly 

development of that land following the exchange. In September 2015, the Forest Service and Mt. 

Hood Meadows arrived at mutually acceptable terms of a conservation easement encompassing 

approximately 31 acres (see figure 8). The wetland easements were based on locally inventoried 

wetland delineations combined with the geomorphic functional contributing areas.

Figure 8. Agreed-upon wetland conservation easements per the Omnibus Act
Draft Environmental Impact Statement

Chapter 2 –Alternatives, Including the Proposed Action

Mt Hood National Forest

41

In regard to the wetland conservation easement, the following direction is stated in the proposed 

Clarification Act: 

Prior to the exchange of the Federal and non-Federal land—

(i) the Secretary and Mt. Hood Meadows may mutually agree for the Secretary to 

reserve a conservation easement to protect the identified wetland in accordance 

with applicable law, subject to the requirements that—

(I) the conservation easement shall be consistent with the terms of the 

September 30, 2015, mediation between the Secretary and Mt. Hood 

Meadows; and

(II) in order to take effect, the conservation easement shall be finalized not 

later than 120 days after the date of enactment of the Mount Hood 

Cooper Spur Land Exchange Clarification Act.

Since the reservation of a wetland conservation easement could be changed from being a 

mandatory condition to the Land Exchange in the Omnibus Act (i.e., “shall reserve”) to a “may 

mutually agree”-upon condition in the proposed Clarification Act, the proposed action includes 

an analysis of the effects of both having the wetland conservation easement reserved as a 

condition to the Land Exchange under the mutually acceptable terms reached in September 2015, 

and of not having it included as a condition, in the event the Congress ultimately enacts the 

proposed Clarification Act. Rather, the acres could be reduced from 31 acres to nine acres of 

wetland protection, which represents the approximate acres of wetlands delineated by Terra 

Science, Inc.7 in 2006 (see figure 9). Also, since the Clarification Act has not been enacted, there 

is uncertainty as to what would be agreed upon within the 120 days after the date of enactment. 

In order to provide the Responsible Official with a range of conservation easement opportunities 

that would be consistent with legislation, the proposed action includes the least and greatest 

potential protections to the existing wetlands in the Government Camp parcels. In addition, the 

Forest Service wishes to advise that it could still revise the mutually acceptable terms of the 

wetlands conservation easement reached in September 2015, if it were to conclude that any 

revisions are necessary to comply with the direction in the Omnibus Act following its review of 

environmental effects in this EIS, as it has previously acknowledged. If the agency were to make 

any such revisions, however, it has further indicated its intent to work cooperatively with Mt. 

Hood Meadows Oregon to resolve any resultant issues that could ensue.

 7 In September 2006, Terra Science, Inc. prepared a report for Mt. Hood Meadows titled, “Wetland Delineation Report 

for Upper Camp Creek Area, Government Camp, Clackamas County, Oregon.” The Forest Service obtained the GIS 

dataset from Terra Science in order to spatially calculate and depict the wetland acres.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

42

Figure 9. Wetland boundaries delineated using Terra Science’s GIS dataset

Under the Omnibus Act, as a condition of the conveyance of the Federal land, the Forest Service 

is also directed to reserve a trail easement for existing Forest Service Trails 755, 755A, and 755B 

on the Government Camp parcels that allows for: (1) non-motorized use by the public of existing 

trails; (2) roads, utilities, and infrastructure facilities to cross the trails; and (3) improvement or 

relocation of the trails to accommodate development of the Federal land. The width of the trail 

easement from the center of the trail would be 32 feet (see figure 10). However, the proposed 

Clarification Act would alter this direction somewhat to require the Forest Service to reserve a 

24-foot wide, non-exclusive trail easement at the existing trail locations (Forest Service Trails 

755, 755A, and 755B) that retains for the United States existing rights to construct, reconstruct,

maintain, and permit non-motorized use by the public subject to the right of the owner of the 

Federal land to cross the trails with roads, utilities, and infrastructure facilities; and to improve or 

relocate the trails to accommodate development of the land following the exchange. Since there 

is uncertainty about which trail easement could be required at the time this NEPA analysis is 

completed, the proposed action includes an analysis of the effects of both trail easement 

conditions.
Draft Environmental Impact Statement

Chapter 2 –Alternatives, Including the Proposed Action

Mt Hood National Forest

43

Figure 10. Trail easements on Government Camp parcels

Lands and Infrastructure to be Acquired

The Omnibus Act identifies approximately 769 acres located in Hood River County as the nonFederal estate. Approximately 514 acres are located outside the current NFS administrative 

boundary. The non-Federal estate is comprised of three diverse property types situated in the 

vicinity of the Cooper Spur Ski Area on the northeast flank of Mt. Hood. The three types are: 

(1) the structures and personal property at the Cooper Ski Area; (2) land and all development at 

the Cooper Spur Mountain Resort; and, (3) mostly vacant forest land.

Infrastructure Acquired at the Cooper Spur Ski Area

The Cooper Spur Ski Area is located at a base elevation of 4,000 feet and summit elevation of 

4,350 feet, which provides 350 feet of vertical drop. Although 1,172 acres of National Forest are 

under permit, the effective developed and skiable area is about 50 to 60 acres. The lift system is 

comprised of one double chair, one rope tow and two tube tows. There are ten runs with 

40 percent rated easiest, 40 percent rated more difficult, and 20 percent rated most difficult.

As the underlying land at the ski area is already federally owned and administered, only the 

following described infrastructure, besides the aforementioned lifts, is considered in the estate to 

be conveyed: a day lodge, A-frame cabin, first-aid station, four multi-purpose buildings, 

instructor's hut, and pump house. The day lodge is the primary building with kitchen and dining 

area on the main floor, additional seating area in a loft, and lift ticket/equipment rental in the 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

44

lower daylight level. Restrooms are housed in one of the multi-purpose buildings. In addition, 

there is a private well water system, irrigation system, and septic system.

The special use permit area would be reduced from 1,172 acres to about 129 acres (see figure 

11). Approximately 1,012 acres of the existing permit area would become part of the Mt. Hood 

Wilderness. 

Cooper Spur Mountain Resort

The Cooper Spur Mountain Resort is located about two miles east of the Cooper Spur Ski Area 

at the intersection of Cooper Spur and Cloud Cap Roads. The resort site consists of 11 different 

structures. The registration desk portion of the restaurant building and the Homestead Cabin 

were built in 1942. The restaurant addition and all other structures were added in 1985–1986. 

Also, there are five log cabins of 1,200 square feet, each with a kitchen area, living room and 

fireplace, two bedrooms and one bath on the main floor. The resort also includes spas, storage, 

tennis court, equipment storage and shop, and a single-family residence.

In addition to the cabins and restaurant, there are several septic tanks that lead to a single leach 

field northeast of the improvements. A well with well house and another small building are 

located on Tax Lot 401. Another recently installed well is located on Tax Lot 102.

Special Use Permit(s) for the Cooper Spur Ski Area and Cooper Spur Mountain 

Resort

The proposed action involves the transfer of ownership of facilities associated with Cooper Spur 

Ski Area and Cooper Spur Mountain Resort. Based on the Forest Service’s preliminary analysis, 

it has determined that it is not in the public interest for the U.S. Government to operate these 

facilities; therefore, the Forest will look for opportunities to issue special use permit(s) for these 

areas and potential operation of these facilities. Thus, the proposed action includes authorizing 

the issuance of special use permit(s) for the operation and maintenance of the Cooper Spur Ski 

Area and Cooper Spur Mountain Resort. The term of the permit(s) would be for up to 20 years. 

The permitted areas would include 129 acres and is depicted in figure 11. The specific uses and 

activities would be determined through a prospectus process. The special use permit prospectus 

would have evaluation criteria to screen for such things as: services to the public, uses consistent 

with the management of the area, financial/technical feasibility, fee return to the 

government/maintenance of facilities, and activities that enhance nature-based outdoor recreation 

experiences. For government-owned facilities, the criteria would require a viable business plan 

that could generate fees that would off-set the expected deferred maintenance costs of the 

facilities.
Draft Environmental Impact Statement

Chapter 2 –Alternatives, Including the Proposed Action

Mt Hood National Forest

45

Figure 11. Proposed Cooper Spur Ski Area and Cooper Spur Mountain Resort permit boundary area
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

46

The permit holder(s) would be responsible for the full operations and maintenance of the 

facilities and permit area(s) as per terms and conditions and operation plans under special use 

permit. The permit holder(s) would be required to pay the U.S. Government a percentage of 

gross receipts, or other approved fee structures approved under special uses policy, dependent 

upon the use and activities. 

If through the prospectus process for operation of these government-owned facilities, there are 

no viable business proposals submitted, the Forest Service may then consider conveyance of the 

facilities (not including the underlying lands). There would be another special use permit 

prospectus to solicit proposals for viable business operation, including purchase or transfer of the 

excess facilities.

If the Forest Service retains ownership of the facilities, the permits would be issued under the 

Granger-Thye Act (G-T) authority. This authority allows for permit fees to be off-set by 

performing “landlord maintenance” and replace worn out facilities, such as toilets, water 

systems, and other infrastructure and improvements. More substantial ground-disturbing

activities that may be needed for future management would be analyzed separately as the 

projects are planned. 

If the Forest Service transfers ownership of the facilities, then other authorities would be used to 

authorize the special use permit(s). These authorities could be the Act of March 4, 1915, Ski 

Area Permit Act of 1986, or the Organic Act of 1897. These authorities cover uses where the 

facilities are not owned by the U.S. Government. 

Special use permit(s) would be monitored by a Forest Service permit administrator for 

compliance with Operating Plan(s) and permit terms. 

The proposed action is an administrative change that does not involve construction of new 

facilities or infrastructure. All of the sites currently exist, and management would continue with 

existing policies and regulations. Site improvements would be authorized with separate NEPA 

analysis. However, if there is no interest expressed for operation and maintenance of the Cooper 

Spur Ski Area and Cooper Spur Mountain Resort, then these facilities would be 

decommissioned, pending available funds.

Vacant Forest Land

The remaining property contains a mixture of pre-merchantable plantations covering about 

60 percent of the area, with the balance in second-growth timber stands. The plantations range 

from approximately 10 to over 25 years old—composed of mixed species including both planted 

and naturally regenerated Douglas-fir, ponderosa pine, white fir, western hemlock, western white 

pine, and lodgepole pine. Timber stands contain merchantable trees dominated by Douglas-fir 

and white fir mixed with trace amounts of western red cedar, western white pine and western 

hemlock.

Mt. Hood Forest Plan Land Use Allocations and Amendment

The Omnibus Act also provides that, upon completion of the land exchange, additional lands 

would be considered part of the Mt. Hood Wilderness and that the Crystal Springs Watershed 

Special Resource Management Unit would be created. Section 1202(2)(c) directs that 

approximately 1,709 acres depicted on the Mt. Hood Wilderness Tilly Jane map shall be 

incorporated in, and considered to be a part of, the Mt. Hood Wilderness, as designated under the 

Wilderness Act (16 U.S.C.1132(a)). The Omnibus Act states that the purposes of the Crystal 
Draft Environmental Impact Statement

Chapter 2 –Alternatives, Including the Proposed Action

Mt Hood National Forest

47

Springs Watershed Special Resource Management Unit are to ensure the protection of the quality 

and quantity of the Crystal Springs watershed as a clean drinking water source for the residents 

of Hood River County, Oregon; and, to allow visitors to enjoy the special scenic, natural, 

cultural, and wildlife values of the Crystal Springs watershed (Section 1205(a)).

In order to comply with the direction included in the Omnibus Act, the proposed action includes 

a programmatic amendment to the Forest Plan in order to assign land use allocations to the 

newly acquired land, change the land use allocations for the wilderness addition and the Crystal 

Springs Watershed Special Resource Management Unit, and add standards and guidelines for the 

Crystal Springs Watershed Special Resource Management Unit. Also, the conveyed lands at 

Government Camp lands would be removed from the Forest Plan, as amended.

Under the Forest Plan, the land use allocation of the NFS lands to be conveyed is primarily A11-

Winter Recreation Area. There is one acre of A4-Special Interest Area. The Northwest Forest 

Plan land use allocations included in the Government Camp parcels are Riparian Reserve and 

Administratively Withdrawn. Once the land has been exchanged into private ownership, the 

Forest Plan’s management direction would no longer apply. Thus, the Forest Plan would be 

amended to remove these lands from the agency’s management. 

The 1,709 acres of NFS lands that would be designated as part of the Mt. Hood Wilderness are 

currently designated in the Forest Plan as A4-Special Interest Area for the Cloud Cap-Tilly Jane 

Historic District (492 acres), A11-Winter Recreation Area (1,109 acres), and B2-Scenic 

Viewshed (108 acres) (see figure 7 in chapter 1). In order to comply with the legislation, the 

Forest Plan would be amended to change the 1,709 acres to A2-Wilderness (figure 12). The goal 

of A2 lands is to promote, perpetuate and preserve the wilderness character of the land; protect 

watersheds and wildlife habitat; preserve scenic and historic resources; and promote scientific 

research, primitive recreation, solitude, physical and mental challenge, and inspiration (Forest 

Plan, page 4-136). All of the standards and guidelines found on pages 4-138 to 4-144 of the 

Forest Plan would apply to these lands. These acres are also designated as Administratively 

Withdrawn, Riparian Reserves, and Matrix under the Northwest Forest Plan. Per congressional 

direction, these lands would change to Congressionally Reserved.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

48

Figure 12. Mt. Hood Wilderness addition

The 2,090 acres of NFS lands that would be designated as part of the Crystal Springs Watershed 

Special Resources Management Unit are currently designated in the Forest Plan as A4-Special 

Interest Area for the Cloud Cap-Tilly Jane Historic District (660 acres), A11-Winter Recreation 

Area (236 acres), B2-Scenic Viewshed (1,160 acres), and C1-Timber Emphasis (34 acres). These 
Draft Environmental Impact Statement

Chapter 2 –Alternatives, Including the Proposed Action

Mt Hood National Forest

49

acres are also designated as Administratively Withdrawn, Riparian Reserves, and Matrix under 

the Northwest Forest Plan. The Forest Plan would be amended to change these acres to A14-

Crystal Springs Watershed Special Resources Management Unit, which is further described in 

the section below. Under the Northwest Forest Plan, these lands would be changed to 

Administratively Withdrawn and Riparian Reserves.

The Forest Plan amendment would also designate the 769 acres of acquired lands as A14-Crystal 

Springs Watershed Special Resources Management Unit, which is further described below.

A14-Crystal Springs Watershed Special Resources Management Unit 

The Crystal Springs Watershed Special Resources Management Unit would become A14 upon 

execution of the land exchange. A14 is a newly developed land use allocation proposed in this 

project. The following description of A14 is proposed to fully comply with the management 

direction for the Crystal Springs Watershed Special Resources Management Unit pursuant to the 

Omnibus Act. This proposed amendment to create the management direction for A14 lands 

would only apply to the lands within the Crystal Springs Watershed Special Resource 

Management Unit (figure 13). The following existing land use allocations would no longer apply 

to the area within the Management Unit: A4-Special Interest Area for the Cloud Cap-Tilly Jane 

Historic District; A11-Winter Recreation Area; B2-Scenic Viewshed; and C1-Timber Emphasis.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

50

Figure 13. Proposed Crystal Springs Watershed Special Resources Management Unit
Draft Environmental Impact Statement

Chapter 2 –Alternatives, Including the Proposed Action

Mt Hood National Forest

51

The following language below would be added to the Forest Plan for the management direction 

for A14-Crystal Springs Watershed Special Resources Management Unit.

Goal

As established per the Omnibus Public Land Management Act (Public Law 111-11, March 30, 

2009), the purposes of the Crystal Springs Watershed Special Resources Management Unit 

(herein referred to as the “Management Unit”) are to (A) ensure the protection of the quality and 

quantity of the Crystal Springs watershed as a clean drinking water source for the residents of 

Hood River County, Oregon; and (B) to allow visitors to enjoy the special scenic, natural, 

cultural, and wildlife values of the Crystal Springs watershed (PL 111-11, Section 1205(a)(2)). 

Location

The designation of the Management Unit applies specifically to the portion of the Crystal 

Springs watershed in Hood River County, Oregon as depicted on a map dated June 2006 (see PL 

111-11, Section 1205(a)(1)(A)). Also, a map of the Management Unit is provided above. The 

Management Unit does not include any National Forest System land that is designated as 

wilderness by Section 1202 of the 2009 Omnibus Public Land Management Act (PL 111-11, 

Section 1205(a)(1)(B)). Further, the withdrawal of location, entry, and patent under the mining 

laws does not apply to the parcel of land generally depicted as ‘‘HES 151’’ on the map (PL 111-

11, Section 1205(a)(1)(C)(ii)).

There are no other management areas representing Management Requirements that overlap the 

A14 Management Area boundaries. All forestwide standards and guidelines apply; however, A14 

prescriptions predominate over other Forest Plan prescriptions.

Desired Future Condition

Major Characteristics

♦ Provides consistently excellent water quality (e.g., clarity, temperature and 

chemistry).

♦ No more than 25 percent of the Management Unit will be in a hydrologically 

disturbed condition at any time.

♦ Excellent fish spawning and rearing habitat, high quality waterfowl breeding, 

nesting and resting habitat, wildlife cover, and diverse plant communities.

♦ A variety of tree sizes exist, representing a healthy, resilient landscape.

♦ Each area is uniquely formed by natural forces and historic human achievement.

♦ Each area is unique by itself and presents its own special set of values and 

experiences.

♦ Maintain and improve opportunities for visitors to experience the natural landscape 

and the historic human environment. These opportunities are also encouraged and 

managed appropriately.

♦ Opportunities for environmental and cultural/historic education and interpretation 

are emphasized.

♦ Area has special characteristics, such as: massive lava flows, glacial cirque basins, 

high elevation meadows and forests, hot springs, outstanding views of majestic 

mountains, old growth forests, unique plant communities, unique combinations of 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

52

geology, ecology, and hydrology, interpretive trails and visitor points and/or historic 

buildings and travel routes.

♦ No new National Forest System roads are constructed.

♦ The transportation system is managed to preserve the integrity of the natural and 

historic environments.

Sensory Perceptions

♦ Expansive vistas.

♦ General feeling of “closeness” to nature.

♦ Solitude and tranquility.

♦ Sense of curiosity, discovery and inspirational.

♦ Physically challenging.

♦ Sense of kinship and sharing with individuals who hold similar values.

♦ Sights, sounds and smells associated with humans are evident but subordinate to the 

experience.

♦ Presence or evidence of a variety of wildlife, plants and animals.

Standards and Guidelines

A. Dispersed Recreation and Developed Recreation

1. New developed recreation sites, or expansions to existing sites, may occur provided 

watershed (i.e., water, soil, and fish) values are protected. 

2. The development of new or expansion of existing recreation sites, facilities and trails 

(hiking and cross-country skiing) may occur, but should avoid or protect sensitive 

watershed lands. 

3. Developments or expansions should avoid special aquatic and terrestrial habitats (e.g., 

side channels, ponds, and wetlands). 

4. Where existing developments (e.g., recreation sites and trails) are not consistent with 

riparian and/or watershed values, modification or rehabilitation of the site or facility may 

occur. 

5. Dispersed recreation and natural resource management interpretation should be 

encouraged, but should be discouraged within 100 feet of waterways. Whenever damage 

occurs to riparian resources, the damaged site shall be restored. 

B. Visual Resource Management

1. Management activities within the cultural landscape of the Cloud Cap – Tilly Jane 

National Historic District (see map below) shall meet a visual quality objective (VQO) 

of retention in the foreground and partial retention in the middleground and background 

distance zones, as seen from open roads, high recreational use areas, and water bodies. 

a. Foreground retention for the Cloud Cap Road within the National Historic District is 

applied to lands visible for distances up to 0.5 miles from the road and public areas, 

and means the following:

i. Vegetation is composed primarily of multi-age, multi-species stands with 

diverse understory of natural plant associations (where biologically feasible).
Draft Environmental Impact Statement

Chapter 2 –Alternatives, Including the Proposed Action

Mt Hood National Forest

53

ii. Numerous large diameter, old trees are a major component of the stands 

(where biologically feasible).

iii. Small, natural appearing openings provide diversity and a sense of depth.

iv. The ground is generally free of unnatural forms and patterns of debris or litter.

v. Seasonal changes in vegetation color and texture are emphasized.

b. Middleground and background partial retention is applied to lands visible for 

distances from 0.5 to 5 miles from the Cloud Cap Road and public areas within the 

National Historic District, and means the following:

i. Natural appearing forest landscape, with little evidence of human alteration.

ii. Dominant visual impression is mostly continuous tree canopies, with diversity 

in occasional natural appearing openings.

iii. Mosaic of species and age classes add texture and color contrast in natural 

patterns.

iv. Management activities repeat form, line, color, and texture common to the 

characteristic landscape.

2. Management activities outside of the cultural landscape of the Cloud Cap – Tilly Jane 

National Historic District (see map below) shall achieve a VQO of partial retention from 

open roads.

3. VQOs accepting less visual quality disturbance shall be applied when A14 Management 

Areas are located within “designated Viewsheds.” 

4. See Forestwide Visual Resource Management Standards and Guidelines for VQOs 

prescribed for trails. 

C. Cultural Resources Management

1. The area within the cultural landscape of the Cloud Cap – Tilly Jane National Historic 

District (see map below) shall meet the Recreation Opportunity Spectrum (ROS) 

classification of Roaded Natural (FSM 2311.1).

2. Authorized excavation of cultural resource sites shall be conducted in a manner which 

minimized impacts on watershed values. Ground and vegetation disturbance associated 

with site excavation should be rehabilitated immediately following completion of 

activities.

3. Maintenance and preservation of historic structures and features may be conducted.

4. The use of preservation and waterproofing materials and chemicals such as but not 

limited to fungicides, pesticides, stains, paints and sealers may occur, provided their use 

follows the appropriate precautions for the handling, storage, and application of the 

materials.

5. Vegetation management for the restoration and maintenance of the historic vistas at 

Inspiration Point, at milepost 8.4, and at the Amphitheater shall be permitted. 

6. The stands of whitebark pine within the cultural landscape of the Cloud Cap – Tilly Jane 

National Historic District (see map below) should be retained as much as possible (i.e., 

pruned, thinned, and fertilized to maintain vigorous growth and prevent disease).

7. See Forestwide Cultural Resources Management Standards and Guidelines.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

54

D. Wildlife and Fisheries

1. Wildlife and fisheries rehabilitation and enhancement projects may be permitted, 

provided watershed values are protected. Projects shall emphasize improvement or 

rehabilitation of key and/or sensitive wildlife and fisheries habitat. 

E. Range Management

1. Commercial livestock grazing is prohibited.

F. Timber Management

1. Regulated timber harvest shall not occur, other than activities relating to the harvest of 

merchantable products that are byproducts of activities conducted to further the 

designated purposes of the Management Unit (see Goals). Watershed impact areas 

should not exceed “thresholds of concern8

” (TOC) of 25 percent.

2. Biological and manual methods of vegetation management should be favored in 

domestic use watersheds.

3. Fuel reduction and forest health management treatments may be conducted to maintain 

and restore fire-resilient forest structures containing late successional forest structure 

characterized by large trees and multi-storied canopies, as ecologically appropriate in 

any of the following areas: within 400 feet of structures on NFS land or on adjacent 

private land; within 400 feet of the Cooper Spur Road, the Cloud Cap Road, and the 

Cooper Spur Ski Area Loop Road; and on any other NFS land with priority given to 

activities that restore previously harvested stands, including the removal of logging 

slash, smaller diameter material, and ladder fuels. 

4. Firewood cutting should be allowed only in specifically designated areas.

5. Activities involving fertilization of vegetation, in municipal or domestic watersheds 

shall be coordinated with appropriate municipalities or individuals.

6. Timber salvage activities may occur, if needed to ensure the protection of the quality and 

quantity of the Crystal Springs watershed as a clean drinking water source for the 

residents of Hood River County, Oregon or to allow visitors to enjoy the special scenic, 

natural, cultural, and wildlife values of the Crystal Springs watershed.

G. Soil, Water and Air Quality

1. See Forestwide Soil Productivity, Water, Riparian Area, and Air Quality Standards and 

Guidelines.

H. Minerals Management

1. New minerals exploration and development shall be prohibited. 

2. Subject to valid rights in existence on the date of the Omnibus Public Land Management 

Act (Public Law 111-11, March 30, 2009), the Federal land designated as the 

Management Unit is withdrawn from all forms of entry, appropriation, or disposal under 

public land laws; location, entry, and patent under the mining laws; disposition under all 

laws pertaining to mineral and geothermal leasing or mineral materials. Except for the 

parcel of land depicted as HES 151. 

3. See also Forestwide Minerals Management Standards and Guidelines. 

 8 The “threshold of concern” represents the percentage of a watershed that is hydrologically disturbed by 

management activities at any one time (see Forest Plan p. Four-53).
Draft Environmental Impact Statement

Chapter 2 –Alternatives, Including the Proposed Action

Mt Hood National Forest

55

I. Geology

1. See Forestwide Geology Standards and Guidelines

J. Lands and Special Uses

1. The Secretary may acquire from willing landowners any land located within the area 

identified on the map included in Section 1205(a)(1)(A) of the Omnibus Act as the 

“Crystal Springs Zone of Contribution.”

2. See also Forestwide Lands Program and Special Uses Standards and Guidelines.

K. Transportation Systems/Facilities; Travel and Access Management

1. New road construction and renovation of existing roads shall only be permitted to 

provide for public health and safety. 

2. Temporary roads may be used to further the Goals (see above) of the Management Unit 

and should be reclaimed upon use.

3. The Secretary may provide for the closure or gating to the general public of any Forest 

Service Road within the Management Unit, except for the Cloud Cap Road, which shall 

be administered in accordance with applicable law. 

4. The placement of new fuel storage tanks is prohibited. 

5. Road crossings for perennial streams shall be designed to meet aquatic organism passage 

(AOP) Standards and Guidelines. 

6. Drainage systems for roads or parking areas shall incorporate practical features to 

minimize or eliminate sediment and/or other pollutants from discharging directly into 

water bodies (i.e. streams, lakes, ponds, reservoirs, and wetlands). 

7. Recreational off-road vehicle use (other than over-snow) is prohibited.

L. Fire Prevention and Suppression

1. Fire retardants can be applied to the extent necessary to further the purposes of the 

Management Unit (see Goal). 

2. See Forestwide Forest Protection Standards and Guidelines

M. Wood Residue Management

1. See Forestwide Soil Productivity, Wildlife and Forest Diversity Standards and 

Guidelines. 

2. Prescribed burning may be permitted to enhance watershed resistance to catastrophic 

wildfire. 

N. Integrated Pest Management

1. Biological control measures should be favored. See Forestwide Timber Management 

Standards and Guidelines regarding integrated pest management.

2. Except to the extent necessary to further the purposes of the Management Unit (see 

Goal), the application of any toxic chemicals (other than fire retardants), including 

pesticides, rodenticides, or herbicides shall be prohibited. However, in order to protect 

the integrity of the natural system of the Management Unit (see Goal), the spread of 

State-listed noxious weeds and other invasive species of management concern may be 

prevented through the use of approved herbicides. If the application of herbicides does 

occur, it shall be coordinated with associated municipalities, groups or individuals.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

56

Summary of the Proposed Action

A summary of the proposed changes to the Forest Plan land use allocation acres are displayed in 

the following tables. Also, a summary of key elements of the proposed action are displayed 

below.

Table 2. Acreage of each existing land use allocation that would become A2-Wilderness

Land Use 

Allocation Description

Existing 

Condition

Acres

A4 Special Interest Area (Cloud Cap-Tilly Jane Historic District) 492

A11 Winter Recreation Area 1,109

B2 Scenic Viewshed 108

Total Wilderness Addition 1,709

Table 3. Acreage of each existing land use allocation that would become A14-Crystal Springs 

Watershed Special Resources Management Unit

Land Use 

Allocation Description

Existing 

Condition

Acres

A4 Special Interest Area (Cloud Cap-Tilly Jane Historic District) 660

A11 Winter Recreation Area 236

B2 Scenic Viewshed 1,160

C1 Timber Emphasis 34

n/a Private lands acquired 769

Total acres 2,859

Table 4. Proposed action summary

Description of Action Measure Value

Lands to be conveyed Acres 109

Lands to be acquired Acres 769

Crystal Springs Watershed 

Special Resources Management 

Unit

Acres 2,859

(769 from acquired lands; 2,090 

from existing NFS lands)

New wilderness addition to the 

Mt. Hood Wilderness

Acres proposed to be added 1,709

Cooper Spur Ski Area special 

use permit area

Existing acres 1,012

Cooper Spur Ski Area and 

Mountain Resort special use 

permit area

Acres proposed for new special 

use permit area

129

Facilities Number of buildings/structures 

to be acquired

20 structures, ski lift, 3 rope 

tows, 2 wells, tennis court, spa, 

several septic tanks, and 2 drain 

fields
Draft Environmental Impact Statement

Chapter 2 –Alternatives, Including the Proposed Action

Mt Hood National Forest

57

Alternatives Considered but Eliminated from Detailed Study

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

alternatives to a proposed action and to briefly discuss the reasons for eliminating any 

alternatives that were not developed in detail (40 CFR 1502.14). Public comments received in 

response to the proposed action provided suggestions for alternative methods for achieving the 

purpose and need. Some of these alternatives may have been outside the scope of the Omnibus 

and proposed Clarification Acts or duplicative of the alternatives considered in detail. Two 

alternatives considered but not fully developed are described below. 

Direct Purchase Alternative

Internal administrative guidance calls for the Forest Service to consider a direct purchase 

alternative as reflected in Forest Service Handbook 5409.13, Sec. 33.41a: 

Land exchange evaluations shall consider a purchase alternative in the National 

Environmental Policy Act (NEPA) analysis and document the non-Federal party’s 

position on the United States’ direct purchase of the proposed exchange parcels 

documented in the administrative record.

Under such an alternative, no lands would be exchanged; rather 769 acres of non-Federal land 

would be purchased from the non-Federal Party by the United States. 

The Forest Service determined that this alternative was not warranted for consideration in detail 

in this EIS, however, for several reasons:

1. The non-Federal party is not a willing seller as evidenced by prior court actions between 

the Hood River Valley Residents Committee (HRVRC) and Mt. Hood Meadows Ski 

Area, a dispute about proposed development of the non-Federal lands. The parties to the 

exchange wish to acquire Federal land adjacent to the village of Government Camp. Mt. 

Hood Meadows wishes to dispose of some of its property to the United States. Mt. Hood 

Meadows is unwilling to sell their land to the United States. They have entered the 

exchange with the desire to obtain the Federal parcels. The purchase option would not 

meet any of the landowner’s goals and, therefore, the option to purchase the private 

parcels is not viable.

2. Funds are not available to purchase the non-Federal lands. The Forest Service has 

limited funds for acquiring lands. The Trust for Public Land facilitates Federal agency 

acquisitions of important parcels by negotiating and temporarily holding non-Federal 

parcels. Funding sources are generated from the Land and Water Conservation Fund 

(LWCF). Efforts to secure the necessary appropriation would have to compete against 

other regional and nationwide requests. Given higher priority requests, it is unlikely that 

the necessary funds would be appropriated due to the competitive nature of the LWCF 

process. 

3. Finally, Section 1206 of the Omnibus Act directs the Forest Service to acquire the nonFederal lands via a specifically delineated Land Exchange. The Omnibus Act supersedes 

other Federal laws regarding land exchanges, and unequivocally prescribes the mode of 

acquisition of the non-Federal lands at issue in the Proposed Action. Per FSM 

5409.13.31.13:

“Legislated land exchanges often include provisions that conflict with standard land 

exchange authorities or with Forest Service land exchange regulations at Title 36, Code 

of Federal Regulations, part 254, subpart A (36 CFR part 254, subpart A). When a 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

58

legislative exchange contains direction that conflicts with current regulation or policy, 

the legislation overrides the requirements of regulation and policy.”

For the foregoing reasons, the non-Federal lands cannot be acquired through direct purchase, and 

therefore, it is not a feasible alternative and was eliminated from detailed study.

Deed Restriction Alternative 

Consideration of a Deed Restriction alternative is also ordinarily to be undertaken pursuant to 

administrative guidance in Forest Service Handbook 5409.13, Sec. 33.41a, which states:

The evaluation should also include other exchange configurations that were considered, 

including a deed restriction alternative when appropriate (36 CFR 254.3(h) and sec. 32 

of this Handbook). (h) Reservations or restrictions in the public interest. In any 

exchange, the authorized officer shall reserve such rights or retain such interests as are 

needed to protect the public interest or shall otherwise restrict the use of Federal lands to 

be exchanged, as appropriate. The use or development of lands conveyed out of Federal 

ownership are subject to any restrictions imposed by the conveyance documents and all 

laws, regulations, and zoning authorities of State and local governing bodies.

The purpose of a deed restriction is to limit use or development of the Federal lands after 

conveyance as a means of addressing an environmental concern. Deed restrictions controlling 

future use and development of Federal lands conveyed into non-Federal ownership should be 

used only when required by law, regulation, or executive order, or when the intended use of the 

conveyed Federal land would substantially conflict with established management objectives on 

adjacent Federal lands (FSH 5409.13, Sec. 33.41c). 

The applicable congressional direction pursuant to which the Forest Service is operating in 

evaluating this proposed action already includes provisions regarding the reservation of 

conservation and trail easements, and thus, appropriate restrictions to address environmental and 

recreational concerns are already included in the proposed action as it has been defined and 

prescribed by the Congress. 

The Forest Service Handbook 5409.13.32.12 addresses the Forest Service’s consideration of 

deed restrictions and reservations, as follows:

...due to the reduced value of the Federal estate and perpetual obligations that may be 

imposed on the United States, initiate or agree to a reservation or restriction on the 

Federal lands only when needed to protect the public interest or to satisfy a requirement 

of law, such as those concerning wetlands, floodplains, heritage sites, and so forth (36 

CFR 254.3(h)). For example, if the highest and best use of the Federal lands is for 

subdivision development, a deed restriction limiting development to protect a heritage 

site from ground-disturbing activities could have a negative impact on the value of the 

Federal land. The costs of deed reservations and restrictions shall be considered in the 

appraisal and decision processes. When a proposal is accepted by both parties, an 

Agreement To Initiate an exchange (ATI) (sec. 32.7) is executed that defines the 

proposal and documents the assignment of responsibilities and costs of each party (36 

CFR 254.4). Modifications to the terms and agreements to the ATI must be documented 

through an amendment.

The proposed action includes the deed restrictions prescribed by the legislation. The Responsible 

Official has been given reasonable discretion to subject the Land Exchange to additional terms 

and conditions if she ultimately were to find any are required, but the Forest Service has 

determined that development of a wholly separate alternative to be considered in detail is not 
Draft Environmental Impact Statement

Chapter 2 –Alternatives, Including the Proposed Action

Mt Hood National Forest

59

warranted or necessary under these circumstances, particularly where it is operating under 

legislative direction that already includes quite specific deed restrictions the Congress considered 

and found necessary.

Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

61

Chapter 3 – Affected Environment and 

Environmental Consequences

Introduction

This chapter presents the relevant resource components of the existing environment. It describes 

the resources of the area that would be affected by the alternatives. This chapter also discloses 

the environmental effects of implementing the alternatives. These form the scientific and 

analytical basis for comparing the alternatives described in chapter 2.

Most specialists used a Geographic Information System (GIS) to calculate the miles and areas 

affected, or to model habitats. If specialists used models other than GIS, it would be described in 

their report.

Analysis Assumptions

The following assumptions were identified regarding the future use and management of the 

conveyed and acquired lands, as an aid in identifying the resources that may be affected by the 

proposal. All assumptions were based on the best scientific, social, and economic information 

available at the time of analysis. References to the information from which each assumption is 

based are provided.

Government Camp: The Federal Lands to be Conveyed

Future development is based on Clackamas County zoning regulations and the existing condition 

of the private parcel that lies between the two Government Camp parcels. This private parcel is 

assigned the same zoning criteria as the parcels to be conveyed. The Clackamas County Planning 

and Zoning Division was contacted for assistance in interpreting the zoning regulations (Project 

Record). The lands to be conveyed would be zoned primarily as Hoodland Residential (HR), 

with Open Space Management (GCOSM) buffers along the property lines (see figure 14).
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

62

Figure 14. Clackamas County zoning districts and buffers for the parcels to be conveyed
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

63

Hoodland Residential (HR) is a single family residential zoning district that would permit 

development similar to the subdivision between the two parcels to be conveyed. HR is 

designated as Low Density Residential in the Clackamas County Comprehensive Plan.

9 Section 

317.01 of the Clackamas County Zoning and Development Ordinance describes the purpose, 

applicability, and uses permitted for the HR District. The types of uses that are prohibited are 

anything not listed as allowable, two-plus family dwellings and commercially related uses or 

services. Hotels and motels are also not allowed. Section 314.04 describes the applicable 

dimensional standards and allowed modifications. Minimum yard depth and building separation, 

and maximum lot coverage and building height are defined. There is no yard depth adjacent to 

the Mt. Hood National Forest. Maximum building heights are 40 feet, and up to 50 feet to 

accommodate understructure parking.

Generally, residential development is prohibited in the Floodplain Management District 

regulated by Section 703, river and stream corridors, wetlands, mass movement areas regulated 

by Section 1003, and on slopes greater than 25 percent. 

The Government Camp Open Space Management District (GCOSM) is intended to preserve and 

manage the Government Camp Village open space resources for the benefit, health, and welfare 

of the people. These resources provide the community with recreation, water quality treatment 

facilities, natural protection areas and pedestrian networks. Section 711 of the Clackamas County 

Zoning and Development Ordinance describes the purpose, areas of application, uses, buffer 

areas, dimensional standards, and development standards for the GCOSM. It is oriented toward 

providing non-motorized recreational, natural, and visually appealing experiences. Residential 

development is prohibited. 

The interdisciplinary team developed the following list of assumptions based on the best 

available information at the time of their analyses. This list was developed through interpretation 

of the Clackamas County zoning ordinances, including the potential variances that could be 

approved at the time of development. It also assumes all required State and Federal laws 

regarding the protection of streams and wetlands would be followed. 

• All acreages and mileages are approximate. For consistency in the analysis, the numbers 

used throughout this EIS were generated using spatial data (i.e., Geographical Information 

Systems). All final acre values will be determined by a licensed surveyor at a future date.

• Effects analysis assumes full development of the land.

• Development on the parcels to be conveyed will be subject to State and County laws, 

building codes, and zoning regulations.

• Size of the west parcel to be conveyed is 68 acres.

• Size of the east parcel to be conveyed is 41 acres.

• The wetland conservation easement would be approximately 31 acres and it includes 

locally inventoried wetland delineations plus geomorphic functional contributing areas. 

The latter was determined using bare earth LiDAR and ArcGIS hydro tools to define 

stream initiation zones and provincial topographic contributing areas which were then 

refined based upon field validation.

 9 For more information regarding the Clackamas County Comprehensive Plan, please go to: 

http://www.clackamas.us/planning/comprehensive.html. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

64

• There are nine acres of wetlands, as delineated by the GIS dataset created by Terra 

Science, Inc. in 2006. Therefore, the acres of wetland protection within the lands to be 

conveyed ranges from nine to 31 acres.

• 108 acres of parcels to be conveyed is currently Forest Plan LUA A11-Winter Recreation 

Area.

• One acre of parcels to be conveyed is currently Forest Plan LUA A4-Special Interest Area.

• There would be a non-exclusive trail easement under Clarification Act (definition provided 

in recreation section).

• There would be an exclusive trail easement under Omnibus Act (definition provided in 

recreation section).

• There would be a 24-foot trail easement (12 feet from center line) under Clarification Act, 

which is approximately three acres.

• There would be a 32-foot trail easement (16 feet from center line) under Omnibus Act, 

which is approximately four acres.

• There would be 65 developable acres after removal of wetlands, acres zoned as buffer and 

stream conservation areas, and if 15 percent of that area is removed for roads under 

Clarification Act. This could include approximately 260 lots.

• There would be 54 developable acres after removal of wetlands, acres zoned as buffer, 

stream conservation areas, and wetland conservation easements, and if 15 percent of that 

area is removed for roads under the Omnibus Act. This could include approximately 212 

lots.

• Lots would be approximately 10,890 square feet (1/4 acre).

• Lot coverage (impervious surface) would not exceed 40 percent.

• The building type would be residential.

• Building heights would not exceed 50 feet. 

• There would be no buffer (setbacks) along boundaries with NFS lands (open space 

zoning).

• The existing Forest would be converted to non-forested lands.

• The 6th field HUC is Zigzag Canyon.

• There is 0.5 mile of stream with fish present.

• There is 0.7 mile of stream with fish absent.

• There is 0.5 mile of perennial stream.

• There is 0.7 mile of intermittent stream.

• The intermittent stream buffer width would be 50 feet from the streambank.

• The perennial stream buffer width would be 70 feet from streambank.

• There are 58 acres of Riparian Reserves as based on the Northwest Forest Plan definition.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

65

Cooper Spur: The Private Lands to be Acquired

• Special use permits would be issued for the management of the Cooper Spur Ski Area and 

Cooper Spur Mountain Resort.

• The proposed permitted area for both the Cooper Spur Ski Area and Cooper Spur 

Mountain Resort would be approximately 129 acres.

• If there is no interest/response to the special use permit prospectus’, or adequate proof of 

the ability to successfully manage and operate the facilities is not provided, then the 

facilities would be decommissioned

• There are eight acres of existing wetlands.

• The 6th field HUC is the Middle East Fork Hood River.

• There are three miles of perennial streams.

• There is 0.3 mile of intermittent stream.

• There are approximately 166 acres of Riparian Reserves on the lands to be acquired based 

the Northwest Forest Plan definition.

Past, Present, and Reasonably Foreseeable Actions

The interdisciplinary team considered the effects of past actions as part of the existing condition.

The current conditions are the sum total of past actions. The Council on Environmental Quality 

recognizes “agencies can conduct an adequate cumulative effects analysis by focusing on current 

aggregate effects of past actions without delving into the historical details of individual past 

actions” (Council on Environmental Quality 2005). Innumerable actions over the last century 

and beyond have shaped the Mt. Hood National Forest land base. Attempting to isolate and 

catalog these individual actions and their effects would be nearly impossible. By looking at 

current conditions, the effects of past human actions and natural events, regardless of which 

event contributed to those effects are captured. 

Courts have interpreted a “reasonably foreseeable future action” as one that has been proposed 

and is in the planning stages. To analyze the cumulative effects of present and reasonably 

foreseeable future actions, each resource specialist considered the projects listed in table 5. They 

identified the ones expected to cause effects to their resource, at the same time and in the same 

place as effects from the proposed action.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

66

Table 5. Past, present, and reasonably foreseeable actions considered for cumulative effects

Government Camp Parcels

Mirror Lake Trailhead Relocation Project

Oregon Department of Transportation (ODOT) Highway 26 Safety Widening Project

Ongoing ODOT road maintenance, including snowplowing on NFS lands, Government Camp, and 

Highway 26

Timberline, Skibowl and Summit Ski Areas’ winter recreation activities, operation and maintenance

Timberline, Skibowl and Summit Ski Areas’ summer recreation activities, operation and maintenance 

(such as bike parks, race events and concerts)

Skibowl Ski Area Snowmaking Infrastructure Improvements Project (water withdrawal from Camp Creek)

Portland General Electric (PGE) powerline right-of-way maintenance

Clackamas County waterline/infrastructure maintenance

Ongoing Forest Service trail use and maintenance (winter and summer uses) for the Glade, Alpine, 

Timberline to Town, Mirror Lake, and Government Camp area trails

Timberline Ski Area Mountain Bike Trails and Skills Park Project, including watershed restoration 

activities

Camp Creek Summer Home Tract

Government Camp Sewer District operations

Government Camp Water District operations

Collins Lake Resort operations

Private water diversions from Camp Creek and Little Zigzag

Mazama Lodge Parking Area Expansion Project

Operation and maintenance of Kiwanis Camp

Operation and maintenance of Lady Creek Water System

Cooper Spur Parcels

Past timber harvest on NFS lands

Past timber harvest and agricultural activities on private land

Ongoing ODOT road maintenance, sanding, and snowplowing on NFS lands (specifically the 3510 road

(Cooper Spur Road) and the 3512 road (Cloud Cap Road)), as well as Highway 35

Forest Service vegetation treatment activities planned or underway (such as the Tilly Jane & Polallie 

Cooper Hazardous Fuels Reduction and other general pre-commercial treatments)

Gnarl Ridge Fire, including burned area rehabilitation activities

Past aquatic restoration projects, including road decommissioning and East Fork Hood River stream 

channel improvements projects

Debris flows in the East Fork Hood River from 2000 and 2006

Invasive plant treatments

Cooper Spur Ski Area activities, operation and maintenance

Development of private land (past and current)

Ongoing recreation and trail use and maintenance (winter and summer uses) for the Tilly Jane and 

Cloud Cap areas

Crystal Springs Water District operations

Timberline Trail - Eliott Crossing Relocation Project

Ongoing or upcoming Forest Service road closures

Wilderness additions from the 2009 Omnibus Act (not including the Mt. Hood Wilderness addition which 

is included in the proposed action for this project)

Existing Cloud Cap and Tilly Jane special use permits
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

67

In regard to addressing any potential cumulative impacts that could arise in connection with the 

Forest Service’s proposed acquisition of the Cooper Spur parcels, it should be first be noted that 

the proposed action of itself has no direct environmental effects, as it simply comprises a realestate transaction that would result in a change of ownership of the respective parcels at issue.

Nor does the proposed action include or authorize any ground-disturbing activities on the Cooper 

Spur parcels that would follow transfer of ownership to the Forest Service. In regard to 

evaluating the effects of past actions that have been carried out on the Cooper Spur parcels or 

within their immediate vicinity, the Council on Environmental Quality has issued guidance 

indicating that, “[g]enerally, 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.” We find that there are no factors present that would make 

reliance on that guidance inadvisable or improper, and so we are relying upon the environmental 

baseline as the principal basis for our consideration of the effects of past actions in regard to 

these parcels. In addition, with the exception of the Polallie Cooper Hazardous Fuels Reduction 

Project, our investigation has found no existing proposals or sufficiently concrete, likely, and/or 

detailed plans or proposals to engage in any ground-disturbing activities on these parcels or 

within their immediate vicinity, and so, per NEPA’s implementing regulations, we do not have a 

duty to consider such effects within the scope of our cumulative impact analysis in this EIS.

Even accounting for this specific reasonably foreseeable project, however, because the proposed 

action would not result in any direct or indirect environmental impacts on the Cooper Spur 

parcels or within their immediate vicinity, by definition there cannot be any incremental impacts 

in this context that could add to and/or accumulate with the effects of other past, present, and 

reasonably foreseeable future actions for purposes of this DEIS. The one primary exception is 

the addition of the Cooper Spur facilities to the Forest’s building inventory – the cumulative 

impact of adding more structures is discussed in the Facility section below. In addition, any 

future activities proposed for the Cooper Spur parcels would be considered and reviewed under 

NEPA; at that time, any effects would be analyzed based on the activities being proposed. In 

particular, we would note that the Forest Service has prepared and issued in January 2016 a Draft 

Environmental Assessment for the Polallie Cooper project referenced above, and we will 

continue to monitor and consider the analysis in that NEPA document to help inform the analysis 

in this DEIS, even though we have determined, as noted above, that the project will not give rise 

to any synergistic effects from the proposed action subject to analysis in this DEIS.

Therefore, in light of the foregoing, the majority of the reasonably foreseeable actions evaluated 

as part of the cumulative effects analyses in this DEIS focus on the likely future uses of the 

parcels at Government Camp, with respect to which there is a much greater degree of certainty, 

detail, and understanding of the likely shape and parameters such uses are projected to take.

Specialist Reports

Relevant resource components from each resource specialist’s report are highlighted in this 

chapter. Components include the existing environment which is the baseline environmental 

condition as described under Alternative 1-No Action, and the anticipated environmental effects 

of implementing the Proposed Action.

This DEIS incorporates by reference the resource specialists’ reports in the Project Record (40 

CFR §1502.21). These reports contain the detailed data, executive summaries, regulatory 

framework, assumptions and methodologies, analyses, conclusions, maps, references, and 

technical documentation that the resource specialists relied upon to reach their conclusions.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

68

Project Record

As also stated in chapter 1, the Government Camp-Cooper Spur Land Exchange Project Record 

is referenced in an effort to keep this document brief and concise as per 40 CFR §1502.21. The 

Project Record contains a variety of documents, including, but not limited to: specialists’ reports, 

literature, supporting documents, and other process-related documents.

Botany

Introduction

This section of the EIS discloses the potential effects of the proposed land exchange on sensitive 

botanical species (vascular plants, bryophytes, lichens, and fungi) on the Region 6 Regional 

Forester’s Special Status Species List (July 2015), the potential habitat of Survey and Manage 

botanical species (December 2003 List), ethnobotanical species, and non-native invasive plants. 

Botanical species, forested plant communities, and non-native invasive plant species that 

currently occupy the land exchange parcels are described in detail so that the respective 

terrestrial ecosystem values and services of the Government Camp and Cooper Spur parcels can 

be compared and evaluated. 

Land exchanges are administrative actions carried out under statutes and regulations that require 

public participation, ESA Section 7 consultation, executive order requirements for wetland 

protection, and environmental analysis. Land exchanges are not habitat-disturbing activities, as 

described in the 2001 Survey and Manage ROD standards and guidelines (USDA Forest Service 

and USDI BLM 2001, p. 22) and as determined by the Pacific Northwest Regional Office 

(Portland, OR). Therefore, land exchanges do not trigger the need for Survey and Manage predisturbance surveys; however, a land exchange may affect the future management of Survey and 

Manage species; thus, a discussion and disclosure of currently available information and likely 

impacts to these species are appropriate in the NEPA document.

Physical inventories of Survey and Manage species are not triggered by a land exchange, but if 

there is existing information that a species could be impacted negatively or positively, then it is 

appropriate to disclose what that likely impact may be. Types of discussions that may be useful 

(depending on species) include: information on existing known species’ sites, long-term or shortterm anticipated gains or losses in potential habitat, changes in the distribution and connectivity 

of habitat, impacts of potential changes in road density, changes in security habitat, anticipated 

human disturbance levels, and habitat fragmentation particularly considering whether or not 

these effects would limit dispersal and may affect species-persistence objectives.

Although not required, surveys for Survey and Manage vascular plants, bryophytes, and lichens 

were combined with surveys for Region 6 sensitive species. The Botany Specialist Report 

(Project Record) identifies what Survey and Manage botanical species have potential habitat in 

the land exchange parcels in order to disclose the impacts that future development or 

management activities may have on a given species.

The Botany Specialist Report provides additional background information and detail regarding 

the methodology undertaken to conduct the analysis. It also includes much supporting 

information regarding the Forest Plan and other laws and regulations related to this resource, 

including the process and requirements for conducting Biological Evaluations. 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

69

Affected Environment

Plant Associations

Lands to be Conveyed

The forest stands in the western and eastern parcels are in the Pacific silver fir zone, which 

occurs from roughly 3,000 to 5,000 feet (900 to 1,500 meters) in elevation on the western slopes 

of the Cascade Range from British Columbia south to the southern end of the Willamette 

National Forest (Hemstrom et al. 1982, McCain and Diaz 2002). The elevation of the 

Government Camp land exchange parcels ranges from 3,600 to 4,000 feet (1,100 to 1,200 

meters). Pacific silver fir is the climax tree species in this zone. “Climax” refers to the tree 

species that can be expected to dominate a forest over the passage of time (180+ years) barring 

disturbance (e.g., fire, logging, volcanic eruptions, flooding) that would interrupt or alter forest 

development. The Pacific silver fir zone is wet in winter with deep snow accumulations at upper 

elevations and relatively dry in summer (Hemstrom et al. 1982). 

Annual precipitation ranges from about 70 inches (1,800 mm) in local rain shadows to over 

130 inches (3,350 mm) on some high ridges (Hemstrom et al. 1982). Much of this precipitation 

accumulates as a snowpack 3 to 10 feet (1 to 3 meters) deep that melts from May to July 

(Hemstrom et al. 1982). At elevations above 5,000 to 5,500 feet (1,500 to 1,670 meters), 

mountain hemlock is the climax tree species (Hemstrom et al. 1982, Diaz et al. 1997). At upper 

elevations, the Pacific silver fir zone blends into the mountain hemlock zone (Hemstrom et al.

1982). Some of the eastern parcel may lie in this transition zone between the Pacific silver fir 

zone and the mountain hemlock zone, despite the elevation of the parcels lying solidly in the 

Pacific silver fir zone. 

Lodgepole pine is a pioneer (early seral) species in the mountain hemlock zone following 

disturbance (Simpson 2007, Simpson 2014, Diaz et al. 1997). Most lodgepole pine stands on the 

west side of the Cascade Range are seral and developed following stand-replacement fire or 

timber harvest (Franklin and Dyrness 1973). Lodgepole pine is present in both parcels but 

particularly in the eastern parcel. Stand-replacement fire and young infertile soils derived from 

andesitic lava flows explain the presence of lodgepole pine. Wildfires burned in the upper Zigzag 

River basin in 1901, during the period from 1908 to 1920, and in 1933–1934 (Zigzag Watershed 

Analysis, USDA Forest Service 1995). The Oregonian newspaper reported a fire occurring in 

April 1931, in the Mirror Lake area. A fire map in the Zigzag Watershed Analysis displays the 

Government Camp parcels as having burned once during one of these fire periods (which one is 

not clear). Mountain hemlock and Pacific silver fir broadly overlap in their ecological 

distribution in the Oregon Cascades, so that distinguishing between the two series can be 

difficult (Simpson 2007). In most stands within the mountain hemlock series, when Pacific silver 

fir is present, it will likely never be excluded, and is essentially a co-dominant even in climax 

and near-climax stands (Simpson 2007).

A note on the concept of potential natural vegetation (or “climax plant community”) is helpful. A 

potential natural community is the biotic community that presumably would be established and 

maintained over time under present environment conditions, if all successional sequences were 

completed without additional human-caused disturbance (Hall 1998). Present environmental 

conditions include climate change, eroded or damaged soils, and natural disturbances in riverine 

riparian systems (Hall 1998). Grazing by native fauna and natural disturbances such as droughts, 

flood, wildfires, wind, insects, and disease are inherent in the development of communities; 

however, potential natural communities are described without disturbance by natural elements, 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

70

including fire (Hall 1998). The potential natural communities may include naturalized nonnative 

species. Thus, a potential natural community is composed of those species the investigator 

presumes will be most competitive over time (climax) and that will prevent establishment by less 

competitive (seral) species under existing site conditions and climate, and without human-caused 

disturbance (Hall 1998).

Pacific silver fir plant associations (Hemstrom et al. 1982, Simpson 2007), in order of likely 

occurrence in the Government Camp parcels, include the following:

Pacific silver fir/big huckleberry/beargrass (ABAM/VAME/XETE) 

Pacific silver fir/Pacific rhododendron/beargrass (ABAM/RHMA3/XETE) 

Pacific silver fir/Pacific rhododendron-Alaska huckleberry/western bunchberry 

(ABAM/RHMA3-VAAL/COCA13) 

Pacific silver fir/Alaska huckleberry/western bunchberry (ABAM/VAAL/COCA13)

Pacific silver fir/Alaska huckleberry-salal (ABAM/VAAL-GASH)

Pacific silver fir-western hemlock/Pacific rhododendron-salal (ABAM-TSHE/RHMA3-

GASH) 

Possible mountain hemlock plant associations (Diaz et al. 1997, Simpson 2007) occurring in the 

Government Camp parcels include the following:

Mountain hemlock/big huckleberry/beargrass (TSME/VAME/XETE)

Mountain hemlock/big huckleberry/queen’s cup (TSME/VAME/CLUN)

Mountain hemlock/queen’s cup (TSME/CLUN) 

Both Simpson (2007) and Diaz et al. (1997) note the presence of lodgepole pine as an early seral 

species following disturbance for the mountain hemlock plant associations listed above.

Lands to be Acquired

The Cooper Spur parcels occur in what is commonly called the mixed conifer zone. Use of this 

term is recommended advisedly because it has different meanings for various people (Topik et al.

1988). Concerning Cooper Spur it means forests with a diversity of conifer species (Douglas-fir, 

ponderosa pine, grand fir, lodgepole pine, western hemlock, mountain hemlock, western larch, 

Engelmann spruce, noble fir, Pacific silver fir, and subalpine fir). The Cooper Spur area is 

environmentally diverse not only with its diversity of conifer species but in its confluence of 

forest zones/series (grand fir, mountain hemlock, western hemlock, and Pacific silver fir). Many 

of the plant communities in the Cooper Spur parcels fit best in the grand fir series. Forests in the 

grand fir zone include a number of other conifers (notably Douglas-fir and ponderosa pine), but 

grand fir dominates the regeneration in the understory (Topik et al. 1988). Regeneration in many 

of the forest stands in the Cooper Spur parcels is dominated by grand fir. The upper elevation 

limit of the grand fir zone occurs where abundant moisture and cool temperatures allow 

development of stands dominated by Pacific silver fir, mountain hemlock, or subalpine fir (Topik 

et al. 1988). 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

71

Plant associations in the grand fir series for the area include the following:

Grand fir/vine maple/vanilla-leaf (ABGR/ACCI/ACTR)

Grand fir/twinflower (ABGR/LIBO) 

Grand fir/oceanspray (ABGR/HODI)

Grand fir/dwarf Oregon grape (ABGR/MANE)

Other plant associations that may occur in the parcels include the following:

Mountain hemlock/queen’s cup (TSME/CLUN)

Western hemlock/vanilla-leaf (TSHE/ACTR)

Pacific silver fir/vanilla-leaf (ABAM/ACTR)

The grand fir/vine maple/vanilla-leaf association seems to be the best fit for many of the plant 

communities in mature forest in the parcels where natural regeneration and plant association 

indicator species are evident. Determining plant associations (potential natural vegetation or 

climax plant communities) in plantation (early seral) stands is less straightforward at the present, 

but it can be assumed that they will more or less follow the same trajectory as they develop over 

time as neighboring mature stands. 

Environmental Consequences

Direct and Indirect Effects

Alternative 1

Under the no-action alternative, approximately 100 acres of forest habitat in the Government 

Camp parcels (109 acres minus 9 acres of wetlands and stream) would not be lost to land 

development. There would be no effect on forest habitat, riparian/wetland habitat, native plant 

communities, or the potential habitat of rare botanical species: sensitive or strategic species on 

the Region 6 Regional Forester’s Special Status Species List (July 2015) or species on the 

Survey and Manage list (December 2003).

Under the no-action alternative, all or a portion of the 769 acres in the Cooper Spur parcels may 

remain as they currently are (undeveloped, for the most part, except for the Cooper Spur 

Mountain Resort), or all or a portion may be developed sometime in the future by the owner 

depending on Hood River County planning requirements. Although there is no proposal to 

expand the Cooper Spur Ski Area, under the no-action alternative, the permit area would remain 

at 1,172 acres. If the Cooper Spur parcels are developed in the future, it would result in a loss of 

forest habitat, riparian/wetland habitat, native plant communities, and potential habitat for rare 

botanical species: sensitive or strategic species on the Region 6 Regional Forester’s Special 

Status Species List (July 2015) and species on the Survey and Manage list (December 2003).

The no-action alternative (i.e., with no land exchange occurring) would comply with all Forest 

Plan standards and guidelines related to forest diversity (FW-148 through FW-169) and 

threatened, endangered, and sensitive (TES) plants (FW-170 through FW-186) (Forest Plan 

1990, pp. 67-70). No action would prevent the loss of 109 acres of upland forest and riparian 

habitat within the Government Camp parcels in the upper Zigzag watershed and, with it, the loss 

of potential habitat for sensitive botanical species (vascular plants, bryophytes, lichens, and 

fungi) on the Region 6 Regional Forester’s Special Status Species List (July 2015) and for 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

72

botanical species on the Survey and Manage list (December 2003). FW-175 requires that “habitat 

for threatened, endangered, and sensitive plants and animals shall be protected and/or 

improved.” The no-action alternative would provide for the continued maintenance of 

populations of existing native plant species within the Government Camp parcels. FW-162 

requires that management activities “should provide for the maintenance of viable populations of 

existing native and desired non-native wildlife, fish (36 CFR 219.19), and plant species (USDA 

Regulation 9500-4) well distributed throughout their current geographic range within the 

National Forest System.” The no-action alternative would comply with FW-148 by preserving 

the diversity of plant and animal communities in the Government Camp land exchange parcels: 

“Management activities shall preserve and enhance the diversity of plant and animal 

communities, including endemic and desirable naturalized plant and animal species” (FW-148). 

With the no-action alternative, the harvest of special forest products (e.g., beargrass, mushrooms, 

forest greens, mosses and ferns, and medicinal forest products) in the Government Camp parcels 

would not be affected (FW-710, FW711, p. 131).

Alternative 2

The action alternative (land exchange) would result in the loss of 109 acres of upland forest and 

riparian habitat in the Government Camp parcels in the upper Zigzag watershed and, with it, the 

loss of potential habitat for sensitive botanical species (vascular plants, bryophytes, lichens, and 

fungi) on the Region 6 Regional Forester’s Special Status Species List (July 2015) and for 

botanical species on the Survey and Manage list (December 2003). FW-175 stipulates that 

“habitat for threatened, endangered, and sensitive plants and animals shall be protected and/or 

improved.” Although no sensitive or Survey and Manage botanical species were found during 

botany surveys and there are no known sites recorded for sensitive or Survey and Manage 

species for the Government Camp parcels in the NRIS TESP database, there is potential habitat 

for sensitive and Survey and Manage species in the Government Camp parcels that would be 

lost. Pertaining to FW-162, the land exchange would not provide for the maintenance of 

populations of existing native plant species within the Government Camp parcel; however, the 

land exchange is unlikely to affect the maintenance of viable (persistent and interbreeding) 

populations of existing native plant species well-distributed throughout their current geographic 

range across the Mt. Hood National Forest and within the National Forest System. FW-162 

requires that management activities “should provide for the maintenance of viable populations of 

existing native and desired non-native wildlife, fish (36 CFR 219.19), and plant species (USDA 

Regulation 9500-4) well distributed [sic] throughout their current geographic range within the 

National Forest System.” The land exchange would not preserve the diversity of plant and 

animal communities in the Government Camp land exchange parcels, which would be lost to 

future development (FW-148). Any future harvest of special forest products (e.g., beargrass, 

mushrooms, forest greens, mosses and ferns, and medicinal forest products) in the Government 

Camp parcels would be lost with the land exchange (FW-710, FW711, p. 131).

On the Cooper Spur side of the mountain, all or a portion of the 769 acres in the Cooper Spur 

parcels would remain as they currently are being managed by Mt. Hood Meadows (undeveloped, 

for the most part, except for the Cooper Spur Mountain Resort). Any future developments on the 

Cooper Spur parcels would be decided by Mt. Hood Meadows and dependent on State and 

County land development requirements. If the Cooper Spur parcels are developed in the future, it 

would result in a loss of forest habitat, riparian/wetland habitat, native plant communities, and 

potential habitat for rare botanical species: sensitive or strategic species on the Region 6 

Regional Forester’s Special Status Species List (July 2015) and species on the Survey and 

Manage list (December 2003). If the 769 acres of forest habitat is acquired by the Forest Service, 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

73

then there would be no commercial developments resulting in greater protections for botanical 

species. After the Cooper Spur parcels have been acquired by the Forest Service, any future 

activities proposed by the Forest Service would follow the agency’s applicable laws, regulations 

and polices, and would be analyzed in a future NEPA document.

Ethnobotany

Huckleberry 

The transfer of the Government Camp parcels (109 acres) to private ownership and future 

development would result in the loss of prime huckleberry habitat. Huckleberry species present 

in the Government Camp parcels include big huckleberry (Vaccinium membranaceum), Alaska 

huckleberry (V. alaskaense), oval-leaf huckleberry (V. ovalifolium), and red huckleberry (V. 

parvifolium). The east parcel contains more huckleberry plants than the west parcel because of 

its more open forest habitat (dominated by lodgepole pine), allowing sunlight to reach the forest 

floor. Numbers of hikers and other recreationists go berry-picking in August in the east parcel 

because of its proximity to town, located immediately north of 1st Street. 

Huckleberry fruits are an important food source for songbirds, geese, gulls, cranes, pigeons, 

turkeys, and upland game birds (Moerman 1998, USDA-NRCS publication). Many mammals, 

from black bears to mice, feed on huckleberries. Herbivores graze on the entire plant; it appears 

to be a favorite browse of deer. Huckleberries and blueberries form a major part of the black 

bear's diet in late summer and fall. Grouse feast on the leaves and blossoms. The fruits, twigs, 

and foliage are eaten by foxes, opossums, raccoons, squirrels, deer, elk, pikas, rabbits, and 

skunks (USDA-NRCS publication). 

Huckleberry plants are an important food and medicinal source for Native Americans (Moreman 

1998). Berries are eaten fresh, dried and stored for eating later, or boiled and mashed. They are 

used in a variety of foods: breads, cakes, pancakes, muffins, pies, jams and jellies, puddings, and 

soup (Moerman 1998). The berries are a source of vitamin C and the quinic acid in the plant’s 

leaves and finely chopped stems and roots are used to treat a number of ailments: gout, 

rheumatism, arthritis, colds, glycosuria (excess sugar in the urine), hyperglycemia, and diabetes 

mellitus (Moerman 1998, USDA-NRCS publication). A first fruits ceremony or feast is held by 

many nations in the Pacific Northwest, including the Columbia Plateau Indians, the Umatilla, the 

Yakima, the Warm Springs, and the Colville Confederated Tribes (USDA-NRCS publication). 

Huckleberry feasts are held in July or August, coinciding with the first berry harvest. A 

thanksgiving ceremony is held at this time, with gratitude expressed through prayer, dancing, 

and celebration (USDA-NRCS publication).

Beargrass

The land exchange would result in the loss of beargrass populations in the two Government 

Camp parcels. Beargrass is the dominant herbaceous vegetation (forb) in the two parcels. 

Beargrass is used medicinally by Native Americans for treating wounds, to stanch bleeding, to 

wash sores, and to treat breaks and sprains (Moerman 1998). Its leaves are used by Native 

Americans for basketry, as decorative trim for mats and baskets, and to make or decorate 

clothing (dresses and belts) (Moerman 1998).

Alaska Yellow Cedar 

The land exchange would result in the loss of Alaska yellow cedar trees scattered throughout the 

two Government Camp parcels. The bark and branch tips of Alaska yellow cedar are used by 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

74

Native Americans for a variety of medicinal purposes: as a cover for poultices, to treat arthritis 

and rheumatism, as a wash for sores and swellings, as a lotion, and to treat general illness 

(Moerman 1998). Yellow cedar’s fiber is used by Native Americans to make clothing, mats, rugs, 

blankets, and bedding; basketry; bows, adz handles, paddles, boat ribs, and storage containers for 

canoes; cordage (rope); bowls and ornamental dishes; head-dresses; and sacred items (e.g., totem 

poles and talking sticks) (Moerman 1998).

Western Red Cedar

The land exchange would result in the loss of western red cedar trees scattered throughout the 

two Government Camp parcels. The leaves, bark, buds, and/or cones of western red cedar are 

used by Native Americans to treat a variety of ailments: rheumatism, colds and coughs, 

bronchitis, tuberculosis, gastrointestinal pain, toothache, kidney problems, diarrhea, venereal 

disease sores, leprosy; to cauterize sores and swellings; to relieve swelling; and to treat skin 

problems (Moerman 1998). The tree’s fiber is used for basketry; building materials; construction 

of canoes; furniture; mats, rugs, and bedding; clothing; cordage; ceremonial items; decorations; 

musical instruments; making tools; containers; fasteners; cleaning agents; and fuel (Moerman 

1998).

Invasive Plants

Many of the roads, trail sides, forest openings, and old landings in the Cooper Spur parcels are 

infested with St. John’s wort, spotted knapweed, diffused knapweed, and/or woolly mullein. St. 

John’s wort is the most common and widespread invasive plant in the Cooper Spur parcels and is 

abundant in disturbed areas. It is not surprising that spotted and diffuse knapweed are present 

since spotted, diffuse, and meadow knapweed are common and widespread on the Hood River 

Ranger District (e.g., along Highway 35, in the Lake Branch area, and elsewhere). Forest Service 

botanists should be consulted for recommendations on controlling St. John’s wort and spotted 

and diffuse knapweed in the acquired parcels. Typically, Hood River County or the Oregon 

Department of Agriculture are contracted to control knapweeds on the Hood River Ranger 

District. St. John’s wort may be difficult to tackle because it is so abundant and widespread in the 

Cooper Spur parcels and, indeed, may be beyond control.

Yellow toadflax (also known as butter and eggs) infests a dry riparian meadow located between 

the unnamed tributary immediately east of the Cooper Spur Mountain Resort and the 3510 road 

(below the house at the southernmost extent of the 3510 road in section 6). Plants are abundant. 

Once present, yellow toadflax establishes dense patches that are extremely difficult to control, let 

alone to eradicate (Fact Sheet – Alberta Invasive Species Council). Brought from Europe over 

100 years ago as an ornamental plant, yellow toadflax has escaped and has now become a 

serious problem in rangeland and mountain meadows all over North America. This perennial 

plant produces seed, but reproduction is primarily sprouting from its extensive, creeping root 

system (rhizomes). Two- to three-week-old seedlings can produce creeping roots. The ability of 

this plant to form large colonies allows it to crowd out other vegetation (Fact Sheet - Alberta 

Invasive Species Council). Control of this population will fall to the responsibility of the Forest 

Service staff.

Information on managing invasive plant populations can be obtained from the regional invasive 

plant FEIS (2005a) and the site-specific invasive plant treatments FEIS for the Mt. Hood 

National Forest and Columbia River Gorge National Scenic Area (USDA Forest Service 2008). 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

75

Survey and Manage

The conveyance of the Government Camp parcels over to private ownership for future 

development may result in the loss of individuals or the loss of potential habitat for 234 Survey 

and Manage species (December 2003 list): 192 fungi, 25 lichens, 10 bryophytes, and 7 vascular 

plants. No Survey and Manage botanical species, however, were found during informal surveys; 

therefore, it is important to clarify the either/or effect: individuals of a given species may be 

present in the parcels but were undetected during field surveys; or individuals of a given species 

may not be present, but the parcels contain potential habitat for some of the species. Thus, the 

following discussion is focused on the potential habitat for Survey and Manage botanical species 

on the Government Camp parcels.

Of the 192 fungi on the December 2003 Survey and Manage list, there is potential habitat in the 

Government Camp parcels for all of them, although it is probably unlikely that there is habitat 

for Albatrellus avellaneus (Category B), which, as far as is known, is primarily a coastal species 

with a few inland sites. Six of the 192 Survey and Manage fungi have Survey and Manage status 

in Washington and/or California, but not in Oregon: Bondarzewia mesenterica (Category B), 

Cantharellus subalbidus (Category D), Gomphus floccosus (Category F), Gymnopilus

punctifolius (Category B), Phaeocollybia olivacea (Category E), and Ramaria 

rubripermananens (Category B).

Of the 30 lichens on the December 2003 list, there is potential habitat in the Government Camp 

parcels for 25 of them. Bryoria pseudocapillaris (Category A), Bryoria spiralifera (Category A), 

and Pseudocyphellaria perpetua (Category A) are strictly oceanic/coastal species. Tholurna 

dissimilis (Category B) is a high-elevation alpine-artic lichen that has been found at timberline 

on Mt. Hood (near Paradise Park) but is unlikely to occur in the Government Camp parcels. It is 

unlikely that there is potential habitat in the Government Camp parcels for U. longissima, which 

for the most part is restricted to low-elevation riverine and stream corridors. Two species are 

listed twice because they have different management categories within the Northwest Forest Plan 

area: Dendriscocaulon intricatulum is a Category E species in California and a Category A 

species in most of western Oregon (except five counties) and in Washington. Usnea longissima

is a Category A species in California and in three counties in Oregon (Curry, Josephine, and 

Jackson) and a Category F species in the rest of Oregon and in Washington. Lobaria oregana

(Category A) only has Survey and Manage status in California. It was not found during field 

surveys, but probably does occur in the Government Camp parcels. 

Of the 15 bryophytes on the December 2003 list, there is potential habitat in the Government 

Camp parcels for 10 of them. There is only one known site for Iwatsukiella leucotricha

(Category B) in the Pacific Northwest and that is on Saddle Mountain in the Oregon Coast 

Range. The only documented site of Kurzia makinoana (Category B) in Oregon is from Coos 

County. Orthodontium gracile (Category B) is only known to occur in coastal redwood forests. 

Tritomaria exsectiformis (Category B) and Tritomaria quinquedentata (Category B) occur in 

seeps, springs, and low-gradient streams on the east side of the Cascade Range. Buxbaumia 

viridis (Category E) and Ptilidium californicum (Category A) may occur in the Government 

Camp parcels, but have Survey and Manage status in California only.

Of the 12 vascular plants on the December 2003 list, there is potential habitat in the Government 

Camp parcels for all but five of them. Botrychium minganense (Category A) and Botrychium 

montanum (Category A) occur in forest wetlands on the east side of the Mt. Hood National 

Forest; though unlikely, they could potentially occur in the Government Camp parcels. Coptis 

trifolia (Category A) occurs along the edges of dry meadows; there are known sites for it on the 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

76

east side of the Mt. Hood National Forest, but it is doubtful that there is potential habitat for it in 

the Government Camp parcels. Corydalis aquae-gelidae (Category A) occurs in coldwater 

streams at low elevations on the west side of the Mt. Hood National Forest. The majority of 

known sites on the Mt. Hood National Forest are in the Clackamas River and Oak Grove Fork 

watersheds. Cypripedium fasciculatum (Category C) occurs primarily on the east side of the 

Cascade Range. Galium kamtschaticum (Category A) and Platanthera orbiculata var. orbiculata

(Category C) appear to be restricted to northwest Washington, although they may occur in the 

Bull Run watershed and the Zigzag watershed where the climate is colder and wetter, similar to 

the climate in northwest Washington. There is potential habitat in the Government Camp parcels 

for Arceuthobium tsugense mertensianae (Category F), but this species has Survey and Manage 

status in Washington only, and there is potential habitat for Bensoniella oregana (Category A), 

but this species has Survey and Manage status in California only.

In sum, there is potential habitat in the Government Camp parcels for a total of 234 Survey and 

Manage botanical species (192 fungi, 25 lichens, 10 bryophytes, and 7 vascular plants). The 

December 2003 Survey and Manage List is provided in Appendix C of the Botany Specialist 

Report (Project Record).

There is one known site of a Survey and Manage fungus (Category B), Fayodia bisphaerigera (= 

Fayodia gracilipes), which is located between the two Government Camp parcels near or along 

Camp Creek (NRIS TESP database 2016). 

Although no Survey and Manage species were found during field review, there could still be 

individual species present on the Government Camp parcels since there is known habitat to 

support certain species. More specifically, the conveyance of the Government Camp parcels to 

private ownership could result in the loss of known habitat of 233 Survey and Manage species 

(vascular plants, bryophytes, lichens, and fungi). If individuals are present on the Government 

Camp parcels, then they would be lost once development occurs.

Sensitive Species on the Region 6 (Pacific Northwest) Regional Forester’s Special 

Status Species List

The transfer of the Government Camp parcels over to private ownership for future development 

may result in either the loss of individuals or the loss of potential habitat for 37 sensitive species 

on the Region 6 Regional Forester’s Special Status Species List (table 6). The Botany Specialist 

Report (Project Record) includes a table in Appendix D that lists the special status (sensitive and 

strategic) botanical species documented or suspected on the Mt. Hood National Forest with 

potential habitat in the Government Camp and Cooper Spur land exchange parcels.

Table 6. Number of Region 6 Sensitive botanical species with potential habitat in the land exchange 

parcels

Potential Habitat for Region 6 

Sensitive Botanical Species

Government Camp Parcels Cooper Spur Parcels

Vascular Plants 9 13

Bryophytes 7 8

Lichens 4 4

Fungi 17 16

TOTAL 37 41
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

77

No vascular plants, bryophytes, or lichens on the Region 6 Regional Forester’s Special Status 

Species List (July 2015) were found in the Government Camp or Cooper Spur land exchange 

parcels; however, sensitive fungi on the list that may be present in the Government Camp parcels 

may be affected by the land exchange. 

The following 18 sensitive fungi on the Region 6 Regional Forester’s Special Status Species List 

are either documented or suspected on the Mt. Hood National Forest and have a reasonable 

likelihood of occurring in the Government Camp and Cooper Spur parcels. Unlike surveys for 

vascular plants, bryophytes, and lichens, surveys for these fungi are not considered practical 

because their fruitbodies are (a) ephemeral (short-lived); (b) they do not fruit every year; (c) 

some (Cystangium, Macowanites, Rhizopogon) are hypogeous fungi, only fruiting belowground; 

and (d) all are difficult to find and identify (except Pseudorhizina californica). Therefore, these 

fungi are simply assumed to be present in the affected area—in this case, the Government Camp 

and Cooper Spur parcels. A brief discussion is included below for each species. Disposal and 

future development of the Government Camp parcels may have an impact on individuals or their 

habitat, but are not expected to lead to a trend toward Federal listing of any of these fungi.

1. Albatrellus avellaneus (Suspected)

2. Bridgeoporus nobilissimus (Documented)

3. Choiromyces venosus (Suspected)

4. Cortinarius barlowensis (Documented)

5. Cystangium (= Martellia) idahoensis (Suspected)

6. Helvella crassitunicata (Documented)

7. Macowanites mollis (Documented)

8. Mythicomyces corneipes (Documented)

9. Phaeocollybia californica (Documented)

10. Phaeocollybia oregonensis (Documented)

11. Pseudorhizina (= Gyromitra) californica (Documented)

12. Ramaria amyloidea (Documented)

13. Rhizopogon alexsmithii (Documented)

14. Rhizopogon brunneifibrillosus (Documented)

15. Rhizopogon ellipsosporus (Documented)

16. Rhizopogon exiguus (Suspected)

17. Rhizopogon inquinatus (Suspected)

18. Stagnicola perplexa (Documented)
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

78

1. Albatrellus avellaneus is primarily a coastal species with most collections of it from within 

32 kilometers of the Pacific Coast associated with older Sitka spruce, western hemlock, and 

Pacific silver fir forest (Species Fact Sheet, Interagency Special Status/Sensitive Species 

Program). It is documented on the Olympic and Siuslaw National Forests but also inland on the 

Spokane BLM District. For that reason, it is suspected on the Mt. Hood National Forest and 

other inland national forests and BLM districts. 

2. Bridgeoporus nobilissimus is known from several sites on the Zigzag Ranger District (Larch 

Mountain, Wildcat Mountain, the Bull Run watershed), on the far west side of the Clackamas 

River Ranger District (Goat Mountain, South Fork Mountain, and in the vicinity of Memaloose 

Lake and Williams Lake), and on nearby Salem District BLM-administered lands. There are 12 

known sites on the Mt. Hood National Forest (NRIS 2010). It is certain that the perennial conks 

of B. nobilissimus are present elsewhere on the Clackamas River and Zigzag Ranger Districts in 

forests and within road prisms wherever large-diameter noble fir or Pacific silver fir stumps, 

snags, and live trees are present. Its conks (fruiting bodies) are present year-round, growing at 

the base of large-diameter noble fir or Pacific silver fir stumps, snags, and, occasionally, live 

trees—and sometimes out of the ground. It is known from road prisms (FS road 2609 on Wildcat 

Mountain) and young plantations, where it is typically associated with remnant large-diameter 

noble or Pacific silver fir stumps or snags, but conks can also grow on small-diameter trees. 

Because Bridgeoporus nobilissimus conks (sporocarps) are perennial and, therefore, detectable 

year-round, surveys for this species are practical and required in areas with suitable habitat and 

hosts for this fungus. B. nobilissimus conks typically grow on noble fir and Pacific silver fir 

stumps, snags, and, occasionally, live trees in low- to mid-elevation forests on the west side of 

the Cascade Range. The Government Camp parcels contain suitable hosts (noble fir, Pacific 

silver fir, and western hemlock) for B. nobilissimus. 

No B. nobilissimus conks were found in the Government Camp parcels during field surveys, but 

the land exchange may impact undetected individuals or the habitat of this sensitive fungus on 

the Region 6 Regional Forester Special Status Species List. B. nobilissimus is also a Survey and 

Manage Category A species on the Survey and Manage list (December 2003). Category A means 

to manage all known sites.

3. Choiromyces venosus, in the true truffle group, forms fruiting bodies beneath the soil surface 

under Douglas-fir and western hemlock at low elevations. Only two known sites were reported 

for this species in the Northwest Forest Plan area in 1999 (Castellano et al. 1999). No known 

sites are documented on the Mt. Hood National Forest (NRIS TESP database), but the species is 

suspected to occur on the Forest.

4. Cortinarius barlowensis forms fruiting bodies on the forest floor and is associated with 

various conifers in the Pinaceae family. Known sites for this species are documented on the Mt. 

Hood National Forest (NRIS 2012).

5. Cystangium idahoensis (syn. Martellia idahoensis) forms fruiting bodies beneath the soil 

surface and is associated with the roots of Pacific silver fir, subalpine fir, noble fir, Engelmann 

spruce, and mountain hemlock from 1,200 to 1,650 meters in elevation. No known sites are 

documented on the Mt. Hood National Forest (NRIS TESP database), but the species is 

suspected to occur on the Forest.

6. Helvella crassitunicata is endemic to Oregon and Washington and grows scattered to 

gregarious on soil, especially along trails, in montane regions with Pacific silver fir, noble fir, 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

79

grand fir, and subalpine fir. There are only two known sites documented on the Mt. Hood 

National Forest (NRIS TESP database).

7. Macowanites mollis is endemic to Oregon and Washington. There is only one known site on 

the Mt. Hood National Forest (Larch Mountain). This mushroom looks like a disfigured 

specimen of Russula or Lactarius and is found in association with the roots of grand fir, 

Douglas-fir, and western hemlock above 1,000 meters elevation.

8. Mythicomyces corneipes is widespread across western North America and northern Europe 

and was reported on the Mt. Hood National Forest (Castellano et al. 2003); however, no known 

sites are documented on the Mt. Hood National Forest in the NRIS TESP database. This species 

is in the Cortinariaceae family, is solitary to gregarious in habit, and grows along margins of 

bogs among mosses or on wet soil under conifers and alder species.

9. Phaeocollybia californica is endemic to the Pacific Northwest with 34 sites known from 

western Washington, western Oregon, and northern California. There is one known site on the 

Mt. Hood National Forest (Larch Mountain) recorded in the NRIS TESP database. P. californica

is terrestrial (mycorrhizal), fasciculate (growing in close bundles) to gregarious (growing in arcs) 

in habit, and occurs in humic soils of moist coniferous (true fir, hemlock, Douglas-fir) forest and 

mixed (true fir, Pacific madrone, oak, Douglas-fir, and hemlock) coastal and coastal montane 

forests. 

10. Phaeocollybia oregonensis is endemic to the Pacific Northwest with 10 sites known from 

the Oregon Coast Range and the western Cascade Range. There are five known sites documented 

on the Mt. Hood National Forest (NRIS 2010). This mushroom species is terrestrial 

(mycorrhizal), occurring solitary to gregarious, and associated with the roots of true fir, western 

hemlock, and Douglas-fir. 

11. Pseudorhizina californica (syn. Gyromitra californica) is found from British Columbia 

south to northern California and east to Colorado, Montana, and Nevada. It is known in 

Washington, Oregon, and northern California from 35 sites, one of which is on the Mt. Hood 

National Forest (Hood River Ranger District). P. californica grows on well-rotted stumps and 

logs of conifers or in soil with rotted wood. 

12. Ramaria amyloidea is endemic to the Pacific Northwest with 16 sites known from western 

Washington to northern California. There is one known site on the Mt. Hood National Forest 

(NRIS TESP database). Habitat for the species is soil in coniferous forest. 

13. Rhizopogon alexsmithii (formerly Alpova alexsmithii), in the false truffle group, forms 

fruiting bodies beneath the soil surface and is associated with conifer trees in the Pinaceae 

family, particularly western hemlock and mountain hemlock, from 1,200 to 3,200 meters in 

elevation. There are only four known sites on the Mt. Hood National Forest (NRIS TESP 

database).

14. Rhizopogon brunneifibrillosus is a very rare false truffle with only one documented site in 

Region 6: in the former Bear Springs ranger district on the Mt. Hood National Forest (Trappe et 

al. 2009). R. brunneifibrillosus has an obligate mycorrhizal association with Douglas-fir.

15. Rhizopogon ellispsosporus is a false truffle endemic to Oregon with three reported sites: the 

Bureau of Land Management Medford District, the Siskiyou National Forest, and the Mt. Hood 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

80

National Forest. The species has been found in association with the roots of Pseudotsuga 

menziesii and scattered Pinus lambertiana at 850 meters elevation. It fruits in October.

16. Rhizopogon exiguus is a false truffle known from seven sites in the Northwest Forest Plan 

area in Washington and Oregon (Okanogan-Wenatchee, Mt. Baker-Snoqualmie, Rogue RiverSiskiyou, and Siuslaw National Forests, and the Medford District BLM). Four of the sites occur 

in the Douglas-fir series, one in the white fir/grand fir series, one in the western red cedar series, 

and one in the western hemlock series. The elevation of the sites ranges from near sea level to 

3,850 feet (USDA Forest Service Species Fact Sheet - February 2014).

17. Rhizopogon inquinatus, a false truffle, is found in association with the roots of Douglas-fir 

and western hemlock from 500 to 1,400 meters elevation. There are no known sites on the Mt. 

Hood National Forest although the species is suspected to occur on the Forest. Castellano et al.

(1999) report two sites on the Willamette National Forest.

18. Stagnicola perplexa, in the Cortinariaceae family, grows in groups on rotten wood, 

occasionally buried deeply enough to appear “rooting” in wet (or recently) dried-up depressions 

in coniferous forest. One known site is reported for the Mt. Hood National Forest (Middle Fork 

of the Salmon River) by Castellano et al. (2003); however, no known sites are listed for the Mt. 

Hood National Forest in the NRIS TESP database.

The transfer of the Government Camp parcels over to private ownership for future development 

may result in the loss of individuals or the potential habitat of some sensitive species on the 

Region 6 Regional Forester’s Special Status Species List (July 2015). Table 7 summarizes the 

effect of the land exchange on sensitive species present or with potential habitat in the 

Government Camp parcels. Individuals or the habitat of some sensitive species may be impacted 

(MIIH rating). A no effect/impact rating is given for species whose habitat is not present. 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

81

Table 7. Biological evaluation process summary by species (Region 6 Sensitive Species)

Species

Step #1

Prefield Review

Step #2

Field Reconn.

Step #3

Conflict 

Determination

Step #4

Analysis of 

Effects

Step #5

Biological 

Investigation

Habitat present in the proposed 

land exchange parcels? Species present? Conflict? Important? Needed?

Vascular Plants

Agoseris elata Yes No MIIH N/A N/A

Astragalus tyghensis No No No Impact N/A N/A

Boechera atrorubens No No No Impact N/A N/A

Botrychium lunaria Yes No MIIH N/A N/A

Botrychium montanum Yes No MIIH N/A N/A

Calamagrostis breweri No No No Impact N/A N/A

Carex capitata Possibly No MIIH N/A N/A

Carex comosa No No No Impact N/A N/A

Carex diandra Yes No MIIH N/A N/A

Carex lasiocarpa var. americana Possibly No MIIH N/A N/A

Carex livida No No No Impact N/A N/A

Carex nardina No No No Impact N/A N/A

Carex retorsa Yes No MIIH N/A N/A

Carex vernacula Possibly No MIIH N/A N/A

Castilleja thompsonii No No No Impact N/A N/A

Coptis trifolia No No No Impact N/A N/A

Corydalis aquae-gelidae No No No Impact N/A N/A

Delphinium nuttallii Yes No MIIH N/A N/A

Elatine brachysperma Yes No MIIH N/A N/A

Erigeron howellii Yes No MIIH N/A N/A

Eucephalus (=Aster) gormanii No No No Impact N/A N/A

Fritillaria camschatcensis No No No Impact N/A N/A
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

82

Species

Step #1

Prefield Review

Step #2

Field Reconn.

Step #3

Conflict 

Determination

Step #4

Analysis of 

Effects

Step #5

Biological 

Investigation

Habitat present in the proposed 

land exchange parcels? Species present? Conflict? Important? Needed?

Howellia aquatilis var. howellii 

(FEDERALLY THREATENED 

SPECIES)

No No No Impact N/A N/A

Lewisia columbiana

var. columbiana

No No No Impact N/A N/A

Lomatium watsonii No No No Impact N/A N/A

Lycopodiella inundata No No No Impact N/A N/A

Lycopodium complanatum Yes No MIIH N/A N/A

Ophioglossum pusillum No No No Impact N/A N/A

Phlox hendersonii No No No Impact N/A N/A

Pinus albicaulis No No No Impact N/A N/A

Potentilla villosa No No No Impact N/A N/A

Ranunculus triternatus 

(=R. reconditus)

No No No Impact N/A N/A

Romanzoffia thompsonii No No No Impact N/A N/A

Rorippa columbiae Yes No MIIH N/A N/A

Rotala ramosior No No No Impact N/A N/A

Scheuchzeria palustris ssp. 

americana

No No No Impact N/A N/A

Sisyrinchium sarmentosum Possibly No MIIH N/A N/A

Streptopus streptopoides Yes No MIIH N/A N/A

Sullivantia oregana No No No Impact N/A N/A

Suksdorfia violacea Yes No MIIH N/A N/A

Taushia stricklandii Possibly No MIIH N/A N/A

Utricularia minor No No No Impact N/A N/A

Utricularia ochroleuca No No No Impact N/A N/A

Wolfia borealis No No No Impact N/A N/A

Wolfia columbiana No No No Impact N/A N/A
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

83

Species

Step #1

Prefield Review

Step #2

Field Reconn.

Step #3

Conflict 

Determination

Step #4

Analysis of 

Effects

Step #5

Biological 

Investigation

Habitat present in the proposed 

land exchange parcels? Species present? Conflict? Important? Needed?

Bryophytes

Anastrophyllum minutum No No No Impact N/A N/A

Andreaea schofieldiana Yes No MIIH N/A N/A

Anthelia julacea No No No Impact N/A N/A

Barbilophozia lycopodioides No No No Impact N/A N/A

Blepharostoma arachnoideum Yes No MIIH N/A N/A

Brachydontium olympicum No No No Impact N/A N/A

Bryum calobryoides Possibly No MIIH N/A N/A

Calypogeia sphagnicola No No No Impact N/A N/A

Cephaloziella spinigera No No No Impact N/A N/A

Conostomum tetragonum No No No Impact N/A N/A

Encalypta brevicollis No No No Impact N/A N/A

Encalypta brevipes No No No Impact N/A N/A

Entosthodon fascicularis No No No Impact N/A N/A

Gymnomitrion concinnatum No No No Impact N/A N/A

Haplomitrium hookeri Yes No MIIH N/A N/A

Harpanthus flotovianus No No No Impact N/A N/A

Herbertus aduncus ssp. aduncus No No No Impact N/A N/A

Lophozia gillmanii No No No Impact N/A N/A

Lophozia laxa No No No Impact N/A N/A

Marsupella condensata No No No Impact N/A N/A

Marsupella emarginata

var. aquatica

Yes No MIIH N/A N/A

Marsupella sparsifolia No No No Impact N/A N/A

Nardia japonica No No No Impact N/A N/A

Polytrichastrum sexangulare var.

vulcanicum

No No No Impact N/A N/A
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

84

Species

Step #1

Prefield Review

Step #2

Field Reconn.

Step #3

Conflict 

Determination

Step #4

Analysis of 

Effects

Step #5

Biological 

Investigation

Habitat present in the proposed 

land exchange parcels? Species present? Conflict? Important? Needed?

Polytrichum strictum No No No Impact N/A N/A

Preissia quadrata No No No Impact N/A N/A

Rivulariella gemmipara Possibly No MIIH N/A N/A

Scapania obscura Yes No MIIH N/A N/A

Schistidium cinclidodonteum No No No Impact N/A N/A

Schofieldia monticola Possibly No MIIH N/A N/A

Tetraphis geniculata Yes No MIIH N/A N/A

Trematodon asanoi (= T. boasii) No No No Impact N/A N/A

Lichens

Hypotrachyna riparia No No No Impact N/A N/A

Leptogium cyanescens Yes No MIIH N/A N/A

Lobaria linita Yes No MIIH N/A N/A

Pannaria rubiginella Unlikely No No Impact N/A N/A

Pilophorus nigricaulis Yes No MIIH N/A N/A

Ramalina pollinaria Possibly No MIIH N/A N/A

Stereocaulon spathuliferum No No No Impact N/A N/A

Texosporium sancti-jacobi No No No Impact N/A N/A

Tholurna dissimilis No No No Impact N/A N/A

Fungi

Albatrellus avellaneus No No No Impact N/A N/A

Bridgeoporus nobilissimus Yes Assumed Presence MIIH Yes No

Choiromyces venosus Yes Assumed Presence MIIH N/A N/A

Cortinarius barlowensis Yes Assumed Presence MIIH N/A N/A

Cystangium idahoensis Yes Assumed Presence MIIH N/A N/A

Helvella crassitunicata Yes Assumed Presence MIIH N/A N/A

Macowanites mollis Yes Assumed Presence MIIH N/A N/A

Mythicomyces corneipes Yes Assumed Presence MIIH N/A N/A
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

85

Species

Step #1

Prefield Review

Step #2

Field Reconn.

Step #3

Conflict 

Determination

Step #4

Analysis of 

Effects

Step #5

Biological 

Investigation

Habitat present in the proposed 

land exchange parcels? Species present? Conflict? Important? Needed?

Phaeocollybia californica Yes Assumed Presence MIIH N/A N/A

Phaeocollybia oregonensis Yes Assumed Presence MIIH N/A N/A

Pseudorhizina 

(= Gyromitra) californica

Yes Assumed Presence MIIH N/A N/A

Ramaria amyloidea Yes Assumed Presence MIIH N/A N/A

Rhizopogon alexsmithiii Yes Assumed Presence MIIH N/A N/A

Rhizopogon brunneifibrillosus Yes Assumed Presence MIIH N/A N/A

Rhizopogon ellipsosporus Yes Assumed Presence MIIH N/A N/A

Rhizopogon exiguus Yes Assumed Presence MIIH N/A N/A

Rhizopogon inquinatus Yes Assumed Presence MIIH N/A N/A

Stagnicola perplexa Yes Assumed Presence MIIH N/A N/A

No Impact = A project or activity will have no environmental impacts on the habitat, individuals, a population, or a species because the habitats where these species occur are not 

within the affected area (the Government Camp land exchange parcels).

MIIH = A project or activity may impact individuals or their habitat, but will not likely contribute to a trend toward Federal listing of the species or a loss of viability to the species.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

86

There is a known site for the sensitive plant Suksdorfia violacea immediately east of the Cooper 

Spur parcels in section 31 (Ash Creek/Tilly Jane Creek). The S. violacea site is located on cliffs 

in the Tilly Jane Creek gorge in the NW 1⁄4 of the NW 1⁄4 of Section 32 on NFS lands. Since there 

are no ground-disturbing activities proposed at this site for this project, there would be no 

impacts to this sensitive plant site.

Cumulative Effects

Alternative 1

Since there would be no direct or indirect effects, there would be no cumulative effects. 

Alternative 2

The cumulative effect of past, present, and proposed (reasonably foreseeable) activities in the 

upper Zigzag watershed is the continued loss of forest habitat within the watershed. The 

Government Camp-Cooper Spur land exchange would result in the loss of 100 acres of forest (a 

total of 109 acres minus 9 acres of wetland in the two Government Camp parcels) in the 

watershed to land development. The Timberline Express ski runs constructed in 2006-2007 

below Timberline Lodge resulted in the loss of about 80 acres of forest comprised of mature 

Pacific silver fir and old-growth mountain hemlock (Timberline Express FEIS, USDA Forest 

Service 2005b; botany surveys 2010-2011). The Mirror Lake Trailhead Relocation project would 

result in the loss of about 0.5 acre of forest to the construction of a new parking lot west of 

Skibowl’s current parking lot. The ODOT Highway 26 safety widening project has resulted in 

the loss of about 3 to 5 acres of forest. Additionally, the Timberline downhill mountain bike park 

(17 miles of trails); Skibowl’s mountain bike trail additions (1 to 2 miles); the Mirror Lake trail 

relocation project (about 3⁄4 to 1 mile); and Mazama Lodge Parking Area Expansion project 

would contribute further to forest fragmentation in the upper Zigzag watershed. The gradual 

shrinkage of forest habitat in the upper watershed results in the loss of potential habitat for about 

37 sensitive botanical species on the Region 6 Regional Forester’s Special Status Species List 

(July 2015) and about 234 botanical species on the Survey and Manage list (December 2003).

The loss of forest habitat in the Government Camp parcels would be offset by acquisition of 769 

acres of forest in the Cooper Spur parcels; however, even though there would be a net gain in 

forest habitat as a result of this land exchange, there would still be a cumulative effect of further 

loss of forest on the south side of Mt. Hood in the upper Zigzag watershed, particularly within 

the Highway 26 corridor. This additive loss of forest habitat on the south side of Mt. Hood would 

negatively impact resident plants and wildlife in the Upper Zigzag watershed. Although there 

would be an adverse cumulative impact at the watershed-scale for botanical species, there would 

not be an adverse cumulative impact at the Forest-scale. This is due to the acquisition of forest 

lands at Cooper Spur, as well as the fact that the loss of acres at Government Camp, when 

compared to the overall acres of the Mt. Hood National Forest, is relatively small. 

Climate Change

The Council of Environmental Quality (CEQ) recently issued its final guidance for Federal 

agencies on how to consider the impacts of their actions on climate change in their NEPA 

reviews (CEQ 2016). This guidance recommends that Federal agencies analyze: (1) a proposed 

action’s effects on greenhouse gas emissions, commensurate with the extent of the effects of the 

proposed action, and (2) the effects of climate change relevant to a proposed action – particularly 

how climate change may change an action’s environmental effects. This guidance encourages 

agencies to draw on their experience and expertise to determine the appropriate level (broad, 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

87

programmatic or project- or site-specific) and the extent of quantitative or qualitative analysis 

required to comply with NEPA.

The proposed action, when implemented, would result in approximately 109 acres of land 

conveyed to private ownership where 101 acres of forest are anticipated to be developed and 

therefore would no longer be forested. Approximately 769 acres of land would be acquired, 763 

acres of which are forested. This results in a net gain of 662 acres of forested land. This addition 

would be administratively withdrawn from the suitable timber base. Another 249 acres of land 

that is currently in the suitable timber base, would become administratively withdrawn as a result 

of the connected actions (addition to wilderness). The end result in an addition of 911 acres of 

forest that would no longer be eligible for timber harvest. Regardless, this scope and degree of 

change would be minor relative to the amount of forested land on the Mt. Hood National Forest 

as a whole (1,015,854 acres). Climate change is a global phenomenon because major greenhouse 

gasses (GHG) mix well throughout the planet’s lower atmosphere (IPCC 2013). Considering 

emissions of GHG in 2010 was estimated at 49 ± 4.5 gigatonnes globally (IPCC 2014) and 6.9 

gigatonnes nationally (US EPA, 2015), a project of this magnitude makes an infinitesimal 

contribution to overall emissions. Therefore, at the global and national scales, this proposed 

action’s direct and indirect contribution to greenhouse gasses and climate change would be 

negligible. In addition, because the direct and indirect effects would be negligible, the proposed 

action’s contribution to cumulative effects on global greenhouse gasses and climate change 

would also be negligible. 

Cultural Resources and Treaty Rights

Cultural resources are not directly related to the purpose and need of this project. Concerns 

identified during scoping included the loss of an eligible historic property and the Mt. Hood 

National Forest’s ability to fulfill treaty rights on the Forest Service parcel of land that would be 

conveyed to Mt. Hood Meadows, LLC.

Mt. Hood National Forest, including the project area, contains ceded lands for the Confederation 

Tribes of Warm Springs. As such the tribes have rights to traditional cultural properties on ceded 

lands. The Confederated Tribes of Grand Ronde also are recognized as having traditional use 

rights to lands encompassed by Mt. Hood National Forest, including the project area.

Indian Tribes can be affected by the policies and actions of the Forest Service in managing the 

lands and resources under its jurisdiction. Therefore, the Forest Service has a duty to consult 

with them on matters affecting their interests, such as the proposed project. Efforts were made to 

honor the government-to-government relationship by involving local tribal governments and 

soliciting their input regarding the proposed action.

The legal framework that requires the Forest Service to consider effects on cultural resources, 

traditional cultural uses, and treaty rights is fairly extensive. For all forest actions, section 106 of 

the National Historic Preservation Act of 1966 (amended in 1976, 1980, and 1992) is the 

foundation for all cultural resources management concerns in Federal agencies during the 

planning and implementation phase. Additional regulations that support and enhance the 

National Historic Preservation Act are disclosed in chapter 2 of this DEIS and in the Cultural 

Resources Specialist Report (Project Record). 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

88

Affected Environment

Existing Condition

The prehistory and history of the Government Camp and Cooper Spur areas have been 

documented and compiled in several publications. Those used for this analysis include, Cultural 

Resource Overview for the Mt. Hood National Forest (Burchard 1991), An Ethnographic Study 

of the Mt Hood National Forest, Oregon (French 1995), Archaeology of Oregon (2nd Edition) 

(Aikens 1986), and many other publications. These documents provide adequate detail of 

ethnographic and historic background for this project-level analysis.

