United States 

Department of

Agriculture

Forest 

Service

April 2010

Draft Environmental 

Impact Statement

Two Bit Vegetation Management

Happy Camp Ranger District, Klamath National Forest

Siskiyou County, California
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i

Two Bit Vegetation Management

Draft Environmental Impact Statement

Siskiyou County, California

Lead Agency: USDA Forest Service

Responsible Official: Patricia A. Grantham, Forest Supervisor 

Klamath National Forest

Information Contact: John Allen (530) 493-1741

Address Comments to: Two Bit Project

PO Box 377

Happy Camp, CA 96039-0377

Facsimile Comments to: 530-493-1796

Electronic Comments Accepted: comments-pacificsouthwest-klamath-happycamp@fs.fed.us

Website: http://www.fs.fed.us/r5/klamath/projects/projects/two-bit

Abstract

Land managers for the Klamath National Forest propose the Two Bit Vegetation Management 

Project to sustain diverse, fire resilient ecosystems more in keeping with historic conditions, and 

to provide a programmed flow of timber products north and west of Happy Camp, California. 

This Draft Environmental Impact Statement (DEIS) considers the environmental effects of 

thinning and burning on about 9,530 acres of National Forest System land (see the vicinity map 

and proposed action map below). 

The proposed action was developed with the input of local citizens and representatives from 

various organizations and government agencies and is designed to address the laws, policies and 

plans that guide vegetation management on National Forest System lands within the project area. 

The thinning and burning is intended to sustain diverse, fire-resilient ecosystems and a 

functioning forest and watershed by 1) reducing stand densities; 2) improving structural diversity 

within stands, where applicable; 3) maintaining natural meadows and wetlands or restoring 

meadows and wetlands where encroachment has occurred; 4) maintaining existing hardwood 

diversity or restoring hardwood diversity where loss has occurred or recruitment is low; 5)

protecting mid- and early-seral forest from loss due to wildfire; 6) developing heavily stocked 

early seral stands into later seral conditions and reducing the risk of losing northern spotted owl 

habitat due to wildfire; and 7) maintaining or improving watershed conditions and the quality of 

the Indian Creek water source. The thinning and burning is intended to provide a programmed 

flow of timber products by: 1) improving and maintaining good growth rates; 2) minimizing 
ii

insect and disease damage through stocking control; and 3) continuing maintenance treatments in 

existing plantations.

Comments on this DEIS are due 45 days following the publishing of the Notice of 

Availability in the Federal Register. Reviewers should provide the Forest Service with their 

comments during the review period of the DEIS. This will enable the Forest Service to analyze 

and respond to the comments at one time and to use the information acquired in the preparation 

of the Final EIS, thus avoiding undue delay in the decision-making process. Reviewers have an 

obligation to structure their participation in the National Environmental Policy Act (NEPA) 

process so that it is meaningful and alerts the agency to the reviewer’s concerns and contentions 

(Vermont Yankee Nuclear Power Corp. v. NRDC, 435 U.S. 519, 553 (1978). Environmental 

objections that could have been raised at the draft stage may be waived if not raised until after 

completion of the final environmental impact statement. City of Angoon v. Hodel (9th Circuit, 

l986) and Wisconsin Heritages, Inc. v. Harris, 490 F. Supp. 1334, 1338 (E.D. Wis. 1980). 

Comments on the draft environmental impact statement should be specific and should address 

the adequacy of the statement and the merits of the alternatives discussed (40 CFR 1503.3).
iii

Figure 1. Vicinity Map
iv
v

Figure 2. Activities proposed for alternative 2 – proposed action note: stream layers shown on this map have not been field verified; for field-verified stream locations, see Two Bit Hydrology Specialist Report (Bousfield 2010)
vi
Two Bit Vegetation Management Draft Environmental Impact Statement Summary

vii

Summary

Land managers for the Klamath National Forest propose the Two Bit Vegetation Management 

Project to sustain diverse, fire resilient ecosystems more in keeping with historic conditions, and 

to provide a programmed flow of timber products north and west of Happy Camp, California. 