Prehistoric Use

There is little specific information available regarding pre-contact use of the Mt. 

Hood/Government Camp Area. The Government Camp area has been identified as an important 

traditional use area for the Molala, Tygh Valley, Wasco and Northern Paiute people during the 

ethnohistoric period.

Huckleberries were an important traditional food for Northwest Indians, and they were usually 

picked in quantities and processed for winter use. Aside from huckleberries, Indian people also 

collected the raw material needed to make baskets while in the mountains. These materials 

included cedar roots, cedar bark, beargrass, and willow. Strips of cedar bark were peeled from 

living trees in order to make ridged, folded bark baskets. When coiled berry baskets were filled, 

bark baskets could be made at the camp to hold the surplus of berries and transport them back to 

villages. Most ethnographic sources emphasize the importance of the huckleberry grounds south 

of Mt. Hood were considered shared territory, and were used jointly by neighboring groups on 

both sides of the Cascades.

Historic Use

The project area is located in an area of extensive historic activity, associated with both the 

Barlow Road/Oregon Trail and with recreational development at Government Camp. The Barlow 

Road was initially constructed between 1845 and 1846 as a wagon route across the Cascades, 

and it was used as an alternate route for pioneers following the Oregon Trail. It passed through 

the center of the Government Camp area, immediately south of the project area. The 

Government Camp area received its name after an army wagon train following the Barlow Road 

reportedly abandoned a number of wagons at the spot in 1849. Recreational development of the 

area began in the 1880s. The 1884 General Land Office plat for Township 3 South, Range 81⁄2 

East does not show any settlers in the Government Camp area, but it does show the “Mt. Hood 

and Barlow Wagon Road” in Section 23, and the “Trail running N.E. to foot of Mt. Hood” 

running diagonally across the south 1⁄2 of Section 14. 

In spite of the elevation, several early homestead claims were filed in what is now Government 

Camp. General Land Office Survey notes for Township 2 South, Range 8 East (Lacklund 

1884:505) indicate that a man named Severs had located a homestead in the NE1⁄4 Section of 24 

(immediately south of the project area) in 1884. Oliver C. Yocum reportedly began visiting the 

Government Camp area as early as 1884, and by 1892 he filed a homestead claim in Section 23. 

He built a hotel on his claim in 1899, called the Mountain View House (later the Government 

Camp Hotel). A portion of the easternmost project parcel was within the original homestead 

claim of Francis C. Little, a founding member of the Mazamas in 1894. His homestead was often 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

89

used as a camp during early Mazama outings. He exchanged all but 40 acres of his claim 

(including the present project area) to the U.S. Government in 1901. 

In the early 1900s Oliver Yocum platted parts of his land claim at Government Camp in blocks, 

and called the plat Pompeii (Grauer 1975). The name Government Camp was well-entrenched by 

this time, however, and the town eventually acquired that name. Elijah Coalman bought Yocum’s 

hotel in 1910, and it burned in 1933. Everett Sickler and Albert Krieg built the Battle Axe Inn in 

1925, and it burned on November 7, 1950. The Rafferty’s built and ran a hotel next to the Battle 

Axe Inn. It changed hands and names (Tyrolean Lodge, Mountain View Inn) over time, before it 

burned down in 1955. 

The Mt. Hood Loop Highway was constructed in 1925. In 1926, the south side of Mt. Hood was 

declared a “Recreation Area”. The Skiway Lift, an aerial tram that connected Government Camp 

to Timberline Lodge, was built between 1948 and 1951. It crossed the project area. A large 

building was built at the lower end of the lift in 1949, immediately south of the project area, with 

a restaurant, rest rooms, and a waiting lounge. The tram was not successful and closed after only 

a few years in operation. The towers were removed in 1961. The terminal building at the base of 

the lift was purchased and expanded into a hotel called the Thunderhead Lodge. The Skiway 

Trail was completed for hikers, bikers, and skiers several years later. This trail, as well as several 

others including the Crosstown Trail, Maggie’s Trail, Lucy’s Trail, and the Alpine Loop are 

modern and continue to be used today.

From modern ethnographic data, the government camp area continues to be an active area of 

traditional cultural use by both the Confederated Tribes of Warm Springs (CTWS) and 

Confederated Tribes of Grand Ronde (CTGR). Oral history interviews confirm the very active 

use of the Government Camp area for traditional use of various resources within the APE.

Cooper Spur Area

The East Fork of Hood River is a perennial tributary to the Hood River, which flows directly into 

the Columbia River. Glacially fed tributaries to the drainage within the project area include 

Polallie Creek, Tilly Jane Creek, Doe Creek (tributary to Tilly Jane Creek) and Buck Creek. As a 

largely glacial stream, the East Fork of Hood River provided a gateway onto the slopes of Mount 

Hood for both Native Americans and early pioneers. 

Relatively few archaeological excavations have been conducted within or near the project area, 

and little is known about the prehistory of the region. There is some evidence that huckleberries 

and other plant resources were gathered, along with hunting forays for deer, elk, and other 

wildlife. Huckleberries remain numerous along the lower slopes of the Cloud Cap-Tilly Jane 

National Historic District. 

Current and past hiking trails likely followed earlier Indian trails. One such trail is the Polallie 

Ridge Trail with its earliest indications on a 1912 Oregon National Forest map, where it is shown 

as an intermittent dotted line. The Polallie Ridge Trail most likely followed an earlier Native 

American trail for summertime exploitation of alpine resources. Another trail on the same map 

extends east from the East Fork Hood River, steeply ascending the steep west-facing slopes, to 

continue on to Brooks Meadow. The 1914 General Land Office plat map for Township 2 South, 

Range 10 East shows the two previous trails as part of the “Trail from Brooks Meadow to 

Parkdale and Cloudcap Inn.” Another early trail is shown heading upstream along the East Fork 

Hood River as far as Robinhood Creek. By 1916 the trail had extended south to connect to the 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

90

Barlow Road. Another early trail is simply labeled “old trail” and travels north along Surveyor’s 

Ridge from the Brooks Meadow Trail. 

In the 1880s, David Cooper, Henry Coe and Oscar Stranahan decided that they should capitalize 

on the tourism brought to Hood River by the railroad with the construction of a mountain resort. 

The three started construction on a wagon road up the mountain following Indian trails, but were 

eventually blocked by brush and wind-blown trees. Aided by a “wild” fire, they eventually 

finished their toll road and erected a tent camp at Tilly Jane Meadows, named after one of their 

first visitors, Tilly Jane Ladd. They charged $1.00 for camping and $10.00 for the wagon ride to 

and from the tent camp. In 1888, Cooper’s company sold their interest to William Ladd, who 

went on to finance the construction of Cloud Cap Inn in 1889. 

The upper portion of the East Fork Hood River remained bypassed by meaningful transportation. 

The Barlow Wagon Road skirted around the south side of Mount Hood. The wagon road from 

the valley rest area up to Cloud Cap Inn was the only development through the area until the 

construction of the Mount Hood Loop Highway in 1925. 

The construction of the Mount Hood Loop Highway was an idea largely supported by the 

tourism and agricultural industries in Hood River and the upper valley. Local residents Homer 

Rogers and J. O. Hannum participated in the selection of the route for the highway. In addition to 

operating the Mt. Hood Lodge, Rogers also acquired the Cloud Cap Inn while Hannum 

constructed the Homestead Inn at the Cooper Spur Junction in 1922 in anticipation of tourism. At 

that time, the Loop Highway was usually closed due to snow, and the junction was situated at the 

end of the road. However, neither the Lodge nor the Homestead Inn realized expectations and 

both establishments were gone by the 1930s. The highway unlocked the previously inaccessible 

areas along the East Fork of Hood River to automobiles, and expanded opportunities for 

recreation and timber harvest. Campgrounds along Robinhood Creek and Hood River Meadows 

were developed and improved through the 1920s. 

By this time, Sand Creek had been renamed Polally Creek and the Mount Hood Loop Highway 

had been completed. According to Oregon Geographic Names (McArthur 2003), the Forest 

Service began a campaign of replacing mundane or repetitious place names in the 1920s, and 

Sand Creek was widely used. The spelling later changed to Polallie, which was believed to be 

Chinook jargon meaning powdery or sandy; however, George Gibb believes that the name 

derives from the French word poudre and was not originally Chinook or Chehalis. 

The construction of the Loop Highway affected the overall philosophy of the Forest Service to 

incorporate recreation and public access into its management. A new road was constructed to 

Cloud Cap Inn in 1926, along with construction of the Tilly Jane Guard Station and campground. 

The Civilian Conservation Corps (CCC) contributed further to the recreational development of 

the area and may have added stone culverts to the Cloud Cap Road, made improvements to the 

Tilly Jane Campground, constructed the Tilly Jane Warming Hut, and may have built a 

campground at the mouth of Polallie Creek. The CCC also constructed another warming shelter 

in the Cooper Spur area and may have improved a ski trail down from the Tilly Jane Warming 

Hut. 

Downhill skiing lessons were offered at the Mt. Hood Lodge as early as 1913, and Hannum 

began brushing an area for the sport in the 1920s. In the 1940s, local residents resurrected the 

area near the Cooper Spur junction for skiing, which is now managed and operated under a 

special use permit.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

91

Environmental Consequences

Direct and Indirect Effects

Alternative 1

The implementation of this no-action alternative would not result in any earth disturbance or 

visual effects. The project area would remain at its current existing condition. There would be no 

effect to heritage resources under Alternative 1, other than the natural process that are already 

occurring on the landscape. This alternative would allow for the continued use of ceded lands for 

both the Confederated Tribes of Warm Springs and Confederated Tribes of Grand Ronde.

Alternative 2

Lands to Be Conveyed (Government Camp Parcels)

Cultural Resources

The two National Forest System parcels located within the lands to be conveyed contain three 

potentially eligible cultural resources: 1) Skiway Trail; 2) Mt. Hood Ski Patrol Building; and 3) 

Summit Ski Area. On the westerly parcel there is the Skiway Trail, which is potentially eligible 

as a historic trail. As a result of the proposed action, effects to the Skiway Trail would be a 

reduced trail easement that could potentially damage the integrity the trail. The smaller the trail 

easement, the greater there is for potential impacts to this trail. Additionally, indirect effects to 

the Skiway Trail would be loss of feeling, setting, and association of the resource as the forested 

landscape around the trail is converted to non-forested lands. 

The Mt. Hood Ski Patrol Building is an eligible cultural resource. Any eligible cultural resource 

on the lands to be conveyed, such as the Mt. Hood Ski Patrol Building, would be considered an 

adverse effect by the State Historic Preservation Office (SHPO) as a result of change in 

ownership from Federal to private ownership. More specifically, SHPO considers the change in 

ownership from Federal to private ownership an adverse effect due to the fact that compliance 

with Section 106 under the National Historic Preservation Act (NHPA) can no longer be applied. 

Section 106 review applies only to projects occurring on Federal lands or with Federal funding. 

For this reason, the land exchange would result in an adverse effect under Section 106 of NHPA 

for the Mt. Hood Ski Patrol Building. Currently, consultation with SHPO is underway for this 

property, which will provide a determination of effects.

Immediately adjacent to the easterly parcel there is an eligible historic site and a potentially 

eligible historic district, Summit Ski Area. A potential effect resulting from this land exchange to 

the Summit Ski Area could be the loss of setting and feeling on the east boundary of the parcel, 

which could be considered an adverse effect under Section 106 of NHPA. Currently, consultation 

with SHPO is underway for this site and historic district, which will provide a determination of 

effects.

Treaty Rights

The two National Forest System parcels located within Government Camp are identified as 

ceded lands to the Confederated Tribes of Warm Springs (CTWS) and Confederated Tribes of 

Grand Ronde (CTGR). The CTWS signed the Treaty with the Tribes of Middle Oregon in 1855. 

Several tribal groups ceded to the U.S. Government approximately 10 million acres of land south 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

92

the Columbia River between the Cascade and Blue Mountain ranges. The groups that became the 

Confederated Tribes of the Warm Springs Reservation also reserved 578,000 acres south of the 

Columbia on the Deschutes, Warm Springs, and Metolius rivers for their exclusive use. The 

treaty also preserved the groups’ traditional practices of traveling to various off-reservation sites 

for fishing, hunting, and gathering. Included within the 10 million acres of land south of the 

Columbia River was the 109 acres within the Government Camp parcels as well as 769 acres in 

the Cooper Spur parcels.

The treaty with the Confederated Bands of Kalapuya (1855) is the only ratified treaty with the 

Kalapuyan groups who are indigenous to the Willamette Valley. The treaty dispossessed the 

Kalapuyans and their descendants of their aboriginal lands and effectively transferred the 

Willamette Valley to non-Indians. Between 1851 and 1855, the Kalapuyans faced increasing 

harassment and encroachment by American settlers. Finally, in January 1855, Superintendent of 

Indian Affairs Joel Palmer met with Kalapuyans, several bands of the Clackamas Chinook, and 

northern Molala peoples at Dayton and negotiated another treaty with the Confederated Bands of 

the Kalapuya, also known as the Bands of Willamette Valley Indians. The details on the exact 

location of the reservation for the Kalapuyans were left vague, largely due to the tense and often 

violent nature of settler-Indian relations in western Oregon during the early 1850s (the Rogue 

River War was then raging in southern Oregon). In order to resolve the problematic issue of 

where to relocate the state's Native peoples, the original Coast Reservation was created by 

executive order in 1855. It was intended to be the home for the Coast, Umpqua, and Willamette 

Valley groups and a majority of the Rogue River peoples. This vast tract, roughly one-third of 

the Oregon coast, included the area that later became the original Grand Ronde Reservation in 

1857. The Kalapuyans, Clackamas, and Mollala of the Willamette Valley were forcibly removed 

from the Willamette Valley to Grand Ronde Encampment during the winter of 1855-1856.

Although the Federal Government terminated its trust relationship with the Confederated Tribes 

of the Grand Ronde Indian Reservation in 1954, the ratified treaties with the tribes, including the 

Kalapuya Treaty of 1855 (also called the Willamette Valley treaty), played an important role in 

the tribes' successful bid for restoration and community revival in the 1980s. Following the 

Confederated Tribes' restoration in 1983, treaty obligations were again recognized, allowing for 

government-to-government negotiations on a variety of issues.

Direct effects include loss of ceded land in the amount of 109 acres to the CTGR and CTWS. 

Additional direct effects include the increase in access to ceded land for CTWS on the Cooper 

Spur parcels. 

Lands to be Acquired (Cooper Spur)

Cooper Spur Ski Area

The Cooper Spur Ski Area includes approximately 60 acres with one double chair, one rope tow, 

and two tube tows to make a total of ten ski runs. The “Jump Hill” within the ski area is 

potentially eligible. In the proposed action, the Forest Service would put the ski area under 

special use permit, and the site would remain in existing use with no effect to the resource. If the 

Forest Service does not find a potential candidate for the special use permittee after the transfer, 

the area would be decommissioned. 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

93

Cooper Spur Mountain Resort

The Cooper Spur Mountain Resort consists of 11 different structures from 1942 to 1986. None of 

the structures in the resort complex are eligible resources and would remain in their existing use. 

None of the structures are eligible resources and the decommissioning of the Cooper Spur 

complexes would have no effect to historic resources unless ground disturbance occurs. 

Vacant Forest Land

These parcels are a mixture of pre-merchantable plantations and second-growth timber stands. 

There would be no direct effects to cultural resources under the proposed action, other than the 

natural process that are already occurring on the landscape. This area is identified as ceded land 

for CTWS. CTWS would gain 769 acres of ceded land on the east side of Mt. Hood (Cooper 

Spur parcels). Existing CTWS ceded land that was once under private ownership would change 

to administration under the Forest Service. This would be a benefit to CTWS, as the Forest 

Service would fulfill its trust responsibility on these lands as opposed to a private owner who 

would not be obligated to do so. 

A loss of CTWS ceded land in the Government Camp parcels (109 acres) and the addition of 

ceded land in the Cooper Spur parcels (769), there is a total of 655 acres of increased access to 

CTWS ceded land.

Connected Actions

The proposed action also provides that upon completion of the land exchange, additional lands 

would be considered part of the Mt. Hood Wilderness and the Crystal Springs Watershed Special 

Resources Management Unit would be created. The new addition to the Mt. Hood Wilderness 

and the creation of the Management Unit would not affect heritage resources since these are 

administrative actions not resulting in disturbance to cultural resources and historic properties. 

Further, the proposed Forest Plan amendment to include management direction for A14-Crystal 

Springs Watershed Special Resources Management Unit provides management direction for the 

Tilly Jane-Cloud Cap Historic District that is similar to how the historic district is currently 

being managed. Therefore, there would be no impacts to how cultural resources and historic 

properties in this area are managed and protected.

Summary of Direct and Indirect Effects

In sum, the effects of the proposed land exchange would be a loss of ceded land for both the 

CTGR and CTWS. CTGR would lose 109 acres of ceded land based on the lands to be conveyed 

(Government Camp parcels). Existing CTWS ceded land that was once under private ownership 

(Cooper Spur) would change to administration under the Forest Service. A loss of CTWS ceded 

land in the Government Camp parcels (109 acres) and the addition of ceded land 769 acres 

(Cooper Spur) would result in a total of 655 acres of increased access to CTWS ceded land.

Forest Plan Amendment Effects Summary

A total of 1,109 acres would change from Land Use Allocation designated as Winter Recreation 

to Wilderness, decreasing potential effects to cultural resources by motorized recreational use. 

Approximately 769 acres of Cooper Spur acquired lands and 2, 110 acres of existing Federal

lands to be included in the Crystal Springs Watershed Special Resources Management Unit. The 

Crystal Springs Watershed Special Resources Management Unit is designated to focus on the 

protection of the Crystal Springs Watershed as the primary goal for the land use allocation.

Within this new land use allocation is the Cloud Cap-Tilly Jane Historic District, which was 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

94

designated a Special Interest Area (because of the historic designation of the district) in the 

current Mt. Hood National Forest Land and Resource Management Plan. In order to continue the 

protection and preservation management direction for the future for the Cloud Cap-Tilly Jane 

Historic District the management guidelines for the Special Interest Area and the Cloud CapTilly Jane Historic District have been incorporated into the new Crystal Springs Watershed 

Special Resources Management.

Cumulative Effects

The past, present, and reasonably foreseeable projects listed in the table at the beginning of this 

chapter were considered for their potential to add to the effects of this project on cultural 

resources, traditional uses, and treaty rights. 

Alternative 1

Since no direct or indirect effects would result from this alternative, there can be no cumulative 

effects. 

Alternative 2

Cultural Resources

Of the projects listed in the beginning of this chapter, there are two activities that have the 

potential to result in a cumulative impact on cultural resources. Specifically, in the westerly 

parcel of the lands to be conveyed (Government Camp), there is a Portland General Electric 

transmission line that was constructed with a large right-of-way and there are several Forest 

Service (non-historic) trails. The construction and management of the transmission line, as well 

as the trails, have incrementally impacted the integrity of the Skiway Trail. Over time, continued 

maintenance needs for the transmission line and trails have used the Skiway Trail as an access 

route. The potential impacts to the Skiway Trail resulting from the land exchange, cumulatively 

added to the past, present and future impacts associated with maintaining the powerline and 

trails, could further degrade the integrity of this potentially eligible cultural resource. 

The activities related to the transmission line and trails have no effect on the Mt. Hood Ski Patrol 

Building or the Summit Ski Area; therefore, there would be no cumulative impacts on these two 

potentially eligible sites. Also, there are no other reasonably foreseeable projects that have the 

potential to affect any cultural resources within the area of potential effect.

In regards to cultural resources on the Hood River Ranger District, the only activity with 

potential cumulative impacts are Forest Service vegetation treatment activities planned near the 

lands to be acquired. However, they would not affect any known cultural resources in the area as 

the agency has completed Section 106 review related specifically to the projects in this area. Past 

timber harvest and agricultural activities on private land have occurred within the acquired lands, 

but did not affect any known cultural resources to the agency. Future vegetation treatment 

activities on the Hood River Ranger District would be required to comply with Section 106, in 

which the potentially eligible Cooper Spur Ski Hill would be identified for protection. There are 

no other direct or indirect effects to cultural resources so cumulative effects were not further 

assessed.

However, because would not affect any known cultural resources in the area as the agency had 

conducted Section 106 review related specifically to the project in these areas. Past timber 

harvest and agricultural activities on private land have occurred within the acquired lands, but 

did not affect any known cultural resources to the agency. Future vegetation treatment activities 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

95

in the area would be required to comply with Section 106 of the National Historic Preservation 

Act, in which the potentially eligible Cooper Spur Ski Hill would be identified for protection. 

There are no other direct or indirect effects to cultural resources so cumulative effects were not 

further assessed.

Traditional Uses and Treaty Rights

There are two projects within the Area of Potential Affect (APE) of the Government Camp 

parcels that have the potential for cumulative effects to traditional uses and treaty rights: (1) 

Mirror Lake Trailhead Relocation Project; and (2) Mazama Lodge Parking Area Expansion 

Project. Both of these projects propose to convert forest land into parking areas. The proposed 

action, combined with the conversion of the forested lands into parking areas, would be a 

continuation of a loss of ceded land for the CTWS and CTGR. However, both of projects cover 

no more than two acres, which is a relatively small percentage of overall ceded lands for both 

tribes. Since both projects are relatively small in size, in previously disturbed areas, and in or 

near existing special uses permit areas, cumulative effects would be minor.

Facilities

Introduction

The information provided in this section was derived from the Cooper Spur Resort Property 

Condition Survey, March 2012 and the Government Camp-Cooper Spur Land Exchange 

Facilities Report, July 2016. Both documents are filed in the project record. 

The Forest Service currently owns one structure in the Government Camp parcel, which is the 

Mt. Hood Ski Patrol building. This structure is currently being used by the Mt. Hood volunteer 

ski patrol. Through the land exchange, all improvements to the land would become property of 

Mt. Hood Meadows, thereby removing the Ski Patrol building from the Mt. Hood National 

Forest facility inventory.

Depending on the outcome of the appraisal equalization process, the Forest Service may acquire 

a significant number of structures that comprise the Cooper Spur Ski Area and Mountain Resort. 

However, the assumption for this analysis is that the Forest Service would acquire the structures 

along with the lands. The following described infrastructure at the ski area is considered in the 

estate to be conveyed: ski lift system comprised of one double chair, one rope tow and two tube 

tows; a day lodge, A-frame cabin, first-aid station, four multi-purpose buildings, instructor's hut, 

and pump house. The day lodge is the primary building with kitchen and dining area on the main 

floor, additional seating area in a loft, and lift ticket/equipment rental in the lower daylight level. 

Restrooms are housed in one of the multi-purpose buildings. In addition, there is a private well 

water system, irrigation system, and septic system.

The Cooper Spur Mountain Resort is located about two miles east of the Cooper Spur Ski Area 

at the intersection of Cooper Spur and Cloud Cap roads. The resort site consists of 11 different 

structures. The registration desk portion of the restaurant building and the Homestead Cabin 

were built in 1942. The restaurant addition and all other structures were added in 1985-1986. 

There are five log cabins of 1,200 square feet, each with a kitchen area, living room and 

fireplace, two bedrooms and one bath on the main floor. The resort also includes spas, storage, 

tennis court, equipment storage and shop, and a single-family residence. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

96

In addition to the cabins and restaurant, there are several septic tanks that lead to a single leach 

field northeast of the improvements. A well with well house and another small building are 

located on Tax Lot 401. Another recently installed well is located on Tax Lot 102.

The public expressed concern over the ability of the Forest Service to care for and manage these 

newly acquired facilities. They were interested in the plans the Forest Service has for the future 

use and management of the resort and ski area, and the condition the facilities to be acquired are 

in.

Condition assessments for the facilities to be acquired have been conducted. A number of 

inadequacies were identified that would need to be addressed before they could be opened for 

public use. A special use permit would also need to be developed for the future operation of the 

Cooper Spur Mountain Resort. A prospectus would be sent out for review and response by 

interested citizens. If there was no interest or the respondent could not prove their ability to 

maintain the facility to specific standards as outlined in the prospectus, the resort and/or ski area 

would be decommissioned.

Affected Environment

Existing Condition

The Cooper Spur Mountain Resort facilities were mostly constructed in the 1980’s with one 

building originating in 1917, called the Cooper Spur Inn. The resort has 18 structures with most 

of the structures situated around the Cooper Spur Inn, 15 total. The other facilities are located 

near the ski area with the day lodge and other support buildings. The majority of the structures in 

both locations are log construction but there are a few light framed wood and pole barn 

structures. The lower portion of the site is located at approximately 4,000 feet with the ski area at 

4,350 feet above mean sea level. The terrain is mountainous with the lodge site dropping 

approximately 80 feet in grade. Access to the resort area is directly adjacent to Cooper Spur 

Road. Cooper Spur Road is a paved loop that starts and ends at Highway 35. The Cooper Spur 

Inn and the day lodge each have their own paved parking areas, with some short paved routes to 

the rental cabins.

While the facilities near the day lodge only see seasonal use, dependent on snow accumulation, 

the facilities around the Cooper Spur Inn are used year round, with most of the usage peaking in 

the winter months. The condition survey of 2012 noted that, “the overall condition of the various 

structures on the property ranges from poor to good, but the majority of the structures are in 

good condition” (USDA 2012). The properties have ongoing preventative maintenance and 

improvements have been made to various structures. There were not any signs of pest 

infestations or hazardous materials during the 2012 visual site observation.

Some utilities in the resort area are handled on-site and do not connect to county or city services. 

All water is accessed by an on-site water system provided by wells and wastewater is disposed of 

through a septic system that flows into drain fields. The electrical service is provided 

commercially by Pacific Power and runs to the transformers and meters where the user then 

becomes responsible for maintenance. The phone system consists of individual lines running into 

each unit. There was no central system. There were wireless routers in the rental cabins and the 

lodge/motel. 

The Mt. Hood National Forest Facilities Master Plan (FMP) is incorporated into this analysis by 

reference (USDA 2015). It provides context for how the facilities that would be acquired through 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

97

this land exchange would be evaluated and addressed. Per the FMP, “The goal of this FMP was 

to evaluate the facilities of the Mt. Hood NF and develop an intelligent investment roadmap for 

the future by identifying optimum facility locations to meet the needs of the Forest and become 

more sustainable. This document lays out the criteria used to evaluate facilities, including 

historic value, forest needs, and management direction, and the reasons why recommendations 

were made within this FMP. The FMP was successful in recommending that 99 buildings of the 

197 existing administrative buildings be removed from the administrative inventory. It is 

recognized that while this is a large reduction in the facility footprint, additional reductions may 

be needed in the future to reach the goal of sustainability with future budgets. This FMP is a 

living document and will be revisited as appropriate with this goal in mind.”

Environmental Consequences

Direct and Indirect Effects

Alternative 1

Under the no-action alternative, the facilities would continue to be maintained and managed by 

Mt. Hood Meadows. The Property Condition Assessment states that, “the property appears to 

have ongoing preventative maintenance and improvements to the various structures” (USDA 

2012). Also, the Mt. Hood Ski Patrol building would remain under Federal ownership.

Alternative 2

With the acquisition of the facilities at the Cooper Spur Mountain Resort and Ski Area, the 

Forest Service has the option to retain the buildings or consider them excess, depending on the 

outcome of the prospectus process for issuing a special use permit. Under the proposed action, 

the Mt. Hood Ski Patrol building would no longer be managed by the Forest Service.

Special Use Permit

If the buildings are retained, as stated in the proposed action description, they would need to be 

operated under a special use permit with a concessionaire. There is an option in which the 

buildings could be owned and operated by the concessionaire, and a special use permit would be 

required for conducting business on Federal lands. Another method of a special use permit is 

through the Granger-Thye Act, where the Forest Service would continue to own the buildings, 

but they would be operated by the concessionaire. Some examples of these agreements made 

through the Granger-Thye Act in the Pacific Northwest include Timberline Lodge, Multnomah 

Falls, and Cloud Cap Inn. In this scenario, a Request for Proposals would be advertised for what 

could include the operation of the ski resort, rental facilities, and Cooper Spur Mountain Resort. 

The benefit of using this particular special use permit is that day-to-day operations are the 

responsibility of the concessionaire with Forest Service oversight and stipulations. In either 

scenario, a percentage of the revenue would be earmarked for deferred maintenance, renovations 

and upgrades for accessibility.

Accessibility

With the buildings coming under Federal ownership, there would need to be upgrades to meet 

the accessibility requirements of the Architectural Barriers Act (ABA), as summarized below. A 

transition plan would need to be developed to ensure that the structures would meet accessibility 

requirements as renovations occur.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

98

In the Cooper Spur Inn, the entrance would need to be replaced with a 32-inch doorway and 

handles with levers that can be opened with a closed fist. A 36-inch path of travel would need to 

be added from designated parking areas to waiting areas, restrooms, food bars and entertainment 

areas. The men’s restroom in the lobby would require reconstruction to become accessible.

The spa area would require upgrades to the access gate and handles for accessibility. There 

would need to be a 36-inch path from a parking spot or other location to meet accessibility 

requirements.

The hotel would require upgrades to comply with the ABA. Upgrades would include power 

assisted opening outside doors and replacement of door handles with lever styles. To meet 

accessibility in the restrooms, the showers would need to be replaced without lips, toilets moved 

to the acceptable height, and the grab bars should be added. In the living areas, countertop 

heights may need to be adjusted. In the communal areas, the weight room and laundry room may 

need to be modified. Lastly, a designated parking stall and 36-inch path from the parking to the 

entrance would need to be provided. According to Table F224.4 in the Architectural Barriers Act 

Standards, only one room would need to be made accessible.

The following buildings would need to be reevaluated for accessibility compliance: The 

Homestead Suite, the five Rental Cabins, the Log Home, the Day/ Ski Lodge, the A-Frame 

Cabin, and the First Aid Station. It appears there are some elements in most of these buildings 

that would need to be upgraded to meet ABA requirements.

Table 8 summarizes some of the accessibility upgrades that would be required by the ABA with 

their estimated costs for reconstruction. The Property Condition Assessment did not provide 

many cost estimates for accessibility upgrades (USDA 2012). Prices without a 2012 cost are a 

rough government cost estimate from RS Means 2002 cost estimating guide, adjusted for an 

inflation of 34 percent (RS Means 2002). If the cost for an accessibility upgrade is not listed in 

the table below (e.g., costs for the weight room and laundry room), then the estimated cost is 

unknown.

Table 8. Estimated cost for accessibility upgrades

Building Corrective Action for 

Accessibility Estimated Cost (2012) 5% inflation (2016)

Cooper Spur Inn Site access ramp $ 1,834.00 $ 1,925.70

Replace entry door $ 1,418.46

Men’s restroom $ 1,662.54

Spa Site access $ 1,750.00

Hotel Site access $ 1,750.00

Replace entry door $ 1,418.46

Bathroom upgrade $ 1,804.71

Total $11,729.86

Life and Safety

In addition to accessibility upgrades, there were some urgent corrections needed to a few of the 

buildings to make them safer for public use identified in the Property Condition Assessment 

(USDA 2012). The total cost for all activities needing corrections is approximately $38,895. 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

99

From those urgent corrective actions, the table below is a summary of actions that are needed for 

life and safety upgrades.

The Cooper Spur Inn has modified electrical panels and older electrical wire that is incorrectly 

installed and would need to be remedied immediately. Loose wires are a fire hazard and should 

be corrected upon ownership of the building. The equipment shop has a similar issue with loose 

wiring that would need to be corrected by providing conduit. Other buildings that need electrical 

work are the A-Frame Cabin and the Homestead Suite. Also, the Log Home electrical panel 

needs to be relocated. 

The rental cabins and hotel need some renovations to their water system. The hotel and rental 

cabins need domestic water cross connections; and circulating hot water system needs to be 

installed to meet current energy code requirements. 

A number of buildings need structural upgrades. In the Cooper Spur Inn, a few beams need to be 

replaced and some floor beam connections are needed. The foundation for the Homestead Cabin 

needs to be installed in the north section and replaced in the south section. The A-Frame Cabin 

needs the balcony replaced and there are some connections in the Ski Lodge deck that need new 

connections in the stairs and better anchorage of the fabric canopy.

Table 9. Corrective action for life and safety

Building Corrective Action for Safety Estimated Cost 

(2012)

5% Inflation 

(2016)

Cooper Spur Inn Electrical upgrade $ 13,180.00 $ 13,839.00

Fire service connections $ 2,525.00 $ 2,651.25

Sprinkler piping $ 1,380.00 $ 1,449.00

Structural upgrade $ 1,286.00 $ 1,350.30

Equipment Shop Electrical upgrade not determined unknown

Rental Cabin (1-5) Domestic water cross connections $ 1,080.00 $ 1,134.00

Homestead Suite Electrical upgrade $ 3,000.00 $ 3,150.00

Spa Signage for chemical storage $ 50.00 $ 52.50

Hotel Domestic water cross connections $ 840.00 $ 882.00

Laundry room ventilation $ 250.00 $ 262.50

Hot water recirculation system $ 1,125.00 $ 1,181.25

Log Home Relocate electrical panel $ 5,050.00 $ 5,302.50

Ski Lodge Decks Structural connections $ 2,357.00 $ 2,474.85

A-Frame Cabin Bury wires in conduit $ 219.00 $ 229.95

Correct electrical panel $ 435.00 $ 456.75

Replace balcony $ 1,311.00 $ 1,376.55

Total $ 35,792.40

Deferred Maintenance

In addition to urgent corrective actions, the 2012 Property Condition Assessment identified 

immediate upgrades that need to occur within one to three years. The total cost of immediate 

upgrades estimated in the 2012 Property Condition Assessment was approximately $235,774 

worth of improvements. Using an estimate of 5% for inflation that cost in 2016 dollars is 

approximately $247,563. Some examples of repairs in this tier of improvements include 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

100

replacing materials from normal deterioration such as exterior siding and roofing, mechanical 

systems, a log sealant for log construction buildings. The highest cost maintenance item is a 

2-inch overlay of asphalt pavement for the parking lot and driveways at a cost of $46,620.

Deferred maintenance items are defined as upgrades or repairs that should be addressed between 

3 and 10 years, according to the Property Condition Assessment. The total cost of deferred 

maintenance expected is approximately $48,494. A major component of this category is 

replacing the galvanized piping in the Cooper Spur Inn, addressing chimney cracks in the five 

rental cabins and lodge home, and replacing the deck at the Ski Lodge with proper members for 

beams.

Excess

In the event that a special use permit is not issued to a potential permittee, a prospectus would be 

developed to consider the need to keep the structures administratively, with a likely outcome of 

considering the buildings excess to the government’s need. Once a structure is considered 

excess, it would trigger a disposal process for that structure. The options for disposal include 

transferring buildings through General Services Administration (GSA) procedures, where 

another government agency would presume ownership of the buildings and maintain the 

facilities. It is also possible to donate the buildings to public bodies for offsite removal, where 

the Forest Service would not be compensated, but would realize savings through the absence of 

future maintenance costs. The Property Condition Assessment estimates a repair total of 

$323,488 in 2012, or $339,662 adjusted for an inflation of 5%.

The Forest Service could also convey structures through the sale of facilities for offsite removal. 

The sale of the structure may be retained if it is sold under the Forest Service Facility 

Realignment Act (109-54 Pub. L.), the other option would be to convey the structure through 

GSA.

Excess buildings could also be demolished; however, only properties that have been determined 

to have no commercial value, or if the cost of care and handling exceeds estimated proceeds 

from sales, could be demolished. The total cost for decommissioning the suite of buildings on 

the acquired lands is approximately $161,412. Compared to the total maintenance cost of 

$339,662 identified in the Property Condition Assessment, the Forest Service could realize a 

savings of over $178,000 if the facilities are decommissioned.

Cumulative Effects

The Mt. Hood National Forest currently manages and maintains 197 facilities. Of those 

buildings, it was determined that 98 are designated as necessary to meet the mission of the 

Forest, while the remaining buildings were either designated to be disposed of, conveyed, or 

converted for other uses such as recreation use under concessionaires. The Facility Master Plan 

recommends that 99 buildings of the 197 existing administrative buildings be removed from the 

administrative inventory (USDA 2015). This is considered a large reduction in the number of 

facilities and there could be more reductions in the future to account for future budgets.

The current trend of facilities is downsizing and restructuring. In the late 1980s, the Forest 

managed approximately 230 buildings with 700 employees, and that has been reduced to 197 

buildings serving a workforce of 235 employees. This reduction has been made to match 

declining budgets. With limited funding, investments in facilities have focused on emergency 

repairs and meeting health and safety codes.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

101

Some of the Forest direction according to the Facilities Master Plan includes providing facilities 

to meet the needs of the current and future workforce, including retention and recruitment. 

Additionally, the Forest direction is to provide facilities for an effective visitor contact network.

Most of the buildings in the Cooper Spur Mountain Resort would qualify as quarters. In the 

Facilities Master Plan a summary of quarters is provided. One-third of quarters are to be retained 

and one-third are to be converted. There are two quarters that the Forest proposed to obtain to fill 

its needs, which is three percent of the total count of 72. The remaining quarters, just under one 

third, are to be disposed of or conveyed (USDA 2015). Adding additional quarters from the 

Cooper Spur Mountain Resort would lead to a two-thirds chance that these facilities would not 

be retained.

The addition of the Copper Spur facilities could put a strain on facilities management in the Mt. 

Hood National Forest. As discussed above, the buildings would likely be considered excess and 

would be added to the list of facilities that need to be disposed. Although half of the buildings in 

the Forest’s inventory are scheduled to be excess, there has not been enough funding to execute 

the disposal of these buildings. Thus, the cumulative impact of adding the Cooper Spur facilities 

to a list of excess buildings without sufficient funding, could possibly result in reordering the 

queue of buildings to be disposed of.

Fisheries

Introduction

Forest management activities that may alter aquatic habitat or affect individuals or populations of 

proposed, endangered, threatened, and sensitive fish and aquatic species require a biological 

evaluation to be completed (FSM 267l.44 and FSM 2670.32) as part of the National 

Environmental Policy Act (NEPA) process and Endangered Species Act to determine their 

potential effects on sensitive, threatened or endangered species. The biological evaluation 

process (FSM 2672.43) is intended to conduct and document analyses necessary to ensure 

proposed management actions will not likely jeopardize the continued existence or cause adverse 

modification of habitat for: 

A. Species listed or proposed to be listed as endangered (E) or threatened (T) by the 

USDI Fish and Wildlife Service or USDC NOAA Fisheries, and their listed or proposed 

listed critical habitat.

The biological evaluation process (FSM 2672.41) is also intended to conduct and document 

analyses to ensure that Forest Service actions do not contribute to loss of viability of any native 

or desired non-native plant or contribute to animal species or trends toward Federal listing of any 

species for:

B. Species listed as sensitive (S) by USDA-Forest Service Region 6. 

In addition to the above, the Forest Service is required to assess and disclose the effects of any 

Federal action on Regional Forester’s special status species, as outlined in the Endangered 

Species Act of 1973 and National Forest Management Act of 1976 (see effects determination 

section). The Magnuson-Stevens Fishery Conservation and Management Act of 1976 requires 

the Forest Service to assess and disclose the affects to Essential Fish Habitat. Clean Water Act 

compliance and consistency with the standard and guidelines outlined in the Northwest Forest 

Plan Aquatic Conservation Strategy objectives is discussed in the Hydrology specialist report.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

102

The Fisheries Specialist Report (Project Record) provides additional information from what is 

provided in this section of the DEIS, regarding analysis methodology, applicable Forest Plan 

Standards and Guidelines, and other supporting information and detail relating to this resource. 

Affected Environment

The affected environment, also known as the action area, is defined as all areas to be affected 

directly, indirectly, or cumulatively as a result of the Federal action and not merely the 

immediate area involved in the action [50 CFR §402.02]. This includes an analysis of how long 

(short-term versus long-term) the effects will occur (FSH 1909.15, 152b). For this analysis, the 

action area is defined as all of the land proposed under the exchange, as well as aquatic habitat 

areas where potential effects could occur. The short-term effects are defined as any effects that 

will take place within two years and the long-term effects are those that will take place over 

multiple decades. 

The project encompasses two separate geographic areas with multiple subwatersheds on Mt. 

Hood. During this discussion, we will divide the effects analysis in the following way. In 

Government Camp, there are two 7th-field watersheds that are part of the action area; Camp 

Creek and the Little Zigzag River. Both are tributaries to the Zigzag Canyon 6th-field watershed. 

For purposes of this report, a discussion about effects to those two subwatersheds will be 

referred to as the Government Camp action area. On the Cooper Spur side, there are four 7thfield subwatersheds in the action area: Tilly Jane Creek, Doe Creek, Ash Creek, and Crystal 

Springs Creek. All are tributaries to the Middle East Fork Hood River. These subwatersheds will 

be referred to as the Cooper Spur action area (figure 15). 

In the Government Camp area, this analysis documents measurable, indirect effects to aquatic 

environments that extend from the project area downstream below Yokum Falls in Camp Creek 

(about 4.5 river miles) and to the mouth of the Tributary to the Little Zigzag River (1.1 river 

miles) (figure 15). The timing of those effects will be observed both over the short term (less 

than 2 years) and extend out over many decades as the land is developed. Cumulative effects 

include actions that overlap in time and space, and therefore, the cumulative effects action area is 

larger than the direct and indirect effects action area. In Camp Creek, it extends from the 

Government Camp parcels to the Zigzag River (about 8.1 river miles). And from the 

Government Camp parcels to the Little Zigzag River and then to the confluence with the Zigzag 

River (about 2.4 river miles). 

In the Cooper Spur area, there are no measurable effects to aquatic organisms or habitat 

documented under either of the alternative actions. Therefore, the analysis area is the same as the 

parcel boundary and is only discussed in the existing condition section (figure 15). Since there 

are no effects, there is no evaluation of the temporal or cumulative impacts of the project. 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

103

Figure 15. Map of action area in the Hood River and Sandy River Basins
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

104

Existing Condition

The existing condition discussion is divided into two main sections: (1) aquatic species 

distribution and basic life history; and (2) existing habitat conditions, particularly as they relate 

to designated critical and essential fish habitat, and the primary processes that may be impacted 

by the project. Only those species and associated habitat that are found within the action area are 

discussed and analyzed since there would be no effect/impact to species/habitat outside the 

action area.

Presence of Proposed, Endangered, or Threatened Species

The Mt. Hood National Forest supports several species of anadromous salmonids, including 

Chinook, coho, and steelhead. These salmon and steelhead populations, which historically 

numbered in the tens of thousands (Taylor 1998; NOAA Fisheries 2013), have experienced 

substantial declines during the last century. Although there are different reasons for their current 

status, common issues throughout their range include impaired fish passage at dams and other 

obstructions, commercial and recreational fishing, habitat modification and/or loss, hatchery 

influences, and pollution. Hydropower, irrigation, domestic water supply, and flood control dams 

have disrupted migrations and eliminated historically available habitat. Commercial and 

recreational fishing have reduced numbers of wild fish in some populations. Habitat has been 

degraded, simplified, and fragmented due to a variety of land management activities both on and 

off the Forest. Important food sources such as aquatic macroinvertebrates have been impacted 

from habitat modification and water quality degradation. Hatchery programs have influenced 

populations, partly by masking declines in native fish abundance and dilution of native gene 

pools due to interbreeding. Reduced water quality from both point and non-point sources has had 

an impact at localized and even watershed scales in some areas (NOAA Fisheries 2013).

Government Camp. There are three Endangered Species Act (ESA)-listed fish species present 

in the action area in Government Camp; Lower Columbia River winter steelhead, Lower 

Columbia River Chinook salmon, and Lower Columbia River coho (table 10). There are about 

5.8 miles of designated critical habitat for Lower Columbia River steelhead, and about 3.8 miles 

for Lower Columbia River Chinook and coho salmon in the area (figure 16, figure 18, and figure 

19). No other ESA-listed fish species that occur elsewhere on the Forest are found in the action 

area. 

Cooper Spur. There are no ESA-listed fish species present in the Cooper Spur action area. 

Resident cutthroat trout and rainbow trout are present in the lowermost section of Crystal 

Springs Creek and in Tilly Jane and Doe Creeks (figure 17).

Restoration of abundant native salmon and steelhead populations and the habitat that supports 

them is a high priority for the Mt. Hood as well as other Federal, tribal, state, and local 

governments and agencies, as those species play critical economic, cultural, and recreational 

roles. 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

105

Table 10. Presence of ESA-listed fish, designated critical habitat, and essential fish habitat within 

the analysis area of the Government Camp-Cooper Spur Land Exchange

Species Distinct Population 

Segment (DPS)/

Status Action Area Presence

Evolutionary Significant 

Unit (ESU)

Government 

Camp

Cooper 

Spur

Steelhead trout

Oncorhynchus 

mykiss)

Lower Columbia River DPS Threatened 1/06

Critical Habitat 9/05 Yes No

Chinook salmon

(O. tshawytscha) Lower Columbia River ESU

Threatened 6/05

Critical Habitat 6/09

Essential Fish

Yes No

Coho salmon

(O. kisutch) Lower Columbia River ESU

Threatened 6/05

Critical Habitat 2/16

Essential Fish

Yes No

Note: The date in the status column is the date of listing or most recent status review and subsequent Federal Register

notice for ESA-listed species.

Lower Columbia River Steelhead

Lower Columbia River steelhead trout are found in both the Hood River and Sandy River 

Basins. These trout occupy a greater range of habitat than any other listed salmonid species in 

their range, extending from high elevation mountain streams to the Columbia River. Both Lower 

Columbia River summer and winter steelhead runs occur in the Hood River Basin; however, 

only winter steelhead are present in the East Fork Hood River Watershed. Only Lower Columbia 

River winter-run steelhead are present in the Zigzag River Basin. Sandy River historic returns 

may have once numbered 20,000 adults (ODFW 2002, as found in Sandy River Basin Partners 

[2005]). The mean return size for the period of 1999 to 2008 was 777 native adults (NOAA 

Fisheries 2016). The mean return size for winter-run steelhead in the Hood River Basin for the 

period of 1999 to 2008 was 558 native adults (NOAA Fisheries 2016). 

In both the Sandy and Hood Rivers, winter-run steelhead typically enter the basin in significant 

numbers from February through May, with peak spawning occurring in mid-May. Following 

emergence, steelhead fry will often seek refuge from fast currents by inhabiting stream margins 

and pool backwater habitats (as found in Sandy River Basin Partners (2005). As they begin to 

mature and grow larger, juveniles will typically inhabit deeper water habitats of pools, riffles, 

and runs. Steelhead juveniles may rear 2 to 3 years in their natal stream before migrating as 

smolts to the ocean. As such, the quality of the habitat they inhabit during this time is critical to 

their survival. Smolt emigration takes place primarily from March through June during spring 

freshets (Sandy River Basin Partners 2005). 

In Camp Creek, Lower Columbia River steelhead are present up to Yokum Falls, which is the 

historic upper limits for the anadromous form of rainbow trout; however, the resident form is 

present to the headwaters of Camp Creek, which is where the two Government Camp parcels are 

located. Designated critical habitat for Lower Columbia River steelhead extends from the mouth 

upstream to the natural barrier at Yokum Falls (about 5.8 miles) (figure 16). Today, the majority 

of steelhead in the Zigzag River 5th-field watershed, reside in Still Creek. However, there is 

strong historical evidence that Camp Creek and the mainstem Zigzag River provided important 

habitat for steelhead. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

106

Lower Columbia River steelhead use the section below Little Zigzag Falls for spawning, rearing,

and as a migration route. Designated critical habitat is present to the Little Zigzag Falls (figure 

2).

Lower Columbia River winter steelhead runs are present in the East Fork Hood River, but are not 

currently known to be present in the action area (figure 17). Steelhead spawning has been 

documented in the East Fork Hood River near the Tilly Jane and Crystal Spring tributaries, and 

while they may potentially be able to utilize the East Fork Hood River up to the Tilly Jane Creek 

confluence near the Forest boundary, they have not been documented there (Rod French; 

personal communication October 16, 2015). There is no designated critical habitat in any of the 

tributaries within the Cooper Spur action area. Designated critical habitat for steelhead is located 

about 0.25 mile downstream of the action area in the East Fork Hood River.

Lower Columbia River Chinook Salmon

Lower Columbia River spring and fall Chinook salmon are also present in both the Sandy and 

Hood River Basins. Lower Columbia River spring Chinook salmon are found throughout the 

Sandy River including the Zigzag River 5th-field watershed and Camp Creek, and are present 

within the Government Camp action area (figure 18). Historic returns may have once numbered 

15,000 adults (City of Portland 2004). The mean return size for the period of 1999 to 2008 was 

1,108 native origin spawning adults (NOAA Fisheries 2016). In the East Fork Hood River, 

known spring Chinook salmon upper distribution ends about 4 miles downstream of the action 

area, although they may potentially be able to utilize the East Fork Hood River up to the Tilly 

Jane Creek confluence near the Forest boundary (Rod French; personal communication, 

October 16, 2015). Chinook salmon are not currently known to be present in the Cooper Spur 

action area (figure 17).

Both the Sandy River and Hood River spring Chinook share similar life histories. Both 

populations enter the river in early spring, most commonly in April and May. Peak migration 

occurs in June, with a smaller peak occurring in September. Spawning occurs primarily in 

August through October. Juveniles emigrate in the fall or the following spring after emergence, 

and return generally at age 4 or 5. 

Fall Chinook salmon are present in both basins, but not in either of the action areas.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

107

Figure 16. Map of Lower Columbia River steelhead and designated critical habitat in the Government Camp action area
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

108

Figure 17. Map of resident trout and Lower Columbia River steelhead, coho, and Chinook designated critical habitat in the Cooper Spur action area
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

109

Figure 18. Map of Lower Columbia River Chinook salmon and designated critical habitat in the Government Camp action area
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

110

Lower Columbia River Coho Salmon

Lower Columbia River coho are present throughout the Upper Sandy River Basin and in the 

action area in Government Camp (figure 19). They may be present up to Little Zigzag Falls 

which prevents fish passage into the upper watershed, but designated critical habitat is not 

present in the Little Zigzag River (figure 19). Coho are also present in Camp Creek with 

designated critical habitat extending to the Laural Hill pit area (figure 19). The Sandy River 

population includes both an early hatchery-origin run of coho, with peak presence occurring in 

September and October, and a late wild run generally peaking from October through December.

Lower Columbia River coho salmon are known to reside in the East Fork Hood River up to Dog 

River and based on limited observations in the past (Mt. Hood National Forest Plan, unpublished 

data) they inhabit the lower 0.25 mile of Dog River (figure 18). Proposed critical habitat, 

however, extends well beyond the upper limit of known distribution—up to the headwaters of 

the East Fork Hood River and about 1.2 miles above the mouth in Dog River. Critical habitat 

was designated for the Lower Columbia River coho populations in February 2016 (figure 17).

Fry emergence primarily occurs from February through April and peaks in March (Sandy River 

Basin Partners 2005). Following emergence, juvenile coho typically seek stream margin habitats 

and backwater pools for initial rearing (ODFW 1997). As they continue to grow in size, juveniles 

seek low velocity pool and off-channel habitats for summer and winter rearing. Juvenile coho 

rely heavily on slack water habitats with complex large woody debris for protection from winter 

freshets. Juvenile coho in the Sandy River typically emigrate to the ocean as smolts at about 12 

to 14 months of age (ODFW 1997). The timing of juvenile coho outmigration is usually late 

March through June, peaking in April and May (ODFW 1997). Coho salmon in the Lower 

Columbia River and Southwest Washington Coast Evolutionary Significant Unit typically rear in 

the ocean for two summers and return as 3-year-olds.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

111

Figure 19. Map of Lower Columbia River coho salmon and designated critical habitat in the Government Camp action area
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

112

Presence of Region 6 Regional Forester’s Special Status Sensitive 

Species

As part of the NEPA process, the Forest Service reviews programs and activities to determine 

their potential effect on sensitive species. Species on the Mt. Hood National Forest included in 

the July 2015 Regional Forester’s special status species list are described below (table 11).

Government Camp. There are four Region 6 Regional Forester’s sensitive species present 

within the action area including Pacific lamprey (about 5.8 miles of habitat), and resident and 

anadromous cutthroat trout (about 8.8 miles of habitat). Brook trout, a non-native salmonid, have 

been documented in Collins Lake (USDA Forest Service unpublished data). Scott’s apatanian 

caddisfly are present in the headwaters of Camp Creek and within a few hundred feet of the land 

exchange boundaries. The Columbia duskysnail, which are Northwest Forest Plan Survey and 

Manage Species, are also present. 

Cooper Spur. There are two Region 6 Regional Forester’s sensitive species within the action 

area. Resident and anadromous cutthroat trout are in Doe, Tilly Jane, and Crystal Springs Creeks 

(about 3.5 miles of habitat). The Columbia duskysnail is also present.

Table 11. Presence of Region 6 Regional Forester’s special status sensitive and strategic species 

within the action area

Scientific Name Common Name Forest Presence Action Area Presence

Government 

Camp

Cooper 

Spur

Sensitive Species

Entosphenus tridentatus Pacific lamprey Documented Yes No

Onchorynchus mykiss 

gairdneri

Redband trout Documented Unknown No

Onchorynchus clarki Coastal cutthroat trout Documented Yes Yes

Juga hemphilli dallesensis Dalles juga Suspected No No

Juga hemphilli hemphilli Barren juga Documented No No

Juga hemphilli maupinensis Purple-lipped juga Suspected No No

Allomyia scotti Scott’s apatanian 

caddisfly

Documented Yes Unknown

Namamyia plutonis Caddisfly (no common 

name)

Suspected Unknown Unknown

Strategic Species

Juga sp. nov. (Basalt) Basalt juga Documented No No

Colligyrus greggi Columbia duskysnail Documented Yes Yes

Pacific Lamprey

Pacific lamprey occur throughout the Mt. Hood National Forest in both small and large streams 

and rivers. They are present throughout the Sandy River and Hood River Basins and are known 

to occur in Camp Creek and the Little Zigzag River, but have not been documented in the 

Cooper Spur subwatersheds. Pacific lampreys migrate from freshwater streams to the Pacific 

Ocean, then return upstream to spawn. Typical spawning habitat is similar to that for salmon or 

steelhead trout, in medium- and large-sized, low-gradient rivers and streams. Lampreys construct 

a nest (called a redd) in small gravel substrate. Females can lay up to 100,000 eggs, which are 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

113

fertilized externally by the male. Adult lampreys die within four days of spawning. Pacific 

lampreys spend most of their life in freshwater streams before entering the ocean as adults to 

feed. Young lamprey burrow into the muddy bottoms of backwater pools and eddies, where they 

filter the mud and water. The juveniles, called ammocoetes, live in fresh water for up to 5 or 

6 years. Juvenile lampreys are filter feeders. After a 2-month metamorphosis they emerge as 

adults less than 5 inches long, then migrate downstream to saltwater. In the ocean they grow to 

16 to 27 inches before returning after 1 or 2 years to fresh water to spawn and die. Adults are 

parasitic on other fish, scavenge, or are predators while in the ocean. Pacific lampreys do not 

feed while traveling to spawn. Pacific lampreys are vulnerable to habitat losses due to reduced 

river flows, water diversions, dredging, streambed scouring, channelization, inadequate 

protection of streamside vegetation, chemical pollution and spills, and impeded upstream 

passage due to dams and poorly designed road culverts.

Redband Trout

Redband/inland rainbow trout (redband trout) occur in the White River and Fifteenmile 

Watersheds and are suspected in the Upper Sandy River Watershed, but definitive genetic 

analysis has not been conducted (USDA Forest Service 2005). Redband rainbow trout are not 

known to occur in the Hood River Basin, and are not known in the Cooper Spur action area. 

Spawning occurs in the spring. Fry emergence from the gravel normally occurs by the middle of 

July, but depends on water temperature and exact time of spawning. Redband trout prefer water 

temperatures from 50 to 57 °F, but have been found actively feeding at temperatures up to 77 °F 

in high desert streams of Oregon and have survived in waters up to 82 °F. There is suitable 

habitat for redband trout within both action areas. 

Coastal Cutthroat Trout

Cutthroat trout are present throughout the Forest and are present within both the Government 

Camp and at Cooper Spur action areas (figure 16). These fish are also a management indicator 

species on the Forest and a more detailed description of their life history and habitat 

requirements are described in the following “Management Indicator Species” section.

Dalles Juga

This species of aquatic mollusk has been found in Mill Creek and the central and eastern 

Columbia River Gorge from Hood River to The Dalles, in Hood River and Wasco Counties, 

Oregon, and Skamania County, Washington (Frest and Johannes 1995). The Dalles juga is found 

at low elevation large springs and small-medium streams with a stable gravel substrate and fastflowing, unpolluted, highly-oxygenated cold water. Relatively few macrophytes or epiphytic 

algal taxa are present, with Rorippa being the most frequently encountered. The species cannot 

survive long out of water (Frest and Johannes 1995). None of these species were found during 

surveys conducted in 2013 within streams in the Cooper Spur area. Although no surveys have 

been conducted for them in the Government Camp area, the Upper Sandy River Basin is outside 

of the known range of the Dalles Juga, and therefore they are not expected to occur there.

Barren Juga

This species of aquatic mollusk is found in freshwater habitats in small- to medium-sized, highly 

oxygenated cold water streams at low elevations. The species prefers streams that have moderate 

velocity level bottoms with stable gravel substrates. The known range of this species is the 

Columbia River Gorge in Oregon and Washington. They have been found in the Mt. Hood 

National Forest and the Columbia River Gorge National Scenic Area. They are also suspected to 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

114

occur in the Gifford Pinchot National Forest. None were found during surveys conducted in 2013 

within streams in the Cooper Spur area. Barren juga are not known to occur in the Upper Sandy 

River Basin which is outside of their known range. Therefore, they are not present in either of 

the action areas.

Purple-lipped Juga

The Purple-lipped juga snail is endemic to Oregon. It is found in large streams at low elevations. 

These snails prefer riffle habitat with stable gravel substrates, in cold, well oxygenated water. It 

is more tolerant of silt and slack water than other Juga subspecies. The known range of the 

species is the Lower Deschutes River drainage, below Pelton Dam, and the Warm Springs River 

in Wasco and Sherman Counties, Oregon. Sites where the species are known to occur are located 

on the Warm Springs Reservation and Prineville Bureau of Land Management in the Deschutes 

Wild and Scenic River Area. There are few locations on the Mt. Hood National Forest that match 

the above preferred habitat description. None of these species were found during surveys 

conducted in 2013 within streams in the Cooper Spur area. Although no surveys have been 

conducted for them in the Government Camp area, the Upper Sandy River Basin is outside of the 

known range of the purple-lipped juga, and therefore they are not expected to occur there.

Scott’s Apatanian Caddisfly

Allomyia scotti is a glacial relict species with a patchy distribution only (endemic) recorded 

around Mt. Hood, Oregon. Scott’s apatanian are present within 200 feet of the Government 

Camp parcels in Camp Creek, and suitable habitat exists at the confluence of the unnamed 

Tributary and the Little Zigzag River in the Government Camp action area. No surveys have 

been completed in the Cooper Spur area and no known suitable habitat exists, thus their presence 

there is unknown. 

This species was first collected in 1964 in what was likely West Fork Salmon River near the 

Timberline Highway and in South Fork Iron Creek near Highway 35 (Wiggins 1973b). In 2010, 

this species was recorded at seven sites in headwater seeps, springs, and tributaries to the West 

Fork Salmon River (Wisseman 2010). 

From 2013 to 2015 an exhaustive survey was conducted around Mt. Hood from 3,157 to 

6,257 feet elevation for larval A. scotti (Wanner and Arendt 2015). Six new populations of 

A. scotti were recorded in the Little Zigzag River, Sand Canyon Creek, Still Creek, a tributary to 

the Muddy Fork of the Sandy River, a tributary to McGee Creek, and in a tributary to the East 

Fork Hood River within the Mt. Hood Meadows Ski Area. In 2016, surveys of the headwater 

springs adjacent to the land exchange found them to be present – thus expanding the known 

population to include Camp Creek. 

As a result of the 2013 to 2015 survey efforts, and past records (Wiggins 1973b; Wisseman 

2010), A. scotti populations are known to occur in approximately 4.6 linear miles of seeps, 

springs, and 1st- through 3rd-order streams around Mt. Hood (Wanner and Arendt 2015). 

However, because of their patchy distribution, association with cold seeps and springs, and dense 

mats of wiry moss, 4.6 miles maybe a gross over-estimate of their actual habitat. The Little 

Zigzag River and Sand Canyon Creek appear to be the stronghold habitat for this species. These 

two streams account for 69 percent of their entire known range. These two streams have stable 

discharge mostly originating from springs. Suitable habitat is present in the unnamed Tributary 

to the Little Zigzag within the action area. The population range in Still Creek and West Fork 

Salmon River are believed to only occur in the headwater springs of these streams. A. scotti

habitat in South Fork Iron Creek and tributaries to McGee Creek, and Muddy Fork Sandy River 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

115

are much less known due to the steepness of terrain and lack of sampling that has occurred in 

these streams; however, these streams do have the required spring fed, cold water with dense 

mats of moss. Much of the A. scotti populations are protected from anthropomorphic 

disturbances (with the exception fires or climate change) due to their location within the 

congressionally designated Mt. Hood Wilderness. The populations on Still Creek, West Fork 

Salmon River, and the tributary to East Fork Hood River are more susceptible to human 

disturbance as they are located within ski permit areas with associated roads and trails and 

appear to be occupying limited ranges within those areas.

Namamyia plutonis

Little is known about the specific life history characteristics of Namamyia plutonis but it is likely 

that their life history is similar to other caddisflies in general (including Allomyia scotti) as 

described by Spellman (2008). They have been found in small streams in densely forested old 

growth or mature forest watersheds, and larvae have been found in core samples collected from 

areas composed of coarse gravel mixed with silt and organic sediments (Anderson 1976). They 

are known to reside in the Coastal and Cascade Ranges of Oregon and California, including 

documented occurrences in the Rogue River-Siskiyou, Siuslaw, and Willamette National Forests 

(Anderson 1976), and a more recent occurrence in the Rogue River-Siskiyou National Forest 

(Borgias and Wisseman 1999). Namamyia plutonis has never been documented in the Mt. Hood 

National Forest, including during surveys conducted in 2013 and 2014 in Tilly Jane Creek, Doe 

Creek, and the unnamed tributary to Polallie Creek. Suitable habitat, as described by Anderson 

(1976), may be present in the Government Camp area, however since they have never been 

observed in other suitable habitat on the Mt. Hood National Forest, they are presumed not 

present in the Government Camp action area.

Columbia Duskysnail

This species of aquatic mollusk has been found across the Mt. Hood National Forest during 

surveys conducted over the past several years (Mt. Hood National Forest, unpublished data) and 

has been documented in Camp Creek above Yokum Falls. Habitat requirements for this species 

are fairly specific: cold, well oxygenated springs, seeps, and small streams, preferring areas 

without aquatic macrophytes (Furnish and Monthey 1998). Until recently, individuals had not 

been found in larger streams and rivers, or glacial streams. However, one individual was found in 

the East Fork Hood River.

In 2013, the Columbia duskysnail was found within the East Fork Hood River (one site below 

Polallie Creek), and several other sites including Clinger Springs (two sites, a tributary to the 

East Fork Hood River) and Dog River (four sites). Interestingly, no Columbia duskysnail 

individuals were found in Tilly Jane or Doe Creek. It is also noteworthy that the one specimen 

found in the East Fork Hood River is the first described in a glacially influenced stream on the 

eastside of the Mt. Hood National Forest (Mt. Hood National Forest, unpublished data). While 

surveys have not been completed for Columbia duskysnail in all of the Government Camp area 

or in Crystal Springs, there is suitable habitat present; and since they have been documented in 

several places nearby (an unnamed tributary to Camp Creek and in the East Fork Hood River), 

they are assumed to be present within the Government Camp action area and in Crystal Springs 

within the Cooper Spur action area. 

Basalt Juga

This species of aquatic mollusk is a rare and uncommon species as outlined in the Northwest 

Forest Plan. Their habitat requirements appear similar to that of the Columbia duskysnail 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

116

(Furnish and Monthey 1998). These small snails have only been found in one survey on the Mt. 

Hood National Forest in North Fork Mill Creek (Mt. Hood National Forest, unpublished data). 

They have not been found in any other stream or water body surveyed since Mt. Hood National 

Forest personnel began surveying in 1998. They are not believed to reside in watersheds other 

than those that drain into the Columbia River near The Dalles, Oregon.

Surveys for Basalt juga were conducted throughout Tilly Jane Creek and Doe Creek in 2013 (Mt. 

Hood National Forest, unpublished data). No individuals were found at any site surveyed in 

those streams, and therefore they are not assumed to be present. No surveys have been 

completed in either Crystal Springs Creek, Camp Creek, or the Little Zigzag River, but since 

these locations are outside of the known range of the Basalt juga’s habitat, they are not assumed 

to be present in either of those streams.

Presence of Mt. Hood National Forest Management Indicator 

Species

During the preparation of the Mt Hood National Forest Land and Resource Management Plan 

(USDA Forest Service 1994), a group of fish and wildlife species were identified as management 

indicator species. Because of their relative sensitivity to change, salmonids were selected as “an 

indicator species group” for aquatic habitats. This group of species is especially important for 

their commercial and game values and because they occupy the spectrum of aquatic habitats on 

the Mt. Hood National Forest. These requirements are restricted enough that it is reasonable to 

assume that if the life history needs of salmonids are met, the rest of other fish species found on 

the Mt. Hood National Forest will be met (see final EIS, page III-58).

A forest-level analysis of the status of these species and their habitat was conducted in March 

2011. The state of Oregon, in collaboration with the regulatory agencies, manages fish 

populations while the Mt. Hood National Forest manages the habitat. For a population to be 

viable, attributes such as species abundance, productivity, spatial structure, and genetic diversity 

are needed for the species to maintain its capacity to adapt to various environmental conditions 

and allow it to sustain itself in the natural environment. All of these attributes are affected by 

habitat and other environmental conditions that influence species behavior and survival. 

The forestwide analysis also assessed the quantity and quality of habitat available on the forest, 

and how much habitat was occupied, for each of the salmonid species. The analysis was 

performed by calculating the linear distance of stream miles of the intersect between widely 

available National Hydrography Dataset and StreamNet fish distribution layers of the geo 

database on file at the Mt. Hood National Forest headquarters office. Fish distribution was 

determined by utilizing the Oregon Department of Fish and Wildlife 1:24000 data for 

anadromous fish (which matched StreamNet data), U.S. Fish and Wildlife Service data for bull 

trout, and Mt. Hood National Forest legacy fish distribution data for resident trout distribution. 

Results of this analysis are summarized below (table 12). Since other sections of this document 

discuss the location, trends, and project-related impacts to all other management indicator

species salmonid species present within the action area, the following discussion will focus 

solely on cutthroat trout.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

117

Table 12. A comparison of salmonid management indicator species occupied habitat within the Mt. 

Hood National Forest (total) and the occupied habitat within the action area

Management 

Indicator 

Species (MIS)

ESA 

Status

Miles of 

Occupied 

Habitat 

on Forest

Miles of Habitat in the 

Action Area

Percentage of Habitat 

In Action Area

Government 

Camp

Cooper 

Spur

Government 

Camp

Cooper 

Spur

Chinook Salmon Threatened 143 ~4.5 0 0.03 0

Coho Salmon Threatened 193 ~4.5 0 0.03 0

Steelhead Trout Threatened 303 ~6.4 0 0.21 0

Bull Trout Threatened 20 No 0 0 0

Cutthroat Trout None 1,290 ~8.8 ~3.52 0.006 0.002

Rainbow Trout None 1,290 ~8.8 ~3.52 0.006 0.002

Note: Private land wholly within the Mt. Hood National Forest boundary is included in the “Occupied Habitat” column. 

Steelhead trout is the winter run only.

The life history of coastal cutthroat trout may be one of the most complex of any Pacific 

salmonid (USFWS 2010). Three general life-history forms of coastal cutthroat trout have been 

recognized and all are assumed to be present within both action areas.

Nonmigratory Coastal Cutthroat Trout

This life history form includes fish generally found in small streams and headwater tributaries. 

These non-migratory coastal cutthroat trout, in general, appear to grow more slowly than other 

life-history forms of trout, are smaller at maturity, and generally do not live as long as migratory 

forms (USFWS 2010). 

Freshwater-Migratory Coastal Cutthroat Trout

This freshwater, or potamodromous, life-history form includes fish that migrate entirely within 

fresh water. This includes populations that migrate from large tributaries to small tributaries to 

spawn (fluvial-adfluvial), populations that inhabit lakes and migrate upstream to spawn in the 

lake's tributaries (lacustrine-adfluvial), and populations that live in lakes and migrate 

downstream to spawn in the lake outlet (allucustrine). These freshwater-migratory populations 

are best documented in rivers and lakes with physical barriers to anadromous fish, such as above 

waterfalls (USFWS 2010).

Saltwater-Migratory Coastal Cutthroat Trout

Juvenile fish typically spend 2 to 5 years rearing in fresh water before making their initial 

seaward migration in the late winter and spring to feed in marine environments (estuarine or 

nearshore) during the summer. They then enter fresh water in the winter to feed, seek refuge, or 

spawn, sometimes returning to seawater in the spring (USFWS 2010). Unlike other anadromous 

salmonids, the saltwater migratory form of coastal cutthroat trout does not overwinter in the 

ocean and only rarely makes extended migrations across large bodies of water.

Cutthroat trout typically spawn from December through June. Eggs begin to hatch within 6 to 

7 weeks of spawning, depending on temperature; fry emerge between March and June, with peak 

emergence in mid-April (USFWS 2010). These trout use a large variety of habitat types, 

including lower and upper reaches of both large and small river systems, estuaries, sloughs, 

ponds, lakes, and nearshore ocean waters. In freshwater habitat these fish prefer deeper pool 

habitat and cover, such as that formed by woody debris. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

118

There are approximately 1,290 miles of stream habitat used by resident trout (including 

cutthroat) on the Mt. Hood National Forest. The total miles of stream occupied by resident 

cutthroat trout within the Government Camp action area is about 8.8 miles and 3.5 miles in the 

Cooper Spur action area; a fraction of 1 percent of available habitat on the Mt. Hood. The 

existing conditions within the analysis area and the relation to forest-scale conditions are 

described in the following section.

Existing Habitat Conditions, Including Designated Critical Habitat 

and Essential Fish Habitat

Aquatic habitat conditions within the action area vary depending on the location, past land 

management activities, and natural events such as floods, fire, and debris torrents. Habitat 

conditions where land management has occurred range from poor to good, depending on the type 

and scale of disturbance, proximity to streams, timing and duration of land management 

activities, and sensitivity of channel type to perturbation. The subwatersheds within both action 

areas have been altered by some of the following: recreation development, urban infrastructure, 

large wildfires as well as fire suppression, past logging practices, municipal water diversions, 

municipal sewage facilities, and road networks. Separately and cumulatively, these activities 

have resulted in loss of function of natural processes related to water quality and quantity, 

riparian and floodplain function and connectivity, in-channel habitat, and obstruction free 

migration corridors for aquatic organisms. As a result of this project, some additional effects to 

those processes are possible. The parameters identified include water quantity and quality, 

substrate and fine sediment levels in streams; and pool quantity and quality. Because other 

habitat parameters and/or fluvial processes are analyzed in the Hydrology specialist report or 

proposed activities would not impact them, only those habitat parameters listed above will be 

discussed in the effects sections that follow.

Designated critical habitat is present for three species within the action area in Government 

Camp, but is not present within the action area in Cooper Spur. Much of the discussion 

concerning critical habitat, including effects analyses, will center on the physical and biological

features related to freshwater habitat conditions that include spawning, rearing, and migration for 

Lower Columbia River steelhead trout and Lower Columbia River coho and Chinook salmon. 

Nothing in the proposed project would have an effect on estuarine or marine habitat components, 

thus they are not discussed. 

A baseline determination of functioning, functioning at risk, or not properly functioning is given 

to each habitat element that may be effected by the project and summarized in table 13.

Government Camp. Camp Creek originates from a series of seeps and springs on the southern 

shoulders of Mt. Hood at an elevation of about 3,700 feet. Three perennially flowing channels 

combine into what is considered Camp Creek proper within the community of Government 

Camp near Collins Lake. Its course takes it from its origination on U.S. Forest Service land, 

through private land in Government Camp, and then back onto Forest Service land before 

joining with the Zigzag River.

Historically, Camp Creek meandered across the Government Camp valley, through the flat bench 

of wetlands and small lakes that still dot the landscape, until dropping over the steep topography 

at Yocum Falls (Laural Hill) into a gently sloped valley where it joined the Zigzag River. Today, 

Camp Creek is highly confined and urbanized as it flows through the town of Government 

Camp. Passing through a series of culverts and impoundments; including Collins Lake, the 

stream runs under Highway 26 and through the SkiBowl permit area, receives outfall from the 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

119

Government Camp sewage treatment facility, and is then forced into a ditch adjacent to Highway 

26 for almost a mile, before going over Yokum Falls. Below the falls, the stream environment is 

less urban and more forested, but habitat conditions are still impacted by acute amounts of 

sediment, as well as the presence of campgrounds, summer cabins, and other infrastructure 

adjacent to the stream channel. 

Camp Creek lacks riparian cover and floodplain in sections where it runs through Government 

Camp and along Highway 26. Storm water runoff from Government Camp, highway sanding, 

and floodplain development have created conditions where water quality is degraded, sediment 

loading can be acute, and riparian vegetation is lacking. In the past, sewage treatment plant 

failures resulted in excess nutrient loads and other potential pollutants entering the stream. 

Chemical pollutants from highway vehicle traffic and winter de-icing are also present. Several 

large historic fires burned across the watershed and past logging practices removed mature 

riparian forests below Yokum Falls. But the principal process of concern is the amount of 

sediment present in Camp Creek. Since the early 1980s, surveys have documented acute 

sediment loads below Yokum Falls resulting from human-caused activities. The channel is 

dominated by fine sediment in both riffles and pools and there are “beaches” of sand along the 

stream margins and floodplains. The principal source of the sediment is from winter-time road 

sanding on Highway 26 that is routed into Camp Creek due to its close proximity to the highway. 

As a result, Camp Creek currently does not meet many of the parameters of the Northwest Forest 

Plan or Mt. Hood Forest Plan standards for riparian and in-stream habitat within the analysis 

area.

Despite many of the chronic problems facing Camp Creek due to its urbanized nature, it still 

provides important habitat for all life stages of salmon, trout, and sensitive aquatic invertebrates,

and these species are present year round, although in greatly reduced numbers. Federally 

threatened salmon and steelhead use the section below Yokum Falls both for spawning and 

rearing and as a migration route. Resident cutthroat trout and rainbow trout have been 

documented in perennial streams above Yokum Falls and throughout the action area.

The Little Zigzag River originates from the base of a glacial moraine on the Zigzag Glacier and 

flows in a southwestern direction to its confluence with the Zigzag River. At its headwaters, it 

flows through steep unstable canyons which are a natural source of sediment into the channel. 

The channel flows intermittently and subsurface until about river mile 4.4 at which point it is 

perennial. The stream borders the Mount Hood Wilderness from river mile 2.75 to the 

headwaters at about river mile 5.5. Human management activities appear to have had little 

impact to this stream (USDA Forest Service 2000; Wanner et al. 2015). A tributary to the Little 

Zigzag River originates just below the wetlands on the westernmost edge of the west parcel and 

passes through undisturbed forest. This tributary flows into the Little Zigzag immediately above 

the Little Zigzag River Falls. Federally threatened salmon and steelhead use the section below 

Little Zigzag Falls for spawning rearing and as a migration route. Resident cutthroat and rainbow 

trout have been documented below the falls but there is no information about fish presence 

above the falls or in the little Tributary. No fish information is available for Enid Lake.

Cooper Spur. There are many streams, springs and wetlands located within the 7th-field 

watersheds in this area. The primary streams include Tilly Jane Creek, Doe Creek, Ash Creek, 

Crystal Spring Creek, and Buck Creek. The hydrology in the Cooper Spur action area is 

characterized by numerous ephemeral drainages that eventually become intermittent streams and 

in a few cases perennial streams (examples include Evans Creek and Doe Creek). Tilly Jane 

Creek is the only stream in this area that is perennial from the source. The streams are small, 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

120

spring fed, with relatively gentle gradients except some steeper sections depending on stream 

and location. In the headwaters of Doe Creek and some tributaries to the East Fork Hood River,

the streams “pipe” water underground for varying distances, with occasional surface flow, before 

the water surfaces and the stream becomes perennial. 

Sediment, Turbidity and Substrate

Fine sediment deposition and turbidity in streams can adversely affect fish and fish habitat, 

particularly for salmonids, by reducing the quantity and/or quality of spawning habitat; reducing 

food supply by impacting invertebrate habitat; reducing interstitial habitat, thereby decreasing 

fry survival; and reducing pool quality and quantity. Both past and on-going land use activities 

can contribute fine sediment in streams. The Mt. Hood National Forest Land and Resource 

Management Plan (forest plan) states that spawning habitat shall maintain less than 20 percent 

fine sediments less than 2 millimeters (FW-096). 

Government Camp. Considerable housing and infrastructure development has already occurred 

in the Camp Creek Watershed. The infrastructure and development associated with single family 

and multi-family residences, ski areas, and road construction has resulted in forest clearing and 

acres of impervious surfaces. Each of these human activities increases fine sediment input to 

stream channels and as a result, fine gravel substrates dominate stream bottoms within the action 

area. Modeling results suggest that wintertime safety sanding is the largest contributor of 

sediment in the action area, followed by the road network, and recreation, respectively 

(Hydrology Specialist Report). Current sediment loads have already caused sufficient habitat 

alteration to adversely impact threatened fish species and other sensitive aquatic fauna in Camp 

Creek (USDA Forest Service 2011). Acceleration of fine sediment inputs from human activities 

will only exacerbate that problem. 

Many of the roads within this area are adjacent to Camp Creek and road sand is blown directly 

into the stream network during winter snow removal operations. This problem occurs throughout 

the watershed, but is particularly acute on Highway 26 where Camp Creek runs directly adjacent 

to the highway for about 1 mile. In total, approximately 2,102 tons of road sand are delivered 

into the Camp Creek 7th-field watershed each year (Hydrology specialist report). Stream surveys 

and project reports dating back to the 1980s also identify the unstable cut-slopes adjacent to the 

highway as a direct source of sediment into the stream (USDA Forest Service 1991, 1992, 2000).

Sediment and embeddedness levels in Camp Creek are substantially higher than natural 

background levels. Fine sediment (sand or silt less than 2 millimeters in diameter) accumulations 

in stream reaches in the action area are acute and extend all the way downstream to the 

confluence with the Zigzag River (USDA Forest Service 2011; Hydrology specialist report). The 

watershed analyses for the Zigzag River identifies sedimentation of streams in the upper 

watershed as a process of concern. “Wolman” pebble counts collected during stream surveys 

have documented excessive in-channel sediment loading since the first stream surveys were 

conducted in the 1980s. In addition, as residual road sand builds up along road margins and 

ditch-lines it is mobilized into the stream network during snowmelt and/or rain events. If culverts 

and ditch relief pipes are blocked or not properly maintained, large pulses of road sand can be 

mobilized into the stream within a few hours, resulting in spikes of turbidity. There is limited 

data available to evaluate the magnitude of turbidity spikes in Camp Creek. Baseline 

determination is: Not properly functioning.

In general, streams that have experienced little to no land management are in good condition 

even though forest plan standards (such as, pools per mile and pieces of wood per mile) are not 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

121

always met. Some of these streams have been impacted by natural events and, indeed, were 

formed or maintained by such events. Glacial streams such as the headwaters the Zigzag River

and Little Zigzag River are examples of streams exhibiting relatively degraded, but natural, 

conditions due to natural events. The Little Zigzag River is spring fed, but is also influenced by 

snowmelt from headwater glaciers. Long stretches of exposed talus slopes in the headwaters are 

a source of glacial fines and sediment, and therefore the natural background condition for 

sediment is high. Human management activities appeared to have little impact on this stream 

above Kiwanis Camp. The tributary to the Little Zigzag River is also relatively unaffected by 

human activities. Baseline determination is: Properly functioning.

Cooper Spur. As in Camp Creek, there are a number of past and on-going land use activities 

which are likely contributing fine sediment into these streams. All the streams are located near 

potential anthropogenic sources of fine sediment, including roads, small-scale resort facilities, 

the Cooper Spur Ski Area, and in some cases old timber harvest units. In addition, a large-scale 

fire (Gnarl) occurred over a decade ago in the headwaters of these streams which replaced much 

of the mature forest and may have exacerbated erosion. These small stream channels naturally 

lack the hydraulic power or competence to effectively move fine sediment quickly downstream 

and fine substrates dominate stream bottoms within the action area. The source of this sediment 

is likely a combination of natural and human-caused, but there has not been an analysis to 

determine the proportional amounts. There is no survey data available for Ash Creek. There is no 

data available about the magnitude or duration of human cause turbidity in the action area but it 

is assumed there are occasional, short-term spikes. Baseline determination is: Functioning at 

risk.

Chemical Contaminants/Nutrients

Chemical contamination in water can cause both lethal and sub-lethal effects to salmonids and 

other aquatic species. Effects from contaminants may reduce or eliminate production of specific 

aquatic invertebrates which could impact food forage for salmonids. Introduction of nutrients 

may be beneficial (increase primary production and aquatic invertebrate production) or in excess 

may lead to lethal or sub-lethal effects to aquatic plants and invertebrates.

Government Camp. There are no ODEQ (Oregon Department of Environmental Quality) 303d 

reaches within the two subwatersheds listed for contaminants. There is one known point source 

of pollution within the action area that effects Camp Creek. Treated effluent from the 

Government Camp Sewage Treatment Facility empties into Camp Creek. On occasion, total 

dissolved solids releases into Camp Creek have exceeded the NPDES permit (ODEQ 2016). 

There may also be a small amount of untreated effluent generated into lower Camp Creek from 

poorly functioning septic systems in the Camp Creek Summer Home tract which consists of 138 

cabins. There are no known point sources of pollution to Little Zigzag River in the action area.

Camp Creek has other sources of non-point source pollution is a result of the urban environment 

it passes through. Roadways and parking lots are impervious and accumulate a mixture of 

contaminants, including metals; petroleum-derived compounds from oil, grease, and vehicle 

exhaust; among others (NOAA Fisheries 2016). “Runoff pollution is associated with rainwater or 

melting snow that washes off roads, bridges, parking lots, rooftops, and other impermeable 

surfaces. As it flows over these surfaces, the water picks up dirt and dust, rubber and metal 

deposits from tire wear, antifreeze and engine oil that has dripped onto the pavement, pesticides 

and fertilizers, and discarded cups, plastic bags, cigarette butts, pet waste, and other litter. A large 

amount of this runoff pollution is carried directly to water bodies (as found in EPA 1995).” In 

addition, the Oregon Department of Transportation uses magnesium chloride as a de-icing agent 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

122

on U.S. Highway 26 during the winter. The average application rate is approximately 30 gallons 

per lane mile or about 1 ounce per square yard (Parker 2011). Application timing is related to 

projected weather and the chances for snow or ice.

Since Camp Creek is the principal waterbody in Government Camp, it is likely that it receives 

the majority of the runoff pollution generated from the area. There is little to no data regarding 

the magnitude of chemical contamination in Camp Creek, and therefore it is difficult to assess 

the potential impacts to aquatic species. There is no documentation of lethal effects to fish 

species and no data are available to evaluate potential effects to aquatic invertebrates, therefore 

this analysis assumes there may be some impacts to water quality parameters and thus to juvenile 

and adult fish species that are sub-lethal. Baseline determination is: Functioning at risk.

There are no known non-point sources of chemical contamination in the Little Zigzag River 

action area: Baseline determination is: Properly functioning.

Cooper Spur. There are no ODEQ 303d reaches within the three subwatersheds listed for 

contaminants. Oregon Department of Transportation and Hood River County use magnesium 

chloride (de-icing agent) on U.S. Highway 35 and the county portions of Cooper Spur Road

during the winter months. Some de-icing may occur on Forest Service roads that access the 

Cooper Spur Ski Area; however, there is no information on the amount except that it happens as 

needed during winter months (pers. comm., Bob Ballard 2016).

Runoff pollution is likely negligible as these subwatersheds flow primarily through forested land 

with very little impervious surface present. Doe Creek runs adjacent to and below the Cooper 

Spur Ski Area and may intercept some runoff from the Cooper Spur parking lot and other 

infrastructure. Tilly Jane and Ash Creek cross the Cooper Spur road at a 90-degree angle 

minimizing the area where de-icing agent can enter the creeks. Baseline determination is: 

Properly functioning.

Peak/Base Flows and Drainage Network

Government Camp. “It is likely that past land management activities and wildfires in the 7thfield watersheds associated with the Government Camp area have affected peak and base flows 

(as found in Hydrology specialist report).” However, both Camp Creek and Little Zigzag are 

below the threshold of concern based on Grant (2008). All the subwatersheds are below the 

threshold associated with the methodology for addressing cumulative watershed effects, 

watershed sensitivity, and hydrologic recovery associated with the Mt. Hood Forest Plan (USDA

Forest Service 1990a). When the combined impacts of vegetation management and roads are 

examined, all the subwatersheds are rated as properly functioning in the 6th-field watershed 

condition from the Northwest Forest Plan–The First 20 Years (1994–2013) Watershed Condition 

Status and Trend Report (Miller, in press) (as found in Hydrology Specialist Report).

Another factor in evaluating changes in peak/base flow are changes in the stream drainage 

network due to roads and trails. The relatively impermeable surfaces of roads and trails cause 

surface runoff to bypass subsurface flow routes in soils (Hydrology specialist report). Roads and 

trails are hydrologically connected by ditch-lines and gullies, and therefore the stream network is 

considered lengthened wherever they interrelate (Hydrology Specialist Report).

The final factor evaluated to determine the existing condition in peak/base flows was the amount 

of water being diverted from the Government Camp area. The Little Zigzag has only limited 

water diversions totaling about 0.002. Average low-flow in the Little Zigzag is approximately 

16.1 cubic feet per second (Hydrologist specialist report). Thus, the amount of water being 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

123

diverted for human use is inconsequential from an aquatic habitat perspective. In Camp Creek 

however, there are multiple water diversions for human use. Water rights of 4.56 cubic feet per 

second are currently allocated and the mean low-flow is approximately 2 cubic feet per second 

(Hydrology specialist report). As a result, there could be impacts to aquatic habitat and species if 

all the water rights currently allocated were exercised. 

In summary, watershed health related to flow is considered properly functioning. Changes to 

flows related to roads and trails are estimated to be somewhat impaired, and water rights may be 

over-allocated, but are not currently being fully exercised. Baseline determination is: 

Functioning at risk.

Cooper Spur. It is likely that past land management activities and wildfires in the 7th-field 

watersheds associated with the Cooper Spur area have affected peak and base flows. All of the 

subwatersheds, except Tilly Jane Creek, are below the threshold of concern based on Grant 

(2008; as found in the Hydrology specialist report). All the subwatersheds are below the 

threshold associated with the methodology for addressing cumulative watershed effects, 

watershed sensitivity, and hydrologic recovery associated with the Mt. Hood Forest Plan (USDA

Forest Service 1990a). When the combined impacts of vegetation management and roads are 

examined all the subwatersheds are rated as properly functioning in the 6th-field watershed 

condition from the Northwest Forest Plan–The First 20 Years (1994–2013) Watershed Condition 

Status and Trend Report (Miller, in press). Baseline determination is: Properly functioning.

Tilly Jane Creek Watershed is above the threshold of concern from The Effects of Forest 

Practices on Peak Flows and Consequent Channel Response Report (Grant 2008, as found in the 

Hydrology specialist report) due to vegetation loss from the Gnarl Ridge Fire. However, 

indications of major increased peak flows such as channel bed instability or scour and channel 

bank erosion were not noted during field visits to Tilly Jane Creek just below the burned area.

Baseline determination is: Functioning at risk.

None of the subwatersheds except for Crystal Springs have water withdrawal allocations that 

exceed the mean low-flow; therefore, there are no impacts to aquatic fauna or habitat related to 

water diversions. The Crystal Springs Water District has water rights of 7.16 cubic feet per 

second and the mean low-flow is approximately 5.14 cubic feet per second (Hydrology specialist 

report). As a result, there could be impacts to aquatic habitat and species if all the water rights 

currently allocated were exercised. Summary baseline determination is: Functioning at risk.

Pool Quality and Quantity

Pool habitat is a critical component of healthy stream habitat for salmonid populations. The 

forest plan requires that pool habitat be maintained or increased as a result of a given project 

(FW-088) and that streams contain one or more primary pools per five to seven channel widths 

in low-gradient streams (less than 3 percent slope), and one per three channel widths in steeper 

channels (FW-090/091). A primary pool is defined as a pool at least 3 feet deep, which occupies 

at least half of the low-water flow channel. Pool frequency is often related to the occurrence of 

large wood or other channel obstructions (Montgomery et al. 1995) and pool depth is a function 

of a variety of factors including sediment input and the ability of the stream at that site to scour, 

and maintain, a pool. Fine sediment above natural background levels can fill pools and increase 

bed mobility, resulting in shallower scour depths (Buffington et al. 2002).

Government Camp. Pool frequency and quality do not meet NMFS-AP indicator or forest 

management plan standards in Camp Creek above Yokum Falls. Below the falls, pool frequency 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

124

is better, primarily as a result of in-stream restoration projects which placed large wood 

structures in the channel and floodplain. However, stream surveys dating back to the 1980s 

document heavy sediment loads in the pool tail-outs below the falls which are impacting the 

quality of the pool habitat. Baseline determination is: Not properly functioning.

Pool quality is considered good in the Little Zigzag Canyon River. The residual depths of the 

pools are high for a stream of its size and despite the naturally high background levels for 

sediment (USDA Forest Service 2000). Pool frequency did not meet NMFS-AP indicator or 

forest management plan standards, but given that much of the watershed is within designated 

wilderness and has steep topography, it is likely the pool habitat frequency and quality is 

naturally limited and may not have met the above standards. Baseline determination is: Properly 

functioning.

Cooper Spur. Pool frequency in all streams within the action area is below forest plan standards 

(Hydrology specialist report). There are steam reaches that have been impacted by land 

management activities, including a reduction of pool-forming large wood, across the action area 

that may have fewer pools now than in the past. Although the forest plan standard is not met in 

any action area stream, most streams in the action area have at least some reaches within the 

range of natural conditions given stream size, gradient, and valley type in the action area. 

Baseline determination is: Properly functioning.

Table 13. Resource indicators and measures for the existing condition that may be affected by the 

land exchange

Environmental Baseline Condition

Indicator

Camp Creek Little Zigzag 

River

Tilly Jane Creek Ash & Doe Creek

PF FAR NPF PF FAR NPF PF FAR NPF PF FAR NPF

Sediment, Turbidity 

and Substrate

X X X X

Chemicals/Nutrients X1 X1 X1 X1

Change in 

Peak/Base Flows

X X X X

Change in Stream 

Drainage Network

X X X X2

Pool Frequency and 

Quality

X X X X2

Note: PF = Properly functioning; FAR = Functioning at risk; NPF = Not properly functioning.

1 No direct data.

2 Limited data.

Environmental Consequences

Measures and Indicators

NOAA Fisheries has worked with the U.S. Fish and Wildlife Service (USFWS), Bureau of Land 

Management (BLM), and the Forest Service to revise the methods for making determinations of 

effect for land management activities impacting ESA-listed salmonid species in the Northwest 

Forest Plan geographical area (USDA Forest Service 2005). This approach was used to assess the 

effects of the proposed action. In this regard, the elements of the proposed action were analyzed 

for potential effects on Lower Columbia River Chinook salmon, Lower Columbia River Coho 

salmon, and Lower Columbia River (Distinct Population Segment) steelhead due to changes in 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

125

the habitat pathways of water quality, habitat access, habitat elements, channel conditions and 

dynamics, flow/hydrology, and watershed conditions. In applying the analysis approach, the 

agencies consider eight factors, derived largely from the joint NOAA Fisheries and U.S. Fish and 

Wildlife Service ESA Section 7 Consultation Handbook, when evaluating the effects of an action 

on habitat indicators and subsequently the effects on ESA-listed fish. These factors are 

proximity, probability, magnitude (severity and intensity), nature, distribution, frequency, 

duration, and timing, where applicable.

This analysis considered the potential direct and indirect effect of the project’s elements on each 

habitat indicator, and then utilized the relevant factors to determine if there was an effect and 

whether it was measurable, insignificant, discountable, or beneficial. A summary for each habitat 

indicator was developed to ascertain whether effects from various elements combine to create 

adverse effects on any of the indicators. These effects and those of interrelated or interdependent 

actions to the proposed action were considered to reach an overall effect determination for this 

project. The effects of other concurrent Federal actions are disclosed to provide information to 

assist the Services in their jeopardy and destruction/adverse modification of critical habitat 

determinations.

Methodology and Analysis Assumptions

This effects analysis utilizes research, relevant monitoring, field data, previous experience and 

professional judgment, as well as GIS information, to provide the context, amount, and duration 

of potential effects on aquatic resources from the proposed project. The physical scientist reports 

on soils and hydrology provide the basis for the analysis for effects to aquatic habitat. The 

analysis method utilized to determine potential impact to fish, aquatic invertebrates, and their 

associated habitat are listed below.

• Determine known and suspected locations of federally listed or proposed aquatic species, 

designated critical habitat, essential fish habitat, Region 6 Regional Forester’s sensitive 

species and survey and manage species, and Mt. Hood National Forest management 

indicator species in relation to proposed project activities.

• Assess proposed project activities and determine the aquatic habitat elements potentially 

impacted and the geographic area where effects could occur (i.e., the action area).

• Overlap the species/habitat locations with the action area and determine which 

species/habitat could be affected by project activities.

• When species/habitat overlaps with the action area impacts are predicted from proposed 

project activities to individuals and their associated habitat. 

• Potential effects to aquatic fauna and habitat were determined from the following:

♦ Direct and/or indirect effects to individuals from proposed activities;

♦ Potential reductions in stream shade and subsequent increases in water temperature 

compared to existing levels;

♦ Potential increases in erosion and fine sediment input to streams and wetlands 

compared to existing levels;

♦ Potential impacts to existing and future levels of large wood in stream channels and 

Riparian Reserves, including any impacts to large wood recruitment; 

♦ Potential impacts to the quantity and quality of pool habitat; and,
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

126

♦ Cumulative effects associated with ongoing or proposed projects in the action area or 

close enough so that cumulative effects could occur.

• Where impacts to individuals or habitat parameters discussed above result from proposed 

project activities, the potential impacts to aquatic species/habitat were analyzed and then 

the effects to the biological resource were determined based on professional experience, 

applicable surveys/studies, and available literature/research.

• Assumptions associated with this methodology are listed below.

♦ Aquatic faunal and habitat survey data utilized is the latest available and utilized 

standard survey protocols. It is assumed that this information is representative of 

current conditions unless otherwise noted.

♦ Clackamas County Zoning and Development Ordinance, 704 River and Stream 

Conservation Area (RSCA), would be applied to ensure that medium-sized fish 

bearing, perennial channels (type F streams) in Government Camp will have a 

protective buffer of 70 feet and small-size fish bearing, perennial channels (small type 

F) would have a protective buffer of 50 feet. Small streams have an average annual 

flow of 2 cubic feet per second or less. Medium streams have an average annual flow 

greater than 2 cubic feet per second but less than 10 cubic feet per second. Large 

streams have an average annual flow of 10 cubic feet per second or greater.

♦ Clackamas County Zoning and Development Ordinance, 704 River and Stream 

Conservation Area (RSCA), would be applied to ensure that aquatic organism passage 

would be retained in the event roads or infrastructure cross streams in the Government 

Camp parcels.

♦ The Oregon Forest Practices Act standards for all commercial activities involving the 

establishment, management, or harvesting of trees on Oregon’s forestlands was used to 

evaluate the current management of private forestlands in the Cooper Spur action area.

♦ The Hood River County Stream Protection Overlay Zone was used to evaluate the 

current management of private non-forested lands in the Cooper Spur action area.

♦ The areas of impact outlined in the environmental impact statement, chapter 2, are the 

actual areas of disturbance. 

Direct and Indirect Effects

Alternative 1

Under the no-action alternative, current management plans would continue to guide management 

of the project area. The land exchange would not be implemented and the purpose and need 

would not be met. The parcels north of the village of Government Camp would remain under 

National Forest System ownership under their current land allocations. The parcels in the Cooper 

Spur area would remain under private ownership. The existing 1,172-acre Cooper Spur Ski Area 

special use permit area would remain the same. No new special use permit prospectus would be 

advertised. 

The designation of wilderness would not occur on 1,709 acres, and there would be no 

measurable change to aquatic habitat and fauna because the existing land allocations under the 

Forest Plan and the Northwest Forest Plan include protective measures that preserve aquatic 

ecosystems. In the near term (years), conditions for aquatic habitat and fauna under National 

Forest System management would remain essentially unchanged from existing conditions unless 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

127

natural events, such as floods or fire, occurred. Over the long term, aquatic habitat would 

continue to recover under either the existing land use allocations or the wilderness designation. 

The Crystal Springs Watershed Special Resources Management Unit would not be created. The 

2,090 acres of National Forest System lands that are currently in the land use allocations A4 (660 

acres), A11 (236 acres), B2 (1,160 acres), and C1 (34 acres) would continue to be classified as 

they are now and aquatic resources would continue to be protected for the foreseeable future. 

The Crystal Springs Watershed Special Resources Management Unit would not be established on 

the existing private lands and riparian reserves would not be established on existing private land. 

In this case, the private forestland adjacent to streams would continue to be protected under the 

Oregon State Forest Practices Act. The private non-forested land would continue to be protected 

under Hood River County stream protection overlay regulations. The difference between 

preservation of aquatic habitat under the Northwest Forest Plan and the Oregon State Forest 

Practices and Hood River County Regulation is difficult to measure since all three are designed 

to prevent aquatic ecosystem loss. It is possible that there would be an increased buffer width 

(riparian reserve) which could provide more protection for riparian resources, but those changes 

are not expected to change the functional processes in the East Fork Hood River Watershed 

(Hydrology specialist report).

There would be no development on Federal land in the headwaters of Camp Creek and the Little 

Zigzag River, and therefore, no increase in effects to federally threatened fish species or 

designated critical habitat or essential fish habitat, or to sensitive aquatic species or management 

indicator species salmonids. There would be no change to aquatic habitat in the Cooper Spur 

action area because the existing Federal lands would remain within Federal status. A summary of 

the effects of the no-action alternative on habitat elements that may have been affected by the 

project activities is provided in table 14. 

Sediment, Turbidity and Substrate

Because no ground-disturbing actions would occur, the existing condition in regards to fine 

sediment and turbidity levels in both action areas would remain. Current sources of fine 

sediment including roads, winter-time sanding, and housing and recreation development would 

continue to contribute sediment into Camp Creek and the Cooper Spur action area streams for 

the short term and long term. In Camp Creek, there would be no increase in sediment from the 

conversion of forested lands to residential lands. In the Little Zigzag River, there would be no 

increase in sediment as a result of development within the tributary headwaters. In summary, 

sediment input to streams from human-caused activities would remain the same in Camp Creek 

and the Cooper Spur subwatersheds, but would not increase in the Little Zigzag River tributary.

Chemicals/Nutrients

Because no change in land use or ground-disturbing actions would occur, the existing condition 

in regards to current sources of chemicals and nutrients would remain the same in both action 

areas.

Change in Peak/Base Flows

Because no change in land use or ground-disturbing actions would occur, the existing condition 

in regards to current sources of chemicals and nutrients would remain the same in both action 

areas. Because no increase in impervious surfaces or storm-drainage networks would occur on 

Federal land, the existing condition in regards to peak flows would remain unchanged.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

128

Change in Stream Drainage Network

Because no change in land use or ground-disturbing actions would occur, the existing condition 

in regards to current sources of chemicals and nutrients would remain the same in both action 

areas. Because no increase in road and ditch networks would occur on Federal land, the existing 

condition in regards to stream drainage would remain unchanged.

Pool Quantity and Quality

Because no change in land use or ground-disturbing actions would occur, the existing condition 

in regards to pool quantity and quality would remain the same in both action areas. The principal 

mechanism effecting pools is related to sediment delivery and would therefore not change.

Table 14. Change in effect to habitat indicators for alternative 1 (no action)

Habitat Indicator

No-action 

Effect 

Government 

Camp:

Camp Creek

No-action 

Effect 

Government 

Camp:

Little Zigzag

No-action 

Effect 

Cooper Spur:

Tilly Jane

No-action 

Effect

Cooper Spur:

Doe/Ash

Sediment, 

Turbidity and 

Substrate

Existing 

Condition

Not properly 

functioning

Properly 

functioning

Functioning at 

risk

Functioning at 

risk

Alternative 1 No change No change No change No change

Chemicals and 

Nutrients

Existing 

Condition

Functioning at 

risk

Properly 

functioning

Properly 

functioning

Properly 

functioning

Alternative 1 No change Maintain No change No change

Change in Stream 

Drainage Network

Existing 

Condition

Functioning at 

risk

Properly 

functioning

Functioning at 

risk

Properly 

functioning

Alternative 1 No change Maintain No change No change

Change in 

Peak/Base Flows

Existing 

Condition

Functioning at 

risk

Properly 

functioning

Functioning at 

risk

Properly 

functioning

Alternative 1 No change Maintain No change Maintain

Pool Frequency 

and Quality

Existing 

Condition

Not properly 

functioning

Properly 

functioning

Functioning at 

risk

Functioning at 

risk

Alternative 1 No change Maintain No change No change

Alternative 2

The following effects analysis assumes full build-out within five years once the land exchange is 

completed. Depending on the exact size of the conservation easement, there would be 54 to 

65 developable acres or 212 to 260 lots that could be potentially developed. Each lot would be 

0.25 acre in size and impervious surface would not exceed 40 percent. The building type would 

be residential and would not exceed 50 feet in height. Wetlands would be preserved and stream 

buffers would prevent development within 50 to 70 feet of the stream bank (please refer to the 

proposed action in chapters 1 and 2 of the draft EIS for complete discussion of the proposed 

action and analysis assumptions).

As previously described, the number of habitat parameters that may be affected by proposed 

project activities are related to water quantity and quality, substrate and fine sediment levels in 

streams, and pool quantity and quality.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

129

Direct Effects. Direct effects are those that occur during project implementation; in this case 

actions such road and home building in Government Camp. To directly impact aquatic 

species/habitat the activity needs to be in close proximity to the water body where they reside, 

often within the water body itself. From an aquatic perspective, direct effects most often result in 

disturbance to aquatic organisms—forcing movement or a flight response. Depending on the 

activity, it is possible that individuals can be injured or killed; this is almost always a result of 

people or equipment working directly in water. Direct habitat effects are possible, but depend on 

the activity. For example, removal of vegetation directly adjacent to a stream can immediately 

reduce shade, thereby reducing available cover for fish which might alter their use of that area.

This analysis assumes that Clackamas County zoning and construction codes would provide 

stream protection buffers of 70 feet for medium-sized perennial, fish-bearing streams, and 

50 feet for small-sized perennial, fish-bearing streams, and would protect wetlands. These 

buffers are sufficient to prevent any construction material or equipment from entering the stream 

and should prevent disturbance to streamside vegetation. Therefore, there are no direct effects 

identified for aquatic organisms or their habitat in the Government Camp analysis area. There are 

no direct effects identified for the Cooper Spur action area as there would be no ground 

disturbance.

Indirect Effects. Indirect effects are effects caused by or resulting from the proposed actions, are 

later in time, and are reasonably certain to occur. For example, in the vegetation removal 

scenario mentioned above in the “Direct Effects” section, the indirect effect associated with 

shade reduction could be an increase in water temperature. The magnitude of such an effect, if it 

occurred, would depend on the amount of vegetation removed, location and elevation of the 

stream, amount of stream flow, etc. In this case, indirect effects from the proposed action are 

limited to aquatic organisms present in the Government Camp action area (table 11) as there are 

no effects documented in the Cooper Spur area because the difference between preservation of 

aquatic habitat under the Northwest Forest Plan and the Oregon State Forest Practices and Hood 

River County regulation is difficult to measure since all three are designed to prevent aquatic 

ecosystem loss.

Sediment, Turbidity and Substrate

Camp Creek. In Camp Creek, high levels of sedimentation have resulted in increased turbidity 

and embeddedness. Sediment modeling predicts an increase of approximately 70 tons of 

sediment entering Camp Creek each year as a result of the proposed action. As previously 

described, the existing condition related to sediment is acute with an estimated 2,144 tons of 

sediment entering Camp Creek from human activities (Hydrology Specialist Report). The 

projected increase in sediment of 70 tons generated from new roads and the development of the 

parcels is a substantial increase, and when compared to the natural background level of 504 tons 

per year, results in a 14 percent increase within Camp Creek (Hydrology Specialist Report).

Once sediment enters a stream it interacts with complex stream dynamics. Above Yokum Falls, 

the confined and simplified channel lacks large wood and connectivity to its floodplain and offchannel habitat. Sediment is expected to be transported through the relatively confined and 

simplified channel reaches in the Government Camp area and settle out in the lower gradient 

valley below Yokum Falls (about 2.5 miles below the project area). Sediment sampling 

demonstrates that this is an area where high levels of fine sediment accumulate from upstream 

sources (USDA Forest Service 1992, 2000, 2004). During flood and storm events, the overall 

storage capacity serves to buffer sedimentation impacts on downstream areas. Large debris in 

channels reduces the rate of downstream sediment movement and tends to feed sediment through 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

130

the stream ecosystem in a slow trickle (Hydrology specialist report). In Camp Creek, storage 

capacity is poor because there is a lack of large wood structure which can capture and retain 

sediment; channel riffles are armored as a result of embedded fines; and many of the pools are 

already filled with fine sediments (USDA Forest Service 1992, 2000). Therefore, it is expected 

that as sediment is generated during annual storm events, the material will be routed downstream 

within a short period of time (days to weeks). 

Camp Creek is spring fed and quite clear, with turbid conditions naturally occurring only during 

flood or high water events. Turbidity increases related to the project may temporarily redistribute 

resident rainbow and cutthroat as well as Lower Columbia River salmon and steelhead 

individuals as they either avoid it or move into it to feed on drifting invertebrates. Primary 

production, benthic invertebrate abundance, and thus, food availability, for fish may be reduced 

as sediment levels increase due to reductions in photosynthesis within murky waters (Cordone 

and Kelley 1961; Loyd et al. 1987). Social (Berg and Northcoate 1985) and feeding behavior can 

be disrupted by increased levels of suspended sediment (Noggle 1978). 

Turbidity and sediment increases are most likely expected October through March during rain 

and snow-melt events when Chinook and coho are spawning, which may reduce egg survival 

and developing alevins by reducing the availability of dissolved oxygen in the gravel (Everest et 

al. 1987; Hicks et al. 1991). Rearing capacity of Lower Columbia River salmon and steelhead 

habitat may decrease as cobble embeddedness levels increase. Furthermore, over-wintering 

rearing habitat within substrate may be a limiting factor to fish production and survival, and the 

reduction of this over-wintering habitat may result in increased levels of mortality during rearing 

life stages (as found in USDA Forest Service et al. [2013]). Over time, the continuous input of 

even small amounts of sediment added to the existing condition may have chronic negative 

effects to Lower Columbia River salmon and steelhead critical habitat.

Little Zigzag River. The tributary to the Little Zigzag River is relatively unchanged from its 

historic condition, based on ecosystem function. Human-caused disturbance in the upper 

watershed is primarily related to hiking trails and dispersed recreation. Existing sediment, 

turbidity, and embeddedness levels are low and considered to be properly functioning. Turbidity 

and embeddedness are not currently processes of concern in the tributary because the intact, 

complex channel and floodplain habitat appear to be providing adequate storage capacity for the 

negligible amount of sediment entering from the trail network. Sediment modeling predicts an 

increase of approximately 12 tons of sediment entering the Little Zigzag River Tributary and 

then the Little Zigzag River each year as a result of the proposed action. This is a substantial 

increase from the existing condition in the Little Zigzag Tributary, but it is difficult to assess 

whether the added sediment will tip the scale on turbidity and embeddedness as those are 

processes that are hard to predictively model. 

In the Little Zigzag River, there are inputs from highway sanding (406 tons) and existing roads 

(3 tons) and natural sediment background levels are high due to the glacial influence of the 

stream. An increase of 12 tons may not be large when compared to the existing condition, but is 

still a concerning amount. It is difficult to assess whether the added sediment will tip the scale on 

turbidity and embeddedness as those are processes that are hard to predict. It is less likely that 

the increased turbidity or sediment will change the existing condition in the Little Zigzag River 

because the amount of sediment may be undetectable at that scale. 

There are no listed fish in the tributary and resident fish presence is unknown, although there is 

suitable habitat within the tributary. There is also suitable habitat for A. scotti in the lowermost 

reach of the tributary where it meets the Little Zigzag River which could be affected. Lower 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

131

Columbia River steelhead critical habitat is present below Little Zigzag Falls and may be slightly 

impacted by the increase in sediment delivery but it is unlikely that turbidity would result in 

behavioral changes in aquatic biota. 

Indicator Summary. Sediment and turbidity associated with this project would occur annually 

and would result in chronic, human-caused sediment delivery into designated critical habitat and 

essential fish habitat occupied by Lower Columbia River salmon and steelhead, management 

indicator species trout, and Region 6 sensitive aquatic species in Camp Creek and the Little 

Zigzag River. The source and delivery potential is detailed in the Soil and Hydrology specialist 

reports. It would likely increase during high flows for the first couple of storm events each fall as 

unstable soils are carried into nearby stream channels. During storm events, the duration of 

increased turbidity would depend on the length of time and the intensity of the storm. The total 

amount of sediment generated within the Camp Creek action area resulting from human-caused 

disturbance would be increased by about 14 percent and overall would remain high. In the Little 

Zigzag River, the effect on habitat for fish and aquatic invertebrates is expected to increase by 

12 tons, which may not result in behavioral changes in aquatic biota but could change some 

habitat conditions. As a result, there is a high probability that there would be a negative effect in 

Camp Creek. There is also a high probability that there would be a slightly negative effect in the 

Little Zigzag River.

Chemicals/Nutrients

Roofs, roadways, and parking lots are impervious and accumulate a mixture of contaminants, 

including metals; petroleum-derived compounds from oil, grease, and vehicle exhaust; and 

pesticides; among others. During rainfall events, storm water collects these contaminants from 

the impervious surfaces in Government Camp and Highway 26 and deposits them into Camp 

Creek. 

When toxics enter our waterways via storm water runoff, they can cause a variety of adverse 

effects to aquatic species. In addition to directly impacting salmon and steelhead, toxics can 

harm or kill the aquatic insects that salmon eat. Pollution risks vary depending on the particular 

chemical, the amount transported in storm water, and environmental persistence. Recent research 

has shown that common contaminants can impair salmon health in a variety of ways. For 

example, certain metals, such as copper, and pesticides are toxic to the salmon nervous system, 

thereby disrupting feeding and predator avoidance. Copper is used in roofing materials, treated 

wood, and is a by-product found in the exhaust and brake pads of vehicles. Pesticides and 

petroleum-derived compounds suppress the immune system, rendering salmon more vulnerable 

to pathogens that cause lethal diseases. Petroleum-derived compounds are also known to depress 

growth rate of juvenile salmon, which can affect their survival. Other compounds target the 

developing cardiovascular system, causing heart failure or permanent heart defects (as found in 

NOAA Fisheries [2016]).

Camp Creek. As previously described, the magnitude of chemical and nutrient levels in Camp 

Creek is unknown. The Government Camp sewage treatment facility has occasionally discharged 

untreated effluent into Camp Creek, and winter-time road de-icing agents likely enter Camp 

Creek. Runoff pollution occurs; however, the magnitude and duration is unknown. A 

combination of impervious surface development and peak flow changes was used to assess 

potential increases in surface water that could be carrying runoff pollution. The project is 

expected to result in a development footprint (impervious surface) of about 32 acres (40 percent 

of the project parcel) in the Camp Creek Watershed. There are 2,073 acres in the subwatershed 

above Yokum Falls which is where most of the increase in peak surface flows is predicted to 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

132

occur (Hydrology Specialist Report). Increases in peak flows were detectable near Government 

Camp, but reduced as they traveled downstream through the system. Modeling showed peak 

flow increases of 21 percent at Highway 26, and 11 percent at Yokum Falls, and not detectable at 

the confluence with the Zigzag River. The increase in surface area that may contribute to runoff 

pollution is small when compared to the watershed area, but changes to peak streamflow that 

could be carrying contaminants through sensitive and Endangered Species Act (ESA)-listed fish 

habitat is measurable. Impacts to aquatic invertebrates in Camp Creek are difficult to measure, 

but are assumed to be small.

Little Zigzag River. Approximately 15 acres within the western parcel of the land exchange that 

is part of the Little Zigzag River Tributary Watershed would be developed (impervious surface) 

out of a total of 538 acres (3 percent); with a modeled 31 percent change in peak flows as a result 

of the project. Hence, there would be a measurable increase in storm-water that could be 

carrying pollutants into the tributary and on into the Little Zigzag River where sensitive and 

ESA-listed species are present. Impacts to aquatic organisms are difficult to measure, but are 

assumed to be small.

Indicator Summary. Human-caused runoff pollution into Camp Creek and the Little Zigzag River 

is a process of concern for aquatic organisms and their habitat. Based on the Wildcat Peak flow 

modeling described in the Hydrology specialist report, there would be increases in storm-water 

runoff into Camp Creek that would have a greater effect on aquatic species above Yokum Falls 

(as compared to below). In the Little Zigzag River Tributary there is currently no known runoff 

or nutrient pollution. As a result of the project, there would be a small increase that would not 

likely be detectable at the 7th-field scale. As a result there is a high probability that there would 

be a slightly negative effect.

Change in Peak/Base Flows

There are two several primary pathways that can change flows in the Government Camp area. 

The first is related to the amount of water being withdrawn from the stream for human use (such 

as for drinking water or snowmaking). The second is related to change in peak flows due to an 

increase in the stream-drainage network from new road ditches or trails. As described in the 

hydrology specialist report, modeling suggests there would be no change in flows related to 

water withdrawal, but there would be a change as a result of stream-drainage network increases. 

The report states that,

A primary mechanism that changes the volume and timing of peak flows is the road 

network, which essentially increases the drainage density of channels, intercepts 

subsurface water, and decreases the time for overland runoff to reach the stream channel. 

Even though a watershed receives the same amount of precipitation, it is transported 

through the system much more quickly, thus resulting in higher peak discharges and 

resultant increases in stream power. This increased stream power can more effectively 

erode the streambed and banks. Because the total amount of water remains relatively 

constant, base flows decrease because the rapid runoff reduces the total amount of water 

that can infiltrate and be stored in the soil (Castro [2003] as found in Hydrology 

Specialist Report).

At the site scale, both Camp Creek and the unnamed tributary to the Little Zigzag River have 

predicted peak streamflow increases above 10 percent, which is considered to be above the 

threshold where changes to aquatic habitat occur. Based on predicted increases in peak 

streamflows, streambed composition, and stream gradient; there may be impacts in the form of 

increased bank erosion, channel scour, channel widening, and sedimentation in these areas. As 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

133

the watershed size gets larger, peak streamflow impacts are reduced in Camp Creek at Yocum 

Falls; the Little Zigzag River at the confluence with the Zigzag River predicted peak flow 

increases are less than 10 percent.

Streamflows may result in less suitable habitat for resident fish, as well as listed salmon and 

steelhead, and may have an adverse effect on A. scotti habitat in the Little Zigzag River 

Tributary. Stable discharge appears to be one of the principal habitat elements that is required for 

this species. Changes to the stream drainage network and resulting increases in peak flows may 

result in scouring or shearing along the mossy stream banks where this caddisfly resides. There 

is potential for long-term, localized effects to Scott’s apatanian habitat downstream of the 

tributary. Since this area is considered to be the bottom of the available habitat in the Little 

Zigzag River, the effects are not expected to be significant; however, any changes to suitable 

habitat for a species with such limited range is a cause for concern. 

Indicator Summary. Annual storm events and saturated soil conditions are likely to result in 

increased peak flows, which may affect channel habitat in Camp Creek above Yokum Falls 

where resident trout and Region 6 sensitive species occur, but is not expected to be detectible in 

critical habitat below the falls. The magnitude of the effect to the Little Zigzag River Tributary is 

much greater (31 to 62 percent) and will likely result in significant changes to channel structure 

and composition where resident trout and Region 6 sensitive species may occur. In the Little 

Zigzag River 7th-field watershed peak flows are modeled to increase about 6 percent, which is 

not likely to significantly alter critical habitat for listed fish species. As a result, there is a high 

probability that there would be a slightly negative effect at the 7th-field-watershed scale in Camp 

Creek and the Little Zigzag River. 

Change in Stream Drainage Network

As described in the Hydrology Specialist Report, changes in the stream drainage network is 

strongly correlated to the road network. The key process of concern is associated with inboard 

ditches delivering runoff to a stream where a road intercepts the stream. This channel 

lengthening process can result in increased peak flows which is described above in the stream 

drainage network section. 

Pool Quantity and Quality

In Camp Creek, the combination of multiple factors has resulted in a highly impaired existing 

condition in regards to pool quality and quantity. The lack of large wood and the large volumes 

of fine sediment related to human-caused disturbance, results in pool frequency and quality 

which are considered to be not properly functioning. In the Little Zigzag Subwatershed, primary 

pool frequency is considered to be properly functioning even though it does not meet some 

Mt. Hood National Forest standards. Given the steep topography within the upper watershed it is 

likely the pool habitat frequency and quality is naturally limited and may not have met the above 

standards. 

Indicator Summary. Given the existing condition in Camp Creek, there could be some additional 

reduction in pool volume resulting from increased fine sediment levels. In the Little Zigzag 

Tributary some reductions in pool quantity could occur as a result of increased fines in pools. As 

a result, there is a high probability that there would be a negative effect at the 7th-fieldwatershed scale in Camp Creek, and a high probability that there would be a slightly negative 

effect at the 7th-field-watershed scale in the Little Zigzag River.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

134

Table 15. Change in effect to habitat indicators for alternative 2 (proposed action)

Habitat Indicator Proposed 

Action Effect 

Government 

Camp:

Camp Creek

Proposed 

Action Effect 

Government 

Camp:

Little Zigzag

Proposed 

Action Effect 

Cooper Spur:

Tilly Jane

Proposed 

Action Effect 

Cooper Spur:

Doe/Ash

Sediment, Turbidity 

and Substrate

Existing 

Condition

Not properly 

functioning

Properly 

functioning

Functioning at 

risk

Functioning at 

risk

Alternative 2 Degrade Degrade No change No change

Chemicals and 

Nutrients

Existing 

Condition

Functioning at 

risk

Properly 

functioning

Properly 

functioning

Properly 

functioning

Alternative 2 Degrade Degrade No change No change

Change in 

Peak/Base Flows

Existing 

Condition

Functioning at 

risk

Properly 

functioning

Functioning at 

risk

Properly 

functioning

Alternative 2 Degrade Degrade No change No change

Change in Stream 

Drainage Network

Existing 

Condition

Functioning at 

risk

Properly 

functioning

Functioning at 

risk

Properly 

functioning

Alternative 2 Degrade Degrade No change Maintain

Pool Frequency 

and Quality

Existing 

Condition

Not properly 

functioning

Properly 

functioning

Functioning at 

risk

Functioning at 

risk

Alternative 2 Degrade Degrade No change No change

Cumulative Effects

Cumulative effects include the effects of past, present, and reasonably foreseeable future state, 

tribal, local or private actions that overlap in time and space within the action area (i.e., affected 

environment) of the Federal action subject to consultations (50 CFR 402.02). The “reasonably 

foreseeable” clause is a key factor in assessing and applying cumulative effects and could 

include actions that are permitted, imminent, have an obligation of venture, or have initiated 

contracts (U.S. Fish and Wildlife Service and NOAA Fisheries 1998). Past and present impacts 

are incorporated as part of the environmental baseline and discussed here in the effects 

discussion.

Only those indicators that are effected by the project are included in the cumulative effects 

analysis (if the action has no direct/indirect effects there would be no cumulative effects). The 

spatial context for the following cumulative effects analysis is the action area as described 

previously. Project/activities occurring outside this area may have an effect on aquatic 

species/habitat, but would not add to those effects from projects proposed in this environmental 

assessment. The temporal context depends on the existing or future project/activity. If there is an 

overlap in time from an effects perspective then it is included. 

Cumulative effects from an aquatic species and habitat perspective overlap considerably with 

water quality (sediment delivery, chemicals/nutrients/ peak flows) cumulative effects because 

most of the attributes analyzed by the hydrologist are directly related to aquatic habitat 

conditions. 

The analysis summary outlined in table 16 follows a similar format as the cumulative effects 

table in the Hydrology Specialist Report.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

135

Table 16. Summary of past, present, and reasonably foreseeable future actions which may contribute to cumulative effects to aquatic fauna and habitat 

for all alternatives

Project

Potential

Effects Overlap in

Measurable 

Cumulative 

Effect? Extent, Detectable?

Aquatic Species and Stream Habitat 

Effects

Time Space

Ongoing ODOT 

road maintenance, 

including 

snowplowing on 

National Forest 

System lands, 

Government Camp, 

and Highway 26

Suspended 

Sediment 

Yes Yes Yes An overlap in time and location exists 

with Highway 26 road maintenance 

(summer and winter). There is annual 

introduction of fine sediment from 

winter safety sanding (2,102 tons into 

Camp Creek and 406 tons into Little 

Zigzag) that may mix with the fine 

sediment from the project which is 

modeled to be 70 tons in Camp Creek 

and 3 tons in Little Zigzag River. There 

is a likelihood of negative cumulative 

effects which are measurable both in 

the short term and long term (chronic).

Potential for cumulative effects to aquatic 

resources are expected to extend from the 

Government Camp parcels to the mouth of 

Camp Creek and the Little Zigzag River 

Tributary. Effects are expected to impact 

habitat for resident fish, Region 6 aquatic 

organisms, and Lower Columbia River

coho, Chinook, and steelhead. Based on 

the volume of sediment entering both 

subwatersheds, it is anticipated the 

following habitat elements will be further 

degraded: water quality, pool quality and 

quantity, spawning and rearing habitat. Fish 

may exhibit sediment avoidance behavior. 

Egg survival may be reduced and juvenile 

survival may be reduced. Aquatic

invertebrate species may experience poor 

stream conditions. 

Chemicals/N

utrients

Yes Yes Yes An overlap in time and location exists 

with Highway 26 winter de-icing and 

runoff pollution. Increased runoff from 

impervious surfaces in the Government 

Camp parcels may mix with the runoff 

pollution from Highway 26 and winter 

de-icing agents. There is a moderate 

risk of cumulative effects in both 

subwatersheds, but the magnitude and 

extent is difficult to measure.

Potential for cumulative effects to aquatic 

organisms are expected to extend from the 

Government Camp parcels to below Yokum 

Falls and the Little Zigzag River Tributary. 

Effects are expected to impact habitat and 

aquatic species described in table 17 and 

table 18. Aquatic organisms may be 

exposed to increased pollution from runoff. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

136

Project

Potential

Effects Overlap in

Measurable 

Cumulative 

Effect? Extent, Detectable?

Aquatic Species and Stream Habitat 

Effects

Time Space

Ongoing Forest 

Service trail use 

and maintenance 

(winter and 

summer uses) for 

the Glade, Alpine, 

Timberline to 

Town, Mirror Lake, 

and Government 

Camp area trails

Suspended 

Sediment

Yes Yes Yes An overlap in time and location exists 

with these trails and the project. At 

each stream crossing, small amounts 

of fine sediment generated from the 

trail can enter the stream channel and 

may mix with the fine sediment from 

the project. The amount at the trails is 

likely small and local, but will occur 

over the life of the trails (decades). 

There is a moderate risk of cumulative 

effects in both subwatersheds, but the 

magnitude should remain small and 

localized. 

Potential for cumulative effects to aquatic 

resources is expected to be localized with a 

potential for some sediment avoidance 

behavior. Aquatic invertebrate species may 

have low levels of short-term negative 

stream conditions. Trail maintenance 

project design criteria are in place that 

should reduce the overall amount of 

sediment delivered to streams and 

minimize effects to aquatic resources. 

Stream 

Drainage 

Network 

Yes Yes No Trails are hydrologically connected by 

ditch-lines and gullies, and therefore, 

the stream network is considered 

lengthened wherever they interrelate 

(Parker 2011). There is a small risk of 

cumulative effects in both 

subwatersheds, but the magnitude 

should remain small and localized.

Aquatic invertebrate species may have low 

levels of short-term negative stream 

conditions with slightly higher turbidity and 

some local scour. Trail maintenance project 

design criteria are in place that should 

reduce the overall amount of sediment 

delivered to streams and minimize effects 

to aquatic resources.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

137

Project

Potential

Effects Overlap in

Measurable 

Cumulative 

Effect? Extent, Detectable?

Aquatic Species and Stream Habitat 

Effects

Time Space

Mirror Lake 

Trailhead 

Relocation Project

Suspended 

Sediment

Yes Yes Yes This new trail will cross Camp Creek 

once and cross nine tributaries to 

Camp Creek. Small amounts of fine 

sediment generated from the trail can 

enter the stream channel and may mix 

with the fine sediment from the project. 

The amount at the trails is likely small 

and local, but will occur over the life of 

the trails (decades). There is a 

moderate risk of cumulative effects to 

the Camp Creek Subwatershed, but 

the magnitude should remain small 

and localized.

Potential for cumulative effects to aquatic 

resources is expected to be localized with a 

potential for some sediment avoidance 

behavior. Aquatic invertebrate species may 

have low levels of short-term negative 

stream conditions. Trail maintenance 

project design criteria are in place that 

should reduce the overall amount of 

sediment delivered to streams and 

minimize effects to aquatic resources.

Stream 

Drainage 

Network

Yes Yes Yes Trails are hydrologically connected by 

ditch-lines and gullies, and therefore, 

the stream network is considered 

lengthened wherever they interrelate 

(Parker 2011). There is a moderate 

risk of cumulative effects to the Camp 

Creek Subwatershed, but the 

magnitude should remain small and 

localized.

Potential for cumulative effects to aquatic 

resources is expected to be localized with a 

potential for some localized scour and 

channel change. Trail maintenance project 

design criteria are in place that should 

reduce the overall amount of sediment 

delivered to streams and minimize effects 

to aquatic resources.

ODOT Highway 26 

Safety Widening 

Project

Suspended 

Sediment

Yes Yes Yes There may be an overlap in timing of 

this project with the Highway 26 safety 

project; any minor suspended 

sediment would not be measurable 

due to implementation of mitigation 

measures and design criteria and 

conformance with existing standards 

and guidelines in the project.

Potential for cumulative effects to aquatic 

resources is expected to be localized with a 

potential for some sediment avoidance 

behavior. Aquatic invertebrate species may 

have low levels of short-term negative 

stream conditions. Road maintenance 

project design criteria are in place that 

should reduce the overall amount of 

sediment delivered to streams and 

minimize effects to aquatic resources.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

138

Project

Potential

Effects Overlap in

Measurable 

Cumulative 

Effect? Extent, Detectable?

Aquatic Species and Stream Habitat 

Effects

Time Space

ODOT Highway 26 

Safety Widening 

Project (continued)

Chemicals/

Nutrients

Yes Yes Yes An overlap in time and location exists 

with the Highway 26 safety project and 

this project. Increased runoff from 

impervious surfaces in the Government 

Camp parcels may mix with the runoff 

pollution from Highway 26. There is a 

moderate risk of cumulative effects in 

both subwatersheds, but the 

magnitude and extent is difficult to 

measure.

Potential for cumulative effects to fish are 

expected to extend from the Government 

Camp parcels to Yokum Falls and the Little 

Zigzag River Tributary. Effects are 

expected to impact habitat and aquatic 

species described in table 17 and table 18. 

Aquatic organisms may exposed to 

increased pollution from runoff.

Stream 

Drainage 

Network

Yes Yes Yes Roads are hydrologically connected by 

ditch-lines and gullies, and therefore, 

the stream network is considered 

lengthened wherever they interrelate 

(Parker 2011). There is a high risk of 

cumulative effects to the Camp Creek 

Subwatershed.

Potential for cumulative effects to aquatic 

resources is expected to be localized with a 

potential for some localized scour and 

channel change. 

SkiBowl and 

Summit ski area 

winter recreation 

activities, operation 

and maintenance

Chemicals/

Nutrients

Yes Yes Increased runoff from impervious 

surfaces in the Government Camp 

parcels may mix with the runoff 

pollution from SkiBowl parking areas. 

There is a moderate risk of cumulative 

effects in the Camp Creek watersheds, 

but the magnitude and extent is difficult 

to measure.

Potential for cumulative effects to fish are 

expected to extend from the Government 

Camp parcels to the mouth of Camp Creek 

and the Little Zigzag River Tributary. Effects 

are expected to impact habitat and aquatic 

species described in table 17 and table 18. 

Aquatic organisms may exposed to 

increased pollution from runoff.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

139

Project

Potential

Effects Overlap in

Measurable 

Cumulative 

Effect? Extent, Detectable?

Aquatic Species and Stream Habitat 

Effects

Time Space

SkiBowl and 

Summit ski area 

summer recreation 

activities, operation 

and maintenance 

(such as bike 

parks, race events 

and concerts)

Suspended 

Sediment

Yes Yes Yes Trails are hydrologically connected by 

ditch-lines and gullies, and therefore, 

the stream network is considered 

lengthened wherever they interrelate 

(Parker 2011). There is a moderate 

risk of cumulative effects to the Camp 

Creek Subwatershed, but the 

magnitude should remain small and 

localized.

Potential for cumulative effects to aquatic 

resources is expected to be localized with a 

potential for some localized scour and 

channel change. Trail maintenance project 

design criteria are in place that should 

reduce the overall amount of sediment 

delivered to streams and minimize effects 

to aquatic resources.

SkiBowl Ski Area 

Snowmaking 

Infrastructure 

Improvements 

Project (water 

withdrawal from 

Camp Creek)

Water 

Quantity

Yes Yes Not 

measurable

Water withdrawal from Camp Creek for 

snowmaking occurs from November 1–

March 30; the total withdrawal is 

0.03 cubic feet per second. 

None.

PGE powerline 

right-of-way 

maintenance

Suspended 

Sediment

Yes Yes Not 

Measurable

No cumulative effects are expected 

due to mitigation measures and design 

criteria implementation, and 

conformance with existing standards 

and guidelines on the existing projects.

None.

Stream 

Drainage 

Network

Yes Yes Not 

measurable

No cumulative effects are expected 

due to mitigation measures and design 

criteria implementation, and 

conformance with existing standards 

and guidelines on the existing projects.

None.

Clackamas County 

waterline/infrastruct

ure maintenance

Suspended 

Sediment

No Yes Not 

Measurable

None. None.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

140

Project

Potential

Effects Overlap in

Measurable 

Cumulative 

Effect? Extent, Detectable?

Aquatic Species and Stream Habitat 

Effects

Time Space

Timberline Ski Area 

Mountain Bike 

Trails and Skills 

Park Project, 

including 

watershed 

restoration 

activities

Suspended 

Sediment

Yes No Not 

Measurable

There may be a spatial and temporal 

overlap of effects of this project with 

the Bike Park project. Several of the 

Bike Park trails are within the Little 

Zigzag River. However, there were no 

effects to aquatic species or habitat 

identified in that watershed as a result 

of the Bike Park Project. 

None.

Camp Creek 

Summer Home 

Tract

Suspended 

Sediment

Yes Yes Yes An overlap in time and location exists 

with the Summer Home Tract on Camp 

Creek and the project. There is annual 

introduction of fine sediment from 

roads and infrastructure present within 

the summer home tract that may mix 

with the fine sediment from the project; 

however, the extent is expected to be 

localized. There is a likelihood of small 

negative cumulative effects which are 

measurable both in the short term and 

long term (chronic).

Potential for cumulative effects to aquatic 

resources are expected to extend from the 

Camp Creek Summer Homes to the mouth 

of Camp Creek and the Little Zigzag River 

Tributary. Effects are expected to impact 

habitat for the species listed in table 17 and

table 18. Based on the volume of sediment 

entering both subwatersheds, it is 

anticipated the following habitat elements 

will be further degraded: water quality, pool 

quality and quantity, spawning and rearing 

habitat. Fish may exhibit sediment 

avoidance behavior. Egg survival may be 

reduced and juvenile survival may be 

reduced. Aquatic invertebrate species may 

experience poor stream conditions.

Chemicals/

Nutrients

Yes Yes Yes Increased runoff from impervious 

surfaces in the Camp Creek tract may 

mix with the runoff pollution from the 

project. There is a moderate risk of 

cumulative effects in the Camp Creek 

Watersheds, but the magnitude and 

extent is difficult to measure.

Potential for cumulative effects to fish are 

expected to extend from the Government 

Camp parcels to the mouth of Camp Creek 

and the Little Zigzag River Tributary. Effects 

are expected to impact habitat and aquatic 

species described in table 17 and table 18. 

Aquatic organisms may exposed to 

increased pollution from runoff.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

141

Project

Potential

Effects Overlap in

Measurable 

Cumulative 

Effect? Extent, Detectable?

Aquatic Species and Stream Habitat 

Effects

Time Space

Camp Creek 

Summer Home 

Tract (continued)

Water 

Quantity

Yes Yes Not 

Measurable

As outlined in the Hydrology specialist 

report, there is not expected to be a 

change in water quantity as a result of 

the project.

None.

Government Camp 

Sewer District 

operations

Chemicals/

Nutrients

Yes Yes Yes An overlap in time and location exists 

with Sanitary Sewer operations and 

this project. Increases in chemicals 

and nutrients are possible because 

chemical runoff from impervious 

surfaces in the Government Camp 

parcels may mix with sanitary sewer 

discharge. There is a moderate risk of 

cumulative effects in the Camp Creek 

Subwatershed, but the magnitude and 

extent is difficult to measure.

Potential for cumulative effects to fish are 

expected to extend from the Government 

Camp parcels to the mouth of Camp Creek. 

Effects are expected to impact habitat and 

aquatic species described in table 17 and 

table 18. Aquatic organisms may exposed 

to increased pollution from runoff and 

nutrients.

Government Camp 

Water District 

operations

Water 

Quantity

Yes Yes Not 

Measureable

As outlined in the Hydrology specialist 

report, there is not expected to be a 

change in water quantity as a result of 

the project. 

None.

Collins Lake Resort 

operations

Chemicals/N

utrients

Yes Yes Yes An overlap in time and location exists 

with the Collins Lake Resort and this 

project. Increases in chemicals and 

nutrients are possible because 

chemical runoff from impervious 

surfaces in the Government Camp 

parcels may mix with Collins Lake 

runoff from impervious surfaces and 

infrastructure. There is a moderate risk 

of cumulative effects in the Camp 

Creek Subwatershed, but the 

magnitude and extent is difficult to 

measure.

Potential for cumulative effects to fish are 

expected to extend from the Government 

Camp parcels to the mouth of Camp Creek. 

Effects are expected to impact habitat and 

aquatic species described in table 17 and 

table 18. Aquatic organisms may exposed 

to increased pollution from runoff.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

142

Project

Potential

Effects Overlap in

Measurable 

Cumulative 

Effect? Extent, Detectable?

Aquatic Species and Stream Habitat 

Effects

Time Space

Collins Lake Resort 

operations

(continued)

Stream 

Drainage 

Network

Yes Yes Yes Roads are hydrologically connected by 

ditch-lines and gullies, and therefore, 

the stream network is considered 

lengthened wherever they interrelate 

(Parker 2011). There is a risk of 

cumulative effects to the Camp Creek 

Subwatershed 

Potential for cumulative effects to aquatic 

resources is expected to be localized with a 

potential for some localized scour and 

channel change. 

Private water 

diversions from 

Camp Creek and 

Little Zigzag

Water 

Quantity

Yes Yes Not 

Measurable

As outlined in the Hydrology specialist 

report, there is not expected to be a 

change in water quantity as a result of 

the project.

None.

Mazama Lodge 

Parking Area 

Expansion Project

Suspended 

Sediment

Yes No No There is no spatial overlap with the 

project and the Mazama Lodge 

Project. The Mazama Lodge Project 

does not occur in the Camp Creek or 

Little Zigzag Subwatersheds.

None.

Operation and 

maintenance of 

Kiwanis Camp

Suspended 

Sediment

Yes Yes Yes An overlap in time and location exists 

with Kiwanis Camp and Little Zigzag 

River and the project. There is annual 

introduction of fine sediment from 

roads and infrastructure present within 

Kiwanis Camp that may mix with the 

fine sediment from the project; 

however, the extent is expected to be 

localized. There is a likelihood of small 

negative cumulative effects which are 

measurable both in the short term and 

long term (chronic).

Potential for cumulative effects to aquatic 

resources are expected to be local and 

extend from the Camp to the mouth of the 

Zigzag River. Effects are expected to 

impact habitat for the species listed in table 

17 and table 18. It is anticipated the 

following habitat elements will be further 

degraded: water quality, pool quality and 

quantity, spawning and rearing habitat. Fish 

may exhibit sediment avoidance behavior. 

Egg survival may be reduced and juvenile 

survival may be reduced. Aquatic 

invertebrate species may experience poor 

stream conditions.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

143

Project

Potential

Effects Overlap in

Measurable 

Cumulative 

Effect? Extent, Detectable?

Aquatic Species and Stream Habitat 

Effects

Time Space

Operation and 

maintenance of 

Kiwanis Camp

(continued)

Chemicals

/Nutrients

Yes Yes Yes An overlap in time and location exists 

with the Kiwanis Camp operations and 

this project. Increased runoff from 

impervious surfaces in the Government 

Camp parcels may mix with the runoff 

pollution from the impervious surfaces 

from the Camp which is located in the 

Little Zigzag Subwatershed. There is 

risk of cumulative effects in the Little 

Zigzag Watershed, but the magnitude 

and extent is difficult to measure.

Potential for cumulative effects to fish are 

expected to extend from the Government 

Camp parcels to the mouth of Camp Creek. 

Effects are expected to impact habitat and 

aquatic species described in table 17 and 

table 18. Aquatic organisms may exposed 

to increased pollution from runoff.

Operation and 

maintenance of 

Lady Creek Water 

System

Water 

Quantity

Yes Yes Not 

Measurable

As outlined in the Hydrology specialist 

report, there is not expected to be a 

change in water quantity as a result of 

the project.

None.

Suspended 

Sediment

Yes Yes No Repair and ongoing replacement of 

existing infrastructure will continue to 

occur in the future. Excavation of 

trenches to replace waterlines can 

result in increases in sediment. 

Sediment would not be measurable 

due to implementation of mitigation 

measures and design criteria and 

conformance with existing standards 

and guidelines in the projects.

None.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

144

Summary of Environmental Effects to Fisheries

Determinations for the proposed action were made as a result of analysis at the 6th-field 

watershed scale (Middle Zigzag River and Middle East Fork Hood River) and 7th-field 

watershed scale (Camp Creek, Little Zigzag River, Tilly Jane Creek, Doe Creek, Buck Creek, 

and Ash Creek). The checklist for Documenting Environmental Baseline and Effects of Proposed 

Action(s) on Relevant Indicators was consulted for this project and a cumulative effects analysis 

was completed. A summary of the effects of the alternatives on habitat elements that may be 

effected by the project is provided in table 19.

There would be measurable change from baseline conditions resulting from implementation of 

this project which may affect designated critical habitat and associated listed fish species as well 

as essential fish habitat. A review of potential impacts found the proposed development of the 

Government Camp parcels would increase sediment, turbidity and embeddedness, water quality, 

peak/base stream-flows, and pool habitat for Lower Columbia River Chinook, coho, and 

steelhead as well as Region 6 sensitive species and management indicator species. The land 

exchange was determined to have no effects to aquatic organisms or habitat in the Cooper Spur 

area as there were no causal mechanisms to indicator measures.

The following discussion summarizes effects to ESA-listed fish, their critical habitat, Regional 

Forester’s sensitive aquatic species, management indicator species, and essential fish habitat for 

the project. A brief rationale is given for each.

Effect Determination for Listed Species

No direct effects to listed species were identified. Elements of the project may indirectly effect 

(may affect, and is likely to adversely affect) ESA-listed fish species designated as threatened 

(table 17) based on the potential for increases in sediment, turbidity, and embeddedness, which 

can impact spawning and rearing as well as food source availability. Changes to water quality 

could impair navigation or reduce food sources. Increases in peak/base stream-flows could 

reduce suitable in-channel habitat for rearing, spawning, or migration.

Effect Determination for Critical Habitat

The project “may adversely modify” designated critical habitat for Lower Columbia River 

Chinook, coho, and steelhead in the Zigzag Watershed (table 17). Three of the six physical and 

biological features that have been established for the critical habitat of the species are addressed 

here; freshwater spawning sites, freshwater rearing sites, and freshwater migration corridors (50 

CFR Part 226 70 FAR 52664-5). The project would measurably modify these physical and 

biological features. 

Effect Determination for Essential Fish Habitat

The Magnuson-Stevens Fishery Conservation and Management Act (MSA), as amended by the 

Sustainable Fisheries Act of 1996 (Public Law 104-267), established procedures designed to 

identify, conserve, and enhance essential fish habitat for those salmon species regulated under a 

Federal fisheries management plan. The Pacific Fisheries Management Council (PFMC) has 

recommended an essential fish habitat designation for Pacific salmon fishery that would include 

those waters and substrate necessary to ensure the production needed to support a long-term 

sustainable fishery. 

Salmon fishery essential fish habitat includes all those streams, lakes, ponds, wetlands, and other 

water bodies currently, or historically accessible to the three salmonid species identified under 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

145

the MSA, coho salmon, Chinook and Puget Sound pink salmon in Washington, Oregon, Idaho, 

and California, except above impassable barriers identified by PFMC (PFMC 1999). Salmon 

essential fish habitat excludes areas upstream of longstanding naturally impassable barriers 

(natural waterfalls in existence for several hundred years). 

Essential fish habitat is commensurate with critical fish habitat where designated. If critical 

habitat has not been designated, then the action agency defines the extent of essential fish habitat 

based on known or suspected fish distribution. The proposed project would “adversely affect 

essential fish habitat” for Lower Columbia River Chinook and coho in the Zigzag Watershed.

Table 17. The Government Camp-Cooper Spur Land Exchange Project effects determination 

summary for ESA-listed species, designated critical habitat, and Region 6 Regional Forester’s 

sensitive species present in the action area

Species Present Effects of Action: 

Government Camp Action 

Area

Effects of Action: 

Cooper Spur Action Area

Endangered Species Act Listing 

by Evolutionary Significant 

Unit/Distinct Population Segment 

No Action Proposed 

Action

No Action Proposed 

Action

Lower Columbia River Steelhead 

Trout

Threatened No effect Likely to 

adversely affect

No effect No effect

Designated Critical Habitat No adverse 

modification

Adverse 

modification

No adverse 

modification

No adverse 

modification

Lower Columbia River Chinook 

Threatened No effect Likely to 

adversely affect

No effect No effect

Designated Critical Habitat No adverse 

modification

Adverse 

modification

No adverse 

modification

No adverse 

modification

Designated Essential Habitat No adverse 

effect

Likely to 

adversely affect

No adverse 

effect

No adverse 

effect

Lower Columbia River Coho

Threatened No effect Likely to 

adversely affect

No effect No effect

Designated Critical Habitat No adverse 

modification

Adverse 

modification

No adverse 

modification

No adverse 

modification

Designated Essential Habitat No adverse 

effect

Likely to 

adversely affect

No adverse 

effect

No adverse 

effect

Effect Determination for Forest Service Region 6 Regional Forester’s Special 

Status Species

The project “may impact individuals or habitat, but will not likely contribute to a trend toward

Federal listing or loss of viability to the population or species” based on the potential for 

increases in sediment, turbidity and embeddedness, water quality, peak/base streamflows, and 

pool habitat (table 18).

Effect Determination for Management Indicator Species Fish Species

On the Zigzag Ranger District, both resident and anadromous cutthroat trout and other salmonid 

species are present within the Government Camp action area. Sediment, water quality, and 

stream drainage network increases would be the most likely avenue of potential effects to 

cutthroat trout. Because this project impacts a fraction of 1 percent of suitable habitat across the 

Mt. Hood National Forest, the overall direct, indirect and cumulative effects will result in a small 

negative trend of habitat (increase in disturbance). The loss of habitat (increase in disturbance) 

will be insignificant at the scale of the Mt. Hood National Forest. Thus, continued viability of 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

146

cutthroat trout and other salmonid management indicator species is expected on the Mt. Hood 

National Forest.

Table 18. The Government Camp-Cooper Spur Land Exchange Project effects determination 

summary for ESA-listed species, designated critical habitat, and Region 6 Regional Forester’s 

sensitive species present in the action area

Species Present

Effects of Action: 

Government Camp 

Action Area

Effects of Action: 

Cooper Spur Action Area

Forest Service Region 6 Regional Forester’s Sensitive Species

Pacific Lamprey

Entosphenus tridentatus

NI1 NI MIIH2 NI NI NI

Redband Trout

Onchorynchus mykiss gairdneri

NI NI MIIH NI NI NI

Cutthroat (management indicator species)

Onchorynchus clarki

NI NI MIIH NI NI NI

Barren Juga

Juga hemphilli hemphilli

NI NI MIIH NI NI NI

Caddisfly

Namamyia plutonis

NI NI MIIH NI NI NI

Scott’s Apatanian Caddisfly

Allomyia scotti

NI NI MIIH NI NI NI

1 NI = No impact: There is no impact to the species, because there is no causal effect to the species. 

2 MIIH = May impact individuals or habitat, but will not likely contribute to a trend toward Federal listing or loss of viability 

to the population or species.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

147

Table 19. Change in effect to habitat indicators which compares both alternatives to the existing 

condition in the Government Camp and Cooper Spur areas

Habitat Indicator

Alternatives 

Effect 

Government 

Camp:

Camp Creek

Alternatives 

Effect 

Government 

Camp:

Little Zigzag

Alternatives 

Effect Cooper 

Spur:

Tilly Jane

Alternatives 

Effect Cooper 

Spur:

Doe/Ash/Crystal

Sediment, Turbidity 

and Substrate

Existing 

Condition

Not properly 

functioning

Properly 

functioning

Functioning at 

risk

Functioning at risk

No Action No change No change No change No change

Proposed 

Action

Degrade Degrade No change No change

Chemicals and 

Nutrients

Existing 

Condition

Functioning at 

risk

Properly 

functioning

Properly 

functioning

Properly 

functioning

No Action No change Maintain No change No change

Proposed 

Action

Degrade Degrade No change No change

Change in Peak/Base 

Flows

Existing 

Condition

Functioning at 

risk

Properly 

functioning

Functioning at 

risk

Properly 

functioning

No Action No change Maintain No change No change

Proposed 

Action

Degrade Degrade No change No change

Change in Stream 

Drainage Network

Existing 

Condition

Functioning at 

risk

Properly 

functioning

Functioning at 

risk

Properly 

functioning

No Action No change Maintain No change No change

Proposed 

Action

Degrade Degrade No change Maintain

Pool Frequency and 

Quality

Existing 

Condition

Not properly 

functioning

Properly 

functioning

Functioning at 

risk

Functioning at risk

No Action No change Maintain No change No change

Proposed 

Action

Degrade Degrade No change No change
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

148

Hydrology and Water Rights

Introduction

To ensure compliance with Forest Plan and State and Federal requirements, the hydrology report 

considers potential project-related effects on watershed and hydrologic resources, including 

wetlands, floodplains, stream channels, and associated riparian areas as well as water and 

sediment yield changes from soil disturbance, ground cover removal and impervious surfaces. 

The Hydrology Specialist Report (Project Record) includes additional detail regarding the 

analysis methodology, regulatory framework that would guide the implementation of this 

project, including Forest Plan standards and guidelines, as well as best management practices 

(BMPs) and project design features that would be required should the project be implemented.

Affected Environment

Existing Condition

The project consists of a number of parcels distinctly recognized as the lands to be conveyed 

(Government Camp parcels) and the lands to be acquired (Cooper Spur parcels). The 

Government Camp parcels are in the Zigzag Canyon 6th field watershed and the following 7th 

field watersheds: Little Zigzag River (28 percent of the project area.) and Camp Creek (72 

percent of the project area). The Cooper Spur parcels are in the Middle East Fork Hood River 6th 

field watershed and the following 7th field watersheds: Crystal Springs (33 percent of the project 

area), Tilly Jane Creek (28 percent of the project area), East Fork Hood River (7 percent of the 

project area) and East Fork Hood River Lower (32 percent of the project area).

There are many streams, springs, and wetlands located within the sub-watersheds associated with 

the lands to be conveyed and acquired.

Lands to be conveyed - Government Camp Parcels Description

The primary streams associated with the Government Camp Parcels include Camp Creek and 

Little Zigzag River. There are approximately 51 miles of stream in these 7th field watersheds in 

the following categories: 35 miles of perennial streams (flow year around), and 15 miles of 

intermittent streams. There are no springs identified in the National Hydrography Dataset (NHD) 

and there are 166 acres of wetlands identified in the National Wetlands Inventory.

There are 1.2 miles of streams (0.5 perennial and 0.7 intermittent) within the parcels. There are 

9 acres of wetlands and no springs.

Thick pyroclastic flow and debris flow deposits from approximately 1,500 years ago comprise 

the surface material in the project area. These permeable deposits filled in over the older 

topographic surface (including stream channels) and created the present smooth fan on the 

southwest side of Mt. Hood (Sherrod and Scott 1995). The age and permeability of this material 

explains the limited stream development above Timberline Lodge; the buried topography 

(including stream channels) probably helps to concentrate groundwater flow in certain areas and 

partially explains why springs are located where they are (USDA Forest Service 2005a).
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

149

Figure 20. Government Camp parcels and associated 7th field watersheds
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

150

Camp Creek is in the area affected by pyroclastic flow and debris flow deposits from 

approximately 1,500 years ago. Camp Creek and its associated tributaries originate from a series 

of seeps and springs in the 4,000- to 4,300-foot elevation band. As with Still Creek, it is assumed 

that the location of the current seeps and springs that form the headwaters of Camp Creek are 

associated with topography that was buried 1,500 years ago. 

Springs in the area (groundwater discharge) appear to form at the contact between the Polallie 

eruptive period, pyroclastic-flow and debris-flow deposits (between 12,000 and 15,000 years 

ago) that is surrounded by Timberline eruptive period, pyroclastic-flow and debris-flow deposits 

(approximately1,500 years ago). The springs appear to be at the lower end of the Polallie 

eruptive period, pyroclastic-flow and debris-flow deposits and the upper end of the Timberline 

eruptive period, pyroclastic-flow and debris-flow deposits. It is assumed that this is based on 

buried streams or transmissivity contacts due to contrasting perviousness (Reinwald, Pers. 

Comm., July 2016) 

The streamflow regime in Still Creek is “buffered” by the constant influx of groundwater. Pulses 

of surface runoff during rain events occur primarily when the ground surface becomes saturated 

and the ephemeral reaches of Still Creek carry water (USDA Forest Service 2005). The Camp 

Creek 7th field watershed is adjacent to the Still Creek 7th field watershed with similar geology 

and spring sites so it is assumed that the streamflow regime of Camp Creek is similar to that of 

Still Creek.

The planning area receives approximately 84.5 inches of precipitation annually in the form of 

rain and snow based on data from the PRISM model developed by the Oregon Climate Service 

(http://www.prism.oregonstate.edu/explorer/). There is a SNOTEL (Snow Telemetry) site 

adjacent to the project area. The Mud Ridge Site is about 4 miles south of the Government Camp 

parcels at 3,800 feet elevation (the Government Camp parcel varies from 3,760 to 4,120 feet 

elevation).

Table 20. Data from the Mud Ridge SNOTEL Site from 1979 through 2004

Total Precipitation 

(inches)

Snowpack measured as inches 

of Snow Water Equivalent

% of Total Precipitation 

contained in the Snowpack

Average 66.44 28.08 42

Minimum 45.20 6.80 15

Maximum 95.10 45.10 47

Lands to be acquired- Cooper Spur Parcels Description

There are many streams, springs and wetlands located within the 7th field watersheds in these 

parcels. The primary streams include East Fork Hood River, Tilly Jane Creek, Doe Creek, Ash 

Creek, Crystal Spring Creek, and Buck Creek. There are 22 springs (NHD and Yinger 2003), and 

120 acres of wetlands in the watersheds. There are approximately 70 miles of stream in these 7th 

field watersheds in the following categories: 34 miles of perennial streams (flow year around), 

31 miles of intermittent streams, and 6 miles of ephemeral streams. 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

151

Figure 21. Cooper Spur parcels and associated 7th field watersheds
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

152

Within the parcels there are 3.3 miles of streams (3.0 perennial and 0.3 intermittent), 2 springs (Yinger 

2003), and 8 acres of wetlands.

Outside of the East Fork Hood River, streams have steep channels, particularly in the upper reaches of 

their basins, that are cut into relatively young, unconsolidated volcanoclastic units, and they have an 

abundant source of easily erodible material. The lower basins of these streams are heavily wooded with 

conifers and have channels that are bordered by brush and small deciduous trees (Gallino and Pierson. 

1985).

These parcels receive approximately 88 inches of precipitation annually in the form of rain and snow 

based on data from PRISM model developed by the Oregon Climate Service 

(http://www.prism.oregonstate.edu/explorer/). Using modeled data from the National Operational 

Hydrologic Remote Sensing Centers interactive snow information website 

(http://www.nohrsc.noaa.gov/interactive/html/map.html) for 2012 and 2013 as representative years from 

the closest SNOTEL site (approximately 6 miles away) at Red Hill (4,416 feet: the base of Cooper Spur 

Ski area is at 4,000 feet), approximately 30 percent of the total precipitation for the area is in the form of 

snow.

Table 21. Modeled data for the Red Hill SNOTEL site

Total Precipitation 

(inches)

Snowpack measured as inches 

of Snow Water Equivalent

% of Total Precipitation 

contained in the Snowpack

2012 data 72.84 24.15 33

2013 data 104.44 29.13 28
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

153

Table 22. Resource indicators and measures for the existing condition Government Camp Parcels

Resource Element Resource Indicator Measure Area Analyzed No Action

Watershed Condition Upslope/Riparian 

Condition

AREMP10 6th Field Watershed 

Assessment

Zigzag Canyon 6th field watershed Functioning at Risk

Water Quality, Riparian and Channel 

Function and Watershed Function

Water yield Peak 

Streamflows

AREMP 6th Field Watershed 

Assessment

Zigzag Canyon 6th field watershed Properly Functioning

Water Quality, Riparian and Channel 

Function and Watershed Function

Water yield Peak 

Streamflows

2-year 24-hour storm event 

streamflow

Camp Creek 7th field watershed 323

Little Zigzag 7th field watershed 296

Water Quality, Riparian and Channel 

Function and Watershed Function

Water yield Peak 

Streamflows

Aggregate Recovery 

Percentage 

Camp Creek 7th field watershed 89%

Little Zigzag 7th field watershed 98%

Water Quality, Riparian and Channel 

Function and Watershed Function

Water yield Peak 

Streamflows

Road Drainage Stream 

Network Enhancement

Camp Creek 7th field watershed 6%

Little Zigzag 7th field watershed 1%

Water Quality, Riparian and Channel 

Function and Watershed Function

Water yield –base 

streamflows

Are more water rights allocated 

than the D50 lowflow

Camp Creek subcatchment Yes

Little Zigzag 7th field watershed No

Water Quality Overall Water 

quality

Water quality limited streams Camp Creek 7th field watershed 0

Little Zigzag 7th field watershed 5.5

Water Quality Stream 

Temperature

Stream temperature. 

Compliance with State 

standard

Camp Creek 7th field watershed Yes

Little Zigzag 7th field watershed Yes

Water Quality Sediment delivery 

land use

Tons per year delivered Camp Creek 7th field watershed 153.3

Little Zigzag 7th field watershed 23.3

Water Quality Sediment delivery 

roads

Tons per year delivered Camp Creek 7th field watershed 42.4

Little Zigzag 7th field watershed 2.8

Water Quality Sediment In channel fine sediment 

levels. Number of stream 

reaches that exceed threshold

Camp Creek 7th field watershed 5

Little Zigzag 7th field watershed 2

Water Quality Riparian Processes 

Indicator

AREMP 6th Field Watershed 

Assessment

Zigzag Canyon 6th field watershed Properly Functioning

 10 The NW Forest Plan watershed monitoring module (also known as the Aquatic and Riparian Effectiveness Monitoring Program or AREMP)
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

154

Table 23. Resource indicators and measures for the existing condition Cooper Spur parcels

Resource Element Resource Indicator Measure Area Analyzed No Action

Watershed Condition Upslope/Riparian 

Condition

AREMP11 6th Field 

Watershed Assessment

Middle East Fork Hood River 6th Field 

Watershed

Functioning at 

Risk

Water Quality, Riparian and 

Channel Function and Watershed 

Function

Water yield Peak 

Streamflows

AREMP 6th Field 

Watershed Assessment

Middle East Fork Hood River 6th Field 

Watershed

Properly 

Functioning

Water Quality, Riparian and 

Channel Function and Watershed 

Function

Water yield Peak 

Streamflows

2-year 24-hour storm event 

streamflow

Not assessed

Water Quality, Riparian and 

Channel Function and Watershed 

Function

Water yield Peak 

Streamflows

Aggregate Recovery 

Percentage 

Crystal Springs 7th field watershed 91%

Tilly Jane Creek 7th field watershed 69%

East Fork Hood River 7th field watershed 93%

East Fork Hood River Lower 7th field watershed 93%

Water Quality, Riparian and 

Channel Function and Watershed 

Function

Water yield Peak 

Streamflows

Road Drainage Stream 

Network Enhancement

Crystal Springs 7th field watershed 7%

Tilly Jane Creek 7th field watershed 13%

East Fork Hood River 7th field watershed 12%

East Fork Hood River Lower 7th field watershed 5%

Water Quality, Riparian and 

Channel Function and Watershed 

Function

Water yield –base 

streamflows

Are more water rights 

allocated that than the D50 

lowflow

Crystal Springs 7th field watershed Yes

Tilly Jane Creek 7th field watershed No

East Fork Hood River 7th field watershed Not assessed

East Fork Hood River Lower 7th field watershed Not assessed

Water Quality Overall Water quality Water quality limited 

streams (miles)

Crystal Springs 7th field watershed 0

Tilly Jane Creek 7th field watershed 0

East Fork Hood River 7th field watershed 6.4

East Fork Hood River Lower 7th field watershed 3.4

Water Quality Stream Temperature Stream temperature. 

Compliance with State 

standards

Crystal Springs 7th field watershed Yes

Tilly Jane Creek 7th field watershed Yes

East Fork Hood River 7th field watershed Yes

East Fork Hood River Lower 7th field watershed Yes

 11 The NW Forest Plan watershed monitoring module (also known as the Aquatic and Riparian Effectiveness Monitoring Program or AREMP)
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

155

Resource Element Resource Indicator Measure Area Analyzed No Action

Water Quality Sediment delivery land 

use

Tons per year delivered Not assessed

Water Quality Sediment delivery 

roads

Tons per year delivered Crystal Springs 7th field watershed 37.9

Tilly Jane Creek 7th field watershed 36.0

E Fork Hood River 7th field watershed 10.5

E Fork Hood River Lower 7th field watershed 20.3

Water Quality Sediment In channel fine sediment 

levels. Number of stream 

reaches

Crystal Springs 7th field watershed 1

Tilly Jane Creek 7th field watershed 6

E Fork Hood River 7th field watershed Not assessed

E Fork Hood River Lower 7th field watershed Not assessed

Water Quality Riparian Process 

Indicator

AREMP 6th Field 

Watershed Assessment

Middle East Fork Hood River 6th Field 

Watershed

Functioning at 

Risk
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

156

Resource Indicator and Measure Overall Watershed Condition

The existing condition for the 6th field watersheds is based on datasets associated with the 

Northwest Forest Plan–The First 20 Years (1994 to 2013) Watershed Condition Status and Trend 

Report (Miller et al. 2015). The watershed monitoring module (also known as the Aquatic and 

Riparian Effectiveness Monitoring Program or AREMP) determines if the NW Forest Plan’s 

aquatic conservation strategy is achieving the goals of maintaining and restoring the condition of 

watersheds. AREMP determined the status and trend of upslope/riparian watershed condition for 

6th field watersheds within the NW Forest Plan area. Upslope and riparian condition are based 

on mapped data (e.g., road density, vegetation) representing the years 1993 and 2012 for all 

watersheds with 5 percent or greater Federal ownership (Miller et al. 2015). Watersheds were 

scored from 0 to 100 for stream condition and upslope/riparian condition, separately. Scores for 

upslope/riparian conditions were normalized to fall between 0 (poor) and 100 (good) (Miller 

2015). Scores closer to zero signify a watershed has adversely deviated from expectation; 100 

denotes above expectation (Miller 2015).

The assessment was based on factors affecting five major aquatic processes: sediment production 

and delivery (mass wasting), wood production and delivery, riparian habitat, hydrologic 

processes (specifically peak flows), and fish passage. The status of each process was estimated 

based on impacts of road densities and vegetation conditions derived from mapped data, 

including road metrics from Forest Service and Bureau of Land Management geographic 

information system road layers and vegetation metrics derived from satellite imagery (Miller et 

al. 2015).

The AREMP approach applies expert-derived criteria to regionally available datasets (Lanigan 

and Gordon 2012).

Figure 22. Overall upslope/riparian condition is based on the combination of 5 process indicators, 

which were in turn derived from a number of finer grained metrics (Miller et al. 2015)
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

157

The AREMP scores from 0 to 100 were converted to Watershed Condition Framework type of 

scores using the formula [2*((100-ArempScore)/100)+1] (AREMP 2016).

The Watershed Condition Framework (WCF) is a separate process that uses nationally consistent 

reconnaissance-level methodology for classifying watershed condition, using a comprehensive 

set of 12 indicators that are surrogate variables representing the underlying ecological, 

hydrological, and geomorphic functions and processes that affect watershed condition. The 

process is described at: 

http://www.fs.fed.us/publications/watershed/Watershed_Condition_Framework.pdf.

Watershed condition classification is the process of describing watershed condition in terms of 

discrete categories (or classes) that reflect the level of watershed health or integrity. 

Class 1 = Functioning Properly. Watersheds exhibit high geomorphic, hydrologic, and 

biotic integrity relative to their natural potential condition. These are considered to be 

functioning properly.

Class 2 = Functioning at Risk. Watersheds exhibit moderate geomorphic, hydrologic, 

and biotic integrity relative to their natural potential condition. These are considered to 

be functioning at risk.

Class 3 = Impaired Function. Watersheds exhibit low geomorphic, hydrologic, and biotic 

integrity relative to their natural potential condition. These are considered to have 

impaired function.

Both Watershed Condition Framework (WCF) and AREMP use the same general "multiattribute" approach, in which a number of watershed indicators are evaluated individually and 

then their standardized scores are combined using a hierarchical model structure. However, the 

WCF differs considerably from the AREMP model in the watershed attributes used, how they are 

evaluated, and how they are combined. In terms of attributes used, the national model is more 

subjective, in that it relies on experts to rate each watershed, taking into account whatever data 

they may have. The AREMP approach is more mechanistic; it applies expert-derived criteria to 

regionally-available datasets. The national assessment includes many indicators for which 

consistent data are not available, whereas each AREMP indicator must be represented by a 

regional dataset (Lanigan and Gordon 2012).

The AREMP watershed indicators were used because the indicators were developed for 

processes in the area associated with the Northwest Forest Plan, the indicators evaluate whether 

the NWFP Aquatic Conservation Strategy (ACS) is achieving the goal of maintaining and 

restoring the condition of watersheds, and the ratings are more recent than the Watershed 

Condition Framework ratings.

Using the same break points as the WCF process for Properly Functioning, Functioning at Risk, 

and Not Properly Functioning the AREMP scores for process indicators were assessed.

Both the Zigzag Canyon and Middle East Fork subwatersheds are classified as functioning at 

risk.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

158

Water Quantity

Human activities such as tree removal and roads can influence the amount of water available for 

runoff and the timing of runoff, which may translate into increased peak flows. These increased 

peak flows can cause stream channel damage in the form of increased bank erosion, channel 

scour, channel widening, and sedimentation (USDA Forest Service 2014).

Changes in hydrologic processes associated with management activities can be grouped into two 

classes according to causal mechanisms. One class consists of change resulting from removing 

forest vegetation through harvest. A second class consists of changes in hydrologic processes that 

control infiltration and the flow of surface and subsurface water. This latter class is dominated by 

the effects of forest roads (USDA Forest Service 1993).

Changes in hydrologic processes associated with the removal of forest vegetation through 

harvest can be assessed using the Aggregate Recovery Percentage (ARP) methodology. The ARP 

model was developed for use in the transient snow zone. It provides a methodology for indexing 

the susceptibility of a watershed to increased peak flows from rain-on-snow events associated 

with management created openings in the canopy. This method assumes that the greatest 

likelihood for significant, long-term cumulative effects on forest hydrologic processes is caused 

by created openings in the canopy (from both timber harvest and from the existence of roads) 

that impact snow accumulation and snowmelt. 

Changes in hydrologic processes that control infiltration and the flow of surface and subsurface 

water are dominated by the effects of forest roads. The relatively impermeable surfaces of roads 

cause surface runoff that bypasses longer, slower subsurface flow routes. Where roads are insloped to a ditch, the ditch extends the drainage network, collecting surface water from the road 

tread and intercepting subsurface water exposed by road cuts, and then transporting it to streams 

quicker than the norm. These changes in hydrologic processes are assessed by estimating the 

extension of the stream drainage network associated with roads.

A primary mechanism that changes the volume and timing of peak flows is the road network, 

which essentially increases the drainage density of channels, intercepts subsurface water, and 

decreases the time for overland runoff to reach the stream channel. Even though a watershed 

receives the same amount of precipitation, it is transported through the system much more 

quickly, thus resulting in higher peak discharges and resultant increases in stream power. This 

increased stream power can more effectively erode the streambed and banks. Because the total 

amount of water remains relatively constant, base flows decrease because the rapid runoff 

reduces the total amount of water that can infiltrate and be stored in the soil (Castro 2003).

Impervious surfaces are hard surfaces such as asphalt, concrete, rooftops, and highly compacted 

soils. Unlike pervious areas where soil and vegetation absorb rainwater, impervious surfaces are 

areas that water cannot go through. Land cover that is impervious prevents rainwater from 

entering into the soil and forces it to run off the land until it finds a place where it can enter the 

soil or is incorporated into human-made drainage systems that carry it directly to a stream, lake, 

or estuary. Research has shown that as the amount of impervious surface increases, the amount 

of runoff generated increases. This increased runoff has the potential to scour streambeds, erode 

stream banks, and cause sediment and other entrained pollutants to enter adjacent water bodies 

each time it rains (Shaver et al. 2007).
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

159

Resource Indicator and Measure: Hydrologic Processes Aquatic and Riparian 

Effectiveness Monitoring Program

The watershed monitoring module (also known as the Aquatic and Riparian Effectiveness 

Monitoring Program or AREMP) determined the status and trend of upslope/riparian watershed 

condition for sixth-field watersheds within the NW Forest Plan area (Miller et al. 2015).

The assessment evaluated hydrologic processes (specifically peak flow). The AREMP 

assessment factors in vegetative disturbance, roads and climate zone. The percent increases from 

roads and vegetation are then summed to estimate the overall indicator for peak flow change 

(Miller et al. 2015).

Both the Zigzag Canyon and Middle East Fork Hood River subwatersheds are rated as properly 

functioning for this attribute.

Resource Indicator and Measure: Peak Streamflows Wildcat5 Modeling

This software program is designed to assist watershed specialists in analyzing rainfall-runoff 

events to predict peak flow and runoff volumes generated by single-event rainstorms for a 

variety of watershed soil, vegetation, and land-use conditions, including post-wildfire conditions 

(Hawkins and Barreto-Munoz 2016). 

The general model strategy of Wildcat5 is that of a traditional rainfall-runoff model. Necessary 

model inputs are: (1) rainstorm characteristics of depth, duration, and distribution; (2) parameters 

related to watershed soil and cover to calculate runoff depths; (3) runoff timing parameters to 

define the travel times to the watershed outlet; and (4) unit hydrograph shape and scale (Hawkins 

and Barreto-Munoz 2016).

The peak flow estimation techniques in Wildcat5 are applicable to the many kinds and 

complexity of projects on which U.S. Forest Service hydrologists and others typically work 

(Hawkins and Barreto-Munoz 2016).

Because Wildcat5 is based on general rainfall-runoff hydrology, it can be applied to almost any 

kind of land use and watershed where model inputs are available and where peak flows are due 

to large rainfall events. Wildcat5 and similar rainfall-runoff models were intended for watersheds 

where flow originates as direct runoff from rainfall (Hawkins and Barreto-Munoz 2016).

Within the Government Camp area flow events that originate as direct runoff from rainfall are 

not unprecedented. In November 2006, there was a rainfall event that on November 7 had 2.6 

inches of rain and on November 8 had 2.9 inches of rain, and for the entire period from 

November 4 through November 14 there was 13.5 inches of rain at the Mud Creek SNOTEL 

site.

The following text is from Timberline Express Draft EIS March 2005 (USDA Forest Service 

2005)

Since stream flow conditions can be analyzed in an infinite number of temporal and 

spatial scales, it is useful to describe changes in flow conditions at a few key recurrence 

intervals that are of most concern for a specific stream flow study. The concept of 

recurrence interval is commonly used to describe the statistical probability that a 

particular flow event would be exceeded in any given year. For the purposes of this 

analysis, the existing and proposed stream flow conditions were calculated for the 2-year 

peak flow. This specific flow condition was selected for analysis because, according to 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

160

published literature, these are the flow conditions most likely to be affected by land 

cover changes

Another important consideration is the impact of bankfull flow, often described as the 

high flow during two out of three years, or as a stream discharge having a recurrence 

interval of 1.5 years. The shape of the channel more closely reflects the bankfull width 

and height than it does the less frequent floods. If the bankfull flow is raised above the 

range of natural conditions, excess scouring can occur. If lower, the stream may not have 

the power to move its natural sediment load, causing sediment deposition within the 

watershed.

For this project, Wildcat5 was used to model the Government Camp parcels to establish a 

baseline for streamflows associated with the 2-year 24-hour precipitation event in an area where 

under the proposed action there are changes in land use from forested land to developed areas. In 

order to isolate the potential impacts associated with the project, smaller watersheds were 

established to focus on the potential changes in land use. Wildcat5 was not used to model 

streamflow in the Cooper Spur parcels because there are no ground-disturbing activities 

proposed for the Cooper Spur parcels. The model was run at various sized watersheds to 

determine how far the potential impacts associated with the proposed action extend.

The 2-year 24-hour precipitation amounts for each area were from the basin characteristics from 

USGS StreamStats Version 3.0 output for that area.

Table 24. Predicted peak streamflows for the 2-year 24-hour precipitation event

Analysis Area Acres Peak Streamflow (cubic 

feet per second)

Camp Creek at Highway 26 441 23.8

Camp Creek at Yocum Falls 2,073 109.5

Camp Creek 7th Field 5,992 322.7

Unnamed Tributary to Little Zigzag River below Enid Lake 196 7.1

Unnamed Tributary to Little Zigzag River at Little Zigzag 

River

301 11.9

Little Zigzag River 7th Field 2,735 295.7

Zigzag River at Lady Creek 6,403 721.4
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

161

Figure 23. Wildcat5 modeled watersheds
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

162

Resource Indicator and Measure: Peak Streamflows Aggregate Recovery Percentage

The Aggregate Recovery Percentage (ARP) has been used to represent the proportion of a watershed in a 

“hydrologically mature” condition. By measuring the percent of an area in a hydrologically recovered 

condition, the ARP model evaluates the risk of increased peak flows from rain-on-snow events. In stands 

with little or no forest canopy within the transient snow zone, more snow accumulates than beneath a 

partially or fully intact forest canopy. 

In western Oregon, the lower boundary of the transient snow zone falls between 350 and 450 meters 

(approximately1,150 to 1,475 feet), and the upper boundary falls between 1,100 and 1,200 meters 

(approximately 3,600 to 3,940 feet) (Grant et al. 2008). However, for this analysis the 7th field 

watersheds associated with the Government Camp parcels and Cooper Spur parcels were analyzed with 

ARP methodology associated with the following rationale:

Streamflow data from Still Creek at 3,600 feet (Golder Associates Inc. 2010) indicate a peak flow 

event in January 2009, with an “estimated significant snowmelt contribution.” Due to similarities 

in location, geology and the stream network between Still Creek and Camp Creek it is assumed 

that Camp Creek would respond similarly to Still Creek with a significant snowmelt contribution 

from a similar storm event.

The watershed analysis for the East Fork Hood River (USDA Forest Service 1996) indicates; 

“Most of the streams in these watersheds lie entirely within the rain-on-snow zone. Typically, this 

zone extends from 2,500 to 4,500 feet, however, because of the shape and orientation of the East 

Fork Watershed and its proximity to Mt. Hood, the entire watershed reacts to rain-on-snow in a 

similar manner.”

As timber harvest occurs either by complete or partial canopy removal, a portion of the watershed is no 

longer considered hydrologically mature if enough forest canopy is removed, thus the ARP for that 

drainage is reduced from 100 percent depending on the extent and intensity of timber harvest. Studies 

have shown that in forest openings, or areas that have had forest cover removed, snow accumulation is 

increased due to the loss of canopy interception. With higher levels of snow accumulation and increased 

rates of snowmelt in stands where sufficient canopy has been removed, there is the potential to generate 

more water during rain-on-snow events, which can contribute to increased peak stream flows. As an 

increasing portion of a watershed is put into an open or partially hydrologically immature condition, the 

potential for peak flows to be increased becomes greater. Over time, vegetation grows back and in 

35 years would return to a hydrologic mature condition, thereby “recovering.” 

The ARP analysis also addresses many other factors including: 

• All past timber harvest, road construction, rock quarries, and other openings such as power lines; 

• Recent wildfires; and

• Other ownership
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

163

Table 25. Current level of hydrologic recovery 7th field watersheds12

Subwatershed ARP Existing Condition Impact Area Existing13

Camp Creek14 89 11

Little Zigzag River 98 2

Crystal Springs 91 9

Tilly Jane Creek 69 31

East Fork Hood River 93 7

East Fork Hood River Lower 93 7

The Effects of Forest Practices on Peak Flows and Consequent Channel Response Report (Grant et al. 

2008) details (using the mean change for all reported data) that approximately 20 percent of an area can 

be harvested before increases in peak streamflows are detectable. Using the ARP values to reflect the 

percent of the area that is harvested, all of 7th field subwatersheds except Tilly Jane Creek are below the 

threshold where increases in peak streamflows are detectable from Grant et al. 2008. 

Figure 24. Change in peak flow associated with harvest activities (Grant et al. 2008)

 12 ARP values for Crystal Springs, Tilly Jane Creek, East Fork Hood River, and East Fork Hood River Lower are from the 

Polallie Cooper Hazardous Fuels Reduction Project Draft Environmental Assessment (USDA Forest Service 2016) 13 Watershed impact area represents the portion of watersheds which are hydrologically disturbed by management activities (e.g.,

timber harvest and road construction) and/or natural disturbances (e.g., wildfire and landslides) (USDA Forest Service 1990a) 

and is derived by subtracting the Aggregate Recovery Percent (ARP) value from 100, i.e., an ARP value of 75 percent results in a 

watershed impact area of 25 percent. 14 The ARP values for Camp Creek and Little Zigzag River were calculated for the year 2018. For the analysis it was assumed 

that the project would be implemented in 2018.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

164

During development of the Mt. Hood Forest Plan a methodology for addressing cumulative watershed 

effects, watershed sensitivity, and hydrologic recovery was developed to address Special Emphasis 

Watersheds. As part of the process, a threshold of concern with respect to hydrologic recovery was 

recommended for all watersheds on the Forest (USDA Forest Service 1990a).

Using a combination of professional judgment and experience, resource specialists (hydrologists, soil 

scientists, and fisheries biologists) at the Forest and District level identified 28 “candidate” watersheds 

that were determined to be inherently sensitive due to their physical characteristics (soils, geology, 

channel morphology, susceptibility to snowmelt-induced peak flows, etc.). Several watersheds that appear 

to have been heavily impacted by frequent timber harvest and road construction entries were also 

evaluated (USDA Forest Service 1990a).

On the basis of observation and collective experience and judgment, Forest watershed and fisheries 

specialists developed a methodology for assigning, weighting, and summing values for various factors, 

yielding a unitless numerical rating, or index (USDA Forest Service 1990a):

WS = EH + LS + SM + CS + BU

Where:

WS = Watershed Sensitivity (a unit less numerical value)

EH = Erosion Hazard

LS = Land Stability

SM = Snow Melt

CS = Channel Stability

BU = Beneficial Uses

Based on Watershed Sensitivity ratings individual Thresholds of Concern (TOC) values were established 

forestwide for Special Emphasis Watersheds 

On a forestwide basis, outside of Special Emphasis Watersheds, a watershed disturbance TOC of 

35 percent has been recommended. This value allows more disturbance than the previously cited literature 

and applications of ARP seem to imply. Forest watershed staff believe that it represents a reasonable 

“threshold level of concern,” which is applicable to the less-sensitive watershed lands outside of the 

recommended Special Emphasis Watersheds, reflecting observations of such lands to date (USDA Forest 

Service 1990a).

Based on the watershed sensitivity analysis completed for the Forest Plan associated with special 

emphasis watersheds and current watershed impact areas, all of the 7th field watersheds associated with 

the project are below the disturbance TOC of 35 percent recommended for watersheds that are not 

designated as Special Emphasis Watersheds. 

Resource Indicator and Measure: Peak Streamflows- Stream Drainage Network 

Extension 

Based on research on two basins in the Western Cascades of Oregon, 57 percent of their road length is 

connected to the stream network by surface flowpaths including roadside ditches and gullies below road 

drainage culverts (Wemple et al. 1996). 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

165

Water generated on the road prism can enter the natural stream channel network in a variety of ways 

(http://www.stream.fs.fed.us/news/streamnt/jul00/jul00_2.htm):

• Inboard ditches delivering runoff to a stream at a road-stream crossing

• Inboard ditches delivering runoff to a cross drain (culvert, dip, waterbar, etc.) where sufficient 

discharge is available to create a gully or sediment plume that extends to a stream channel

• Other cross-drainage features, such as waterbars or dips, that discharge sufficient water to create a 

gully and/or sediment plume that extends to a stream channel

• Roads sufficiently close to streams so that the fill slope encroaches on the stream, such as at roadstream crossings

• Landslide scars on the road-fill that expose bedrock and create a surface flow path to an adjacent 

channel.

For this analysis, the key process of concern is associated with inboard ditches delivering runoff to a 

stream where a road intercepts the stream. The increase in channel length due to the inboard ditch was 

calculated as the length of the ditch directly connected to the stream up to the next ditch relief structure. 

Table 26. Percent increase in the length of the stream channel due to roads 15

Subwatershed Percent increase in the length of 

the stream channel due to roads

Camp Creek 6

Little Zigzag River 1

Crystal Springs 7

Tilly Jane Creek 13

East Fork Hood River 12

East Fork Hood River Lower 5

It is generally accepted that based on considerations of gage and measurement error at high-flow events, a 

minimum detectable change in peak flow (detection limit) of ±10 percent for site-scale analysis. 

Percentage changes in peak flow that fall in this range are within the experimental and analytical error of 

flow measurement and cannot be ascribed as a treatment effect (Grant et al. 2008). Since this process 

increases flow routing efficiency and may result in increased magnitude of peak stream flows, the 

10 percent threshold was used to set a level of concern associated with this process. Based on the 

10 percent threshold of concern for this process, all of the analysis subwatersheds, except Tilly Jane Creek 

and East Fork Hood River, are below the threshold for concern.

In a study on the effects of forest roads on peak streamflows (LaMarche and Lettenmaier 2001) in the 

western slope of the Cascade Range in southwestern Washington, forest roads alone were predicted to 

have increased the mean annual flood in the subcatchments from 2.2 to 9.5 percent, and from 2.9 to 

12.2 percent for the 10-year event. The largest increases associated with forest roads (without harvest) 

were roughly equivalent to those predicted for harvest, without roads. The predicted increases in floods 

due to roads generally increase with flood return period, while vegetation effects decrease. The effects of 

roads and harvest on peak flows at the subcatchment (7th field watershed, approximately 5,000 acres) and 

 15 Values for Crystal Springs, Tilly Jane Creek, East Fork Hood River, and East Fork Hood River Lower are from the Polallie 

Cooper Hazardous Fuels Reduction Project Draft Environmental Assessment (USDA 2016) and based on 350-foot spacing (the 

midpoint between the 200-foot and 500-foot culvert spacing values)
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

166

catchment (6th field watershed, approximately20,000 acres) levels are essentially independent, and the 

combined effects on peak flows are, therefore, roughly additive. 

Modeling studies for Washington watersheds suggest an approximate doubling of the percentage change 

in peak flows attributed to harvest alone when road construction is included in the model (Grant et al. 

2008).

Since the effects of vegetation removal through harvest and roads are considered independent from each 

other and they are roughly additive, they should be integrated when assessing management effects on 

peak streamflows within a watershed. However, at different scales the combined effects are not always 

apparent. At the hillslope scale, modeled as well as field-observed road ditch response was dependent on 

vegetation state, with higher road effects occurring below harvested hillslopes. The absence of such a 

synergy at the subcatchment and catchment levels may well be due to scaling issues (most likely due to 

desynchronization in the channel system) of peak flows from the collective hillslopes (LaMarche and 

Lettenmaier 2001).

Table 27. Hydrologic impact area by 7th field watershed

Subwatershed16 Watershed Impact Area Existing

Camp Creek17 11

Little Zigzag River 2

Crystal Springs 9

Tilly Jane Creek 31

East Fork Hood River 7

East Fork Hood River Lower 7

With the approximate doubling of the percentage change in peak streamflows attributed to harvest alone 

the “doubled” impact area for the 7th field watersheds varies from 4 to 62 percent and all of the 

subwatersheds except Camp Creek and Tilly Jane Creek are below the approximately 20 percent of an 

area that can be harvested before increases in peak streamflows are detectable from the Grant et al. 2008 

threshold. 

However, the threshold where road construction is considered additive to harvest to assess impacts on 

streamflow in Grant et al. 2008 is 2 percent of the watershed area in roads, in Tilly Jane Creek 1.7 percent 

of the watershed area is in roads, and in Camp Creek, 1.1 percent of the area is in roads. Due to the 

limited area in roads for this assessment, the impacts of roads were not considered additive, so they did 

not suggest an approximate doubling of the percentage change in peak flows attributed to harvest alone in 

the Tilly Jane Creek and Camp Creek subwatersheds.

Resource Indicator and Measure: Peak Streamflows Summary

All of the subwatersheds, except Tilly Jane Creek, are below the threshold of concern from “The Effects 

of Forest Practices on Peak Flows and Consequent Channel Response Report” (Grant et al. 2008). All the 

subwatersheds are below the threshold associated with the methodology for addressing cumulative 

watershed effects, watershed sensitivity, and hydrologic recovery associated with the Mt. Hood Forest 

 16 Values for Crystal Springs, Tilly Jane Creek, East Fork Hood River, and East Fork Hood River Lower are from the Polallie 

Cooper Hazardous Fuels Reduction Project Draft Environmental Assessment (USDA 2016) 17 The ARP values for Camp Creek and Little Zigzag River were calculated for the year 2018. For the analysis it was assumed 

that the project would be implemented in 2018.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

167

Plan (USDA Forest Service 1990a). When the combined impacts of vegetation management and roads are 

examined, all the subwatersheds are rated as properly functioning in the 6th Field Watershed Condition 

from the “Northwest Forest Plan–The First 20 Years (1994-2013) Watershed Condition Status and Trend 

Report” (Miller et al. 2015).

Tilly Jane Creek watershed is above the threshold of concern from “The Effects of Forest Practices on 

Peak Flows and Consequent Channel Response Report” (Grant et al. 2008) due to vegetation loss from 

the Gnarl Ridge fire. However, indications of major increased peak flows such as channel bed instability 

or scour and channel bank erosion were not noted during field visits to Tilly Jane Creek just below the 

burned area (USDA Forest Service 2016).

Resource Indicator and Measure: Base Streamflows Water Rights

Water rights for the project were examined by 7th field watershed or in the case of Camp Creek a smaller 

watershed to focus in on the project area. The water rights are from the Oregon Water Resources 

Department’s water right surface Points of Diversion (POD) and groundwater Points of Appropriation 

(POA) locations in the state of Oregon geodatabase (Oregon Water Resources 2014). Wells and storm 

water were not included in water right totals in the table.

Table 28. Water rights summary

Area Acres Water Rights D50 Low-Flow18

Camp Creek 441 4.56 cubic feet per second (cfs) 2.26 cfs

Little Zigzag River 2,735 0.002 cfs 16.1 cfs

Crystal Springs Creek 1,881 7.16 cfs 5.41 cfs

Tilly Jane Creek 2,860 0.89 cfs 14.9 cfs

Both Camp Creek and Crystal Springs Creek have more water rights than the predicted 50th percentile 

annual low flow. The D50 low-flow is the flow statistics for the 50th percent exceedances annual lowflow event. This has the potential to impact base streamflow in these areas.

When the water rights for Camp Creek are examined, 3 cfs out of the 4.56 cfs total water rights allocated 

are associated with Collins Lake. As the map of Collins Lake from the water rights permit application 

details, there are two outlets for the lake with one into Bezuco Pond and eventually into what was called 

Mosquito Creek at the time and the other back into Camp Creek. It appears that this is not a consumptive 

use with the water diverted into the lake flowing back into Camp Creek or one of its tributaries. If this is 

the case, there is 1.56 cfs total being used with the D50 low-flow, at 2.26 cfs the area is not overallocated.

 18 Computed from USGS Oregon Streamstats site
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

168

Table 29. Water rights for Camp Creek in the Government Camp area

Water Rights Holder Use Rate Cfs

Collins Domestic 1.5

Collins Fish Culture 1.5

Western Novelty Co. Domestic 0.025

Western Novelty Co. Domestic 0.025

U.S. Mount Hood National Forest Domestic 0.005

Leuthold Domestic 0.005

Government Camp Water19 Municipal 1.5

Figure 25. Map from application to appropriate the public waters of the State of Oregon (permit #8449, 

certificate #8919)

Water availability in Camp Creek at the confluence with the Zigzag River was evaluated by the Oregon 

Water Resources Department. The Oregon Water Resources Department (Department or OWRD) limits 

appropriation from Oregon streams to assure new applicants use of surface water a reasonable amount of 

time and to minimize regulatory conflict. Water availability is obtained from natural stream flow by 

subtracting existing storage, out-of-stream consumptive uses, and in-stream demands (Cooper 2002).

 19 This water right is not in the Oregon Water Resources Department’s water right surface Points of Diversion (POD)

geodatabase. The water right is based on information in Government Camp Water Company Incorporated Water Utility Annual 

Report C for the year ending December 31, 2011 (Oregon PUC 2012)
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

169

Consumptive use is divided into three major categories: irrigation, municipal, and all others (e.g., 

domestic, livestock). These uses are less than 100 percent consumptive. It is assumed the non-consumed 

part of a diversion is returned to the stream from which it was diverted (Cooper 2002).

There are two types of in-stream demands: instream water rights and scenic waterway flows. In-stream 

demands diminish availability upstream only. Because they are non-consumptive, they do not diminish 

stream flow downstream as do consumptive uses (Cooper 2002).

Table 30. Water availability in Camp Creek report

Month Natural 

Stream Flow

Consumptive 

Use

Expected 

Stream Flow

Reserved 

Stream Flow

Instream 

Requirement

Net Water 

Avail

JAN 29.1 0.751 28.3 0 25 3.35

FEB 37.3 0.751 36.5 0 25 11.5

MAR 36 0.75 35.2 0 25 10.2

APR 47.4 0.75 46.6 0 25 21.6

MAY 45.7 0.75 45 0 25 20

JUN 22.1 0.75 21.4 0 20 1.35

JUL 10.2 0.75 9.45 0 16.2 -6.75

AUG 7.66 0.75 6.91 0 9.13 -2.22

SEP 6.6 0.75 5.85 0 10.5 -4.65

OCT 8.3 0.75 7.55 0 12.2 -4.65

NOV 17.1 0.75 16.4 0 25 -8.65

DEC 37.5 0.751 36.7 0 25 11.7

Based on the Oregon Water Resources Department output, there is no water available in Camp Creek at 

the confluence with the Zigzag River in July, August, September, October, or November.

When the water rights for Crystal Springs are examined, 7.15 cfs out of the 7.16 cfs total water rights 

allocated are associated with Crystal Springs Water District. The language from the application for a 

permit to appropriate the waters of the State of Oregon indicates that the water district intended to apply 

for more water than was available from the spring time water yield.

Table 31. Water rights Crystal Springs 7th field watershed

Water Rights Holder Use Rate Cfs

Crystal Springs Water District Group Domestic 2.65

Crystal Springs Water District Municipal Uses 3.5

Crystal Springs Water Co. Domestic 1

Lee Livestock 0.005
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

170

Figure 26. Water rights permit application #34196

Water rights is further discussed in the section below titled, “Soils, Wetlands and Water Rights.”

Resource Indicator and Measure: Water Quality- Water Quality Limited 303(d) Streams

Rivers, streams, and lakes within and downstream of the treatment areas are used for boating, fishing, 

swimming, and other water sports. Additionally, the Forest streams provide habitat and clean water for 

fish and other aquatic biota, each with specific water quality requirements. The CWA protects water 

quality for all of these uses.

The CWA requires states to set water quality standards to support the beneficial uses of water. The Act 

also requires States to identify the status of all waters and prioritize water bodies whose water quality is 

limited or impaired. For Oregon, the DEQ develops water quality standards and lists water quality limited 

waters. In addition, Region 6 of the Forest Service has entered into a Memorandum of Agreement (MOA) 

with the Oregon State DEQ to acknowledge the Forest Service as the Designated Management Agency 

for implementation of the CWA on National Forest System land. In an effort to support the CWA, the 

Forest conducts a variety of monitoring and inventory programs to determine status of meeting state water 

quality standards as well as other regulatory and agency requirements. 

In an average year, approximately 75 sites are monitored for water temperature throughout the Forest. In 

addition, other water quality monitoring occurs at various locations throughout the Forest depending on 

the year. This could be turbidity monitoring, instream sediment sampling, water chemical sampling, or 

surveys of physical stream conditions. Currently, approximately 25 miles of physical stream habitat is 

surveyed every year and to date approximately 1,787 miles of stream have been surveyed or resurveyed. 

Some of the information collected during these surveys includes the number of pools and riffles, amount 

of large wood, riparian area condition and types, numbers of fish and other aquatic organisms, stream 

substrate and embeddedness. 

Section 303(d)

Section 303(d) of the CWA requires that water bodies violating state or tribal water quality standards be 

identified and placed on a 303(d) list. The EPA regulations also allow states and tribes to include 

threatened waters (that is, waters that display a downward trend that suggests water quality standards 

would not be met in the near future).
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

171

By direction of the CWA, where water quality is limited, DEQ develops a Total Maximum Daily Load 

(TMDL) plan to improve water quality to support the beneficial uses of water. For water quality limited 

streams on NFS lands, the Forest Service provides information, analysis, and site-specific planning efforts 

to support state processes to protect and restore water quality. 

The TMDL plans for water temperature for streams in the project area (Sandy River Basins and West 

Hood Sub-basin) were completed by the Oregon DEQ and accepted by the EPA in 2005 and 2002 

respectively. In these documents, DEQ concluded that standards and guidelines in the Mt. Hood Forest 

Plan and the NW Forest Plan meet the requirements of a TMDL management plan. 

The table below details the water quality status of streams in the project area with respect to associated 

Oregon's 2012 Integrated Report Assessment Database and 303(d) List. 

Table 32. Water Quality Status -Oregon's 2012 Integrated Report Assessment Database and 303(d) List –

Streams in Status Categories 4 or 5

Stream Name Miles Pollutant Listing Status

Little Zigzag Canyon 0 to 5.5 Biological Criteria Cat 5: Water quality limited, 303(d) list, TMDL needed

East Fork Hood River 0 to 27.4 Iron Cat 5: Water quality limited, 303(d) list, TMDL needed

East Fork Hood River 0 to 27.4 Copper Cat 5: Water quality limited, 303(d) list, TMDL needed

East Fork Hood River 0 to 27.4 Thallium Cat 5: Water quality limited, 303(d) list, TMDL needed

East Fork Hood River 0 to 27.4 Biological Criteria Cat 5: Water quality limited, 303(d) list, TMDL needed

East Fork Hood River 9.8 to 27.4 Temperature Cat 4A: Water quality limited, TMDL approved

Category 4: Water is water quality limited but a TMDL is not needed. This includes: 

4A: TMDL approved - TMDLs needed to attain applicable water quality standards have been 

approved. 

4B: Other pollution control requirements are expected to address all pollutants and will attain 

water quality standards. 

4C: Impairment is not caused by a pollutant (e.g., flow or lack of flow is not considered a 

pollutant.) 

Category 5: Water is water quality limited and a TMDL is needed, Section 303(d) list. 

The 303(d) listings for iron, copper, and thallium associated with East Fork Hood River are based on 

samples from the County Gravel Pit (River Mile 0.75). The confluence of Crystal Springs Creek and the 

East Fork Hood River is at approximately river mile 10.7 (approximately 10 miles upstream of the gravel 

pit) and due to the distance from the project site and the water quality variables involved it is assumed 

that the listings for iron, copper and thallium are not associated with forest management activities.

• The major sources of thallium in drinking water are leaching from ore-processing sites; and 

discharge from electronics, glass, and drug factories (https://safewater.zendesk.com/hc/enus/articles/212075567-5-How-does-thallium-get-into-my-drinking-water-)

• The major sources of copper in drinking water are corrosion of household plumbing systems; and 

erosion of natural deposits. (https://safewater.zendesk.com/hc/en-us/articles/211402968-5-Howdoes-copper-get-into-my-drinking-water-)
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

172

• Iron is the fourth most abundant element, by weight, in the earth's crust. Natural waters contain 

variable amounts of iron depending on the geological area and other chemical components of the 

waterway. (http://www.water-research.net/index.php/metals-in-the-environment)

Biological Criteria Assignment of Assessment Category: 

The following text is from: PREDATOR: Development and use of RIVPACS-type macroinvertebrate 

models to assess the biotic condition of wadeable Oregon streams (November 2005 models) (Hubler 

2008)

The Oregon Department of Environmental Quality (DEQ) is responsible for protecting the waters 

of the state from pollution that may adversely affect drinking water, aquatic life and recreational 

uses. DEQ routinely monitors conventional water quality parameters such as nutrients, dissolved 

oxygen, pH, turbidity, conductivity and bacteria to report on the water quality status and trends in 

Oregon. However, resource limitations make it impractical to measure all the potential pollutants 

which may impair Oregon’s waters. Aquatic insect communities are direct indicators of biological 

conditions and a surrogate for watershed health. They provide a cost effective screening tool for 

assessing and identifying problems that may require further examination.

The PREDictive Assessment Tool for Oregon (PREDATOR) consists of three regional models 

that assess the biological integrity of wadeable streams across Oregon. DEQ developed the 

models to supply a scientifically rigorous bioassessment tool that is easy to apply and provides a 

more complete understanding of the stream conditions across Oregon.

The list of species generated from the reference locations is known as the “Expected” taxa list or 

“E”. This list is compared to the captured aquatic insects or, “Observed” taxa (“O”), at an 

assessment site. The predictive model output is the observed to expected (O/E) taxa ratio. Scores 

less than one have fewer taxa at a site than were predicted by the model. Scores greater than one 

are either equivalent to the reference location or may have an enhanced insect community as a 

result of some type of enrichment.

If a single sample falls below the 10th percentile of the reference distribution, the sample is 

considered to be outside the reference distribution. We feel confident that a single sample score 

below the 10th percentile is not different simply by chance, but rather a true difference in 

biological condition exists (assuming the site is not an outlier for any reason). In this case, a 

single sample is sufficient to classify the stream reach as biologically disturbed, or “not 

supporting” the beneficial use. However, if a sample falls between the 10th and 25th percentiles 

of the reference distribution (“moderately disturbed”), there is less confidence that the O/E score 

is outside of the reference distribution. In this case, DEQ recommends repeated measures of O/E 

to determine if a significant difference in biological condition exists. We also recommend 

assessments include surveys of water quality, instream and riparian habitat, and remote sensing of 

the watershed (GIS) to provide insights into possible sources of disturbance. A site with a “most 

disturbed” O/E score and minimal signs of human influences may indicate that the site was not 

accurately modeled with the current set of reference sites. These are important findings that may 

be used to increase the future accuracy of predicting locally common reference taxa.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

173

Resource Indicator and Measure: Water Quality- Stream Temperature

Within the project area the following standards apply for stream temperature (Oregon Administrative Rule 

(OAR) 340-041-0028 Temperature)

• 13.0 °C during times and at locations of salmon and steelhead spawning.

• 16.0 °C during times and at locations of core cold water habitat identification.

• 18.0 °C during times and at locations of salmon and trout rearing and migration.

The core cold water habitat requirement applies to all perennial streams associated with the 7th field 

watersheds in the project area associated with the Government Camp parcels. The salmon and trout 

rearing and migration standards apply to all the streams in the 7th field watersheds associated with the 

Cooper Spur parcels. In addition, the salmon and steelhead spawning criteria apply in Camp Creek from 

Yocum Falls downstream for approximately 1 mile from January 1 to June 15 and from there downstream 

to the confluence with the Zigzag River from October 15 to June 15. The criteria apply in the Little 

Zigzag River from the confluence with the Zigzag River approximately 1 mile upstream from January 1 

to June 15. In the East Fork Hood River the criteria apply from October 15 to May 15. 

Stream temperatures from on-going Forest Service stream temperature monitoring, and Forest Service 

Stream surveys were assessed for compliance with stream temperature standards.

The ranges for the highest 7-day average maximum stream temperatures for stream temperature data 

loggers that were deployed during the summer months are displayed in table 33.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

174

Table 3320. Highest 7-Day average maximum stream temperatures in the analysis area (degrees Celsius)

Stream 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2011

Camp Creek ND21 ND ND ND ND ND ND ND ND ND ND ND ND ND 11.2

Doe Creek ND ND ND ND 10.5 10.0 10.3 12.3 10.4 ND 11.9 11.6 ND ND ND

E. Fork Hood 

River - Lower

15.9 12.7 13.3 13.0 ND 13.2 14.6 17.1 14.5 16.6 16.5 17.3 15.5 16.4 ND

E. Fork Hood 

River - Upper

ND ND ND ND ND ND 13.6 15.8 15.5 15.5 15.6 16.4 ND ND ND

Tilly Jane 

Creek -

Lower

ND ND ND ND 8.6 10.0 10.0 10.6 10.5 10.4 10.8 10.2 ND ND ND

All of the sites detailed meet the applicable stream temperature standards

The table illustrates some cold water temperatures within the project area, due primarily to a contribution of flow from groundwater and glacial 

sources. Tilly Jane Creek has groundwater influence while East Fork Hood River water temperatures are somewhat influenced by glacial 

meltwater. Stream surveys also noted cool water temperatures in Crystal Springs Creek, and Doe Creek suggesting these streams also have a 

moderate to strong groundwater influence (USDA Forest Service 2016).

 20 Doe Creek, East Fork Hood River, and Tilly Jane Creek stream temperatures are from the Polallie Cooper Hazardous Fuels Reduction Project Draft Environmental Assessment 

(USDA Forest Service 2016) 

21 ND – Datalogger was not deployed
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

175

Since there is limited stream temperature data available on streams in the Government Camp 

parcels, including Camp Creek and Little Zigzag River, the NorWeST temperature database was 

examined.

The NorWeST project and database team has developed a comprehensive, interagency stream 

temperature database for the northwestern U.S. Those data were used to develop accurate (R2 = 

90 percent; RMSE <1.0 °C), high- resolution (1 kilometer) stream temperature scenarios for 

500,000 kilometers of streams and rivers (The NorWeST Interagency Stream Temperature 

Database and Climate Scenarios briefing paper, 

http://www.fs.fed.us/rm/boise/AWAE/briefing/AWAE_Science_BriefingsNorWeSTRegionalStreamTemperatureDatabaseAndModeledClimateScenarios.pdf).

The temperature database was compiled from hundreds of biologists and hydrologists working 

for dozens of resource agencies and contains more than 45,000,000 hourly temperature 

recordings at more than 15,000 unique stream sites. These temperature data are being used with 

spatial statistical stream network models to develop an accurate and consistent set of climate 

scenarios for all streams (http://www.fs.fed.us/rm/boise/AWAE/projects/NorWeST.html).

August mean stream temperature was the metric selected to be modeled in the NorWeST 

temperature model. Use of this metric allowed the largest proportion of data in the NorWeST 

observed temperature database to be used (approximately 80 percent), which facilitated 

calibration of the model to thousands of unique stream sites across the region (NorWeST 

Modeled Stream Temperature Stream Points for the “Oregon Coast” Processing Unit, Metadata).

Sites associated with the Government Camp parcel are in the Oregon Coast Processing 

Unit.

Model Prediction Accuracy 

(http://www.fs.fed.us/rm/boise/AWAE/projects/NorWeST/downloads/images/Scenarios/OregonC

oastModelResults.jpg)

Figure 27. Zigzag Canyon 6th field watershed mean August Stream Temperature (2002-2011)
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

176

Figure 28. Historical composite scenario representing 9 year average August mean stream 

temperatures for 2002 – 2011

The map depicted in figure 28 details a maximum mean August stream temperature in Camp 

Creek of 11.1 °C and in the Little Zigzag River of 6.7 °C

In an effort to compare NorWest project stream temperatures to stream temperature standards, 

the August mean Stream Temperature. (2002 through 2011) from NorWest was compared to the 

maximum of the 7-day average of the daily maximum at the Zigzag River at the Forest Boundary 

monitoring site and the mean value of the maximum of the 7-day average was 2.3 °C higher than 

the August mean modeled stream temperature. Using this relationship, an estimated 7-day 

average of the daily maximum stream temperature dataset was created and is detailed in the map 

below.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

177

Figure 29. Zigzag Canyon 6th field watershed NorWest stream temperatures adjusted to estimate 

daily maximum for 2002 through 2011

The map depicted in figure 29 details an estimated 7-day average of the daily maximum with a 

maximum temperature in Camp Creek of 13.3 °C and in the Little Zigzag River of 8.9 °C, which 

are both below the 16 °C temperature standard for the period after June 15.

Resource Indicator and Measure: Riparian Shading and Habitat- Aquatic and 

Riparian Effectiveness Monitoring Program

Riparian conditions play a key role in a number of aquatic processes, including the effect of 

shading on stream temperatures, roots on bank stability, and the provision of habitat for a 

number of species. The AREMP model rates the condition of these processes using the average 

of two indicators: riparian vegetation condition and riparian road density (Miller et al. 2015).

For this indicator, the Zigzag Canyon sub-watershed was rated as Properly Functioning and the 

Middle East Fork Hood River sub-watershed as Functioning at Risk.

Resource Indicator and Measure: Sediment

For this analysis sediment delivery associated with natural background levels from landslides, 

wildfires, road surfaces, highway sanding and land use were examined.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

178

Resource Indicator and Measure: Sediment Production and Delivery- Aquatic 

and Riparian Effectiveness Monitoring Program

High rates of sediment delivery to streams from episodic mass wasting events such as landslides 

and erosion have been shown to have detrimental effects on salmonids and other aquatic biota. 

Natural rates for these processes are determined by a variety of factors, including slope, 

concavity, soils, geology, geomorphology, and precipitation. Within the range of the northern 

spotted owl, Federal forest management affects these rates primarily through road and vegetation 

disturbances. To evaluate the process of sedimentation production and transport, the AREMP 

model used the difference between an estimated background rate of sediment delivery and the 

rate estimated given the status of road and vegetation disturbances (Miller et al. 2015).

For this indicator, the Zigzag Canyon sub-watershed was rated as Functioning at Risk and the 

Middle East Fork Hood River sub-watershed was rated as Not Properly Functioning. 

Resource Indicator and Measure: Sediment Production and Delivery Mass 

Wasting

Mass wasting is a natural process that occurs to some extent in most forested basins in the 

Pacific Northwest. The time scale (relative or absolute) of mass wasting in a basin is important to 

an understanding of the sediment mass balance of a watershed. Mass wasting events may occur 

on a return interval of one or two years, decades, centuries, or even millennia. While the smaller, 

more frequent events may cause the fresh scars to be visible on the landscape, the larger, 

infrequent events are probably the real shapers of the landscape. Both types of landslides are 

influential in their impact on physical resources. In a natural, unmanaged forested basin, the 

dynamic replenishment of material to the channels by mass wasting is essential to the diversity 

and health of the ecosystem (DNR 2011b).

Not all landslides deposit sediment directly in streams; sediments may be deposited on 

floodplains, glacial or alluvial terraces, or foot slopes, without reaching a stream. However, as 

basin area increases, the cumulative probability of either one small landslide entering a stream or 

one small failure triggering a debris torrent with catastrophic impact on habitat conditions 

increases (DNR 2011b). 

A forestwide map of landslide risk was compiled in 2000, from the geomorphic mapping 

completed during watershed analysis. Each watershed, and eventually the entire Forest, had been 

divided into geomorphic map units, primarily based on geologic unit and slope angle. Each 

geomorphic map unit had then been assigned a qualitative descriptor of its propensity for 

landslides (high, medium, or low). The assignment of this adjective was based on landslide 

inventories. The map lumps all landslide types together (USDA Forest Service 2003).

Table 34 identifies the landslide risk in the 7th field watersheds associated with the project based 

on the forestwide map of landslide risk.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

179

Table 34. Landslide risk percentages by sub-watershed 

7th Field Watershed High Moderate Low Unclassified

Camp Creek 15% 24% 61%

Little Zigzag 0% 7% 85% 9%

Crystal Springs 1% 26% 74%

Tilly Jane Creek 9% 16% 75%

East Fork Hood River 24% 31% 45%

East Fork Hood River (Lower Reach) 35% 22% 43%

Using sediment delivery rates from undisturbed forested areas in an area classified as an unstable 

zone in the H.J. Andrews Experimental Forest (Swanson and Dyrness 1975) sediment delivered 

from the unstable zones (areas classified as high landslide risk) was estimated for the 7th field 

watersheds associated with project. 

Table 35. Natural background levels of sediment yield from mass wasting

7th Field Watershed Estimated Natural Background from 

Slides (cubic yards per year)

Camp Creek 420

Little Zigzag 0

Crystal Springs 6

East Fork Hood River 644

East Fork Hood River (Lower Reach) 497

Tilly Jane Creek 117

Resource Indicator and Measure: Sediment Production and Delivery Wildfires

Besides substantially altering hydrologic processes, wildfire has been shown to affect water 

quality by increasing rates of erosion and sedimentation and increasing the concentrations of 

nutrients and other water quality constituents. Generally, the largest effects on water quality are 

directly or indirectly rated to increases in erosion and sedimentation. 

In a recent study (Moody and Martin 2009), measurements of post-fire sediment, erosion, 

transport, and deposition collected within 2 years of a wildfire were compiled from the published 

literature (1927 to 2007) for sites across the western United States. Post-fire sediment yields for 

each method were then grouped into eight different rainfall regimes. Mean sediment yield from 

channels (approximately 106 tons per acre) was significantly greater than from hillslopes 

(approximately 36 tons per acre). This indicated that on the time scale of wildfire (10 to 

100 years) channels were the primary sources of available sediment. A lack of correlation of 

sediment yield with topographic slope and soil erodibility further suggested that sediment 

availability may be more important than slope or soil erodibility in predicting post-fire sediment 

yields. Based on 80 years of data from the literature, wildfires have been an important 

geomorphic agent of landscape change when linked with sufficient rainfall. These effects are 

limited in spatial scale to the immediate burned area and to downstream channel corridors. 

(Moody and Martin 2009)
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

180

There have been no large fires (greater than 5 acres) in the 7th field watersheds associated with 

the land exchange parcels from 2010 to the present. The Gnarl Ridge fire, which burned 

1,266 acres in the Tilly Jane 7th field watershed, was in 2008. 

Published sediment yields after wildfires vary from 0.01 to over 110 Mg ha-1 year-1 (0.004 to 

48 tons per acre per year) in the first post-fire year, decrease by an order of magnitude the 

following year, and recover, with no measurable erosion, by the fourth year (Robichaud and 

Brown 2005). The Gnarl Ridge fire has had eight winter runoff periods, and based on Robichaud 

and Brown (2005), that would be the timeframe where there would be no measureable erosion 

associated with the wildfire.

Burned Area Emergency Response (BAER) treatments in conjunction with natural recovery of 

the area have minimized negative wildfire effects on area streams. Tilly Jane Creek drains the 

watershed that was the most severely burned by the Gnarl Ridge fire. Major negative effects 

from higher runoff and high sediment loading were not readily apparent in a 2015 field visit. The 

most noticeable effect was the increased amount of small limbs in the channel, likely from the 

wood loading transported from the burned area just upstream (USDA Forest Service 2016).

Resource Indicator and Measure: Hydrologic Sediment Production and DeliveryRoads

Road networks in many upland areas of the Pacific Northwest are the most important source of 

management-accelerated delivery of sediment to anadromous fish habitats. The sediment 

contribution to streams from roads is often much greater than that from all other land 

management activities combined, including log skidding and yarding. Road related land sliding, 

surface erosion and stream channel diversions frequently deliver large quantities of sediment to 

streams, both chronically and catastrophically during large storms. Roads may have unavoidable 

effects on streams, no matter how well they are located, designed or maintained. Many older 

roads with poor locations and inadequate drainage control and maintenance pose high risks of 

erosion and sedimentation of stream habitats (USDA Forest Service 1993).

Sediment yield associated with the existing road system was estimated for 7th field watersheds 

using the Geomorphic Roads Analysis and Inventory Package (GRAIP-Lite) model.

The Geomorphic Roads Analysis and Inventory Package is designed to determine the impacts of 

road systems on erosion and sediment delivery to streams. As the name implies it couples an 

inventory with analytical tools to build an approach to roads analysis that can be locally 

calibrated in a repeatable fashion with minimal effort. The full scope of GRAIP includes 

methods to inventory roads and analyze the inventory for surface erosion, gully risk, and 

landslide risk; methods to measure surface erosion from sample sites; and methods to estimate 

surface erosion where no inventory has been taken (NetMap Tools Technical Help Guide).

GRAIP-Lite is the GIS version of GRAIP and it was designed to quickly prioritize watersheds 

based on approximated road-related sediment production and delivery. It requires a road layer 

embedded within a GIS. In NetMap, the road layer is integrated within a digital terrain model. 

GRAIP-Lite requires calibration datasets to calculate road erosion and they are included in 

NetMap’s GRAIP interface. Users are encouraged to apply the full GRAIP technology to 

develop calibration datasets for their own landscapes (NetMap Tools Technical Help Guide). 

Road sediment production is predicted by: E = B*R*S*V
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

181

E is road sediment production (kg/yr), B is the base road surface erosion rate, R is the elevation 

difference between the road segment end points, S is the road surface factor and V is the 

vegetation factor. V and therefore E are calculated separately for each combination of road 

surface type and road maintenance level. V = 1 - 0.86x where x is the fraction of the road where 

flow path vegetation is greater than 25 percent (NetMap Tools Technical Help Guide).

Once road sediment production is calculated (E), the proportion that is delivered to streams is 

highly sensitive to the distance of the road to the stream. NetMap calculates the distance of each 

road segment to the corresponding stream segment that it drains into. Field studies during 

GRAIP analyses have indicated a significant reduction in sediment delivery with increasing 

distance of the road from the stream. The average of those curves is used in NetMap’s GRAIP 

tool to predict the fractional proportion of sediment delivery to streams from forested roads. The 

effect of distance to stream is significant: roads located less than 200 meters from a stream are 

predicted to deliver greater than 40 percent of sediment to stream channels; roads located greater 

than 200 meters from streams are predicted to delivery approximately less than 5 percent of 

sediment (NetMap Tools Technical Help Guide).

Figure 30. Fractional sediment delivery curve used in NetMap’s GRAIP tool (NetMap Tools Technical 

Help Guide)

This model was selected because it allows for standardized and repeatable calculations of road 

surface erosion using the standard Forest Service road network GIS dataset.

Presentation of the GRAIP-Lite model results are intended to provide a means of comparing 

existing conditions with the proposed project in which both existing and proposed actions utilize 

the same assumptions and to give a comparison in broad terms of natural to management related 

sediment yields within the project area. As with the Washington State Road Surface Erosion 

Model (Dubé et al. 2004) it is appropriate to look at the relative differences in erosion estimates 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

182

when comparing watershed areas or road segments, but the sediment values should always be 

regarded as estimates not absolute values. Any predicted runoff or erosion value—by any 

model—will be, at best, within plus or minus 50 percent of the true value. Erosion rates are 

highly variable, and the models predict only a single value. Replicated research has shown that 

observed erosion values vary widely for identical plots, and for the same plot from year to year 

(Elliot et al. 2000).

The road network used to estimate the sediment yield for the existing road system was the Forest 

Service road network dataset and where it was not available the BLM ground transportation 

dataset and the Clackamas County roads dataset were used.

Table 36. Estimated sediment yield from the existing road system

7th Field Watershed Estimated tons of Sediment Delivery per year from the 

existing road system road surface erosion

Camp Creek 42.4

Little Zigzag 0.6

Crystal Springs 37.9

East Fork Hood River 36.0

East Fork Hood River (Lower Reach) 10.5

Tilly Jane Creek 20.3

The 1995 Zigzag Watershed Analysis characterized sediment sources and sediment delivery to 

the stream system associated with Highway Sanding that is used to improve vehicle traction. 

There was 2,102 tons per year of sediment delivery estimated for the Camp Creek 7th field 

watershed and 406 tons per year of sediment delivery estimated for the Zigzag/Little Zigzag 

Canyon watershed. There are no highways adjacent to the Zigzag River so it is assumed that all 

highway sand in this area is delivered to the Little Zigzag River.

The 1996 East Fork Hood River and Middle Fork Hood River Watershed Analyses (USDA 

Forest Service 1996) did not quantify sediment delivery associated with road sanding but did 

address the issue.

The effect of sanding for winter transportation safety within the East and Middle Forks 

of the Hood River is observed primarily on Highway 35, the access roads to the Mt. 

Hood Meadows and Hood River Meadows ski areas and their respective parking lots. 

The Oregon Department of Transportation places approximately 1,000 cubic yards of 

aggregate a year on the portion of Highway 35 from Parkdale to Bennett Pass. The same 

amount (1,000 cubic yards) is used to sand the 3.6 miles of access roads to Mt. Hood 

Meadows Hood River Meadows (Forest Service roads 3555 and 3545) and the 

19.3 acres of parking area. 

Within the Cooper Spur parcel 7th field watersheds the East Fork of Hood River which 

parallels Highway 35 has the greatest potential for sediment input from highway 

sanding. Crystal Springs Creek, Ash Creek and Tilly Jane Creek cross Highway 35 at a 

90 degree angle minimizing the area where sand from the highway can enter these 

creeks.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

183

Resource Indicator and Measure: Sediment Production and Delivery- Land Use

The Geospatial Interface for the Water Erosion Prediction Project (GeoWEPP) is based on the 

WEPP model, a spatial erosion modeling tool that is widely accepted for soil erosion, runoff and 

sediment yield prediction in forests, woodlands, shrublands, grasslands, rangelands, and 

agricultural lands (Renschler and Elliot 2006). GeoWEPP models erosion and sediment yield 

using site specific spatial information for topography, land use and soils while using local 

climate data. 

For this project GeoWEPP was used to model the Government Camp parcels to establish a 

baseline for sediment yield in an area where under the proposed action there are changes in land 

use from forested land to developed areas. In order to isolate the potential impacts associated 

with the project smaller watersheds were established to focus on the potential changes in land 

use. The Cooper Spur parcels were not modeled because there are no ground-disturbing activities 

proposed for the Cooper Spur parcels. The average annual sediment discharge from the outlet 

includes contributions from hillslope and channel soil loss.

Table 37. Average annual sediment discharge from outlet associated with land use

Modeled Area Acres Average annual. sediment 

discharge from outlet (tons)

Camp Creek Catchment 1 481.7 151.8

Camp Creek Catchment 2 14.0 1.1

Camp Creel Catchment 3 10.3 0.4

Camp Creek Total 506 153.3

Unnamed Tributary to Little Zigzag River Catchment 1 96.4 22.8

Unnamed Tributary to Little Zigzag River Catchment 2 8.7 0.4

Unnamed Tributary to Little Zigzag Total 105.1 23.3
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

184

Figure 31. GeoWEPP modeled catchments

Resource Indicator and Measure: Sediment- In-Channel Fine Sediment Levels

In-channel fine sediment was evaluated based on stream surveys. Areas where surface fines 

(material less than 6 millimeters) exceed 20 percent of the substrate were identified. The 

threshold of concern for fine sediment is based on the relationship of embryo survival and 

percentage of substrate particles less than 6.35 millimeters for chinook, kokanee, rainbow, 

cutthroat and steelhead trout (Bjorn and Reiser in Meehan 1991). Above 20 percent surface fines, 

the survival of salmonid embryos decreases rapidly in that study. 

The Mt. Hood Forest Plan (USDA Forest Service 1990) Standards FW-097 and FW-098 state: 

“Spawning habitat (e.g., pool tailouts and glides) shall maintain less than 20 percent fine 

sediments (i.e., particles less than 1.0 millimeter in diameter) on an area-weighted average. The 

area considered within the average should include only the stream reaches available for 

vegetative manipulation (e.g., Wilderness areas should not be included).” Stream surveys 

complete pebble counts in representative riffles (areas not considered “spawning habitat”) so the 

Mt. Hood Forest Plan Standards FW-097 and FW-098 would not appear to apply in these areas 

since they are not spawning habitat (e.g., pool tailouts and glides). Mt. Hood Forest Plan 

Standards FW-099 and FW-100 state: “Riffle areas shall maintain less than 25 percent 

embeddedness on an area-weighted average. The area considered within the average should 

include only the stream reaches available for vegetative manipulation,” so this would appear to 

be the standard used to assess fine sediment levels associated with stream surveys. The smallest 

material measured during stream surveys is 2 millimeters, so it is used to define fine sediment 

associated with the Forest Plan standards 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

185

Table 38. In-channel fine sediment levels in surveyed streams

Stream Reach Year Surveyed % Less than 2mm % Less than 6mm

Camp Creek Reach 1 2011 14 16

Camp Creek Reach 2 2011 8 11

Camp Creek Reach 3 2011 22 22

Camp Creek Reach 4 2011 23 23

Camp Creek Reach 5 2011 3 3

Camp Creek Reach 6 2011 26 26

Camp Creek Reach 7 2011 23 25

Camp Creek Reach 8 2011 55 78

Little Zigzag River Reach 1 2000 13 17

Little Zigzag River Reach 2 2000 20 26

Little Zigzag River Reach 3 2000 22 26

Tilly Jane Creek Reach 1 1997 23 25

Tilly Jane Creek Reach 2 1997 58 61

Tilly Jane Creek Reach 3 1997 23 26

Doe Creek Reach 1 1997 26 32

Doe Creek Reach 2 1997 58 61

Doe Creek Reach 3 1997 45 57

Doe Creek Trib. Reach 1 1997 49 68

Doe Creek Trib. Reach 2 1997 22 27

Crystal Springs Crk Reach 1 2003 32 33

Forest Service stream surveys as far back as 1984 identify issues with fine sediment in Camp 

Creek, “A final factor which likely plays a negative role is heavy sedimentation in depositional 

areas, blanketing potential spawning and rearing habitat with sand.” The 1994 stream survey 

noted: high accumulations of silt and sand occurred throughout the stream with the highest 

accumulations observed adjacent to Camp Creek Campground (RM 1.7) and adjacent to Mirror 

Lake Trailhead (RM 5.8). High accumulations of silt were also noted in areas adjacent to 

summer homes, bridge crossings, road landings, stream segments running along Highway 26, 

and the Ski Bowl recreation site. It should be noted that sedimentation was observed even in 

areas where bank erosion was not evident. Sedimentation could be attributed to heavy road 

sanding on Highway 26 as well as bank erosion. It was not possible to distinguish between 

sediment originating from road sanding or eroding stream banks. Issues with fine sediment were 

noted again in the 2011 stream survey: an abundance of sand was noted mostly in the section 

from RM 2.2 to RM 5.9 in Camp Creek. Many of the pools had deep sand deposits.

The stream survey of Little Zigzag River in 1992 noted: The most outstanding features affecting 

the drainage appeared to be the fluctuating flow and the resultant sedimentation. The stream was 

glacially fed and evidence of flow fluctuations were common. The flashy flow seemed to have 

caused bank scour and increased siltation. The long stretches of exposed talus slopes above river 

mile 2.6 increased the sedimentation problem. Cobble substrate was estimated to be more than 

35 percent embedded in the surrounding, smaller substrate in all but the lowermost 1.5 miles of 

stream. At the time of the survey, the turbidity prevented the collection of accurate fish 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

186

identification and distribution data. Human management activities appeared to have little impact 

on this stream. (USDA Forest Service 1992)

With respect to sedimentation the 1997 Tilly Jane Creek stream survey noted: several areas of 

large bank erosion were encountered during the survey. No immediate cause was determined for 

these areas of erosion. (USDA Forest Service 1997a)

The 1997 Doe Creek survey (USDA Forest Service 1997b) noted: Bank stability and erosion are 

not problems in Doe Creek or the tributary. It appears some down cutting was occurring with 

some slumping banks and undercut banks present. Reaches 1 and 3 had 0 percent unstable banks 

while Reach 2 had 1.5 percent unstable banks. These are well within the properly functioning 

conditions for the matrix of pathways and indicators from National Marine Fisheries Service 

(NMFS) (1996). Spawning gravels were available but sedimentation was a problem in a few 

areas mostly near roads.

Table 39. Matrix of pathways and indicators to evaluate properly functioning condition from NMFS 

1996

Indicators Properly functioning (PF) At risk (AR) Not properly 

functioning (NPF)

Streambank 

condition

>90% stable; i.e., on average, less than 

10% of banks are actively eroding

80-90% 

stable

<80% stable

Environmental Consequences

Direct and Indirect Effects

Alternative 1- No Action

Resource Indicator and Measure: Overall Watershed Condition

Under the existing condition the AREMP watershed condition score indicates that both the 

Zigzag Canyon and Middle East Fork Hood River watersheds are in the functioning at risk 

categories. This category indicates that watersheds exhibit moderate geomorphic, hydrologic, 

and biotic integrity relative to their natural potential condition. Under the no-action alternative 

the land exchange parcels and surrounding landscape would be managed under the same 

direction as the existing condition so it is expected that the watersheds would remain in the same 

condition.

Water Quantity

It is likely that past land management activities and wildfires in the 7th field watersheds 

associated with the Government Camp and Cooper Spur parcels have affected peak and base 

flows. 

All of the subwatersheds, except Tilly Jane Creek are below the threshold of concern from “The 

Effects of Forest Practices on Peak Flows and Consequent Channel Response Report” (Grant et 

al. 2008). All the subwatersheds are below the threshold associated with the methodology for 

addressing cumulative watershed effects, watershed sensitivity, and hydrologic recovery 

associated with the Mt. Hood Forest Plan (USDA Forest Service 1990a). When the combined 

impacts of vegetation management and roads are examined, all the subwatersheds are rated as 

properly functioning in the 6th Field Watershed Condition from the “Northwest Forest Plan–The 

First 20 Years (1994-2013) Watershed Condition Status and Trend Report” (Miller et al. 2015).
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

187

Tilly Jane Creek watershed is above the threshold of concern from “The Effects of Forest 

Practices on Peak Flows and Consequent Channel Response Report” (Grant et al. 2008) due to 

vegetation loss from the Gnarl Ridge fire. However, indications of major increased peak flows 

such as channel bed instability or scour and channel bank erosion were not noted during field 

visits to Tilly Jane Creek just below the burned area (USDA Forest Service 2016).

Under the no-action alternative, the percentage of the watershed completely hydrologically 

recovered (in terms of ARP values) would continue to recover in terms of hydrologic recovery as 

young plantations grow and areas impacted by wildfire recover. 

Under the no-action alternative, there would be no land exchange with associated development 

in the Government Camp parcels. There would not be a residential district with associated 

infrastructure including roads established in the Government Camp parcel, so there would be no 

additional risk of peak flow increases due to these activities.

In the Cooper Spur parcel, the Crystal Springs Watershed Special Resources Management Unit 

would not be established on the existing private lands, and riparian reserves would not be 

established on existing private land.

Resource Indicator and Measure: Hydrologic Processes Aquatic and Riparian 

Effectiveness Monitoring Program

The AREMP assessment factors in vegetative disturbance, roads and climate zone. Under the noaction alternative there is no planned vegetation disturbance, road construction or road 

decommissioning so the indicator would be expected to remain the same as the existing 

condition.

Since the impacts of vegetative removal though harvest and roads are essentially the same as 

those described in the existing condition and the climate zone stays the same the hydrologic 

process indicator is expected to stay the same as the existing condition.

Resource Indicator and Measure Base Streamflows Water Rights

Under the no-action alternative, there are no water uses planned, so this indicator would stay in 

the same condition as described in the existing condition.

Resource Indicator and Measure: Water Quality- Water Quality Limited 303(d) 

Streams

Little Zigzag Canyon (Little Zigzag River) from river mile 0 to 5.5 and East Fork Hood River 

from river mile 0 to 27.4 are 303(d) listed for biocriteria (waters of the state must be of sufficient 

quality to support aquatic species without detrimental changes in the resident biological 

communities). The biocriteria is based on macroinvertebrate communities in Oregon’s perennial, 

wadeable streams.

The text below is from “Monitoring Guidelines to Evaluate Effects of Forestry Activities on 

Streams in The Pacific Northwest and Alaska” (MacDonald et al. 1991).

The effects of forest activities on macroinvertebrate communities vary. Increases in the 

riparian canopy opening or the amount of organic material in the streams generally 

enhance aquatic insect populations. An increase in fine sediment usually has the opposite 

effect. Removing the riparian canopy decreases the input of terrestrial organic material 

and the number of detritivores. However, this decline often is overwhelmed by the 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

188

corresponding increase in primary production and herbivorous insects. Several studies 

have documented an increase in primary productivity after partial or complete removal 

of the riparian canopy. However, no increase was found in Carnation Creek in coastal 

British Columbia, where phosphorus was found to be the limiting factor. Logginginduced increases in aquatic insects have been observed in northern California and the 

Oregon Cascades. While logging activities may increase total abundance, species 

diversity is usually reduced.

Invertebrate communities also are affected by management practices on forest lands. 

Buffer strips 30 meters wide appeared to protect in vertebrate communities from logging 

induced changes, but buffer strips 10 meters wide still resulted in a decrease in detrital 

inputs and macroinvertebrate densities. The net effect of logging on aquatic 

macroinvertebrates depends on the relative balance among all the controlling factors.

Primary shade zones (areas of riparian vegetation directly adjacent to streams) along perennial 

streams would continue to fill in with understory vegetation. Sediment delivery to streams in the 

project area would remain at current levels. It is anticipated that the macroinvertebrate 

community as assessed by Oregon Department of Environmental Qualities PREDictive 

Assessment Tool for Oregon would remain in the same range as the existing condition because 

primary shade zones and sediment inputs are anticipated to stay at the current levels.

Resource Indicator and Measure: Water Quality- Stream Temperature

Stream temperatures can be affected by processes that remove stream shade, alter channel 

structure, or alter the flow regime. 

The natural watershed parameters that are most influential in determining stream temperature 

include: solar radiation, air temperature, stream width, stream depth, shading, and groundwater 

inflow. Forest practices can affect these parameters. For example, removal of riparian vegetation 

increases the solar radiation received by a stream reach; logging can alter streamflow, either 

decreasing or increasing summer low flows depending on local situations, and sedimentation can 

decrease channel depth and increase channel width (DNR 2011a).

Increased water temperature can often be traced to removal of shade-producing riparian 

vegetation along fish-bearing streams and along smaller tributary streams that supply cold water 

to fish-bearing streams. Removal of streambank vegetation has resulted largely from timber 

harvest in riparian areas (USDA Forest Service 1993).

Stream temperatures are anticipated to remain at current levels. Primary shade zones (areas of 

riparian vegetation directly adjacent to streams) along perennial streams would continue to fill in 

with understory vegetation as young plantations grow and areas impacted by wildfire recover. 

Since these areas are already densely vegetated, it is not anticipated that this component will 

reduce stream temperatures any great degree within the project area. Increased peak streamflows 

have the potential to erode the streambed and banks, however it was concluded in the Water 

Quantity Section of this report that current peak streamflows do appear to be adversely 

impacting stream channel morphology.

Resource Indicator and Measure: Riparian Shading and Habitat Aquatic and Riparian 

Effectiveness Monitoring Program

The AREMP model rates the condition of these processes using the average of two indicators: 

riparian vegetation condition and riparian road density (Miller et al. 2015). Under the no-action 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

189

alternative, there would be no land exchange with associated development in the Government 

Camp parcels that would remove riparian vegetation or create new roads in the riparian area. In 

the Cooper Spur parcel the Crystal Springs Watershed Special Resources Management Unit 

would not be established on the existing private lands and riparian reserves would not be 

established on existing private land. There are no earth-disturbing or vegetation management 

activities planned in this parcel. As riparian vegetation and road density will stay the same in 

both parcels the riparian shading and habitat processes rating would stay the same

Resource Indicator and Measure: Sediment

Under the no-action alternative there would be no land exchange with associated development in 

the Government Camp parcels. There would not be a residential district with associated 

infrastructure including roads established in the Government Camp parcel so there would be no 

additional sediment generated from new roads or changes in land use and sediment delivery 

would be the same as described in the existing condition.

In the Cooper Spur parcel the Crystal Springs Watershed Special Resources Management Unit 

would not be established on the existing private lands and riparian reserves would not be 

established on existing private land. There are no earth disturbing or vegetation management 

activities planned in this parcels so sediment delivery would be the same as described in the 

existing condition.

Resource Indicator and Measure: Sediment- In-Channel Fine Sediment Levels

Sediment delivery would be the same as that described in the existing condition. Peak 

streamflows are not at the level where increased bank erosion, channel scour, channel widening, 

and sedimentation are expected, so in channel fine sediment levels would be expected to remain 

at the same level as those described in the existing condition.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

190

Table 40. Resource indicators and measures for the no-action alternative Government Camp Parcels

Resource Element Resource Indicator Measure Area Analyzed No Action

Watershed Condition Upslope/Riparian 

Condition

AREMP22 6th Field Watershed 

Assessment

Zigzag Canyon 6th field watershed Functioning at Risk

Water Quality, Riparian and 

Channel Function and Watershed 

Function

Water yield Peak 

Streamflows

AREMP 6th Field Watershed 

Assessment

Zigzag Canyon 6th field watershed Properly Functioning

Water Quality, Riparian and 

Channel Function and Watershed 

Function

Water yield Peak 

Streamflows

2-year 24-hour storm event 

streamflow

Camp Creek 7th field watershed 323

Little Zigzag 7th field watershed 296

Water Quality, Riparian and 

Channel Function and Watershed 

Function

Water yield Peak 

Streamflows

Aggregate Recovery 

Percentage 

Camp Creek 7th field watershed 89

Little Zigzag 7th field watershed 98

Water Quality, Riparian and 

Channel Function and Watershed 

Function

Water yield Peak 

Streamflows

Road Drainage Stream Network 

Enhancement

Camp Creek 7th field watershed 6%

Little Zigzag 7th field watershed 1%

Water Quality, Riparian and 

Channel Function and Watershed 

Function

Water yield –base 

streamflows

Are more water rights allocated 

that than the D50 lowflow

Camp Creek subcatchment Yes

Little Zigzag 7th field watershed No

Water Quality Overall Water quality Water quality limited streams Camp Creek 7th field watershed 0

Little Zigzag 7th field watershed 5.5

Water Quality Stream Temperature Stream temperature. 

Compliance with State standard

Camp Creek 7th field watershed Yes

Little Zigzag 7th field watershed Yes

Water Quality Sediment delivery land 

use

Tons per year delivered Camp Creek 7th field watershed 153.3

Little Zigzag 7th field watershed 23.3

Water Quality Sediment delivery 

roads

Tons per year delivered Camp Creek 7th field watershed 42.4

Little Zigzag 7th field watershed 2.8

Water Quality Sediment In channel fine sediment levels. 

Number of stream reaches that 

exceed threshold

Camp Creek 7th field watershed 5

Little Zigzag 7th field watershed 2

Water Quality Riparian Processes 

Indicator

AREMP 6th Field Watershed 

Assessment

Zigzag Canyon 6th field watershed Properly Functioning

 22 The NW Forest Plan watershed monitoring module (also known as the Aquatic and Riparian Effectiveness Monitoring Program or AREMP)
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

191

Table 41. Resource indicators and measures for the no-action alternative Cooper Spur Parcels

Resource Element Resource Indicator Measure Area Analyzed No Action

Watershed Condition Upslope/Riparian 

Condition

AREMP23 6th Field 

Watershed Assessment

Middle East Fork Hood River 6th Field 

Watershed

Functioning at 

Risk

Water Quality, Riparian and 

Channel Function and Watershed 

Function

Water yield Peak 

Streamflows

AREMP 6th Field 

Watershed Assessment

Middle East Fork Hood River 6th Field 

Watershed

Properly 

Functioning

Water Quality, Riparian and 

Channel Function and Watershed 

Function

Water yield Peak 

Streamflows

2-year 24-hour storm event 

streamflow

Not assessed

Water Quality, Riparian and 

Channel Function and Watershed 

Function

Water yield Peak 

Streamflows

Aggregate Recovery 

Percentage 

Crystal Springs 7th field watershed 91

Tilly Jane Creek 7th field watershed 69

E Fork Hood River 7th field watershed 93

E Fork Hood River Lower 7th field watershed 93

Water Quality, Riparian and 

Channel Function and Watershed 

Function

Water yield Peak 

Streamflows

Road Drainage Stream 

Network Enhancement

Crystal Springs 7th field watershed 7%

Tilly Jane Creek 7th field watershed 13%

E Fork Hood River 7th field watershed 12%

E Fork Hood River Lower 7th field watershed 5%

Water Quality, Riparian and 

Channel Function and Watershed 

Function

Water yield –base 

streamflows

Are more water rights 

allocated that than the D50 

lowflow

Crystal Springs 7th field watershed Yes

Tilly Jane Creek 7th field watershed No

E Fork Hood River 7th field watershed No

E Fork Hood River Lower 7th field watershed No

Water Quality Overall Water quality Water quality limited 

streams (miles)

Crystal Springs 7th field watershed 0

Tilly Jane Creek 7th field watershed 0

E Fork Hood River 7th field watershed 6.4

E Fork Hood River Lower 7th field watershed 3.4

Water Quality Stream Temperature Stream temperature. 

Compliance with State 

standards

Crystal Springs 7th field watershed Yes

Tilly Jane Creek 7th field watershed Yes

E Fork Hood River 7th field watershed Yes

E Fork Hood River Lower 7th field watershed Yes

 23 The NW Forest Plan watershed monitoring module (also known as the Aquatic and Riparian Effectiveness Monitoring Program or AREMP)
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

192

Resource Element Resource Indicator Measure Area Analyzed No Action

Water Quality Sediment delivery land 

use

Tons per year delivered Not assessed

Water Quality Sediment delivery 

roads

Tons per year delivered Crystal Springs 7th field watershed 37.9

Tilly Jane Creek 7th field watershed 36.0

E Fork Hood River 7th field watershed 10.5

E Fork Hood River Lower 7th field watershed 20.3

Water Quality Sediment In channel fine sediment 

levels. Number of stream 

reaches

Crystal Springs 7th field watershed 1

Tilly Jane Creek 7th field watershed 6

E Fork Hood River 7th field watershed Not assessed

E Fork Hood River Lower 7th field watershed Not assessed

Water Quality Riparian Process 

Indicator

AREMP 6th Field 

Watershed Assessment

Middle East Fork Hood River 6th Field 

Watershed

Functioning at 

Risk
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

193

Alternative 2- Proposed Action

Resource Indicator and Measure: Overall Watershed Condition

The Government Camp Parcels contain 0.5 percent of the total land area of the Zigzag Canyon 

watershed and 0.8 percent of the riparian reserve area of the entire watershed. Due to the limited 

acreage associated with the proposed action it is assumed that the Zigzag Canyon watershed 

would stay in the functioning at risk category.

The land use in the Cooper Spur parcel would change from county zoning to Forest Service 

allocations including riparian reserves and the Crystal Springs Watershed Special Resources 

Management Unit. While these changes could be assumed to provide more protection to riparian 

resources, in the short term, it is assumed that the Middle East Fork Hood River watershed 

would stay in the functioning at risk category.

Water Quantity

Resource Indicator and Measure: Hydrologic Processes Aquatic and Riparian 

Effectiveness Monitoring Program

The AREMP assessment factors in vegetative disturbance, roads and climate zone. As detailed in 

this section the Aggregate Recovery Percentage is essentially the same as the existing condition 

and the stream drainage network enhancement is the same as the existing condition so the ratings 

for this indicator would be expected to remain the same (both the Zigzag Canyon and Middle 

East Fork Hood River rated as Properly Functioning).

Resource Indicator and Measure: Peak Streamflows- Wildcat5 Modeling

WildCat5 was used in the Government Camp parcel to assess changes in peak streamflows 

associated with the 2-year 24-hour precipitation event from changes in land use associated with 

converting the area from the existing condition to a residential district with the associated 

infrastructure.

Table 42. Predicted peak streamflows for the 2-year 24-hour precipitation event

Analysis Area Acres

Peak Streamflow 

(cubic feet per 

second) Existing 

Condition

Peak Streamflow 

(cubic feet per 

second) Proposed 

Action

Percent 

Change

Camp Creek at Highway 26 441 23.8 28.9 21%

Camp Creek at Yocum Falls 2,073 109.5 121.1 11%

Camp Creek 7th Field 5,992 322.7 322.7 0%

Unnamed Tributary to Little 

Zigzag River below Enid Lake

196 7.1 12.3 73%

Unnamed Tributary to Little 

Zigzag River at confluence 

with Little Zigzag River

301 11.9 18.4 55%

Little Zigzag 7th Field 2,735 295.7 318.0 8%

Zigzag River at Lady Creek 6,403 721.4 721.4 0%

It is generally accepted that based on considerations of gage and measurement error at high-flow 

events, a minimum detectable change in peak flow (detection limit) of ±10 percent for site-scale 

analysis. Percentage changes in peak flow that fall in this range are within the experimental and 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

194

analytical error of flow measurement and cannot be ascribed as a treatment effect (Grant et al. 

2008). 

Peak streamflow increases above 10 percent have the potential to cause stream channel damage 

in the form of increased bank erosion, channel scour, channel widening, and sedimentation. 

(USDA Forest Service 2014). Recent studies (Grant et al. 2008) support the inference that when 

present, peak flow effects on channels should be confined to a relatively discrete portion of the 

stream network: stream reaches where channel gradients are less than approximately 2 percent 

and streambed and banks are gravel and finer material. Peak flow effects on channel morphology 

can be confidently excluded in high-gradient (slopes greater than 10 percent) and bedrock 

reaches, and are likely to be minor in most step-pool systems. On the other hand, if channels are 

gravel or sand-bedded, a more detailed hydrologic and geomorphic analysis may be warranted.

At the site scale both Camp Creek and the unnamed tributary to the Little Zigzag River have 

predicted peak streamflows increases above 10 percent and based on stream surveys on Camp 

Creek and the Little Zigzag River the dominant substrate is these areas is gravel and based on 

stream gradient from NetMap stream datasets there are sections of stream with gradients in the 

2 to 4 percent range. Based on predicted increases in peak streamflows, streambed composition 

and stream gradient there may be impacts in the form of increased bank erosion, channel scour, 

channel widening, and sedimentation in these areas.

As the watershed size gets larger peak streamflow impacts are reduced in Camp Creek at the 

confluence with the Zigzag River and the Little Zigzag River at the confluence with the Zigzag 

River predicted peak flow increases are less than 10 percent.

Resource Indicator and Measure: Peak Streamflows - Aggregate Recovery Percentage

The following table details the change in Aggregate Recovery Percentage (ARP) values 

associated with project implementation that includes residential district development with 

associated infrastructure including roads in the Government Camp parcel.

Table 43. Hydrologic recovery proposed action 24

Subwatershed ARP (Impact Area) 

Existing Condition

ARP (Impact Area) 

Proposed Action

Camp Creek25 89 (11) 88 (12)

Little Zigzag River 98 (2) 97 (3)

Crystal Springs 91 (9) 91 (9)

Tilly Jane Creek 69 (31) 69 (31)

East Fork Hood River 93 (7) 93 (7)

East Fork Hood River Lower 93 (7) 93 (7)

The slight changes in ARP associated with the project would not likely cause any additional 

changes in stream channel stability or increases in peak flows beyond those described for the 

existing condition. 

 24 ARP values for Crystal Springs, Tilly Jane Creek, East Fork Hood River, and East Fork Hood River Lower are from 

the Polallie Cooper Hazardous Fuels Reduction Project Draft Environmental Assessment (USDA 2016) 25 The ARP values for Camp Creek and Little Zigzag River were calculated for the year 2018. For the analysis, it was 

assumed that the project would be implemented in 2018.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

195

Resource Indicator and Measure: Peak Streamflows- Stream Drainage Network Extension 

Stream channel network extension would stay the same as the current condition in all the 7th 

field watersheds. This is due to the limited number of stream crossings associated with 

implementation of the proposed action in the Government Camp Exchange parcels and that there 

are no new stream crossing associated with implementation of the proposed action in the Cooper 

Spur parcels.

Table 44. Percent increase in the length of the stream channel due to roads

Subwatershed26 Existing Condition Proposed Action

Camp Creek 6% 6%

Little Zigzag River 1% 1%

Crystal Springs 7% 7%

Tilly Jane Creek 13% 13%

East Fork Hood River 12% 12%

East Fork Hood River Lower 5% 5%

Impacts associated with the proposed action with respect to stream drainage network extension 

would be the same as those described in the existing condition.

The effects of vegetation removal through harvest and roads are considered independent from 

each other and they are roughly additive so they should be integrated when assessing 

management effects on peak streamflows within a watershed (LaMarche and Lettenmaier 2001).

Since the impacts of vegetative removal though harvest and roads, as assessed by the Aggregate 

Recovery Percentage model and the stream drainage network extension model at the 7th field 

watershed scale, are essentially the same as those described in the existing condition the 

integrated impacts would be considered to be the same as those described in the existing 

condition (summarized below).

All of the subwatersheds, except Tilly Jane Creek, are below the threshold of concern from “The 

Effects of Forest Practices on Peak Flows and Consequent Channel Response Report” (Grant et 

al. 2008). All the subwatersheds are below the threshold associated with the methodology for 

addressing cumulative watershed effects, watershed sensitivity, and hydrologic recovery 

associated with the Mt. Hood Forest Plan (USDA 1990a). When the combined impacts of 

vegetation management and roads are examined, all the subwatersheds are rated as properly 

functioning in the 6th Field Watershed Condition from the “Northwest Forest Plan–The First 20 

Years (1994-2013) Watershed Condition Status and Trend Report” (Miller et al. 2015).

Tilly Jane Creek watershed is above the threshold of concern from “The Effects of Forest 

Practices on Peak Flows and Consequent Channel Response Report” (Grant et al. 2008) due to 

vegetation loss from the Gnarl Ridge fire. However, indications of major increased peak flows 

such as channel bed instability or scour and channel bank erosion were not noted during field 

visits to Tilly Jane Creek just below the burned area (USDA Forest Service 2016).

 26 Values for Crystal Springs, Tilly Jane Creek, East Fork Hood River, and East Fork Hood River Lower are from the 

Polallie Cooper Hazardous Fuels Reduction Project Draft Environmental Assessment (USDA Forest Service 2016) 

and based on 350-foot spacing (the midpoint between the 200-foot and 500-foot culvert spacing values)
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

196

Resource Indicator and Measure: Base Streamflows- Water Rights

Water rights for the project were examined by 7th field watershed or in the case of Camp Creek a 

smaller watershed to focus in on the project area

Table 45. Water rights summary

Area Acres Water Rights D50 Low-Flow27

Camp Creek 441 4.56 cubic feet per second (cfs) 2.26 cfs

Little Zigzag River 2,735 0.002 cfs 16.1 cfs

Crystal Springs Creek 1,881 7.16 cfs 5.41 cfs

Tilly Jane Creek 2,860 0.89 cfs 14.9 cfs

Both Camp Creek and Crystal Springs Creek have more water rights than the predicted 50th 

percentile annual low flow. However after further examination of the Camp Creek water rights it 

appears that out of the 4.56 cfs of water rights, 1.56 are for consumptive uses; so it appears that 

Camp Creek is not over allocated.

The Government Camp water system is an unmetered, spring-fed, gravity system. Average 

demand, peak demand, and pumping capacity figures are unavailable. It has been estimated that 

the current spring collection system produces a flow of about 720,000 gallons per day (gpd) 

(approximately 1.11 cfs). The Government Camp Water Company has the right to appropriate up 

to 969,475 gpd (approximately 1.5 cfs) (Oregon PUC 2002). The 20000 Master Plan for the 

Government Camp Water Company (citation) estimates daily water demand at 129,250 gpd 

(0.20 cfs). 

Assuming that there would be approximately 250 additional residences in the Government Camp 

land exchange parcels associated with implementation of the proposed action and that the 

average American family of four uses 400 gallons of water per day 

(https://www3.epa.gov/watersense/pubs/indoor.html) this would result in an additional demand 

on the Government Camp Water system of 100,000 gallons per day or 0.15 cfs per day.

This is consistent with the 2000 Master Plan for the Government Camp Water Company 

(citation); “Based on existing and projected populations for the Government Camp community 

and assuming that the water supply facilities should be capable of delivering the maximum daily 

flow over a 24-hour period, the existing water supply need is 91 gallons per minute (gpm) (0.20 

cfs) and the year 2020 water supply need is 247 gpm (0.55 cfs). The estimated water supply 

available from the existing spring collection system is approximately 500 gpm (1.11 cfs). This 

indicates that the capacity of the existing spring source and spring collection system is sufficient 

to meet existing and projected year 2020 water supply needs.”

The Government Camp Water Company has the water rights to 1.5 cfs and it is estimated that the 

current spring collection system produces 1.1 cfs; so it appears that there is adequate water 

available and that the implementation of the proposed action will not impact base streamflows in 

Camp Creek where there is an estimated 2.26 cfs for the D50 event.

Based on the Oregon Water Resources Department output, as with the existing condition there is 

no water available in Camp Creek at the confluence with the Zigzag River in July, August, 

September, October or November.

 27 Computed from USGS Oregon Streamstats site
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

197

There is a small stream network that is associated with the overflow from the Government Camp 

Water Companies 100,000-gallon water tank located in the eastern parcel of the Government 

Camp conveyance. One of the forks of this stream network supplies water to a wetland in the 

parcel. The current 100,000 gallon tank was installed in the early 1980s (Wentzl email); 

however, it is unclear if this stream network existed prior to the installation of the water tank.

Drawings of the water system prior to the installation of the 100,000-gallon water tank indicate 

that the stream from the spring that supplies water to Government Camp Water Company flowed 

on the surface to a water supply pond in very close proximity to the current water tank that 

appears to feed the same stream network that the water tank does.

Figure 32. Government Camp conveyance eastern parcel stream network created from overflow of 

100,000 gallon water tank (OR DSL 2007)
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

198

Figure 33. Overflow outlet of 100,000-gallon water tank

It is unclear how the proposed action may impact the stream network and associated wetlands 

that are currently supplied water from the overflow from the tank.

Based on the proposed action there would be no additional water demand in the Cooper Spur 

parcels.

Resource Indicator and Measure: Water Quality- Stream Temperature

The proposed action proposes to remove vegetation that is adjacent to streams. Vegetation 

removal near water bodies has the potential of increasing solar radiation to surface water which 

in turn may increase water temperature. Utilizing tools contained within the NW Forest Plan 

Temperature TMDL Implementation Strategies: Evaluation of the Northwest Forest Plan Aquatic 

Conservation Strategy (ACS) and Associated Tools (USDA Forest Service 2012) necessary 

vegetation that is providing shade so that stream temperatures within treatment areas will not 

increase as a result of the proposed vegetation treatments is identified. The previously mentioned 

document is the result of work between the USFS and the BLM and identifies how to maintain 

sufficient stream shading to meet the Clean Water Act Water Quality Objectives while providing 

the opportunity to treat Riparian Reserve vegetation to improve riparian conditions. The State of 

Oregon DEQ conditionally approved the Strategy in September 2005, as the temperature TMDL 

implementation mechanism under the CWA. 

The concept of the sufficiency analysis associated with the “Northwest Forest Plan (NWFP) 

Temperature TMDL Implementation Strategies: Evaluation of the Northwest Forest Plan Aquatic 

Conservation Strategy (ACS) and Associated Tools” (USDA Forest Service 2012) is to maintain 

a primary shade zone of vegetation next to the stream and identify a secondary shade zone and 

other areas within the Riparian Reserves further away from the stream that can be treated to 

reach Riparian Reserve Objectives while maintaining stream temperatures. In order to maintain 

sufficient shade next to the stream, the primary shade zone is untreated. The size of this zone is 

dependent on the current height of the trees and the associated hill slope gradient. This 

relationship is shown in the table below.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

199

Table 46. Width of primary shade zone (feet) based on slope (percent) and tree height (average 

height of stand in feet). Widths are measured by slope distance.

Tree Height Hill Slope <30% Hill Slope 30 to 60% Hillslope >60% 

Trees < 20 feet 12 feet 14 feet 15 feet

Trees 20 to 60 feet 28 feet 33 feet 55 feet

Trees >60 to 100 feet 50 feet 55 feet 60 feet

Trees >100 to 140 feet 70 feet 75 feet 85 feet

For the Government Camp conveyance, there are two perennial streams either in or adjacent to 

the eastern parcel and there is one perennial stream on the western end of the western parcel. 

Based on vegetation databases developed by the Landscape Ecology, Modeling, Mapping and 

Analysis (LEMMA) group at the USFS Pacific Northwest Research Station and Oregon State 

University, which is based on 2012 imagery, the tallest trees adjacent to the streams in the 

eastern land exchange parcel are approximately 90 feet tall and the hill slope gradient is less than 

30 percent. Based on the width of the primary shade zone table, a 50-foot buffer would be 

adequate to protect the primary shade zone. Based on Clackamas County zoning ordinances for 

River and Stream Conservation Areas, the buffer on the eastern most stream in the eastern parcel 

would be 70 feet and the other stream would have a 50-foot buffer (with essentially a 70-foot 

buffer in the parcel due to the streams location and adjacent wetlands). These buffers would 

protect the primary shade zone.

The tallest trees adjacent to the stream in the western parcel are approximately 80 feet tall and 

the hill slope gradient is less than 30 percent. Based on the width of the primary shade zone 

table, a 50-foot buffer would be adequate to protect the primary shade zone. If the perennial 

stream in the western parcel does not have a stream buffer based on Clackamas County zoning 

ordinance for River and Stream Conservation Areas, in most but not all cases the adjacent 

wetlands would provide a 50-foot buffer. 

With respect to smaller streams, relative to temperature effects, non-fish-bearing streams tend to 

be narrow channels in steeper constrained valleys. Near-stream vegetation and topographic 

features often shade the entire channel in such settings. In addition, water temperatures in 

headwater streams are strongly influenced by in-channel substrate (Reeves et al. 2016).

The perennial stream in the western parcel outside of the area zoned as buffer was assessed with 

Oregon Department of Environmental Qualities Shade-a-lator model (Boyd and Kasper 2003) 

for changes in effective shade (a measure of the percentage of total daily direct beam solar 

radiation that is blocked by vegetation or topography before reaching the stream surface) 

associated with implementation of the proposed action. Associated with the juxtaposition of the 

stream and the wetlands in this area, it was assumed that there would be no development on the 

east side of the stream. The model results indicated a reduction in effective shade from 

95 percent to 72 percent in this area. 

Due to the reduction in effective shade, there may be some slight increase in stream temperature 

in the 700-foot reach of stream in the land exchange parcel; however, where this stream joins 

Camp Creek, it is 7 percent of the flow of Camp Creek (based on NetMap stream reach data). 

Downstream at the closest stream temperature point associated with the NorWest dataset, the 

estimated 7-day average of the daily maximum stream temperature is 10.7 °C with the summer 

stream temperature standard in this area at 16 °C. The slight increase in stream temperature 

within the land exchange parcel is not expected to impact stream temperature downstream at the 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

200

closest point assessed by the NorWest dataset or potentially cause the stream to exceed stream 

temperature standards in this area.

Resource Indicator and Measure: Riparian Shading and Habitat- Aquatic and Riparian 

Effectiveness Monitoring Program

Riparian conditions play a key role in a number of aquatic processes, including the effect of 

shading on stream temperatures, roots on bank stability, and the provision of habitat for a 

number of species. The AREMP model rates the condition of these processes using the average 

of two indicators: riparian vegetation condition and riparian road density (Miller et al. 2015). 

Associated with the development of the residential district in the Government Camp parcel there 

would be the loss of approximately 46 acres of Riparian Reserves (wetlands and stream 

conservation areas totaling approximately 12 acres would be established under Clackamas 

County zoning). There are approximately 7,272 acres of riparian reserves in the Zigzag Canyon 

6th field watershed, so the loss of riparian reserves of 46 acres is 0.6 percent of the total acreage 

of Riparian Reserves and would not be expected to change the current rating from properly 

functioning to functioning at risk. 

Resource Indicator and Measure: Sediment Production and Delivery- Aquatic and 

Riparian Effectiveness Monitoring Program

High rates of sediment delivery to streams from episodic mass wasting events such as landslides 

and erosion have been shown to have detrimental effects on salmonids and other aquatic biota. 

Natural rates for these processes are determined by a variety of factors, including slope, 

concavity, soils, geology, geomorphology, and precipitation. Within the range of the northern 

spotted owl, Federal forest management affects these rates primarily through road and vegetation 

disturbances. To evaluate the process of sedimentation production and transport, the AREMP 

model used the difference between an estimated background rate of sediment delivery and the 

rate estimated given the status of road and vegetation disturbances (Miller et al. 2015). 

Under the proposed action, the only areas with road and vegetation disturbances are the 

Government Camp land exchange parcels where a residential district with associated 

infrastructure including roads would be built. Based on landslide risk from the forestwide map of 

landslide risk that was compiled in 2000, from the geomorphic mapping completed during 

watershed analysis (USDA Forest Service 2003) the Government Camp land exchange parcels 

are in an area classified as low landslide risk. Since there would be limited development 

associated with the proposed action and it is in an area of low landslide risk, it is assumed that 

the sediment production and delivery factor would remain the same as the existing condition.

For this analysis sediment delivery associated with natural background levels from landslides, 

wildfires, road surfaces, highway sanding and land use were examined.

Sediment delivery associated with natural background levels from landslides is expected to 

remain the same as that described in the existing condition because there are no earth disturbing 

activities in the high landslide risk or areas that drain directly into these areas (other than an 

approximately 600-foot section of Camp Creek approximately 150 feet upstream of the 

confluence of Camp Creek and the Zigzag River).

Sediment yield from wildfires is also expected to remain the same as that described for the 

existing condition.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

201

Resource Indicator and Measure: Hydrologic Sediment Production and Delivery- Roads

GRAIP-Lite is used to quantify road-related sediment production and delivery. It requires a road 

layer embedded within a GIS. In NetMap, the road layer is integrated within a digital landscape. 

GRAIP-Lite requires calibration datasets to calculate road erosion and they are included in 

NetMap’s GRAIP interface (NetMap Tools Technical Help Guide). 

Presentation of the GRAIP-Lite model results are intended to provide a means of comparing 

existing conditions with the proposed action in which both existing and proposed actions utilize 

the same assumptions and to give a comparison in broad terms of natural to management related 

sediment yields within the project area.

As with the Washington Road Surface Erosion Model (Dubé et al. 2004) it is appropriate to look 

at the relative differences in erosion estimates when comparing watershed areas or road 

segments, but the sediment values in tons per year should always be regarded as estimates not 

absolute values. 

Any predicted runoff or erosion value—by any model—will be, at best, within plus or minus 

50 percent of the true value. Erosion rates are highly variable, and the models predict only a 

single value. Replicated research has shown that observed erosion values vary widely for 

identical plots, and for the same plot from year to year (Elliot et al. 2000).

Table 47. Estimated sediment yield from the existing road system

7th Field Watershed

Estimated tons of Sediment 

Delivery per year from the existing 

road system road surface erosion

Estimated tons of Sediment Delivery 

per year from the proposed road 

system road surface erosion

Camp Creek 42.4 42.8

Little Zigzag 2.8 3.1

Crystal Springs 37.9 37.9

East Fork Hood River 36.0 36.0

East Fork Hood River 

(Lower Reach)

10.5 10.5

Tilly Jane Creek 20.3 20.3

Table 48. Estimated changes in sediment yield from roads associated with the proposed action

Analysis 

Watershed

Proposed Action Change from No 

Action (tons/year)

Proposed Action Percent Change 

from No Action

Camp Creek 0.4 1%

Little Zigzag 0.3 11%

Crystal Springs 0 0%

East Fork Hood 

River

0 0%

East Fork Hood 

River (Lower Reach)

0 0%

Tilly Jane Creek 0 0%
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

202

Resource Indicator and Measure: Sediment Production and Delivery- Land Use

Changes in land use associated with the residential district with associated infrastructure 

including roads in the Government Camp land exchange parcels was used in GeoWEPP to 

determine any changes in average annual sediment output from the watershed outlet. 

As with the Washington Road Surface Erosion Model (Dubé et al. 2004) it is appropriate to look 

at the relative differences in erosion estimates when comparing watershed areas, but the 

sediment values in tons per year should always be regarded as estimates not absolute values. 

Any predicted runoff or erosion value—by any model—will be, at best, within plus or minus 

50 percent of the true value. Erosion rates are highly variable, and the models predict only a 

single value. Replicated research has shown that observed erosion values vary widely for 

identical plots, and for the same plot from year to year (Elliot et al. 2000).

Table 49. Average annual sediment discharge from outlet associated with land use

Modeled Area Acres

Existing Condition Average 

annual sediment discharge 

from outlet (tons/year)

Proposed Action Average 

annual sediment 

discharge from outlet 

(tons/year)

Camp Creek Catchment 1 481.7 151.8 177.9

Camp Creek Catchment 2 14.0 1.1 24.3

Camp Creel Catchment 3 10.3 0.4 20.8

Camp Creek Total 506 153.3 223.0

Unnamed Tributary to Little 

Zigzag River Catchment 1

96.4 22.8 28.8

Unnamed Tributary to Little 

Zigzag River Catchment 2

8.7 0.4 6.9

Little Zigzag Total 105.1 23.3 35.7

Table 50. Estimated changes in sediment yield from land use associated with the proposed action

Modeled Area

Change in annual sediment 

discharge from outlet (tons/year) 

associated with the proposed 

action

Percent change in annual 

sediment discharge from 

outlet associated with the 

proposed action

Camp Creek Catchment 1 26.1 17%

Camp Creek Catchment 2 23.2 2,109%

Camp Creel Catchment 3 20.4 5,100%

Camp Creek Total 69.7 45%

Unnamed Tributary to Little 

Zigzag River Catchment 1

6 26%

Unnamed Tributary to Little 

Zigzag River Catchment 2

6.5 1,625%

Little Zigzag Total 12.4 53%
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

203

Sediment Production and Delivery Summary

The table below compares all quantified sources of sediment that were estimated (these comparisons should only be used in a broad sense to 

understand the differences in scale between the different sources). 

Table 51. Sediment yield

Analysis 

Watershed

Estimated Natural 

Background from 

Slides 

(tons per year)28

Estimated tons of 

Sediment Delivery 

per year from 

highway sanding

Estimated tons of 

Sediment Delivery 

per year from the 

existing road system

Estimated Increase in 

Sediment Yield from roads 

associated with 

implementation of the 

proposed action

(tons per year)

Estimated Increase in 

Sediment Yield from land use 

associated with 

implementation of the 

proposed action 

(tons per year)

Camp Creek 504 2,102 42.4 0.4 69.7

Little Zigzag 0 406 2.8 0.3 12.4

Crystal Springs 7 37.9 0 0

East Fork Hood 

River

773 36.0 0 0

East Fork Hood 

River (Lower Reach)

596 10.5 0 0

Tilly Jane Creek 140 20.3 0 0

 28 Assumes 1.2 tons per cubic yard (the same ratio as was used for the 36 Pit Fire Burned Area Report)
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

204

Table 52. Comparison of background sediment yield to sediment yield associated with the proposed action

Analysis 

Watershed

Estimated Sediment 

Yield Current 

Condition 

(landslides, highway 

sanding, and roads)

Increased sediment yield from 

changes in the road network 

and land use associated with 

implementation of the 

proposed action

Percent increase in sediment 

yield from changes in the 

road network and land use 

associated with 

implementation

Camp Creek 2,648 70.1 3%

Little Zigzag 409 12.7 3%

Crystal Springs 45 0 0%

East Fork Hood 

River

809 0 0%

East Fork Hood 

River (Lower 

Reach)

607 0 0%

Tilly Jane Creek 161 0 0%

Implementation of the proposed action would result in a 3 percent increase in sediment yield from 

background levels in both the Camp Creek and Little Zigzag 7th field watersheds. The increase in 

sediment yield will be used to assess water quality limited 303(d) streams and in-channel fine sediment 

levels.

Resource Indicator and Measure: Water Quality- Water Quality Limited 303(d) Streams

Little Zigzag Canyon (Little Zigzag River) from river mile 0 to 5.5 and East Fork Hood River from river 

mile 0 to 27.4 are 303(d) listed for biocriteria (waters of the state must be of sufficient quality to support 

aquatic species without detrimental changes in the resident biological communities). The biocriteria is 

based on macroinvertebrate communities in Oregon’s perennial, wadeable streams.

The text below is from “Monitoring Guidelines To Evaluate Effects Of Forestry Activities On Streams In 

The Pacific Northwest And Alaska” (MacDonald et al. 1991).

The effects of forest activities on macroinvertebrate communities vary. Increases in the riparian 

canopy opening or the amount of organic material in the streams generally enhance aquatic insect 

populations. An increase in fine sediment usually has the opposite effect. Removing the riparian 

canopy decreases the input of terrestrial organic material and the number of detritivores. 

However, this decline often is overwhelmed by the corresponding increase in primary production 

and herbivorous insects. Several studies have documented an increase in primary productivity 

after partial or complete removal of the riparian canopy. However, no increase was found in 

Carnation Creek in coastal British Columbia, where phosphorus was found to be the limiting 

factor. Logging-induced increases in aquatic insects have been observed in northern California 

and the Oregon Cascades. While logging activities may increase total abundance, species 

diversity is usually reduced.

Invertebrate communities also are affected by management practices on forest lands. Buffer strips 

30 meters wide appeared to protect in vertebrate communities from logging induced changes, but 

buffer strips 10 meters wide still resulted in a decrease in detrital inputs and macroinvertebrate 

densities. The net effect of logging on aquatic macroinvertebrates depends on the relative balance 

among all the controlling factors.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

205

For the Little Zigzag River peak flows at the 7th field level assessed with WildCat5, ARP, stream channel 

network extension, and the AREMP hydrologic processes indicator are all at a level where there were no 

adverse impacts that would result in bank erosion, channel scour, channel widening, and sedimentation. 

With respect to base streamflows there are no impacts anticipated from water withdrawals in the 7th field 

watershed. Stream temperatures are expected to remain at current levels. Sediment generation associated 

with the proposed action have the potential to impact the Little Zigzag River. Integrating the potential 

impacts to peak streamflows, base streamflows, temperature and sediment it is anticipated that the 

macroinvertebrate community as assessed by Oregon Department of Environmental Qualities PREDictive 

Assessment Tool for Oregon would remain in the same range as the existing condition or be slightly 

degraded because water quality conditions are anticipated to stay at the current levels or be slightly 

degraded.

The proposed action in the Cooper Spur parcels is not anticipated to have an impact on peak streamflows, 

base streamflows, temperature or sediment. Since there are no impacts anticipated to channel form or 

structure, stream temperature or sediment associated with implementation of the proposed action in the 

Cooper Spur parcel, it is anticipated that the macroinvertebrate community, as assessed by Oregon 

Department of Environmental Qualities PREDictive Assessment Tool for Oregon, would remain in the 

same range as the existing condition in the East Fork of Hood River.

Resource Indicator and Measure: Sediment- In-Channel Fine Sediment Levels

The table below details stream segments with fine sediment concerns and if the stream segment has the 

potential to be impacted by implementation of the proposed action. Both Camp Creek and Little Zigzag 

River have sediment inputs that may impact in channel fine sediment levels. Camp Creek has a potential 

of 70 tons per year delivery of sediment to the stream system in reach 8. Due to the existing high levels of 

sediment input into Camp Creek associated with highway sanding (2,102 tons per year) it is assumed that 

stream segments that are currently impacted will remain impacted and that the reaches that are not 

impacted will remain in that state because they most likely have high sediment transport capacity. Camp 

Creek reaches 2 and 5 that currently have lower levels of in-channel fine sediment are both classified as 

Rosgen B3a stream types (Rosgen 1996). The B3 stream types are moderately entrenched systems with 

channel gradients of 2 to 4 percent. B3 stream types are typically developed in very coarse alluvial fans, 

lag deposits from stabilized slide debris, rock- fall, talus, and very coarse colluvial deposits and 

structurally controlled drainage ways. The channel bed morphology is dominated by cobble materials and 

characterized by a series of rapids with irregular spaced scour pools. The channel materials are composed 

primarily of cobble with a few boulders, lesser amounts of gravel and sand. B3a stream types meet the 

criteria of a B3 channel, however, the stream gradient is greater than 4 percent. B3 stream types are 

characterized with a low sensitivity to disturbance (including increases in streamflow magnitude and 

timing and/or sediment increases). In the case of Camp Creek, it appears that the gradient greater than 

4 percent is helpful in transporting the fine sediments through these stream reaches.

Currently, reach 1 of the Little Zigzag River is not at a level where fine sediment is a concern based on 

the 6-millimeter threshold from Bjorn and Reiser in Meehan 1991 or the 2-millimeter threshold associated 

with the Mt. Hood Land and Resource Management Plan standards. The subcatchment that is generating 

the most sediment (6.5 tons per year out of the total 12.5 tons per year) flows through two wetland 

complexes before it reaches the Little Zigzag River, so it is assumed that the 6.5 tons of sediment from 

this subcatchment would be deposited in the wetlands and not make it to the Little Zigzag River. Using 

the stream gradient associated with NetMap, there are no depositional reaches (stream reaches with less 

than a 2 percent gradient) between the catchment and reach 1 of the Little Zigzag River, so there is 

potential for additional fine sediment deposition in this reach that would cause fine sediment levels to 

exceed the 6-millimeter threshold from Bjorn and Reiser in Meehan 1991.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

206

Table 53. In-channel fine sediment levels in surveyed streams

Stream Reach Year 

Surveyed

% Less 

than 2 mm

% Less 

than 6 mm

Potential to be impacted by Project 

(reach is in or downstream of 

project activities)

Camp Creek Reach 1 2011 14 16 Yes

Camp Creek Reach 2 2011 8 11 Yes

Camp Creek Reach 3 2011 22 22 Yes

Camp Creek Reach 4 2011 23 23 Yes

Camp Creek Reach 5 2011 3 3 Yes

Camp Creek Reach 6 2011 26 26 Yes

Camp Creek Reach 7 2011 23 25 Yes

Camp Creek Reach 8 2011 55 78 Yes

Little Zigzag River Reach 1 2000 13 17 Yes

Little Zigzag River Reach 2 2000 20 26 No

Little Zigzag River Reach 3 2000 22 26 No

Tilly Jane Creek Reach 1 1997 23 25 Yes

Tilly Jane Creek Reach 2 1997 58 61 No

Tilly Jane Creek Reach 3 1997 23 26 No

Doe Creek Reach 1 1997 26 32 Yes

Doe Creek Reach 2 1997 58 61 Yes

Doe Creek Reach 3 1997 45 57 No

Doe Creek Trib. Reach 1 1997 49 68 Yes

Doe Creek Trib. Reach 2 1997 22 27 No

Crystal Springs Crk Reach 1 2003 32 33 Yes
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

207

Table 54. Resource indicators and measures for the proposed alternative Government Camp Parcels

Resource Element Resource Indicator Measure Area Analyzed No Action Proposed 

Action

Watershed Condition Upslope/Riparian 

Condition

AREMP29 6th Field Watershed 

Assessment

Zigzag Canyon 6th field 

watershed

Functioning 

at Risk

Functioning 

at Risk

Water Quality, Riparian 

and Channel Function and 

Watershed Function

Water yield Peak 

Streamflows

AREMP 6th Field Watershed 

Assessment

Zigzag Canyon 6th field 

watershed

Properly 

Functioning

Properly 

Functioning

Water Quality, Riparian 

and Channel Function and 

Watershed Function

Water yield Peak 

Streamflows

2-year 244hour storm event 

streamflow

Camp Creek 7th field watershed 323 323

Little Zigzag 7th field watershed 296 318

Water Quality, Riparian 

and Channel Function and 

Watershed Function

Water yield Peak 

Streamflows

Aggregate Recovery Percentage Camp Creek 7th field watershed 89 88

Little Zigzag 7th field watershed 98 97

Water Quality, Riparian 

and Channel Function and 

Watershed Function

Water yield Peak 

Streamflows

Road Drainage Stream Network 

Enhancement

Camp Creek 7th field watershed 6% 6%

Little Zigzag 7th field watershed 1% 1%

Water Quality, Riparian 

and Channel Function and 

Watershed Function

Water yield –base 

streamflows

Are more water rights allocated that 

than the D50 lowflow

Camp Creek subcatchment Yes Yes

Little Zigzag 7th field watershed No No

Water Quality Overall Water quality Water quality limited streams Camp Creek 7th field watershed 0 0

Little Zigzag 7th field watershed 5.5 5.5

Water Quality Stream Temperature Stream temperature. Compliance 

with State standard

Camp Creek 7th field watershed Yes Yes

Little Zigzag 7th field watershed Yes Yes

Water Quality Sediment delivery land 

use

Tons per year delivered Camp Creek 7th field watershed 153.3 223

Little Zigzag 7th field watershed 23.3 35.7

Water Quality Sediment delivery 

roads

Tons per year delivered Camp Creek 7th field watershed 42.4 42.8

Little Zigzag 7th field watershed 2.8 3.1

Water Quality Sediment In channel fine sediment levels. 

Number of stream reaches that 

exceed threshold

Camp Creek 7th field watershed 5 5

Little Zigzag 7th field watershed 2 2

Water Quality Riparian Processes 

Indicator

AREMP 6th Field Watershed 

Assessment

Zigzag Canyon 6th field 

watershed

Properly 

Functioning

Properly 

Functioning

 29 The NW Forest Plan watershed monitoring module (also known as the Aquatic and Riparian Effectiveness Monitoring Program or AREMP)
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

208

Table 55. Resource indicators and measures for the proposed action alternative Cooper Spur Parcels

Resource Element Resource 

Indicator Measure Area Analyzed No Action Proposed 

Action

Watershed Condition Upslope/Riparian 

Condition

AREMP30 6th Field 

Watershed Assessment

Middle East Fork Hood River 6th Field Watershed Functioning 

at Risk

Functioning at 

Risk

Water Quality, Riparian 

and Channel Function and 

Watershed Function

Water yield Peak 

Streamflows

AREMP 6th Field 

Watershed Assessment

Middle East Fork Hood River 6th Field Watershed Properly 

Functioning

Properly 

Functioning

Water Quality, Riparian 

and Channel Function and 

Watershed Function

Water yield Peak 

Streamflows

2-year 24-hour storm 

event streamflow

Not assessed

Water Quality, Riparian 

and Channel Function and 

Watershed Function

Water yield Peak 

Streamflows

Aggregate Recovery 

Percentage 

Crystal Springs 7th field watershed 91 91

Tilly Jane Creek 7th field watershed 69 69

E Fork Hood River 7th field watershed 93 93

E Fork Hood River Lower 7th field watershed 93 93

Water Quality, Riparian 

and Channel Function and 

Watershed Function

Water yield Peak 

Streamflows

Road Drainage Stream 

Network Enhancement

Crystal Springs 7th field watershed 7% 7%

Tilly Jane Creek 7th field watershed 13% 13%

E Fork Hood River 7th field watershed 12% 12%

E Fork Hood River Lower 7th field watershed 5% 5%

Water Quality, Riparian 

and Channel Function and 

Watershed Function

Water yield –

base streamflows

Are more water rights 

allocated that than the 

D50 lowflow

Crystal Springs 7th field watershed Yes Yes

Tilly Jane Creek 7th field watershed No No

E Fork Hood River 7th field watershed No No

E Fork Hood River Lower 7th field watershed No No

Water Quality Overall Water 

quality

Water quality limited 

streams (miles)

Crystal Springs 7th field watershed 0 0

Tilly Jane Creek 7th field watershed 0 0

E Fork Hood River 7th field watershed 6.4 6.4

E Fork Hood River Lower 7th field watershed 3.4 3.4

Water Quality Stream 

Temperature

Stream temperature. 

Compliance with State 

standards

Crystal Springs 7th field watershed Yes Yes

Tilly Jane Creek 7th field watershed Yes Yes

E Fork Hood River 7th field watershed Yes Yes

E Fork Hood River Lower 7th field watershed Yes Yes

 30 The NW Forest Plan watershed monitoring module (also known as the Aquatic and Riparian Effectiveness Monitoring Program or AREMP)
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

209

Resource Element Resource 

Indicator Measure Area Analyzed No Action Proposed 

Action

Water Quality Sediment 

delivery land use

Tons per year delivered Not assessed

Water Quality Sediment 

delivery roads

Tons per year delivered Crystal Springs 7th field watershed 37.9 37.9

Tilly Jane Creek 7th field watershed 36.0 36.0

E Fork Hood River 7th field watershed 10.5 10.5

E Fork Hood River Lower 7th field watershed 20.3 20.3

Water Quality Sediment In channel fine sediment 

levels. Number of stream 

reaches

Crystal Springs 7th field watershed 1 1

Tilly Jane Creek 7th field watershed 6 6

E Fork Hood River 7th field watershed Not 

assessed

Not assessed

E Fork Hood River Lower 7th field watershed Not 

assessed

Not assessed

Water Quality Riparian 

Processes 

Indicator

AREMP 6th Field 

Watershed Assessment

Middle East Fork Hood River 6th Field Watershed Functioning 

at Risk

Functioning at 

Risk
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

210

Proposed Action with Wetland Conservation Easements 

The 2009 Omnibus Act prescribed as a mandatory condition to the land exchange that the Forest Service reserve wetland and trail easements on 

the Federal parcels to be exchanged. More specifically, the Omnibus Act required the Forest Service to reserve a conservation easement on the 

Federal land to protect existing wetlands, as identified by the Oregon Department of State Lands that allows equivalent wetland mitigation 

measures to compensate for minor wetland encroachments necessary for the orderly development of that land following the exchange. The 

Clarification Act (which is now the Proposed Action) changed this provision from “shall reserve” to “may mutually agree to reserve.” Table 56

details the ratings for the resource elements at the 7th field watershed scale for no action, proposed action and an alternative that includes the 

wetland conservation easements. The Cooper Spur parcels were not assessed because the wetland conservation easements would have no effect on 

those parcels. The only resource element that is different between the proposed action and the wetland conservation easement alternatives at the 

7th field watershed scale is the sediment delivery associated with land use. Implementation of the proposed action would result in an estimated 

3 percent increase in sediment yield in the Camp Creek and Little Zigzag 7th field watersheds and implementation of the wetland conservation 

easement alternative would result in an estimated 2 percent increase in sediment yield in the Camp Creek and Little Zigzag 7th field watersheds. 

Table 56. Resource indicators and measures for the proposed alternative Government Camp Parcels

Resource Element Resource 

Indicator Measure Area Analyzed No Action Proposed 

Action

Wetland 

Conservation 

Easements

Watershed Condition Upslope/Riparian 

Condition

AREMP31 6th Field 

Watershed 

Assessment

Zigzag Canyon 6th field watershed Functioning 

at Risk

Functioning 

at Risk

Functioning at 

Risk

Water Quality, Riparian 

and Channel Function and 

Watershed Function

Water yield Peak 

Streamflows

AREMP 6th Field 

Watershed 

Assessment

Zigzag Canyon 6th field watershed Properly 

Functioning

Properly 

Functioning

Properly 

Functioning

Water Quality, Riparian 

and Channel Function and 

Watershed Function

Water yield Peak 

Streamflows

2-year 24-hour 

storm event 

streamflow

Camp Creek 7th field watershed 323 323 323

Little Zigzag 7th field watershed 296 318 318

Water Quality, Riparian 

and Channel Function and 

Watershed Function

Water yield Peak 

Streamflows

Aggregate Recovery 

Percentage 

Camp Creek 7th field watershed 89 88 88

Little Zigzag 7th field watershed 98 97 97

Water Quality, Riparian 

and Channel Function and 

Watershed Function

Water yield Peak 

Streamflows

Road Drainage 

Stream Network 

Enhancement

Camp Creek 7th field watershed 6% 6% 6%

Little Zigzag 7th field watershed 1% 1% 1%

Water Quality, Riparian 

and Channel Function and 

Watershed Function

Water yield –base 

streamflows

Are more water 

rights allocated that 

than the D50 lowflow

Camp Creek subcatchment Yes Yes Yes

Little Zigzag 7th field watershed No No No

 31 The NW Forest Plan watershed monitoring module (also known as the Aquatic and Riparian Effectiveness Monitoring Program or AREMP)
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

211

Resource Element Resource 

Indicator Measure Area Analyzed No Action Proposed 

Action

Wetland 

Conservation 

Easements

Water Quality Overall Water 

quality

Water quality limited 

streams

Camp Creek 7th field watershed 0 0 0

Little Zigzag 7th field watershed 5.5 5.5 5.5

Water Quality Stream 

Temperature

Stream temperature. 

Compliance with 

State standard

Camp Creek 7th field watershed Yes Yes Yes

Little Zigzag 7th field watershed Yes Yes Yes

Water Quality Sediment delivery 

land use

Tons per year 

delivered 

Camp Creek 7th field watershed 153.3 223 218

Little Zigzag 7th field watershed 23.3 35.7 29.8

Water Quality Sediment delivery 

roads

Tons per year 

delivered 

Camp Creek 7th field watershed 42.4 42.8 42.8

Little Zigzag 7th field watershed 2.8 3.1 3.1

Water Quality Sediment In channel fine 

sediment levels. 

Number of stream 

reaches that exceed 

threshold

Camp Creek 7th field watershed 5 5 5

Little Zigzag 7th field watershed 2 2 2

Water Quality Riparian 

Processes 

Indicator

AREMP 6th Field 

Watershed 

Assessment

Zigzag Canyon 6th field watershed Properly 

Functioning

Properly 

Functioning

Properly 

Functioning
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

212

At the scale of the analysis areas used for Wildcat5 streamflow modeling and the catchments 

used for GeoWEPP sediment modeling there are some differences in peak streamflows and 

sediment yield between implementation of the proposed action and implementation of the 

proposed action with wetland conservation easements.

WildCat5 modeling of peak streamflows associated with the 2-year 24-hour precipitation event 

indicates that there is no difference between analysis areas between the proposed action and 

implementation of the proposed action with wetland conservation easements, except for the 

unnamed tributary to Little Zigzag River at confluence with Little Zigzag River where there is a 

55 percent increase in peak streamflows under the proposed action and a 39 percent increase in 

peak streamflows when wetland conservation easements are added.

Table 57. Predicted peak streamflow for the 2-year 24-hour precipitation event with and without 

wetland conservation easements

Analysis Area Acres

Peak 

Streamflow 

(cubic feet per 

second) 

Existing 

Condition

Peak 

Streamflow 

(cubic feet per 

second) 

Proposed 

Action

Peak Streamflow 

(cubic feet per 

second) Proposed 

Action with Wetland 

Conservation 

Easements

Camp Creek at Highway 26 441 23.8 28.9 28.9

Camp Creek at Yocum Falls 2,073 109.5 121.1 121.1

Camp Creek 7th Field 5,992 322.7 322.7 322.7

Unnamed Tributary to Little 

Zigzag River below Enid 

Lake

196 7.1 12.3 12.3

Unnamed Tributary to Little 

Zigzag River at confluence 

with Little Zigzag River

301 11.9 18.4 16.6

Little Zigzag 7th Field 2,735 295.7 318.0 318.0

Zigzag River at Lady Creek 6,403 721.4 721.4 721.4

Table 58. Percent change in the predicted Peak Streamflow for the 2-year 24-hour precipitation 

event with and without wetland conservation easements

Analysis Area

Percent Change 

Associated with 

Implementation of the 

Proposed Action

Percent Change Associated 

with Implementation of the 

Proposed Action with 

Wetland Conservation 

Easements

Camp Creek at Highway 26 21% 21%

Camp Creek at Yocum Falls 11% 11%

Camp Creek 7th Field 0% 0%

Unnamed Tributary to Little Zigzag 

River below Enid Lake

73% 73%

Unnamed Tributary to Little Zigzag 

River at confluence with Little Zigzag 

River

55% 39%

Little Zigzag 7th Field 8% 8%

Zigzag River at Lady Creek 0% 0%
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

213

GeoWEPP modeling of average annual sediment output from the watershed outlet indicates 

slight differences in sediment output when conservation easements are added in the Camp Creek 

catchments and larger differences in the Little Zigzag River catchments associated with unnamed 

tributary to Little Zigzag River catchment 1 where there is a 26 percent increase in sediment 

yield under the proposed action and no increase in sediment yield when the conservation 

easements are added to the proposed action.

Table 59. Average annual sediment discharge from outlet with and without wetland conservation 

easements

Modeled Area Acres

Existing 

Condition 

Average annual 

sediment 

discharge from 

outlet 

(tons/year)

Proposed 

Action Average

annual 

sediment 

discharge from 

outlet 

(tons/year)

Proposed Action 

with wetland 

conservation 

easements average 

annual sediment 

discharge from 

outlet (tons/year)

Camp Creek Catchment 1 481.7 151.8 177.9 173.4

Camp Creek Catchment 2 14.0 1.1 24.3 24.3

Camp Creel Catchment 3 10.3 0.4 20.8 20.8

Camp Creek Total 506 153.3 223.0 218.5

Unnamed Tributary to Little 

Zigzag River Catchment 1

96.4 22.8 28.8 22.8

Unnamed Tributary to Little 

Zigzag River Catchment 2

8.7 0.4 6.9 6.9

Little Zigzag Total 105.1 23.3 35.7 29.8

Table 60. Percent change in average annual sediment discharge from outlet with and without 

wetland conservation easements

Modeled Area Percent change 

with the 

proposed action

Percent change with the 

proposed action with wetland 

conservation easements

Camp Creek Catchment 1 17% 14%

Camp Creek Catchment 2 2,109% 2,109%

Camp Creel Catchment 3 5,100% 5,100%

Camp Creek Total 45% 43%

Unnamed Tributary to Little Zigzag River 

Catchment 1

26% 0%

Unnamed Tributary to Little Zigzag River 

Catchment 2

1,625% 1,625%

Little Zigzag Total; 53% 28%

The major difference between the proposed action and the wetland conservation easements 

alternative is that currently reach 1 of the Little Zigzag River is not at a level where fine 

sediment is a concern based on the 6-millimeter threshold from Bjorn and Reiser in Meehan 

1991 or the 2-millimeter threshold associated with the Mt. Hood Forest Plan standards. Under 

the wetland conservation easement alternative, it is assumed it would remain that way because 

the subcatchment that is generating sediment under this alternative flows through 2 wetland 

complexes before it reaches the Little Zigzag River, so it is assumed that the sediment from this 

subcatchment would be deposited in the wetlands and not make it to the Little Zigzag River. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

214

Forest Plan Amendment Summary

A forest plan amendment is required to assign land use allocations to the acquired lands, and 

change the land use allocations for the new Tilly Jane Wilderness Addition and Crystal Springs 

Watershed Special Resource Management Unit.

The land use allocation for the acquired Cooper Spurs parcels would be Crystal Springs 

Watershed Special Resource Management Unit. Existing allocations for the Tilly Jane 

Wilderness Addition and the Crystal Springs Watershed Special Resource Management Unit are 

detailed in the tables below.

Tilly Jane Wilderness Addition

Current Mt. Hood Land and Resource Management Plan Dominant 

Allocation

Acres

Winter Recreation Area (A11) 1,109

Special Interest Area, Cloud Cap-Tilly Jane Historic District (A4) 492

Scenic Viewshed (B2) 108

Crystal Springs Watershed Special Resource Management Unit

Current Mt. Hood Land and Resource Management Plan Dominant 

Allocation

Acres

Winter Recreation Area (A11) 236

Special Interest Area, Cloud Cap-Tilly Jane Historic District (A4) 660

Scenic Viewshed (B2) 1,160

Timber Emphasis (C1) 34

The purposes of the Crystal Springs Watershed Special Resources Management Unit are to 

ensure the protection of the quality and quantity of the Crystal Springs watershed as a clean 

drinking water source for the residents of Hood River County, Oregon; and to allow visitors to 

enjoy the special scenic, natural, cultural, and wildlife values of the Crystal Springs watershed.

The goal of the lands in the Tilly Jane Wilderness Addition is to promote, perpetuate and 

preserve the wilderness character of the land; protect watersheds and wildlife habitat; preserve 

scenic and historic resources; and promote scientific research, primitive recreation, solitude, 

physical and mental challenge, and inspiration (forest plan, page 4-136).

Changing from land management allocations where watershed protection is not one of the 

primary goals to the new allocations where watershed protection is the primary or one of the 

primary goals would provide for the protection of water quantity and water quality in these areas.

Cumulative Effects

According to the Council on Environmental Quality's (CEQ) regulations for implementing 

NEPA, an action may cause cumulative impacts on the environment if its effects overlap in space 

and/or time with the effects of other past, present, or reasonably foreseeable future actions, 

regardless of what agency or person undertakes the action. Cumulative effects can result from 

individually minor, but collectively significant actions, taking place over a period of time (FERC 

2006).
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

215

The Government Camp – Cooper Spur Land Exchange proposed action includes the conveyance 

of two parcels totaling approximately 109 acres of NFS lands currently within the Forest that are 

adjacent to Government Camp in exchange for the acquisition of approximately 769 acres of 

land owned by Mt. Hood Meadows Oregon, LLC. In this analysis, the parcels are referred to as 

the Government Camp parcel and the Cooper Spur parcel. There were no direct or indirect 

effects identified with the proposed action in the Cooper Spur parcel so cumulative effects in that 

area were not assessed.

The Government Camp parcel includes project activities in the Zigzag Canyon subwatershed 

(6th field watershed) and the Camp Creek and Little Zigzag River 7th field watersheds. The 7th 

field watersheds were selected as the area to assess cumulative effects. The boundaries for the 

cumulative effects analysis areas should be far enough downstream that direct effects from the 

Government Camp – Cooper Spur Land Exchange project would not likely be measurable. 

The time frame used to include or exclude actions varies by the type of action. Some impacts are 

considered permanent with no modeled recovery including permanent roads, quarries and the 

power line right-of way. Some impacts such as regeneration harvest would recover gradually 

over approximately 35 years. 

Table 61 provides a qualitative summary of potential cumulative watershed effects. It shows 

existing and potential projects, effects from those projects that may result in cumulative effects 

with the Government Camp – Cooper Spur Land Exchange Project, whether these projects 

overlap in time and space and a brief description of expected impacts from the project. Findings 

of this summary are supported by the analysis which utilizes pertinent research, design features 

and applicable management standards and guidelines.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

216

Table 61. Cumulative Effects Summary for Hydrology

Project Potential Effects Overlap in

Extent,

Detectable?

Time Space

Mirror Lake Trailhead 

Relocation and 

Connector Trail

Sediment Yes Yes The new trailhead is located outside the riparian reserves and designed to address 

storm water from the newly created impervious surfaces (less than 1 acre) with catch 

basins and sediment traps so there is no sediment delivery anticipated with the new 

trailhead and parking lot. The new connector trail crosses Camp Creek and 9 tributaries 

to Camp Creek and there will be channel spanning bridges at all the crossings, 

however the trail surface has potential to deliver sediment to Camp Creek and the 9 

tributaries. Impacts would be at the site scale.

Stream

Temperature

Yes Yes The new trailhead is located outside the riparian reserves and is not expected to impact 

stream shade. The stream crossings with bridges of Camp Creek and the 9 tributaries 

will require some vegetation removal, however the removal of understory vegetation is 

not expected to impact stream shade. There is no expected increase in width/depth 

ratios for heavily used streamside recreation sites because of the bridges.

Water Quantity Yes Yes No effects anticipated associated with this activity

ODOT Highway 26 

Safety Widening Project

Coarse and Fine

Sediment

Yes Yes Ongoing work adjacent to Camp Creek and the small tributary to Camp Creek in the 

vicinity of Mirror Lake trailhead has the potential to directly delivery small amounts of 

sediment to the stream system at the site scale.

Stream

Temperature

Yes Yes A small intermittent tributary to Camp Creek has been rerouted and in the process is 

exposed to solar radiation and there is the potential for increased stream temperatures 

at the site scale. 

Water Quantity Yes Yes No effects anticipated associated with this activity

Ongoing ODOT road 

maintenance, including 

snowplowing on NFS 

lands, Government 

Camp, and Highway 26

Coarse and Fine

Sediment

Yes Yes Highway 26 is directly adjacent to and runs parallel to Camp Creek in this area. There 

is the potential for sediment delivery from highway sanding (both through the ditch lines 

and direct delivery through snowmelt and snowplows). The 1996 Zigzag Watershed 

Analysis (USDA Forest Service 1996) estimated highway sanding to deliver 2,102 tons 

per year of sediment to Camp Creek.

Stream

Temperature

Yes Yes Road brushing is ongoing adjacent to Camp Creek in this area, however topographic 

shading prevents any increases in intercepted solar radiation.

Water Quantity Yes Yes There is the potential for increased peak streamflows associated with the impervious 

highway surface directly routing runoff into Camp Creek
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

217

Project Potential Effects Overlap in

Extent,

Detectable?

Time Space

Skibowl and Summit ski 

areas winter recreation 

activities, operation and 

maintenance

Coarse and Fine

Sediment

Yes Yes Ski run clearing, slope grading, and developing access routes, ski lift and towline 

facilities, ski lodges and infrastructure and similar actions can expose and compact 

soils, resulting in accelerated runoff and erosion. Increased runoff can increase 

instream sediment from channel erosion (USDA Forest Service 2012a). Impacts would 

be at the site scale.

Stream

Temperature

Yes Yes Historical clearing for ski runs and hazard tree removal in riparian areas and increased 

width/depth ratios associated with accelerated runoff and erosion have the potential to 

increase stream water temperatures at the scale of the stream reach.

Water Quantity Yes Yes Changes in land use and impervious surfaces can alter temporarily or permanently 

storm water runoff resulting in increased peak streamflows (USDA Forest Service 

2012a). Created openings associated with ski runs were assessed with ARP.

Skibowl and Summit ski 

areas summer recreation 

activities, operation and 

maintenance (such as 

bike parks, bike trails, 

equestrian use, bike race 

events and concerts)

Coarse and Fine

Sediment

Yes Yes Trail construction, maintenance, and use by bicycles, humans, or stock can adversely 

affect water quality by increased sediment delivery. Compaction of the trail surface 

limits water infiltration, which can lead to concentrated runoff on the trail surface.

Concentrated runoff on trails lacking adequate drainage causes erosion of the trail 

surface and can transport sediment and other pollutants directly into waterbodies if not 

filtered. Heavy tread, foot, or hoof traffic can loosen some trail surface materials, 

making them more susceptible to erosion (USDA Forest Service 2012a). Impacts would 

be at the site scale. 

Stream

Temperature

Yes Yes Hazard tree removal in riparian areas and increased width/depth ratios associated with 

accelerated runoff and erosion have the potential to increase stream water 

temperatures at the scale of the stream reach.

Water Quantity Yes Yes Where roads and trails are in-sloped to a ditch, the drainage network can become 

extended, collecting surface water from the road and trails tread and in places 

intercepting subsurface water exposed by cut slopes, potentially transporting this water 

more rapidly to the drainage network than the norm. However, the number of road 

stream intercepts in this area is not expected to have an impact on peak streamflows.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

218

Project Potential Effects Overlap in

Extent,

Detectable?

Time Space

Skibowl Ski Area 

Snowmaking 

Infrastructure 

Improvements Project 

(water withdrawal from 

Camp Creek

Coarse and Fine

Sediment

Yes Yes The construction, operations and maintenance associated with the snowmaking 

infrastructure improvements at Skibowl are not expected to have any impact on coarse 

and fine sediment delivery to the stream system.

Stream

Temperature

Yes Yes This additional water in spring runoff from snow created from snowmaking may result in 

cooler water during the snowmelt season at the site scale.

Water Quantity Yes Yes This additional water from the snowmaking could melt in a rain on snow event 

impacting peak streamflows.

Timberline Ski Area 

Mountain Bike Trails and 

Skills Park Project, 

including watershed 

restoration activities

Coarse and Fine

Sediment

Yes Yes Trail construction, maintenance, and use by bicycles can adversely affect water quality 

by increased sediment delivery. Compaction of the trail surface limits water infiltration, 

which can lead to concentrated runoff on the trail surface. Concentrated runoff on trails 

lacking adequate drainage causes erosion of the trail surface and can transport 

sediment and other pollutants directly into waterbodies if not filtered. Heavy bike traffic 

can loosen some trail surface materials, making them more susceptible to erosion 

(USDA Forest Service 2012a).

Stream

Temperature

Yes Yes There are no impacts anticipated from this activity.

Water Quantity Yes Yes Where roads and trails are in-sloped to a ditch, the drainage network can become 

extended, collecting surface water from the trails tread and in places intercepting 

subsurface water exposed by cut slopes, potentially transporting this water more rapidly 

to the drainage network than the norm. However, the number of road stream intercepts 

in this area is not expected to have an impact on peak streamflows.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

219

Project Potential Effects Overlap in

Extent,

Detectable?

Time Space

Government Camp 

Sewer Treatment Plant 

Operations and 

Maintenance

Coarse and Fine

Sediment

Yes Yes Under a National Pollutant Discharge Elimination System (NPDES) permit, treated 

wastewater is discharged to Camp Creek. The outfall is a single port diffuser with a sixinch orifice located in a shallow rapidly moving section of Camp Creek. The outfall 

location is about a mile above Yocum Falls. Monthly average flow measurement in 

Camp Creek upstream of the discharge location ranged from 6 cfs (September 2001) to 

24 cfs (June 2002). Under design flow, this facility would discharge about 0.5 cfs. 

Current plant discharge flow has been measured at <0.4 cfs (0.17 cfs in September 

2008 and 0.36 cfs in June 2008) (Oregon DEQ 2008)). There are no impacts to coarse 

and fine sediment anticipated.

Stream

Temperature

Yes Yes The site has a maximum effluent temperature of 20.8 °C and a waste load allocation of 

2.91x 106 kilocalories per day (Oregon DEQ 2005)). This would have an impact on 

stream temperature at the site scale.

Water Quantity Yes Yes There are no impacts anticipated from this activity.

Government Camp 

Water Company 

Operations and 

Maintenance

Coarse and Fine

Sediment

Yes Yes The intake is at a spring collection site that is stable so there are no impacts anticipated 

to coarse and fine sediment.

Stream

Temperature

Yes Yes The removal of 0.1 cfs out of the 1.1 cfs produced at the spring collection site is not 

anticipated to have an impact on stream temperature.

Water Quantity Yes Yes There is a slight impact on base streamflows that is assessed in the direct and indirect 

effects section for this project.

Mazama Lodge Parking 

Area Expansion Project

Coarse and Fine

Sediment

Yes Yes Runoff from these areas can create rills or gullies and carry sediments to nearby 

surface waters (USDA Forest Service 2012a).

Stream

Temperature

Yes Yes There are no impacts to stream temperature anticipated.

Water Quantity Yes Yes This area is small enough (~0.5 acre) so there are no impacts to peak streamflow 

anticipated associated with runoff from the impervious surface.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

220

Project Potential Effects Overlap in

Extent,

Detectable?

Time Space

Forest Service 

Recreational 

Residences-Camp Creek 

Tract

Coarse and Fine

Sediment

Yes Yes User trails for the recreational residences to access Camp Creek and picnic and 

campfire sites adjacent to the stream have the potential to create bank erosion and 

deliver sediment from the disturbed areas adjacent to the stream. Impacts would be at 

the site scale.

Stream

Temperature

Yes Yes Falling of hazard trees may open the canopy along the stream and subject the stream 

to increased solar radiation. Typically, the number of trees that need falling at any 

particular site is small (often only 1-2). Due to the scattered location of summer homes, 

and because tree falling only occurs sporadically, the effect of this activity will often be 

negligible (USDA Forest Service and USDI BLM 2008).

Water Quantity Yes Yes There are no impacts anticipated

Operation and

maintenance of Kiwanis 

Camp

Coarse and Fine

Sediment

Yes Yes Developed areas adjacent to the Little Zigzag River including the ropes course have the 

potential to create bank erosion and deliver sediment for the disturbed areas adjacent 

to the stream.

Stream

Temperature

Yes Yes Falling of hazard trees and parking lot development has removed vegetation along the 

Little Zigzag River, however is does not appear to be at the level where stream shade 

is impacted.

Water Quantity Yes Yes There are no impacts anticipated.

Hazard Trees Coarse and Fine

Sediment

Yes Yes There may be very small amounts of sediment delivered to the stream system over 

widely scattered areas associated with deposition of fine sediment into road ditch lines 

that are connected to the stream system during storm events (2011 Programmatic). 

Stream

Temperature

Yes Yes Reductions of stream shade are reasonably certain to occur in a small number of areas 

scattered throughout the action area where multiple shade-producing trees are 

removed within 150 feet of a perennial stream, causing minor increases in water 

temperatures at the reach scale (2011 Programmatic)

Water Quantity Yes Yes Hazard trees are widely scattered so their removal would not impact ARP values 

because canopy cover of stands would not be impacted.

Ongoing Road 

Maintenance Activities 

Coarse and Fine

Sediment

Yes Yes Associated with this activity localized, short-lived increases in fine sediment in stream 

substrates or along channel margins may occur. However, proper road maintenance is 

likely to reduce chronic sediment inputs from roads over the long term (NMFS 2011). 

Stream

Temperature

Yes Yes With road maintenance activities there are potential increases in stream temperature 

widely scattered over time and space associated with road brushing (NMFS 2011). 

Water Quantity Yes Yes No effects anticipated associated with this activity.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

221

Project Potential Effects Overlap in

Extent,

Detectable?

Time Space

PGE Powerline Corridor 

Maintenance

Coarse and Fine

Sediment

Yes Yes There is the potential for widely scattered and small amounts of sediment to be 

delivered to the stream system associated with the use of secondary roads and 

powerline pole maintenance and replacement (NMFS 2011) 

Stream

Temperature

Yes Yes There is the potential to raise average and maximum stream temperatures for short 

reaches of streams associated with vegetation removal (NMFS 2011).

Water Quantity Yes Yes No effects anticipated associated with this project. The powerline corridor is maintained 

in an early seral condition impacting ARP values and is assessed in the ARP analyses.

Recreation Site, Trail, 

and Administrative 

Structure Maintenance 

and Associated Public 

Use

Coarse and Fine

Sediment

Yes Yes The heavy use of certain recreation sites along streambanks is likely to result in 

significant bank erosion, delivery of sediment, and increased channel width (NMFS 

2011). Impacts would be at the site scale.

Stream

Temperature

Yes Yes Depending on site specific conditions, the combination of suppressed vegetation and 

increased width/depth ratios for heavily used streamside recreation sites are likely to 

increase stream water temperatures for heavily used stream sides at the scale of the 

stream reach (NMFS 2011). 

Water Quantity Yes Yes No effects anticipated associated with this activity.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

222

Cumulative Effects – Water Quantity

The Mt. Hood Forest Plan states under standard FW-066 that “Cumulative effects analyses of 

management activities on water quality and/or stream channel stability (e.g., watershed impact 

analyses) shall include lands in all ownerships within the watershed” so that is the focus of this 

analysis.

The 7th field watersheds used earlier in the document are used as the analysis area for 

cumulative effects. 

The time frame used to include or exclude actions varies by the type of action. Some impacts are 

considered permanent with no modeled recovery including permanent roads, quarries and the 

power line right-of way. Some impacts such as regeneration harvest would recover gradually 

over approximately 35 years. 

Harvest that has occurred on private land is included. Foreseeable future projects were listed in 

the activities with potential cumulative effects summary table earlier in this section. While there 

may be future logging or other management within the watershed, there are no current proposals 

with sufficient site specificity to conduct an analysis. 

Past disturbances within the action area are the most substantial contribution to cumulative 

effects, and include fires, timber harvest, road construction and private land development. 

The following table details the cumulative recovery of all stands in the watershed combined with 

the cumulative impact of all actions that have affected hydrologic recovery. It is a weighted 

average of the modeled recovery status of thousands of stands. 

Table 62. Hydrologic recovery proposed action32

Subwatershed Hydrologic Recovery

Camp Creek33 88

Little Zigzag River 97

Crystal Springs 91

Tilly Jane Creek 69

East Fork Hood River 93

East Fork Hood River Lower 93

The slight changes in ARP associated with the project would not likely cause any additional 

changes in stream channel stability or increases in peak flows beyond those described for the 

existing condition. 

The following discussion summarizes the material from the existing condition and direct and 

indirect effects section from this document.

 32 ARP values for Crystal Springs, Tilly Jane Creek, East Fork Hood River, and East Fork Hood River Lower are from 

the Polallie Cooper Hazardous Fuels Reduction Project Environmental Assessment (USDA Forest Service 2016). 33 The ARP values for Camp Creek and Little Zigzag River were calculated for the year 2018. For the analysis it was 

assumed that the project would be implemented in 2018.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

223

All of the subwatersheds, except Tilly Jane Creek, are below the threshold of concern from “The 

Effects of Forest Practices on Peak Flows and Consequent Channel Response Report” (Grant et 

al. 2008). All the subwatersheds are below the threshold associated with the methodology for 

addressing cumulative watershed effects, watershed sensitivity, and hydrologic recovery 

associated with the Mt. Hood Forest Plan (USDA Forest Service 1990a). When the combined 

impacts of vegetation management and roads are examined, all the subwatersheds are rated as 

properly functioning in the 6th Field Watershed Condition from the “Northwest Forest Plan–The 

First 20 Years (1994-2013) Watershed Condition Status and Trend Report” (Miller et al. 2015).

Tilly Jane Creek watershed is above the threshold of concern from “The Effects of Forest 

Practices on Peak Flows and Consequent Channel Response Report” (Grant 2008) due to 

vegetation loss from the Gnarl Ridge fire. However, indications of major increased peak flows 

such as channel bed instability or scour and channel bank erosion were not noted during field 

visits to Tilly Jane Creek just below the burned area (USDA Forest Service 2016).

ODOT Highway 26 operations and maintenance, Skibowl snowmaking activities, and 

Timberline Bike Park construction and maintenance all have the potential to cause increases to 

peak streamflows at the site scale. These activities would be dispersed in time and space. No 

detrimental cumulative effects to peak streamflows are expected as a result of activities within 

the cumulative effects analysis area. Project design features associated with all activities are 

aimed at controlling impacts to peak streamflows.

Stream Temperature 

Activities associated with the Government Camp – Cooper Spur Land Exchange Project are not 

expected to increase water temperature outside the land exchange parcels. As described in the 

direct and indirect effects section, this project would maintain existing water temperatures 

outside the land exchange parcels. 

ODOT Highway 26 safety widening, Skibowl and Summit ski areas winter and summer 

recreation activities, operation and maintenance, Government Camp sewer treatment plant 

operations and maintenance, hazard tree removal, ongoing road maintenance activities, PGE 

powerline corridor maintenance, recreation site maintenance and use, all have to potential to 

impact stream shade and associated stream temperature. However, these activities would be 

dispersed in time and space and all these activities would have water quality protection Best 

Management Practices in place to control impacts to stream temperature. No detrimental 

cumulative effects to stream temperature are expected as a result of activities within the 

cumulative effects analysis area. Project design features associated with all activities are aimed 

at controlling impacts to stream temperature.

Sediment

Implementation of the proposed action would result in an estimated 3 percent increase in 

sediment yield over the current condition in the Camp Creek and Little Zigzag 7th field 

watersheds. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

224

Table 63. Sediment yield (estimated tons per year)

Analysis 

Watershed

Natural 

Background 

from 

Slides)34

Sediment 

Delivery 

from 

highway 

sanding

Sediment 

Delivery 

from the 

existing road 

system

Increase in 

Sediment Yield 

from roads with 

implementation 

of the proposed 

action

Increase in 

Sediment Yield 

from land use with 

implementation of 

the proposed 

action

Camp Creek 504 2,102 42.4 0.4 69.7

Little Zigzag 0 406 2.8 0.3 12.4

Mirror Lake trailhead relocation and connector trail, ODOT Highway 26 safety widening, 

Skibowl and Summit ski areas winter and summer recreation activities, operation and 

maintenance, Timberline Ski Area mountain bike trails and skills park, Mazama Lodge parking 

area expansion, recreational residences-in the Camp Creek Tract, hazard tree removal, ongoing 

road maintenance activities, PGE powerline corridor maintenance, and recreation site 

maintenance and use all have the potential to introduce small amounts of sediment that would be 

dispersed in time and space (and all these activities would have water quality protection Best 

Management Practices in place to control erosion and sedimentation). No additional detrimental 

cumulative effects to instream sediment outside of those described in the direct and indirect 

effects are expected as a result of activities within the cumulative effects analysis area. Project 

design features associated with all activities are aimed at controlling erosion and sedimentation 

reducing the potential of erosion and delivery of material to adjacent surface water.

Oregon State Drinking Water Source Areas

Amendments made in 1996 to the Federal Safe Drinking Water Act provide the means to protect 

drinking water at its source. In developing the amendments, Congress recognized the need to go 

beyond traditional emphasis on treatment to address new challenges to provide clean drinking 

water. The act’s amendments mandated that states conduct “source water assessments” for all 

public water systems. These assessments include delineating contribution zones or source areas 

for all groundwater and surface water- supplied public water systems and identifying potential 

sources of contamination for drinking water in each state. Source water assessments are required 

for all systems with at least 15 hookups or that serve more than 25 people year-round.

The process for developing a Drinking Water Protection Plan includes an Assessment Phase and 

a Protection Phase. The Assessment Phase includes delineating the area that serves as the source 

of the public water supply, inventorying the potential risks or sources of contamination and 

determining the areas most susceptible to contamination. The Assessment Phase has been 

completed. The development of a protection plan associated with the protection phase is 

voluntary and has not been completed for the Drinking Water Source Areas within the project 

area and therefore, no management guidelines or protection standards have been established.

569 acres of the Cooper Spur parcels are located in the Crystal Springs Water District Drinking 

Water Protection Area (DWPA). The entire DWPA is 4,282 acres. A source water assessment 

report was prepared by Oregon Department of Human Services and DEQ in June 2005. The 

report delineated the DWPA and identified potential risks by risk type and location. Within the 

Cooper Spur land exchange parcels there are 2 identified potential contaminant sources. The first 

potential contaminant source is in the intermediate-term recharge area and is identified as Future 

Land Development-Residential with the comment “PWS contact indicates site is under 

 34 Assumes 1.2 tons per cubic yard (the same ratio as was used for the 36 Pit Fire Burned Area Report)
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

225

consideration for development as a destination resort, including a golf course & resort village. 

PWS contact indicates concern about additional traffic on Cooper Spur Rd & the impact of 

development.” Since this area is not planned to be developed under any alternative it would 

appear that this should no longer be listed as a potential contaminant source. The other listed 

potential contaminant source is identified as “Parking Lots/Malls (over 50 spaces)” and the site 

is in the long-term recharge area. The comment for this site is “Risk Reduced to Moderate 

because Inn is located just outside of delineated DWPA.”

Table 64. Cooper Spur parcels in Crystal Springs DWPA

Zone Total Acres Acres in Cooper 

Spur Parcels

% of Area in Cooper 

Spur Parcels

Long-term recharge area (spring) 2,131 30 1%

Intermediate-term recharge area (spring) 1,752 521 30%

Short-term recharge area (spring) 399 19 5%

Figure 34. Crystal Springs drinking water source area (DWSA)
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

226

The Cooper Spur Mountain Resort transient non-community groundwater drinking water system 

is also within the Cooper Spur land exchange parcels. Seventeen of the 18 acres of the system 

are within the land exchange parcels. There are no identified potential contaminant sources 

identified for this system.

The Government Camp parcel has less than a tenth of an acre in the 18-acre DWSA for the Mt. 

Hood Inn, so this area was not assessed.

Recreation 

Introduction

Recreation did not drive the purpose and need for the project, however, the unique recreation 

environment provided by the Mt. Hood National Forest has attracted a robust recreation 

community. The settings of this recreation environment are nationally iconic as well as cherished 

by an established constituency. Recreation on the national forest has a large base.

The primary focus of the recreation analysis was qualitatively analyzing effects to the Mt. Hood 

National Forest recreation setting. The recreational setting is measured in acres of Recreation 

Opportunity Spectrum (ROS) classes. The subsequent use and management of the Government 

Camp parcels conveyed to Mt. Hood Meadows and the following connected actions were also 

analyzed:

• Trail easements held by the Mt. Hood National Forest on the Government Camp parcels to 

be conveyed, and resulting effects to Government Camp Trail System’s administration, 

opportunities, and settings

• Expansion of the Mt. Hood Wilderness by approximately 1,710 acres that would change 

existing land use allocations, and the resulting effects to recreation administration, 

opportunities, and settings; and the general change in management direction

• The creation of the Crystal Springs Watershed Special Resources Emphasis Unit that 

would change the existing land use allocations and the resulting effects to recreation 

administration, opportunities, and settings

Recreation Opportunity Spectrum

Since the early 1980s, the Recreation Opportunity Spectrum (ROS) has been used as a 

framework to identify, classify, plan, and manage a range of recreation settings for both existing 

and desired conditions. ROS is defined as land delineations that identify a variety of recreation 

experience opportunities categorized into six classes on a continuum from primitive to urban. 

Each class is defined in terms of the degree to which it satisfies certain recreation experience 

needs. This is measured based on the extent to which the natural environment has been modified, 

the type of facilities provided, the degree of outdoor skills needed to enjoy the area, and the 

relative density of recreation use. The six classes are: urban (U), rural (R), roaded natural (RN), 

semi-primitive motorized (SPM), semi-primitive non-motorized (SPNM), and primitive (P). The 

Mt. Hood Forest Plan uses the class of Roaded Modified and does not use the class of Semiprimitive Motorized. Definitions for each are:

• Primitive: Area is characterized by an essentially unmodified natural environment of 

fairly large size. Interaction between users is very low, and evidence of other users is 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

227

minimal. The area is managed to be essentially free from evidence of management 

restrictions and controls. Motorized use within the area is not permitted.

• Semi-primitive Non-motorized: Area is characterized by a predominantly natural or 

natural-appearing environment of moderate to large size. Interaction between users is low, 

but there is often evidence of other users. The area is managed in such a way that 

minimum on-site controls and restrictions may be present, but subtle. Motorized recreation 

use is not permitted, but local roads used for other resource management activities may be 

present on a limited basis. Use of such roads is restricted to minimize impacts on 

recreational experience opportunities.

• Roaded Modified: A subclass of the Roaded Natural ROS class. Involves areas that are 

characterized by predominantly natural appearing environments with high evidence of the 

sights and sounds of humans. Such evidence may not harmonize with the natural 

environment Interaction between users may be moderate to high, with evidence of other 

users prevalent. Resource modification and utilization practices are evident and may not 

harmonize with the natural environment. Conventional motorized use is allowed and 

incorporated into construction standards and design of facilities.

• Roaded Natural: Area is characterized by approximately natural-appearing environments 

with moderate evidence of the sights and sounds of man. Such evidence usually harmonize 

with the natural environment. Interaction between users may be moderate to high, and 

evidence of other users prevalent. Resource modification and utilization practices are 

evident but harmonize with the natural environment. Conventional motorized use is 

allowed and incorporated into construction standards and design of facilities.

• Rural: Area is characterized by a natural environment that has been substantially modified 

by development of structures, vegetative manipulation, or pastoral agricultural 

development. Resource modification and utilization practices may be used to enhance 

specific recreation activities and to maintain vegetative cover and soil. Sights and sounds 

of humans are readily evident, and the interaction between users is often moderate to high.

A considerable number of facilities are designed for use by a large number of people. 

Facilities are often provided for special activities. Moderate user densities are present 

away from developed sites. Facilities for intensified motorized use and parking are 

available.

• Urban: Area is characterized by a substantially urbanized environment, although the. 

Background may have natural-appearing elements. Renewable resource modification and 

utilization practices are often used to enhance specific recreation activities. Vegetative 

cover is often exotic and manicured. Sights and sounds of humans are predominant on site 

and in nearby areas. Facilities for highly intensified motor use and parking are available 

with forms of mass transit often available to carry people throughout the site.

To analyze effects of the land exchange, the primary action of the conveyance of land was 

evaluated by the gain/loss of ROS class acres. Each connected action was also analyzed for 

effects to ROS class.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

228

Affected Environment

Existing Condition

Government Camp Area

The community of Government Camp is located along Highway 26 on the south side of Mt. 

Hood. It is a key destination for both summer and winter visitors. The community has a small 

resident population that swells with seasonal visitors. Forest recreation is the major economic 

engine that sustains the community.

Government Camp Trail System

The Government Camp Trail System Area encompasses a range of recreation opportunities, from 

highly developed ski areas and lodges, to semi-primitive untrailed areas. Ski areas and lodges 

include Timberline Lodge and Ski Area, Summit Ski Area, Ski-Bowl and Multorpor Ski Areas. 

All but Summit have both winter and summer recreational activities. There are three national 

forest campgrounds in the area: Trillium Lake, Still Creek, and Alpine Campgrounds. There are 

several summer and winter trails in the project area.

Regularly groomed Nordic trails, outside of developed ski area, are limited on the Mt. Hood 

National Forest to the Teacup Lake Trail system and the Trillium Lake trails. Both areas are at 

capacity on peak weekends.

Government Camp Parcels Land Use Allocation

There are two parcels to be conveyed to private ownership, west and east. The two parcels’ land 

use allocation is primarily A11, Winter Recreation. The goal of this MA is to provide areas for 

high quality winter recreation (and associated summer) opportunities including: downhill skiing, 

Nordic skiing, snowmobiling, and snowplay within a natural-appearing forest environment.

Trail Segments Located in and near West and East Parcels

Crosstown Trail and Wally’s Tie were constructed in 1995, as a hike/bike/ski trail. They receive a 

high amount of use year-round and have held up remarkably well to mountain bikes and other 

uses.

Maggie’s Tie was constructed after the Government Camp Trails Project Environmental Analysis 

(USDA Forest Service 2005). The purpose and need of this project was to provide a safe, low 

maintenance, trail system designed for year-round recreation that links Government Camp to key 

destinations in the Mt. Hood National Forest that surround the community. The trail system and 

trailhead parking were designed to reduce conflicts with local businesses, ski areas, and 

residences. During this project, bridge crossings along the existing Crosstown Trail were 

upgraded for winter grooming to enhance Nordic skiing and snowshoeing. Grooming as an 

operation has yet to commence on the Crosstown Trail, but it is still the intent of future 

management.

The Alpine and Glade Trails were historic downhill runs from Timberline to Government Camp. 

They are also where utility lines to Timberline are located. They are used in the winter by 

downhill and telemark skiers and snowboarders; and in the summer by the more adventurous 

mountain bikers for access to Timberline Lodge. Approximately 250 feet of roadside parking 

was added along Government Camp Loop Road near Thunderhead Lodge as a part of the 2005 

Government Camp Trails Project. The Skiway Trail was constructed before 2005.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

229
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

230

Table 65. Trails with segments inside Government Camp parcels

Government 

Camp Parcel

Trails with Segments 

Located within Parcels

Trail Number Approximate Mileage 

Inside Parcels

West Parcel Skiway 755B 0.3 mi

Maggie’s Tie 753 0.25 mi

Wally’s Tie 755A 0.07 mi

East Parcel Crosstown 755 0.25 mi

Alpine 660 0.13 mi

Summit Ski Area

The east Government Camp Parcel shares a boundary with Summit Ski Area that operates under 

a special use permit.

Annual winter ski area operations range widely from zero days of operation to approximately 

40 days. The ski area opens when it has adequate snow coverage (varies annually) and closes in 

late March or early April. This schedule is dictated by the sheer fact that Summit Ski Area does 

not have snowmaking infrastructure – making it totally dependent on natural snow pack. It is 

largely a Saturday/Sunday/winter holiday operation. The day lodge has a much longer operating 

season (operations during the winter and summer months). The day lodge, which shares a 

parking lot with the Highway 26 rest area, is open outside of the winter operating schedule. It 

serves beverages and a limited menu for breakfast and lunch. 

Summit Ski Area is largely a “drop in” area for forest visitors that are new to snow sports. There 

are a limited number of special use events held annually. The ski area has a popular tubing 

program.

Many skiers climb Summit’s ski trails and descend without purchasing a lift ticket. Also, 

Timberline guests ski back to Government Camp—and ultimately ski through the Summit Ski 

Area—to get back to their vehicles.

Cooper Spur Area

A variety of recreational activities occur within the Cooper Spur area. State Highway 35 is a 

scenic byway. Cooper Spur Road, also known as Forest Road 3512, takes visitors from Highway 

35 to Cooper Spur Ski Area and Resort, and to the Cloud Cap area. Both roads offer scenic views 

and many people drive them for pleasure throughout the year. The Cloud Cap Road is one of the 

most popular roads on the Mt. Hood National Forest due to its terminus at Cloud Cap Inn, its 

access to several trails including the Timberline Trail, and the view of Mt. Hood from the top of 

the road. There are numerous trailheads for popular non-motorized trails within the planning 

area. Recreation use is popular during both the summer and the winter. Groomed snowmobile 

routes and dispersed use are also prevalent within the greater area. Due to numerous recreation 

opportunities, and proximity to the large recreation community of Hood River, recreation is 

thriving in the area.

Developed Recreation Facilities

Developed recreation sites within the Cooper Spur area include several trailheads, two 

campgrounds, five historic buildings, and the Cooper Spur Ski Area. Trailheads include Tilly 

Jane Trailhead and Snopark, and Cloud Cap Trailhead. Both trailheads are day use areas and 

primary trailheads. 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

231

Tilly Jane Trailhead and Snopark is located off of Forest Road 3512. It serves as a trailhead in 

the summer and a Snopark in the winter. Tilly Jane Snopark is plowed by the Oregon 

Department of Transportation in the winter. The trailhead provides parking as well as interpretive 

and directional signing. Tilly Jane Trail (#643) is a hiking trail in the summer and a crosscountry ski trail in the winter. The trail enters the Tilly Jane Historic District and passes several 

developed recreation facilities: Tilly Jane A-Frame, Tilly Jane Guard Station, Tilly Jane 

Campground, and Cloud Cap Campground. 

Tilly Jane A-Frame and Tilly Jane Guard Station are recreation rentals that are managed under 

special use permits with two chapters of the Oregon Nordic Club. They are historic buildings.

Tilly Jane Campground is a primitive campground providing parking, an outhouse, and 

numerous tent sites with picnic tables and fire rings. The campground is operated by a 

concessionaire. 

Cloud Cap Saddle Trailhead is located close to the top of Cloud Cap Road. It is a Northwest 

Forest Pass Trailhead providing designated parking, bulletin boards, interpretive signage, picnic 

tables, water, an outhouse, and access to trails. The site is also a concessionaire-operated day-use 

site, as it is the parking for Cloud Cap Campground as well as a trailhead and day-use site. 

Cloud Cap Campground is a primitive campground similar to Tilly Jane Campground. The 

campground operates under a concessionaire permit. Cloud Cap is smaller than Tilly Jane 

Campground, but more popular due to its proximity to the Timberline Trail. In addition to an 

outhouse and designated sites with picnic tables and fire rings, Cloud Cap Campground also has 

water. 

Cloud Cap Inn and the Snowshoe Club Cabin are located near Cloud Cap Saddle Trailhead at the 

end of Cloud Cap Road. Both historic buildings are managed by special use permits. The area 

surrounding these two buildings provides a spectacular view of the north side of Mt. Hood. 

The Cooper Spur Warming Shelter is a historic warming shelter near Forest Road 3512. The 

Shelter has been maintained in the past by the Oregon Nordic Club. A primitive trail accesses the 

hut, which is used by dispersed recreationists including hikers and cross-country skiers. 

The Cooper Spur Ski Area falls within the A11 portion of the planning area. The small ski area 

operates under a special use permit. The ski area usually sees relatively light usage during 

winters when snow levels allow it to open.

Dispersed Recreation Use

Dispersed recreation occurs throughout the project area. Activities include driving for pleasure, 

hunting, camping, rock climbing, and ski-touring. 

Driving for pleasure can occur on any open road within the area, but is most heavily 

concentrated along Highway 35, Forest Road 3512 (Cooper Spur Road), and Cloud Cap Road 

(also Forest Road 3512 after the gate adjacent to Tilly Jane Trailhead). Highway 35 is one of the 

most popular scenic routes on the Mt. Hood National Forest. The road offers spectacular views 

of Mt. Hood when driving south and beautiful views of the Hood River Valley and its many 

orchards when headed north. Motorists driving along Highway 35 can see steep, rocky canyon 

walls, the East Fork of the Hood River, hillsides with large, yellow-barked yellow pine and many 

hillsides covered with thick, dense firs. Forest Road 3512 (Cooper Spur Road) is very popular 

for drivers as well as road bikers, who enjoy the road that provides access from Highway 35 to 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

232

Parkdale, which is North of the Cooper Spur area. Cloud Cap Road accesses the Cloud Cap-Tilly 

Jane Historic Area and leads to stunning views of Mt. Hood. 

Dispersed camping occurs in various locations throughout the area. Most dispersed camping 

occurs off of secondary routes. Hunters use parts of the Cooper Spur area and use dispersed 

campsites during hunting season. 

Ski touring occurs near the Tilly Jane Trail #643, Cloud Cap Inn, and the area burned by the 

Dollar Lake Fire. These locations receive the most snowfall in the planning area and provide 

adequate slopes for people to tour up and ski down. Depending on snow levels, ski touring could 

occur in other locations within the Cooper Spur area. The area burned by the Dollar Lake Fire 

has no overstory, and receives a lot of snow most years, making some of the steeper aspects 

desirable for some skiers.

Cooper Spur Trails

System trails within the Cooper Spur Area are designed for non-motorized use. These trails are 

close to the city of Hood River and relatively close to Portland, and draw large numbers of 

visitors annually. The Tilly Jane trails are some of the most popular trails on the Hood River 

Ranger District. District trail crews maintain a portion of these trails, but they are also 

maintained by multiple volunteer groups, who assist with needs such as log out, brushing, and 

tread work.

Table 66. Cooper Spur area trails

Trail Name Trail Number Season of Use

Segments 

Within Mt. Hood 

Wilderness 

Expansion

Segments 

Within Crystal 

Springs

Tilly Jane 643 Winter and Summer Yes Yes

643A Winter and Summer Yes Yes

Wagon Road 642 Mostly Cross-country Ski in 

Winter but also Summer Use

Yes Yes

600 SPUR Winter and Summer No Yes

Timberline 600 Winter and Summer No Yes

Tilly Jane 600A Winter and Summer No Yes

In addition to the trails listed above, groomed snowmobile routes are located within the Cooper 

Spur area. These routes are roads in the summer, but become part of a system of snowmobile 

trails during the winter. Snowmobiles are permitted for cross-country travel on National Forest 

System lands, except where they are specifically prohibited, such as within wilderness areas. 

Within the Cooper Spur area, snowmobiles are not permitted off road in the Tilly Jane Cloud 

Cap Historic District. 

User-created trails are also found in locations within the Cooper Spur area, especially in areas 

bordering private homes. These trails are not condoned or maintained by the Forest Service, but 

they are a method some individuals use to access the Forest.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

233

Wild and Scenic Rivers

East Fork Hood River is a designated wild and scenic river that flows northeast of the Cooper 

Spur area. The Omnibus Public Land Management Act of 2009 designated 13.5 miles of the river 

from State Highway 35 to the Mt. Hood National Forest boundary. This Wild and Scenic River 

corridor is administered by the Secretary of Agriculture as a recreational river. Under the Forest 

Plan, this land is designated as B1 – Designated Wild, Scenic, and Recreational Rivers lands. 

The goal for B1 lands is to protect and enhance the resource values for which a river was 

designated into the Wild and Scenic River System, to provide opportunities for recreation 

activities, and to maintain the visual quality of river corridors. 

Designated Wild and Scenic Rivers are evaluated to identify and protect their outstanding and 

remarkable values (ORVs). Geologic/Hydrologic ORVs have been identified for East Fork Hood 

River. The East Fork flows along the edge of a complex series of glacially and fluvial derived 

deposits before entering a narrower bedrock canyon. Recent debris flows from Newton, Clark, 

and Polallie Creek drainages continue to shape the valley floor and influence the river’s freeflowing nature. These attributes are deemed ORVs because they are an easily observable 

example of active glacial and geologic processes at the national level.

Special Use Permits

There are several recreation-related special use permits issued within the planning area. Tilly 

Jane A-Frame, Cloud Cap Inn, the Snowshoe Club Cabin and the concessionaire campgrounds 

were mentioned under Developed Recreation Facilities. 

Cooper Spur Ski Area

The Cooper Spur Ski Area operates under a special use permit that is currently set to expire at 

the end of 2021. Its 3-year average skier days is 4,666 per year. Its 10-year average is 9,681 per 

year. Its season of operation is solely winter. Its operating calendar is dependent on snow 

coverage and typically closes the day after spring break (late March). The number of days it is 

open fluctuates annually between 0 and 60. Some drought years it has not opened.

The current area permitted by the special use permit is 1,172 acres. There are 20 skiable acres.

The ski area’s origins dates back to the 1920s, and historically had a ski jumping program. Now, 

it is a “feeder area.” It functions as a learning area for people to ski/snowboard. When Cooper 

Spur customers outgrow the area (it only has 350 feet of vertical), skiers are fed into larger ski 

areas. It is a beginner’s hill, but also has limited intermediate terrain for parents and older 

siblings. It has a night skiing program, but typically only on Friday and Saturday nights in 

January and February. Other ski areas on Mt. Hood also offer night skiing.

It annually hosts special use events such as ski race events and various community celebrations 

(small in numbers and limited by the size of the parking facility).

The Cooper Spur Race Team is affiliated with the Cooper Spur Ski Area. The winter sports 

portion of the team probably averages between 50 and 65 children. The mountain bike program 

is smaller. See www.cooperspurraceteam.org for information about the team. Founded in 1978, 

the organization supports alpine, freeride, and mountain bike programs. In 2010, 

freestyle/freeride and mountain biking was added to the program. It attracts children from the 

mid-Columbia Gorge region (Cascade Locks to The Dalles and White Salmon to Parkdale). It is 

largely a volunteer-operated organization (coaches and parents). When Cooper Spur isn’t 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

234

operational, the program operates from Mt. Hood Meadows. The team is open for children from 

5 to 18 years of age.

Cooper Spur Parcels

The lands to be acquired include approximately 251 acres located within and 514 acres outside 

of the current NFS administrative boundary. Three diverse property types comprise the nonFederal estate situated in the vicinity of the Cooper Spur Ski Area on the northeast flank of Mt. 

Hood. The three types are: the structures and personal property at the Cooper Ski Area, land and 

all development at the Cooper Spur Mountain Resort, and mostly vacant forest land. As the 

underlying land at the ski area is already federally owned and administered, only the following 

described infrastructure is considered in the estate to be conveyed: ski lifts, a day lodge, A-frame 

cabin, first-aid station, four multi-purpose buildings, instructor's hut, and pump house. There is 

also a private well water system, irrigation system, and septic system.

The Cooper Spur Mountain Resort is located about 2 miles east of the Cooper Spur Ski Area at 

the intersection of Cooper Spur and Cloud Cap roads. The resort site consists of 11 different 

structures. The registration desk portion of the restaurant building and the Homestead Cabin 

were built in 1942. The restaurant addition and all other structures were added in 1985–1986. 

Also, there are five 1,200-square-foot log cabins, each with a kitchen area, living room and 

fireplace, two bedrooms and one bath on the main floor. The resort also includes spas, storage, 

tennis court, equipment storage and shop, and a single-family residence. 

In addition to the cabins and restaurant, there are several septic tanks that lead to a single leach 

field northeast of the improvements. A well with well house and another small building are 

located on Tax Lot 401. Another recently installed well is located on Tax Lot 102.

The remaining property contains a mixture of pre-merchantable plantations covering about 

60 percent of the area with the balance in second-growth timber stands. The plantations range 

from approximately 10 to over 25 years old—composed of mixed species including both planted 

and naturally regenerated Douglas-fir , ponderosa pine, white fir, western hemlock, western 

white pine and lodge pole pine. Timber stands contain merchantable trees dominated by 

Douglas-fir and white fir mixed with trace amounts of western red cedar, western white pine and 

western hemlock.

Recreation Opportunities provided by the resort include but are not limited to the following:

• Gathering of People

• Special Events

• Modest sized trail system for hiking, mountain biking and cross-country skiing

• Spa

• Tennis Courts

• Weight Room

• Swimming Pool

Crystal Springs Watershed Special Resources Management Unit Land Use Allocation 

The Crystal Springs Watershed Special Resource Management Unit would be composed of 

769 acres of the lands to be acquired and an additional 2,090 NFS acres that are currently in the 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

235

A4, A11, B2, and C1 land use allocations (LUAs). The Omnibus Act states that the purposes of 

the Crystal Springs Watershed Special Resource Management Unit are to ensure the protection 

of the quality and quantity of the Crystal Springs watershed as a clean drinking water source for 

the residents of Hood River County, Oregon; and, to allow visitors to enjoy the special scenic, 

natural, cultural, and wildlife values of the Crystal Springs watershed.

Mt. Hood Wilderness Expansion Land Use Allocation

Approximately 1,709 acres would be incorporated in, and considered to be a part of, the Mt. 

Hood Wilderness, as designated under the Wilderness Act (16 U.S.C.1132(a)). As a result, 492 

acres of the A4 LUA, 1,109 acres of the A11 LUA, and 108 acres of the B2 LUA would become 

Wilderness (A2 LUA).

Recreation Opportunity Spectrum (ROS) Class

Both the east and west parcels of the lands to be conveyed (Government Camp) are currently 

classified as Rural. 

The Cooper Spur Parcels are currently classified as a mix of Roaded Natural and Roaded 

Modified.

The area to be newly designated as Mt. Hood Wilderness is currently classified as Roaded 

Natural on the northern boundary, adjacent to the Cloud Cap Road and Cooper Spur Ski Area. 

The remainder of the area, to the south, is classified as Semi-primitive Non-motorized.

The area to be designated the Crystal Springs Watershed Special Resources Management Unit is 

currently a mix of Roaded Natural and Roaded Modified.

Environmental Consequences

Direct and Indirect Effects

The spatial boundaries for analyzing the direct and indirect effects to recreation are the 

Government Camp parcels and Government Camp Trail System, and, the combined Crystal 

Springs watershed protection area and wilderness addition because these areas are predicted be 

most affected by the proposed action.

The temporal boundaries for analyzing the direct and indirect effects are 1 to 5 years (short-term) 

and 5 to 30 years (long-term). The short-term reflects time to finalize the land exchange. The 

long-term reflects time for full build-out of the Government Camp parcels and the subsequent 

change of management of the Cooper Spur parcels.

Alternative 1

Government Camp

The ROS at the Government Camp parcels would continue to be Rural.

The Government Camp Trail System would continue to serve as a flexible network of 

high-quality trails. Trails would continue to link major community and recreation nodes of the 

Government Camp community such as Timberline Lodge and Ski Area, Summit Ski Area, SkiBowl and Multorpor Ski Areas. Trails would continue to be used for recreation and 

transportation. Trail upgrades made during the Government Camp Trails Project would continue 

to make it possible to groom select trails of the system, such as Trail # 755, Crosstown. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

236

Trails within the Government Camp parcels (segments of Crosstown, Alpine, Maggie’s Tie, 

Wally’s Tie and Skiway) would remain in their current location solely on NFS lands. The trails 

would remain connected with only existing infrastructure crossings such as utilities and roads. 

Bridge improvements made during the Government Camp Trails Project would remain in their 

current location and relevant to future potential grooming. The trailhead near Thunderhead 

Lodge would continue to provide modest parking and function as a portal for the community of 

Government Camp to access the trail network. Trails would still access semi-primitive untrailed 

areas. Administration and maintenance would continue to operate under the same regimen and 

frequency.

NFS lands (Government Camp parcels) proposed to be conveyed would continue to be managed

in compliance with the A11 LUA.

Cooper Spur Area

The ROS at the Cooper Spur parcels would remain Roaded Natural. 

The Cooper Spur Resort facilities would remain open to the public on a fee basis and located on 

private lands. The maintenance and operation of the resort facilities and equipment would 

continue to be performed by the Cooper Spur Resort owners. The maintenance and 

administration of the trail system would continue to be performed by the Cooper Spur Resort 

owners. Visitors to the resort would continue to abide by the rules and regulations of the Cooper 

Spur Resort.

The Cooper Spur Ski Area would continue to be operated by a permittee under a special use 

permit until 2021 when the permit is set to expire. Responsibility for maintenance and 

administration of ski area facilities would continue to belong to Cooper Spur Ski Area permittee 

until this time. Facilities and equipment would continue to be owned by Cooper Spur Area 

permittee.

NFS lands in the proposed Mt. Hood Wilderness Expansion would continue to be managed in 

compliance with the Mt. Hood LRMP standards and guidelines for A4, A11, B2, and A2 LUAs. 

Trails would be non-motorized and provide opportunities for mountain biking. Trail maintenance 

would continue to be facilitated by power equipment such as chainsaws. The social setting for 

trail visitors would continue to allow groups of 12 or more. The biophysical setting for trail 

visitors would continue to be in compliance with LUA Standards and Guidelines.

The ROS for NFS Lands proposed for inclusion in the Mt. Hood Wilderness would remain a mix 

of Roaded Natural and Semi-primitive Non-motorized.

NFS lands in the proposed Crystal Springs Watershed Special Resource Management Unit would 

continue to be managed in compliance with the Mt. Hood LRMP standards and guidelines for 

A4, A11, B2, and C1 LUAs.

The ROS for NFS lands proposed for the new LUA of Crystal Springs Watershed Resource 

Management Unit would continue to be Roaded Natural and Roaded Modified.

Table 67. Existing condition ROS classes for Government Camp parcels

Parcel/ Designation ROS Class Acres Total

Government Camp West Parcel Rural 68 109 acres Rural

Government Camp East Parcel Rural 41
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

237

Table 68. Existing condition ROS classes for Cooper Spur Area

Parcel/ Designation ROS Class Acres

Cooper Spur Parcels Roaded Natural 684

Roaded Modified 85

Mt. Hood Wilderness Expansion Roaded Natural 845

Semi-primitive Non-motorized 864

Roaded Natural 1,621

Crystal Springs Watershed Special Resource 

Management Unit

Roaded Modified 1,184

Semi-primitive Non-motorized 54

Alternative 2- Proposed Action

Lands to be conveyed (Government Camp)

The proposed action would have direct and indirect effects to the recreation resource in the 

Government Camp area. The primary proposed action, the land exchange, was analyzed by the 

loss and gain of acres of ROS classes. Both of the Government Camp parcels are classified as 

Rural.

A direct effect of the proposed action is the loss of 109 acres of NFS lands classified as Rural to 

the Mt. Hood National Forest.

The assumption is made that more people will be inhabiting or visiting the Government Camp 

area. An indirect effect would be an increase in demand for recreation with the increase of 

population.

Government Camp Trail System 

A direct effect of the connected action of the reservation of non-exclusive trail easements would 

be the likely change of location of the following trails that are located in the parcels proposed for 

conveyance. Only segments of the trails would be potentially relocated by the new property 

owner. The total of all trail segments subjected to a non-exclusive trail easement is 

approximately 1 mile.

Table 69. Direct effects to trail locations by proposed action

Government Camp Parcel

Trails with Segments 

Located within Parcels

Trail Number

West Parcel Skiway 755B

Maggie’s Tie 753

Wally’s Tie 755A

East Parcel Crosstown 755

Alpine 660

While trail easements would be reserved, the easements would be non-exclusive in nature. 

Meaning they could be relocated to facilitate development by the land owner. The assumption 

was made that the location of trails outside of proposed parcels would not change. Subsequently, 

this assumes that while trails may be relocated within the proposed parcels, their location would 

remain fixed at the parcel boundaries.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

238

The width of the easement would be 24 feet total or 12 feet on either side of the center line of the 

trail alignment. The width of the easement would indirectly affect the future management of the 

trail system. The intent of the Government Camp Trails Project (2009) was to increase the 

amount of groomed trail on the Mt. Hood National Forest outside of developed ski areas for 

Nordic skiing. The width of the proposed trail easement would likely be insufficient to 

accommodate the appropriate equipment for the grooming operations. Because the Government 

Camp Trail System is a connected network, changes on a part of the network can potentially 

affect the whole. If trail managers are unable to use the preferred grooming equipment on a 

portion of the network, it could potentially affect their ability elsewhere in the network.

An indirect effect is the expected loss of ability by trail managers to use the preferred equipment 

for future grooming. 

The non-exclusive nature of the proposed trail easement also renders it more likely to be 

frequently crossed by infrastructure, i.e., utilities and roads. This would directly affect the 

connectivity of the trail which affects the safety and welfare of trail users. Trail crossings would 

put trail users at risk to collisions with motor vehicles. The recommended mitigation of using 

trail underpasses at road crossings would reduce this effect.

If trails are crossed by development, an indirect effect would be the increased exposure of trail 

users to dangerous road crossings.

Exclusive Easement Option

As described in chapters 1 and 2, the trail easement aspect of the proposal has not yet been fully 

determined. Elements of an exclusive trail easement and their resultant effects are described 

below.

The connected action of the reservation of exclusive trail easement held by Mt. Hood 

National Forest. Easements allow non-motorized use of existing trails by the public; roads, 

utilities, and infrastructure facilities to cross the trails; and improvement or relocation of the 

trails to accommodate development of the Federal land. The Regional Forester reserves the right 

to terminate the right-of-way and easement if it is deemed no longer needed. Easements would 

comply by the following conditions.

• Easement shall be 16 feet on each side of the centerline with such additional width as 

required for adequate protection of cuts and fills, maintenance, and snowplowing.

• The trails shall be under the control and jurisdiction of the United State and the United 

States alone shall have the right to extend rights and privileges for use of the trails to other 

Federal departments and agencies, State agencies, and local subdivisions thereof, and to 

other users including members of the public. 

• The United States shall have the right to use motorized equipment for administrative use 

including but not limited to: trail construction, maintenance, and emergency access. 

Motorized use by the public is prohibited.

• Roads, utilities, and infrastructure facilities shall be allowed to cross the trails at any place 

by any reasonable means and for any purposes in such manner as will not interfere 

unreasonably with use of the trail.

• Improvement or relocation of the existing trails to accommodate development of the 

Federal land after conveyance shall be in such manner as will not interfere with use of the 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

239

trails and shall be subject to review and approval by the United States prior to any 

construction. Mt. Hood Meadows Oreg., LLC, its successors, heirs, and assigns 

(“Landowner”) shall bear all costs associated with such improvement or relocation of 

trails, including the cost of construction or replacement of bridges and other trail 

infrastructure necessary for trail use as determined by the Forest Service. 

• Relocated trails or portions of trails shall be subject to the same terms and conditions as 

the existing trails reserved herein. Landowner shall bear responsibility for developing legal 

descriptions and producing recordable plats for any relocated trails subject to Forest 

Service standards, review and approval. Relocated trails shall be acknowledged in the form 

of legal easements granted to the United States and shall be recorded in County records at 

landowner’s expense. The United States shall execute termination documents for those 

trails or portions of trails being abandoned due to relocation.

• The United States shall have the right to fell hazardous trees within or adjacent to the 

easement area that are deemed a safety risk by knowledgeable Forest Service personnel, 

and the right to manage vegetation within the trail easement areas, including the removal 

of those portions of downed trees lying within the easement areas, provided however that 

the landowner retains ownership of the woody material and may remove any portion in a 

manner that does not damage the trails or interfere with public use of the trails.

• The United States shall have the right to establish and maintain appropriate signage for 

marking trails and providing directions or other appropriate information in connection with 

the trails.

• The total width of the easement would be 32 feet, which would adequately allow for future 

grooming by the preferred equipment.

Cooper Spur Area

The proposed action would have direct and indirect effects to the recreation resource in the 

Cooper Spur Area. The primary proposed action, the land exchange, was analyzed by the loss 

and gain of acres of ROS classes. The Cooper Spur parcels proposed to be conveyed to the Mt. 

Hood National Forest have been classified as Roaded Natural and Roaded Modified.

A direct effect of the proposed action is the gain of 684 acres of NFS lands classified as Roaded 

Natural and 85 acres classified as Roaded Modified to the Mt. Hood National Forest. 1,708 acres 

would also be added to the Mt. Hood Wilderness.

A direct effect is the loss 1,012 acres of the permitted area under the special use permit for 

operation of the Cooper Spur Ski Area.

The reduction of the area permitted would modify the special use permit for the Cooper Spur Ski 

Area. However, the entire 1,012 acres is outside the “skiable acres” accessed by existing lift 

facilities and considered “out of bounds” in nature. This “out of bounds” area would continue to 

be accessible to adventurous back country skiers by non-motorized means (skiing).

A direct effect would be the shift of 845 acres of Roaded Natural and 865 acres of Semiprimitive Non-motorized ROS classes to more a Primitive ROS class. As management reflects 

the primitive nature of wilderness designation, the setting would be increasingly more primitive. 

Future management would also employ the Wilderness Resource Spectrum (similar to ROS), 

which is applied in Mt. Hood National Forest wilderness areas.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

240

A direct effect to recreation would be the loss of the opportunity to mountain bike in the area 

proposed as wilderness, and the gain of more opportunities for solitude and wilderness 

experience.

A direct effect would be the required use of primitive tools for maintenance on portions of trails 

listed below. A minimum tool analysis would be required for the use of power tools.

A direct effect would be that the group size of visitors to the wilderness area would have to 

comply with A2 standards and guidelines. 

A direct effect would be the prohibition of mountain bikes on portions of the Tilly Jane, Wagon 

Road and 643A trails. 

A direct effect would be the change of 1,109 acres of A11, 492 acres of A4, and 108 acres of B2 

LUAs to 1,708 acres A2 LUA (Wilderness).

The change in LUA would change how the 1,708 acres are managed. The overarching 

management goal is to promote, perpetuate, and preserve the wilderness character of the land; 

protect watersheds and wildlife habitat; preserve scenic and historic resources; and promote 

scientific research, primitive recreation, so1itude, physical and mental challenge, and inspiration.

The complete list of Goals, and Standards and Guidelines for the A2 LUA is provided in 

appendix A of the Recreation Specialist Report. Select changes in management direction relevant 

to recreation are also highlighted in that report. 

The LUA of Crystal Springs Watershed Special Resource Management Unit 

(CSWSRMU)

A direct effect to the creation of CSWSRMU would be recreation management direction that 

would comply with the newly created LUA of A14. A full list of Standards and Guidelines for 

this new LUA appears in chapter 2 of the EIS.

ROS Classes

Table 70 summarizes the gain and loss of ROS classes resulting from the land exchange.

Table 70. Comparison of acres of ROS class gained and lost

Parcels Gain/ Loss ROS Class Acres

Government Camp Parcels Loss Rural 109

Cooper Spur Parcel Gain Roaded Natural 684

Roaded Modified 85

Forest Plan Amendment Summary

The expansion of the Mt. Hood Wilderness would restrain the types of recreational outfitters and 

guides that could operate under a special use permit in this management area. Management area 

standards would preclude some uses such as the operation of bicycles. Social setting standards 

for group size would restrict the number of visitors.

The Land Use Allocation of A14 would have no changes that would alter the long-term 

relationship between levels of multiple-use goods and services. The management area would 

continue to provide the spectrum of recreational opportunities as the no action alternative.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

241

The expansion of the Mount Hood Wilderness would have important effects on the 1,708 acres 

to be managed as A2 LUA but not on the entire planning area or land management plan. 

Important in the context that the area would be lost to bicycling. Maintenance would be 

restricted to use of primitive tools. 

The Land Use Allocation of A14 would have no important effect on the entire land management 

plan or affect land and resources throughout a large portion of the planning area during the 

planning period. The management area would continue to provide the spectrum of recreational 

opportunities as the no action alternative.

Cumulative Effects

The spatial boundaries for analyzing the cumulative effects to recreation are the Government 

Camp parcels and Government Camp Trail System, and, the combined Crystal Springs 

watershed protection area and wilderness addition because these areas are predicted be most 

affected by the land exchange and connected actions.

The temporal boundaries for analyzing the cumulative effects are 1 to 5 years (short-term) and 

5 to 30 years (long-term). The short-term reflects time to finalize land exchange. The long-term 

reflects time to full build-out of Government Camp parcels and subsequent change of 

management of Cooper Spur parcels.

Alternative 1- No Action

Since there would be no direct or indirect effects, there can be no cumulative effects. 

Alternative 2- Proposed Action

Government Camp Area

The following projects were analyzed for cumulative effects to the recreation resource:

• Mirror Lake Trailhead Relocation Project

• Ongoing ODOT road maintenance, including snowplowing on NFS lands, Government 

Camp, and Highway 26

• Skibowl and Summit ski areas’ winter recreation activities, operation and maintenance

• Skibowl and Summit ski areas’ summer recreation activities, operation and maintenance 

(such as bike parks, race events and concerts)

• Ongoing Forest Service trail use and maintenance (winter and summer uses) for the Glade,

Alpine, Timberline to Town, Mirror Lake, and Government Camp area trails

• Timberline Ski Area Mountain Bike Trails and Skills Park Project, including watershed 

restoration activities

• Camp Creek Summer Home Tract

• Collins Lake Resort operations

• Mazama Lodge Parking Area Expansion Project

• Operation and maintenance of Kiwanis Camp
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

242

The listed projects have shaped and continue to shape the ROS classes in the Government Camp 

area. Opportunities for recreation, such as ski areas, lodges, camps, residences, trails, and semiprimitive untrailed areas, continue to attract a large user base to the Government Camp area. 

Transportation improvements continue to facilitate access to recreation resources. The 

Government Camp Trail Network is a shared transportation and recreation resource by the 

Government Camp community. The Network functions as a flexible connected system where 

trailheads are access portals.

The proposed action(s), when considered with the listed projects, would continue to shape the 

Recreation Opportunity Spectrum, but cumulatively, there would be no change in ROS class.

Cooper Spur Area

The following projects were considered for cumulative effects to the recreation resource:

• Ongoing Oregon Department of Transportation (ODOT) road maintenance, including 

snowplowing on both NFS lands and Highway 35

• Cooper Spur Ski Area activities, operation and maintenance

• Development of private land (past and current)

• Ongoing recreation and trail use and maintenance (winter and summer uses) for the Tilly 

Jane and Cloud Cap areas

• Ongoing ODOT road maintenance and sanding, including snowplowing on Road 3510 

(Cooper Spur Road) and Road 3512 (Cloud Cap Road)

• Ongoing or upcoming Forest Service road closures

• Timberline Trail - Eliott Crossing Relocation Project

• Wilderness additions from the 2009 Omnibus Act (not including the Mt. Hood Wilderness 

addition, which is included in the proposed action for this project)

• Existing Cloud Cap and Tilly Jane special use permits

The listed projects have shaped and continue to shape the ROS classes in the Cooper Spur area. 

Recreation opportunities, such as skiing, trails, semi-primitive un-trailed areas, lodging, and the 

Cloud Cap-Tilly Jane Historic District attract a large user base. The transportation network 

continues to facilitate access to recreation resources. 

The wilderness additions move the ROS class toward the primitive setting. Otherwise, the 

proposed action(s), when considered with the listed projects, will continue to shape the 

Recreation Opportunity Spectrum, but cumulatively, there would be no change in ROS class.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

243

Silviculture

Introduction

The purpose of the silvicultural analysis is to summarize the forested habitat types and structures 

for the lands being exchanged and received in the Government Camp – Cooper Spur Land 

Exchange (GCCSLEX) Project, and to assess the lands for suitability in accordance with 36 CFR 

219.13, timber resource land suitability. Field reconnaissance and existing Geographic 

Information System (GIS) database information was used to inform the analysis of silvicultural 

effects. GIS analysis of the Mt. Hood NF’s timber suitability layer was conducted to make a 

determination of suitability (in regard to management for timber production).

Additional information regarding the Silvicultural requirements of the National Forest 

Management Act and applicable Forest Plan direction is available in the Silvicultural Specialist 

Report (Project Record). 

Affected Environment

Existing Condition

Lands to be Conveyed

The forest habitat types on the lands to be conveyed are considered to be productive or highly 

productive35 (McCain and Diaz 2002). While the forest types are considered very productive, the 

majority of the acres being given up in the land exchange are considered unsuitable for timber 

production.

Stand ages in the lands to be conveyed range from 85 to 145 years. All of the lands to be 

conveyed are either in the moist or montane36 mixed conifer or lodgepole pine habitat types. 

There are 72 total acres classified as moist mixed conifer in the western and eastern parcels. 

There are 36 acres of lodgepole pine habitat in the eastern parcel. None of the lands to be 

conveyed are in Later Successional Reserves nor do they meet the age and structural 

requirements for old growth.

Topography is gentle. The soil is rocky, with occasional large boulders. It varies from welldrained to areas of overland flow.37 All of the lands to be conveyed are classified as non-suitable 

for timber production by management direction. This is because all of the lands to be exchanged 

are either in A11 or A4.

Moist mixed conifer habitat is a forest, or rarely woodland, dominated by evergreen conifers, 

deciduous broadleaf trees, or both. Late seral stands typically have an abundance of large 

coniferous trees, a multi-layered canopy structure, large snags, and many large logs on the 

ground. Early seral stands typically have smaller trees, single-storied canopies, and may be 

dominated by conifers, broadleaf trees, or both. Coarse woody debris is abundant in early seral 

stands after natural disturbances, but much less so after clearcutting. Forest understories are 

structurally diverse: evergreen shrubs tend to dominate on nutrient-poor or drier sites; deciduous 

shrubs, ferns, and/or forbs tend to dominate on relatively nutrient-rich or moist sites. Shrubs may 

be low, medium-tall, or tall. Almost all structural stages are represented in the successional 

 35 Field guide to the forested plant associations of the Westside central cascades of northwest Oregon 36 Productivity in the montane mixed conifer is only slightly lower than in the moist mixed conifer habitat type. As 

such, for the purposes of this analysis, acres of moist and montane conifer habitat types will be aggregated together.

37 Northwest Forestry Services, Timber Cruise Report 2016
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

244

sequence within this habitat. Mosses are often a major ground cover. Lichens are abundant in the 

canopy of old stands.

The lodgepole pine habitat is composed of open to closed evergreen conifer tree canopies. 

Vertical structure is typically a single tree layer. Reproduction of other more shade-tolerant 

conifers can be abundant in the undergrowth. Several distinct undergrowth types develop under 

the tree layer: evergreen or deciduous medium-tall shrubs, evergreen low shrub, or graminoids 

with few shrubs. On pumice soils, a sparsely developed shrub and graminoid undergrowth 

appears with open to closed tree canopies.

The western land parcel to be exchanged (approximately 68 timbered acres38) is all in the Pacific

silver fir habitat types with ABAM/VAME/XETE39 being the most prolific (Lebo 2016). This 

forest type; as seen in figure 35, is considered to be moderately productive. Average site index 

for Douglas-fir in this forest type is 90. Species other than Pacific silver fir in the overstory 

consist of Douglas-fir, mountain hemlock, western hemlock, western red cedar, Alaska yellow 

cedar and western white pine. Estimated age of the average sized tree is 130 to 145 years old. 

However, the stand contains many young seedlings and saplings, as well as scattered relic trees 

that are estimated to be around 400 years old. Most of the trees fall into the 16- to 25-inch 

diameter breast height (d.b.h.) range. A few being 25 inches d.b.h. or larger. Canopy cover 

averages 77 percent with a range of 52 to 82 percent. Average tree height is 112 feet. Figure 35

shows the typical tree cover in the western parcel. 

Figure 35. Typical moist mixed conifer area in Government Camp

The eastern parcel (approximately 41 acres40) is dominated by lodgepole pine habitat types with 

smaller inclusions of moist mixed conifer (ABAM/VAME/XETE). Species other than lodgepole 

pine in the overstory include: Douglas-fir, western red cedar, and Pacific silver fir. The average 

tree is 85 to 95 years old, but the stand contains many young seedlings and saplings as well as 

old growth that is estimated to be around 400 years. Most of the trees fall into the 11- to 18-inch 

 38 Approximately 55.2 timbered acres, 4.3 acres of improvements, 2.6 acres of riparian reserves, 2.6 acres of powerline 

right-of-way, and 2.4 acres of brush. 39 Pacific silver fir/huckleberry/bear grass 40 Approximately 37.2 acres of timbered lands, 2.8 acres of wetlands, and 1 acre of riparian reserve.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

245

d.b.h. range; a few being 21 inches d.b.h. or larger. Canopy cover averages 63 percent with a 

range of 41 to 76 percent. Average tree height is 110 feet. Figure 36 shows the typical tree cover 

in the eastern parcel.

Figure 36. Typical lodgepole pine area in Government Camp

There are individual trees or clumps of trees that meet the standards for old growth. According to 

the Record of Decision and Standards and Guidelines for Amendments to the Survey and 

Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines (2001 

Survey and Manage ROD) “old-growth” is defined as an ecosystem distinguished by old trees 

and related structural attributes. Old growth encompasses the later stages of stand development 

that typically differ from earlier stages in a variety of characteristics, which may include tree 

size, accumulations of large dead woody material, number of canopy layers, species, 

composition, and ecosystem function. More specific parameters applicable to various species are 

available in the U.S. Forest Service, Region 6, 1993 Interim Old Growth Definitions (USDA 

Forest Service 1993). The Northwest Forest Plan Supplemental EIS and FEMAT (Forest 

Ecosystem Management Assessment Team) describe old-growth forest as a forest stand usually 

at least 180 to 220 years old with moderate-to-high canopy closure; a multi-layered, multispecies canopy dominated by large overstory trees; high incidence of large trees, some with 

broken tops and other indications of old and decaying wood; numerous large snags; and heavy 

accumulations of wood, including large logs on the ground. The two Government Camp parcels 

to be conveyed lack key components of the old growth definitions. Mainly stand age and the 

large-diameter snags and down wood are missing (USDA Forest Service and USDOI BLM 

1994).
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

246

Table 71. Resource indicators and measures for the existing condition Government Camp Lands

Resource Element Resource Indicator

(Quantify if possible)

Measure

(Quantify if 

possible)

Existing 

Condition41

Productivity of Forested 

Lands being Exchanged

Highly Productive Plant 

Associations

Acres 101

Timber Production Suitable for timber Production Acres 0

Resource Indicator and Measure 1 - Productivity of Forested Lands

Analysis of the Government Camp area illustrates that 101 of the 108 acres of the lands to be 

exchanged are of moderate productivity. 

Resource Indicator and Measure 2 - Suitable or Unsuitable for Timber 

Production

Analysis of the Government Camp area indicates that the 101 forest acres of land will be 

exchanged. None of the 101 acres is suitable for timber production because they all fall under 

LUAs A4 and A11. Regulated timber harvest is prohibited under management direction for both 

LUAs.

Lands to be Acquired

The large majority of the lands to be acquired are in the moist mixed conifer habitat types and 

can generally be categorized as plantations less than 80 years old and lightly entered stands over 

80 years of age. The lands that are being acquired under this exchange have been managed more 

intensely than those lands to be conveyed. The acquired lands include areas with many buildings 

and other infra-structural improvements such as: ski slopes, parking lots, tennis courts, etc. In 

addition to these developed acres, the bulk of the acquired lands are timbered acres that the 

Forest Service will take under management. These timbered lands consist of plantations as well 

as second-growth managed stands.

Of the acres being received in the land exchange, 452 are classified as moist mixed conifer. An 

additional 244 acres are considered to be dry mixed conifer. The remaining 67 acres42 are other 

less productive forest types. The moist and dry conifer lands being received are considered very 

productive forest habitats (ABGR/MANE2 and ABGR/HODI)43. While these two forest types 

are in the grand fir series, the dominant tree is Douglas-fir. Average site indices for Douglas-fir 

in the ABGR/MANE2 and HODI types are 128 and 125, respectively. These are well above the 

site index of 90 for Douglas-fir in the Government Camp lands to be exchanged. As well as 

being productive, the vast majority of the acres to be acquired are considered suitable for timber 

production; 732 acres are considered suitable for timber production and 33 acres are unsuitable. 

The predominant stand structures of these acquired lands can best be described as immature 

plantations less than 80 years old and lightly entered stands over 80 years (figure 37 and figure 

38).

The majority of the plantations are in the stem exclusion stage dominated by small to medium 

size material with a quadratic mean diameter (QMD) ranging from 5 to 8 inches, an average of 

 41 The lands being exchanged. 42 Mixed conifer-deciduous 30 acres, interior Douglas-fir 14 acres, ponderosa pine –Douglas-fir 13 acres, and 

lodgepole pine 9 acres.

43 ABGR/MANE2 – grand fir/dwarf Oregon grape; ABGR/HODI – grand fir/ocean spray.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

247

800 TPA and an average height of 65 feet (figure 35 and figure 36). Canopy cover averages 

approximately 80 percent with a range of 60 to 100 percent (Olesker 2014).

Figure 37. Plantation less than 25 years old Figure 38. Overstocked plantation over 25 years 

old

The areas that have been lightly entered range in age from 80 to 120 years old and are dominated 

by stands in the re-initiation stage (figure 39). Canopy cover averages approximately 70 percent 

with a range of 50 to 90 percent. The QMD within these stands range from 9 to 12, an average of 

900 TPA and have an average height of 75 feet. Regeneration in these stands are dominated by 

shade-tolerant species like grand fir and western hemlock. These stands have an abundance of 

ladder fuels built up in the understory with very little to no shrub component.

Figure 39. Typical dense stand with ladder fuels in Cooper Spur

On average, the lands being received are below Forest Plan standards for snags. Currently, 

within plantations there are roughly 1 snag per acre and in lightly entered stands there are 3 

snags per acre
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

248

Under the proposed action, in the Cooper Spur area 249 acres of matrix lands that are being 

proposed to become wilderness or the new Crystal Springs LUA are classified as suitable for 

timber production; 1,092 acres are currently classified as unsuitable for timber production. Lands 

under A2 Wilderness or the new A14 Crystal Springs Watershed Special Resources Management 

Unit LUAs are by management direction unsuitable for timber production.

Resource Indicator and Measure 1- Productivity of Forested Lands

The 696 acres being acquired in the Cooper Spur area are considered to be highly productive 

from a biomass production standpoint44 (table 72). 

Resource Indicator and Measure 2- Suitable or Unsuitable for Timber Production

Currently, for the lands to be acquired in the Cooper Spur, there is no decision as to whether they 

are suitable or unsuitable for timber production. This is due to them being held privately. On 

existing Forest Service lands near Cooper Spur there are 249 acres suitable for timber 

production. After the land exchange, all of the acquired acres will be unsuitable per management 

direction (table 72).

Table 72. Resource indicators and measures for the existing condition Cooper Spur lands

Resource Element Resource Indicator

(Quantify if possible)

Measure

(Quantify if possible)

Existing 

Condition45

Productivity of Forested Lands 

being Exchanged

Highly Productive Plant 

Associations

Acres 696

Timber Production Suitable for timber Production Acres 249

Environmental Consequences

One of the characteristics of forest types is how “productive” they are. A standard indicator of 

productivity is “site index.” Site index is a species-specific measure of the site quality or 

productivity expressed in terms of the average height of dominant or co-dominant trees at a 

specific age (Helms 1998). Essentially, the higher the site index at a common age, the higher the 

productivity. Site quality; because it is directly related to “how fast can we grow a ‘large’ tree,” 

directly affects a variety of resources (timber, wildlife, hydrology, etc.). The measure for site 

index will be the number of acres lost or gained with higher site index levels.

A complementary resource indicator to productivity is: are the lands to be exchanged suitable for 

timber production? The measurement indicator for this will be whether areas are considered 

suitable or unsuitable for timber production or from vegetation management. The measure will 

be the net loss or gain in the acres suitable for timber production. Table 73 illustrates both 

resource indicators and measures.

 44 The lands being acquired are generally in the grand fir habitat types, and approximately 41 percent more productive 

than the predominantly Pacific silver fir and lodgepole habitat types of the lands being conveyed. 

45 The lands being acquired.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

249

Table 73. Resource indicators and measures for assessing effects

Resource Element Resource Indicator

Measure

(Quantify if 

possible)

Used to 

address: P/N, 

or key issue?

Source

(LRMP S/G; 

law or policy, 

BMPs, etc.)?

Productivity of 

Forested Lands 

being Exchanged

Forest Habitat Types Acres No None

Timber Production Timber Suitability Acres No NFMA

The change in the number of productive acres and acres considered to be suitable for timber 

production in the lands being lost and gained will be used to measure the effect to the 

silvicultural resource. 

Lands are considered to be either suitable or unsuitable for timber production based on an 

analysis of their intrinsic physical values such as: are they naturally forested or not, are they in 

areas prone to landslides and mass-wasting, or are the soils highly compactable? These are a few 

of the physical characteristics that either singly or together indicate an area’s suitability or 

unsuitability. Management decisions also govern suitability/unsuitability. Management direction 

for designated wilderness or special emphasis areas automatically make them unsuitable for 

timber production. Suitable for timber production means “regulated” timber production. 

Unsuitable for timber production still allows for management actions like timber salvage or other 

vegetation manipulation projects in certain LUAs.

Direct and Indirect Effects

Alternative 1

By definition, direct and indirect effects (40 CFR 1508.8), and cumulative effects (40 CFR 

1508.7) result from the proposed action, and thus, are not germane to the no-action alternative.

The effect of adopting alternative 1 would be no change in the existing acres suitable for timber 

production nor in the acres of highly productive timber stands, and 1,700 acres of Matrix lands 

would not be converted into a wilderness or designation (table 74).

Under the no-action alternative, the existing condition, as described earlier, of the proposed lands 

to be exchanged would continue to persist under the auspices of natural succession. There would 

be no change in the number of acres that are either increasing or decreasing in site productivity. 

There would be no change to the number of existing acres that are suitable or unsuitable for 

timber production. No forested lands would be removed. Regulated timber harvest and salvage, 

as well as other non-regulated vegetation treatments, would still be allowed in the LUAs where 

they are currently allowed.

Table 74. Resource indicators and measures for alternative 1

Resource Element Resource Indicator

(Quantify if possible)

Measure

(Quantify if 

possible)

(+/-) Number of acre 

change from the 

existing condition

Productivity of 

Forested Lands being 

Exchanged

Highly Productive Plant 

Associations

Acres 0

Timber Production Suitable for timber Production Acres 0
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

250

Alternative 2

Resource Indicator and Measure 1 - Productivity of Forested Lands

The direct effect of adopting the proposed action on resource measure one is that the Forest 

Service would add 657 more productive acres in the A14 LUA, when compared to the existing 

condition (table 74). There are no indirect effects because productivity is a constant metric. 

Resource Indicator and Measure 2 - Suitable or Unsuitable for Timber Production

The number of acres considered as suitable for timber production will decrease by approximately 

249 acres (table 75). This is due to 249 acres of suitable lands in both the B2 and the C1 LUAs 

being re-classified as either A2 or A14 after the land exchange. A2 and A14 are unsuitable for 

timber production by management direction. There are no indirect effects because timber 

suitability is a constant metric.46

Table 75. Resource indicators and measures for alternative 2 direct and indirect effects

Resource Element Resource Indicator

(Quantify if possible)

Measure

(Quantify if 

possible)

(+/-) Number of acre 

change from the 

existing condition

Productivity of 

Forested Lands being 

Exchanged

Highly Productive Plant 

Associations

Acres + 657

Timber Production Suitable for timber Production Acres - 249

Summary of Effects

Table 76 illustrates that implementation of the proposed action would increase the productivity 

of the Mt Hood National Forest while at the same time it would also lower the number of acres 

suitable for timber production across the Forest. 

The inherent value of a more productive acre of timber is desirable by more resources than just 

timber. The ability to grow larger trees faster is desirable to the wildlife resource in areas that 

might lack larger-diameter forest structures or larger coarse woody debris, and hydrology and 

fisheries resources would benefit from increased canopy cover in areas where it may be limited

Table 76. Summary comparison of environmental effects to silvicultural resource

Resource Element Indicator/Measure Alt 1 Alt 2 

Productivity of Forested Lands 

being Exchanged

Highly Productive Plant 

Associations

0 + 657

Timber Production Suitable for timber Production 0 - 249

Cumulative Effects

Alternative 1

Since there are no direct or indirect effects, there can be no cumulative effects. 

 46 Unless management direction changes. This cannot be predicted.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

251

Alternative 2

There are no cumulative effects to resource indicator and measure 2: timber production. That 

effect is direct and immediate. However, the cumulative effect from the proposed action to 

resource element 1: timber productivity, is that, over time trees will grow larger, faster on the 

lands acquired than was occurring on the lands conveyed. 

Socioeconomics

Introduction

The land exchange, connected actions, and subsequent uses of the lands after exchange have the 

potential to have social and economic effects to local communities. This socioeconomic analysis 

is an evaluation of how the proposed action would affect quality of life, human uses and values, 

environmental justice, and economic efficiency. The social and economic analysis area consists 

of the two Oregon counties where the proposed exchange would takes place—Clackamas and 

Hood River counties.

This analysis does not address the land appraisal or process. The appraisal process is governed 

by a strict set of rules and guidelines. In addition, the appraisal is assumed to be accurate and 

represents the real market value of the lands and properties. This analysis does address the 

assumed uses of the land after the proposed exchange and the social and economic impacts of 

this on the communities. 

This analysis generally describes the economic impacts of the acquisition of the Cooper Spur 

Mountain Resort which would require development of a new special use permit. Special use 

permit(s) would be issued for the concession operation and maintenance of the Cooper Spur Ski 

Area and Cooper Spur Mountain Resort. This analysis does not discuss detailed effects to the 

existing Cooper Spur Ski Area special use permit nor does it address all potential permutations 

of options available for the new permit(s). 

The purpose and need is to comply with the congressional direction and conditions in the 

Omnibus Public Land Management Act of March 30, 2009 (123 Stat. 991, P.L. 111-11). As such, 

social or economic issues are not driving the purpose and need. However, the unique 

environment provided by the Mt. Hood National Forest and the conditions of the proposed action 

impact the quality of life and welfare of the surrounding communities. In addition, the project 

environment is nationally iconic and therefore the welfare effects may extend beyond the local 

communities to additional communities of users, as well as non-users.

Affected Environment

Existing Condition

Existing social and economic conditions are necessary to establish the baseline from which to 

estimate potential consequences of the proposed land exchange. This section analyzes the current 

conditions and trends related to the social and economic environment of the planning area, 

including: population and demographics, human uses and values, local government taxes and 

revenues, and Forest Service revenues and expenses. Environmental justice is also addressed.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

252

Social Conditions

Population Size, Growth and Density

This section highlights population trends in the two county study area. Population is an 

important consideration in managing natural resources. In particular, population structure (size, 

composition, density) and population dynamics (how the structure changes over time) are 

essential to describing the consequences of changes to the forest on the social environment 

(Seesholtz et al. 2006). 

Population Size and Growth 

The study area was home to 398,338 people as of the 2010 Census of population (U.S. Census 

Bureau 2010). Table 77 displays population data for the two counties in the study area, as well as 

state and national population figures for census years 2000 and 2010. 

Table 77. Population, population change, and population density

Population 

Count, 

2000

Population 

Count, 

2010

Percent 

Change in 

Population, 

2000–2010

Population 

Density, People 

per Square Mile, 

2000

Population 

Density, People 

per Square Mile, 

2010

Clackamas 

County

338,391 375,992 11.1 181.1 201.0

Hood River 

County

20,411 22,346 9.5 39.1 42.8

Oregon 3,421,399 3,831,074 12.0 35.6 39.9

United 

States

281,421,906 308,745,538 9.7 79.6 87.4

Source: U.S. Census Bureau, 2010 and 2000 census.

Clackamas County is considerably more populated than Hood River County. As of the 2010 

census it was the third most populous county in the State of Oregon (U.S. Census Bureau 2010). 

Clackamas County is situated immediately southwest of the city of Portland, Oregon, and the 

county is part of the Portland-Vancouver-Hillsboro, Oregon-Washington metropolitan statistical 

area. Oregon City, the county seat, contains 8 percent of the county population. 

Government Camp, an unincorporated community within Clackamas County, is adjacent to the 

project area. Government Camp is a community of 193 residents as of the 2010 census. 

However, these residents occupy only 16 percent of the housing units located within the 

community. Over 75 percent of the housing units are for seasonal, recreational, or occasional use 

(U.S. Census Bureau 2010). The owners and users of these housing units are not included in the 

population count. Government Camp is entirely surrounded by National Forest lands and is the 

closest community to the larger Mt. Hood area ski resorts of Timberline Ski Area, Mt. Hood 

Meadows Ski Resort, and Mt. Hood Skibowl. Summit Ski Area, a smaller ski area, is located 

adjacent to the Government Camp community. 

Hood River County is considerably less populated than Clackamas County. Hood River County 

is delineated as a micropolitan statistical area—an area with an urban cluster greater than 10,000 

but less than 50,000 population, or socially or economically integrated with the core (Office of 

Management and Budget 2015). Hood River County contains the city of Hood River where over 

35 percent of county residents live (U.S. Census Bureau 2010). The county also contains several 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

253

unincorporated communities, Parkdale, Odell, and Mt. Hood are closest to the portion of the 

project area located in Hood River County with populations of 311, 2,255, and 286, respectively 

(U.S. Census Bureau 2010). 

Both counties saw steady growth in population between 2000 and 2010 decennial census 

estimates. According to the American Community Survey (U.S. Census Bureau 2006–2014) 

population growth has continued in a similar upward trend growing at an average 0.9 and 1.0 

percent annually in Clackamas and Hood River Counties, respectively, from 2010 to 2014. 

Population growth signals continued economic opportunity, desirable amenities, or both 

(McGranahan 1999). 

Population Density

Population density can serve as an indicator of a number of socioeconomic factors of interest—

urbanization, availability of open space, socioeconomic diversity, and civic infrastructure (Horne 

and Haynes 1999). More densely populated areas are generally more urban, diverse, and offer 

better access to infrastructure. In contrast, less densely populated areas provide more open space, 

which may offer natural amenity values to residents and visitors. Table 77 displays the number 

of people per square mile for each of the counties of interest. 

Clackamas County is the fourth most density populated county in the State of Oregon with more 

than 200 people per square mile in the county (U.S. Census Bureau 2010). Hood River County is 

considerably less densely populated, with 42.8 people per square mile, but still slightly above 

statewide average density levels. Often low population density points to high levels of public 

ownership. However, both counties have above average population density and still contain a 

majority of land area as federally managed—53 and 62 percent in Clackamas and Hood River 

county, respectively, in 2010 (U.S. Department of the Interior 2016). The majority of this public 

land is managed by the Forest Service. 

Human Uses and Values

An assessment of values, beliefs, and attitudes provides insight into the relationship between the

public and the proposed project area. Members of the public submitted scoping comments on the 

Mt. Hood Land Exchange. These comments were evaluated to identify values, beliefs, and 

attitudes related to the proposed project activities. This section forms the basis of the subsequent 

social effects analysis.

As of 2010, Hood River County had 62 percent of total land area federally administered—

99 percent of which is the Mt. Hood National Forest—spanning from the Columbia River Gorge 

past Mt. Hood itself (U.S. Department of the Interior 2016). Clackamas County had over 

52 percent of its total land area federally administered—87 percent of which is by the Forest 

Service (U.S. Department of the Interior 2016). The majority of this is Mt. Hood National Forest. 

These lands provide a significant resource for recreation and the proximity to populations, 

including Portland, Oregon’s largest city, which means many people are able to enjoy this 

resource. The national visitor use monitoring finds that 10 of the top 15 reported zip codes for 

visitors to the Mt. Hood National Forest are in Multnomah County—the county containing 

Portland (USDA Forest Service 2016b). Zip codes from Hood River and Clackamas County also 

appear in this list (USDA Forest Service 2016b).

Highlighting the economic contributions of this resource the National Forest Economic 

Contributions (USDA Forest Service 2016c) estimates local recreation visitors (traveling 

50 miles or less for activities including picnicking, backpacking, skiing, snowmobiling) to the 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

254

Mt. Hood National Forest generated $14.1 million (in 2014 dollars) in gross regional product—

the market value of all final goods and services produced within the region. Another $31 million 

(in 2014 dollars) in gross regional product is generated by non-local recreation users. 

Public scoping highlighted the appreciation of this resource as comments included statements 

regarding the use and enjoyment of the Forest. Public scoping comments highlighted the 

recreation value of the “historic backcountry” found on the Cooper Spur parcel as some 

commenters began their submissions with statements such as “a frequent user of this backcountry area” or “a long-time visitor and use.r. The project is believed by many commenters to 

enhance recreation values due to both the Mt. Hood National Forest acquisition of new lands on 

the Cooper Spur side of the Forest and the new wilderness designation also proposed in that area.

Government Camp

Both Government Camp parcels are boarded on one side by low-density residential development 

providing nearby residents amenities such as beauty and scenery of the forest, wildlife viewing, 

and a sense of solitude, as well as recreational opportunities. The parcels include two segments 

of a non-motorized trail system. These trails are used for hiking and biking in summer and for 

Nordic skiing, winter fat biking, and snowshoeing. Scoping comments supported the value of 

these trails for year-round recreation. Other comments stated residents and visitors “use this trail 

to ski home from Timberline Ski Area,” and “it is a very popular snowshoe and cross-country ski 

trail.” In the summer they becomes the “most popular hiking and mountain biking trails.” 

All users of these recreation trails are demonstrating value; however, value can also be measured 

though the price of nearby homes. Indeed, a scoping comment encapsulates this by saying 

proximity to the trails is “often a consideration when purchasing a unit”. Studies have shown that 

homes in neighborhoods with trails sell at a premium (for example, Asabere and Huffman 

[2009]). More specifically, one such study found that proximity to trail entrances positively 

impacts property values (Parent and von Hofe 2013).

Cooper Spur

The easterly slope of the Cooper Spur project area contains historic recreation opportunities in 

the Tilly Jane and is highly valued wilderness recreation opportunities for the counties in the 

study area, but also the nearby urban population centers and visitors from farther away. Tilly 

Jane Ski Trail is historically significant because it was built to provide direct access to the 

structures in the Cloud Cap/Tilly Jane Historic District and the northeast side of Mt. Hood during 

the snow season. As a result, the area became immensely popular with backcountry recreational 

enthusiasts. A significant portion of the public submitted scoping comments relate to the value 

and special attachment the public has for the recreational use of both project areas, but with 

special emphasis on the Tilly Jane recreation area. For example, one individual states “This part 

of Mt. Hood is one of my favorite places to snowshoe, camp and climb precisely because it is 

remote and not developed.” The recreation opportunities of the proposed project areas are 

discussed in more detail in the Recreation Specialist Report.

The acquisition of the Cooper Spur parcels by the Forest Service remove the land from private 

ownership and as one commenter states “removes the possibility of development.” Commenters 

“value the assurance of no development in area,” “value remote and not developed,” and “protect 

the historic backcountry on the North side of Mt. Hood from further commercial development.” 

One commenter believes the project would “ensure the quality remains high for everyone’s 

visit.” 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

255

One business also noted the prevention of development in these locations as a positive aspect of 

the project, but for reasons outside of the effects on recreation and forest users. They note the 

positive effects of the lack of development as it relates to off-forest activities such a “fewer uses 

and people in the area that are incompatible with our farm and forest practices; Less traffic to 

interfere with farm operations and slow moving tractors on highways. Less competition for water 

so that we can irrigate our crops.”

While the comments were largely in support of the project related to recreation and access, one 

commenter noted concerns stating that “closing roads and trails and adding to Wilderness makes 

additional land inaccessible to the general public (unless you are a hiker).”

The project area is also contains tribal ceded lands. These lands provide traditional uses to tribes 

in the region. This is outlined in the “Environmental Justice” section below and in greater detail 

in the Cultural Resources and Treaty Rights Specialist Report. 

Non-market Values

The economic value of U.S. forests are not entirely captured in market transactions. Much of the 

value of National Forests is “non-market” in nature—meaning that many of the benefits that 

forests provide to humans are not bought and sold in a market transactions and therefore 

assigning a price is more problematic. The lack of a price, however, should not be conflated with 

an absence of value. Indeed, non-market values from forests provide economic benefits to 

adjacent communities and forest visitors. One example is provided by a scoping comment, 

“removing the possibility of development will help keep this side of the mountain wild for the 

sustainability of watersheds, wildlife, and traditional human-powered recreation.” Another 

commenter stated “This is an opportunity to protect some still undeveloped sections of the forest, 

for use by future generations.” 

Ecosystem services are “components of nature, directly enjoyed, consumed, or used to yield 

human well-being” (Boyd and Banzhaf 2007). Healthy forests provide numerous ecosystem 

services, including clean water and air, biodiversity, forest products, and many other goods and 

services. Numerous commenters addressed their desire to see the proposed action implemented 

due to the potential water quality benefits that would be provided. Consistent with direction 

provided in 40 CFR 1502.23 and Forest Service Handbook 1909.15 (July 6, 2004) and 22.35 

January 14, 2005), the analysis of environmental consequences will consider non-market goods

and services primarily in qualitative terms. Where appropriate, discussion of how the alternatives 

may affect non-market values will be presented. However, due to the qualitative nature of these 

discussions, direct comparisons between changes in market and non-market values are generally 

not possible.

Economic Benefits

Local Government Taxes and Revenues

State and local government in Oregon receive revenue from both privately owned and federally 

managed lands through several types of payment mechanisms. These are Federal Payments InLieu of Taxes (PILT), the Secure Rural Schools Act, Federal 25 Percent Fund, and property taxes 

paid on private lands. 

Forest Service County Payments. Counties receive revenue sharing payments from commercial 

activities on Federal lands, such as oil and gas leasing, livestock grazing, and timber harvesting. 

Beginning in 1908 the payment was 25-percent of the moneys received annually. Since 2008 the 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

256

payments are based on 25-percent of the 7-year rolling average annual receipts. These payments 

are commonly called 25-percent payments. However, in 2000, the Secure Rural Schools and 

Community Self-determination Act was passed which offered a guaranteed source of payments 

that was not tied to annual commercial revenue on National Forests. Clackamas and Hood River 

Counties both elected to receive the Secure Rural Schools Act State Payment share in 2015 and 

not the 25-percent payments. Table 78 shows the county total and per-acre revenue from Forest 

Service payments in fiscal year 2015. 

Table 78. Forest Service county payments, fiscal year 2015

Total Acres Total Payments Average Payment per Acre

Hood River County 209,303 $735,579.47 $3.51

Clackamas County 508,440 $1,289,828.64 $2.54

Source: USDA Forest Service (2016)

Payments In-Lieu of Taxes (PILT). PILT are Federal payments to local governments that help 

counties offset losses in property taxes associated with nontaxable Federal land located within a 

county’s boundary. PILT payments are distributed by the Department of the Interior (DOI) for 

tax-exempt Federal land administered by the BLM, the Forest Service, the National Park 

Service, U.S. Fish and Wildlife Service, and for Federal water projects and some military 

installations. These payments are designed to supplement other Federal land receipt-sharing 

payments that local governments may receive, including timber receipts from national forests, 

grazing fee receipts, mineral material sales receipts, and some receipts collected on wildlife 

refuges. PILT payments traditionally helped balance the uneven distribution of Federal 

25 Percent Fund payments between counties with Forest Service land and counties with other 

types of Federal land that do not generate timber revenues. PILT has historically been a more 

stable and dependable revenue source than Federal 25 Percent Fund payments because it is a flat 

per-acre payment that is not tied to levels of revenue generated by Forest Service land.

Both Clackamas and Hood River Counties receive PILT payments for Federal lands. Table 4 

shows total and per-acre payments made to the two counties in fiscal year 2015 for all PILTeligible lands. As mentioned above, a majority of Federal lands in both counties which the 

payments are based is administered by the Forest Service. 

Table 79. Payments in-lieu of taxes, 2015

Total PILT Payments Payments per Acre PILT Acres Administered 

by Forest Service

Hood River County $74,152 $0.36 99.9%

Clackamas County $616,512 $0.98 87.4%

Source: U.S. Department of the Interior (2016)

County Property Taxes. The local property tax system is one of the most important sources of 

revenue for local taxing districts in Oregon. Property taxes are based on county assessed value of 

privately owned real property (land, buildings and fixed machinery and equipment), 

manufactured homes and personal property used in a business. Tax rates are established based on 

the amount of property taxes a district needs to support the budget for a fiscal year. Property 

taxes are specified in the form of a rate per $1,000 of assessed value. These rates vary within 

counties by the locality. The tax rate in Government Camp was 14.9306 (as of August 2016) 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

257

(personal communication with Clackamas County Department of Assessment and Taxation). The 

tax rates for the project area in Clackamas County are 12.0096 and 11.8873 (as of August 2016), 

varying by the location of the parcels (personal communication with Micaela Keller, Compliance 

Planner, Hood River County). 

Forest Service Revenue and Expenses

There are several recreation-related special use permits issued within the project area. Tilly Jane 

A-Frame, Cloud Cap Inn, the Snowshoe Club Cabin, and the concessionaire campgrounds are 

discussed in the Recreation Specialist Report. These special use permits are not affected by the 

proposed project and are not discussed in this report. See the Recreation Specialist Report for 

additional details. 

Cooper Spur Ski Area

The Cooper Spur Ski Area operates under a special use permit that currently is set to expire at 

the end of 2021. The current area permitted by the special use permit is 1,172 acres. There are 

20 skiable acres. All structures and facilities are privately owned. It is a solely winter operation 

and its operating calendar is dependent on adequate snow coverage, but typically closes the day 

after spring break (late March). The number of days it is open fluctuates annually between 0 and 

60. Some drought years it has not opened. Its 3-year average skier days is 4,666 per year. Its 

10-year average is 9,681 per year. (Details on operation and use were obtained through personal 

communication with Scott Kaden, Special Use Permit Administrator and Artillery Program 

Manager, Mt. Hood National Forest.)

Special use permits holders are assessed fees by the Forest Service. The Cooper Spur Ski Area 

pays an annual land use fee based on revenues from the operation. Because this is an annual 

operation which is highly weather dependent, the annual fees paid by Cooper Spur have ranged 

widely from a minimum $110.00 to $6,500.00 (personal communication with Scott Kaden, 

Special Use Permit Administrator and Artillery Program Manager, Mt. Hood National Forest). 

These fees are paid directly to the U.S. Treasury and are not available to the Forest for use. 

The public expressed concern over the ability of the Forest Service to care for and manage the 

facilities associated with this ski area which would be acquired under the proposed action. One 

commenter stated “acquisition of the Cooper Spur ski area and its aging infrastructure is 

substantially counter to the public interest.” Commenters generally were interested in the plans 

the Forest Service has for the future use and management of the ski hill, and the financial 

implications of such. 

The facilities associated with the ski area as well as the currently privately owned Cooper Spur 

Mountain Resort, which would also be acquired under the proposed action, have undergone a 

comprehensive property condition assessment by Miller Consulting Engineers, Inc. and PAE 

Consulting Engineers (USDA Forest Service 2012). The assessment finds the facilities in need of 

“urgent corrective action” and “immediate upgrade,” as well as maintenance that can be deferred 

for 3 to 10 years or more. Table 80 shows the estimated costs of repairs to the ski area and resort 

by the indicated urgency level. The sum of the recommended urgent repairs is just over $6,000 

for the ski area (in 2015 dollars). The Cooper Spur Inn and Resort is an additional $34,000 (in

2015 dollars) for urgent repairs. Based on the property condition assessment report, total repairs 

needed at the ski area (excluding ski lifts) within the next 10 years is $90,940 (in 2015 dollars). 

Including the Cooper Spur Resort, needed repairs increases the 10-year total to $331,228 (in 

2015 dollars). The Facilities Specialist Report discusses the structures and their condition in 

greater detail. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

258

Table 80. Estimated repair totals for Cooper Spur Ski Area and Resort facility deficiencies, by 

timeframe required (in 2015 dollars)

Urgent 

Corrective 

Action

Immediate 

Upgrade (1–3 

years)

Deferred 

Maintenance 

(3–10 years)

Action 

Required 

Beyond 10 

years

Structure 

Decommissioning

Ski Area $6,123.79 $65,976.27 $18,840.04 $0.00 $24,331.01

Resort $34,028.73 $177,420.53 $28,838.17 $2,719.16 $134,365.10

Total Repair Costs $40,152.51 $243,396.81 $47,678.21 $2,719.16 $158,696.11

Note: Repair and structure decommissioning estimates exclude ski lifts. 

Source: USDA Forest Service (2012). Updated with 2015 dollars using Bureau of Labor Statistics Consumer Price Index. 

Environmental Justice

Executive Order 12898 directs Federal agencies to focus attention on the human health and 

environmental conditions in minority and low-income communities. The purpose of EO 12898 is 

to identify and address, as appropriate, disproportionately high and adverse human health or 

environmental effects on minority and low-income populations.

Environmental justice is the fair treatment and meaningful involvement of people of all races, 

cultures, and incomes, with respect to the development, implementation, and enforcement of 

environmental laws, regulations, and policies. The goal of environmental justice is for Federal 

agency decision-makers to identify impacts that are disproportionately high and adverse with 

respect to minority and low-income populations and identify alternatives that will avoid or 

mitigate those impacts. According to USDA DR5600-002 (USDA 1997), environmental justice,

minority, minority population, low-income, and human health and environmental effects, are 

defined as follows.

Environmental Justice means that, to the greatest extent practicable and permitted by 

law, all populations are provided the opportunity to comment before decisions are 

rendered on, are allowed to share in the benefits of, are not excluded from, and are not 

affected in a disproportionately high and adverse manner by, government programs and 

activities affecting human health or the environment.

Minority means a person who is a member of the following population groups: 

American Indian or Alaskan Native; Asian or Pacific Islander; Black, not of Hispanic 

origin; or Hispanic.

Minority Population means any readily identifiable group of minority persons who live 

in geographic proximity to, and, if circumstances warrant, migrant farm workers and 

other geographically dispersed/transient persons who will be similarly affected by 

USDA programs or activities.

Low-income Population means any readily identifiable group of low-income persons 

who live in geographic proximity to, and, if circumstances warrant, migrant farm 

workers and other geographically dispersed/transient persons who will be similarly 

affected by USDA programs or activities. Low-income populations may be identified 

using data collected, maintained and analyzed by an agency or from analytical tools such 

as the annual statistical poverty thresholds from the Bureau of the Census' Current 

Population Reports, Series P-60 on Income and Poverty.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

259

Human Health and/or Environmental Effects as used in this departmental regulation 

include interrelated social and economic effects.

The emphasis of environmental justice is on health effects and/or the benefits of a healthy 

environment. The CEQ has interpreted health effects with a broad definition: “Such effects may 

include ecological, cultural, human health, economic or social impacts on minority communities, 

low-income communities or Indian Tribes...when those impacts are interrelated to impacts on 

the natural or physical environment” (CEQ 1997).

Race and Ethnicity

According to the U.S. Census Bureau, American Community Survey (2014) data, the two 

counties are reasonably similar in their racial composition (table 81). Both counties have nearly 

90 percent white populations. Clackamas County has a higher share of Asian population, 

3.9 percent compared to 1.3 percent in Hood River County. However, Hood River County has a 

substantially higher share of Hispanic or Latino persons—30.3 percent—which is about twice 

the share found at the state and national level. 

Table 81. Race and ethnicity (%)

Clackamas 

County

Hood River 

County Oregon United States

White 89.5 89.6 85.1 73.8

Black or African American 0.9 0.3 1.8 12.6

American Indian and Alaska 

Native

0.7 0.6 1.2 0.8

Asian 3.9 1.3 3.9 5.0

Native Hawaiian and Other Pacific 

Islander

0.3 0.3 0.4 0.2

Some other race 1.5 4.8 3.7 4.7

Two or more races 3.3 3.0 3.9 2.9

Hispanic or Latino (of any race) 8.0 30.3 12.1 16.9

Source: U.S. Census Bureau, 2010–2014 American Community Survey 5-Year Estimates, table DP05.

The communities located closest to the proposed project area are predominately white. 

Government Camp was 95 percent white as of the 2010 Census. Parkdale, Odell, and Mount 

Hood in Hood River County had lower share of white populations at 65, 76 and 75 percent, 

respectively. This is driven primarily by the relatively larger share of Hispanic or Latino 

populations in these three communities which identify as non-white (some other race) (U.S. 

Census Bureau 2010). 

A 2013 study found that Hood River and Clackamas counties had the third and fourth highest 

population of migrant and seasonal farm workers in the state (Larson 2013). The degree which 

this population is already accounted for in the U.S. Census Bureau estimates is unknown. 

Migrant and seasonal farm workers may be undocumented and therefore less willing to 

participate in government-sponsored survey for fear of deportation or other repercussions, so 

estimates may be under representing this population. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

260

Low-income Populations

The percentage of residents in both Clackamas and Hood River County with income below the 

poverty level are below statewide levels (table 82). The incidence of poverty is often not evenly 

distributed among racial and ethnic groups. For example, nationally, 13 percent of the white 

population was below the poverty level in 2014, while 27 percent of the Black or African 

American population was below poverty levels. At a state-level, Oregon showed similar 

discrepancy with 15 percent of the white population and 36 percent of the Black or African 

American population below the poverty level. The Hispanic and Latino population had equally 

high levels of poverty—25 percent nationally and 28 percent in Oregon—in 2014 (U.S. Census 

Bureau 2014). While county-level estimates of poverty by race and ethnicity have very low 

levels of reliability due to small sample size, this pattern appears to hold and the higher rate of 

poverty in Hood River County relative to Clackamas County is driven by a larger share of 

minority populations—notably Hispanic or Latino. 

Table 82. Percentage of people with Income below poverty level

People Below Poverty Level

Clackamas County 9.7

Hood River County 15.7

Oregon 16.7

United States 15.6

Source: U.S. Census Bureau, 2010–2014 American Community Survey 5-Year 

Estimates, table DP03

The study area satisfies criteria for identifying environmental justice communities. It has a 

meaningfully greater share of Hispanic or Latino residents than the state. In addition, Hispanic or 

Latino residents appear to have higher rates of poverty than other groups in the study area.

Environmental Consequences

Direct and Indirect Effects

Alternative 1 - No Action

The cost of project planning and environmental analysis would be the same under both 

alternatives. There would be no change to the Forest costs and revenues as a result of the 

alternative because existing management plans and land use allocations do not change, existing 

Forest boundaries remain intact, and management strategies are not altered under the no-action 

alternative.

The 109 acres north of the village of Government Camp would remain under Forest Service 

ownership, and in the Forest Plan the land use allocation is “A11 Winter Recreation Area.” The 

community of Government Camp would not see any growth due to development on the Forest 

Service parcels. There would be no changes to Clackamas County revenues as no new lands 

would enter or leave public ownership. Residents and visitors to Government Camp would 

continue to use and enjoy the existing trail system. There would be no adverse impact to tribal 

activities and access. 

Under this alternative the Mt. Hood National Forest would not acquire the Cooper Spur Ski Area 

and its infrastructure, and therefore not acquire the uncertainty about the financial implications 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

261

of management or decommissioning of these facilities. The existing 1,172-acre Cooper Spur Ski 

Area Special Use Permit area and boundary would remain the same. The nine structures and ski 

lifts on the ski hill (Forest Service land) would remain under private ownership. No new special 

use permit prospectus would be advertised. The current nonexclusive permit expires in 2021, and 

may be extended an additional 20 years if it is in compliance with the site development schedule 

in the Master Development Plan. The no-action alternative would continue to generate variable 

revenue for the U.S. Treasury under the existing special use permit for the Cooper Spur Ski Area. 

The Cooper Spur Mountain Resort, including the land and 15 buildings would remain under 

private ownership. No special use permit prospectuses would be advertised. This land is zoned 

C-1 (Commercial Zone). Additional lands would remain under private ownership. These lands 

are currently zoned as F-2, and F-1 (Primary Forest and Forest Zones) (personal communication 

with John Roberts, AICP, Community Development Director, Hood River County). Therefore, 

there is the potential for development on some of these lands. Scoping comments suggested 

development was undesirable in this area and could adversely affect quality of life due to 

changing the character or quality of the area for recreation users and potential increases in traffic. 

Therefore, this alternative would result in decreased welfare of the local community relative to 

the proposed action, should development occur at these sites. Development on this private 

property would impact county tax revenues as development would increase the market value of 

the property and therefore the taxable value. Correspondingly, development could also increase 

the costs of county services if development required additional law enforcement activity or road 

maintenance, for example. 

The 1,709 acres within land use allocations A4 (492 acres), A11 (1,109 acres) and B2 (108 acres) 

would not be re-allocated as wilderness (land use allocation A2) and the Crystal Springs 

Watershed Special Resources Management Unit would not be created. Summer and winter 

recreation would continue in the current manner, under the current land use allocations. As a 

result, this alternative would contribute less toward enhancing the remote backcountry 

experience some user’s value. Therefore, this alternative would contribute less to the range of 

cultural, social, and spiritual needs of wilderness recreationists. Hence, contributions to their 

well-being and sustainability would be less than Alternative 2. However, without a wilderness 

designation the area would continue to provide motorized and mechanized forms of access (for 

example, mountain biking) and therefore would offer higher well-being for this user group than 

under Alternative 2. 

Because the Crystal Springs Watershed Special Resources Management Unit would not be 

created in this alternative, these acres would not be managed to meet to specific needs for the 

protection of the quality and quantity of the Crystal Springs Watershed. As a result, Alternative 2 

would contribute more toward ecosystem services, specifically a clean drinking water source for 

the residents of Hood River County. Hood River residents would continue to benefit from the 

proximity of the National Forest and the existing ecosystem services, including water quality 

protection. However, they would not benefit from the targeted resource management provided 

under the proposed action.

Alternative 2 – Proposed Action

The proposed action includes the conveyance of two parcels totaling approximately 109 acres of 

NFS lands adjacent to Government Camp in exchange for the acquisition of approximately 

769 acres of land owned by Mt. Hood Meadows Oregon, LLC. Once the Federal parcels are 

conveyed, the land would be available for development subject to the requirements in the 

Government Camp Village Revitalization Plan and the Clackamas County Comprehensive Land 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

262

Use Plan. The original legislation requires trail easements, while the Clarification Act specifies 

the Forest Service to reserve a 24-foot-wide, non-exclusive trail easement at the existing trail 

locations on the Government Camp parcels. The Clarification Act has not yet been passed by 

Congress, but both actions are discussed below.

The Omnibus Act identifies approximately 769 acres located in Hood River County as the nonFederal estate. Approximately 514 acres are located outside the current Forest Service 

administrative boundary. The non-Federal estate is comprised of three diverse property types 

situated in the vicinity of the Cooper Spur Ski Area on the northeast flank of Mt. Hood. The 

three types are: the structures and personal property at the Cooper Ski Area, land and all 

development at the Cooper Spur Mountain Resort, and mostly vacant forest land. Because the 

underlying land at the ski area is already federally owned and administered, only the 

infrastructure, including lifts, is considered in the estate to be conveyed. The special use permit 

area would be reduced from 1,172 acres to about 60 acres. 

Mt. Hood Wilderness and the Crystal Springs Watershed Special Resources Management Unit 

(Forest Plan land use allocation A14) would be created.

The proposed action involves issuing a special use permit(s) for the concession operation and 

maintenance of the Cooper Spur Ski Area and Cooper Spur Mountain Resort. The term of the 

permit(s) would be for 20 years with an option to extend the permit(s) another 20 years noncompetitively if the permittee operates at a sustained satisfactory level. However, if there is no 

interest expressed for concessionaire operation and maintenance of the Cooper Spur Ski Area 

and Cooper Spur Mountain Resort, a prospectus would be developed to consider the need to 

keep the structures administratively. If the buildings are determined to be in excess to the 

government’s need, a disposal process would be triggered.

Social Conditions

Population Size, Growth and Density

As mentioned in the “Affected Environment” section, a portion of population growth in this 

region can be attributed to the scenic beauty and outdoor recreation supported by the Mt. Hood 

National Forest. Communities surrounding the Mt. Hood National Forest are attractive as places 

to live due in part to their proximity to open spaces and natural settings which provide residents 

with easy access to recreational opportunities year round. Under all the alternatives, these open 

spaces and natural settings would continue to support quality of life for area communities and be 

a contributing factor to population growth. For communities where development is less desired 

in the project region, Hood River County for example, this alternative would convey private 

property to public ownership acting as a protection to those parcels from development and a 

buffer to potential development. This protection from development and buffering effect would 

provide greater welfare and non-use values compared to the no-action alternative. 

In exchange for the protection from development through public ownership in Hood River 

County, Federal lands would be placed in private ownership in Clackamas County. It is assumed 

that these properties would be developed into residential units subject to state and county laws, 

building codes, and zoning regulations. The assumed level of development would increase the 

total housing units in Government Camp by close to 40 percent. As mentioned in the “Existing 

Condition” section, only 16 percent of existing units are used as primary residences. It is 

unknown whether and to what extent these new units would be used as primary versus secondary 

residences. That is to say, it is unknown the effect this development would have on the 

population count of the community. The community’s considerable seasonal residences are due 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

263

to the desirable qualities such as open space, natural setting and recreational opportunities 

provided. Regardless, the proposed alternative would result in increased population, visitors and 

users to the area. 

Human Uses and Values

Government Camp

Under Alternative 2 the existing Forest Service trails on the Government Camp parcels would be 

placed under easements, and should the Clarification Act be passed by Congress they would be 

non-exclusive, 24-foot-wide trail easements. Non-exclusive means the trails could be relocated 

to facilitate development by the land owner. The assumption was made that the location of trails 

outside of the proposed parcels to be conveyed would not change; however, it is assumed likely 

that the location of the trails within the parcels proposed for conveyance would change should 

the Clarification Act pass, which would allow this. 

The relocation of these trails would affect the properties in Government Camp as access to these 

trails provide residents of and visitors to the housing units one means of convenient access to 

recreation opportunities. The direction and magnitude of this effect on the community as a whole 

is not possible to determine at this time as any trail relocation will have both winners and losers 

in terms of proximity and relative ease of access due to relocation of trails. 

The width of the trail easement would be 24 feet total under the Clarification Act. This width 

would indirectly affect the future management of the trail system. The intent of the Government 

Camp Trails Project (2009) was to increase the amount of groomed trail on the Mt. Hood 

National Forest outside of developed ski areas for Nordic skiing (see Recreation Specialist 

Report for more details). The width of the proposed trail easement would likely be insufficient to 

accommodate the appropriate equipment for winter grooming operations. Therefore, this 

alternative could directly and negatively affect the welfare of this community of users. 

The result of the development surrounding the Government Camp trail system could also 

negatively affect users’ enjoyment and scenic beauty of these trails due to changes in location 

and nearby developments as well as potential trail discontinuity and changes in safety due to 

additional road crossings. If so, it could be that users may choose to use alternative sites and 

trails which might adversely impact local business, such as guiding businesses. 

Cooper Spur

A connected action in Alternative 2 would re-allocate Forest Service lands as wilderness and the 

Crystal Springs Watershed Special Resources Management Unit would be created. This 

alternative would contribute toward enhancing the remote backcountry experience many users 

value. Therefore, this alternative would contribute to the range of cultural, social, and spiritual 

needs of wilderness recreationists. Hence, contributions to their well-being and sustainability 

would be greater than the no-action alternative. However, a wilderness designation would make 

lands less accessible to users who currently may access these lands through mechanized or 

motorized means, such as mountain biking and snowmobiling, thereby reducing this community 

of users’ well-being. 

There are economic effects of a wilderness designation related to recreation, cultural heritage, 

on-site hunting, and commercial guiding and outfitting. Wilderness attracts tourists and generates 

visitor spending in communities nearby as people value wilderness for recreation opportunities. 

Studies have been done to help document this employment and income generated by wilderness 

visitation (for example, Hjerpe et al. [2016]). However, several factors in the Mt. Hood National 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

264

Forest complicate the economic assessment of recreation benefits of wilderness designation. 

Namely the relative scarcity of wilderness as a number of acres are already designated. That is, 

the marginal value of each additional acre is expected to decrease and the marginal value is 

unknown. In addition, the self-limiting nature of parts of the Forest means that, in practice, many 

non-designated areas are already protected from motorized access. In these instances, the 

wilderness designation may add limited value in terms of direct recreational use. However, other 

non-market values of wilderness designation are discussed below.

The Recreation Specialist Report also discusses impacts to recreational users in greater detail. 

Non-market Values

The proposed action would recommend an additional 1,709 acres of wilderness, which 

represents an approximately 2.5 percent increase within the Mt. Hood National Forest, as well as 

create the Crystal Springs Watershed Special Resources Management Unit. The social value of 

wilderness is not limited to recreation (as discussed above). Wilderness and this special 

management area may provide amenity values to nearby residents and landowners, support 

ecosystem service provision (for example, clean water and carbon sequestration), and offer 

opportunities for research and environmental education. Indeed, the purposes of the Crystal 

Springs Watershed Special Resources Management Unit are to ensure the protection of the 

quality and quantity of the Crystal Springs Watershed as a clean drinking water source for the 

residents of Hood River County, Oregon; and, to allow visitors to enjoy the special scenic, 

natural, cultural, and wildlife values of the Crystal Springs Watershed. Designated wilderness 

may also protect “non-use” values. Non-use values arise not from the consumption of goods or 

services provided by wilderness areas, but from the value of knowing it exists or preserving the 

option to visit in the future. The proposed action would do more to support social and nonmarket values related to wilderness and specially managed lands than the no-action alternative.

Economic Benefits

Local Government Taxes and Revenues

The proposed action would remove private property from the Hood River County tax rolls 

placing the land under Federal management. Clackamas County would see the opposite result 

having Federals lands placed into private ownership. As a result, this alternative would have 

opposite effects to the two counties revenues. 

Under the proposed alternative Hood River County would see a decrease in county revenues 

because the increase in PILT and Forest Service payments would not fully offset the decrease in 

county property tax revenues. The direct effect is estimated to be an annual decrease of less than 

0.5 percent of 2015 total county revenue. 

Under the proposed alternative Clackamas County would see an increase in property tax revenue 

due to the conveyance of Forest Service parcels into private ownership as county property tax 

revenues are estimated to exceed the loss in Federal payments. The degree to which the county 

tax revenues increase in Clackamas County will be contingent on the development which occurs 

and the assessed value of the development. Therefore, the potential effects are unknown, but 

estimated. It is estimated the annual increase in tax revenue could range from 0.01 percent of 

2015 total county property tax revenue on the undeveloped parcels to 0.1 percent of total county 

property tax revenue if the parcels are developed. 

The above effects indicate changes in county revenues as a result of the proposed action. This, 

however, does not consider changes or avoided county expenditures which these taxes are levied 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

265

to cover. For example, Clackamas County and Government Camp could incur additional costs 

from the new residential development for public services such as roads and maintenance, law 

enforcement, or schools. The decrease in private lands could result in avoided costs in Hood 

River County for similar public services. 

Forest Service Revenues and Expenses 

Alternative 2, the proposed action, would have direct and indirect financial implications for the 

Forest. 

Land Exchange and Connected Actions

A direct result of Mt. Hood National Forest acquiring new lands and the connected actions of the 

wilderness designation and management area designation would be both one-time costs as well 

as annual or intermittent costs that are incurred. One-time costs are expected to include, but are 

not limited to: boundary surveying and boundary marking, new signage, staff time to develop 

forest plan amendments and issuing special use permit prospectus. (Costs related to the special 

use permit for the Cooper Spur Ski Area and Resort and the related structures are discussed in 

the following section.) These costs are not expected to generate additional jobs or alter the 

absolute size of the Mt. Hood National Forest’s budget, but would result in an opportunity cost 

of Forest activities that are foregone or postponed as a result of the need to carry out these 

activates. 

Annual or intermittent costs incurred due to the proposed action (excluding the costs discussed 

related to the Cooper Spur Ski Area and Mountain Resort, discussed below) are expected to 

include, but are not limited to: changes in management due to the required use of primitive tools 

for maintenance on portions of trails within the designated wilderness area; Forest Service time 

related to administration of the special use permit.

Cooper Spur Ski Area and Mountain Resort

The acquisition of the Cooper Spur Ski Area and Mountain Resort would require development of 

a new special use permit. Special use permit(s) would be issued for the concession operation and 

maintenance of the Cooper Spur Ski Area and Cooper Spur Mountain Resort. The permit area for 

the Cooper Spur Mountain Resort and ski area under Alternative 2 includes 129 acres, a 

reduction of the existing special use permit for the ski area from 1,172 acres.

The proposed action is an administrative change that does not involve construction of new 

facilities or infrastructure. All of the sites currently exist, and management would continue with 

existing policies and regulations. Site improvements would be authorized with separate NEPA 

analysis. Land use and facility rental fees would be assessed annually based on revenues and/or 

the fair market value for the uses authorized. However, if there is no interest expressed for 

concessionaire operation and maintenance of the Cooper Spur Ski Area and Cooper Spur 

Mountain Resort, a prospectus would be developed to consider the need to keep the structures 

administratively. If the buildings are determined to be in excess to the government’s need, a 

disposal process would be triggered.

Two potential scenarios are analyzed for the subsequent administration of the facilities and 

equipment acquired by the Mt. Hood National Forest include: (1) fully operational ski area and 

resort; and (2) ski area is decommissioned while base facilities are repurposed and inn and resort 

is fully operational.

Fully operational ski area and resort. Special use permit(s) would be issued for the concession 

operation and maintenance of the Cooper Spur Ski Area and Cooper Spur Mountain Resort. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

266

Because the Forest Service would own the facilities in addition to the land which the 

concessionaire is operating the fees would be based on both revenues as well as a facility use fee. 

These fees would be collected under the authority of the Granger-Thye Act of 1950 (FSH 

2709.11 Chapter 30). The annual fees paid by Cooper Spur Ski Area in the past, based on 

revenues alone and collected under a term permit authority, have ranged widely from a minimum 

of $110.00 to $6,500.00. The minimum was assessed in recent years when the ski area did not 

open due to inadequate snow fall. The fees paid by any future concessionaire would not 

necessarily be similar due to the change in the special use permit permitting area, the change in 

ownership of the facilities, the different fee collection authority and the potential addition of the 

facilities at the Cooper Spur Mountain Resort. The annual fee for the Mountain Resort operation 

is not estimable at this time. At the time the appraisal is complete a better assessment of fee may

be possible. The fees from the ski area and resort are expected to remain variable due to the 

seasonal nature of the weather-dependent business operation.

The acquired facilities however, would require investment to meet operational standards. An 

assessment finds the facilities in need of “urgent corrective action” and “immediate upgrade”, as 

well as maintenance which can be deferred for 3 to 10 years or more (USDA Forest Service 

2012). Table 80 shows these estimated costs of repairs to the ski area and resort by the indicated 

urgency level.

The Granger-Thye Act fee offset authority, allows the concessionaire to perform pre-agreed upon 

work, as well as emergency maintenance as a fee offset. The work is outlined in an annual or 

5-year Granger-Thye Act plan. Therefore, this fee collection authority provides an offset to the 

facilities upgrades and maintenance outlined in the property condition assessment report. The 

fees are not estimable at this time however, given the estimated repair costs the fees required to 

cover these costs can be calculated. Table 83 shows the estimated costs and required fees to 

cover these costs over different time periods. If the “urgent corrective actions” and “immediate 

upgrades” are incurred in years 0 and 1, an assessed permit fee of over $59,000 annually for 

5 years is required to cover these costs. However, if a longer time frame—10 years—is allowed 

for cost recovery additional maintenance costs will also be incurred, but the longer timeframe to 

recover costs reduces the total required fee to under $40,000 annually. 

Table 83. Permit fees required to cover estimated repair costs over 5 years and 10 years

Net Present Value Annual Fees 

Required

Repair Totals, 0–1 years (urgent and 

immediate upgrades)

$265,601 5-Year Fee Plan: $59,661

Repair Totals, 0–10 years (urgent, immediate,

and deferred maintenance) 

$307,987 10-Year Fee Plan: $37,972

Source: Repair Costs are based on USDA Forest Service (2012) and updated to 2015 dollars using Bureau of Labor 

Statistics Consumer Price Index. Repair costs are assumed to be incurred in years 0, 1, and 3. A 4 percent real discount 

rate is used. Future inflation is assumed to be zero.

Ski area is decommissioned while base facilities are repurposed and inn and resort is fully 

operational. Special use permit(s) would be issued for the concession operation and 

maintenance of the Cooper Spur Mountain Resort with the base area facilities repurposed for 

additional resort activities. The ski lifts would be decommissioned. Because the Forest Service 

would own the facilities in addition to the land which the concessionaire is operating the fees 

would be based on both revenues as well as a facility use fee. These fees would be collected 

under the authority of the Granger-Thye Act of 1950 (FSH 2709.11 Chapter 30). The annual fee 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

267

for the Mountain Inn Resort operation are not estimable at this time. At the time the appraisal is 

complete a better assessment of fee may be possible. The fees from the resort are expected to 

remain variable due to the seasonal nature of the business operation. However, the Forest 

revenues from the resort are expected to be variable due seasonality of visitation. Also, without 

the ski area operation, which is highly seasonal and dependent on weather conditions, the 

variability could be less than the above scenario. Further, the total revenue may be lower as well 

without the business generated from the ski area operation. 

The repair schedule and fee calculations to cover repairs are the same as the above scenario. This 

scenario assumes all facilities, excluding the ski lifts, are repaired and repurposed for resort use. 

Under this scenario, the ski area would not be operated. There are several methods to dispose of 

these facilities. These alternatives are discussed in detail in the Facilities Specialist Report. This 

report considers only the decommissioning option which comes at an expense to the Forest 

Service. The estimated cost of decommissioning the ski lifts is $100,000 (personal 

communication with Rithy Bein, Civil Engineer, Mt. Hood National Forest). There are no fees or 

revenues to offset this cost. The opportunity cost of this action would be the activities the Forest 

cannot pay for due to the funds being spent on decommissioning.

Environmental Justice

The proposed action results in improvements in environmental quality and improved recreation 

opportunities for many users. The proposed land exchange is estimated to result in lower county 

revenues in Hood River County which could have potential effects on county services. However, 

the decrease in revenue is very small and not expected to affect environmental justice 

communities. 

The Confederated Tribes of Grand Ronde and Warm Springs would lose access to 109 acres of 

ceded land for traditional uses through the conveyance of the Government Camp parcels. The 

assumption is that the land conveyance would result in an adverse effect to this cultural resource. 

In exchange for the Government Camp parcels, Mt. Hood National Forest would acquire 

approximately 769 acres on the east side of Mt. Hood (Cooper Spur parcels), of which all would 

be Confederation Tribes of Warm Springs ceded land. The acquired parcels are located further 

from the Confederation Tribes of Warm Springs reservation. While this alternative results in a 

net increase of ceded lands, the location and makeup of the parcels are not equivalent impacting 

access and use. 

One of the connected actions associated with this land exchange is the re-assignment of 

1,709 acres of Forest Service “matrix” lands to wilderness. As a result of this re-assignment, use 

of these lands by the Confederate Tribes of Warm Springs for traditional use would be restricted. 

The Cultural Resources and Treaty Rights Specialist Report documents in further detail the 

consultation efforts with the tribes and the potential mitigation activities are currently under 

discussion. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

268

Table 84. Resource indicators and measures for alternative 2 direct and indirect effects 

Resource 

Element

Resource 

Indicator

Measure

(quantify if 

possible)

Alternative 2 

Direct and Indirect Effects

Social Conditions Population size, 

growth and 

density

Change in housing 

units

Government Camp would see 

approximately 40% increase in total 

housing units

Human Uses and 

Values

Recreation Qualitative 

evaluation

Enhances the remote backcountry 

experience increasing welfare of 

wilderness recreationists

Decreases well-being of mechanized 

and motorized access user groups

Government Camp Trail relocation and 

nearby development could affect users’ 

enjoyment and scenic beauty of these 

trails as well as safety

Human Uses and 

Values

Property values Change in property 

values (Qualitative)

Moving trail location in Government 

Camp would have indeterminate effects 

on property values with some units 

benefiting while others negatively 

impacted

Human Uses and 

Values

Non-market 

values

Qualitative 

evaluation

Increases social and non-market values 

related to amenity, option and 

preservation values and ecosystem 

services

Economic Benefit Local 

government 

taxes and 

revenues

Percent of 2015 

County Property 

Tax Revenue

Hood River County: annual decrease of 

less than 0.5%; 

Clackamas County: annual increase 

ranging 0.01–0.1%

Economic Benefit Forest Service 

revenues and 

costs

Qualitative 

evaluation; net 

present value

One time and annual increases in costs 

for implementation and management

Fees generated by special use permit 

needed to offset urgent and immediate 

maintenance: approximately $60,000/5 

years or $40,000/10 years

Additional costs contingent on need to 

decommission acquired ski lift facilities: 

$100,000

Environmental 

Justice

Disproportionate 

and adverse 

effects to lowincome and/or 

minority 

populations

Qualitative 

evaluation

Improvements in environmental quality 

and recreation opportunities for most 

users

Net increase of ceded lands-the location 

and makeup of the lands are not 

equivalent

Reassignment of acres to Wilderness 

restricts traditional uses

Forest Plan Amendment Summary

A programmatic forest plan amendment is needed to assign LUAs to the newly acquired land, 

change the land use allocations for the Wilderness addition and Crystal Springs Watershed 

Special Resource Management Unit, and add standards and guidelines for the Crystal Springs 

Watershed Special Resource Management Unit. These changes would contribute toward

enhancing the remote backcountry experience many users value. Therefore, these LUA changes 

would contribute to the range of cultural, social and spiritual needs of wilderness recreationists. 

However, a wilderness designation would make lands less accessible to users who currently may 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

269

access these lands through mechanized or motorized means, such as mountain biking and 

snowmobiling, thereby reducing this community of users’ well-being. 

Cumulative Effects

The spatial boundaries for analyzing the cumulative effects to social and economic conditions 

are the same as that for direct and indirect effects, which includes the counties of Clackamas and 

Hood River. Individuals who reside in these counties are most directly impacted by the proposed 

action as well as any past, present, and reasonably foreseeable activities relevant to the 

cumulative effects analysis. However, communities of users and visitors to Mt. Hood National 

Forest reside outside the study area and are addressed where appropriate. 

The temporal scope extends from present through 20 years, which is the expected length of any 

initial special use permit issuance. The action is a one-time event, but social and economic 

consequences would continue to impact communities. Unmeasurable impacts would continue 

into the future.

Alternative 1

There is the potential for development on private lands in the study area. Scoping comments 

suggested development was undesirable in Hood River County and could adversely affect 

quality of life due to changing the character or quality of the area for recreation users and 

potential increases in traffic. Under Alternative 1 there is more private land available for 

development and could result in cumulative effects in the region when considered with other 

potential development on private lands. This would also impact both county revenues and costs. 

Since there are no direct or indirect effects to environmental justice in Alternative 1, there would 

be no environmental justice cumulative effects. 

Cumulative effects related to recreation and facility management are addressed in the relevant 

specialist reports.

Alternative 2

Development is always possible on other privately owned lands throughout the study area. 

Development would result in changes in local tax revenues and impacts to the costs of county 

services. The magnitude of the changes to revenues in the proposed action is small and unlikely 

to be contributing in any meaningful way to impacts on revenues from development in other 

parts of the study area. 

None of the past, present, or reasonably foreseeable activities would affect economic efficiency 

because none of the activities would affect the costs or revenues associated with the proposed 

land exchange. 

The Government Camp-Cooper Spur land exchange is directed by the Omnibus Public Land 

Management Act of 2009 (123 Stat. 991, P.L. 111-11), which also directed additional wilderness 

designations of lands in the Mt. Hood National Forest. The cumulative effects of other 

wilderness lands means the marginal value of additional wilderness acres is decreasing, however 

the total recreation and non-market values would be larger with the additional wilderness. 

Additional wilderness designated lands also results in additional areas where traditional use by 

Indian tribes would be restricted. 

The effects to social and economic resources are summarized in table 85. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

270

Table 85. Summary comparison of environmental effects to social and economic resources 

Resource Element

Measure

(quantify if possible) Alternative 1 Alternative 2

Social Conditions Population and change in 

housing units

Current rate of population growth in 

region would likely continue.

Government Camp would see approximately 40% increase in 

total housing units. This is expected to largely impact seasonal 

use and not population levels, but would impact needed 

county services and Mt. Hood National Forest visitation.

Human Uses and 

Values: Recreation

Qualitative evaluation Residents and visitors to Government 

Camp would continue to use and enjoy 

the existing trail system.

Development in Government Camp could negatively impact 

users enjoyment and safety on existing trail segments

Enhances the remote backcountry experience increasing 

welfare of wilderness recreationists

Decreases accessible area for mechanized and motorized 

access user groups

Human Uses and 

Values: Property 

Values

Change in property 

values (qualitative)

No new development and no changes 

to existing trail system results in no 

direct effects to property values in 

Government Camp.

Moving trail location in Government Camp would have 

indeterminate effects on property values with some units 

benefiting while others negatively impacted.

Human Uses and 

Values: Non-market 

values

Qualitative evaluation Mt. Hood National Forest will continue 

to provide social and non-market values 

to users and non-users. However, 

without the targeted management 

efforts, the values will be lesser than 

under alternative 2. 

Supports greater social and non-market values related to 

amenity, option, and preservation values and ecosystem 

services than alternative 1.

Local Government 

Taxes and Revenues

Percent of 2015 County 

Revenue

No changes to county revenues. Hood River County: annual decrease of less than 0.5% 

Clackamas County: annual increase ranging 0.01-0.1%

Forest Service 

Revenues and Costs

Qualitative evaluation; 

net present value

No changes to costs and revenues. Forest Service would see one time and annual increases in 

costs for implementation and management of new lands and 

plans. The fees generated by special use permit needed to 

offset urgent and immediate maintenance of newly acquired 

facilities are significant. Additional costs could be incurred, but 

are contingent on need to decommission acquired ski lift 

facilities should no concessionaire be found. The costs to the 

Forest Service are greater under alternative 2. 

Environmental Justice Qualitative evaluation No effects to environmental justice 

communities.

Alternative 2 results in improvements in environmental quality 

and improved recreation opportunities for most users. There is 

a net increase of ceded lands; however, the location and 

makeup of the lands are not equivalent. Reassignment of 

acres to wilderness restricts traditional uses for Indian tribes.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

271

Soils, Wetlands and Water Rights

Introduction

This section addresses terrain, soil, and wetland resources in the project areas that could be 

affected as well as water rights. Interpretations and descriptions contained in this report rely 

heavily on local information derived from the soil surveys of Clackamas and Hood River 

Counties (USDA NRCS 1985 and 1981), the Mount Hood National Forest Soil Resource 

Inventory (USDA Forest Service 1979), digital spatial data in the Forest Service’s corporate 

Geographic Information System (GIS), and other local reports as cited. These information 

sources were used along with topographic and geologic maps, aerial photographs, watershed 

analyses, and field-based reconnaissance and sampling to characterize local conditions and 

support evaluation of the potential environmental consequences of the proposed land exchange.

Affected Environment

Government Camp Parcels

The parcels to convey adjacent to Government Camp are located on the lower southern slopes of 

Mt. Hood, a glaciated volcano. Terrain was formed by pyroclastic and debris-flows deposited 

during several former primary eruptive periods, the most recent occurring between about 1,400 

to 1,800 years before present. Slopes are gentle to moderately steep (averaging 5 to 15 percent) 

and fairly uniform. 

Soils underlying the parcels developed in loosely consolidated parent materials comprised 

chiefly of highly mixed andesite and dacite rocks and sands, and volcanic ash. The Mt. Hood 

National Forest Soil Resource Inventory (SRI, USDA Forest Service 1979) identifies several 

dominant soil types with a similar range of characteristics, capabilities, sensitivity, and 

resilience. They comprise about 87 percent of the total acreage of the conveyance parcels.

They are relatively young soils that have incurred nominal development, meaning they have 

weak structure and cohesion, a somewhat thin topsoil, and have low organic content. These are 

moderately acidic soil types, with a somewhat low nutrient status. Surface soils are mostly 

gravelly medium-textured loams, sandy loams, or silt loams over deep subsurface layers of 

coarser cobbley sandy loams. Litter and duff layers provide a nearly continuous layer of 

protective ground cover that is partially densified by the weight of a 3- to 4-foot deep snowpack 

that develops and persists through the winter in most years. 

These soils are capable of producing and supporting fully stocked stands of high-elevation 

coniferous forest, principally because of the prodigious annual precipitation. But since the 

elevation is fairly high, the soil temperature regime is cold, and the growing season relatively 

short, so the degree of forest productivity (i.e., growth rate) is considered to be low to moderate.

These are permeable, well-drained soils with moderate to high infiltration rates, and moderately 

low runoff potential. Erosion hazard of surface soils is slight, but moderate in subsurface soils. 

The risk of mass movement is low. Their susceptibility to compaction is low to moderate. 

Overall, these soil types are not considered to be sensitive, but because of their thin topsoil, low 

organic content, weak structure, and the elevation they are moderately prone to disturbance and 

their inherent resilience to naturally recover can be low to moderate. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

272

Sensitive Soils

Within these dominant soil types are contrasting inclusions. These are wetland soils and they 

comprise about 8 percent (9 acres) of the total acreage of the conveyance parcels. Categorized as 

hydric soil types, these are permanently saturated at the surface and are either headwater springs 

or locations of high water tables. They support emergent vegetation, hardwood shrubs, or in 

places coniferous forest and function to regulate hydrologic vacillation and sediment production, 

produce organic matter, buffer nutrients and pollutants, and provide unique aquatic habitats. 

Hydric soil types are considered to be sensitive to disturbance because they are saturated, 

flooded, or ponded throughout the growing season. Once impaired, or hydrologically altered as a 

result of ground disturbance, their functional capability is easily diminished and can be 

problematic to restore.

Soil Conditions

Soil resources in the conveyance parcels are considered to be mostly in an undisturbed condition 

and unimpaired. The extent and footprint of prior human-caused ground disturbance is not 

widespread. Commercial timber harvest has not been a principal management objective. 

Compaction is present in powerline and an old gondola corridors as access roads, there are also 

foot trails, and a couple of other old dirt road segments. Overall, however, it is estimated that 

detrimental soil impacts comprise less than 5 percent of the conveyance parcel acreage.

Soil quality across the majority of the parcels is in relatively good condition. Soils are 

functioning to support and maintain a growing native forest. They are mostly functioning to their 

capability, and despite some prior disturbance serving as a growing medium, storing and cycling 

nutrients and water, producing biomass, and supporting or regenerating a contiguous vegetative 

cover.

Cooper Spur Parcels 

The parcels to acquire adjacent to the Cooper Spur Mountain Resort are located near the base of 

the northeastern slopes of Mt. Hood, a glaciated volcano. Terrain is variable and mountainous, 

consisting of broad gently sloped ridges and benches dissected by a couple of steep narrow 

ravines and several weakly defined drainages; and moderately steep mountain side slopes. On 

average, slopes range between about 5 and 15 percent, but in several places they slant to 40 

percent or more. Their shape transitions from concave to convex, but in places on the broad 

ridges and benches, they tend to be uniform.

The most extensive (over 85 percent of the parcel’s acreage) soil types underlying the parcels 

developed in volcanic ash and mixed gravelly colluvium with high proportions of pyroclastic 

materials and andesite (USDA NRCS 2016). They have undergone a moderate degree of 

development, and have a lighter colored leached surface horizon that overlies a subsoil with 

good structure where organic carbon, aluminum, and iron has accumulated from above. Slightly 

acidic, these soils have a moderately good nutrient status. Surface and subsurface soils are 

mostly ashy, fine sandy loams that overlie a buried rocky, loamy glacial till. On the surface, a 

litter and duff layer provides a continuous effective ground cover.

These soils receive a prodigious amount of annual precipitation and are capable of producing and 

supporting fully stocked stands of mid-elevation coniferous forest, and can support over-stocked 

stands, too. The elevation is somewhat high and the soil temperature regime cold. These soils

store a good amount of water late into the growing season, so the degree of forest productivity 

(i.e., growth rate) is considered to be moderate to moderately high.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

273

These are very deep, well-drained soils that are moderately permeable, with a moderate 

infiltration rate and moderate runoff potential. They have good water-holding capacity. The 

erosion hazard is moderate to high and the mass movement potential is moderate, depending 

upon the degree of slope. Their susceptibility to compaction is moderate to high. Overall, these 

soil types are not considered to be sensitive. Because they are deep, with lots of volcanic ash, 

have a high water-holding capacity, a fair amount of organic carbon, and moderate to moderately 

high productivity, these soils not overly prone to ground disturbance, and exhibit a moderately 

high degree of resilience. They have an inherent capability to recover from disturbance.

Other soils of minor extent are located in several narrow, confined ravines. They are rocky soils 

that are somewhat shallow (less than 40 inches deep), less developed, and are ashy sandy loams 

that overlie andesite. Their side slopes are steep (50 to 70 percent). They comprise less than 

15 percent of the parcel’s acreage. 

Sensitive Soils

Inclusions of wetland soils are also present in the bottom of one of the ravines and in a swale. 

These are hydric soils and they comprise less than 1 percent (4 acres) of the acreage (WPN 

2010). They support emergent vegetation, hardwood shrubs, or, in places, coniferous forest and 

function to regulate hydrologic vacillation and sediment production, produce organic matter, 

buffer nutrients and pollutants, and provide unique aquatic habitats. Hydric soil types are 

considered to be sensitive to disturbance because they are saturated, flooded, or ponded 

throughout the growing season. Once impaired, or hydrologically altered as a result of ground 

disturbance, their functional capability is easily diminished and can be problematic to restore.

Soil Conditions

Soils in the acquisition parcels have been subject to ground-disturbing activities, primarily in the 

form of past timber harvest and some rural/resort development. The footprint of prior humancaused ground disturbance is present on all parcels, and timber harvest consisted of groundbased logging systems that included access spur roads, primary and secondary skid trails, and 

landings. Compaction is present on these surfaces, and in places, vegetative recovery in terms of 

tree stocking and growth suggests that detrimental soil conditions persist to a moderate extent. 

On portions of some parcels, it is estimated that the extent of detrimental soil conditions exceeds 

10 to 15 percent of the acreage, while on others it is approximated to be between 5 to 10 percent. 

Currently, land use on these parcels consists mainly of rural recreational activities and private 

woodland management.

Soil quality across the majority of the parcels is fairly good. Soils are mostly functioning to their 

potential to support and maintain a growing native forest, although certain portions are less than 

fully stocked and exhibit growth rates that may not be to their full potential. Mostly, however, 

soils are functioning to their capability, and despite some prior disturbance, continue to serve as 

a growing medium, storing and cycling nutrients and water, producing biomass, and supporting 

or regenerating a contiguous vegetative cover.

Wetlands

A local wetland inventory was completed in 2010 for both the conveyance and acquisition 

parcels (WPN 2010). It identified the presence of wetlands, categorized their type, and 

delineated their location and extent. The inventory also assessed the function and values of each 

of the wetlands identified.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

274

Government Camp Parcels 

There are five areas on the conveyance parcels where wetlands have been identified. They 

amount to nearly 9 acres (8 percent of the total disposal acreage). They occur primarily in swales 

or drainageways. Most of these wetland areas are either forested or comprised of heavy brush, 

although one in the eastern parcel is dominated by emergent vegetation such as sedges. All can 

be characterized as either springs or having high water tables, and most are contributing 

headwaters to Camp Creek, although the most westerly ones drain to the pond known as Enid 

Lake in the Little Zigzag River drainage. 

The wetlands in the Government Camp parcels are considered to have high functional value for 

organic production and transport, amphibian habitat, and richness of native aquatic plants. They 

are also sources of cold, high quality water. All but one are considered to be undisturbed, in good 

condition, and functioning unimpaired. One, however, has been disturbed in the past, and is 

located between two road and trail corridors where there was prior land use. Its hydrology has 

been altered and its function is partially impaired.

Cooper Spur Parcels 

Two wetland areas have been identified on the acquisition parcels. They amount to about 4 acres 

(less than 1 percent), and are split nearly equally on each of the southern and northern parcels. 

One occurs along the long, narrow ravine of Tilly Jane Creek, and the other is in a long narrow 

swale that is tributary to Doe Creek. The former is a narrow floodplain adjacent to the creek and 

is forested with an emergent vegetation understory. The latter is mostly shrub and emergent 

vegetation. Both have high water tables and drain to the East Fork of Hood River.

These wetlands on the Cooper Spur parcels are considered to have high functional value for 

organic production and transport; good habitat for fish, aquatic vertebrates, mammals, and birds; 

and richness of native aquatic plants. They also convey cold water and filter sediment. The 

wetland in the Till Jane ravine is intact, in good condition, and functioning unimpaired. The 

other wetland, however, has been encroached upon by several rural home sites, a resort property, 

and several small adjacent dirt roads. It is also bisected by Cooper Spur road, but remains 

connected by a culvert. Although encroached upon, this wetland is in fairly good condition and 

continues to function with only slight impairment.

Water Rights

Water rights associated with the exchange parcels are recorded with the Oregon Water Resources 

Department (OWRD). The status, definition, and location of those water rights and any points of 

diversion have been queried using their online data base, the Water Rights Information System 

(OWRD 2016). Information acquired from that database has been compiled and is used here to 

characterize the associated water rights that are located within the boundaries of the exchange 

parcels. There are no federally reserved water rights within any of the exchange parcels.

Government Camp Parcels 

There are two private party water rights on record located within the Forest Service parcels to 

convey. Both are designated for domestic use, one for a single dwelling and the other for five. 

Summarized in table 86, both are in a “non-cancelled” status. There are no records in the Water 

Rights Information System of wells or groundwater use in the parcels to convey.

There are two Points of Diversion for Certificate 22582, one originates from National Forest 

System (NFS) land and the other on private land. Certificate 54668 has a single Point of 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

275

Diversion that originates on NFS land. A pipeline conveys the water to the Point of Use on 

private land for both water rights. The priority of the right for Certificate 22582 was confirmed 

in October of 1938, and extensions to complete the construction and improvement of the system 

was granted into 1953. But with the development and subsequent expansion of the Government 

Camp water system, the use of this certified water right is uncertain, as it may have been 

succeeded. The priority of the water right for Certificate 54668 was confirmed in December of 

1977, but there have been developments on the lot(s) since then that may have succeeded its use 

too.

Table 86. Summary of water rights in the Government Camp Parcels (OWRD 2016)

Permit or 

Certification No.

Tshp., 

Rng., Sec.

Type Use Point(s) of 

Diversion

Point of 

Use

Status

Cert. 22582 3S, 8.5E,

14

Surface 

Water,

forks of 

Camp Ck. 

(2)

Domestic Lot 3, NW 1⁄4 

SW 1⁄4 (USFS) 

& Lot 4 SW 1⁄4 

SW 1⁄4 (PVT)

Lot 4 SW 1⁄4 

SW 1⁄4 (PVT)

Noncancelled

Cert. 54668 3S, 8E, 13 Spring Domestic Lot 3, SE 1⁄4 

SE 1⁄4 (USFS)

3S, 8E, 24, 

NW 1⁄4, NE 

1⁄4 (PVT)

Noncancelled

Cooper Spur Parcels 

Table 87 summarizes the water rights recorded with OWRD that are within the acquisition 

parcels in the Cooper Spur area. Four of them are in a non-cancelled status, but the fifth one, 

which was for a Dillard Reservoir, has been cancelled. All are private party holders. Certificate 

88981 is appurtenant to Tax Lot 103, which is the Cooper Spur Resort. It is the only water right 

designated for commercial use. Two other certificates also had Point of Use designations for the 

resort parcel, but both had points of diversion from another parcel and had priority dates in the 

late 1920s. So, while it’s unconfirmed, it is likely that they have not been used for some time. 

The rights that were used primarily for irrigation to support livestock are also quite old, with 

priority dates from the early 1900s, and it’s questionable when they were last in use. 

Table 87. Summary of water rights in the Cooper Spur Parcels (OWRD 2016)

Permit or 

Certification 

No.

Tshp., 

Rng., Sec.

Type Use Point of 

Diversion

Point of 

Use

Status

Cert. 8190 2S, 10E, 6 Surface

Water,

Buck Ck.

Irrigation,

Domestic

Tax Lot 102 Tax Lots 

102, 103

Noncancelled

Cert. 10729 2S, 10E, 6 Spring Domestic Tax Lot 401 Tax Lot 103 Noncancelled

Cert. 15034 2S, 10E, 6 Surface

Water,

Unnamed

Irrigation Tax Lot 102 Tax Lot 102 Noncancelled

Cert. 88981 2S, 10E, 6 Well Commercial Tax Lot 401 Tax Lot 103 Noncancelled

Permits R12474 and 

R-12475

2S, 10E, 6 Reservoir,

Dillard

Fire 

Protection,

Fish & 

Wildlife

NE 1⁄4 SE 1⁄4 Same Cancelled
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

276

Well logs recorded with OWRD indicate that several wells were drilled in the vicinity of 2S 10E 

6, tax lots 102 and 401; however, most were abandoned because of inadequate or no water. 

According to the well logs, there are wells on tax lots 102 and 401. One of those, bore hole 

HOOD 517, was reconditioned, and is most likely the well associated with certificate 88981 for 

the Cooper Spur Resort.

Environmental Consequences

Effects of implementing any one of the alternatives have been analyzed based upon the 

regulatory framework that would be appurtenant to the type of land use. Public lands that would 

be administered by the Forest Service would be used based upon the standards and guidelines of 

attendant management plans and other applicable directives and Federal law. The use of private 

lands would be as per the individual land owner in accordance with State and county laws and 

zoning, and other Federal regulations, as applicable.

Direct and Indirect Effects

Alternative 1 – No Action

There would not be an exchange of lands under this alternative, and parcels would remain in 

their existing ownership. NFS lands would be administered as they currently are being used. 

Private lands would be used as is presently exercised by the current owner. Management of soil 

resources, wetlands, and water rights would remain as is.

Soil Resources

Government Camp Parcels

On the Federal parcels in Government Camp, soil resources would continue to be managed 

according to Standards and Guidelines of the Mt. Hood Land and Resource Management Plan 

(LRMP, USDA Forest Service 1990), as amended by the Northwest Forest Plan (NFP, USDA 

Forest Service and USDI BLM 1994). Regionally adapted agency directives including the 

programmatic Forest Service Manual and the activity-specific Forest Service Handbook would 

also guide any actions or management of soil resources on the Federal parcels.

Ground-disturbing activities in addition to current recreational use on existing trails or access on 

existing segments of road would not be expected to occur. Soils would remain in good condition 

and continue to function as a principal component supporting forest vegetation. They would be 

mostly unimpaired, providing ecosystem processes that transform, filter, store, and house water, 

nutrients, and biota. Existing soil conditions on the Government Camp parcels would not be 

expected to change. The current extent of detrimental soil conditions would not be expected to 

expand or diminish, and would remain in present form on compacted trails and segments of 

access roads. Sensitive hydric soil types would remain in an undisturbed condition.

Cooper Spur Parcels

Soils on private lands on the Cooper Spur tracts would continue to be used for rural home and 

recreational sites and woodland management. The footprint of prior human-caused ground 

disturbance would remain at its current extent on all parcels where there are cleared driving 

surfaces such as access spur roads/driveways, parking areas, old primary and secondary skid 

trails, and old landings. Detrimental soil conditions would persist on these surfaces to a moderate 

extent.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

277

Soil quality across the majority of the parcels would remain in fairly good condition. Soils would 

function mostly to their potential to support and maintain a growing native forest or other home 

site vegetation such as grass, although certain portions would remain less than fully stocked and 

exhibit growth rates that may not be to their full potential. Mostly, soils would function to their 

capability, and despite some prior disturbance, continue to serve as a growing medium, storing 

and cycling nutrients and water, producing biomass, and supporting or regenerating a contiguous 

vegetative cover. Sensitive hydric soil types would remain mostly unimpaired in their current 

condition.

Ground-disturbing activities that could occur as a result of woodland management like timber 

harvest, would be regulated by the Oregon Department of Forestry according to the Oregon 

Forest Practices Act, which includes provisions to minimize adverse impacts to soils. 

Improvements, upgrades, or additional development of resort properties could potentially occur 

that would be ground-disturbing, and could convert productive soils to a surface type for another 

use such as a building site or parking area. These kinds of actions would be in response to the 

inclinations of the landowner and regulated by county zoning regulations and building codes.

Wetlands

Government Camp Parcels

Wetlands (9 acres) in the Government Camp parcels would continue to be managed by the Forest 

Service as directed by standards and guidelines in the LRMP and NFP. The standards and 

guidelines in the LRMP are intended to protect or restore these areas. The NFP recognizes them 

to be Riparian Reserves, prescribes specific buffer widths to protect them even further, and 

encourages restoration if needed. 

The wetlands in the Government Camp parcels would remain in their current good condition and 

largely undisturbed and unimpaired. They would continue to have high functional value for 

organic production and transport, amphibian habitat, and richness of native aquatic plants. Being 

springs or having high water tables, they would remain sources of cold, high-quality water 

contributing to the headwaters of Camp Creek and the Little Zigzag River drainage. 

Cooper Spur Parcels

In the Cooper Spur parcels the two wetlands (4 acres) would remain in private ownership. Any 

future development or construction within them would have to be authorized by the Oregon 

Division of State Lands and necessitate requisite review and permitting. Currently, few activities 

occur on them aside from minor, non-motorized recreational pursuits in the wetland adjacent to 

the resort and Cooper Spur Road. 

There is no road or trail access to the wetland in the bottom of the Tilly Jane Creek ravine, so it 

would be expected to remain mostly undisturbed and intact. The wetland next to the resort 

property that has been encroached upon slightly would also be expected to remain fairly 

unimpaired. Both of these wetlands would continue to offer high functional values for organic 

production and transport; good habitat for fish, aquatic vertebrates, mammals, and birds; and 

richness of native aquatic plants. They also would continue to store water and filter sediment.

Water Rights 

None of the water rights in the exchange parcels would change under the no-action alternative. 

There are no water rights on record in the name of the Forest Service in the exchange parcels. 

Water rights that are in a non-cancelled status would be expected to stay with their current right 

holders, and for the same beneficial uses unless transferred. No proof of use would be 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

278

anticipated. Any applications, permits, or certificates that are in a cancelled status could 

potentially become subject to re-application in the future through the OWRD application 

process. 

Alternative 2 – Proposed Action

Lands exchanged under this alternative, would be managed differently than they were

previously. National Forest System lands would be transferred to private ownership to be 

developed and used as residential and vacation properties. Laws or directives to conserve natural 

resources would no longer be administered by the Forest Service, rather they would be levied by 

other county, State, or Federal authorizations. 

Private lands that would be transferred to Federal ownership to become public domain would be 

used as per the ascribed LRMP land allocation as amended by the NFP, and the 2009 Omnibus 

Bill. The management of soil, water, and wetland resources would be provisioned by the 

standards and guidelines specified by the designated land allocation, and according to Forest 

Service policy directives.

Soil Resources

Government Camp Parcels

Land use in the conveyance parcels would change from natural resource and recreation 

management to residential land use. Standards and guidelines of the Mt. Hood LRMP for soil 

productivity would no longer apply to the parcels. Soil management objectives to provide 

ecosystem services and sustain natural resources would shift to supporting residential buildings 

and infrastructure.

Soils would be converted from mostly an undisturbed condition to residential development, and 

would no longer function to support the maintenance and growth of a native forest. The extent 

and footprint of human-related ground disturbance resulting from conversion to residential use 

would increase substantially, with impervious surfaces comprising up to 40 percent of individual 

lots. Soil quality across the majority of the parcels would be transformed. Only the remaining 

portions of individual lots that are not an impervious surface would be available to serve as a 

growing medium, to store and cycle nutrients and water, and to support vegetation.

Cooper Spur Parcels

Land use in the acquired parcels would change from private ownership to management of natural 

resources and recreation on public lands. Standards and guidelines of the Mt. Hood LRMP for 

soil productivity (FW-022 to FW-038) would be put into effect. Soil management objectives 

would shift to providing ecosystem services that sustain natural resources and beneficial uses 

specified by the designated land allocation.

Soil quality across the parcels would remain in their current condition, which is fairly good. The 

existing footprint of prior human-caused ground disturbance such as building sites, parking and 

driveways, access spur roads, former primary and secondary skid trails, and landings would not 

be expected to expand. Detrimental soil disturbance on these surfaces would continue to persist 

in the near-term, but could be expected to improve somewhat from their current status. The 

degree of improvement would depend on the issuance of a special use permit for a 

concessionaire to run and manage the Cooper Spur Mountain Resort. If a permit were to be 

issued for the resort, then soil conditions could be expected to remain as they are with 

incremental improvements as soil restoration opportunities arise such as reconditioning of some 

segments of old access road. If a permit was not authorized, then the resort site would be 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

279

expected to be decommissioned. An element of decommissioning would be reconditioning of 

compacted surfaces such as building sites, parking areas, and segments of road, so that soils 

could become productive again. Site decommissioning would result in restoration of detrimental 

soil conditions, notably reducing their extent on the acquisition parcels. 

In either circumstance, soils would continue to function mostly to their potential to support and 

maintain a growing native forest, although certain areas would remain less than fully stocked 

where growth rates would not be to their full potential. Mostly, soils would function to their 

capability, and despite some prior disturbance, continue to serve as a growing medium, storing 

and cycling nutrients and water, producing biomass, and supporting or regenerating a contiguous 

vegetative cover.

Wetlands

Nine acres of wetlands within the conveyance parcels would transfer from public to private 

ownership, while 4 acres would be transferred from private to public ownership. This would 

result in a net loss of 5 acres of wetlands from NFS lands. The local inventory of wetlands that 

was conducted for the exchange parcels included an assessment of function and values useful for 

making relative comparisons between individual wetlands based upon their ecological benefit. 

The methodology uses a series of rating scores that when summed generate a unit-less output 

value termed Functional Capacity Units (FCUs). Table 88 displays the FCUs that were 

determined for each site in the inventory’s assessment. 

Table 88. Comparison of functional capacity units (FCUs) for wetlands in the exchange parcels 

(WPN 2010)

Exchange Parcel FCUs Percent of Total FCUs Acres

Government Camp 625 65 9

Cooper Spur Parcels 337 35 4

Total 962 100 13

Government Camp Parcels

Wetlands in the conveyance parcels would no longer be managed and conserved by the Forest 

Service as Riparian Reserves. Regulatory authority and oversight for the protection of these 

wetlands would switch to the Oregon Division of State Lands who share the responsibility 

implementing Section 404 of the Clean Water Act, the principal statute for governing activities in 

wetlands, with the Oregon Department of Environmental Quality, the U.S. Army Corps of 

Engineers and the U.S. Environmental Protection Agency. Activities associated with residential 

development that could encroach upon the wetlands would have to undergo a review and 

permitting process according to Oregon Revised Statute before they would be authorized (ORS 

196.795-990).

A result of the proposed exchange would be that the wetlands acquired would have less function 

and value (i.e., ecological benefit) as represented by FCUs (table 88) than those that would be 

conveyed. The Forest Service would lose from its lands 9 acres of wetlands, and acquire 4 acres 

wetlands of a lesser ecological benefit. The inequity of the trade would not result in a loss of 

wetlands overall from the State because Section 404 of the Clean Water Act protects them from 

net loss regardless of ownership by the use of either on-site conservation easements or 

compensatory mitigation (i.e., funding the creation or restoration of wetlands at a different place 

and time and maintaining them in perpetuity). The proposed action would include conservation 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

280

easements, so the wetlands in the conveyed parcels would be protected according to regulation 

by the Oregon Division of State Lands. 

Conservation easements would minimize direct impacts to the wetlands on the conveyed parcels. 

Existing wetland vegetation, hydrologic connectivity, and hydric soils would not be subject to 

ground-disturbing activities and remain in good condition and unimpaired. Indirectly, there 

would be a high potential for heightened runoff and sedimentation as a result of development 

activities and a persistence of hardened surfaces. Mitigation measures and design features would 

be requirements to the Oregon Division of State Lands permitting process, and have to meet 

requirements of the National Pollutant Discharge Elimination System as regulated by the Oregon 

Department of Environmental Quality and their requirements for Section 401 certification of the 

Clean Water Act. 

All but one of the inventoried wetlands would continue to have high functional value for organic 

production and transport, amphibian habitat, and richness of native aquatic plants. They would 

remain on the landscape as springs or places of high water tables, and would be contributing 

sources of cold, high quality water to headwaters of Camp Creek or the pond known as Enid 

Lake in the Little Zigzag River drainage. There is one wetland, however, which has been 

disturbed in the past, and is located between two road and trail corridors in the western most 

parcel where there was prior land use. It would remain in its current altered and partially 

impaired condition. 

Cooper Spur Parcels

Wetlands in the acquisition parcels would become managed and conserved by the Forest Service 

as Riparian Reserves. They would remain in their current condition, and would be evaluated to 

determine if any restoration or enhancement opportunities might be needed. Conditions would be 

expected to change little from their current status in the near-term.

Existing vegetation in the two identified wetland areas would not be disturbed as a result of the 

exchange. Surveys would be conducted to detect the presence and extent of any invasive plants 

that may have encroached, and eradication measures would be planned. Both wetlands would 

continue to have high water tables and drain to the East Fork of Hood River.

Both wetlands on the Cooper Spur parcels would continue to provide high functional values for 

organic production and transport; good habitat for fish, aquatic vertebrates, mammals, and birds; 

and richness of native aquatic plants. They also would continue to convey cold water and filter 

sediment. The wetland in the Tilly Jane ravine would remain intact and in good condition, and 

functioning unimpaired. The other wetland, which has been encroached upon by the resort 

property, and several small adjacent segments of road would continue to be in fairly good 

condition, but functioning with slight impairment.

Water Rights 

None of the water rights on record within the exchange parcels are in the name of the Forest 

Service. Water rights would be conveyed with the exchange of the property unless specifically 

excluded from the property transaction deed or the buyer otherwise receives notice that interest 

in the water right was conveyed to another party, prior to the sale of the property. Any transfers 

would be in accordance with OWRD and their pertinent administrative rules.

Transfer applications are a tool for changing water rights. Transfer applicants are generally the 

owner of the land to which the water right(s) proposed for change are appurtenant. However, the 

transfer applicant may not always be the landowner. To complete a transfer application, the 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

281

applicant must be able to demonstrate that they are authorized to pursue the requested change. 

Pursuant to Oregon Administrative Rule (OAR) 690-380-4010 (5), the applicant must show, as 

of the time the application is to be proposed for approval that:

1. The applicant is the current owner of the lands to which the water right is appurtenant,

2. The current landowner has consented to the transfer application, or

3. The applicant holds sufficient interest in the water right to pursue the transfer application 

in the absence of the consent of the current landowner.

Water Right Conveyance Agreements provide a method for a water right transfer applicant to 

demonstrate that the applicant holds a sufficient interest in a water right to pursue the transfer. 

The critical elements of these agreements are: (1) a specific conveyance of the interest in the 

land and the water rights separately, and (2) recordation of the document in the deed records of 

the relevant county. A variety of legal documents that are typically used in real estate 

transactions may qualify as Water Right Conveyance Agreements under OAR 690-380-0100(13), 

including, but not limited to, Purchase and Sale Agreements, deeds, and Quit Claims.

OAR 690-380-0100(13) “Water right conveyance agreement” means a purchase 

and sale agreement, deed or other document that has been recorded in the deed 

records by the relevant county describing land to which a water right is 

appurtenant and demonstrating that the interest in that land and interest in the 

appurtenant water right have been separately conveyed. <emphasis added>

If the interest in a water right is not being conveyed as part of a real estate transaction, but is 

intended to be conveyed by the seller to another party or retained by the seller, OWRD 

recommends that an agreement that qualifies as a Water Right Conveyance Agreement be 

executed by the parties prior to the sale of the property (the land) being completed. If a 

subsequent transfer application is submitted to OWRD, a copy of the Water Right Conveyance 

Agreement will be required as part of the transfer application process.

Even if a Water Right Conveyance Agreement has been executed, the water rights remain 

appurtenant to those lands until OWRD approves a water right transfer. The Water Right 

Conveyance Agreement or other agreement in which interest in water rights are retained or 

conveyed should describe the lands to which the water rights are appurtenant sufficient to satisfy 

the purpose of the seller and purchaser, and in a manner consistent with typical procedures for 

real property transactions (OWRD 2016a).

Government Camp Parcels

The two appurtenant water rights on record that are within the conveyance parcels are in the 

name of private owners, in a non-cancelled status, designated for domestic use, and certificated. 

As standard practice of the real property transaction, they would be reviewed to determine if they 

are still in use, or have been used in the last 5 to 15 years. If they have not, then they may be 

considered to be abandoned, and could be transferred, cancelled, forfeited, or remain outstanding 

to a third party.

Water rights that could supply the proposed residential development at full build-out do not 

currently exist on the conveyance parcels. Sources would have to be developed under either a 

new water right application through OWRD, or by tapping into an existing off-site source. Using 

an off-site source would necessitate third-party feasibility and examination by OWRD.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

282

Water rights are obtained in a three-step process. The applicant first must apply to the 

Department for a permit to use water. Once a permit is granted, the applicant must construct a 

water system and begin using water. When water is applied, the permit holder must hire a 

certified water right examiner to complete a survey of water use and submit to the Department a 

map and report detailing how and where water is being applied. If water has been used according 

to the provisions of the permit, a water right certificate is issued based upon the report findings 

(OWRD 2016).

Cooper Spur Parcels

The appurtenant water rights on the acquisition parcels would be transferred to the Forest 

Service according to the OWRD review process. Surface rights that have been cancelled or 

abandoned could be subject by the State to statutory forfeiture, or recognized as an instream 

water right to be held by the State (OWRD 2002). Rights transferred to the Forest Service would 

either remain apportioned to their original beneficial use or possibly re-apportioned to another as 

part of the transfer. 

Exercised rights for domestic use, such as the well that supplies the resort, would become the 

responsibility of the Forest Service, or a permittee/concessionaire and necessitate annual wateruse reporting, system maintenance, water quality testing, and be in compliance with the Safe 

Drinking Water Act as amended in 1996, and enforced by the Oregon Department of 

Environmental Quality and the Oregon Health Authority.

Connected Actions

Conservation easements to protect wetlands: The Clarification Act includes a provision to the 

Government Camp parcels that “the Secretary and Mt. Hood Meadows may mutually agree for 

the Secretary to reserve a conservation easement to protect the identified wetland in accordance 

with applicable law, subject to the requirements that the conservation easement shall be 

consistent with the terms of the September 30, 2015, mediation between the Secretary and Mt. 

Hood Meadows, and in order to take effect, the conservation easement shall be finalized not later 

than 120 days after the date of the enactment of the Mount Hood Cooper Spur Land Exchange 

Clarification Act.” Since the Clarification Act has not yet been enacted, the following 

assumption was developed to enable the environmental analysis process to progress. This 

assumption was developed using the best scientific information available, and knowledge of 

county, State, and Federal laws and regulations related to wetland protection. 

Wetland easements include locally inventoried wetland delineations plus geomorphic functional 

contributing areas. The latter was determined using bare earth LiDAR and ArcGIS hydro tools to 

define stream initiation zones and provincial topographic contributing areas which were then 

refined based upon field validation.

Cumulative Effects

Alternative 1

Since no direct or indirect effects would occur, there can be no cumulative effects. 

Alternative 2

Residential land use being proposed in the conveyance parcels would necessitate development of 

a water system of sufficient supply, and would have to undergo the application and permit 

process through OWRD. Use of an existing appurtenant water right that may have been 

transferred to the new landowner, or a new water right such as a well, or supplemental to an 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

283

existing off-site right like a municipal system would be subject to review and the OWRD 

permitting process. 

A part of that process would be to discern if the transfer or application could be injurious to other 

water right holders. If a water source is used that is contributing to either Camp Creek or the 

Little Zigzag, then a determination would have to be made as to whether existing water users 

downstream would be negatively affected by water usage of the proposed residential 

development. Considering the variety of existing municipal, commercial, domestic, and firefighting uses in the Camp Creek and Little Zigzag subwatersheds, the cumulative effect to 

available water to downstream water right holders would be a vital component for OWRD to 

review before issuing a permit.

Visuals

Introduction

The Mt. Hood National Forest Forest Plan uses the Visual Management System to manage its 

scenery. This system prescribes visual quality objectives (VQOs) that are the minimum level of 

visual quality. The Forest Plan has three viewing platforms (viewpoints) that have prescribed 

VQOs: 

• Management Areas

• Designated Viewsheds

• Views from Trails

This project was analyzed by assessing changes in VQOs between the two alternatives. VQOs, 

distance zones, and viewing platforms were mapped. A schematic visibility study identified 

potentially seen areas. 

The connected action of the reservation of trail easements on the Government Camp parcels was 

analyzed. Scenic quality from affected trails was evaluated by comparing existing conditions to 

visual quality anticipated after land development (full build-out) of the Government Camp 

parcels. While there would be an expected change in visual quality, NFS lands conveyed to 

private ownership would cease to have objectives. Therefore, there would be no expected 

violations of the Forest Plan. An assumption for this analysis is that the parcels to be conveyed 

will be developed for residential housing.

The addition of wilderness and creation of A14 Crystal Springs Watershed Special Resources 

Management Unit was analyzed by expected changes in VQOs.

The connected action of the Special Use Permit Prospectus for Operation of the Cooper Spur 

Mountain Resort and Ski Area is not expected to affect scenic quality, and therefore, is not 

analyzed in this report.

The Forest Plan Goals, Desired Future Condition, and Standards and Guidelines related to 

scenery are described in the Scenery Specialist Report. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

284

Affected Environment

Existing Condition

Biophysical Context for both Government Camp and Cooper Spur Areas

The biophysical description for both the Government Camp and Cooper Spur areas is 

summarized as the Level IV ecoregion, Cascade Crest Montane Forest, 4c (Woods et al. 2002). 

The ecoregion’s landform is characterized as a glaciated, undulating plateau punctuated by 

buttes, volcanic cones, lava flows, and mountains. Locally, the massive Mt. Hood peak, 

Cascades Subalpine/Alpine ecoregion (4d), towers over the sprawling plateau. Scoured canyons 

formed by earth flows radiate downward from its twisted summit. These canyons define 

viewsheds from mid-slope vantages (Government Camp and Cooper Spur areas). When not 

obscured by weather, vegetation, or terrain, the perpetually snow clad summit of the Mt. Hood 

massif is a constant focal point.

Meandering, medium gradient streams drain the glaciated terrain. Numerous lakes dot glacial 

rock-basins. Elevations range between 4,000 and 6,500 feet. Geology is classified as colluvium, 

volcanic ash, glacial deposits, and volcanic rocks on the surface with basaltic and andesitic lava 

flows, breccia, and pyroclastic deposits as bedrock.

Average annual precipitation is between 55 and 100 inches. The mean annual frost free days is 

between 30 and 90 days. The average temperatures in January are a minimum of 21 degrees F 

and high of 35 degrees F. The average temperatures in July are a minimum of 43 degrees F and 

high of 72 degrees F.

Potential vegetation is mostly fir-hemlock forest/ Mostly Pacific silver fir, mountain hemlock, 

and subalpine fir; some noble fir, Douglas-fir, western white pine and lodgepole pine. 

Understory is vine maple, huckleberries, rhododendron, beargrass, twinflower, and wintergreen. 

Mountain meadows support sedges, dwarf willows, and tufted hairgrass.

Land uses are predominantly forest recreation and some logging. The ecoregion is an important 

water source for lower elevation urban, suburban, and agricultural areas.

Government Camp Parcels

The parcels are located on the gentle southwest-facing slope of Mt. Hood at the north end of the 

village of Government Camp. Elevations range from about 3,760 to 4,120 feet. Parcels are 

mostly undeveloped and fully vegetated by a mature, conifer overstory, and lush understory. See 

the vegetation specialist report for more details. The two parcels are physically separated by a 

40-acre aliquot part that is privately owned. 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

285

West Parcel

The westerly parcel in Section 13 lies mostly north of Government Camp Loop Road and is 

accessed from a street on the east end. A creek traverses from northeast to southwest at the 

southeast comer of the property. The area around the creek is predominately wetlands. There are 

two parallel cuts through the timber for the Skyway Trail, a former gondola tram that ran from 

Thunderhead Condominiums to Timberline Lodge. A transmission line also cuts through the 

timber from the southwest to the northeast. Wally's Trail leads from the southern terminus of the 

Skyway Trail to the northwest comer of the parcel. The Forest has issued numerous special-use 

permits for a water storage tank and water lines, transmission lines, trails, and a telephone line. 

There is a terrain break that runs through the center of parcel. Western reaches of the parcel are 

lower in elevation than eastern reaches.

Figure 40. Aerial oblique view of Government Camp West Parcel (looking north)
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

286

East Parcel

The easterly parcel in Section 14 lies at the north end of Government Camp with subdivision 

development to the south and west and with a Summit Ski Area run to the east. Access is 

provided by East Lige Lane that lies on the southern border of the parcel. The Crosstown Trail 

enters the property at the southeast comer and exits at the midpoint of the northern border. The 

Forest has issued special-use permits for a water tank and water lines, electric and power lines. 

Figure 41. Aerial oblique view of Government Camp East Parcel (looking north)

Government Camp Parcels Visual Quality Objectives

The following platforms have existing VQOs for the Government Camp parcels.

• A11 Management Area

• Designated Viewsheds relevant to the Government Camp Parcels are listed in table 89:

♦ Highway 26, West of Jct./ Hwy 35

♦ Timberline Road

♦ Timberline Lodge

♦ Trillium Lake

• Segments of the trails listed in table 91
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

287

Table 89. Existing conditions: VQOs of Government Camp area

Viewing Platform Parcels Potentially 

Visible Distance Zone VQO

A11 yes Foreground Middleground Retention/ Partial 

Retention

Type II Trails yes Near Foreground/ Far 

Foreground/ Middleground

Partial Retention/ 

Modification/ Modification

Highway 26, West 

of Jct./ Hwy 35

yes Foreground/ Middleground Retention/ Retention

Timberline Road yes Middleground Partial Retention

Timberline Lodge yes Middleground Partial Retention

Trillium Lake yes Middleground Partial Retention

Table 89 summarizes Management Area and Designated Viewshed VQOs relevant to the 

Government Camp Parcels. The most restrictive VQO is Retention from the Highway 26 

viewing platform and the foreground of A11 Management Area; therefore, it is used to compare 

alternatives.

Both Government Camp parcels, 109 acres, have VQOs of Retention for this analysis.

Table 90. VQOs in acres for the Government Camp parcels existing condition

Parcel/ Designation VQO Acres Total

Government Camp West Parcel Retention 68 109 acres Retention

Government Camp East Parcel Retention 41

As stated earlier, a connected action is the retention of trail easements by the Mt. Hood National 

Forest. These trails would continue to have prescribed VQOs by the Forest Plan. Table 91

summarizes trails with proposed easements, trail class, and VQOs.

Table 91. Trails within Government Camp parcels

Government 

Camp Parcel

Trails with Segments 

Located within Parcels

Trail 

Number

Trail 

Class

VQO

Near foreground/ Far foreground/ 

Middleground

West Parcel Skiway 755B II Partial Retention/ Modification/ Modification

Maggie’s Tie 753 II Partial Retention/ Modification/ Modification

Wally’s Tie 755A II Partial Retention/ Modification/ Modification

East Parcel Crosstown 755 II Partial Retention/ Modification/ Modification

Alpine 660 II Partial Retention/ Modification/ Modification
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

288

Cooper Spur Area

A variety of recreational activities occur within the Cooper Spur area. State Highway 35, a 

scenic byway, runs to the east. Portions of the proposed lands are within the designated 

viewshed. Cooper Spur Road, or Forest Road 3512, bisects the proposed lands. Both roads offer 

scenic views and many people drive them for pleasure throughout the year. Forest Road 3512 

also provides access to Cloud Cap Road, which is one of the most popular roads on the Mt. Hood 

National Forest due to its terminus at Cloud Cap Inn, its access to several trails including the 

Timberline Trail, and the view of Mt. Hood from the top of the road. There are numerous 

trailheads for popular non-motorized trails within the planning area. Recreation use is popular 

during both the summer and the winter. Due to the variety of activities available, and its 

proximity to Hood River, a popular tourist destination, the amount of visitor use increases 

annually. 

Cooper Spur Parcels

The land exchange proposes that the Mt. Hood National Forest would acquire 769 acres of 

private land. This land is described as mostly vacant forest land in various stages of seral 

development, the Cooper Spur Mountain Resort, and structures at Cooper Spur Ski area. The 

terrain is gently sloping, dissected by deep canyons, gradually breaking off toward the East Fork 

of the Hood River. 

The resort is located about 2 miles east of the Cooper Spur Ski Area at the intersection of Cooper 

Spur and Cloud Cap roads. The resort site consists of 11 different structures. The resort also 

includes spas, storage, a tennis court, equipment storage and shop, and a single-family residence.

Figure 42. Aerial oblique view of Cooper Spur parcels (looking north)
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

289

Cooper Spur Parcels Visual Quality Objectives

The private land does not have VQOs, but for the purposes of comparing the land exchange, 

direction for scenery management is derived from the following viewing platforms.

• Newly Created Crystal Springs WSRMU, A14 Management Area

• Designated Viewsheds

• There are no NFS system trails that currently cross the private property

Table 92. Designated viewshed in the Cooper Spur area

Distance Zone from Viewer Position

Designated Viewsheds Viewer Position Foreground Middleground Background

Highway 35 OR Hwy 35, Rec 

Sites

Retention Partial 

Retention

Partial 

Retention

Crystal Springs Watershed Special Resources Management Unit, A14 Management 

Area

A goal of the CSWSRMU is to allow visitors to view the scenery of the watershed. A desired 

future condition is predominantly natural appearing scenery. The following Standards and 

Guidelines would apply.

B. Visual Resource Management

1. Management activities within the cultural landscape of the Cloud Cap – Tilly Jane 

National Historic District (see map below) shall meet a visual quality objective (VQO) 

of retention in the foreground and partial retention in the middleground and background 

distance zones, as seen from open roads, high recreational use areas, and waterbodies. 

a. Foreground retention for the Cloud Cap Road within the National Historic District is 

applied to lands visible for distances up to 0.5 miles from the road and public areas, 

and means the following:

i. Vegetation is composed primarily of multi-age, multi-species stands with diverse 

understory of natural plant associations (where biologically feasible).

ii. Numerous large diameter, old trees are a major component of the stands (where 

biologically feasible).

iii. Small, natural appearing openings provide diversity and a sense of depth.

iv. The ground is generally free of unnatural forms and patterns of debris or litter.

v. Seasonal changes in vegetation color and texture are emphasized.

b. Middleground and background partial retention is applied to lands visible for 

distances from 0.5 to 5 miles from the Cloud Cap Road and public areas within the 

National Historic District, and means the following:

i. Natural appearing forest landscape, with little evidence of human alteration.

ii. Dominant visual impression is mostly continuous tree canopies, with diversity in 

occasional natural appearing openings.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

290

iii. Mosaic of species and age classes add texture and color contrast in natural 

patterns.

iv. Management activities repeat form, line, color, and texture common to the 

characteristic landscape.

2. Management activities outside of the cultural landscape of the Cloud Cap – Tilly Jane 

National Historic District (see map below) shall achieve a VQO of partial retention from 

open roads.

3. VQOs accepting less visual quality disturbance shall be applied when A14 Management 

Areas are located within “designated viewsheds.” 

4. See Forestwide Visual Resource Management Standards and Guidelines for VQOs 

prescribed for trails. 

Table 93. VQOs for proposed Cooper Spur parcels 

Viewing Platform Parcels Potentially 

Visible Distance Zone VQO

A 14 yes Foreground, 

Middleground

Partial Retention all 

distance zones

A 14: Cloud Cap-Tilly 

Jane Historic District

yes Foreground 

Middleground

Retention/ Partial 

Retention

Highway 35 yes Foreground 

Middleground

Partial Retention / Partial 

Retention

The Visual Resource Management Standards and Guidelines for A 14 prescribe the VQO of 

Retention for the foreground distance from the Cloud Cap road. Approximately 160 acres of the 

proposed land exchange private land fall within this distance zone. The remaining, 609 acres are 

outside the Cloud Cap road foreground and have a VQO of Partial Retention.

Table 94. Existing condition: VQOs in the Cooper Spur area

Parcel/ Designation VQO Acres Total

Cooper Spur Parcels Retention 160 160 acres Retention

Partial Retention 609 609 acres of Partial Retention

CSWSRMU Retention 660 660 acres of Retention

Partial Retention 1,396 1,396 acres of Partial Retention

Modification 34 34 acres of Modification

Mt. Hood Wilderness Addition Retention 492 492 acres of Retention

Partial Retention 1,217 1,217 acres of Partial Retention

Table 94 lists the existing condition VQOs for the management area direction on NFS lands 

proposed to be designated as the CSWSRMU and added to the Mt. Hood Wilderness.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

291

Environmental Consequences

Direct and Indirect Effects

The spatial boundaries for analyzing the direct and indirect effects on visuals are the 

Government Camp parcels and Government Camp trail system, and the combined Crystal 

Springs Watershed Special Resources Management Unit and the wilderness addition because 

these areas are predicted be most affected by the proposed action.

The temporal boundaries for analyzing the direct and indirect effects are 1 to 5 years (short-term) 

and 5 to 30 years (long-term). The short-term reflects time to finalize the LEX. The long-term 

reflects time for full build-out of the Government Camp parcels and the subsequent change of 

management of the Cooper Spur parcels.

Alternative 1

Government Camp

NFS lands would remain managed by A11 land use allocation (LUA) management area 

direction, which prescribes a Visual Quality Objective (VQO) of Retention in the foreground and 

Partial Retention in the middleground.

NFS lands visible from the Highway 26, designated viewshed, would continue to be managed to 

meet the VQO of Retention in the foreground and middleground distance zones.

NFS lands visible from the other designated viewsheds would be managed to meet the prescribed 

VQOs from these viewing platforms.

Trails within the Government Camp parcels (segments of Crosstown, Alpine, Maggie’s Tie, 

Wally’s Tie and Skiway) would remain in their current location, solely on NFS lands. The NFS 

lands adjacent to the Level II trails would be managed to meet the following VQOs.

• Near-foreground- Partial Retention

• Far-foreground- Modification

• Middleground- Modification

Retention: “The visual quality objective provides for management activities which are not 

visually evident. Activities may only repeat form, line, color, and texture, which are frequently 

found in the characteristic landscape.”

Partial Retention: “Activities may repeat form, line, color, or texture which are found 

infrequently or not at all in the characteristic landscape, but remain visually subordinate to the 

visual strength of the characteristic landscape.”

Modification: “Activities of vegetative and landform alteration must borrow from naturally 

established line, form, color, and texture so that their visual characteristics are those of natural 

occurrences within the surrounding area when viewed as middle ground or background.

Activities may visually dominate the original characteristic landscape.”
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

292

Table 95. Existing conditions: VQOs of Government Camp area

Viewing Platform Parcels 

Potentially Visible Distance Zone VQO

A11 yes Foreground 

Middleground

Retention Partial 

Retention

Type II Trails yes Near Foreground/ Far 

Foreground/ 

Middleground

Partial Retention/ 

Modification/ Modification

Highway 26, West of Jct./ 

Hwy 35

yes Foreground/ 

Middleground

Retention/ Retention

Timberline Road yes Middleground Partial Retention

Timberline Lodge yes Middleground Partial Retention

Trillium Lake yes Middleground Partial Retention

Cooper Spur Area

The private land (proposed Cooper Spur parcels) would continue to be managed without any 

objectives for managing effects to the scenery. 

NFS lands in the proposed CSWSRMU would continue to be managed in compliance with 

VQOs prescribed for the A4, A11, B2, and C1 LUAs. 

The VQOs for NFS lands proposed for inclusion in the Mt. Hood Wilderness would remain a 

mix of Retention and Partial Retention.

Table 96. Existing condition: VQOs in the Cooper Spur area

Parcel/ Designation VQO Acres Total

Cooper Spur Parcels None None None

CSWSRMU Retention 660 660 acres of Retention

Partial Retention 1,396 1,396 acres of Partial Retention

Modification 34 34 acres of Modification

Mt. Hood Wilderness Addition Retention 492 492 acres of Retention

Partial Retention 1,217 1,217 acres of Partial Retention

Alternative 2- Proposed Action

Government Camp

The proposed action would have direct and indirect effects to the scenery in the Government 

Camp area. The primary proposed action, the land exchange, was analyzed by the loss and gain 

of acres of VQOs. Both of the Government Camp parcels are prescribed a VQO of Retention.

A direct effect of the proposed action is the loss of 109 acres of NFS lands with the VQO of 

Retention to the Mt. Hood National Forest, therefore, 109 acres of land would cease to have 

VQOs.

An indirect effect would be a change in the visual quality of the future use and management of 

the Government Camp parcels proposed for the land exchange. 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

293

It was assumed that future development would comply with Clackamas County zoning 

ordinances. This states that both Government Camp parcels would be developed for residential 

housing. Houses would occupy 1⁄4 acre lots. The total amount of impervious surface would not 

exceed 40 percent of each lot. The height of the buildings would not exceed 50 feet. Lots would 

likely be cleared of most mature forest vegetation, but some select specimens/ islands of forest 

vegetation would be retained for aesthetic values. 

It was further assumed that future build out would result in very similar land use/ land cover that 

currently exists on the 40-acre aliquot part, which physically separates the two proposed LEX 

parcels. The following figures are photos of this development. An aerial Google Earth image

displays overall residential fabric that would likely be viewed from above (the proposed LEX 

parcels are outlined in magenta). Future housing stock would be similar in height and 

proportions to existing stock. The streetscapes would likely be large enough to handle emergency 

vehicles, but be residential in nature. 

Additional Assumptions:

• Private development would not have a required buffer between NFS lands.

• Buffers of native forest would be retained around aquatic resources such as wetlands and 

streams.

• Architecture and lot vegetation would be consistent with ecoregion attributes.

Figure 43. Existing residential development in the Government Camp area (looking northwest)
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

294

Figure 44. Existing housing stock in the Government Camp area

Figure 45. Existing building height in the Government Camp area
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

295

Figure 46. Existing lot with forest vegetation in the Government Camp area

Figure 47. Existing streetscape in the Government Camp area
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

296

Visibility

To determine Designated Viewsheds and facilitate analysis, a schematic reverse viewshed map 

was created. It is coarse in detail but characterizes areas potentially visible from the Government 

Camp parcels and vice versa. The following figure displays the viewshed. 

Figure 48. Government Camp parcels schematic viewsheds

Government Camp Trail System 

A direct effect from the connected action of the reservation of trail easements would be segments 

of affected trails would cease to have VQOs. The following table lists affected trails. The trails 

would cease to have a VQO of Partial Retention in the near-foreground or any objectives to meet 

regarding visual quality. The total of all trail segments subjected to easements is approximately 

1 mile. It would be expected that visual quality would change from the trail viewing platform, 

from natural-appearing to modified by residential development.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

297

Table 97. Trails within Government Camp parcels that would cease to have VQOs

Government 

Camp 

Parcel

Trails with 

Segments Located 

within Parcels

Trail 

Number

Trail 

Class

VQO

Near foreground/ Far foreground/ 

Middleground

West Parcel Skiway 755B II Partial Retention/ Modification/ Modification

Maggie’s Tie 753 II Partial Retention/ Modification/ Modification

Wally’s Tie 755A II Partial Retention/ Modification/ Modification

East Parcel Crosstown 755 II Partial Retention/ Modification/ Modification

Alpine 660 II Partial Retention/ Modification/ Modification

Cooper Spur Area

The proposed action would have direct and indirect effects to scenery in the Cooper Spur Area. 

The primary proposed action, the land exchange, was analyzed by the loss and gain of acres of 

VQOs. The Cooper Spur parcels proposed to be conveyed to the Mt. Hood National Forest are 

private and therefore lack existing VQOs. However for purposes of comparison, VQOs derived 

from the connected actions were used. VQOs would be Retention and Partial Retention.

A direct effect of the proposed action would be the gain of 160 acres of NFS lands with VQOs of 

Retention and 609 acres of Partial Retention to the Mt. Hood National Forest.

A direct effect would be a total of 769 acres of land would begin to be managed for VQOs.

The LUA of Crystal Springs Watershed Special Resource Management Unit 

(CSWSRMU)

A direct effect to the creation of CSWSRMU would be scenery management direction that would 

comply with the newly created LUA of A14. A full list of Standards and Guidelines for this new 

LUA are listed in chapter 2 of this DEIS. Those regarding VQOs are listed below.

B. Visual Resource Management

1. Management activities within the cultural landscape of the Cloud Cap – Tilly Jane 

National Historic District (see map below) shall meet a visual quality objective (VQO) 

of retention in the foreground and partial retention in the middleground and background 

distance zones, as seen from open roads, high recreational use areas, and waterbodies. 

a. Foreground retention for the Cloud Cap Road within the National Historic District is 

applied to lands visible for distances up to 0.5 mile from the road and public areas, 

and means the following:

i. Vegetation is composed primarily of multi-age, multi-species stands with diverse 

understory of natural plant associations (where biologically feasible).

ii. Numerous large diameter, old trees are a major component of the stands (where 

biologically feasible).

iii. Small, natural appearing openings provide diversity and a sense of depth.

iv. The ground is generally free of unnatural forms and patterns of debris or litter.

v. Seasonal changes in vegetation color and texture are emphasized.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

298

b. Middleground and background partial retention is applied to lands visible for 

distances from 0.5 to 5 miles from the Cloud Cap Road and public areas within the 

National Historic District, and means the following:

i. Natural appearing forest landscape, with little evidence of human alteration.

ii. Dominant visual impression is mostly continuous tree canopies, with diversity in 

occasional natural appearing openings.

iii. Mosaic of species and age classes add texture and color contrast in natural 

patterns.

iv. Management activities repeat form, line, color, and texture common to the 

characteristic landscape.

2. Management activities outside of the cultural landscape of the Cloud Cap – Tilly Jane 

National Historic District (see map below) shall achieve a VQO of partial retention from 

open roads.

3. VQOs accepting less visual quality disturbance shall be applied when A14 Management 

Areas are located within “designated viewsheds.” 

4. See Forestwide Visual Resource Management Standards and Guidelines for VQOs 

prescribed for trails. 

The following table compares changes in VQOs between alternatives.

Table 98. Changes in CSWSRMU VQOs between alternatives

CSWSRMU VQO Alternative 1 acres Alternative 2 acres Net Change

Retention 660 820 Gain of 160 acres

Partial Retention 1,396 2,039 Gain of 643

Modification 34 0 Loss of 34 acres

Addition of 1,708 acres to the Mt. Hood Wilderness

A direct effect is the change of VQO from a combination of Retention and Partial Retention to 

Preservation. The following table summarizes changes.

Table 99. Changes in proposed wilderness addition VQOs between alternatives

Proposed Wilderness

VQO Alternative 1 acres Alternative 2 acres Net Change

Preservation 0 1,709 Gain of 1,709 acres

Retention 492 0 Loss of 492

Partial Retention 1,217 0 Loss of 1,217 acres

Preservation “This objective applies to Wilderness areas, primitive areas, other special 

classified areas, areas awaiting classification and some unique management units which do not 

justify special classification.

A direct effect would be the changes to trail class and VQOs to the trails in the following table.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

299

Existing conditions, the trails are class II with VQOs of Partial Retention in the near-foreground 

and Modification in the Middle and Background. The proposed wilderness addition would 

classify trails as class I with VQOs of Retention in the Near-foreground, Partial Retention in the 

Far-foreground, and Modification in the Middleground.

Table 100. Trails with VQOs affected by the proposed wilderness addition

Trail Name

Trail 

Number Season of Use Within Mt. Hood Wilderness Addition

Tilly Jane 643 Winter and Summer Yes, segments

Tilly Jane ski trail 643A Winter and Summer Yes, segments

Wagon Road 642 Mostly Cross Country Ski in Winter but 

also Summer Use

Yes, segments

Visibility

To determine Designated Viewsheds and facilitate analysis, a schematic reverse viewshed map 

was created. It is coarse in detail but characterizes areas potentially visible from the Cooper Spur 

parcels and vice versa. The following figure displays the viewshed. 

Figure 49. Cooper Spur parcels schematic viewshed map
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

300

Changes in VQOs from Primary Action

Table 101. Comparison of acres of VQOs gained and lost

Parcels Gain/ Loss VQO Acres

Government Camp Parcels Loss Retention 109

Cooper Spur Parcel Gain Retention 160

Partial Retention 609

Changes in VQOs from Connected Actions

The proposed Wilderness Addition would change VQOs from a mix of Retention and Partial 

Retention to Preservation.

The proposed Wilderness Addition would change VQOs for trails listed in table 100 to more 

restrictive in the Foreground distance zones.

The creation of CSWSRMU would change VQOs by gaining 160 acres of Retention and 

609 acres of Partial Retention, and, the loss of 34 acres of Modification.

Forest Plan Amendment Summary

The expansion of the Mt. Hood Wilderness would not have any changes that would alter the 

long-term relationship between levels of multiple-use goods and services. The management area 

would continue to provide high quality scenery to recreation and social uses.

The Land Use Allocation of A14 would have no changes that would alter the long-term 

relationship between levels of multiple-use goods and services. The management area would 

continue to provide high quality scenery for recreation and social uses.

The expansion of the Mt. Hood Wilderness would not have any important effects on the entire 

planning area or land management plan. The management area would continue to provide high 

quality scenery for recreation and social uses.

The Land Use Allocation of A14 would have no important effect on the entire land management 

plan or affect land and resources throughout a large portion of the planning area during the 

planning period. The management area would continue to provide high quality scenery for 

recreation and social uses.

Cumulative Effects

The spatial boundaries for analyzing the cumulative effects to VQOs are the Government Camp 

parcels and Government Camp trail system, and the combined Crystal Springs Watershed 

Special Resources Management Unit and the wilderness addition because these areas are 

predicted be most affected by the proposed action.

The temporal boundaries for analyzing the cumulative effects are 1 to 5 years (short-term) and 5 

to 30 years (long-term). The short-term reflects time to finalize the land exchange. The long-term 

reflects time for full build-out of the Government Camp parcels and subsequent change of 

management of Cooper Spur parcels.

The list of past, present, and reasonably foreseeable projects that may overlap with this project in 

time and space were provided at the beginning of this chapter. Many of the listed projects have 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

301

shaped and continue to shape the Visual Quality in the Government Camp and Cooper Spur 

areas. Patterns of recreation, such as ski areas, lodges, camps, residences, trails, and semiprimitive untrailed areas, continue to blend and contrast with the predominantly natural 

appearing backdrop of the land exchange areas.

The wilderness additions change VQOs to Preservation. Otherwise, the proposed action(s) when 

considered with the listed projects would continue to shape the Visual Quality, but cumulatively 

there would be no change in Visual Quality Objectives.

Wildlife 

(Threatened, Endangered, and Sensitive Species; Management Indicator 

Species; Migratory Birds; and Survey and Manage Species)

Introduction

This section of the DEIS provides a summary of the analyses that were conducted for 

Threatened, Endangered, and Sensitive terrestrial wildlife species via a Biological Evaluation, 

Mt. Hood National Forest Management Indicator Species, Migratory Birds, and Survey and 

Manage Species. Refer to the Wildlife Specialist’s Report in the project record for additional 

background and supporting information. 

Biological Evaluation

As part of the National Environmental Policy Act (NEPA) decision-making process, biological 

evaluations are required to determine how proposed Forest Service management activities may 

affect threatened, endangered, or proposed species, or Forest Service sensitive species or their 

habitats (U.S. Forest Service Manual [FSM] 2670). The Biological Evaluation presents existing 

information on threatened, endangered, proposed, or sensitive species and their habitat in the 

project area, and describes the anticipated direct, indirect, and cumulative effects resulting from 

the proposed project. The review is conducted to ensure that Forest Service actions do not 

contribute to the loss of species viability or cause a species to move toward Federal listing 

(43 U.S.C. 1707 et. seq.). Threatened and endangered species are managed under authority of the 

Endangered Species Act (36 U.S.C. 1531-1544) and the National Forest Management Act 

(16 U.S.C. 1600-1614). The Endangered Species Act requires Federal agencies make certain all 

actions they authorize, fund, or carry out will not likely jeopardize the continued existence of

any threatened or endangered species. Sensitive species are those recognized by the Pacific 

Northwest Region’s Regional Forester as needing special management to meet National Forest 

Management Act obligations. Forest Service policy requires a biological evaluation to determine 

possible effects to sensitive species from proposed management activities.

Excerpts from the Biological Evaluation for the species that could be affected by the Proposed 

Action are provided in this section. Refer the Wildlife Specialist’s Report in the project record 

for the complete Biological Evaluation that contains additional background and supporting 

information. A full list of wildlife species was considered for possible effects from the proposed 

action and alternatives. Table 2, in the Biological Evaluation, lists U.S. Fish and Wildlife Service 

threatened, endangered or proposed terrestrial wildlife species and their critical habitats (where 

applicable), as well as Pacific Northwest Region sensitive terrestrial wildlife that may be present 

or are known within the planning area. The possibility of effects to each species were evaluated 

based on identified threats, important habitat components, and the expected interaction with 

disturbances associated with project alternatives. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

302

The biological evaluation/biological assessment reviews the proposed action and alternatives in 

sufficient detail to determine the level of effect that would occur to federally listed wildlife and 

Pacific Northwest Region sensitive wildlife species. One of four possible determinations is 

chosen based on the available literature, a thorough analysis of the potential effects of the 

project, and the professional judgment of the wildlife biologist who completed the evaluation. 

The four possible determinations (from FSM 2672.42) are:

• No impact 

• Beneficial impact

• May affect individuals, but is not likely to result in a trend toward Federal listing or loss of 

viability in the planning area

• May affect individuals, and is likely to result in a trend toward Federal listing or loss of 

viability in the planning area

Similar categories for federally listed threatened and endangered species are:

• No effect

• Beneficial effect

• May affect, not likely to adversely affect

• May affect, likely to adversely affect 

Species Considered for Analysis

Threatened, Endangered, and Proposed Species

An official list of terrestrial threatened, endangered, and proposed species that may occur within 

the boundary of the project or may be affected by the project, was obtained from the U.S. Fish 

and Wildlife Service’s Information for Planning and Conservation (IPaC) website on August 15, 

2016 (USDI Fish and Wildlife Service 2016a). One listed species, northern spotted owl, is 

described as potentially occurring within, or potentially affected by, the project. The species list 

identifies northern spotted owl designated critical habitat as occurring within the project area; 

however, GIS review of land parcels proposed for transfer shows no overlap with spotted owl 

critical habitat. North American wolverine is currently considered proposed for Federal listing. 

The species occurrence map displayed in the U.S. Fish and Wildlife Service Environmental 

Conservation Online System (ECOS) shows potential occurrence overlaps the project area. In 

addition, the most recent Regional Forester Special Status Species List (USDA Forest Service 

2015) describes suspected occurrence of the species on the Mt. Hood National Forest. Therefore, 

North American wolverine is also addressed in this analysis.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

303

Table 102. Threatened, endangered, and proposed wildlife species applicable to the project

Threatened, 

Endangered, and 

Proposed 

Species

Known Species 

Presence Within 

Project Area?

Habitat 

Present Within 

Project Area?

Analysis 

Included in 

this 

document?

Habitat and Rationale for 

not carrying species 

forward into this 

document

Northern spotted 

owl

(Strix occidentalis 

caurina)

No Yes Yes Late successional and oldgrowth conifer habitats for 

nesting, roosting, and 

foraging; younger stands 

utilized for dispersal. Refer 

to Effects Analysis.

Northern spotted 

owl 

Designated 

Critical Habitat

No No No Designated Critical Habitat 

is not located within the 

project area. 

North American 

wolverine

(Gulo gulo luscus)

No Yes Yes Strongly associated with 

high elevation alpine 

habitats as well as 

subalpine conifer habitats. 

Refer to Effects Analysis.

Sensitive Species

The most recent Region 6 sensitive species wildlife list (effective 21 July 2015; USDA Forest 

Service 2015) was reviewed and 22 species that may occur in or near the Mt. Hood National 

Forest were identified (Biological Evaluation, Table 4). Although each of these species are 

known to or could potentially occur in or near the Mt. Hood National Forest, not all of them have 

potential to occur in the Government Camp-Cooper Spur Land Exchange project area. A prefield wildlife review of the project area for all Pacific Northwest Region sensitive species was 

completed using Heritage database records, district data, and literature reviews to identify which 

sensitive species are applicable to the analysis. Many of the species listed have neither habitat 

nor documented occurrences within the project area. Therefore, the proposed project would have 

no impact upon them. No further analysis is provided for these species. 

The remaining species have potential habitat at least in portions of Government Camp-Cooper 

Spur Land Exchange project area and require further analysis. These species are analyzed in the 

following section, and include: Sierra Nevada red fox, Townsend’s big-eared bat, fringed myotis, 

Larch Mountain salamander, Cope’s giant salamander, Johnson’s hairstreak, Mardon skipper, 

western bumble bee, Dalles sideband, Crater Lake tightcoil, and shiny tightcoil. 

Threatened, Endangered and Proposed Species Carried Forward 

for Analysis

Northern Spotted Owl

Affected Environment

This species, which is listed as threatened, is typically associated with old-growth forested 

habitats throughout the Pacific Northwest. Northern spotted owls have been documented in a 

variety of forest types; however, this species does show a preference to Douglas-fir forests 

(USDI Fish and Wildlife Service 2011). Nest sites and roost sites are typically found in forests 

that exhibit complex structure and heterogeneity. These habitats are multi-storied with largediameter trees and high canopy cover. Most spotted owls are territorial and dispersal of young 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

304

depends on availability of suitable habitat and prey species (USDI Fish and Wildlife Service 

2011). 

Past management activities, such as timber harvest, have reduced or fragmented northern spotted 

owl habitat throughout its range. In addition, the barred owl has presented cumulative impacts to 

this species (Courtney et al. 2004, USDI Fish and Wildlife Service 2011). The barred owl is an 

invasive species from the eastern United States and has expanded its range extensively 

throughout the Pacific Northwest. It is a generalist that can use a wide range of habitat types and 

forest age classes. It also has a wide diet range and can survive on many different prey types 

(Forsman et al. 2004, USDI Fish and Wildlife Service 2011). As a result, overall northern spotted 

owl population densities have decreased, specifically in areas where habitat reduction is 

concentrated and where barred owls are present (USDI Fish and Wildlife Service 2011).

There are no known owl sites either inside or within 1.2 miles of Government Camp parcels. The 

nearest known owl site is located about 2.3 miles to the east (figure 50). No known owl sites 

occur within Cooper Spur parcels, but a total of 5 known sites occur within 1.2 miles of those 

parcels (figure 51).

Spotted Owl Suitable Habitat 

Suitable habitat consists of forested stands used by spotted owls for nesting, roosting, and 

foraging. Features that support nesting and roosting typically include a moderate to high canopy 

closure (60-90 percent); a multi-layered, multi-species canopy with large overstory trees (with 

diameters of greater than 30 inches); a high incidence of large trees with various deformities 

(large cavities, broken tops, mistletoe infections, and other evidence of decadence); large snags; 

large accumulations of fallen trees and other woody debris on the ground; and sufficient open 

space below the canopy for spotted owls to fly (USDI Fish and Wildlife Service 2012). 

Foraging habitat generally has attributes similar to those of nesting and roosting habitat, but such 

habitat may not always support successfully nesting pairs (USDI Fish and Wildlife Service 

2011). Trees within foraging habitat may vary in size, and could be of smaller diameter than tress 

in nesting and roosting habitat depending on site-specific conditions. Together, nesting, roosting 

or foraging habitat comprise suitable habitat in this document.

Suitable Habitat within and Adjacent to the Project Area

Suitable and dispersal habitats within the Government Camp and Cooper Spur parcels were 

delineated based on field reconnaissance and satellite imagery. For areas outside the parcels, 

both the spotted owl habitat GIS layer delineated by the Mt. Hood National Forest (Northern 

spotted owl habitat 2012 layer) and the Mt. Hood corporate vegetation layer generated from

gradient nearest neighbor (GNN) data were reviewed for applicability to the analysis. The GNN 

layer was queried for spotted owl suitable habitat structure characteristics (i.e., canopy cover 

greater than or equal to 60 percent and overstory [majority] tree size greater than 30 inches). This 

resulted in very little suitable habitat represented on the landscape, even in areas where 

inspection of satellite imagery as well as past vegetation information suggested suitable habitat 

was present. Variations in structure query involving lower canopy cover and stand diameter 

values appeared to improve representation of suitable habitat, but comparison of these variations 

to suitable habitat depicted in the Northern spotted owl habitat 2012 layer using satellite imagery 

and ground-based knowledge of the area indicated the northern spotted owl habitat 2012 layer 

better represented spotted owl habitat within the project area. 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

305

Spotted owl habitat spatial data developed for the 20-year monitoring report for the Northwest 

Forest Plan was reviewed for this analysis as a source to identify suitable spotted owl habitat in 

and around the parcels proposed for transfer. Based on satellite image analysis as well as field 

reconnaissance within the Government Camp parcels, it is apparent that the monitoring report 

data are not very accurate in this area, and appears to overestimate the amount of suitable habitat.

The northern spotted owl habitat 2012 layer appears to be more accurate in identifying suitable 

spotted owl habitat in this area, so that data was used for this analysis. 

Government Camp Parcels

The two parcels proposed for transfer in the Government Camp area contain a range of habitat 

conditions from open early seral stands to closed mature conifer. Although no mapped suitable 

habitat occurs within the parcels, field review revealed that relatively small inclusions (less than 

8 acres each) of mature forest with high levels of canopy closure exist within the parcels. These 

total about 3 acres in the east parcel and almost 19 acres in the west parcel, totaling 

approximately 22 acres (table 103). Due to the small patch size, these inclusions can be 

considered marginally suitable habitat, with structure providing mainly foraging habitat, but also 

nesting/roosting structure at the microsite (less than 1 to 2 acres) level. Suitable habitat 

contiguous to the parcels is generally lacking, but larger blocks are present to the west and east 

(figure 50). Mapped suitable habitat within 1.2 miles of the parcels totals 677 acres, which 

equates to approximately 14 percent of all acreage within that area. 

Table 103. Habitat structure within Government Camp parcels

Habitat Structure* East Parcels West Parcels

Dry meadow 0.5 0

Early seral open 0 1.8

Mature closed 3.0 18.7

Mid seral closed 8.1 43.8

Mid seral moderate 6.8 1.2

Mid seral open 20.9 0

Wet meadow 0.6 0

Non-forested emergent 

vegetation wetland

0.9 0

Nonhabitat/Urban 0.2 2.5

Grand Total 41.0 68.0

*Early = 0-25 years old, Mid = 25-80 years old, Mature = >80 years old; 

Open= 0-40% canopy closure, Moderate = 40-60% canopy closure, Closed 

= >60% canopy closure
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

306

Figure 50. Known owl sites and habitat within and near Government Camp parcels

Cooper Spur Parcels

Parcels proposed for transfer in the Cooper Spur area contain a range of habitat conditions from 

open early seral stands to closed mature conifer. Although no mapped suitable habitat occurs 

within the parcels, field review (Dyck 2010, personal communication) showed that 

approximately 30 acres located along Tilly Jane Creek contains mature forest with high levels of 

canopy closure (table 104). Due to the narrow configuration of the stand (generally less than 400 

feet in width) in addition to being surrounded by dispersal habitat and non-habitat, the stand can 

be characterized as marginally suitable habitat. 

Suitable Habitat within Home Range Areas Encompassing Cooper Spur Parcels

There are a total five known owl sites within 1.2 miles of Cooper Spur parcels proposed for 

transfer. Recent surveys (2014) indicated owl breeding activity associated with site 6113P13. 

Analysis results show that suitable habitat amount within 1.2 miles of known owl sites range 

from about 451 to 740 acres, and averaged approximately 620 acres (table 105). Percentage of 

suitable habitat within potential home ranges averaged 19.3 percent and ranged from 15.3 to 

25.2 percent. None of the potential home ranges contained suitable habitat amounts close to or 

above thresholds which the literature indicates is the minimum needed for optimal northern 

spotted owl reproduction (suitable habitat of approximately 40 percent or more in the home 

range; USDI Fish and Wildlife Service 2011). The Gnarl Ridge Fire (2008; Figure 6) removed 

habitat within a considerable portion of the home range surrounding site 6097P91. The home 

range associated with site 6111P96 contains about half of its acreage in other ownerships. 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

307

Vegetation structure within other ownerships was not assessed, but review of satellite imagery 

indicates that some suitable habitat may be present on these lands.

Table 104. Habitat structure within Cooper Spur parcels

Habitat Structure* Acres

Dry meadow urban 4.3

Dry meadow/trees 28.4

Early seral closed 180.0

Early seral mod 50.1

Early seral moderate 39.6

Early seral open 54.0

Hardwood mix 12.7

Mature closed 30.0

Mid seral closed 279.0

Mid seral moderate 27.2

Mid seral open 49.9

Rock/scree 8.6

Developed 6.0

Grand Total 769.7

*Early = 0-25 years old, Mid=25-80 years old, Late= >80 

years old; Open= 0-40% Canopy closure, Moderate= 40-

60% Canopy closure, Closed= >60% Canopy closure

Table 105. Northern spotted owl suitable habitat within 1.2 mile radius of known owl sites within 

1.2 miles of Cooper Spur parcels

Known Owl 

Site

Acres of Suitable 

Habitat within 1.2 

Miles of Known Site, 

Existing NFS lands

Acres of Suitable 

Habitat within 1.2 

Miles of Known Site, 

Cooper Spur Parcels

Total Acres of 

Suitable Habitat 

within 1.2 Miles of 

Known Site

Percent of Area in 

Suitable Habitat 

within 1.2 Miles of 

Potential Site

6084P91 597.3 0 597.3 20.2%

6097P91 605.4 0 605.4 20.9%

6102P90 693.5 0 693.5 23.5%

6111P96 450.9 0 450.9 15.3%

6113P13 713.5 26.9 740.4 25.1%

Average 620.1 21.0%

Suitable Habitat within Core Areas

Areas within 0.5 mile of the 5 known sites were delineated for analysis (figure 51). None of the 

core areas overlap with Cooper Spur parcels.

Results of the analysis show that suitable habitat amount within 0.5 mile of potential sites range 

from about 21 to 205 acres, and averaged approximately 123 acres (table 106). Percentage of 

suitable habitat averaged 24.4 percent and ranged from 4.2 to 40.9 percent. None of the areas 

contained suitable habitat amounts close to or above thresholds which the literature indicates is 

the minimum needed for optimal northern spotted owl reproduction (suitable habitat of 

approximately 50 percent or more within the core area; USDA USDI 2016).
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

308

Figure 51. Known owl site home ranges and core areas within 0.5 mile of Cooper Spur parcels
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

309

Table 106. Northern spotted owl suitable habitat within 0.5 mile radius of known owl sites within 1.2 

miles of Cooper Spur parcels 

Known Owl 

Site

Acres of Suitable Habitat within 1.2 Miles 

of Known Site, Existing NFS lands

Percent of Area in Suitable Habitat 

within 1.2 Miles of Potential Site

6084P91 41.0 8.1

6097P91 176.9 35.2

6102P90 102.2 20.3

6111P96 75.3 15.0

6113P13 160.7 31.9

Average 22.1%

NFS = National Forest System

Dispersal Habitat 

Dispersal habitat allows spotted owl movement across the landscape between stands of suitable 

habitat and for juveniles to disperse from natal territories. This habitat generally lacks the 

optimal characteristics to support nesting and typically lacks multi-storied canopies, large trees 

or large snags and down wood. Dispersal habitat generally consists of mid-seral stands between 

40 and 80 years of age with canopy cover of 40 percent or greater and trees with a mean 

diameter of 11 inches or more (USDI 2011). Most managed or natural forest stands 35 to 

40 years old begin to develop dispersal habitat conditions.

Government Camp

Currently, dispersal habitat is not limiting across the landscape. Within 1.2 miles of known owl 

sites the amount of dispersal habitat ranges from 794 to 1,760 acres. Mid-seral moderate and 

mid-seral closed stands (table 104) comprise dispersal habitat totaling about 60 acres.

Cooper Spur

Availability of dispersal habitat in known Northern spotted owl site home ranges that encompass 

the Cooper Spur parcels is somewhat less than in the Government Camp area, ranging from 

556 acres to 1,400 acres. Mid-seral moderate and mid-seral closed stands (table 104) comprise 

dispersal habitat within the parcels totaling about 306 acres.

Areas of Concern

The North Willamette Late Successional Reserve Assessment (USDA Forest Service 1998) 

identified areas outside the late successional reserves where there are concerns about spotted owl 

dispersal due to the lack of primary constituent elements. The areas of concern were mapped and 

projects were analyzed to ensure that dispersal habitat is maintained in these locations to 

facilitate owl dispersal. There were four areas of concern identified on the Mt. Hood National 

Forest.

In 2012, an analysis of the areas of concern was completed by Ray Davis, Wildlife Biologist for 

the Interagency Regional Monitoring Team. Davis found that each of the four areas had over 

78 percent coverage of dispersal and suitable habitat, sufficient for Northern spotted owl 

dispersal across the landscape. Based on this analysis the Mt. Hood National Forest has removed 

areas of concern as a habitat designation for consultation with the U.S. Fish and Wildlife Service 

and this habitat is now treated the same as any general habitat on the national forest. As a point 

of reference, the Government Camp-Cooper Spur Land Exchange project area is not located 

within any of the previously designated areas of concern.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

310

Recovery Action 32 Designations

Among the recovery actions of the 2011 Revised Recovery Plan for the Northern Spotted Owl, 

Recovery Action 32 is one of the most important actions in retaining high quality suitable 

habitat. This Action 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 as described below 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.

Maintaining or restoring forests with high-quality habitat will provide additional support 

for reducing key threats faced by spotted owls. Protecting these forests should provide 

spotted owls high-quality refugia habitat from the negative competitive interactions with 

barred owls that are likely occurring where the two species’ home ranges overlap. 

Maintaining or restoring these forests should allow time to determine both the 

competitive effects of barred owls on spotted owls and the effectiveness of barred owl 

removal measures. Forest stands or patches meeting the described conditions are a 

subset of NRF habitat and actual stand conditions vary across the range. 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 to identify.

Barred Owls 

The Revised Recovery Plan also identifies competition from the barred owl as an important 

threat to the spotted owl (USDI Fish and Wildlife Service 2011). Current science shows that the 

barred owl is an invasive species from the eastern United States and has expanded its range 

extensively throughout the Pacific Northwest. Unlike the northern spotted owl, it is a generalist 

that can utilize a wide range of habitat types and forest age classes. The species has a wide diet 

range and can survive on many different prey types (Forsman et al. 2004, USDI Fish and 

Wildlife Service 2011). As a result, overall northern spotted owl population densities have 

decreased and barred owls are believed to be out competing spotted owls for habitat and food 

(USDI Fish and Wildlife Service 2011). The barred owl resilience to habitat fragmentation and 

modification increases the likelihood of persistence on the landscape. Hybridization levels may 

increase if northern spotted owl population levels decrease substantially (Courtney et al. 2004). 

Vegetation management activities can also benefit barred owls indirectly by providing habitat 

and prey species that are not necessarily preferred by the northern spotted owl.

Because routine surveys have not been conducted for spotted owls on the Mt. Hood National 

Forest since approximately 1994, it is unknown as to what extent their presence has affected the 

population of spotted owls. However, within the Oregon demographic study areas, there has 

been a steady increase in the number of barred owls as measured by the proportion of spotted 

owl sites with barred owls detected, with as many as 60 percent of the spotted owl sites having 

barred owls detected (Forsman et al. 2011). Dugger et al. (2011) modeled extinction and 

colonization rates for spotted owl pairs in the South Cascade Demographic Study area where 

barred owls were detected on some home ranges. They found that extinction rates for spotted 

owls increased with decreasing amounts of old forest in the core area, and that the effect was 2 to 

3 times greater when barred owls were detected. They found that colonization rates for spotted 

owls decreased as the distance between patches of old forest increased (i.e., increased habitat 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

311

loss and fragmentation) and that barred owl presence similarly decreased the rate of colonization 

of spotted owl pairs. They concluded that conserving large blocks of contiguous old-forest 

habitat was important for reducing interference competition between the two owl species.

Disturbance

The U.S. Fish and Wildlife Service has concluded that noise can result in a disruption of 

breeding, feeding, or sheltering behavior of the spotted owl such that it creates the potential for 

injury to individuals (i.e., incidental take in the form of harassment; USDI Fish and Wildlife 

Service 2011). For a substantial disruption of spotted owl behavior to occur, the disturbance and 

spotted owl(s) must be in close proximity. The northern spotted owl breeding season generally 

extends from March 1 to September 30 with March 1 to July 15 considered to be critical from a 

disturbance perspective.

Activities that generate noise above ambient levels have the potential to disturb or disrupt 

nesting spotted owls. Disturbance activities that can affect northern spotted owl are listed in table 

107 and show the minimum distances required.

A spotted owl that may be disturbed at a roost site is presumably capable of moving away from a 

disturbance without a substantial disruption of its behavior. Since spotted owls forage primarily 

at night, projects that occur during the day are not likely to disrupt its foraging behavior. The 

concern about noise is with breeding behavior at active nest sites.

In the late breeding period, potential effects from disturbance decline because juvenile spotted 

owls are increasingly more capable of moving as the nesting season progresses. The critical 

breeding period is March 1 through July 15. After July 15, most fledgling spotted owls are 

capable of sustained flight and can move away from most disturbances (USDI Fish and Wildlife 

Service 2011).
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

312

Table 107. Minimum disturbance and disruption distances for activities affecting northern spotted 

owls during the breeding season (USDI Fish and Wildlife Service 2016)

Source of Disturbance/ 

Disruption

Disturbance Distance 

Entire Breeding Period

(March 1 – September 30)

Critical Breeding 

Period 

(March 1 – July 15)

Disruption Distance 

Late Breeding Period 

(July 16 – September 30)

Aircraft –small fixed-wing 440 yards (0.25 mile) 110 yards NA

Blasting 1,760 yards (1 mile) 100 yards 100 yards

Burning 440 yards (0.25 mile) 440 yards (0.25 

mile)

NA

Chainsaw use 440 yards (0.25 mile) 65 yards NA

Hauling on open roads 440 yards (0.25 mile) NA NA

Heavy equipment 440 yards (0.25 mile) 65 yards NA

Helicopter: Chinook 47d 880 yards (0.5 mile) 265 yards 100 yards

(hovering only)

Helicopter: Boeing Vertol 

107, Sikorsky S-64 

(SkyCrane)

440 yards (0.25 mile) 150 yards 50 yards

(hovering only)

Helicopters: K-MAX, Bell 

206 L4, Hughes 500

440 yards (0.25 mile) 110 yards 50 yards

(hovering only)

Pile driving 440 yards (0.25 mile) 120 yards NA

Road 

brushing/maintenance

440 yards (0.25 mile) NA NA

Log hauling on open roads 440 yards (0.25 mile) NA NA

Rock crushing 440 yards (0.25 mile) 120 yards NA

Tree climbing 25 yards 25 yards NA

NA = not applicable

Portions of the Government Camp east parcel are located within 0.25 mile of mapped suitable 

spotted owl habitat. 

Environmental Consequences

Analysis Area

The analysis area for spotted owl consists of the land parcels proposed for transfer as well as 

areas included within 1.2 miles surrounding Government Camp parcels (figure 50) and areas 

within 1.2 miles of known owl sites for home ranges encompassing Cooper Spur parcels (figure 

51). 

No Action – Direct and Indirect Effects 

Under the no action alternative there would be no transfer of parcels. Existing habitat within 

109 acres in the Government Camp would remain under Forest Service management in the shortterm (less than 2 years) marginally suitable habitat inclusions and dispersal habitat will remain in 

existing condition. In the longer term, stands will continue to develop with additional amounts of 

suitable habitat available in future decades barring future disturbances such as wildfire, insect 

outbreak, or vegetation management activities that preclude stand development. Forest stands 

within Cooper Spur private parcels will likely develop further in maturity to an extent, but 

because these are private lands and timber harvest has occurred in the recent past, additional 

harvest in these stands is expected once they reach commercial value. 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

313

Alternative 2–Direct and Indirect Effects

Habitat Impacts

The proposed action, which consists of transferring Government Camp parcels to private 

ownership would have no direct effect on northern spotted owls. However, full build-out of 

residential development within the parcels is expected after the ownership transfer is completed 

(see Proposed Action Assumptions). Therefore, the proposed action would indirectly result in 

loss of northern spotted owl habitat loss totaling approximately 22 acres of suitable habitat and 

60 acres of dispersal habitat. Because no recent surveys have been conducted, spotted owl use of 

habitats within the Government Camp parcels is unknown. Based on the small size of suitable 

habitat inclusions within the parcels, the relative isolation from larger blocks of suitable habitat, 

and the low amount of suitable habitat (14 percent) within 1.2 miles of parcels, the potential for 

spotted owl occupancy within the parcels is expected to be low. 

Conversely, Federal acquisition of Cooper Spur parcels would place approximately 30 acres of 

marginally suitable habitat and an estimated 306 acres of dispersal habitat under Forest Service 

management. Portions of suitable habitat (27 acres) occur within the home range of a known owl 

site, while a total of 96 acres of dispersal habitat occurs within the home ranges of 5 known owl 

sites. These lands would receive consideration as spotted owl habitat for future management per 

forest plan and Endangered Species Act requirements.

Barred Owls

Direct and indirect effects of the proposed action, including loss of suitable and dispersal habitat, 

no effect on potential barred owl impacts to spotted owls in the project area, mainly due the 

general lack of suitable habitat in proximity to the parcels. 

Sound Disturbance

The proposed action would have no direct effects on sound disturbance to owls. Indirectly, forest 

clearing and residential construction activities that include use of chainsaws, heavy equipment, 

hauling on open roads, would increase potential disturbance out to 0.25 mile (table 107) for an 

undetermined length of time. Potential for impact to spotted owls due to disturbance is low 

because the only mapped suitable habitat within 0.25 mile of the parcels is located to the 

southeast of the east parcel where existing noise and human activities occur activities occur in 

the town of Government Camp and Highway 26. 

Consistency with Recovery Action 32 Designations

Recovery Action 32 of the recovery plan (USFWS 2011) prescribes retention of high-quality 

habitat stands to promote spotted owl recovery. Under Recovery Action 32, high-quality habitat 

is defined as:

“Older, multi-layered structurally complex forests that 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. This is a 

subset of spotted owl habitat and specific characteristics may vary due to climatic 

gradients and abiotic factors across the range.”

Portions of stands within the Government Camp parcels contain these characteristics. While 

these areas are small (less than 8 acres each), the recovery action recognizes that such areas may 

be small and should be retained. Therefore, habitat loss resulting indirectly from the proposed 

action is inconsistent with Recovery Action 32. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

314

Effects of Other Proposed Action Elements

Elements of the proposed action identified in the DEIS other than land transfer include potential 

wetland easements (if mutually agreed upon), trail easements, and infrastructure special use 

permits and water permit conveyance. These would have no additional measurable effect on 

northern spotted owls. Creation of the Crystal Springs Watershed Special Resource Management 

Unit, identified as an action connected to the proposed action, would have no measurable effect 

on northern spotted owls. Change in land use allocation of 1,709 acres outside the Cooper Spur 

parcels from current land use allocations to additions of wilderness may preclude potential future 

management impacts to habitats within these lands, but would also preclude future habitat 

restoration opportunities if they exist. Wilderness additions would have no measurable effect on 

northern spotted owls. 

Cumulative Effects

The cumulative effects analysis area consists of the parcels proposed for transfer and areas out to 

1.2 miles from these parcels. Past activities such as timber harvest, road construction, 

development, wildfire, and other disturbances are reflected in the existing condition. Ongoing 

and foreseeable activities within the analysis area are listed in appendix A. Those consisting of 

recreation, residential use, infrastructure operations and maintenance, and highway expansion 

would continue to create noise disturbance out to 0.25 mile. The Mazama Lodge Parking Area 

Expansion has the potential to remove a small amount of spotted owl habitat (less than one acre). 

The Mirror Lake Trail Relocation Project may impact small amounts of habitat via parking lot 

construction and new trail construction. The additional effect of these activities is minor and 

does not measurably change overall impacts to spotted owls described above. Any future Forest 

Service projects that include Cooper Spur parcels would be subject to environmental analysis 

and section 7 Endangered Species Act consultation requirements where applicable.

Determinations

Alternative 1 (No Action) 

Alternative 1 would have no effect on northern spotted owls. 

Alternative 2 (Proposed Action)

Alternative 2 may affect, and is likely to adversely affect spotted owls based on the following 

rationale:

• The proposed action would remove approximately 22 acres of spotted owl suitable habitat.

• Potential for spotted owl occurrence with the parcels is expected to be low; however, 

recent spotted owl presence/absence surveys have not been conducted within the 

Government Camp parcels proposed for transfer or within 1.2 miles of these parcels.

North American Wolverine

Affected Environment

In February 2013, the U.S. Fish and Wildlife Service published a proposed rule to list the North 

American wolverine (Gulo gulo luscus) as a threatened distinct population segment in the 

contiguous United States (Federal Register, Vol. 78, No. 23, February 4, 2013, Proposed Rules). 

On August 13, 2014 the U.S. Fish and Wildlife Service withdrew its previous proposal (Federal 

Register, Vol. 79, No. 156, August 13, 2014, Proposed Rules). On April 14, 2016, the Court 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

315

remanded the matter to the U.S. Fish and Wildlife Service for further consideration consistent 

with order CV 14-246-M-DLC (Consolidated with Case Nos.14-247-M-DLC and 14-250-MDLC). The species is currently considered proposed for Federal listing. 

Deep, persistent, and reliable spring snow cover (April 15 to May 14) is the best overall 

predictor of wolverine occurrence in the contiguous United States (Aubry et al. 2007; Copeland 

et al. 2010), although evidence of a requirement for deep snow beyond a den site is lacking 

(USDI Fish and Wildlife Service 2014). Wolverines are opportunistic, consuming a variety of 

foods but primarily scavenged carrion (Hornocker and Hash 1981). Wolverines in Glacier 

National Park had average adult male home ranges of 193 square miles and adult female home 

ranges of 55 square miles (Copeland and Yates 2006). In Montana, natal dens occur above 

7,874 feet and are located on north aspects in avalanche debris, typically in alpine habitats near 

timberline (Inman et al. 2007). Female wolverines forage close to their den in early summer, 

progressively ranging further from dens as kits become more independent (May et al. 2010).

Wolverines have a high dispersal capability and seem to be able to move successfully through 

highly altered landscapes.

Populations in the Cascade Mountains are small and scattered. Current records (1995–2005) are 

limited to north-central Washington, northern and central Idaho, western Montana, and 

northwestern Wyoming (Aubrey 2007). Historic sightings of wolverines both verified and 

unverified are within a few miles of the project area. Snow Bunny Snow Park had one verified 

track sighting in 1990. However, current thinking on wolverine distribution is that individual 

wolverines may invade the Oregon Cascades on occasion but that there is no breeding population 

this far south (Aubry 2007). Camera and hair sample surveys conducted recently in the Cascades 

south of the Mt. Hood National Forest found no evidence of wolverine occurrence (McFaddenHiller and Hiller 2014). 

Recent field surveys in the project area have not been accomplished. The last time broad-based 

surveys were conducted over the watershed was during the winter of 1993–1994 and 1994–1995. 

Some survey efforts have been ongoing, centered around Mt. Hood, but at this point in time there 

have been no verifiable sightings of wolverine or sign of presence. A group of volunteers led by 

Cascadia Wild have performed tracking surveys and some remote camera work for the Mt. Hood 

National Forest since 2001. No wolverine tracks or photos have been located anywhere on the 

national forest during that time. There are also no verified sightings in the Oregon Cascades for 

the last decade. The last verified sighting of a wolverine in the Oregon Cascades was a wolverine 

killed on Interstate 84 near Hood River in 1994.

Habitat within the Analysis Area

Government Camp Parcels

Habitats within these parcels consist of moderate-aged (80 to 120 years old) forested stands with 

relatively large expanses of unroaded and undisturbed lands to the north and developed 

recreation, roaded areas, and urban lands immediately to the east and south. Several well-used 

trails as well as a powerline corridor currently exist within the western parcel. Due to existing 

levels of human activity, wolverine are unlikely to make this a portion of a home range core area, 

but may occasionally pass through the Government Camp parcels. No structure is available for 

denning.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

316

Cooper Spur Parcels

Forested stands within the Cooper Spur parcels consist of young and moderate-aged conifer at 

elevations below 3,800 feet. The area is well roaded with buildings located in the eastern portion.

Although some rock scree slopes exist in the northeastern corner of the parcel, these slopes do 

not constitute suitable denning habitat due to the low elevations and lack of persistent spring 

snows. Due to the low elevation, existing levels of human activity, and lack of unroaded and 

undisturbed lands, presence of wolverines and suitable wolverine habitat within the Cooper Spur 

parcels is unlikely.

Environmental Consequences

No-action Alternative

Under the no-action alternative, existing land ownership in the Government Camp and Cooper 

Spur parcels would remain unchanged. No transfer in ownership of existing amounts of 

California wolverine habitat would occur. No direct, indirect, or cumulative effects would occur 

as a result of the no-action alternative.

Proposed Action

Direct and Indirect Effects

Implementation of the proposed action would have no direct effects on wolverine or habitat. 

Existing levels of disturbance generated by hiking trails that may get used year-round, powerline 

right-of-way, and adjacent residential areas make the parcels an unlikely place for wolverine to 

utilize other than for transient movements. Within the Government Camp parcels, it is assumed 

that under private ownership these lands would be developed for residential, commercial, or 

recreational uses, thereby indirectly removing habitat or further increasing disturbance in areas 

that are currently suitable for travel only. Loss of this habitat would total 109 acres. Loss of 

habitat would not create barriers to wolverine movements at the landscape level.

Upper elevation areas (above 4,000 to 4,500 feet) of the Mt. Hood National Forest consisting of 

mountain hemlock, Pacific silver fir, and alpine vegetation zones are most likely to be used for 

travel by wolverines if present. These areas total approximately 583,669 acres. The loss of travel 

habitat within the Government Camp parcels would equate to approximately 0.02 percent of 

habitat estimated within the Forest. 

Cumulative Effects

The cumulative effects analysis area consists of the parcels proposed for transfer and areas out to 

1.0 mile from these parcels. This encompasses the potential disturbances and habitat impacts for 

wolverine traveling through the area (Scrafford and Boyce 2015). Past activities such as timber 

harvest, road construction, development, wildfire, and other disturbances are reflected in the 

existing condition. Ongoing and foreseeable activities within the analysis area are listed in the 

Past, Present, and Reasonably Foreseeable Actions section. Those consisting of recreation, 

residential use, infrastructure operations and maintenance, and highway expansion would 

continue to create noise disturbance to wolverines out to 1 mile. The Mazama Lodge Parking 

Area Expansion has the potential to remove a small amount of habitat (less than one acre). The 

Mirror Lake Trail Relocation Project may impact small amounts of habitat via parking lot 

construction and new trail construction. The additional effect of these activities is minor and 

does not measurably change overall impacts to wolverines described above. 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

317

Determinations

Alternative 1 (No Action)

Alternative 1 would have no effect on North American wolverines. 

Alternative 2 (Proposed Action)

Alternative 2 will not jeopardize the continued existence of North American wolverines based on 

the following rationale:

• The proposed action would indirectly cause 109 acres of habitat suitable for wolverine 

travel.

• The amount of habitat loss equates to approximately 0.02 percent of travel habitat 

estimated to be available on the Mt. Hood National Forest. 

• The loss of habitat would not create barriers to wolverine movements across the landscape.

• There is currently no known population of wolverines in the Oregon Cascades.

Sensitive Species Carried Forward for Analysis

Sierra Nevada Red Fox

Affected Environment

Sierra Nevada red fox use multiple habitat types in the alpine and subalpine zones (near and 

above treeline). In addition to meadows and rocky areas the species use high-elevation conifer 

habitat in typically open or patchy structure. In winter, they are known to descend into highelevation conifer areas above the subalpine zone (USDI Fish and Wildlife Service 2015). Winter 

sightings in the Oregon Cascades have been in elevations as low as 4,200 feet where the species 

shows a preference for mature closed-canopy conifer forests. Sierra Nevada red fox use natural 

openings in rock piles at the base of cliffs and slopes as denning sites. They may also dig earthen 

dens, but this has not been directly documented. 

Home range for the species in Oregon has not been documented. In the Lassen area (California) 

summer home range size averages about 6,400 acres, with winter home ranges larger, averaging 

about 8,000 acres. Recent species occurrence has been confirmed in the Oregon Cascades as far 

north as Mount Hood. The Mount Hood sightings consist of 15 reports, with three individuals 

distinguished. No estimation of population size or trend in the Oregon Cascades has been 

identified (USDI Fish and Wildlife Service 2015). 

Sierra Nevada red fox could be impacted by noise disturbance from recreation areas, but the 

magnitude of impacts from noise is unknown. Red foxes in the Lassen area of California clearly 

use roads as movement corridors to facilitate both daily and seasonal movements, with some 

individuals foraging along the roads, and several foxes in the Lassen area became acclimated to 

humans, posing problems at some campgrounds and parking areas (Perrine 2005). Sightings in 

areas with existing recreational disturbance suggests the species adjusts to such disturbances 

(USDI Fish and Wildlife Service 2015). 

No sightings have been reported within the analysis area. The nearest known sighting (2013) is 

located approximately 2 miles north of the Government Camp parcels. Carnivore sampling 

stations placed at elevations ranging from 1,250 to 6,400 feet recorded red fox in the Mount 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

318

Hood area recorded red fox occurrences at elevations between 4,700 and 6,300 feet. Nine of 

eleven red fox observations occurred within 1 mile of treeline. The observation most distant from 

alpine habitat was located approximately 1.4 miles from treeline (Mt. Hood National Forest, 

NRIS Database).

Habitat within the Analysis Area

Government Camp Parcels

Habitats within these parcels consist of moderate-aged (80 to 120 years old) relatively dense 

conifer stands with relatively large expanses of unroaded and undisturbed lands to the north, 

including alpine habitats, and developed recreation, roaded areas, and urban lands immediately 

to the east and south. Several well-used trails as well as a powerline corridor currently exist 

within the western parcel. Government Camp parcels are located approximately 2 miles from 

alpine habitats on Mount Hood and about 2 miles from documented species occurrence. Parcel 

elevations range from about 3,760 to 4,120 feet, which is just below the lowest elevation 

reported for Oregon sightings (4,200 feet) and lower than those reported for the Mount Hood 

area (4,700 feet).

Cooper Spur Parcels

Forested stands within the Cooper Spur parcels consist of young and moderate-aged conifer at 

elevations below 3,800 feet. The area is well roaded with buildings located in the eastern portion.

Due to the low elevation and general lack of dense mature conifer stands within these parcels, it 

is unlikely that the Cooper Spur parcels function as either suitable habitat or part of an overall 

seasonal home range.

Environmental Consequences

No-action Alternative

Under the no-action alternative, existing land ownership in the Government Camp and Cooper 

Spur parcels would remain unchanged. No transfer in ownership of existing amounts of Sierra 

Nevada red fox habitat would occur. No direct, indirect, or cumulative effects would occur as a 

result of the no-action alternative.

Proposed Action

Direct and Indirect Effects

Implementation of the proposed action would have no direct effects on red fox or habitat. 

Existing elevations (below 4,200 feet) in addition to distance from alpine and treeline (just over 

2 miles) decrease the potential for red fox occurrence, but do not eliminate the possibility. Given 

that little documented information is available to suggest that the species avoids human presence 

and disturbances, it is possible that Government Camp parcels are used by the species as lower 

elevation portions of a winter home range. Within the Government Camp parcels, it is assumed 

that under private ownership these lands would be developed, thereby indirectly removing 

habitat that may be used by the species. Loss of this habitat would total 109 acres. Loss of 

habitat would not create barriers to Sierra Nevada red fox movements at the landscape level.

Alpine habitats on the Mt. Hood National Forest total approximately 14,500 acres and upper 

elevation conifer areas within 2 miles of alpine habitat total about 36,100 acres. Combined, these 

areas amount to over 50,000 acres of potential suitable red fox habitat. Removal of 109 acres of 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

319

habitat located on the lower fringe of suitability would equate to approximately 0.2 percent of 

available habitat. 

Cumulative Effects

The cumulative effects analysis area consists of the parcels proposed for transfer and areas out to 

0.25 mile from these parcels. This encompasses the potential habitat impacts for Sierra Nevada 

red fox through the area (Scrafford and Boyce 2015). Past activities such as timber harvest, road 

construction, development, wildfire, and other disturbances are reflected in the existing 

condition. Ongoing and foreseeable activities in proximity to the project area are listed in the 

Past, Present, and Reasonably Foreseeable Actions section. Those consisting of recreation, 

residential use, infrastructure operations and maintenance, and highway expansion would 

continue to create noise disturbance, but the effects to red foxes is expected to be minor given 

the species’ apparent ability to adjust to some level of human presence. The Mazama Lodge 

Parking Area Expansion has the potential to remove a small amount of habitat (less than one 

acre). The Mirror Lake Trail Relocation Project may impact small amounts of habitat via parking 

lot construction and new trail construction. The additional effect of these activities is minor and 

does not measurably change overall impacts to Sierra Nevada red fox described above. 

Determinations

Alternative 1 (No Action) 

Alternative 1 would have no impact on Sierra Nevada red fox. 

Alternative 2 (Proposed Action)

Alternative 2 may impact individuals, but is not likely to cause a trend to Federal listing or loss 

of viability to the species based on the following rationale:

• The proposed action would indirectly cause 109 acres of habitat suitable for red fox travel.

• The amount of habitat loss equates to approximately 0.2 percent of habitat estimated to be 

available on the Mt. Hood National Forest. 

• The loss of habitat would not create barriers to red fox movements across the landscape.

• Habitat loss would occur in an area with lower probability of species occurrence.

Cope’s Giant Salamander 

Affected Environment

Habitat

The Cope’s giant salamander ranges across two distinct ecoregions in western Washington and 

Oregon, occurring predominantly in the Coast Ranges and Cascade Range. In the Cascade Range 

it occurs from the Nisqually River at Mount Rainier National Park, Washington, southward to 

the upper White River watershed in Wasco County, Oregon. The species is absent in the Puget 

Sound lowlands and the northeastern portion of the Olympic Peninsula in Washington, and the 

Willamette Valley lowlands and foothills in Oregon (Foster and Olsen 2014)

This species is found in small, steep-gradient, permanent streams with clear, cold water.

Streambeds are composed of large gravel to small boulders, with some large logs and no silt 

(Corkran and Thoms 1996). Normally, this species is restricted to moist coniferous forests with 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

320

water temperatures ranging from 8 to 14 degrees Celsius (46 to 57 degrees Fahrenheit), and can 

be found under stones, bark slabs, or other cover in streams, and out of streams on wet rocks and 

streamside vegetation in nights with heavy rainfall (Nussbaum et al. 1983). Steele et al. (2002) 

reported capturing this species in streams within commercial forest stands ranging from 0 to 

nearly 100 years old. Adams and Bury (2002) found this species in natural stands within 

Olympic National Park to be a generalist in terms of stream substrate, gradient, and aspect, but it 

was associated with low canopy cover. This species has been reported on the Mt. Hood National 

Forest at elevations below 5,500 feet. Based on satellite imagery, forest conditions at known sites 

on the Mt. Hood National Forest appear to vary widely in stand age and structure.

No occurrences are reported for either Government Camp or Cooper Spur parcels. The nearest 

observation to Government Camp parcels, reported in 2006, is located about 2.5 miles to the 

southeast. The closest occurrence to Cooper Spur parcels (2001) is approximately 3.5 miles to 

the northwest.

Habitat within the Analysis Area

Given the rather general nature of habitat associations and with elevational range (from sea level 

to below 5,500 feet), the species may occur in association with perennial streams within 

Government Camp and/or Cooper Spur parcels.

Government Camp Parcels

Suitable habitat consisting of perennial streams occurs within both Government Camp parcels.

Approximately 770 feet of Camp Creek runs through the southeastern corner of the western 

parcel. About 1,140 feet of an unnamed perennial creek bisects the northwestern quarter of the 

eastern parcel.

Coopers Spur Parcels

Perennial stream habitat occurs within the Coopers Spur parcels, with portions of Ash Creek 

(1.5 miles), Doe Creek (1.1 mile), and Tilly Jane Creek (0.8 mile) flowing through the eastern 

portion of these lands.

Environmental Consequences

No-action Alternative

Under the no-action alternative, existing land ownership in the Government Camp and Cooper 

Spur parcels would remain unchanged. No transfer in ownership of existing amounts of Cope’s 

giant salamander habitat would occur. No direct, indirect, or cumulative effects would occur as a 

result of the no-action alternative.

Proposed Action

Direct and Indirect Effects

Implementation of the proposed action would have no direct effects on Cope’s giant salamander 

or habitat. Indirectly, increased peak flows and level of sediment delivery into steams is expected 

due to surrounding development (see Hydrology Specialist Report).

Water Quantity

Peak streamflow increases above 10 percent have the potential to cause stream channel damage 

in the form of increased bank erosion, channel scour, channel widening, and sedimentation. At 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

321

the site scale, both Camp Creek and the unnamed tributary to the Little Zigzag River have 

predicted peak stream flows increases above 10 percent and based on stream surveys on Camp 

Creek and the Little Zigzag River the dominant substrate is these areas is gravel and based on 

stream gradient from NetMap stream datasets there are sections of stream with gradients in the 

2 to 4 percent range. Based on predicted increases in peak stream flows, streambed composition 

and stream gradient there may be impacts in the form of increased bank erosion, channel scour, 

channel widening, and sedimentation in these areas (see Hydrology Specialist Report). These 

changes in stream structure may impact habitat suitability for Cope’s giant salamander within the 

project area.

Water Quality

Removal of surrounding trees due to residential development is predicted to cause slight 

increases in stream temperatures compared to the existing condition. Additional sediment yield 

of about 3 percent is also predicted due to changes in the road network and land use associated 

with implementation of the proposed action (see Hydrology Specialist Report). Changes in 

stream temperature and sediment yield may alter habitat suitability for this species within the 

project area.

Impacts Summary

The proposed action may impact Cope’s giant salamander habitat suitability within portions or 

all perennial streams via predicted increases in stream flows, water temperatures, and sediment 

delivery. Impacts would be localized to two stream reaches (upper portions of Camp Creek and 

tributary to Zigzag Creek). At the larger scale, the Zigzag River subwatershed contains 

approximately 80.1 miles of perennial streams below treeline. Stream length within the parcels 

totals about 0.4 mile, which equates to approximately 0.5 percent of perennial stream length 

within the subwatershed. 

Cumulative Effects

The cumulative effects analysis area consists of perennial stream habitats within and downstream 

from the Government Camp parcels. This encompasses the potential disturbances and habitat 

impacts for Cope’s giant salamander. Past activities such as timber harvest, road construction, 

development, wildfire, and other disturbances are reflected in the existing condition. Ongoing 

and foreseeable activities in proximity to the parcels are listed in the Past, Present, and 

Reasonably Foreseeable Actions section. No projects or activities listed in appendix A are 

expected to contribute detrimental cumulative effects to peak stream flows, stream temperatures, 

or sediment delivery (see Hydrology Specialist Report). 

Determinations

Alternative 1 (No Action) 

Alternative 1 would have no impact on Cope’s giant salamanders. 

Alternative 2 (Proposed Action)

Alternative 2 may impact individuals, but is not likely to cause a trend to Federal listing or loss 

of viability to the species based on the following rationale:

• An increase in sediment delivery, temperature, and streamflow to existing streams is 

expected.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

322

• The affected habitat represents a very small portion of potential habitat within the Zigzag 

subwatershed.

Larch Mountain Salamander 

Affected Environment

Habitat

Larch Mountain salamanders occur in a wide array of habitat types including: (1) old-growth 

forests; (2) younger naturally regenerated forests in gravelly/cobble soils with residual late 

successional features (snags and large down logs); (3) scree and talus (forested and un-forested); 

and (4) lava tube entrances where debris (e.g., pieces of lava, wood, fine organic and inorganic 

particles) has accumulated. In a large portion of the species range, late-seral forest conditions 

appear to be crucial to the species existence. In other areas, combinations of rocky substrates, 

soils, and vegetation provide suitable cool, moist microhabitat conditions necessary for Larch 

Mountain salamanders to exist. Recorded species observations range in elevation from 1,698 to 

3,608 feet, with most individuals found between 2,600 and 3,280 feet (Crisafulli et al. 2008), 

although the species has also been described to occur up to 3,950 feet (Crisafulli 1999). Species 

locations showed no preference for aspect, however, 90 percent of individuals were found on 

slopes greater than 40 percent (Crisafulli et al. 2008). 

The relative importance of vegetation composition and structure appears to be related to the 

substrate/soil conditions present at a site. When rocky substrates (scree, talus or gravelly soils) 

are prevalent, the role of vegetation composition and structure appears to be less important; and 

animals are found where several vegetation types occur. In contrast, when loamy soils are 

present, Larch Mountain salamanders appear to be restricted to sites only with old-growth forest 

conditions, or confined to small isolated pockets of refugia possessing rocky substrates within 

the matrix of old-growth forest with loamy soils (Crisafulli et al. 2008).

Habitat within the Analysis Area

Government Camp Parcels

Surface soils within the eastern three-quarters of Government Camp parcels are composed 

primarily of gravelly loams derived from fine to medium textured glacial till, locally influenced 

by volcanic ash deposit (Soil Resources Inventory [SRI] mapping unit 380). Outcrops of 

tuffaceous brecchia, while described as common in this soil type, were not observed within the 

Government Camp parcels. In the western quarter of the parcels, soil surface layers consist of 

brown sandy loams and silt loams derived from unconsolidated medium textured glacial till (SRI 

mapping unit 333).

Query of the NRIS database showed no reported observations of Larch Mountain salamander 

within 12 miles of these parcels.

Cooper Spur Parcels

Soils information from Mt. Hood National Forest GIS layers is available only for extreme 

western, eastern portions of these parcels, as well as the entire southern “leg.” Extrapolation of 

soil map polygons indicate that soils composition within these parcels are more varied that those 

within the Government Camp parcels. The western portion contains SRI type 333 (discussed 

above) and SRI type 334 (sandy loams and silt loams somewhat similar to 333). In the eastern 

portion, SRI mapping units include 6-7, 168, and 169-6. SRI 168 and 169 consist of cobbly fine 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

323

sandy loams and silt loams of volcanic ash overlaying bedrock of basalt and andesite. Types 6 

and 7 are unvegetated talus and rubbleland consisting of fallen rock materials at the foot of rock 

slopes and headwalls (type 6) and large exposed outcrops of basalt and andesite with some areas 

of shallow soils (type 7). The southern leg is composed almost entirely of SRI 168 with a small 

amount of 6 and 7.

Similar to the Government Camp parcels, query of the NRIS database showed no reported 

observations of Larch Mountain salamander within 12 miles of Cooper Spur parcels.

Environmental Consequences

No-action Alternative

Under the no-action alternative, existing land ownership in the Government Camp and Cooper 

Spur parcels would remain unchanged. No transfer in ownership of existing amounts of Larch 

Mountain salamander would occur. No direct, indirect, or cumulative effects would occur as a 

result of the no-action alternative.

Proposed Action

Direct and Indirect Effects

Implementation of the proposed action would have no direct effects on Larch Mountain 

salamander or habitat. Analysis of forest condition and soils information available for 

Government Camp parcels indicates a lack of old-growth forest, and lack of rock features 

including talus/scree and lava tubes. These parcels do contain mature forests in gravelly or 

cobble soils with residual late successional features (snags and large down logs). The area 

estimated to contain these conditions totals about 12.3 acres. However, the likelihood of Larch 

Mountain salamander occurrence is reduced because the elevation range of these parcels 

(3,760 to 4,100 feet) are at the upper limit or higher than those described for distribution of the 

species (up to 3,950 feet). In addition, the lack of slopes greater than 40 percent, (where 

Crisafulli et al. reported 90 percent of individuals occurring) further decreases the likelihood of 

species presence. After ownership transfer, subsequent forest removal and infrastructure 

development would lead to loss of potential habitat on 12.3 acres with a low potential for species 

occurrence.

Soil and rock conditions in Cooper Spur parcels appear more suitable for this species, 

specifically in areas containing talus, scree, and rocky outcrops. Available soil mapping shows 

that about 60 acres of soil type 6, 7, or a combination of both, occur within Cooper Spur parcels, 

mainly in the vicinity of Tilly Jane Creek. In addition, a large portion of Cooper Spur parcels 

occur at elevations between 2,600 and 3,280 feet where Crisafulli et al. (2008) reported 

individuals to be more common. Within those elevations, small inclusions of talus and scree 

slopes are present on slopes exceeding 40 percent. Mature conifer stands are present along Tilly 

Jane Creek, but the Cooper Spur parcels general lack any old-growth forest structure.

Cumulative Effects

The cumulative effects analysis area consists of suitable habitats within the portions of parcels 

proposed for transfer. This encompasses the potential disturbances and habitat impacts for Larch 

Mountain salamander. Past activities such as timber harvest, road construction, development, 

wildfire, and other disturbances are reflected in the existing condition. Ongoing and foreseeable 

activities in proximity to the project area are listed in appendix A. None of the activities listed in 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

324

appendix A are expected to cause substantial impacts in excess of those described in the direct or 

indirect effects. 

Determinations

Alternative 1 (No Action)

Alternative 1 would have no impact on Larch Mountain salamander. 

Alternative 2 (Proposed Action) 

Alternative 2 may impact individuals, but is not likely to cause a trend to Federal listing or loss 

of viability to the species based on the following rationale:

• The proposed action would remove about 12 acres of potentially suitable habitat.

• There is a lower probability for species occurrence due to lack of steep slopes, rocky 

outcrops, and habitat location at the upper elevational limit described for the species.

Johnson’s Hairstreak

Affected Environment

These butterflies have been found in Southwestern British Columbia, south through eastern and 

western Washington, Oregon, and western Idaho to central California. Scattered sightings have 

been reported in Oregon in the Cascades, Coast Range, Siskiyou Mountains, Blue Mountains and 

Wallowa Mountains. Johnson’s hairstreak has been found in Washington in Olympic and Mt.

Rainer National Parks as well as at a few other locations in western Washington. In Oregon, 

most records indicate that this butterfly survives from 2,000 feet or higher, with the majority 

living at approximately 3,500 feet, and a few as high as 5,000 and 6,000 feet (Huff 2011).

This species is believed to be closely associated with old-growth forests that are infected with 

dwarf mistletoe (Arceuthobium spp.). However, eggs and larvae have been found from infected 

second growth stands as well. The primary host trees for dwarf mistletoes that are associated 

with C. johnsoni presence are western hemlock (Tsuga heterophylla), mountain hemlock (Tsuga 

mertensiana) white fir (Abies concolor) and ponderosa pine (Pinus ponderosa). Dwarf mistletoe 

can occur on all age classes of forest, but is most abundant in mature stands and old-growth.

Johnson’s hairstreak is seldom seen, perhaps because it spends most of its adult life high in the 

forest canopy (Davis and Weaver 2011).

Habitat within the Analysis Area

Government Camp Parcels

Mountain hemlock trees of various sizes are present in these parcels, more specifically 

throughout much of the western parcel, and within the western portion of the eastern parcel. No 

surveys for Johnson’s hairstreak have been conducted within these areas. Field visits noted 

presence of brooms and platforms within conifers, but did not specify or quantify mistletoe 

presence by conifer type (Dyck 2010, pers. comm.). Potential suitable habitat within mature 

conifer containing hemlock totals approximately 22 acres. 

Cooper Spur Parcels

Western and mountain hemlock are absent from Cooper Spur parcels. Ponderosa pine occurs as 

inclusions of mixed conifer stands. Current level of mistletoe occurrence in these stands is 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

325

unknown, but levels are likely to be low if at all present. No known Johnson’s hairstreak 

occurrences are reported for this area.

Environmental Consequences

No-action Alternative

Under the no-action alternative, existing land ownership in the Government Camp and Cooper 

Spur parcels would remain unchanged. No transfer in ownership of existing amounts of 

Johnson’s hairstreak habitat would occur. No direct, indirect, or cumulative effects would occur 

as a result of the no-action alternative.

Proposed Action

Direct and Indirect Effects

Implementation of the proposed action would have no direct effects on Johnson’s hairstreak or 

habitat. Stands where a suitable host species (mountain hemlock) is considered a major species 

component within the Government Camp parcels total about 22 acres, whereas stands with a 

major presence of a suitable host species and potential mistletoe presence are largely lacking. 

Due to advanced stand development and noted indications of dwarf mistletoe presence, 

Government Camp parcels are more likely to contain suitable Johnson’s hairstreak habitat. 

Therefore, implementation of the proposed action would reduce Federal ownership of potential 

habitat for Johnson’s hairstreak by an estimated 22 acres. Subsequent development of 

Government Camp parcels would likely cause habitat loss on 22 acres. Mid to late-seral stands 

(trees larger than 15 inches diameter) containing tree species known to host suitable mistletoe 

species total approximately 119,000 acres within the Mt. Hood National Forest. Loss of 22 acres 

equates to approximately 0.02 percent of existing within the national forest.

Cumulative Effects

The cumulative effects analysis area consists of the parcels proposed for transfer and areas out to 

0.25 mile from these parcels. This encompasses the potential area of use by individuals that may 

use habitats within the parcels. Past activities such as timber harvest, road construction, 

development, wildfire, and other disturbances are reflected in the existing condition. Ongoing 

and foreseeable activities within the analysis area are listed in appendix A. Those consisting of 

recreation, residential use, infrastructure operations and maintenance are not expected increase 

habitat impacts. The Mazama Lodge Parking Area Expansion has the potential to remove a small 

amount of habitat (less than one acre). The Mirror Lake Trail Relocation Project may impact 

small amounts of habitat via parking lot construction and new trail construction. Suitability of 

these habitats would depend on presence of mistletoe preferred by Johnson’s hairstreak. The 

additional effect of these activities is minor and does not measurably increases impacts described 

for direct and indirect effects.

Determinations

Alternative 1 (No Action) 

Alternative 1 would have no impact on Johnson’s hairstreak. 

Alternative 2 (Proposed Action)

Alternative 2 may impact individuals, but is not likely to cause a trend to Federal listing or loss 

of viability to the species based on the following rationale:
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

326

• The proposed action would remove about 22 acres of potentially suitable habitat.

• Affected acres represent a very small portion (0.02 percent) estimated existing potential 

suitable habitat.

Fringed Myotis

Affected Environment

Myotis thysanodes ranges through much of western North America from southern British 

Columbia, Canada, south to Chiapas, Mexico and from Santa Cruz Island in California, east to 

the Black Hills of South Dakota.

Habitats for fringed myotis in Oregon are not well described. Day roosts in northwestern 

California consisted primarily of larger snags (Weller and Zabel 2001). In the eastern Cascades 

of Oregon and Washington, roost sites were in rock substrates consist primarily of rocky 

outcrops, talus slopes, large rocks in wooded side slopes, and boulder fields. Several roost sites 

were also in ponderosa pine snags (Lacki and Baker 2007). Reported night roost structures used 

by this species include bridges, buildings, caves, mines, rock crevices, and under bark or in tree 

cavities (Lacki et al. 2007). Frequent roost switching is reported to be common. Foraging 

habitats reported for the Pacific Northwest include areas along streams and rivers, and 

old-growth Douglas-fir/hemlock forest (Verts and Carraway 1998, Nagorsen and Bridgham 

1993).

There are no reported fringed myotis sightings within the project area. The closest reported 

occurrence of this species to Government Camp parcels is located about 20 miles to the 

southwest. Nearest reported occurrence to Cooper Spur parcels is located approximately 31 

miles to the southwest (Mt. Hood National Forest NRIS database).

Habitats within the Analysis Area

Government Camp Parcels

These parcels lack buildings, caves, bridges, and rock features as potential roosting habitat.

Some moderate and larger-diameter snags noted during field reconnaissance may serve as 

suitable roosting sites within 22 acres of forest stands. Buildings and bridges are present on 

private lands adjacent to these parcels. Foraging habitat is present along existing streams and in 

portions of forested stands with older forest characteristics.

Cooper Spur Parcels

No known caves or bridges occur within the Cooper Spur parcels. About 10 buildings are located 

in the southern portion. Potential or existing bat roosting activities within these buildings are 

unknown. Rocky scree slopes appear to occur in the northeastern portion of these parcels.

Potential foraging habitat exists along portions of Ash Creek, Doe Creek, and Tilly Jane Creek.

No known species observations are reported for these lands. Nearest reported occurrence is 

located approximately 31 miles to the southwest (Mt. Hood National Forest NRIS database).
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

327

Table 108. Fringed myotis habitat features within parcels

Habitat Feature Government Camp Parcels Cooper Spur Parcels

Rock/scree (roosting) 0 acres 8.5 acres

Advanced Forest (roosting and foraging) 22 acres 30 acres*

Riparian (foraging) 0.4 mile 3.4 miles

Building (roosting) 0 10

*size, condition, and abundance of snags are unknown.

Environmental Consequences

No-action Alternative

Under the no-action alternative, existing land ownership in the Government Camp and Cooper 

Spur parcels would remain unchanged. No transfer in ownership of existing amounts of fringed 

myotis habitat would occur. No direct, indirect, or cumulative effects would occur as a result of 

the no-action alternative.

Proposed Action

Direct and Indirect Effects

Implementation of the proposed action would have no direct effects on fringed myotis or habitat.

Potential tree roosting could occur in stands with more advanced structure. Such structure is 

estimated to total about 22 acres in Government Camp and about 30 acres in Cooper Spur 

parcels. However, snags that may support roosting were observed in Government Camp parcels; 

status of snag size, condition, and abundance in Cooper Spur parcels is unknown. Buildings as 

roosting structure occur only in Cooper Spur parcels. Riparian foraging habitat occurs along 

about 0.4 mile of perennial stream in Government Camp parcels in comparison to 3.4 miles 

within Cooper Spur. In addition, buildings and talus/scree sites that may provide roosting are 

present only in Cooper Spur parcels.

Implementation of the proposed action and subsequent development would reduce Federal 

ownership of potential habitat for fringed myotis by an estimated 22 acres. Advanced stands with 

structural characteristics (conifer stands greater than 20 inches diameter) that may support 

roosting total approximately 276,000 acres within the Mt. Hood National Forest. Loss of 

22 acres equates to less than 0.01 percent of existing within the national forest.

Cumulative Effects

Fringed myotis may move fairly long distances between foraging and roosting habitats. 

However, overlap distances of potential disturbances to roosting and foraging with those impacts 

described for the project area are likely to occur within one mile of parcels. Past activities such 

as timber harvest, road construction, development, wildfire, and other disturbances are reflected 

in the existing condition. Ongoing and foreseeable activities listed in the Past, Present, and 

Reasonably Foreseeable Actions section consisting of recreation, residential use, infrastructure 

operations and maintenance are not expected increase habitat impacts. The Mazama Lodge 

Parking Area Expansion has the potential to remove a small amount of potential tree roosting 

habitat (less than one acre). The Mirror Lake Trail Relocation Project may impact small amounts 

of habitat via parking lot construction and new trail construction. Suitability of these habitats 

would depend on presence of larger snags with loose bark or cavities. The additional effect of 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

328

these activities is expected to be minor and does not measurably increases impacts described for 

direct and indirect effects.

Determinations

Alternative 1 (No Action) 

Alternative 1 would have no impact on fringed myotis. 

Alternative 2 (Proposed Action) 

Alternative 2 may impact individuals, but is not likely to cause a trend to Federal listing or loss 

of viability to the species based on the following rationale:

• The proposed action would remove about 22 acres of potentially suitable habitat.

• Affected acres represent a very small portion (less than 0.01 percent) estimated existing 

potential suitable roosting habitat.

Townsend’s Big-eared Bat

Affected Environment

Corynorhinus townsendii occurs throughout the west and is distributed from the southern portion 

of British Columbia south along the Pacific coast to central Mexico and east into the Great 

Plains, with isolated populations occurring in the central and eastern United States.

Townsend’s big-eared bat commonly is considered a cave-dwelling species, and caves and 

abandoned mine tunnels are considered primary hibernacula and maternity sites for this species 

(Verts and Carraway 1998). Buildings and bridges are frequently used as night roosts (Csuti et al. 

1997). Foraging habitat for Townsend’s big-eared bat includes forest edges, roads, riparian 

forest, or forest openings (Dobkin et al. 1995, Lacki et al. 2007). 

The reported observation closest to Government Camp parcels is located about 18 miles to the 

southwest. The species observation nearest to Cooper Spur parcels is located about 30 miles to 

the southwest (Mt. Hood National Forest NRIS database).

Habitat within the Analysis Area

Government Camp Parcels

Primary reproductive, hibernation, and roosting habitats are absent from these parcels. However, 

these areas may function as foraging habitat for this species. No known observations are reported 

for these parcels.

Cooper Spur Parcels

Primary reproductive and hibernation habitat in the form of caves or abandoned mines are likely 

absent from Cooper Spur parcels. These lands also lack potential bridge roost sites. About 10 

buildings currently exist in the southern portion, but the status of suitability or potential bat 

occurrence at these sites is unknown. Both forested and nonforested portions of these parcels 

consist of suitable foraging habitat for this species. No known observations are reported for these 

parcels. The closest reported observation is located about 30 miles to the southwest (Mt. Hood 

National Forest NRIS database).
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

329

Environmental Consequences

No-action Alternative

Under the no-action alternative, existing land ownership in the Government Camp and Cooper 

Spur parcels would remain unchanged. No transfer in ownership of existing amounts of 

Townsend’s big-eared bat habitat would occur. No direct, indirect, or cumulative effects would 

occur as a result of the no action alternative.

Proposed Action

Direct and Indirect Effects

Implementation of the proposed action would have no direct effects on Townsend’s big-eared bat 

or habitat. Lands within the Government Camp parcels contain some foraging habitat in the form 

of forest openings, riparian forest, and forest edges. The western block contains a small amount 

of riparian forest with closed canopy that may be marginal for this species. Narrow openings 

created by the powerline and old road corridors constitute a strip of edge habitat about 6,100 feet 

in length. The existing parking area and trail head also constitute a small opening of about 2 

acres. Larger amounts of potential foraging habitat occur within the eastern block. This block 

contains approximately 2 acres of open wetland and meadow habitat, and about 9 acres of open 

forest habitat. Forest edge habitat is estimated at about 4,800 feet. Length of mapped perennial 

streams in all Government Camp parcels totals 1,900 feet (0.4 mile). Total open foraging habitat 

amounts to 13 acres and edge habitat about 10,900 feet (2.1 miles) within all Government Camp 

parcels (table 109). Development would likely result in loss of edge habitat, but suitable foraging 

habitat may be retained along perennial streams.

Lands within the Cooper Spur parcels appear to contain a higher amount of Townsend’s bigeared bat foraging habitat. About 141 acres of dry meadow, open canopy forest, and areas of 

rock/scree occur within these parcels. There are also approximately 9.8 miles of forest edge 

habitat where dry meadows, rock/scree areas, and early seral and open canopy forest contrast 

with denser and more developed forest stands. Length of mapped perennial streams in all Cooper 

Spur parcels totals over 3 miles.

Table 109. Townsend’s big-eared bat habitat features within parcels

Habitat Feature Government Camp Parcels Cooper Spur Parcels

Meadow/Wetland 1 acre 28 acres

Open Canopy Forest 23 acres 103.9 acres

Rock/scree Opening 0 acres 8.5 acres

Forest Edge 2.1 miles 9.8 miles

Riparian 0.4 mile 3.4 miles

Cumulative Effects

Similar to fringed myotis, Townsend’s big-eared bats may move fairly long distances between 

foraging and roosting habitats. However, overlap distances of potential disturbances to roosting 

and foraging with those impacts described for the project area are likely to occur within one mile 

of parcels. Past activities such as timber harvest, road construction, development, wildfire, and 

other disturbances are reflected in the existing condition. Ongoing and foreseeable activities 

listed in appendix A consisting of recreation, residential use, infrastructure operations and 

maintenance are not expected increase habitat impacts. The Mazama Lodge Parking Area 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

330

Expansion has the potential to remove a small amount of potential tree roosting habitat (less than 

one acre). The Mirror Lake Trail Relocation Project may impact small amounts of habitat via 

parking lot construction and new trail construction. Suitability of these habitats would depend on 

presence of larger snags with loose bark or cavities. The additional effect of these activities is 

expected to be minor and does not measurably increases impacts described for direct and indirect 

effects.

Determinations

Alternative 1 (No Action)

Alternative 1 would have no impact on Townsend’s big-eared bat. 

Alternative 2 (Proposed Action) 

Alternative 2 may impact individuals, but is not likely to cause a trend to Federal listing or loss 

of viability to the species based on the following rationale:

• The proposed action would remove approximately 13 acres of forest edge foraging habitat.

• No impacts to primary maternity or hibernaculum habitats including caves, mines, or 

buildings are expected.

Mardon Skipper

Affected Environment

Surveys for this species in Oregon and Washington have focused on each of the four disjunct 

population areas as well as in between and along the edges of these populations. In the south 

Puget Sound, grasslands have been surveyed, including large areas of Joint Base LewisMcChord. Within forested-grassland openings in areas of the southern Cascades of Washington, 

areas have been surveyed on the Gifford Pinchot National Forest and Naches Ranger District of 

the Okanogan-Wenatchee National Forest. In the southern Oregon Cascades, surveys have been 

conducted on Medford District of the BLM, the Klamath Falls Resource Areas of the Lakeview 

BLM District, the eastern portion of the Rogue River-Siskiyou National Forest, and western 

portion of the Fremont-Winema National Forest. Surveys in between the southern Washington 

Cascade and southern Oregon Cascade populations have been conducted on the Columbia River 

Gorge National Scenic area, and the Mt. Hood and Willamette National Forests with no Mardon 

skippers found (Kerwin and Huff 2011).

Habitat

Mardon skippers occupy grassland habitats, the characteristics of which appear to vary by 

region. Habitats in the south Puget Sound consist of grasslands situated on glacial outwash soils, 

often referred to as prairies. In this habitat type, they use open grasslands with abundant Festuca 

roemeri interspersed with Viola adunca. In the southern Cascades of Washington, distribution 

ranges from 1,800 to 5,500 feet elevation where the species is found in warm, dry grand fir 

(Abies grandis) savannah/woodland with grassland intrusions or in small (less than 1⁄2 acre) to 

larger grassland complexes. Forty percent of the Gifford Pinchot National Forest sites are in 

older clearcuts which are now dominated by fescue bunchgrasses. Site conditions range from 

dry, open ridge tops to areas associated with wetlands or riparian habitats. Populations in

southern Oregon occupy smaller grasslands (0.5 to 10 acres), higher-elevation (4,500 to 

5,100 feet) grasslands within mixed conifer forests at higher elevation (4,500 to 5,100 feet).

They are usually associated with a water source (Kerwin and Huff 2007).
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

331

No known sightings are reported for the Mt. Hood National Forest. Surveys were conducted in 

2009 at six sites with the highest probability of species occurrence, with no Mardon skipper 

occurrences reported (Walcott 2010). One survey site was located about 0.8 mile from the 

Cooper Spur parcels.

Habitat within the Analysis Area

All Parcels

Approximately 28 acres of meadow habitat, located in the western portion of the Cooper Spur 

parcels, may function as suitable Mardon skipper habitat; however, much of this contains 

encroaching conifers. Approximately 0.5 acre of potentially suitable habitat exists within 

Government Camp parcels (table 103).

Environmental Consequences

No-action Alternative

Under the no-action alternative, existing land ownership in the Government Camp and Cooper 

Spur parcels would remain unchanged. No transfer in ownership of existing amounts of Mardon 

skipper habitat would occur. No direct, indirect, or cumulative effects would occur as a result of 

the no-action alternative.

Proposed Action

Direct and Indirect Effects

Alternative 1 (no action) - Under the no-action alternative, existing land ownership in the 

Government Camp and Cooper Spur parcels would remain unchanged. No direct, indirect, or 

cumulative effects would occur as a result of the no-action alternative.

Alternative 2 (proposed action) – Implementation of the proposed action would have no direct 

effects on Mardon skipper or its habitat. Subsequent development of Government Camp parcels 

would potentially cause loss of habitat totaling about 0.5 acre. Meadow habitat is more abundant 

on Cooper Spur parcels (28 acres); however, much of the meadow habitat at Cooper Spur is 

currently encroached by conifers at the edges and interiors. Actual suitability of all sites due to 

local conditions such as wind and exposure are unknown. Overall, there would be a gain in 

Federal ownership of about 27 acres of dry meadow habitats, which could potentially be 

managed to maintain habitat suitability. Portions of meadows will require future removal of 

encroaching conifers to maintain meadow condition in the long term. 

Non-forested habitats on the Mt. Hood National Forest below 5,200 feet elevation total 

approximately 10,500 acres. Removal of 0.5 acre of habitat within the Government Camp 

parcels would equate to less than 0.01 percent of estimated available foraging habitat.

Cumulative Effects

The cumulative effects analysis area for Mardon skipper consists of the parcels proposed for 

transfer and areas out to 0.25 mile from these parcels. This encompasses the potential area of use 

by individuals that may use habitats within the parcels. Past activities such as timber harvest, 

road construction, development, wildfire, and other disturbances are reflected in the existing 

condition. None of the ongoing and foreseeable activities listed in the Past, Present, and 

Reasonably Foreseeable Actions section are expected to contribute impacts to this species in 

excess of those described for direct and indirect effects.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

332

Determinations

Alternative 1 (No Action)

Alternative 1 would have no impact on Mardon skipper. 

Alternative 2 (Proposed Action)

Alternative 2 may impact individuals, but is not likely to cause a trend to Federal listing or loss 

of viability to the species based on the following rationale:

• The proposed action would indirectly cause loss of 0.5 acre of potentially suitable Mardon 

skipper habitat.

• Approximately 28 acres of dry meadow and meadow with tree habitat would be 

transferred to Federal ownership with potential for management to maintain suitable 

foraging conditions. 

• Removal of 0.5 acre of habitat within the Government Camp parcels would equate to less 

than 0.01 percent of estimated available foraging habitat.

Western Bumble Bee 

Affected Environment

Prior to 1998, the western bumble bee was both common and widespread throughout the western 

United States (including Colorado) and western Canada. Since 1998, this bumble bee has 

undergone a drastic decline throughout some areas of its former range. While viable populations 

still exist in Alaska and east of the Cascades in the Canadian and U.S. Rocky Mountains, the 

once common populations of central California, Oregon, Washington and southern British 

Columbia have largely disappeared (Xerces 2015). In Oregon, this species has been documented 

on Deschutes, Fremont-Winema, Malheur, Mt. Hood, Ochoco, Rogue River-Siskiyou, Siuslaw, 

Umatilla, Umpqua, Willamette, and Wallow-Whitman National Forests, and BLM land in the 

Burns, Lakeview and Medford Districts. 

Given the relatively recent range decrease for this species, it is unknown what the current 

“documented” status is for many of these field units, as many of the documented sites are 

considered historic. Species occurrence adjacent to the Government Camp parcels was reported 

in 1932, 1941, 1956, and 1968 and near the Cooper Spur parcels in 1925 (Mt. Hood National 

Forest NRIS database). Surveys conducted on Mount Hood in 2013 reported western bumble bee 

occurrence approximately 2 miles northeast of the parcels (Hatfield et al. 2013). No status or 

trend has been identified for populations within the project area.

The western bumble bee has three basic habitat requirements: suitable nesting sites for the 

colonies, nectar and pollen from floral resources available throughout the duration of the colony 

period (spring, summer and fall), and suitable overwintering sites for the queens (Jepson et al. 

2014). Nests occur primarily in underground cavities such as old squirrel or other animal nests 

and in open west-southwest slopes bordered by trees, although a few nests have been reported 

from above-ground locations such as in logs among railroad ties (Jepson et al. 2014). 

Bumble bees require plants that bloom and provide adequate nectar and pollen throughout the 

colony’s life cycle, which is from early February to late November for B. occidentalis (although 

the actual dates likely vary by elevation). Very little is known about the hibernacula, or 

overwintering sites (Jepson et al. 2014).
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

333

Habitat within the Project Area

Lands within the Government Camp parcels contain some foraging habitat in the form of 

meadows totaling less than 1 acre, and open canopy forested stands totaling 23 acres (table 103). 

Lands within the Cooper Spur parcels appear to contain a higher amount of foraging habitat.

About 28 acres of dry meadows with scattered trees is available to support nectar-producing 

plants in addition to open canopy forest totaling 104 acres.

Environmental Consequences

No-action Alternative

Under the no-action alternative, existing land ownership in the Government Camp and Cooper 

Spur parcels would remain unchanged. No transfer in ownership of existing amounts of western 

bumble bee habitat would occur. No direct, indirect, or cumulative effects would occur as a 

result of the no-action alternative.

Proposed Action

Direct and Indirect Effects

Implementation of the proposed action would have no direct effects on western bumble bee or 

habitat. Subsequent development of Government Camp parcels would potentially cause 

destruction of underground colonies as well as loss of foraging habitat totaling about 24 acres. 

Meadow habitat is more abundant on Cooper Spur parcels (28 acres); however, much of the 

meadow habitat at Cooper Spur is currently encroached by conifers at the edges and interiors. 

Actual suitability of all sites due to local conditions such as wind and exposure are unknown.

Overall, there would be a gain in Federal ownership of about 28 acres of dry meadow habitats, 

which could potentially be managed to maintain habitat suitability. The 81 acres of open canopy 

forest is expected to lose foraging suitability as stands mature and canopies become denser. 

Portions of meadows will require future removal of encroaching conifers to maintain meadow 

condition in the long term. 

Non-forested habitats on the Mt. Hood National Forest total approximately 23,000 acres. 

Removal of less than 1 acre of meadow habitat within the Government Camp parcels would 

equate to less than 0.01 percent of estimated available foraging habitat.

Cumulative Effects

The cumulative effects analysis area consists of the parcels proposed for transfer and areas out to 

0.25 mile from these parcels. This encompasses the potential area of use by individuals that may 

utilize habitats within the parcels. Past activities such as timber harvest, road construction, 

development, wildfire, and other disturbances are reflected in the existing condition. Activities 

listed in appendix A consisting of recreation, residential use, infrastructure operations and 

maintenance are not expected to increase habitat impacts. Current and ongoing development of 

private lands in the vicinity of Cooper Spur parcels may impact habitat availability locally, but 

would not add to direct or indirect impacts because no negative impacts to this species were 

identified for these parcels. No other activities are expected to cause impacts additional to those 

describe for direct and indirect effects. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

334

Determinations

Alternative 1 (No Action)

Alternative 1 would have impact on western bumble bees. 

Alternative 2 (Proposed Action) 

Alternative 2 may impact individuals, but is not likely to cause a trend to Federal listing or loss 

of viability to the species based on the following rationale:

• The proposed action would indirectly cause loss destruction of colonies and loss of 1.1 

acres of suitable bumble bee foraging habitat.

• Approximately 28 acres of dry meadow and meadow with tree habitat would be 

transferred to Federal ownership with potential for management to maintain suitable 

foraging conditions. 

• Removal of less than 1 acre of meadow habitat within the Government Camp parcels 

would equate to less than 0.01 percent of estimated available foraging habitat.

Dalles Sideband

Affected Environment

Dalles sideband is a local endemic known from watersheds tributary to the Columbia Gorge on 

both the Oregon and Washington sides of the river in Wasco, Hood River, Klickitat, Skamania 

and Sherman Counties, from Hood River east to the vicinity of The Dalles, and in upland sites in 

watersheds tributary to the lower Deschutes River in Wasco County. In Oregon, it is documented 

on the Mt. Hood National Forest. Local extirpations and declines have been documented in the 

Columbia River Gorge area. Frest and Johannes (1995) note that extinct colonies have been 

found along the I-84/U.S. 30 corridor, and list the population trend (number of sites, number of 

individuals) as downward. The vast majority (79/100) of known records are from the Barlow 

Ranger District on the national forest where most detections have been relatively recent, and 

changes in population number and size through time are not known (Jordan and Black 2014). 

The parent species, Monadenia fidelis, is found in mesic forest habitats or near springs or other 

water sources in forest situations, generally with rock substrates or large woody debris and logs 

for refugia (Frest and Johannes 1995, 2000). The subspecies Monadenia fidelis minor is known 

only from relatively few sites within a limited range. It is associated with talus habitat and 

seasonally moist rocky areas, especially around seeps and springs, though it is not found in the 

springs or seeps, nor is it considered to be a talus obligate. In The Dalles, this species lives 

among rocks and in and under bluffs around springs and in riparian areas (Burke 2013). Frest 

and Johannes (1995) emphasize the association of this subspecies with basalt and basalt-derived 

soils, noting that taluses are often comparatively dry and open, but partial cover by Celtus, 

grasses, Rhus horribilis, Artemisia, Urtica, and Balsamorrhiza is typical (Jordan and Black 

2014).

Habitat within the Project Area

Suitable habitat for this species is lacking within the Government Camp parcels. A small amount 

of talus/scree habitat (9 acres) occurs within the northeast portion of the Cooper Spur parcels. 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

335

Environmental Consequences

No-action Alternative

Under the no-action alternative, existing land ownership in the Government Camp and Cooper 

Spur parcels would remain unchanged. No direct, indirect, or cumulative effects would occur as 

a result of the no-action alternative.

Proposed Action

Because no suitable habitat exists within the Government Camp parcels, no direct or indirect 

effects to existing species distribution or habitat would result from implementation of the 

proposed action. In addition, no direct or indirect effects to habitats or individuals potentially 

occurring within Cooper Spur parcels as a result of the proposed action and connected actions.

Determinations

Alternatives 1 and 2 

Both the no action and proposed action would have no impact on Dalles sideband. 

Crater Lake Tightcoil

Affected Environment

In Oregon, Crater Lake tightcoil occurs throughout the Oregon Cascades from Mt. Hood 

National Forest in the north to the Umpqua and Winema National Forests in the south at 

elevations exceeding 2,000 feet in scattered wetland areas (Gowan and Burke 1999).

The species is usually found in non-acid fens or sedge habitats at elevations from 2,750 to 

6,400 feet (Gowan and Burke 1999). This species has been found in mature conifer forests and 

among rushes, mosses and other surface vegetation or under rocks and woody debris within 

10 meters of open water in wetlands, springs, seeps and riparian areas which experience 

perennially moist conditions and long winters. The sites where Frest and Johannes (1995) found 

Crater Lake tighcoil were small openings such as “spring meadows” in generally undisturbed 

forests. Plant litter and natural porous soils provide some necessary cover for protection against 

excessive fluctuations in temperature and humidity, and also for hiding or escaping from 

predators (Andrews 2010).

No occurrences are reported within the project area. The nearest known occurrences are located 

approximately 5 miles from Government Camp parcels and over 6 miles from Cooper Spur 

parcels. 

Habitat within the Project Area

Suitable habitat is located within a portion of one wetland (Wetland No. 11, Mt. Hood National 

Forest Land Exchange Wetland Survey, Watershed Professionals Network LCC 2010). The site 

consists of an emergent vegetation wetland totaling 1 acre in size adjacent to moderate-sized 

conifers (figure 52), located in the eastern block of the Government Camp parcel. No suitable 

habitat is expected to occur within Cooper Spur parcels.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

336

Figure 52. Potential Crater Lake tightcoil habitat, Government Camp 

east parcel (photo source: Watershed Professionals Network LCC 2010)

Environmental Consequences

No-action Alternative

Under the no-action alternative, existing land ownership in the Government Camp and Cooper 

Spur parcels would remain unchanged. No transfer in ownership of existing amounts of Crater 

Lake tightcoil habitat would occur. No direct, indirect, or cumulative effects would occur as a 

result of the no-action alternative.

Proposed Action

Direct and Indirect Effects

Implementation of the proposed action would have no direct effects on Crater Lake tightcoil or 

habitat. About 1 acre of suitable habitat is located within Government Camp parcels. The 2009 

Omnibus Act prescribed as a mandatory condition to the land exchange that the Forest Service 

reserve wetland and trail easements on the Federal parcels to be exchanged. More specifically, 

the Omnibus Act required the Forest Service to reserve a conservation easement on the Federal 

land to protect existing wetlands, as identified by the Oregon Department of State Lands that 

allows equivalent wetland mitigation measures to compensate for minor wetland encroachments 

necessary for the orderly development of that land following the exchange. The Clarification Act 

(which is now the proposed action) changed this provision from “shall reserve” to “may 

mutually agree to reserve.” Under both scenarios with or without a Federal conservation 

easement, some increased level of sediment delivery into wetlands is expected due to 

surrounding development (see Hydrology Report). 

Under the proposed action, wetlands in the conveyance parcels would no longer be managed and 

conserved by the Forest Service as Riparian Reserves. Regulatory authority and oversight for the 

protection of these wetlands would switch to the Oregon Department of State Lands who share 

the responsibility implementing section 404 of the Clean Water Act, the principal statute for 

governing activities in wetlands, with the Oregon Department of Environmental Quality, the U.S. 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

337

Army Corps of Engineers and the U.S. Environmental Protection Agency. Activities associated 

with residential development that could encroach upon the wetlands would have to undergo a 

review and permitting process according to Oregon Revised Statute before they would be 

authorized (see Wetland Supplement to the Watershed Resources Report). 

Section 404 of the Clean Water Act protects wetlands from net loss regardless of ownership by 

the use of either on-site conservation easements or compensatory mitigation (funding the 

creation or restoration of wetlands at a different place and time and maintaining them in 

perpetuity). The proposed action would include conservation easements, so that the wetlands in 

the conveyed parcels would be protected according to regulation by the Department of State 

Lands. If on-site conservation easement is applied, retention of suitable Crater Lake tightcoil 

habitat is expected. In the event that compensatory (off-site) mitigation is applied, residential 

encroachment of the site may occur, thereby reducing or removing habitat suitability on 

approximately 1 acre. Based on data accessed from the National Wetlands Inventory (USDI Fish 

and Wildlife Service 2016b), freshwater emergent wetland and freshwater forested/shrub wetland 

habitats total 1,883 acres and 3,840 acres, respectively, on the Mt. Hood National Forest. The 

1-acre patch of habitat within the Government Camp parcel represents approximately 

0.05 percent of freshwater emergent wetland habitat and 0.02 percent of all potential habitat on 

the national forest.

Cumulative Effects

The cumulative effects analysis area consists of the areas within 10 meters of emergent 

vegetation wetland (approximately 1 acre) within the Government Camp parcel as well as 

perennial streams above the wetland. This encompasses the potential disturbances and habitat 

impacts for Crater Lake tightcoil. Past activities such as timber harvest, road construction, 

development, wildfire, and other disturbances are reflected in the existing condition. Ongoing 

and foreseeable activities in proximity to the parcels are listed in the Past, Present, and 

Reasonably Foreseeable Actions section. No projects or activities listed in appendix A are 

expected to contribute detrimental cumulative effects to peak stream flows, stream temperatures, 

or sediment delivery (see Hydrology Report).

Determinations

Alternative 1 (No Action) 

Alternative 1 would have no impact on Crater Lake tightcoil. 

Alternative 2 (Proposed Action) 

Alternative 2 may impact individuals, but is not likely to cause a trend to Federal listing or loss 

of viability to the species based on the following rationale:

• An increase in sediment delivery to wetlands is expected.

• Without application of a Federal wetlands conservation easement, habitat may maintain 

function if on-site mitigations are applied. If compensatory mitigation is applied, habitat 

on 1 acre may be degraded or removed.

• The 1-acre habitat patch that may be impacted constitutes a very small portion of potential 

habitat available forestwide.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

338

Shiny Tightcoil

Affected Environment

This species is reported from many widely separate (but often imprecise) historic locations. It is 

known from the Washington and Oregon Cascades. It is also reported from the Blue Mountains 

in Oregon (Wallowa Valley above Wallowa Lake in Wallowa County) and from several counties 

in Idaho (Washington, Adams, Boise, and Shoshone) (Huff 2011).

The species seems to occur rarely in Oregon and surveys in recent years in appropriate areas 

have failed to relocate it; a number of sites in Wasco County, Oregon, were unsuccessfully 

surveyed for this taxon (Frest and Johannes 1995), as well as areas in western Oregon. In 

Oregon, this species is documented in Deschutes and Mt. Hood National Forests and suspected 

in Malheur, Umatilla and Wallowa-Whitman National Forests, BLM land in the Prineville and 

Salem Districts, and the Columbia Gorge National Scenic Area in Oregon (Huff 2011).

Most sites for this species are in ponderosa pine and Douglas-fir forests at moderate to high 

elevations. The eastern Washington record is from a relatively moist, shaded basalt cliff and with 

talus and Populus cover (Frest and Johannes 1995). Burke and Leonard (2009, draft) describe the 

habitat as primarily under deciduous trees, particularly quaking aspen and red alders. Other 

Pristiloma species in the ecoregion are known to prefer moist microsites such as basalt talus 

accumulations, usually with riparian influence (Duncan 2008).

Habitat within the Project Area

No reported sightings or suitable habitat exist within the Government Camp parcels. No 

sightings are reported for the Cooper Spur parcels, for which the nearest sighting is located about 

6 miles to the northeast. Suitable habitat may occur within Cooper Spur parcels along draws 

containing deciduous trees and basalt talus, particularly along Tilly Jane Creek.

Environmental Consequences

No-action Alternative 

Under the no-action alternative, existing land ownership in the Government Camp and Cooper 

Spur parcels would remain unchanged. No transfer in ownership of existing amounts of Shiny 

tightcoil habitat would occur. No direct, indirect, or cumulative effects would occur as a result of 

the no-action alternative.

Proposed Action

Direct and Indirect Effects

Implementation of the proposed action would have no direct effects on Shiny tightcoil or habitat.

No suitable habitat exists within Government Camp parcels, therefore, no direct or indirect 

impacts would result from transfer of this property from Federal ownership. In addition, no 

direct, indirect, or cumulative impacts would result from the addition of Cooper Spur parcels to 

Federal ownership, including connected actions because no ground-disturbing activities would 

occur without further environmental analysis. 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

339

Determinations

Alternatives 1 and 2 

Both the no-action and proposed action would have no impact on shiny tightcoil. 

Mt. Hood National Forest Management Indicator Species

The Mt. Hood forest plan (USDA Forest Service 1990a) identifies seven wildlife species as 

management indicator species (table 110). These species serve as indicators of the effects of 

management activities by representing a broad range of other wildlife species. The habitat 

requirements of management indicator species are presumed to represent those of a larger suite 

of species using the same type of habitat. Table 110 lists all Mt. Hood National Forest 

management indicator species, primary habitats as identified in the forest plan, as well as habitat 

presence and species occurrence in the Cooper Spur-Government Camp analysis area. Five 

management indicator species and associated habitats are documented or suspected to occur 

within the analysis area. These consist of northern spotted owl, pileated woodpecker, American 

marten, deer, and elk.

Table 110. Management indicator species and their primary habitats

Species Habitat Type Habitat Present 

in Analysis Area

Species Present in 

Analysis Area

Northern spotted owl Mature and old growth forest Yes Suspected

Pileated woodpecker Mature, old growth snags Yes Documented

American (pine) marten Mature and old growth forest Yes Suspected

Silver gray squirrel Pine/oak (East side) No No

Merriam’s turkey Pine/oak (East side) No No

Deer Grass/forb, seedling/sapling Yes Documented

Elk Grass/forb, seedling/sapling, 

old growth forest

Yes Documented

A forestwide analysis for management indicator species has been conducted (USDA Forest 

Service 2011). It summarizes the Mt. Hood National Forest’s consistency with the National 

Forest Management Act goal of managing wildlife habitat to “maintain viable populations of 

existing native and desired non-native vertebrate species.” The forestwide analysis for 

management indicator species describes population and habitat trends and is incorporated by 

reference. It was conducted at a coarse scale using available GIS data. Further refinement is 

provided in this analysis based on available local data.

Monitoring at the national forest scale has been documented in annual monitoring reports 

available on the Mt. Hood National Forest website (http://www.fs.fed.us/r6/mthood). There is no 

requirement in the forest plan, as amended, to survey for or gather site-specific, project-scale 

population data regarding the project implementation’s effects to the viability of the population 

of management indicator species. Rather, the forest plan directs that habitat be used as a proxy 

for population monitoring. Land allocations near or adjacent to the project area that provide 

habitat for management indicator species include late-successional reserves and riparian reserves 

for pine marten, pileated woodpecker, and northern spotted owl; and winter range and summer 

range for deer and elk. Of these allocations, only summer range overlaps the project area. There 

are also numerous forestwide standards and guidelines that pertain to these species. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

340

Northern Spotted Owl

The northern spotted owl was selected as a management indicator species because it represents 

old growth habitats. The biological evaluation above describes, in detail, the species and its

habitat requirements.

The overall trend for spotted owl populations is declining in the Pacific Northwest. The recovery 

for the species is covered under the U.S. Fish and Wildlife Service Revised Recovery Plan for 

the Northern Spotted Owl (Strix occidentalis caurina) (USDI 2011). Because the northern 

spotted owl is listed as a threatened species, the Forest Service consults on the effects to the 

species and its habitat with the U.S. Fish and Wildlife Service prior to making decisions on 

actions by the agency. The US Fish and Wildlife Service has not found any proposed actions on 

the Mt. Hood National Forest to place the northern spotted owl in jeopardy. 

Determination

The degree of effect to northern spotted owl habitat for the Government Camp-Cooper Spur 

Land Exchange project, when combined with other projects that affect owl habitat, would not 

contribute to a negative trend in viability on the Mt. Hood National Forest for the northern 

spotted owl.

American Marten 

Affected Environment

This species (Martes americana) was formerly known as the pine marten. It was selected as a 

management indicator species because of its association with mature and over-mature habitat 

and need for large snags and large amounts of down wood. Shrinking habitat and trapping 

pressure led to the concern for marten populations (USDA Forest Service 1990b). Conservation 

status is listed below.

Table 111. American marten conservation status

Scientific Name

Common Name

Heritage 

Rank

Federal 

Status

Oregon Dept. of 

Fish and Wildlife 

Status

Oregon Biodiversity 

Information Center List

Martes americana

American marten

(SV in BM and CR 

ecoregions only)

G5 [1]

S3S4 [2]

Not 

applicable

SV[3] 4 

(Not rare and apparently 

secure, but with cause for longterm concern, usually with more 

than 100 occurrences.)

1. G5: NatureServe Global Rank - Secure

2. S3: Oregon Natural Heritage Program Conservation Status Rank - Vulnerable. At moderate risk of extinction due to a 

restricted range, relatively few populations, recent and widespread declines, or other factors; S4: Apparently Secure. 

Uncommon but not rare; some cause for long-term concern due to declines or other factors

3. SV – Sensitive Species, Vulnerable Category

Distribution

Globally, the species is distributed throughout Canada and Alaska, south through the Rockies, 

Sierra Nevada, northern Great Lakes Region, and northern New England. In Oregon and 

Washington, it occurs in montane forests of the southern Oregon Coast Range, Siskiyou 

Mountains, Cascade Mountains, Blue Mountains, Olympic Peninsula, and northeast Washington 

(Marcot et al. 2003). Marten are absent from the northern Oregon and southern Washington 

coastal mountains, and are rare in the Olympic Peninsula (Zielinski et al. 2001).
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

341

Habitat Characteristics and Ecology 

American marten are typically associated with late-seral coniferous forests with closed canopies, 

large trees, and abundant snags and down woody (Zielinski et al. 2001). Wisdom et al. (2000; 

Appendix 1, Table 1) list subalpine and montane forests in old multi- and single-story, and 

unmanaged young multi-story structural stages as providing source habitat for American marten 

in the Columbia Basin. Lower montane forests are not listed as source habitat. Snags and down 

logs are identified as special habitat features of source habitat for the marten. Down logs provide 

habitat for prey and subnivean access points as well as rest and den sites for marten. Thomas et 

al. (1993) list marten as closely associated with late-successional and old-growth forests and the 

old-growth elements of large snags and down logs. The reports also indicate a strong relationship 

of marten with riparian areas. On the eastern side of the North Cascades of Washington, marten 

were detected in wet-forest habitats, but were not detected in dry-forest habitats (Munzing and 

Gaines 2008). Wet forests include western hemlock, Pacific silver fir, and mountain hemlock 

plant associations.

Habitat and Trend

American martens prefer older habitat at higher elevations and select habitat with high amounts 

of snags and down wood. Their preference is highly associated with cavities for denning and a 

higher abundance of rodents, especially squirrels and chipmunks. 

American martens occur at high elevations with greatest populations in subalpine areas (Buskirk

and Ruggiero 1994). Riparian areas are used for foraging and resting; they select resting sites in 

large trees or in piles of woody debris in riparian areas. Large coarse woody debris and canopy 

cover are important for martens during winter because they have limited energy reserves in 

winter. Winter habitat requirements include more than 30 percent canopy cover. Under snow, 

coarse woody debris concentrations provide resting areas and habitat for marten prey. Other 

resting sites or den sites include cavities in large snags, hollow stumps, and under logs (USDA 

USDI 1993).

Since the marten was identified as a management indicator species in the forest plan, several 

factors listed below have contributed cumulatively to a trend of improving habitat:

• The establishment of late-successional reserves and riparian reserves has resulted in the 

retention of late-successional stands and the enhancement of younger stands to accelerate 

the development of late-successional conditions.

• The Northwest Forest Plan required the national forests to reassess the need for land 

allocations for pileated woodpeckers during watershed analysis. On the Mt. Hood National 

Forest, most of the B5 land allocations were removed during watershed analyses because 

the network of late-successional reserves, riparian reserves, and other land allocations 

would provide for the species. Currently, no pileated woodpecker land allocations occur 

within proximity of the project area.

• Several wilderness areas have been designated.

• Timber harvest on the Mt. Hood National Forest, even on Matrix lands, has transitioned 

from reliance on regeneration harvest of mature stands to a program of thinning younger 

stands.

• The Mt. Hood National Forest has decommissioned several hundred miles of roads, 

reducing disturbance.

• Hazardous fuels have been treated to reduce the potential impact of wildfire on the species.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

342

Using the data from the habitat modeling analysis (Davis 2008), there are 10,876 to 21,553 acres 

of habitat with a 30 to 40 percent or higher probability of supporting American marten on the Mt.

Hood National Forest.

American marten home range size in Montana ranged from 0.4 to 1.0 square kilometers(99 to 

247 acres). For this analysis of home ranges, 173 acres was used in determining the number of 

home ranges on the national forest. For Mt. Hood National Forest, the analysis indicates there 

are approximately 63 to 125 home ranges for martens. The original analysis for marten was 

much higher (the forest plan indicates a minimum number of home ranges at 231. However, the 

1990 forest plan analysis would have to assume that habitat that current analysis would indicate 

had only a 15 to 20 percent probability would support martens to have that many home ranges.

As stated above, the forest plan overestimated the number of home ranges. The current analysis 

is probably closer in actual number of a population and is better supported by tracking 

information provided by Cascadia Wild from their winter tracking data and camera stations.

During the spring, a home range might be occupied by a male, a female, and three young.

Therefore, an estimate of population on the Mt. Hood National Forest would be 310 to 625 

martens, depending on prey availability.

Habitat within the Project Area

Portions of the Government Camp parcels contain structure suitable for American marten. About 

22 acres contain forested stands mature enough and containing sufficient snags and down log to 

be considered marten habitat. The remaining portions consist of younger stands lacking 

sufficient snags and down logs that may be used for movement.

Environmental Consequences

No-action Alternative

There would be no impacts to marten or marten habitat on Mt. Hood National Forest lands as a 

result of no action.

Proposed Action

Direct and Indirect Effects

Ownership transfer of Government Camp parcels would result in a reduced amount of suitable 

habitat on Mt. Hood National Forest lands totaling 22 acres. Once transferred, it is likely these 

stands would be developed resulting in a loss of suitable marten habitat. Stands with overstory 

and size suitable to support marten within the Cooper Spur parcels is estimated at 30 acres; 

however, the amount of larger snags and down logs has not been identified in these parcels.

Therefore, the habitat may appear suitable, but quality for marten was not verified. In addition, 

existing habitat distribution and potential road-related disturbance factors indicate that habitat at 

Government Camp is currently less impacted by open roads and forested stands not currently 

suitable habitat will begin to become suitable in the short term (less than 20 years) as stands 

continue to mature. Conditions at Cooper Spur consist of higher road densities and younger 

stands that would take longer to develop into suitable habitat.

Cumulative Effects

The area used to analyze cumulative impacts is the area within one mile of all parcels proposed 

for ownership transfer. In the Government Camp area, past development of National Forest 

System and lands of other ownership has decreased available marten habitat locally, but areas to 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

343

the north and west remain primarily forested, with trees continuing advancing in age toward 

maturity. This is reflected in the existing condition. Ongoing and foreseeable activities listed in 

the Past, Present, and Reasonably Foreseeable Actions section consisting of recreation, 

residential use, infrastructure operations and maintenance are not expected to increase habitat 

impacts, but may cause localized noise disturbance leading to marten avoidance of some areas. 

The Mazama Lodge Parking Area Expansion has the potential to remove a small amount of 

potential tree roosting habitat (less than one acre). The Mirror Lake Trail Relocation Project may 

impact small amounts of habitat via parking lot construction and new trail construction. These 

activities may also increase noise disturbance locally, but because of the small scope of these 

activities, the additional effect is minor.

Determinations

The current trend for American marten is stable. The proposed action would transfer about 

22 acres of suitable habitat from Federal ownership and about 30 acres of potentially suitable 

habitat with unverified quality, to the Mt. Hood National Forest. Loss of 22 acres constitutes 

approximately 6 percent of one home range, and 0.11 percent of the upper limit of habitat 

estimated to occur on the Mt. Hood National Forest. Therefore, the project would not contribute 

to a negative trend in viability on the Forest for American marten.

Pileated Woodpecker

Affected Environment

The pileated woodpecker was chosen as a management indicator species because of its need for 

large snags, large amounts of down woody material for foraging, and large defective trees for 

nesting, roosting and foraging. They are listed as an indicator of mature and over-mature habitat.

The breeding bird atlas project (Sauer et al. 2008) analyzed the breeding bird survey routes in 

Oregon and the result was a trend of a 0.9 (in percent per year) increase for the species with a 

0.53 probability with a sample of 61 survey routes. This probability is too high to determine that 

the species was above 0 for the trend. However, a survey-wide analysis for the species showed a 

1.7 percent increase with a 0.0 probability, indicating that it was statistically significant with 

1,890 survey routes as the sample size.

Table 112. Pileated woodpecker conservation status

Scientific Name

Common Name

Heritage

Rank

Federal

Status

Oregon Dept. of 

Fish and Wildlife 

Status

Oregon Biodiversity Information 

Center List

Dryocopus 

pileatus

Pileated 

woodpecker

G5[1]

S4[2]

Not 

applicable

SV[3] 4 

(Not rare and apparently secure, but 

with cause for long-term concern, 

usually with more than 100 

occurrences.)

1. G5: G5: NatureServe Global Rank - Secure

2. S4: Oregon Natural Heritage Program Conservation Status Rank - Apparently Secure-Uncommon but not rare; some 

cause for long-term concern due to declines or other factors

3. SV – Sensitive Species, Vulnerable Category

Habitat Characteristics and Ecology

The pileated woodpecker is associated with forest habitats that have large trees, especially large 

snags (greater than 20 inches diameter) for nesting and foraging. It uses both coniferous and 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

344

deciduous trees, but tends to be most common in old-growth Douglas-fir forests in western 

Oregon. They choose foraging habitats that contain high densities of lags and snags, dense 

canopies, and tall shrub cover. They may forage on small snags but prefer large snags (Schroeder 

1982, Csuti 1997). The pileated woodpecker was chosen as a management indicator species for 

its association to mature and over mature habitat. 

Mellen et al. (1992) found that the mean home range for pileated woodpeckers is 1,181 acres 

with approximately a 9 to 30 percent overlap (about 200 acres) between territories. Mellen et al. 

found that pileated woodpeckers selected habitat that was greater than 71 years of age. Therefore 

an average home range with overlap for pileated woodpeckers would be approximately 

970 acres.

Since identification of the pileated woodpecker as a Management Indicator Species in the forest 

plan, several factors have contributed cumulatively to a trend of improving habitat. The 

following have changed since the species was identified in the forest plan:

• The establishment of late-successional reserves and riparian reserves has resulted in the 

retention of late-successional stands and the enhancement of younger stands to accelerate 

the development of late-successional conditions.

• The Northwest Forest Plan required the Forests to reassess the need for land allocations for 

pileated woodpeckers during Watershed Analysis. On the Forest, most of the B5 land 

allocations were removed during Watershed Analyses because the network of latesuccessional reserves, riparian reserves, and other land allocations would provide for the 

species. Currently, no pileated woodpecker land allocations occur within proximity of the 

project area.

• Several wilderness areas have been designated.

• Timber harvest even on Matrix has transitioned from reliance on regeneration harvest of 

mature stands to a program of thinning younger stands.

• The Forest has decommissioned several hundred miles of roads reducing disturbance.

• Hazardous fuels have been treated to reduce the potential impact of wildfire on the species.

• Insects have killed many trees thereby increasing available pileated woodpecker foraging 

habitat.

Existing Condition on the Mt. Hood National Forest

Currently, there are 405,092 acres of pileated woodpecker habitat on the Mt. Hood National 

Forest based on GIS query for 80 years and older habitat (Jamie Bradbury, 02/28/2001). By 

dividing the acres of pileated woodpecker habitat by the average home range with overlap of 

970 acres, there are 418 potential home ranges on the national forest. An average clutch size of 4 

(Marshall et al. 2003) would indicate that the summer population of pileated woodpeckers could 

be as high as 2,508 birds, including adults and fledglings. The current trend for habitat for 

pileated woodpeckers is an increase in available habitat for the last 10 years due to continued 

forest growth and aging, as well as increased levels of snags and down wood. 

Habitat within the Project Area

The Government Camp parcels currently contain about 22 acres of advanced mid-late 

successional stands that would function as suitable habitat. Cooper Spur parcels are estimated to 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

345

contain approximately 30 acres of potential pileated woodpecker habitat, however, the amount of 

larger snags and down logs has not been identified in these parcels.

Environmental Consequences

No-action Alternative

There would be no impacts under the no-action alternative due to a lack of change in Federal 

ownership pattern and amount.

Proposed Action

Direct and Indirect Effects

The action alternative would result in the loss of 22 acres of suitable pileated woodpecker under 

Mt. Hood National Forest ownership within the Government Camp parcels. After ownership 

transfer, these lands would likely be developed resulting in loss of suitable habitat. In contrast, 

Federal acquisition of Cooper Spur parcels would offset, to a degree, habitat losses at 

Government Camp by gaining suitable habitat totaling about 30 acres. While stand structure 

appears suitable for pileated woodpecker, actual amounts of snags and down logs have not been 

verified in Cooper Spur parcels, therefore the habitat quality may not meet the species’ needs.

Existing habitat distribution and potential road-related disturbance factors indicate that habitat at 

Government Camp is currently less impacted by open roads and forested stands not currently 

suitable habitat will begin to become suitable in the short-term (less than 20 years) as stands 

continue to mature. Conditions at Cooper Spur consist of higher road densities and younger 

stands that would take longer to develop into suitable habitat.

Potential Snag Availability

Existing snags have not been surveyed for size class and abundance in either the Government 

Camp or Cooper Spur parcels. Based on past timber management as well as reconnaissance, it is 

likely that Government Camp parcels contain more and larger snags on a per-acre basis that 

lands in Cooper Spur. 

To assess the effects of the proposed action on future snag availability, information contained in 

the DecAID Advisor (Mellon-McLean et al. 2012) is used to estimate and compare snag 

production potential under various vegetation management scenarios. Snag density and size class 

information provided in DecAID as gathered from all unharvested inventory plots pertinent to 

the Wildlife Habitat Type and Structural Condition categories applicable to the parcels was 

utilized to project and compare potential future snag outputs. 

Density of snags by size class in DecAID is provided in the form of tolerance levels of 30 

percent, 50 percent, or 80 percent. DecAID tolerance levels may be interpreted as three levels of 

“assurance”: low (30 percent tolerance level), moderate (50 percent tolerance level), and high 

(80 percent tolerance level) for meeting species needs. The higher the tolerance level, the higher 

the “assurance” that snag and down wood habitat is being provided. For the purposes of this 

analysis, these tolerance levels are used to display snag densities under different vegetation 

management scenarios. 

Snag Density Capabilities on a Per-Acre Basis

Wildlife habitat type within Government Camp parcels consists of Montane Conifer Forest while 

those at Cooper Spur consist of Eastside Mixed Conifer. The parcels contain both Larger Trees 

and Small/Medium Tree structural conditions; therefore, DecAID inventory plot data for both 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

346

structural conditions is displayed below. For the Government Camp habitat type, snag densities 

for Small/Medium structural condition range from 9 to 32.4 snags per acre for snags 10 inches 

diameter or larger and 1.1 to 7.4 snags per acre for snags 20 inches or larger (table 113). In 

stands managed for large trees, densities are slightly higher with snags 10 inches diameter or 

larger range from about 11 to 26 per acre and 20+ inch diameter snags ranging from about 6 to 

15 per acre. 

Table 113. Snag density capabilities, Government Camp Parcels, montane conifer habitat type

Snag Size Class

30% Tolerance 

Level 

(Snags/ac.)

50% Tolerance 

Level 

(Snags/ac.)

80% Tolerance 

Level 

(Snags/ac.)

Small/Medium Trees Structural Condition

≥ 10 dbh 9 15.3 32.4

≥ 20 dbh 1.1 2.7 7.4

Large Trees Structural Condition

≥ 10 dbh 10.7 15.3 25.8

≥ 20 dbh 5.8 8.6 14.9

By comparison, the Cooper Spur parcels are likely to support lower snag densities mainly due to 

drier site conditions. Density of snags 10 inches diameter or greater for the Cooper Spur habitat 

type in Small/Medium structural condition ranges from approximately 4 to 22 per acre, and 

snags 20+ inches in diameter range in density from 0 to 6.2 per acre (table 114). Densities in the 

Large Tree structural condition range for snags 10 inches or greater range from 1.5 to 14.4 per 

acre, while density of large snags 20 inches diameter or greater range from 0 to 7.3 per acre.

Table 114. Snag density capabilities, Cooper Spur Parcels, eastside mixed conifer habitat type

Snag Size Class

30% Tolerance 

Level 

(Snags/ac.)

50% Tolerance 

Level

(Snags/ac.)

80% Tolerance 

Level

(Snags/ac.)

Small/Medium Trees Structural Condition

≥ 10 dbh 4.0 9.1 22.2

≥ 20 dbh 0.0 2.0 6.2

Large Trees Structural Condition

≥ 10 dbh 1.5 5.3 14.4

≥ 20 dbh 0.0 2.4 7.3

Snag Number Capabilities by Parcel

Potential future snag availability on a per-acre basis are shown above to be potentially higher in 

Government Camp parcels. However, a comparison between parcels as a whole shows that 

Cooper Spur parcels have the capability to provide higher overall snag numbers due to the fact 

that those parcels contain an estimated 710 acres of forest-capable habitat, which is nearly 7 

times the forest capable acreage contained in Government Camp parcels (estimated at 104 acres).

Extrapolating the per-acre snag densities displayed above over the entire Government Camp 

parcel in Small/Medium Tree structural condition indicates a range of total snags ≥ 10 inches in 

diameter up to 3,370 and a range up to 770 snags ≥20 inches in diameter (table 115). In the 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

347

Large Tree structural condition, potential future snag availability ranges up to 2,638 snags 

10 inches or larger in diameter, and up to 1,115 snags 20 inches or greater in diameter. 

Potential future availability of snags on Cooper Spur parcels in the Small/Medium Tree 

structural condition is estimated to range up to 15,762 snags greater than or equal to 10 inches in 

diameter, and up to 6,106 snags greater than or equal to 20 inches in diameter. Although the 

upper range of potential snag availability is higher in Cooper Spur parcels, the zero value shown 

for snags greater than or equal to 20 inches in table 116 is a reflection of the lack of snags 

recorded in some unharvested plots. This indicates a higher potential for gaps in large snag 

availability in comparison to plots in the Montane Mixed Conifer habitat type represented in the 

Government Camp parcels. 

Table 115. Snag total capabilities, Government Camp Parcels, montane conifer habitat type

Snag Size Class

30% Tolerance 

Level (Total 

Snags)

50% Tolerance 

Level

(Total Snags)

80% Tolerance 

Level

(Total Snags)

Small/Medium Trees Structural Condition

≥ 10 dbh 936 1,591 3,370

≥ 20 dbh 114 281 770

Large Trees Structural Condition

≥ 10 dbh 1,113 1,591 2,683

≥ 20 dbh 603 894 1,550

Table 116. Snag total capabilities, Cooper Spur Parcels, eastside mixed conifer habitat type

Snag Size Class

30% Tolerance 

Level (Total 

Snags)

50% Tolerance 

Level

(Total Snags)

80% Tolerance 

Level

(Total Snags)

Small/Medium Trees Structural Condition

≥ 10 dbh 2,769 6,461 15,762

≥ 20 dbh 0 1,420 4,402

Large Trees Structural Condition

≥ 10 dbh 1,065 3,763 10,224

≥ 20 dbh 0 1,704 5,183

Direct and Indirect Effects to Snag Availability

Under the no-action alternative, existing land ownership in the Government Camp and Cooper 

Spur parcels would remain unchanged. No transfer in ownership of existing amounts of snags or 

future available snag habitat would occur. No direct, indirect, or cumulative effects would occur 

as a result of the no-action alternative.

Implementation of the proposed action would have no direct effects on snag habitat. Indirectly, 

subsequent development of Government Camp parcels would remove an unknown existing 

number of snags and would preclude future snag development on 104 acres of forest. By 

comparison, forested stands in the Government Camp parcels are capable of supporting higher 

per-acre snag densities than stands within the Cooper Spur parcels for both Small/Medium and 

Large Tree structural conditions. However, due to the difference in size of parcels, the Cooper 

Spur parcels have the capability to develop a higher number of snags overall, although gaps may 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

348

exist at the stand level. In addition, snag development and retention would be emphasized under 

Forest Service management, whereas if managed as private timberlands, emphasis in managing 

to retain snag snags is unlikely in these parcels. Snag development in younger conifer stands, 

which are estimate to represent about 40 to 45 percent of forest stands in Cooper Spur parcels, 

will take decades whereas snag development is likely occurring at some level in denser mid-seral 

and mature stands. 

Cumulative Effects

Similar to American marten, the area used to analyze cumulative impacts is the area within one 

mile of all parcels proposed for ownership transfer. In the Government Camp area, past 

development of National Forest System and lands of other ownership has decreased available 

pileated woodpecker habitat locally, but areas to the north and west remain primarily forested, 

with trees continuing advancing in age toward maturity. This is reflected in the existing 

condition. Ongoing and foreseeable activities listed in the Past, Present, and Reasonably 

Foreseeable Actions section consisting of recreation, residential use, infrastructure operations 

and maintenance are not expected increase habitat impacts, but may cause localized noise 

disturbance leading to pileated woodpecker temporary avoidance of some areas. The Mazama 

Lodge Parking Area Expansion has the potential to remove a small amount of potential tree 

roosting habitat (less than one acre). The Mirror Lake Trail Relocation Project may impact small 

amounts of habitat via parking lot construction and new trail construction. These activities may 

also increase noise disturbance locally, but because of the small scope of these activities, the 

additional effect is expected to be minor.

Determinations

The current trend for pileated woodpecker is increasing (see Forest-wide Analysis for 

Management Indicator Species). Transfer of lands at Government Camp would potentially 

decrease available habitat in the area by about 22 acres, which equates to approximately 

2.5 percent of one home range. At the Forest-level, loss of 22 acres equates to less than 1/100th

of 1 percent of available habitat. Acquisition of the Cooper Spur parcels would result in an 

additional 30 acres of potentially suitable habitat under Federal ownership, although pileated 

woodpecker suitable habitats would potentially be less effective due to roading, and younger 

forests taking longer to develop into suitable habitat. The very small magnitude of suitable 

habitats gained at Cooper Spur is similar to that lost at Government Camp. Therefore, this 

project would not contribute to negative trend in viability on the Forest for pileated woodpecker.

Deer and Elk 

Affected Environment

In the forest plan, deer and elk were selected as management indicator species because they are 

economically important game animals. Deer and elk utilize early-successional forest habitat for 

foraging and were originally thought to require mature and old growth forest habitat for thermal 

cover.

Habitat

Thermal cover is defined as a stand of coniferous trees at least 40 feet tall with an average crown 

cover of 70 percent or more. Optimal cover is found mainly in multi-storied mature and oldgrowth stands. Elk herds exhibit a close association with riparian habitat in areas of gentle terrain 

and low road density. Forage is widely available but is generally of low quality. The low quality 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

349

of the forage, especially in winter range, and the lack of wetlands and permanent low-gradient 

streams within winter range are considered limiting factors for elk and deer.

The forest plan standards and guidelines contain minimum requirements for optimal and thermal 

cover habitat components, but no specific level for forage. There are currently 69,226 acres of 

early-successional habitat on the Mt. Hood National Forest.

High road densities can lead to harassment of elk herds. Harassed elk move more often than 

those left undisturbed and use of habitat decreases as road density increases (Witmer and 

deCalesta 1985). Elk within or moving through areas of high road density tend to move longer 

distances (Fiedler 1994).

Populations

Based on State and global rankings, deer and elk are common, widespread and abundant. They 

are both managed as game species in the state of Oregon. The Government Camp parcels are 

located within the Santiam Game Management Unit; the Cooper Spur parcels occur within the 

Hood Game Management Unit.

Elk populations within the Santiam Game Management Unit are currently lower in comparison 

to numbers estimated during the 2000s, but population numbers have stabilized over the past 

5 years (figure 53). Elk population in the Hood Game Management Unit are low, but have 

increased slightly over numbers estimated from more than 10 years ago (ODFW 2016). Similar 

to elk populations, mule deer populations are down from previously higher levels, but stable over 

the past 5 years (figure 54). No population estimates are available for black-tailed deer within the 

Santiam Unit. At this time there is no concern for viability of the species by Oregon Department 

of Fish and Wildlife. If viability becomes a concern, the Department would limit or close the 

hunting season. Hunter success has been stable for the last 20 years indicating a stable deer and 

elk population in the state, although there has been a decline since the 1960s (ODFW 2016).

Figure 53. Elk trends, Hood and Santiam Game Management Units (source: ODFW 2016)
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

350

Figure 54. Mule deer trends, Hood Game Management Unit (source: ODFW 2016)

Habitat within the Project Area

Government Camp parcels currently contain approximately 78 acres of thermal cover and 13 

acres of forage habitat (table 117). All Government Camp parcels occur within the distribution

of deer and elk summer range. Cooper Spur parcels are estimated to contain about 279 acres of 

thermal cover and 63 acres in forage. Most acres (90 percent) occur within deer and elk winter 

ranges as mapped by Oregon Department of Fish and Wildlife (2009).

Table 117. Existing acres of deer and elk habitats 

Parcel Optimal Cover

Thermal 

Cover Forage

Summer 

Range

Winter 

Range

Government Camp 0 78 23 120 0

Cooper Spur 0 279 132 74* 695*

MHNF Lands Net Change 0 201 109 -46 695

*Based on ODFW deer and elk winter range distribution maps

MHNF = Mt. Hood National Forest

Environmental Consequences

No-action Alternative

Under the no-action alternative, existing amounts of optimal, thermal, and foraging habitat on 

Federal lands would remain unchanged.

Proposed Action

Direct and Indirect Effects

After transfer of ownership, thermal cover, forage, and summer range habitat amounts in table 

117 within the Government Camp parcels would be removed via development. Acquisition of 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

351

Cooper Spur parcels would increase Federal management of thermal cover, forage habitat, and 

winter range acres on the by amounts shown in table 117. Summer range acres on the Mt. Hood 

National Forest would decrease by approximately 46 acres, but thermal cover, forage, and winter 

range net acreage would all increase. On Cooper Spur parcels, about 28 acres currently in forage 

exists as dry meadow vegetation and would be expected to remain as effective forage habitat for 

the long-term (greater than 20 years) if managed to remove encroaching conifers. The remaining 

forage habitat consists of early successional forest and would be expected to provide forage only 

in the short-term (less than 20 years) as stands grow and conifer cover increases. Less than 1 acre 

within Government Camp parcels consist of dry meadow with potential to provide forage longterm.

Cumulative Effects

The area used to analyze cumulative impacts is the area within one mile of all parcels proposed 

for ownership transfer. In the Government Camp area, past development of national forest and 

lands of other ownership has decreased available deer and elk locally, but areas to the north and 

west remain primarily forested, with trees continuing advancing in age toward maturity. This is 

reflected in the existing condition. Ongoing and foreseeable activities listed in the Past, Present, 

and Reasonably Foreseeable Actions section consisting of recreation, residential use, 

infrastructure operations and maintenance are not expected increase habitat impacts, but may 

cause localized noise disturbance leading to elk avoidance of some areas. Ongoing maintenance 

of early seral habitat in ski runs and powerline corridors retains a forage source for both deer and 

elk. Winter activities would not impact either species because most or all individuals would be 

on winter range during this period. No measurable increase in impacts as a result of ongoing and 

foreseeable activities are expected.

Determinations

The current trend for deer and elk populations is stable (see Forestwide analysis for Management 

Indicator Species). Although the proposed action would augment available forage by 109 acres 

in the short term and 28 acres overall in the long term, this equates to less than one-tenth of 

1 percent of forage at the national forest level. Existing distribution of deer and elk winter range 

as mapped by Oregon Department of Fish and Wildlife totals about 98,000 and 110,000 acres, 

respectively, on National Forest System lands. An additional 695 acres represents less than 

1 percent of this area. Therefore, the proposed action would slightly increase forage and 

available winter range under Federal ownership and would not contribute to a negative trend in 

viability on the Mt. Hood National Forest for deer or elk.

Migratory Birds

Under the National Forest Management Act, the Forest Service 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 Forest Service (FS) Landbird Conservation Strategic Plan, followed by Executive 

Order 13186 in 2001, in addition to the Partners in Flight specific habitat conservation plans for 

birds and the January 2004 Partners in Flight North American Landbird Conservation Plan all 

reference goals and objectives for integrating bird conservation into forest management and 

planning.

In late 2008, a memorandum of understanding between the Forest Service and the U.S. Fish and 

Wildlife Service to Promote the Conservation of Migratory Birds was signed. The intent of the 

memorandum is to strengthen migratory bird conservation through enhanced collaboration and 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

352

cooperation between the Forest Service and the Fish and Wildlife Service as well as other 

Federal, State, tribal and local governments. Within the national forests, 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.

In early 2016, both Forest Service and U.S. Fish and Wildlife Service have agreed to extend the 

memorandum as currently written and the extension document is in the process of review and 

signature.

Existing Situation

Close to 30 species of migratory birds may occur within the Government Camp portion of the 

project, some of which are likely present within the project area during the breeding season.

Altman (1999, 2000) identified land bird focal species applicable to the Partners in Flight 

Physiographic Regions for western Oregon and Washington (Government Camp parcels) as well 

as the East Slope of the Cascade Mountains (Cooper Spur parcels). Those species with habitat 

affiliations found in the project area are listed in table 118. In addition, the U.S. Fish and 

Wildlife Service’s list of Birds of Conservation Concern (USDI Fish and Wildlife 2008) was 

reviewed for species within Bird Conservation Region 5, which encompasses the entire project 

area, applicable to the project area (Wildlife Specialist Report, Table 21). Two species, the 

Rufous Hummingbird and Olive-sided Flycatcher are applicable to the Project Area. The 

hummingbird is found in a variety of habitats, most likely in brushy areas with flowers and 

forests with a well-developed understory; the fly-catcher in open conifer forests (greater than 

40 percent canopy cover) and edge habitats where standing snags and scattered tall trees remain 

after a disturbance.

There are no known important bird areas such as nesting, wintering, or stop-over areas within the 

project area.

Table 118. Landbird focal species and habitats (Altman 1999, 2000)

Physiographic Area Habitat/Forest 

Condition Habitat Attribute Focal Species Applicable 

to the Project Area

Western OR, WA Mature Large snags Pileated woodpecker

Western OR, WA Mature Mid-story tree layers Varied thrush

Western OR, WA Young and Mature Closed canopy Hermit warbler

Western OR, WA Young and Mature Open mid-story Pacific-slope flycatcher

Western OR, WA Young and Mature Deciduous understory Wilson’s flycatcher

Western OR, WA Young and Mature Forest floor complexity Winter wren

Western OR, WA Young and Pole Deciduous canopy trees Black-throated gray warbler

Western OR, WA Pole Deciduous subcanopy Hutton’s vireo

Western OR, WA Early seral Residual canopy trees Olive-sided flycatcher

Western OR, WA Early seral Snags Western bluebird

Western OR, WA Early seral Deciduous vegetation Orange-crowned warbler

Western OR, WA Early seral Nectar producing plants Rufous hummingbird

Western OR, WA Unique Montane wet meadows Lincoln’s sparrow

East slope Cascades Mixed conifer Large trees Brown creeper

East slope Cascades Mixed conifer Large snags Williamson’s sapsucker

East slope Cascades Mixed conifer Grassy openings, dense 

thickets

Flammulated owl
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

353

Physiographic Area Habitat/Forest 

Condition Habitat Attribute Focal Species Applicable 

to the Project Area

East slope Cascades Mixed conifer Multi-layered, structurally 

diverse

Hermit thrush

East slope Cascades Mixed conifer Fire edges and openings Olive-sided flycatcher

East slope Cascades Montane meadows Wet and dry Sandhill crane

Environmental Consequences

No-action Alternative

There would be no transfer of ownership or alteration of habitats under this alternative, and 

therefore, no potential impacts to migratory birds.

Proposed Action

Ownership transfer and subsequent development of Government Camp parcels would remove 

habitat on about 103 acres for species associated with mature and young forest habitat 

components (hermit warbler, Pacific-slope flycatcher, Wilson’s warbler, and winter wren). Lesser 

amounts of early seral open habitat (2 acres) applicable to olive-sided flycatcher, western 

bluebird, orange-crowned warbler, and rufous hummingbird) would also be removed. Montane 

wet meadow (less than 1 acre, Lincoln’s sparrow) habitat may be preserved or impacted 

depending upon the conservation easement strategy applied to wetlands after ownership transfer.

Mt. Hood National Forest acquisition of Cooper Spur parcels would increase Federal ownership 

of habitats potentially providing for brown creeper (approximately 30 acres) and non-breeding 

Sandhill crane (33 acres), although removal of encroaching conifers would be necessary to 

improve suitability to non-breeding Sandhill cranes. In the long term, growth and development 

of forested stands at Cooper Spur could provide almost 400 acres of habitat for species 

associated with mature east-side mixed conifer forest (brown creeper, Williamson’s sapsucker, 

and hermit thrush). However, long-term stand growth would also diminish existing edge habitat 

and early successional areas that currently favor foraging by olive-sided flycatchers.

Cumulative Effects

Since migratory birds venture great distances and each species has a different range, cumulative 

effects can result from a vast array of activities and practices such as conversion of forests and 

wetlands to farms or developments. The use of chemical pesticides can affect birds. These 

practices and others can occur across both North and South America.

Both Federal and private land parcels proposed for ownership transfer constitute a very small 

portion of available land bird breeding habitat within and adjacent to the Mt. Hood National 

Forest. The majority of forested acres at Government Camp consist of mid-successional stands 

which are common in this portion of the national forest, particularly in adjacent wilderness areas.

While there may be some local redistribution of birds to other suitable habitats within and 

adjacent to the Government Camp parcels due to project-level activities and those listed in the 

Past, Present, and Reasonably Foreseeable Actions section, these effects would be localized and 

minor at the landscape scale.

Determinations

The Government Camp-Cooper Spur Land Exchange project may affect habitat for individual 

migratory birds, but is not expected to have a measurable effect on their overall habitat or 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

354

populations because of the large amount of available habitat in proximity to the parcels. Habitat 

loses resulting from this project should not affect this group of species such that their ability to 

persist on the Mt. Hood National Forest or throughout their ranges would be compromised.

Survey and Manage Species

In January 2001, a Record of Decision for Amendments to the Survey and Manage, Protection 

Buffer and other Mitigation Measures Standards and Guidelines (2001 amendment) was signed. 

This decision amended the Northwest Forest Plan survey and manage and related standards and 

guidelines to add clarity, remove duplication, increase or decrease levels of management for 

specific species based on new information, and established a process for making changes to 

management for individual species in the future (USDA USDI 2001).

The 2001 amendment put into place a review process that would allow for the adding or 

dropping of species, based on new information. The 2001 amendment also grouped the species 

into six categories (A through F) based on level of relative rarity, ability to reasonably and 

consistently locate occupied sites during surveys prior to habitat disturbing activities, and the 

level of information known about the species or group of species. A complete description of the 

categories can be found in the 2001 amendment standards and guidelines pages 6 through 14.

This project applies the survey and manage species list published in December 2003 under 

direction resulting legal action and a district court’s remedy order issued on 18 February 2014 

(Conservation Northwest v. Bonnie, W.WA No. C08-1067-JCC) and thus meets the provisions of 

the 2001 Record of Decision and Standards and Guidelines for Amendments to the Survey and 

Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines, as 

modified by the 2014 court order. The following species listed in table 119 shows current survey 

and manage species whose known or suspected range includes the Mt. Hood National Forest. 

Field reconnaissance and GIS analysis was used to determine habitats that were present in the 

project area. Land exchanges are not themselves habitat-disturbing activities (see page 22 of the 

2001 Survey and Manage Record of Decision standards and guidelines) and for this reason do 

not trigger survey and manage pre-disturbance surveys; therefore, pre-disturbance surveys were 

not required for this project. 

Table 119. Survey and manage species within Oregon Western Cascades Geographic Area 

(December 2003 species list; May 2014 Direction)

Category1 Species Potential Habitat Within 

the Project Area? Potential Effects?

Additional 

Analysis 

Needed?

Amphibians

A Larch Mountain 

salamander

(Plethodon 

larselli)

Yes; occurs on shady, 

moss-covered talus slopes 

and cave entrances at low 

to mid-elevations in late 

seral forests and moist 

forest where soils are 

derived from pumice.

Yes Addressed 

as Sensitive 

Species
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

355

Category1 Species Potential Habitat Within 

the Project Area? Potential Effects?

Additional 

Analysis 

Needed?

Birds

A Great gray owl

(Strix nebulosa)

Yes; associated with conifer

and mixed forest, ponderosa 

pine, and lodgepole, most 

frequently in old-growth on 

north-facing slopes; 

adjacent to large open 

meadows.

No; There are no 

proposed activities 

within old-growth 

stands adjacent to 

large open meadows 

within the project 

area. 

No

Mammals

C Red tree vole

(Arborimus 

longicaudis)

No; Species distribution is 

restricted to areas below 

3,500 feet elevation west of 

the Cascades crest. Project 

area is outside the known 

species distribution.

No No

Mollusks

A Columbia 

oregonian

(Cryptomastix 

hendersoni)

No; associated with moist 

areas under closed-canopy 

western hemlock forest and 

moist microclimates in 

semiarid habitat along the 

Columbia River. Project 

area is outside the known 

species distribution

No No

A Crater Lake

tightcoil

(Pristiloma 

arcticum crateris)

Yes; occurs in wetlands in 

moist forest, often in fens or 

sedge habitats near open 

water that experience long 

periods of snow cover.

Yes Addressed 

as Sensitive 

Species 

A Dalles sideband

(Monadenia 

fidelis minor)

Yes; usually found in moist 

rock talus near streams or 

springs and under moist 

woody debris or other litter 

near riparian corridors.

Yes Addressed 

as Sensitive 

Species

B Evening fieldslug

(Deroceras 

hesperium)

Yes; typically inhabits low 

elevation, perennially wet 

meadows in forested 

habitats.

Yes Yes, see 

discussion 

below

B Panther jumping 

slug

(Hemphillia 

pantherina)

No; found under and inside 

logs and other forest litter 

and in talus in moist forest 

and riparian areas below 

3,000 feet elevation.

No; habitat not 

present within the 

project area.

No

A Puget oregonian

(Cryptomastix 

devia)

No; associated with forests 

where big-leaf maples occur 

within conifer overstory; 

often found on or under 

hardwood logs or leaf litter 

or rocks.

No; habitat not 

present within project 

area.

No

1. Survey and manage category definitions:

Category A = Manage all known sites; pre-disturbance surveys practical, strategic surveys

Category B = Manage all known sites; pre-disturbance surveys not practical and not applicable; strategic surveys

Category C = Manage high-priority sites; pre-disturbance surveys practical; strategic surveys
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

356

Deroceras hesperium

Affected Environment

The historic range of D. hesperium, known as the evening fieldslug, is northwestern Oregon 

through western Washington, to Vancouver Island, British Columbia, Canada. Recent 

documented locations indicate that the range also includes the western and eastern Oregon 

Cascades from Hood River to the Klamath River basin (Duncan 2005).

The evening fieldslug is associated with perennially wet meadows in forested habitats; 

microsites include a variety of low vegetation, litter and debris; rocks may also be used as 

refugia. Little detail is known about exact habitat requirements for the species, due to the limited 

number of verified sites. However, this species appears to have high moisture requirements and 

is almost always found in or near herbaceous vegetation at the interface between soil and water, 

or under litter and other cover in wet situations where the soil and vegetation remain constantly 

saturated. Because of the apparent need for stable environments that remain wet throughout the 

year, suitable habitat may be considered to be limited to moist surface vegetation and cover 

objects within 30 meters (98 feet) of perennial wetlands, springs, seeps and riparian areas. Areas 

with coastal fog may allow the species to occupy habitats farther from open water. Down wood 

may provide refugia sites for the species that remain more stable during drier periods of the year 

than the general habitat. Elevations of occupied sites range from coastal meadows to sites near 

the Cascade Crest (Duncan 2005). 

Young and Doerr (2013) reported finding Derocerus laeve, a species potentially synonymous 

with D. hesperium (Roth et al. 2013), among stands of skunk cabbage on the Willamette 

National Forest up to 3,500 feet elevation, and suggested that skunk cabbage plants provide a 

critical reserve habitat during the summer dry period for Deroceras and other mollusks.

There are no documented locations of Deroceras hesperium within the project area. 

Habitat within the Analysis Area

Wetland surveys conducted by Watershed Professionals Network (2010) reported wetlands 

totaling about 6 acres containing skunk cabbage in the Government Camp parcels (Wetland 5 

and a portion of Wetland 10). Although the elevations (3,800 to 4,100 feet) of these parcels may 

be at the upper limit of this species’ range, the presence of suitable wetland sites indicates that 

there is potential for species presence. No suitable habitat is expected to occur within Cooper 

Spur parcels. 

Environmental Consequences

No-action Alternative 

Under the no-action alternative, existing land ownership in the Government Camp and Cooper 

Spur parcels would remain unchanged. No transfer in ownership of existing amounts of potential 

Deroceras hesperium habitat would occur. No direct, indirect, or cumulative effects would occur 

as a result of the no-action alternative.

Proposed Action

Direct and Indirect Effects

Implementation of the proposed action would have no direct effects on this species or habitat.

About 6 acres of suitable habitat is located within Government Camp parcels. The 2009 

Omnibus Act prescribed as a mandatory condition to the land exchange that the Forest Service 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

357

reserve wetland and trail easements on the Federal parcels to be exchanged. More specifically, 

the Omnibus Act required the Forest Service to reserve a conservation easement on the Federal 

land to protect existing wetlands, as identified by the Oregon Department of State Lands that 

allows equivalent wetland mitigation measures to compensate for minor wetland encroachments 

necessary for the orderly development of that land following the exchange. The Clarification Act 

(which is now the proposed action) changed this provision from “shall reserve” to “may 

mutually agree to reserve”. Under both scenarios with or without a Federal conservation 

easement, some increased level of sediment delivery into wetlands is expected due to 

surrounding development (see Hydrology Specialist Report). 

Under the proposed action, wetlands in the conveyance parcels would no longer be managed and 

conserved by the Forest Service as riparian reserves. Regulatory authority and oversight for the 

protection of these wetlands would switch to the Oregon Department of State Lands who share 

the responsibility implementing section 404 of the Clean Water Act, the principal statute for 

governing activities in wetlands, with the Oregon Department of Environmental Quality, the U.S. 

Army Corps of Engineers and the U.S. Environmental Protection Agency. Activities associated 

with residential development that could encroach upon the wetlands would have to undergo a 

review and permitting process according to Oregon Revised Statute before they would be 

authorized (see Supplement to the Watershed Resources Report). 

Section 404 of the Clean Water Act protects wetlands from net loss regardless of ownership by 

the use of either on-site conservation easements or compensatory mitigation (funding the 

creation or restoration of wetlands at a different place and time and maintaining them in 

perpetuity). The proposed action would include conservation easements, so that the wetlands in 

the conveyed parcels would be protected according to regulation by the Department of State 

Lands. If on-site conservation easement is applied, retention of suitable Deroceras hesperium

habitat is expected. In the event that compensatory mitigation is applied, residential 

encroachment of the site may occur, thereby reducing or removing habitat suitability on up to 

6 acres. Based on data obtained from the National Wetlands Inventory (USDI Fish and Wildlife 

Service 2016b), Freshwater Emergent Wetland and Freshwater Forested/shrub Wetland habitats 

total 1,883 acres and 3,840 acres, respectively on the Mt. Hood National Forest. The 6 acres of 

habitat within the Government Camp parcel represents approximately 0.3 percent of freshwater 

emergent wetland habitat and 0.1 percent of all potential habitat on the national forest.

Cumulative Effects

The cumulative effects analysis area consists of the wetland vegetation in Wetland numbers 5 

and 10 (Government Camp parcels), as well as perennial streams above these wetlands. This 

encompasses the potential disturbances and habitat impacts for Deroceras hesperium. Past 

activities such as timber harvest, road construction, development, wildfire, and other 

disturbances are reflected in the existing condition. Ongoing and foreseeable activities in 

proximity to the parcels are listed in the Past, Present, and Reasonably Foreseeable Actions

section. No projects or activities listed are expected to contribute detrimental cumulative effects 

to peak streamflows, stream temperatures, or sediment delivery (see Hydrology Specialist

Report).

Determinations

The Government Camp-Cooper Spur Land Exchange project may affect individuals (if present) 

and habitat suitable for this species on approximately 6 acres. Based upon the small amount of

habitat involved and the position of the habitat at the upper range of elevational distribution, 

potential habitat impacts resulting from this project are not expected to impact Deroceras 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

358

hesperium such that their ability to persist on the Mt. Hood National Forest or throughout their 

range would be compromised.

Summary of Survey and Manage Species Analysis

• There are no known existing occurrences of species listed in table 119 within the project 

area. 

• A total of four survey and manage animal species have potential to occur within the project 

area.

• Three species (Larch Mountain salamander, Crater Lake tightcoil, and Dalles sideband) 

were addressed in the biological evaluation as sensitive species. 

• A total of 6 acres of potential suitable habitat for Deroceras hesperium occurs within the 

Government Camp parcels. Potential impacts to this site would depend upon conservation 

easement strategies that would take effect after transfer of ownership.
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

359

Wildlife Effects Summary

Table 120 provides a summary of effects determinations for threatened, endangered, proposed, 

sensitive, management indicator, migratory bird, and survey and manage species addressed in 

this analysis.

Table 120. Summary of impacts to wildlife addressed in this analysis

Species Impact of No 

Action Impact of Proposed Action

Federally Threatened, Endangered or Proposed

Northern spotted owl (threatened) No effect May affect, and is likely to 

adversely affect 

Northern spotted owl critical habitat No effect No effect

North American wolverine (proposed for listing) No effect Will not jeopardize

R6 Sensitive Species

American peregrine falcon No impact No impact

Bald eagle No impact No impact

White-headed woodpecker No impact No impact

Lewis’s woodpecker No impact No impact

Bufflehead No impact No impact

Harlequin duck No impact No impact

Sierra Nevada red fox No impact May impact*

Townsend’s big-eared bat No impact May impact*

Fringed myotis No impact May impact*

Western pond turtle No impact No impact

Larch Mountain salamander No impact May impact*

Cope’s giant salamander No impact May impact*

Johnson’s hairstreak No impact May impact*

Mardon skipper No impact May impact*

Western bumble bee No impact May impact*

Beller’s ground beetle No impact No impact

Puget Oregonian No impact No impact

Columbia sideband No impact No impact

Dalles sideband No impact No impact

Crater Lake tightcoil No impact May impact*

Crowned tightcoil No impact No impact

Shiny tightcoil No impact No impact

Mt. Hood National Forest Management Indicator 

Species

Northern spotted owl No impact Addressed as threatened 

species

Pileated woodpecker No impact Will not contribute to 

negative trend in viability

American (pine) marten No impact Will not contribute to 

negative trend in viability

Silver gray squirrel No impact No impact
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

360

Species Impact of No 

Action Impact of Proposed Action

Merriam’s turkey No impact No impact

Deer No impact Will not contribute to 

negative trend in viability

Elk No impact Will not contribute to 

negative trend in viability

Migratory Birds

Applicable Birds of Conservation Concern and 

Focal Species

No impact Will not compromise species 

persistence

Survey and Manage Species

Deroceras hesperium No impact Will not compromise species 

persistence

* May impact = May Impact Individuals or habitat, but will not likely contribute to a trend toward Federal listing or cause a 

loss of viability to the population or species

Forest Plan Amendment Summary

A total of 1,109 acres would shift in Land Use Allocation from Winter Recreation to Wilderness, 

thereby reducing potential disturbance to wildlife from on and off-road motorized access. 

Approximately 769 acres of Cooper Spur acquired lands and 2,110 acres of existing Federal 

lands to be included in the Crystal Springs Watershed Special Resources Management Unit 

would be assigned additional management direction under the Forest Plan (see chapter 2). 

Management direction within the Crystal Springs Unit emphasizes watershed health as well as 

wildlife habitat restoration. Presence of large-diameter older trees within visible areas is also 

prescribed, which is expected to benefit a number of special status species including northern 

spotted owl, Johnson’s hairstreak, fringed myotis, pileated woodpecker, American marten, and 

various migratory birds.

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).

Unavoidable Adverse Effects

Alternative 2 would result in the following:

A loss of individuals or potential habitat for 234 Survey and Manage species and 37 sensitive 

plant species on the Regional 6 Regional Forester’s Special Status Species list (Botany section of 

DEIS).

The loss of four potentially eligible cultural resources on the lands to be conveyed. The loss of 

ceded land for the Confederated Tribes of Grand Ronde and Warm Springs (Cultural Resources 

and Treaty Rights).
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

361

Elements of the project may indirectly effect (may affect, and is likely to adversely affect) 

Endangered Species Act (ESA)-listed fish species designated as threatened based on the potential 

for increases in sediment, turbidity, and embeddedness, which can impact spawning and rearing 

as well as food source availability (Fisheries).

The project “may adversely modify” designated critical habitat for Lower Columbia River 

Chinook, coho, and steelhead in the Zigzag Watershed. Three of the six physical and biological 

features that have been established for the critical habitat of the species are addressed here; 

freshwater spawning sites, freshwater rearing sites, and freshwater migration corridors (50 CFR 

Part 226 70 FAR 52664-5). The project would measurably modify these physical and biological 

features (Fisheries). 

The proposed project would “adversely affect essential fish habitat” for Lower Columbia River 

Chinook and coho in the Zigzag Watershed (Fisheries). 

At the site scale both Camp Creek and the unnamed tributary to the Little Zigzag River have 

predicted peak streamflows increases above 10 percent. Based on predicted increases in peak 

streamflows, streambed composition and stream gradient there may be impacts in the form of 

increased bank erosion, channel scour, channel widening, and sedimentation in these areas 

(Hydrology). 

Implementation of the proposed action would result in a 3 percent increase in sediment yield 

from background levels in both the Camp Creek and Little Zigzag 7th field watersheds. Instream fine sediment levels in both streams would increase (Hydrology).

The non-exclusive nature of the proposed trail easement would remove the ability of trail 

managers to use the preferred equipment for future ski trail grooming (trail width would be too 

narrow). This width would indirectly affect the future management of the trail system. The intent 

of the Government Camp Trails Project (2009) was to increase the amount of groomed trail on 

the Mt. Hood National Forest outside of developed ski areas for Nordic skiing. The width of the 

proposed trail easement would likely be insufficient to accommodate the appropriate equipment 

for winter grooming operations. Therefore, this alternative could directly and negatively affect 

the welfare of this community of users (Recreation and Socioeconomics). 

The result of the development surrounding the Government Camp trail system could also 

negatively affect users’ enjoyment and scenic beauty of these trails due to changes in location 

and nearby developments as well as potential trail discontinuity and changes in safety due to 

additional road crossings. If so, it could be that users may choose to use alternative sites and 

trails which might adversely impact local business, such as guiding businesses

(Socioeconomics).

The number of acres considered as suitable for timber production would decrease by 

approximately 249 acres (Silviculture). 

Visual quality as seen from the lands adjacent to the Government Camp parcels would decrease 

with the loss of the visual quality objective of Retention (Visuals).

Alternative 2 may affect, and is likely to adversely affect spotted owls, as it would result in a loss 

of northern spotted owl habitat totaling approximately 22 acres of suitable habitat. 60 acres of 

dispersal habitat would also be lost (Wildlife). 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

362

For nine species on the R6 Sensitive wildlife species list, Alternative 2 may impact individuals or 

habitat, but will not likely contribute to a trend toward Federal listing or cause a loss of viability 

to the population or species (Wildlife).

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. Irretrievable commitments are those that are lost for a 

period of time such as the temporary loss of timber productivity in forested areas that are kept 

clear for use as a power line rights-of-way or road.

The proposed action would convey public land for private use. The lands to be conveyed 

expected to be developed. This is an irreversible action and would result in a loss of many of the 

uses and values formerly provided by this forested land. These values include the scenic beauty, 

amenity and existence values (Socioeconomics).

The proposed action would result in a proportion of the soils in the conveyed parcels to be 

converted to hardened surfaces such as roads, driveways, sidewalks, and rooftops. They would 

no longer be available nor capable of growing and maintaining vegetation. Soils would no longer 

support a contiguous forested cover type, nor function in quite the same capacity to support 

ecosystem functions. Instead, soils would have been committed to supporting buildings, 

structures, and infrastructure of a residential development for the life of its use (Soils). 

Other Required Disclosures

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.”

National Historic Preservation Act

Regulations that support and enhance the National Historic Preservation Act include:

36 CFR 800 (Protection of Historic Properties, section 106).

Section 106 of the National Historic Preservation Act requires Federal agencies to take into 

account the effects of their undertakings on historic properties. The procedures in this part define 

how Federal agencies meet these statutory responsibilities. The section 106 process seeks to 

accommodate historic preservation concerns with the needs of Federal undertakings through 

consultation among the agency official and other parties with an interest in the effects of the 

undertaking on historic properties. This applies to this project to identify historic properties 

potentially affected by the undertaking, assess its effects and seek ways to avoid, minimize or 

mitigate any adverse effects on historic properties. 

36 CFR 63 (Determination of Eligibility to the National Register of Historic 

Places). 

These regulations have been developed to assist Federal agencies in identifying and evaluating 

the eligibility of properties for inclusion in the National Register.

36 CFR 296 (Protection of Archaeological Resources). 

The regulation implements the Archaeological Resources Protection Act of 1979, by establishing 

the uniform definitions, standards, and procedures to be followed by all Federal land managers in 
Draft Environmental Impact Statement

Chapter 3 – Affected Environment and Environmental Consequences

Mt Hood National Forest

363

providing protection for archaeological resources, located on public lands and Indian lands of the 

United States. 

1994 Programmatic Agreement (PA) (amended in 2004) 

Agreement among the USDA Forest Service Pacific Northwest Region, the Advisory Council on 

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

Resource Management in the State of Oregon by the USDA Forest Service.

Further legal authority that guides internal decisions related to cultural resources are:

Archaeological Resources Protection Act (ARPA) of 1979. 

To secure, for the present and future benefit of the American people, the protection of 

archaeological resources and sites which are on public lands and Indian lands, and to foster 

increased cooperation and exchange of information between governmental authorities, the 

professional archaeological community, and private individuals having collections of 

archaeological resources and data which were obtained before the d ate of the enactment of this 

Act. This Act would apply to any areas of importance to the tribe for traditional or cultural 

purposes within the project area.

Native American Graves Protection and Repatriation Act (NAGPRA) of 1990. 

A Federal law passed in 1990, NAGPRA provides a process for museums and Federal agencies 

to return certain Native American cultural items—human remains, funerary objects, sacred 

objects, or objects of cultural patrimony—to lineal descendants, and culturally affiliated Indian 

tribes and Native Hawaiian organizations. This act would apply for any new or old discoveries 

for the lands to be acquired parcel or the conveyed lands parcel.

Executive Order 13007 (Indian Sacred Sites). 

In managing Federal lands, each executive branch agency with statutory or administrative 

responsibility for the management of Federal lands shall, to the extent practicable, permitted by 

law, and not clearly inconsistent with essential agency functions, (1) accommodate access to and 

ceremonial use of Indian sacred sites by Indian religious practitioners and (2) avoid adversely 

affecting the physical integrity of such sacred sites. Where appropriate, agencies shall maintain 

the confidentiality of sacred sites. This act would apply to any areas of importance to the tribe 

for traditional or cultural purposes within the project area.

Environmental Justice Act

Environmental Justice, Executive Order 12898 of February 11, 1994 orders Federal agencies to 

identify and address any adverse human health and environmental effects of agency programs 

that disproportionately impact minority and low-income populations.

Migratory Birds

Executive Order 13186 was signed on January 10, 2001, directing Federal agencies that take 

actions directly or indirectly affecting migratory birds to develop a memorandum of 

understanding with U.S. Fish and Wildlife Service to promote the conservation of migratory bird 

populations. A memorandum of understanding between the Forest Service and U.S. Fish and 

Wildlife Service, signed 2008 (FS Agreement #08-MU-1113-2400-264) and extended in 2016, 

provides a framework to incorporate migratory bird conservation elements into national forestlevel and project-level environmental analysis planning.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

364

Incomplete or Unavailable Information

Land exchanges convey land, interests in land, and the resources associated with them. Of itself, 

the specific act of conveyance does not have environmental effects. Therefore, the Forest Service 

Handbook provides direction that states that the NEPA analysis should focus on the future use 

and management of the lands being conveyed (5409.13, Chapter 30, Section 33.14). For this 

reason, the NEPA analysis was largely focused on the potential development of the Government 

Camp parcels. Because no specific development plans have been finalized and/or approved by 

Clackamas County or any other applicable State permitting authorities, the interdisciplinary team 

identified a general list of assumptions about the development and use of the Government Camp 

parcels (see the list of Analysis Assumptions near the beginning of chapter 3). These 

assumptions are primarily based on zoning regulations required by Clackamas County. The 

effects of the conveyance on each resource evaluated are based on these assumptions and the 

other criteria described in the individual specialist reports.

The question of whether or not wetland conservation easements would be required, and the exact 

nature of them if they were to be agreed upon, was also unknown at the time of analysis. The 

exact nature of the trail easements was also unknown. Assumptions were developed regarding 

the elements of such easements, using the best information available, for the analysis of potential 

effects. A range of effects was disclosed when applicable to the resource evaluated, to account 

for the minimum to expected maximum size of any wetland conservation or trail easements that 

may be agreed upon in the future. 
Draft Environmental Impact Statement

Chapter 4 – Preparers and Contributors

Mt Hood National Forest

365

Chapter 4 – Preparers and Contributors

Consultation and Coordination

This chapter provides a list of preparers and agencies consulted during the development of the 

environmental analysis, as well as a distribution list of the DEIS. The following sections will list 

those involved in the consultation and coordination process of the project. The Interdisciplinary 

Team member section will name all specialists involved in the preparation process of this EIS and 

describe the education and brief experience of each member.

Federal, State and Local Agencies

The following sections describe the formal and informal consultation that was completed with 

Federal and State agencies as part of this project.

Consultation with U.S. Fish and Wildlife Service (USFWS)

Formal consultation is required with USFWS for disturbance of Northern spotted owls (Strix 

occidentalis caurina). Since the future development of the conveyed lands is likely to remove 

approximately 22 acres of suitable spotted owl habitat, the effects determination for this project is 

may effect, likely to adversely affect (LAA) northern spotted owls. Formal consultation with 

USFWS will be completed as part of this project and discussed in the FEIS.

Consultation with National Marine Fisheries Service (NMFS)

Elements of the project may indirectly effect (may affect, and is likely to adversely affect (LAA)) 

three Endangered Species Act (ESA) listed fish species designated as threatened that are present 

in the action area. The specific species include the Lower Columbia River Steelhead Trout 

(Oncorhynchus mykiss), Lower Columbia River Chinook (Oncorhynchus tshawytscha), and 

Lower Columbia River Coho (Oncorhynchus kisutch). This determination is based on the 

potential for increases in sediment, turbidity, and embeddedness, which can impact spawning and 

rearing as well as food source availability. Changes to water quality could impair navigation or 

reduce food sources. Increases in peak/base stream-flows could reduce suitable in-channel habitat 

for rearing, spawning, or migration. The project may adversely modify designated critical habitat 

and would adversely affect essential fish habitat for the same three species in the Zigzag 

Watershed. Three of the six physical and biological features that have been established for the 

critical habitat of the species are addressed in the Biological Evaluation; freshwater spawning 

sites, freshwater rearing sites, and freshwater migration corridors (50 CFR Part 226 70 FAR 

52664-5). The project would measurably modify these physical and biological features. Formal 

consultation with NMFS will be completed as part of this project and discussed in the FEIS.

Consultation with Oregon State Historic Preservation Office (SHPO)

The National Historic Preservation Act and the National Environmental Policy Act both require 

consideration be given to the potential effect of Federal undertakings on historic resources, 

(including historic and protohistoric cultural resource sites). The guidelines for assessing effects 

and for consultation are provided in 36 CFR 800. To implement these guidelines, in 2004, Region 

6 of the Forest Service entered a Programmatic Agreement (PA) with the Oregon State Historic 

Preservation Office (SHPO) and the Advisory Council on Historic Preservation (ACHP). 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

366

In accordance with the 2004 programmatic agreement, heritage resource surveys have been 

conducted and a site evaluation was completed for the Government Camp parcels, which were 

initially documented in Heritage Resource Report 2010-060609-001 (McClure 2010). Currently, 

the 2010 Heritage Report has been updated and was submitted to SHPO on August 2, 2016 for 

their review. An additional report on above ground resources will be submitted and discussed in 

the FEIS.

Since the laws regarding Section 106 do not apply to private entities, the assumption is that the 

land conveyance would result in an adverse effect to a known cultural resource on the 

Government Camp parcel. The potential for mitigation is currently under discussion with the 

State and Tribal Historic Preservation Offices. 

Tribal Consultation

On December 4, 2009, both the Confederated Tribes of Warm Springs (CTWS) and Confederated 

Tribes of Grand Ronde (CTGR) were sent cultural resources reports for the project. A response 

was received from the CTWS in the form of a formal letter citing tribal concerns. A draft 

Memorandum of Agreement (MOA) was developed between the Oregon State Historic 

Preservation Office, US Forest Service and Mt. Hood Meadows. At this time, no response was 

provided by CTGR. 

In 2016, the CTGR cultural resources staff were provided a copy of the initial cultural resources 

report. Forest Service staff met informally with cultural resources staff at CTGR to re-introduce 

the project on April 19, 2016. Comments pertaining to the cultural resources report were received 

by the Forest Service and documented. On June 17, 2016, Forest Service staff visited the CTWS 

and discussed the project. CTWS provided the Forest Service with comments relating to treaty 

rights. On July 11, 2016, both CTWS and CTGR were mailed revised cultural resources reports. 

CTGR responded with comments and a request for a meeting, which was held on August 3, 2016. 

CTWS responded with a request for a meeting, which was held on September 21, 2016.

Additional coordination with the Tribes will continue to discuss specific mitigation measures and 

ensure that Tribal interests are considered.
Draft Environmental Impact Statement

Chapter 4 – Preparers and Contributors

Mt Hood National Forest

367

Preparers and Contributors

The following is a list of contributors to this DEIS. Numerous other Forest Service employees 

contributed to the completion of this document through their assistance in review and support 

functions, and/or by providing Forest Service-level data and other information needs. Their help 

was greatly appreciated and recognized. The members and roles of the interdisciplinary team are 

listed below and short biographies follow for each person.

Team Role Person

Interdisciplinary Team Leader Debra Proctor

Fish Biologist Kathryn Arendt

Engineering / Facilities Rithy Bein

Social-Economic Allison Borchers

Recreation / Visual David Fothergill

Writer-Editor Patricia Goude

NEPA Specialist Michelle Lombardo

Botanist / Invasive Species David Lebo

Silviculture Tom Lowell

Wildlife Biologist Doug Middlebrook

Heritage Resources Debbie Ortiz

Hydrology Todd Parker

Soils / Hydrology Todd Reinwald

Lands Patricia Snyder

GIS Kathryn Strawn

Heritage Resources / Tribal Coordination Alexandra Wenzl

Debra Proctor. Environmental Coordinator, U.S. Forest Service, TEAMS Enterprise Unit. 

Education: B.S. in Water Resources, emphasis in Watershed Management. Experience: 

Environmental Analysis and NEPA Coordination, Deputy and Acting District Ranger, Forest Plan 

implementation, Watershed Specialist, and Soil Scientist with the Forest Service since 1988.

Kathryn Arendt. Eastside Zone Fish Program Manager, U.S. Forest Service, Mt. Hood National 

Forest, Hood River and Barlow Ranger Districts. Education: B.A. in Political Science, emphasis 

on international studies, M.S. in Environmental Studies (thesis unfinished), emphasis on 

Salmonid Ecology. Experience: Fisheries Biologist with the Forest Service for 11 years.

Rithy Bein. Civil Engineer, U.S. Forest Service, Mt. Hood National Forest, Supervisor’s Office. 

Education: B.S. in Civil Engineering. Experience: Provide engineering support for multiple 

Interdisciplinary Team planning, design and implementation projects on the Mt. Hood National 

Forest and Columbia River Gorge National Scenic Area. 

Allison Borchers. Economist, U.S. Forest Service, TEAMS Enterprise Unit. Education: B.A. in 

Economics; M.S. in Food and Resource Economics; Ph.D in Economics with a specialization in 

non-market valuation and environmental economics. Experience: Economic research and writing 

with the USDA since 2010. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

368

David Fothergill. Forest Landscape Architect, U.S. Forest Service, TEAMS Enterprise Unit. 

Education: B.S. in Biology, emphasis in Evolutionary Ecology; M.L.A. in Landscape 

Architecture. Experience: Scenery and Recreation Planning and Design with the Forest Service 

since 2011. 

Patricia Goude. Writer-editor, U.S. Forest Service, TEAMS Enterprise Unit. Education: B.A. in 

Technical Journalism with emphasis in Natural Resources. Experience: Writer-editor with the 

Forest Service since 2010. 

Michelle Lombardo. Forest Environmental Coordinator, U.S. Forest Service, Mt. Hood National 

Forest, Supervisor’s Office. Education: B.S. in Natural Science, emphasis in Geology; M.S. in 

Geography, emphasis in Natural Resource Management. Experience: Forest Plan implementation 

and NEPA coordination and writing with the Forest Service since 2005.

David Lebo. Westside Zone Botanist. U.S. Forest Service, Mt. Hood National Forest, Zigzag and 

Clackamas Ranger Districts. Education: B.A. in Humanities; M.A. in English; M.S. in Forest 

Ecology with emphasis in mycology. Experience: Ecologist with the Forest Service and Bureau of 

Land Management from 1993 to 2004; Botanist with the Forest Service since 2005.

Tom Lowell. Certified Silviculturist. U.S. Forest Service, TEAMS Enterprise Unit. Education: 

B.S. in Forest Resource Management. Experience: Vegetation management operations and 

planning since 1985.

Doug Middlebrook. Wildlife Biologist, U.S. Forest Service, TEAMS Enterprise Unit. Education: 

B.S. in Wildlife Biology. Experience: District Wildlife Biologist and TEAMS Enterprise Wildlife 

Biologist with the Forest Service since 1995.

Debbie Ortiz. West Zone Archeologist, U.S. Forest Service, Mt. Hood National Forest, Zigzag 

and Clackamas Ranger Districts. Education: B.A. in Anthropology; M.A. in Anthropology, 

emphasis in Archaeology. Experience: Archaeological survey, compiling Section 106, and NEPA 

compliance reports with the Forest Service since 2008.

Todd Parker. Westside Zone Hydrologist, U.S. Forest Service, Mt. Hood National Forest, Zigzag 

and Clackamas Ranger Districts. Education: B.S. in Forest Management, B.S. in Business 

Management, emphasis in Finance. Experience: Hydrologist on the Columbia Gorge and Zigzag 

Ranger Districts since 1992.

Todd Reinwald. Soil and Water Program Manager, U.S. Forest Service, Mt. Hood National 

Forest, Supervisor’s Office. Education: A.S. in Forest Management, B.S. in Soil Science. 

Experience: Forest Service 1987 to 1997, Environmental Consultant 1997 to 2006, Oregon 

Department of Forestry 2006 to 2009, and Forest Service 2009 to present.

Patricia Snyder. Land Adjustment Program Manager, U.S. Forest Service, Pacific Northwest 

Regional Office. Education: AOS Marketing Management and AOS Business Administration; 

Multiple International Right-of-Way Association and continuing realty education courses. 

Experience: 36 years of experience as a Title Examiner, Commercial Title Officer, Right-of-Way 

Agent, Land Law Examiner and Realty Specialist. Specialized experience with the ALTA US 

Policy – Department of Justice Land Title Standards for Federal land acquisitions, title and risk 

analysis.
Draft Environmental Impact Statement

Chapter 4 – Preparers and Contributors

Mt Hood National Forest

369

Kathryn Strawn. Geospatial Systems Specialist, U.S. Forest Service, Pacific Northwest 

Regional Office, Data Resource Management. Education: B.S. Political Science, emphasis in 

public administration and international relations; MEM Environmental Management, emphasis in 

advanced spatial modeling. Experience: Geospatial data analysis and geospatial systems 

management since 2011.

Alexandra Wenzl. Historian and Tribal Relations Advisor, U.S. Forest Service, Mt. Hood 

National Forest, Supervisor’s Office. Education: B.A. in Art, emphasis in Art History; M.S. in 

Historic Preservation. Experience: Manager of Heritage Program from 2010 to present involving 

environmental compliance for a complex cultural resources program including over 2,000 sites, a 

National Historic Landmark, a National Historic Trail, and numerous historic districts. Historic 

Site Management including interpretive program development, volunteer management and 

restoration program management from 2003 to 2010. Additional work in the preservation trades 

with historic window restoration and masonry with a specialization in stonework from 1995 to 

2003.

Distribution List for DEIS

This DEIS will be distributed to individuals and organizations that responded throughout this 

process, as well as Federal agencies, federally recognized tribes, State and local governments, and 

key partners. These organizations and agencies are listed below. Also, the mailing list includes 

several individuals that are not listed here. The complete mailing list is maintained in the project 

record, available at the Supervisor’s Office in Sandy, Oregon.

Advisory Council on Historic Preservation

Bark

Bureau of Indian Affairs

Chief of Naval Operations

Clackamas County Board of Commissioners

Clackamas County Planning Department

Collins Lake Resort

Confederated Tribes of Warm Springs

Confederated Tribes of Grand Ronde

Cooper Spur Wild and Free Coalition

Crag Law Center

Department of Energy

Environmental Protection Agency, Office of 

Federal Activities

Environmental Protection Agency, Region 10

Federal Aviation Administration

Federal Highway Administration

Friends of Mt. Hood

Government Camp Community Planning 

Organization

Government Camp Water Company

Hood River Collaborative Stewardship 

Group

Hood River County Board of Commissioners

Hood River County Planning Department

Hood River Valley Residents Committee 

Hoodland Fire District #74

Lower Columbia Canoe Club

Mazamas

Mt. Hood Meadows

Mt. Hood Skibowl

Mt. Hood Ski Patrol
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

370

National Agricultural Library

National Marine Fisheries Service

National Park Service

Natural Resources Conservation Service

North Willamette Watershed District

Northwest Environmental Defense Center

Northwest Power Planning Council 

Oregon Chapter Sierra Club

Oregon Department of Fish and Wildlife

Oregon Department of Transportation

Oregon Nordic Club

Oregon Wild

Portland Water Bureau

Rhododendron Community Planning 

Organization

Timberline Lodge

U.S. Army Corps of Engineers

U.S. Coast Guard

U.S. Environmental Protection Agency

U.S .Fish and Wildlife Service

USDA APHIS PPD/EAD

USDI, Office of Environmental Policy and 

Compliance

Western Lands Project 
Draft Environmental Impact Statement

Chapter 5 – References

Mt Hood National Forest

371

Chapter 5 – References

Botany

Botany surveys for Timberline downhill mountain bike park. 2010-2011. David Lebo, Westside 

Zone Botanist, Mt. Hood National Forest.

Castellano, M.A., J.E. Smith, T. O’Dell, E. Cazares, and S. Nugent. 1999. Handbook to Strategy 1 

Fungal Species in the Northwest Forest Plan. USDA Forest Service, Pacific Northwest 

Research Station, General Technical Report, PNW-GTR-476, 205 pp.

Castellano, M.A., E. Cazares, B. Fondrick, and T. Dreisbach. 2003. Handbook to Additional 

Fungal Species of Special Concern in the Northwest Forest Plan. USDA Forest Service, 

Pacific Northwest Research Station, General Technical Report, PNW-GTR-572, 152 pp.

Diaz, N.M., C.T. High, T.K. Mellen, D.E. Smith, and C. Topik. 1997. Plant association and 

management guide for the mountain hemlock zone. Gifford Pinchot and Mt. Hood 

National Forests. R6-MTH-GP-TP-08-95. Portland, OR: USDA Forest Service, Pacific 

Northwest Region, 141 pp.

EMS TRANSMISSION – 06/19/2014, Instruction Memorandum No. OR-2014-037, Additional 

Direction Regarding the Survey and Manage Mitigation Measure as a Result of Court 

Ruling in Conservation Northwest et al. v. Bonnie et al., Case No. 08-1067-JCC (W.D. 

Wash.), United States Department of the Interior, Bureau of Land Management, Oregon 

State Office, Portland, OR, June 13, 2014.

Franklin, J.F. and C.T. Dyrness. 1988. Natural Vegetation of Oregon and Washington. Corvallis: 

Oregon State University Press. 452 pp. 

Gradient Nearest Neighbor (GNN) Analysis dataset. Provided by the LEMMA (Landscape 

Ecology, Monitoring, Mapping and Analysis) team, comprised of employees of the 

USDA Forest Service, Pacific Northwest Research Station, and the Department of Forest 

Ecosystems and Society at Oregon State University. GNN data for the Government 

Camp-Cooper Spur land exchange parcels retrieved and analyzed by hydrologist Todd 

Parker, Mt. Hood National Forest.

Hall, F.C. 1998. Pacific Northwest eco-class codes for seral and potential natural communities. 

USDA Forest Service, Pacific Northwest Research Station. General Technical Report 

PNW-GTR-418.

Hemstrom, M.A., W.H. Emmingham, N.M. Halverson, S.E. Logan, and C. Topik. 1982. Plant 

association and management guide for the Pacific silver fir zone, Mt. Hood and 

Willamette National Forests. USDA Forest Service, Pacific Northwest Region, R6-

ECOL-100-1982a.

McCain, C. and N. Diaz. 2002. Field guide to the forested plant associations of the westside 

central Cascades of Northwest Oregon. USDA Forest Service, Pacific Northwest Region, 

Technical Paper R6-NR-ECOL-TP-02-02.

Moerman, D.E. 1998. Native American Ethnobotany. Portland: Timber Press. 927 pp.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

372

Non-Native Invasive Species Best Management Practices: Guidance for the U.S. Forest Service 

Eastern Region. 2012. USDA Forest Service. 

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5412628.pdf

NRIS TESP database. Natural Resource Information System – Threatened, Endangered, and 

Sensitive Plants. USDA Forest Service.

Northwest Ecosystem Alliance v. Rey, No. 04-844-MJP. Survey and Manage Mitigation Measure 

(Pechman Exemptions). Oct. 10, 2006. 

Nugent, S. 2016. Hood River Ranger District botanist, Mt. Hood National Forest. Personal 

communication.

Pauly, D. 1995. Anecdotes and the shifting baseline syndrome of fisheries. Tree 10 (10): 430.

Simpson, M. 2007. Forested plant associations of the Oregon East Cascades. USDA-Forest 

Service. Pacific Northwest Region. Technical Paper R6-NR-ECOL-TP-03-2007.

Simpson, M. 2014. U.S. Forest Service ecologist, Ochoco National Forest. Personal 

communication.

Topik, C., N.M. Halverson, and T. High. 1988. Plant association and management guide for the 

ponderosa pine, Douglas-fir, and grand fir zones. USDA Forest Service, Pacific 

Northwest Region, R6-ECOL-TP-004-88.

Trappe, J.M., R. Molina, D.L. Luoma, E. Cazares, D. Pilz, J.E. Smith, M.A. Castellano, S.L. 

Miller, and M.J. Trappe. 2009. Diversity, Ecology, and Conservation of Truffle Fungi in 

Forests of the Pacific Northwest. USDA Forest Service, Pacific Northwest Research 

Station, General Technical Report, PNW-GTR-772, 202 p. 

USDA Forest Service. 1990. Land and Resource Management Plan – Mt. Hood National Forest. 

Pacific Northwest Region.

USDA Forest Service. 1995. Zigzag Watershed Analysis. 1995. Mt. Hood National Forest. 

Hardcopy on file at the Zigzag Ranger Station. No digital copy is available.

USDA Forest Service. 2005a. Pacific Northwest Region Invasive Plant Program: Preventing and 

Managing Invasive Plants. April 2005. Final Environmental Impact Statement - Record 

of Decision and Volumes 1, 2, and 3. Pacific Northwest Region, R6-NR-FHP-PR-02-05. 

Available online at: 

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprd3812803.pdf

USDA Forest Service. 2005b. Timberline Express Proposal, Final Environmental Impact 

Statement, Mt. Hood National Forest. Pacific Northwest Region. 

USDA Forest Service. 2008. Site-Specific Invasive Plant Treatments for Mt. Hood National 

Forest and Columbia River Gorge National Scenic Area in Oregon, including Forest Plan 

Amendment #16. Available online at: http://data.ecosystemmanagement.org/nepaweb/nepa_project_exp.php?project=12218

USDA Forest Service and USDI Bureau of Land Management (BLM). 2001. Record of Decision 

and Standards and Guidelines for Amendments to the Survey and Manage, Protection 
Draft Environmental Impact Statement

Chapter 5 – References

Mt Hood National Forest

373

Buffer, and other Mitigation Measures Standards and Guidelines. January 2001. Portland, 

Oregon.

USDA-NRCS Plant Guide – Black Huckleberry. Available online at: 

https://plants.usda.gov/plantguide/pdf/cs_vame.pdf

USDA-NRCS Plant Guide – Red Huckleberry. Available online at: 

https://plants.usda.gov/plantguide/pdf/cs_vapa.pdf

Van Norman, K. and R. Huff. 2012. Survey and Manage Category B Fungi Equivalent-Effort 

Survey Protocol. Version 1.0. USDA Forest Service Region 6, Oregon and Washington; 

USDI Bureau of Land Management, Oregon, Washington, and California; and USDA 

Forest Service Region 5, California.

Vogt, K.A., J. Bloomfield, J.F. Ammirati, and S.R. Ammirati. 1992. Sporocarp production by 

basidiomycetes with an emphasis on forest ecosystems. In Carroll, G.C. and D.T. 

Wicklow (eds.) The Fungal Community: Its Organization and Role in the Ecosystem, 2nd

ed., pp. 563-581.

Yellow (Common) Toadflax Fact Sheet. Alberta Invasive Species Council. Available online at: 

https://www.abinvasives.ca/factsheets/140514-fs-commontoadflax.pdf

Climate Change

CEQ. 2016. Memorandum for Heads of Federal Departments and Agencies. Final Guidance for 

Federal Departments and Agencies on Consideration of Greenhouse Gas Emissions and 

the Effects of Climate Change in National Environmental Policy Act Reviews. 34 pp. 

IPCC. 2000. Intergovernmental Panel on Climate Change (IPCC), Special Report on Land Use, 

Land Use Change and Forestry, Summary for Policy Makers, 2000. IPCC, Geneva, 

Switzerland. 20 pp. Available online at: 

http://www.ipcc.ch/ipccreports/sres/land_use/index.php?idp=0

IPCC. 2013. Climate Change 2013: The Physical Science Basis. Contribution of Working Group I 

to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change. 

Stocker, T.F., D. Qin, G.-K. Plattner, M. Tignor, S.K. Allen, J. Boschung, A. Nauels, Y. 

Xia, V. Bex and P.M. Midgley (eds.). Cambridge University Press, Cambridge, United 

Kingdom and New York, NY, USA, 1535 pp. Available online at: 

http://www.ipcc.ch/report/ar5/wg1/

IPCC. 2014. Climate Change 2014: Synthesis Report. Contribution of Working Groups I, II and 

III to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change. 

Core Writing Team, R.K. Pachauri and L.A. Meyer (eds.). IPCC, Geneva, Switzerland, 

151 pp. Available online at: http://www.ipcc.ch/report/ar5/syr/

Cultural Resources and Treaty Rights

Burtchard, G.C. and R.W. Keeler. 1991. A consideration of prehistoric and historic land-use and 

cultural resource survey design reevaluation Mt. Hood National Forest, Oregon. 

Laboratory of Archaeology and Anthropology, Portland State University. Portland, OR.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

374

French, K.; Hajda, Y.; Moore, R.; Ellis, D.V. 1995. An ethnographic study of the Mt Hood 

National Forest, Oregon. Report No. 86, Archaeological Investigations Northwest, Inc., 

Portland, OR.

Grauer, J. 1975. Mount Hood, a complete history. Self-published.

Facilities

Accessibility. Missoula Technology and Development Center, 20 Oct. 2009. Web. 26 July 2016. 

Available online at: http://fsweb.mtdc.wo.fs.fed.us/toolbox/exs/index.htm.

Americans with Disabilities Act and Architectural Barriers Act Accessibility Guidelines. United 

States Access Board. 23 July 2004. Web. 26 July 2016.

Cooper Spur Resort Property Condition Survey. USDA Mt. Hood National Forest. March 2012.

Facilities Masterplan. USDA Forest Service, Mt. Hood National Forest. March 2015.

Facilities Toolbox. Missoula Technology and Development Center, 19 Sept. 2014. Web. 26 July 

2016. Available online at: http://fsweb.mtdc.wo.fs.fed.us/toolbox/exs/index.htm.

Public Law 109-54 Sec. 501. 2005.

RSMeans Repair and Remodeling Cost Data. 23rd Edition, RSMeans Company, Inc. 2002.

Fisheries

Anderson, N.H. 1976. Distribution and ecology of Oregon trichoptera. Technical Bulletin #134, 

Agricultural Experiment Station, Oregon State University, Corvallis. 152 p.

Berg, T. and T.G. Northcote. 1985. Changes in territorial, gill-flaring, and feeding behavior in 

juvenile coho salmon (Oncorhynchus kisutch) following short-term pulses of suspended 

sediment.

Borgias, D. and R.W. Wisseman. 1999. Report on the 1998 and 1999 survey for Rhyacophila 

colonus, in forested torrents near O’Brien, Oregon.

Buffington, J.M., T.E. Lisle, R.D. Woodsmith, and S. Hilton. 2002. Controls on the size and 

occurrence of pools in coarse-grained forest rivers. River Research and Applications 18: 

507–531.

Cordone, A.J. and D.W. Kelley. 1961. The influences of inorganic sediment on the aquatic life of 

streams. California Fish and Game 47 (2): 189–228.

EPA (U.S. Environmental Protection Agency). 1995. Controlling nonpoint source runoff pollution 

from roads, highways and bridges. Office of Water (EPA-841-F-95-008a).

Everest, F.H.; [and others]. 1987. Fine sediment and salmonid production: A paradox. In: 

Streamside management: Forestry and fishery interactions. Salo, E.; Cundy, T.; editors. 

University of Washington, Seattle. p. 98–142. 
Draft Environmental Impact Statement

Chapter 5 – References

Mt Hood National Forest

375

Frest, T.J. and E.J. Johannes. 1995. Interior Columbia Basin mollusk species of special concern. 

Final report: Interior Columbia Basin Ecosystem Management Project, Walla Walla, WA. 

Contract #43-0E00-4-9112. 274 p. plus appendices. 

Furnish, J.L. and R.W. Monthey. 1998. Draft management recommendations for ROD mollusk 

species associated with springs and spring runs: Fluminicola new species 2, 3, 11, 19; 

Vorticifex new species 1, Vorticifex klamathensis sinitsini; Juga (Oreobasis) new species 

2; and Lyogyrus new species 1 and 3. v. 2.0

Hicks, B.J., J.D. Hall, P.A. Bisson, and J.R. Sedell. 1991. Response of salmonid populations to 

habitat changes caused by timber harvest. (Pages 438–518) In: Meehan, W.R.; editor. 

Influence of forest and rangeland management on salmonid fishes and their habitats. 

American Fisheries Society Special Publication 19, Bethesda, MD.

Lloyd, D.S., J.P. Koenings, and D. LaPerriere. 1987. Effects of turbidity in fresh waters of Alaska.

North American Journal of Fisheries Management 7: 18–33.

Montgomery, D.R., J.M. Buffington, R.D. Smith, K.M. Schmidt, and G. Pess. 1995. Pool spacing 

in forest channels. Water Resources Research. 31: 1097–1105.

NOAA (National Oceanic and Atmospheric Administration) Fisheries. 2006. Historical 

Population structure of Pacific salmonids in the Willamette River and Lower Columbia 

River Basins. NOAA Technical Memorandum NMFS-NWFSC-73. February.

NOAA Fisheries. 2013. ESA recovery plan for Lower Columbia River coho salmon, Lower 

Columbia River Chinook salmon, Columbia River chum salmon, and Lower Columbia 

River steelhead.

Nehlsen, W., J.E. Williams, and J.A. Lichatowich. 1991. Pacific salmon at the crossroads: Stocks 

at risk from California, Oregon, Idaho, and Washington. Fisheries 16(2): 4-2.

Noggle, C.C. 1978. Behavioral, physiological and lethal effects of suspended sediment on 

juvenile salmonids. MS Thesis, University of Washington, Seattle.

Oregon Department of Fish and Wildlife (ODFW). 1997. Sandy River management plan. 

Portland, OR. 

ODFW. 2002. Draft Sandy Subbasin summary. Prepared for the Northwest Power Planning 

Council (May 17, 2002).

Oregon Department of Fish and Wildlife (ODFW) and Confederated Tribes of the Warm Springs 

Reservation of Oregon (CTWSRO). 1990. Hood River subbasin salmon and steelhead 

production plan. Columbia Basin System Planning Report to the Northwest Power 

Planning Council, Portland, Oregon.

Oregon, State of. 1994. Oregon forest practices technical note number 1. Water classification. 

[Effective April 11, 1994; retrieved on July 22, 2016 from: 

https://www.oregon.gov/ODF/Documents/WorkingForests/WaterClassificationTechNote1

.pdf].

Parker, T. 2011. Hydrology report for Timberline Mountain Bike Park EA. USDA Forest Service, 

Mt. Hood National Forest, Zigzag, OR. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

376

Sandy River Basin Partners (SRBP). 2005. Sandy River Basin habitat characterization report. 

Portland, OR. [http://www.sandyriverpartners.org/pdfs/SRBCR7-20-05.pdf].

Spellman, F.R. 2008. The science of water: concepts and applications. Taylor and Francis Group, 

LLC, Boca Raton, FL. 422 pp.

Taylor, B. 1998. Salmon and steelhead runs and related events of the Sandy River Basin–A 

historical perspective. Prepared for Portland General Electric.

USDA (U. S. Department of Agriculture). 1994. Record of decision for amendments to Forest 

Service and Bureau of Land Management planning documents within the range of the 

northern spotted owl. Standards and guidelines, USDA Forest Service and USDI Bureau 

of Land Management.

USDA Forest Service. [no date]. Unpublished presence data for Region 6 sensitive aquatic 

species on the Mt. Hood National Forest. Mt. Hood National Forest, Zigzag, OR.

USDA Forest Service. 1991. Laural Hill upper chute parking lot issues and concerns soils, 

watershed and fisheries. Mt. Hood National Forest, Zigzag, OR. 

USDA Forest Service. 1992. Stream survey report for Camp Creek. Mt. Hood National Forest, 

Sandy, OR.

USDA Forest Service. 1995. Zigzag watershed analysis. Mt. Hood National Forest, Sandy, OR. 

USDA Forest Service. 2000. Stream survey report for Little Zigzag River. Mt. Hood National 

Forest, Sandy, OR.

USDA Forest Service. 2004. Zigzag River watershed analysis revision. Mt. Hood National Forest.

USDA Forest Service. 2005. Environmental impact statement for the Timberline Express

proposal. Prepared for USDA Forest Service, Region 6 and USDI Bureau of Land 

Management Interagency Special Status/Sensitive Species (ISSSSP) Coordinator. Mt. 

Hood National Forest, Zigzag Ranger District, Zigzag, OR. 

USDA Forest Service [and others]. 2005. Analytical process for developing biological 

assessments for Federal actions affecting fish within the Northwest Forest Plan Area.

USDA Forest Service. 2011. Stream survey report for Camp Creek. Mt. Hood National Forest, 

Sandy, OR. 

USDA Forest Service [and others]. 2013. Fish habitat restoration activities affecting ESA-listed 

animal and plant species and their designated or proposed critical habitat and designated 

essential fish habitat under MSA found in Oregon, Washington and parts of California, 

Idaho and Nevada.

Wanner, G. and K. Arendt. 2015. Caddisfly survey around Mt. Hood: Search for Scott’s apatanian 

and other sensitive caddisfly species. Mt. Hood National Forest, Zigzag, OR.

Waters, T.F. 1995. Sediment in streams: Sources, biological effects and control. American 

Fisheries Society Monograph 7, Bethesda, MD.
Draft Environmental Impact Statement

Chapter 5 – References

Mt Hood National Forest

377

Wiggins, G.B. 1973. Contributions to the systematics of the caddisfly family Limnephilidae 

(Trichoptera). I. Life Sciences Contributions Royal Ontario Museum No. 94. 32 pp.

Wissman, B. 2010. Survey for sensitive aquatic invertebrate species in tributaries of Still Creek 

and the West Fork Salmon River in the vicinity of proposed mountain bike trails for the 

Timberline Lodge Winter Sports Area, Mt. Hood, Mt. Hood National Forest, Oregon. 

August 9–10, 2010.

Links to websites

Oregon Department of Environmental Quality (ODEQ). 2016. Enforcement database query 

results for Government Camp sanitary sewer. Retrieved on 8/8/2016 from 

http://www.oregon.gov/deq/nr/012216govcampE.pdf

Oregon Department of Environment Quality (ODEQ) 2016. Notice of civil penalty assessment 

and order case no: WQ/M-NWR-15-208p. 

http://www.oregon.gov/deq/nr/012216govcampE.pdf

Oregon Natural Heritage Program. 2005. Scott’s apatanian caddisfly, Allomyia scottia. (Publisher 

unknown).

NOAA National Marine Fisheries Service. 2016. Salmon recovery trend summaries. Retrieved 

July 7, 2016, from http://www.nwfsc.noaa.gov/trt/pubs_esu_trend.cfm

NOAA National Marine Fisheries Service. 2016a. Water quality: How toxic runoff affects Pacific 

salmon and steelhead. Retrieved July 14, 2015, from 

http://www.westcoast.fisheries.noaa.gov/publications/habitat/fact_sheets/stormwater_fact

_sheet_3.22.2016.pdf

NOAA National Marine Fisheries Service. 2016b. ArCGIS Critical Habitat Mapping Tool. 

Retrieved July 6, 2016, from: 

https://www.arcgis.com/home/webmap/viewer.html?webmap=9d8de5e265ad4fe09893cf7

5b8dbfb77

U.S. Fish and Wildlife Service (USFWS). 2010. Species fact sheet. Coastal cutthroat trout. 

Retrieved from 

http://www.fws.gov/wafwo/species/Fact%20sheets/CoastalCutthroatTrout.pdf

Personal Communication 

Ballard, B. 2016. U.S. Forest Service, Hood River Ranger District and Barlow Ranger District 

Road Engineer. Personal communication; August 2016.

French, R. 2015. Oregon Department of Fish and Wildlife, Mid-Columbia District Biologist. 

Personal communication; October 16.

Hydrology and Water Rights

AREMP 2016. AREMP Attribute Documentation for the WCF 2016 Assessment

Bjorn, T.C. and D.W. Reiser. 1991. In W. R. Meehan editor, Influences of forest and rangeland 

practices on: salmonid fishes and their habitats. Am. Fish. S. Spec. Pub. No. 19. pp. 83-

138
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

378

Boyd, M. and B. Kasper. 2003. Analytical methods for dynamic open channel heat and mass 

transfer: Methodology for heat source model Version 7.0.

Castro, J. 2003. Geomorphologic Impacts of Culvert Replacement and Removal: Avoiding 

Channel Incision. USFWS – Oregon Fish and Wildlife Office, Portland, OR, February 

2003 – Version 2.0

Cooper, R.M. 2002. Determining Surface Water Availability in Oregon. State of Oregon Water 

Resources Department Open File Report SW 02-002

DeRoo, T. July 26, 2004. U. S. Forest Service, Mt. Hood National Forest, Forest Geologist. On 

geology of the Timberline Study Area and the implications to surface and subsurface 

hydrology

DNR. 2011. Washington Department of Natural Resources Watershed Analysis Manual, 

APPENDIX B Surface Erosion Module, Version 5.0, May 2011

DNR. 2011a. Washington Department of Natural Resources Watershed Analysis Manual, 

APPENDIX G Water Quality Module, Version 5.0, May 2011

DNR. 2011b. Washington Department of Natural Resources Watershed Analysis Manual, 

APPENDIX A Mass Wasting Module, Version 5.0, May 2011

Dubé, K., W.F. Megahan, M. McCalmon. 2004. Washington Road Surface Erosion Module. State 

of Washington Department of Natural Resources.

Elliot, W.J., D.E. Hall and D.L. Scheele. 2000. Disturbed WEPP (Draft 02/2000); WEPP Interface 

for Disturbed Forest and Range; Runoff, Erosion and Sediment Delivery; Technical 

Documentation: U.S. Department of Agriculture, Forest Service, Rocky Mountain 

Research Station.

FERC (Federal Energy Regulatory Commission). 2006. Final Environmental Impact Statement 

(FEIS) Clackamas River Hydroelectric Project; Clackamas County, Oregon; FERC 

Project No. 2195

Gallino G.L. and T.C. Pierson. 1985. Polallie Creek Debris Flow and Subsequent Dam-Break 

Flood of 1980, East Fork Hood River Basin, Oregon. U.S. Geological Survey WaterSupply Paper 2273

Golder Associates Inc. 2010. Timberline Ski Area Annual Report Water Year 2009.

Grant, G.E., S.L. Lewis, F.J. Swanson, J.H. Cissel, and J.J. McDonnell. 2008. Effects of forest 

practices on peak flows and consequent channel response: a state-of-science report for 

western Oregon and Washington. Gen. Tech. Rep. PNW-GTR-760. Portland, OR: U.S. 

Department of Agriculture, Forest Service, Pacific Northwest Research Station. 76 pp.

Hawkins, R.H. and A. Barreto-Munoz. 2016. Wildcat5 for Windows, a rainfall-runoff hydrograph 

model: user manual and documentation. Gen. Tech. Rep. RMRS-334. Fort Collins, CO: 

U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. 68 

pp.
Draft Environmental Impact Statement

Chapter 5 – References

Mt Hood National Forest

379

Hubler, S. 2008. PREDATOR: Development and use of RIVPACS-type macroinvertebrate 

models to assess the biotic condition of wadeable Oregon streams (November 2005 

models). State of Oregon Department of Environmental Quality.

LaMarche, J.L. and D.P. Lettenmaier. 2001. Effects of Forest Roads on Flood Flows in the 

Deschutes River, Washington. Earth Surface Processes and Landforms. 26: 115-134.

Lanigan, S.H. and S.N. Gordon. 2012. A comparison of the U.S. Forest Service national 

watershed condition classification system to the Northwest Forest Plan watershed 

monitoring results. Northwest Forest Plan Aquatic Riparian Effectiveness Monitoring 

Program (AREMP). 

http://www.reo.gov/monitoring/reports/watershed/WCC%20vs%20Aremp%20white%20

paper.pdf

MacDonald, L.H., A.W. Smart, and R.C. Wissmar. 1991. Monitoring guidelines to evaluate 

effects of forestry activities on streams in the Pacific Northwest and Alaska. United States 

Environmental Protection Agency, Region 10.

Miller, S. 2015. Northwest Forest Plan Interagency Regional Monitoring, 20-Year Report Status 

and Trend of Watershed Condition. Aquatic and Riparian Effectiveness Monitoring 

Program (AREMP). Briefing Paper. DRAFT 5/14/2015.

Miller, S.A., S.N. Gordon, P. Eldred, R.M. Beloin, S. Wilcox, M. Raggon, H. Andersen, and A. 

Muldoon. 2015. Northwest Forest Plan - The First 20 Years (1994-2013): Watershed 

Condition Status and Trend. Portland OR: USDA Forest Service, Pacific Northwest 

Research Station. Available online at: http://www.reo.gov/monitoring/reports/20yrreport/.

Moody, J.A. and D.A. Martin. 2009. Synthesis of sediment yields after wildland fire in different 

rainfall regimes in the western United States. International Journal of Wildland Fire, v. 

18 no. 1, pp. 96-115

National Marine Fisheries Service (NMFS). 1996. Making Endangered Species Act 

determinations of effect for individual or grouped actions at the watershed scale. The 

National Marine Fisheries Service, Environmental Technical Services Division, Habitat 

Conservation Branch, Seattle, WA

NMFS. 2011. Endangered Species Act Programmatic Biological Opinion and Magnuson-Stevens 

ishery Conservation and Management Act Essential Fish Habitat Conservation 

Recommendations for the Programmatic Activities of USDA Forest Service, USDI 

Bureau of Land Management, and Coquille Indian Tribe in Western Oregon

NetMap Tools ArcMap 10.x Add-in, Technical Help Guide.

Oregon Department of Environmental Quality. 2005. Sandy River Basin Total Maximum Daily 

Load 

Oregon Department of Environmental Quality. 2008. Fact Sheet and NPDES Wastewater 

Discharge Permit Evaluation Government Camp Sanitary District.

Oregon Department of State Lands. 2007. Wetland Delineation Report for 80 Acre Parcel north of 

Government Camp Loop Road and west of Alpen Way and 40 Acre Parcel north of Liege 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

380

Lane and east of Camp Creek Trail, Government Camp, Clackamas County; T 38, R SE, 

Sec. 13, Tax Lot 160; T 38, R 8.SE, Sec.18, Tax Lot 130 (portion); WD #06-0595

Oregon Public Utility Commission. 2002. ORDER NO. 02-287 In the Matter of the Application 

by Government Camp Water Company for Allocation of Exclusive Territory to Provide 

Water Service, Pursuant to ORS 758.300 Through ORS 758.32.

https://apps.puc.state.or.us/orders/2002ords/02-287.pdf 

Oregon Public Utility Commission. 2012. Government Camp Water Company Incorporated 

Water Utility Annual Report C for the year ending December 31, 2011.

Oregon Public Utility Commission. 2016. Government Camp Water Company Incorporated 

Water Utility Annual Report C for the year ending December 31, 2015.

http://edocs.puc.state.or.us/efdocs/HAQ/rw39haq10381.pdf

Oregon Water Resources Department. 2014. Oregon Water Right Points of Diversion. File 

Geodatabase Feature Class.

Reeves, G.H., B.R. Pickard, N. K. Johnson. 2016. An initial evaluation of potential options for 

managing riparian reserves of the Aquatic Conservation Strategy of the Northwest Forest 

Plan. Gen. Tech. Rep. PNW-GTR-937. Portland, OR: U.S. Department of Agriculture, 

Forest Service, Pacific Northwest Research Station. 97 pp.

Renschler .S. and W.J. Elliot. 2006. Cumulative Watershed Effects Analysis with the Geospatial 

Interface for the Water Erosion Prediction Project (GEOWEPP) Abstract Only.

Proceedings of the Eighth Federal Interagency Sedimentation Conference (8th FISC), 

April 2-6, 2006, Reno, NV, USA.

Reinwald, T. July 8, 2016. U. S. Forest Service, Mt. Hood National Forest, Watershed Program 

Manager. On geology and spring sites in the headwaters of Camp Creek.

Robichaud, .R. and R. E. Brown. 2005. Postfire Rehabilitation Treatments: Are We Learning 

What Works? Proceedings of the 2005 Watershed Management Conference

Rosgen, D. 1996. Applied River Morphology. Wildland Hydrology Books, Pagosa Springs, 

Colorado.

Shaver, E., R. Horner, J. Skupien, C. May, and G. Ridley. 2007. Fundamentals of Urban Runoff 

Management: Technical and Institutional Issues (Second Edition). North American Lake 

Management Society (NALMS), Madison, Wisconsin. 

Sherrod, D.R. and W.E. Scott. 1995. Preliminary Geologic Map of the Mt. Hood 3D-Minute by 

60-Minute Quadrangle, Northern Cascade Range, Oregon. Open File Report 95-219. U.S. 

Geological Survey

Swanson, F. J. and C. T. Dyrness. 1975. Impact of clear-cutting and road construction on soil 

erosion by landslides in the western Cascade Range, Oregon. Geological Society of 

America

USDA Forest Service. 1984 Camp Creek Stream Survey Report. Mt. Hood National Forest.

USDA Forest Service. 1990. Final Environmental Impact Statement, Land and Resource 

Management Plan, Mt. Hood National Forest. Pacific Northwest Region. 491 pp.
Draft Environmental Impact Statement

Chapter 5 – References

Mt Hood National Forest

381

USDA Forest Service. 1990a. Process Paper, Analysis and Identification of Special Emphasis 

Watersheds for the Mt. Hood National Forest: A Methodology for Addressing Cumulative 

Watershed Effects, Watershed Sensitivity, and Hydrologic Recovery. Mt. Hood National 

Forest. December 1990.

USDA Forest Service. 1992. Little Zigzag River Stream Survey Report, Mt. Hood National 

Forest.

USDA Forest Service. 1993. Forest ecosystem management; and ecological, economic, and social 

assessment. Report of the Forest Ecosystem Management Assessment Team, July 1993. 

Washington, DC: United States Department of Agriculture Forest Service.

USDA Forest Service. 1994. Camp Creek Stream Survey Report, Mt. Hood National Forest.

USDA Forest Service. 1996. East Fork Hood River and Middle Fork Hood River Watershed 

Analyses. Mt. Hood National Forest, Hood River Ranger District.

USDA Forest Service. 1997a. Tilly Jane Creek Stream Survey Report, Mt. Hood National Forest.

USDA Forest Service. 1997b. Doe Creek Stream Survey Report, Mt. Hood National Forest.

USDA Forest Service. 1999. Forest Service and Bureau of Land Management Protocol for 

Addressing Clean Water Act Section 303(d) Listed Waters. Available online at:

http://www.fs.fed.us/r6/water/protocol.pdf

USDA Forest Service. 2003. Roads Analysis, Mt. Hood National Forest.

USDA Forest Service. 2005. Timberline Express Draft Environmental Impact Statement, Mt.

Hood National Forest.

USDA Forest Service. 2005a. Government Camp Trails Project Environmental Assessment, Mt.

Hood National Forest, Zigzag Ranger District.

USDA Forest Service, USDI Bureau of Land Management. 2008. Biological Assessment for 

Programmatic Forest Service and Bureau of Land Management Activities in 

Northwestern Oregon. Prepared and Reviewed by: Salem District Bureau of Land 

Management, Eugene District Bureau of Land Management, Mt. Hood National Forest, 

Willamette National Forest, Columbia River Gorge National Scenic Area, Siuslaw 

National Forest. Prepared for Consultation with: National Marine Fisheries Service, U.S. 

Fish and Wildlife Service.

USDA Forest Service. 2011 Camp Creek Stream Survey Report, Mt. Hood National Forest.

USDA Forest Service. 2012. Northwest Forest Plan (NWFP) Temperature TMDL Implementation 

Strategies: Evaluation of the Northwest Forest Plan Aquatic Conservation Strategy (ACS) 

and Associated Tools.

USDA Forest Service 2012a. National Best Management Practices for Water Quality 

Management on National Forest System Lands, Volume 1: National Core BMP Technical 

Guide. FS-990a. April 2012.

USDA Forest Service. 2014. Final Environmental Impact Statement Mt. Hood Meadows Parking 

Improvements, Mt. Hood National Forest, Hood River Ranger District.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

382

USDA Forest Service 2014a. Memorandum of Understanding between State of Oregon 

Department of Environmental Quality and the USDA Forest Service Pacific Northwest 

Region documenting the U.S. Forest Service and DEQ strategy for managing and 

controlling nonpoint source pollution for U.S. Forest Service managed lands in the State 

of Oregon.

USDA Forest Service. 2016. Polallie Cooper Hazardous Fuels Reduction Draft Environmental 

Assessment, Mt. Hood National Forest, Hood River Ranger District.

USDA Forest Service, USDI Bureau of Land Management. 1994. Record of Decision (ROD) for 

Amendments to Forest Service and Bureau of Land Management Planning Documents 

within the Range of the Northern Spotted Owl. U.S. Government Printing Office.

USDA Forest Service, USDI Bureau of Land Management. 2012. Sufficiency Analysis for 

Stream Temperature: Evaluation of the adequacy of the Northwest Forest Plan Riparian 

Reserves to achieve and maintain stream temperature water quality standards. Portland, 

OR.

Wemple, B.C., J.A. Jones, and G.E. Grant. 1996. Channel Network Extension by Logging Roads 

in Two Basins, Western Cascades, Oregon. Water Resources Bulletin American Water 

Resources Association Vol. 32, No. 6.

Wenzl, Alexandra, July 8, 2016. U. S. Forest Service, Mt. Hood National Forest, Historian. On 

Government Camp Water Companies 100,000 gallon wood tank.

Yinger, M. 2003. Crystal Springs Zone of Contribution. Mark Yinger Associates, Sisters, Oregon. 

Recreation

Thorson, T.D., S.A. Bryce, D.A. Lammers, A.J. Woods, J.M., Omernik, J. Kagan, D.E. Pater, and 

J.A. Comstock. 2003. Ecoregions of Oregon (color poster with map, descriptive text, 

summary tables, and photographs): Reston, Virginia, U.S. Geological Survey (map scale 

1:1,500,000). Available online at: https://www.epa.gov/eco-research/ecoregiondownload-files-state-region-10

USDA Forest Service. 1990. Mt. Hood National Forest Land and Resources Management Plan.

USDA Forest Service. 2003. Washington Office, Draft National Recreation Opportunity 

Spectrum (ROS) Mapping Protocol.

USDA Forest Service. 2005. Environmental Assessment: Government Camp Trails Project, Mt. 

Hood National Forest.

USDA Forest Service. 2012. Cooper Spur Resort Property Condition Survey, Mt. Hood National 

Forest. March 2012

USDA Forest Service. 2015. Recreation Specialist Report for Polallie Cooper Fuels Reduction 

Project, Mt. Hood National Forest, April 2015.

Silviculture

Helms, J.A. 1998. The dictionary of forestry. Soc. Am. For., Bethesda, MD. 1998:210.
Draft Environmental Impact Statement

Chapter 5 – References

Mt Hood National Forest

383

Lebo, D. 2016. Botany Field Notes, Government Camp-Cooper Spur Land Exchange Parcels. Mt. 

Hood National Forest. Unpublished document.

McCain, C., and N. Diaz. 2002. Field guide to the forested plant associations of the Westside 

Central Cascades of northwest Oregon. USDA For. Serv. Pac. NW Region Tech. Pap. R6-

NRECOL-TP-02–02 (2002).

National Forest Management Act (NFMA) of 1976 (P.L. 94-588) Sec 219.27

Northwest Forestry Services. 2016. Timber Cruise Report. Northwest Forestry Service, 11825 

SW Greenburg Road | Suite 200, Tigard, OR 97223.

Olesker, W. 2014. Cooper Spur Area Existing Conditions Report. Mt. Hood National Forest. 

Unpublished document.

U.S. Department of Agriculture Forest Service (USDA Forest Service). 1993. Interim Old Growth 

Definition for Douglas-fir Series, Grand Fir/White Fir Series, Interior Douglas-fir Series, 

Lodgepole Pine Series, Pacific Silver Fir Series, Ponderosa Pine Series, Port-OrfordCedar and Tanoak (Redwood) Series, Subalpine Fir Series, Western Hemlock Series. 

Region 6, Pacific Northwest Region. Available online at: 

http://www.blm.gov/or/plans/surveyandmanage/files/16-region6_old_growth_def.pdf.

U.S. Department of Agriculture Forest Service (USDA Forest Service) and U.S. Department of 

the Interior Bureau of Land Management (USDOI BLM). 1994. Interagency SEIS Team. 

Record of decision for amendments to Forest Service and Bureau of Land Management 

planning documents within the range of the northern spotted owl; Standards and 

guidelines for management of habitat for late-successional and old-growth forest related 

species within the range of the northern spotted owl. [Portland, OR. Interagency SEIS 

Team, April 1994]. Available online at: http://www.blm.gov/or/plans/nwfpnepa/FSEIS1994/FSEIS-1994-I.pdf

Socioeconomics

Asabere, P.K. and F.E. Hoffman. 2009. The relative impacts of trails and greenbelts on home 

price. Journal of Real Estate Finance and Economics 38: 408–419.

Boyd, J. and S. Banzhaf. 2007. What are ecosystem services? The need for standardized 

environmental accounting units. Ecological Economics 61(4): 716–723.

Hjerpe, E., T. Holmes, and E. White. 2016. National and community market contributions of 

wilderness. Society and Natural Resources Available online at: 

http://dx.doi.org/10.1080/08941920.2016.1196280.

Horne, A. and R. Haynes. 1999. Developing measures of socioeconomic resiliency in the Interior 

Columbia Basin. General Technical Report PNW-GTR-453, USDA Forest Service, 

Pacific Northwest Research Station, Portland, OR.

Larson, A. 2013. Oregon update: Migrant and seasonal farmworker enumeration profiles study. 

Larson Assistance Services, Washington [accessed on August 26, 2016; available online 

at: 

https://www.oregon.gov/oha/oei/reports/Migrant%20and%20Seasonal%20Farmworker%

20Enumeration%20Profiles%20Study.pdf].
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

384

McGranahan, D.A. 1999. Natural amenities drive rural popualion change. Agricultural Economic 

Report No. 781, USDA Food and Rural Economics Divisions, Economic Research 

Service.

Office of Management and Budget. 2015. Bulletin no. 15-01 

[https://www.whitehouse.gov/sites/default/files/omb/bulletins/2015/15-01.pdf].

Parent, O. and R. vom Hofe. 2013. Understanding the impact of trails on residential property 

values in the presence of spatial dependence. The Annals of Regional Science 51(2): 355–

375.

Seesholtz, D., D. Wickwar, and J. Russell. 2006. Social economic profile technical guide. USDA 

Forest Service, Inventory Monitoring Institute.

U.S. Census Bureau. 2000. 2000 census [accessed on July 6, 2016; http://factfinder.census.gov].

U.S. Census Bureau. 2010. 2010 census [accessed on July 6, 2016, http://factfinder.census.gov].

U.S. Census Bureau. 2016. American community survey, 2006 –2014 5-Year Estimates [accessed 

July 1, 2016; factfinder.census.gov].

U.S. Department of Agriculture. 1997. Environmental justice departmental regulation. Office of 

the Chief Information Officer, Washington, D.C.

U.S. Department of the Interior. 2016. Payment in lieu of taxes: PILT acres by agency and total 

acres and total payments by state/county [accesse July, 26, 2016; 

[https://www.nbc.gov/pilt/counties.cfm].

USDA Forest Service. 1990. Land and resource management plan: Mt. Hood National Forest. 

Pacific Northwest Region [accessed on August 26, 2016; 

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprd3841035.pdf].

USDA Forest Service. 2012. Cooper Spur Resort property condition survey. Mt. Hood National 

Forest and Affiliated Western Inc. March.

USDA Forest Service. 2016a. All service receipts final payment detail report PNF (ASR-10-03)

[accessed on July 26, 2016; 

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd494970.pdf].

USDA Forest Service. 2016b. Visitor use report Mt. Hood NF national visitor use monitoring data 

collected FY 2011 [accessed on August 25, 2016; 

http://apps.fs.fed.us/nfs/nrm/nvum/results/ReportCache/Rnd3_A06006_Master_Report.p

df].

USDA Forest Service. 2016c. National Forest recreation economic contributions [accessed on 

August 30, 2016; publically available version at: 

http://www.fs.fed.us/emc/economics/recreation-contributions/single-reports.shtml.]
Draft Environmental Impact Statement

Chapter 5 – References

Mt Hood National Forest

385

Soils and Wetlands

Oregon Water Resources Department (OWRD). 2002. Water Rights in Oregon. An Introduction to 

Oregon’s Water Law and Water Rights System. Oregon Water Resources Department. 

Salem, Oregon. November 2002.

OWRD. 2016. Water Rights Information System. Oregon Water Resources Department. Salem, 

Oregon. Available online at http://www.oregon.gov/owrd/pages/WR/wris.aspx

OWRD. 2016a. Water Right Transfers and Real Property Transactions. Oregon Water Resources 

Department. Salem, Oregon. Available online at 

http://www.oregon.gov/owrd/WR/docs/Transfer_Property_Transactions.pdf

U.S. Department of Agriculture (USDA) Forest Service. 1979. Soil Resource Inventory. Mt. 

Hood National Forest, Pacific Northwest Region, Forest Service, USDA.

USDA Forest Service. 1990. Land and Resource Management Plan. Mt. Hood National Forest, 

Pacific Northwest Region, Forest Service, USDA. 

USDA Forest Service and U.S. Department of Interior Bureau of Land Management (BLM). 

1994. Record of Decision for Amendments to Forest Service and Bureau of Land 

Management Planning Documents within the Range of the Northern Spotted Owl. 

Standards and Guidelines for Management of Habitat for Late-Successional and OldGrowth Forest Related Species within the Range of the Northern Spotted Owl. 

USDA/USDI.

USDA Natural Resource Conservation Service (NRCS). 2016. Web Soil Survey. Available online 

at http://websoilsurvey.nrcs.usda.gov/app/HomePage.htm

Watershed Professionals Network (WPN). 2010. Mt. Hood National Forest Land Exchange 

Wetland Inventory. Watershed Professionals Network, LLC. Parkdale, OR.

Visuals

Thorson, T.D., Bryce, S.A., Lammers, D.A., Woods, A.J., Omernik, J.M., Kagan, J., Pater, D.E., 

and Comstock, J.A., 2003. Ecoregions of Oregon (color poster with map, descriptive text, 

summary tables, and photographs): Reston, Virginia, U.S. Geological Survey (map scale 

1:1,500,000). Available online at: https://www.epa.gov/eco-research/ecoregiondownload-files-state-region-10.

USDA. 1974. Forest Service Handbook 462. National Forest Landscape Management, Volume 2:

Chapter 1, Visual Management System

Chapter 4, Roads, Agriculture Handbook 483

Chapter 5, Timber, Agriculture Handbook 559

USDA Forest Service. 1990. Mt. Hood National Forest Land and Resource Management Plan.

USDA Forest Service 2015. Mt. Hood National Forest, Scenery Specialist Report for Polallie 

Cooper Fuels Reduction Project, April 2015. 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

386

Wildlife

Adams, M.J. and R.B. Bury. 2002. The endemic headwater stream amphibians of the American 

Northwest: associations with environmental gradients in a large forested preserve. Global 

Ecology and Biogeography 11:169-178.

Altman, B. 1999. Conservation strategy for landbirds in coniferous forests of western Oregon and 

Washington, version 1.0. Oregon-Washington Partners in Flight. 111 pp. Online at: 

http://cain.ice.ucdavis.edu/prbo/orwapif/pdf/western_forest.pdf. 

Altman, B. 2000. Conservation strategy for landbirds of the east-slope of the Cascade Mountains 

in Oregon and Washington, version 1.0. Oregon-Washington Partners in Flight. 121 pp. 

Online at: http://cain.ice.ucdavis.edu/prbo/orwapif/pdf/east_slope.pdf. 

Andrews, H. 2010. Species fact sheet: Pristiloma arcticum crateris (Lehnert 1884). 4 pp.

Aubry, K.B., K.S. McKelvey, and J.P. Copeland. 2007. Distribution and broadscale habitat 

relations of the wolverine in the contiguous United States. Journal of Wildlife 

Management 71(7):2147-2158.

Buehler, D. A. 2000. Bald Eagle (Haliaeetus leucocephalus). In The Birds of North America, No. 

506 (A. Poole and F. Gill, eds.). The Birds of North America, Inc., Philadelphia, 

Pennsylvania, USA.

Burke, T.E. 2013. Land Snails and Slugs of the Pacific Northwest. Oregon State University Press. 

Corvallis, OR. 344p.

Bury, R. B., C. Barkhurst, R. Horn, L. Todd, S. Wray, R. Goggans, K. Beal, N. Sisk. 2001.

Western Pond Turtle: Survey Protocol and Monitoring Plan. Interagency Western Pond 

Turtle Working Group. Final Draft.

Buskirk, L.J., and L.F. Ruggiero. 1994. Chapter 2 – American marten. Pgs 7-37 In. Ruggiero, 

L.F., K.B. Aubry, S.W. Buskirk, L.J. Lyor, and W.J. Zielinski. (Technical editors). The 

scientific basis for conserving forest carnivores: American marten, fisher, lynx, and 

wolverine in the Western United States. General technical report RM-254. USDA, Forest 

Service, Rocky Mountain Forest and Range Experiment Station, Ft. Collins CO. 184 pp.

Copeland, J.P. K.S. McKelvey, K.B. Aubry, A. Landa, J. Persson, R.M. Inman, J. Krebs, E. 

Lofroth, H. Golden, J.R. Squires, A. Magoun, M.K. Schwartz, J. Wilmot, C.L. Copeland, 

R.E. Yates, I. Kojola, and R. May. 2010. The bioclimatic envelop of the wolverine (Gulo 

gulo): do climatic constraints limit its geographic distribution? Canadian Journal of 

Zoology 88: 233-246.

Copeland, J.P. and R.E. Yates. 2006. Wolverine population assessment in Greater Yellowstone 

Park. Spring 2006 progress report. USDA Forest Service, Rocky Mountain Research 

Station. Missoula, MT. 42 pp.

Corkran, C.C. and C. Thoms. 1996. Amphibians of Oregon, Washington, and British Columbia, a 

field identification guide. Lone Pine Publishing. 175 pp.

Courtney, S.P., J.A. Blakesley, R.E. Bigley, M.L. Cody, J.P. Dumbacher, R.C. Fleischer, A.B. 

Franklin, J.F. Franklin, R.J. Gutierrez, J.M. Marzluff, L. Sztukowski. 2004. Scientific 

Evaluation of the Status of the Northern Spotted Owl (SEI Report). Sustainable 

Ecosystems Institute, Portland OR. September 2004.

Crisafulli, C.M. 1999. Survey Protocol for the Larch Mountain salamander (Plethodon larselli), 

Version 3.0. Chapter VII, pp. 253-310, In: Olson, D.H. (Ed.), Survey protocols for 
Draft Environmental Impact Statement

Chapter 5 – References

Mt Hood National Forest

387

amphibians under the Survey and Manage provision of the Northwest Forest Plan, 

Version 3.0, October 1999. Interagency Publication of the Regional Ecosystem Office, 

Portland, OR. BLM Publ. BLM/OR/WA/PT-00/033+1792, U.S. GPO: 2000-589-

124/04022 Region No. 10, 310 p. 

Crisafulli, C.M., D. Clayton, and D. Olson. 2008. Conservation Assessment for the Larch 

Mountain Salamander. USDA Forest Service Region 6 and USDI Bureau of Land 

Management. 36 pp. http://www.fs.fed.us/r6/sfpnw/issssp/planningdocuments/assessments.shtml.

Csuti, B., A.J. Kimerling, T.A. O’Neil, M.M. Shaughnessy, E.P. Gaines and M.M. P. Huso. 1997.

Atlas of Oregon wildlife: distribution, habitat and natural history. Oregon State 

University Press, Corvallis, OR. 492 pp.

Davis, R. and K. Weaver. 2011. Johnson’s hairstreak surveys in Oregon and Washington (2010). 

Unpublished report. On file with: Interagency Special Status Species Program, USDA 

Forest Service and USDI Bureau of Land Management, Portland, OR. 

http://www.fs.fed.us/r6/sfpnw/issssp/

Davis, R. J. 2008. Pine Marten Habitat Similarity Index Map for the Oregon Cascades (v1.0). GIS 

habitat model.

Dobkin, D.S., R.D. Gettinger, and M.G. Gerdes. 1995. Springtime movements, roost use, and 

foraging activity of Townsend’s big-eared bat (Plecotus townsendii) in central Oregon. 

Great Basin Naturalist 55(4):315-321.

Dugger, K.M., R.G. Anthony and L.S. Andrews. 2011. Transient dynamics of invasive 

competition: barred owls, spotted owls, habitat composition and the demons of 

competition present. Ecological Applications 21(7): 2459-2468.

Duncan, N. 2004. Conservation Assessment for Pristiloma arcticum crateris, Crater Lake 

Tightcoil. USDA Forest Service Region 6 and USDI Bureau of Land Management. 18 pp. 

http://www.fs.fed.us/r6/sfpnw/issssp/planning-documents/assessments.shtml

Duncan, N. 2005. Conservation Assessment for Conservation Assessment for Monadenia fidelis 

minor, Dalles Sideband. USDA Forest Service Region 6 and USDI Bureau of Land 

Management. 14 pp. http://www.fs.fed.us/r6/sfpnw/issssp/planningdocuments/assessments.shtml

Dyck, A. 2010. Personal communication. Alan Dyck, Forest Wildlife Biologist, Mt. Hood 

National Forest. 

Fiedler, P. 1994. Clackamas Drainage Elk Telemetry Study, Completion Report Study 1987-1992. 

A Cooperative Project between ODFW and USDA Forest Service, Mt. Hood National 

Forest. 46 pp.

Foltz, S. 2009. Agonium belleri, Beller’s ground beetle, species fact sheet. Accessed 08/30/2016 

at: http://www.xerces.org/wp-content/uploads/2009/09/sfs-iico-agonum-belleri.pdf

Forsman, E.D., R.G. Anthony, E.C. Meslow and C.J. Zabel. 2004. Diets and Foraging Behavior 

of Northern Spotted Owls in Oregon. Journal of Raptor Research 38: 214-230.

Forsman, E.D., R.G. Anthony, K.M. Dugger, E.M. Glenn, A.B. Franklin, G.C. White, 

C.J.Schwarz, K.P. Burnham, D.R. Anderson, J.D. Nichols, J.E. Hines, J.B. Lint, R.J. 

Davis, S.H. Ackers, L.S. Andrews, B.L. Biswell, P.C. Carlson, L.V. Diller, S.A. Gremel, 

D.R. Herter, J.M. Higley, R.B. Horn, J.A. Reid, J. Rockweit, J. Schaberl, T.J. Snetsinger 
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

388

and S.G. Sovern. 2011. Population demography of northern spotted owls: 1985–2008. 

Studies in Avian Biology. Cooper Ornithological Society.

Foster, A.D. and D.H. Olson. 2014. Conservation Assessment for the Cope’s Giant Salamander. 

USDA Forest Service Region 6 and USDI Bureau of Land Management. 57p. 

http://www.fs.fed.us/r6/sfpnw/issssp/planning-documents/assessments.shtml

Frest, T.J. and E.J. Johannes. 1995. Interior Columbia Basin mollusk species of special concern. 

Final report to the Interior Columbia Basin Ecosystem Management Project, Walla Walla, 

WA. Contract #43-0E00-4-9112. 274 pp. plus appendices.

Frest, T.J. and E. J. Johannes. 2000. Baseline Mollusk Survey of Southwest Oregon (Rogue and 

Umpqua Basins). Deixis Consultants, Seattle, Washington. Oregon Natural Heritage 

Program, Portland Oregon.

Gowan, D. and T.E. Burke. 1999. Conservation Assessment for Pristiloma arcticum crateris, 

Crater Lake Tightcoil. Originally issued as Management Recommendations October 1999 

by Nancy Duncan. Reconfigured by N. Duncan in 2004. USDA Forest Service Region 6 

and ISDI Bureau of Land Management, Oregon and Washington. 18 pp.

Hayes, G. and G. J. Wiles. 2013. Washington bat conservation plan. Washington Department of 

Fish and Wildlife, Olympia, Washington. 138+viii pp.

Hornocker, M.G. and H.S. Hash. 1981. Ecology of the wolverine in northwestern Montana. Can. 

J. Zool. 59(7): 1286–1301.

Huff, R. 2011. Johnson’s hairstreak, species fact sheet. 8 pp.

Huff, R. 2011. Pristiloma wascoense (Hemphill 1911), species fact sheet. 11 pp.

Inman, R.M., A.J. Magoun, J. Persson, D.N. Pedersen, J.Mattisson, and J.K. Bell. 2007. 

Reproductive chronology of wolverines. Wolverine Conservation Society. 9 pp.

Jepsen, S., S.F. Jordan, and R. Huff. . 2014. Species fact sheet: Western bumblebee (Bombus 

occidentalis). 6 pp.

Jordan, S.F. and S.H. Black. 2014. Conservation assessment for Monadenia fidelis minor, Dalles 

sideband. USDA Forest Service, USDI BLM, Oregon and Washington Interagency 

Special Status and Sensitive Species Program. 25 pp. 

Kerwin, A. E. and R. Huff. 2011. Conservation Assessment for the Mardon Skipper (Polites 

mardon). USDA Forest Service Region 6 and USDI Bureau of Land Management. 57 pp.

http://www.fs.fed.us/r6/sfpnw/issssp/planning-documents/assessments.shtml

Kogut, T. and N. Duncan. 2005. Conservation Assessment for Cryptomastix devia, Puget 

Oregonian. USDA Forest Service Region 6 and USDI Bureau of Land Management. 24

pp. http://www.fs.fed.us/r6/sfpnw/issssp/planning-documents/assessments.shtml

Lacki, M.J. and M.D. Baker. 2007. Day roosts of female fringed myotis (Myotis thysanodes) in 

xeric forests of the Pacific Northwest. Journal of Mammalogy 88(4):967-973.

Lacki, M.J., J.P. Hayes, and A. Kurta, eds. 2007. Bats in forests, conservation and management. 

Johns Hopkins University Press, Baltimore, MD. 329 pp.

Larsen, E.M., E. Rodrick and R. Milner. 1995. Management Recommendations for Washington's 

Priority Species, Volume I: 42-46.

Marcot, B.G., B.C. Wales, and R. Demmer. 2003. Range maps of terrestrial species in the Interior 

Columbia River Basin and northern portions of the Klamath and Great Basins. PNW-
Draft Environmental Impact Statement

Chapter 5 – References

Mt Hood National Forest

389

GTR-583, USDA Forest Service, Pacific Northwest Research Station, and USDI Bureau 

of Land Management, Portland, OR. 304 p. 

http://www.fs.fed.us/pnw/publications/gtr583/

Marshall, D.B., M.G. Hunter, and A.L. Contreras, Eds. 2003. Birds of Oregon: A General 

Reference. Oregon State University Press, Corvallis, OR. 768p.

McFadden-Hiller, J.E., and T.L. Hiller. 2014. Forest carnivore research in the northern Cascades 

of Oregon, final progress report (Oct 2012–May 2013, Oct 2013–Jun 2014). Oregon 

Department of Fish and Wildlife, Salem, Oregon, USA. Mellen, T. Kim, E. Charles 

Meslow, R. William Mannan. 1992 Source Summertime Home Range and Habitat Use of 

Pileated Woodpeckers in Western: Journal of Wildlife Management, Vol. 56, No. 1 (Jan.

1992), pp. 96-103.

Mellen-McLean, K., B. Wales, and B. Bresson. 2013. A Conservation Assessment for the Whiteheaded Woodpecker (Picoides albolarvatus). USDA Forest Service, Region 6 and USDI 

Bureau of Land Management, Oregon and Washington. 41p. 

http://www.fs.fed.us/r6/sfpnw/issssp/documents2/ca-bi-picoides-albolarvatus-2013-08-

07.pdf

Mellen-McLean, Kim, Bruce G. Marcot, Janet L. Ohmann, Karen Waddell, Susan A. Livingston,

Elizabeth A. Willhite, Bruce B. Hostetler, Catherine Ogden, and Tina Dreisbach. 2012. 

DecAID, the decayed wood advisor for managing snags, partially dead trees, and down 

wood for biodiversity in forests of Washington and Oregon. Version 2.20. USDA Forest 

Service, Pacific Northwest Region and Pacific Northwest Research Station; USDI Fish 

and Wildlife Service, Oregon State Office; Portland, Oregon. 

http://www.fs.fed.us/r6/nr/wildlife/decaid/index.shtml

Munzing, D. and W.L. Gaines. 2008. Monitoring American marten on the east-side of the north 

Cascades of Washington. Northwestern Naturalist 89:67-75.

Nagorsen, D.W. and R.M. Brigham. 1993. Bats of British Columbia. University of British 

Columbia Press. pp. 91-95.

Nussbaum, R.A., E.D. Brodie, Jr., and R.M. Storm. 1983. Amphibians and reptiles of the Pacific 

Northwest. University of Idaho Press, Moscow, ID.

Oregon Department of Fish and Wildlife (ODFW). 2016. Rocky Mountain elk and mule deer, 

2002-2006 population estimates. 2 pp.

Pagel, J.E. 1992. Protocol for Observing Known Potential Peregrine Falcon Eyries in the Pacific 

Northwest. Pages 83-96 in J.E. Pagel, editor. Proceedings of a symposium on peregrine 

falcons in the Pacific Northwest. U.S. Forest Service, Medford, Oregon. 125 pp.

Perrine, J.D. 2005. Ecology of red fox (Vulpes vulpes) in the Lassen Peak region of California, 

USA. PhD Diss., University of California, Berkeley. 236 pp.

Perrine, J. D., L. A. Campbell, and G. A. Green. 2010. Sierra Nevada red fox (Vulpes vulpes 

necator): a conservation assessment. USDA Forest Service, R5-FR-010.

Roth, B., R. Jadin, and R. Guralnick. 2013. The taxonomic status of Deroceras hesperium 

Pilsbry, 1944 (Gastroposa: Pulmonata: Agriolimacidae), a species of conservation 

concern in Oregon, USA. Zootaxa 3691(4): 453-460.
Government Camp – Cooper Spur Land Exchange

Mt Hood National Forest

390

Sauer, J.R., J.E. Hines, and J. Fallon. 2008. The North American Breeding Bird Survey, Results 

and Analysis 1966 - 2007. Version 5.15.2008. USGS Patuxent Wildlife Research Center, 

Laurel, MD.

Schroeder, R.L. 1982. Habitat suitability index models: Pileated woodpecker. USDI Fish and 

Wildlife Service. FWS/OBS-82/10.39.

Scrafford, M and M. Boyce. 2015. Effects of industrial development on wolverine (Gulo gulo) 

ecology in the boreal forest of northern Alberta. Progress Report, Winter 2014/2015. 20

pp.

Steele, C.A. and E.D. Brodie, Jr. 2002. Influence of forest age on densities of Cope’s and Pacific 

giant salamanders. Northwest Science 76(4):347-432.

Stone, T. and R. Huff. 2011. Species Fact Sheet: Columbia sideband, Monadenia fidelis 

Columbiana. USDA Forest Service, Region 6 and USDI Bureau of Land Management, 

Oregon and Washington. 5p.

Thomas, J.W, M.G. Raphael, R.G. Anthony, E.D. Forsman, A.G. Gunderson, R.S Holthausen, 

B.G. Marcot, G.H. Reeves, J.R. Sedell, and D.M. Solis. 1993. Viability assessments and 

management considerations for species associated with late-successional and old-growth 

forests of the Pacific Northwest. Washington, DC: U.S. Department of Agriculture, Forest 

Service, U.S. Government Printing Office. 530p.

Tobalske, B.W. 1997. Lewis’ Woodpecker (Melanerpes lewis). In The Birds of North America, 

No. 284 (A. Poole and F. Gills, eds.). The Academy of Natural Sciences, Philadelphia, 

PA, and The American Ornithologists’ Union, Washington, D.C.

USDA Forest Service and USDI Bureau of Land Management. 1998. North Willamette Late 

Successional Reserve Assessment, Mt. Hood National Forest Cascades Resource Area, 

Salem BLM.

USDA Forest Service and USDI Fish and Wildlife Service. 2008. Memorandum of understanding 

to promote the conservation of migratory birds.

USDA Forest Service, USDI Fish and Wildlife Service. 1993. Forest ecosystem management: an 

ecological, economic, and social assessment. U.S. Government Printing Office 1993-793-

071.

USDA Forest Service. 1990a. Mt. Hood National Forest Land and Resource Management Plan 

(forest plan).

USDA Forest Service. 1990b. Environmental impact statement for the Mt. Hood National Forest 

land and resource management plan and record of decision (forest plan).

USDA Forest Service. 2011. Management Indicator Species Forest-wide analysis. Mt. Hood 

National Forest. 31p.

USDA Forest Service. 2015. Region 6 Regional Forester’s sensitive species list. Updated July 13, 

2015.

USDI Fish and Wildlife Service. 2011. Revised Recovery Plan for the Northern Spotted Owl 

(Strix occidentalis caurina). U.S. Fish and Wildlife Service, Portland, Oregon. xvi + 

258 pp.
Draft Environmental Impact Statement

Chapter 5 – References

Mt Hood National Forest

391

USDI Fish and Wildlife Service. 2008. Birds of Conservation Concern 2008. United States 

Department of Interior, Fish and Wildlife Service, Division of Migratory Bird 

Management, Arlington, Virginia. 85 pp. Online version available at 

http://www.fws.gov/migratorybirds/

USDI Fish and Wildlife Service. 2012. Designation of Revised Critical Habitat for the Northern 

Spotted Owl (Strix occidentalis caurina) - Final Rule. Fed. Reg. Vol. 77. 233: 71876-

72068. December 2012.

USDI Fish and Wildlife Service. 2014. Endangered and Threatened Wildlife and Plants; 

Threatened Status for the Distinct Population Segment of the North American Wolverine 

Occurring in the Contiguous United States; Establishment of a Nonessential 

Experimental Population of the North American Wolverine in Colorado, Wyoming, and 

New Mexico; Proposed Rule. Federal Register 79 (156): 47522-47545.

USDI Fish and Wildlife Service. 2015. Species Report: Sierra Nevada red fox (Vulpes vulpes 

necator). 78 pp. 

USDI Fish and Wildlife Service. 2016a. Updated list of threatened and endangered species. 

August 15, 2016. 6 pp. 

USDI Fish and Wildlife Service. 2016b. National Wetlands Inventory, Wetlands Mapper V1 

website. Accessed on 08/30/2016 at: https://www.fws.gov/wetlands/Data/Mapper.html

Verts, B.J. and L.N. Carraway. 1998. Land mammals of Oregon. University of California Press, 

Berkeley, CA. pp. 90-93.

Walcott, P. 2010. Inventory for the Mardon skipper, Polites mardon, on the Mt. Hood National 

Forest. Report to the Interagency Special Status Sensitive Species Program, FY2009. 

6 pp.

Watershed Professionals Network LCC. 2010. Mt. Hood National Forest land exchange wetland 

inventory. 82 pp.

Weller, T.J. and C.J. Zabel. 2001. Characteristics of fringed myotis day roosts in northern 

California. Journal of Wildlife Management 65(3):489-497.

Wiggins, D. 2005. Harlequin Duck (Histrionicus histrionicus): a technical conservation 

assessment. [Online]. USDA Forest Service, Rocky Mountain Region. 

http://www.fs.fed.us/r2/projects/scp/assessments/harlequinduck.pdf

Witmer, G. W. and D.S. deCalesta. 1985. Effect of Forest roads on habitat use by Roosevelt elk.

Northwest Sci. 59 (2); 122-125.

Xerces Society. 2015. Western bumblebee (Bombus occidentalis). Accessed online at: 

http://www.xerces.org/western-bumble-bee/# [07/14/2015].

Young, T. and J. Doerr. 2013. FY2012 ISSSP Report on Determining the Occurrence and Range 

of Deroceras hesperium on the Willamette National Forest using Summer Surveys of 

Unique Habitats and Comparison of Summer Surveys versus Spring/Fall Mollusk 

Protocol Surveys for Detection of this Species. Unpublished Report. 7 pp.

Zielinski, W.J., K.M. Slauson, C.R. Carroll, C.J. Kent, and D.G. Kudma. 2001. Status of 

American martens in coastal forests of the Pacific states. Journal of Mammalogy 82:478-

490.