This Draft Environmental Impact Statement (DEIS) considers the environmental effects of 

thinning and burning on about 9,530 acres of National Forest System land (see figure 1, vicinity 

map and figure 2, proposed action map). The project is designed to sustain diverse, fire-resilient 

ecosystems and a functioning forest and watershed by: 

Reducing stand densities

Improving structural diversity within stands, where applicable 

Maintaining natural meadows and wetlands or restoring meadows and wetlands where 

encroachment has occurred 

Maintaining existing hardwood diversity or restoring hardwood diversity where loss has 

occurred or recruitment is low

Protecting mid- and early-seral forest from loss due to wildfire

Developing late-successional conditions, increasing patch size of late-successional areas and 

reducing the risk of losing northern spotted owl habitat due to wildfire

Maintaining or improving watershed conditions and the quality of the Indian Creek water 

source

Provide a programmed flow of timber products by:

Improving and maintaining good growth rates

Minimizing insect and disease damage through stocking control

Continuing maintenance treatments in existing plantations

The proposed action would authorize approximately 9,530 acres of thinning and burning 

across approximately 68,000 acres of National Forest System land. Commercial thinning and 

other silvicultural treatments make up approximately 2,280 acres, and the remainder (about 

7,250 acres) is proposed for prescribed burning. The majority of the treatment units proposed for 

commercial thinning are existing plantations. Approximately 315 acres proposed for treatment 

are natural stands.

The Klamath National Forest published a Notice of Intent to prepare an Environmental 

Impact Statement for the Two Bit Vegetation Management Project on February 20, 2009 in the 

Federal Register, initiating the public scoping period for this project. A scoping letter was 

distributed for public input and comment on February 18, 2009. The letter was mailed to 

approximately 90 individuals, groups, agencies and tribal governments and posted on the 

Klamath National Forest website. The Forest Service held a public meeting in Happy Camp, CA 

on March 4 to discuss the project and a public field trip was held on June 22, 2009 to show 

interested individuals the project area, discuss proposed treatments and answer questions. Ten 
Summary Two Bit Vegetation Management Draft Environmental Impact Statement

viii

letters were received in response to the scoping effort and were used in conjunction with internal 

scoping with agency specialists to develop a list of significant issues. These issues led the agency 

to develop alternatives to the proposed action including:

Alternative 1 – No Action 

Alternative 2 – Proposed Action – The proposed action includes a total of 2,280 acres of 

silvicultural treatments, 142 treatment units, approximately 4.1 miles of road 

decommissioning and approximately 7,250 acres of underburning outside of treatment units. 

Approximately 2.9 miles of temporary roads would need to be constructed and about 4.3 

miles of existing temporary roads would be reconstructed to effectively access and treat 

thinning units. 

Alternative 3 – No New Temporary Roads - No new temporary roads would be 

constructed under Alternative 3. Approximately 3.5 miles of existing temporary roads would 

be reconstructed to effectively access and treat thinning units. Skid trails and existing

temporary roads would be used and then hydrologically restored following treatment. Units 

that would require excessive adverse skidding distances would not be treated. Alternative 3 

includes a total of 2,010 acres of silvicultural treatments, 125 treatment units, approximately 

4.1 miles of road decommissioning, and a total of 7,320 acres of underburning outside of 

treatment units.

Alternative 4 – Minimized Underburning - Alternative 4 includes silvicultural treatments 

(2,280 acres in 142 units) and road decommissioning (4.1 miles) as described in alternative

2. Fuels treatments would focus on thinned units, consisting of jack pot burning, pile burning 

and some limited underburning outside of thinned units, for approximately 570 acres outside 

of treatment units. Mastication to treat slash following thinning would be used instead of or 

in combination with underburning/hand pile burning in 93 units, to total approximately 

1,490 acres of mastication.

Alternative components are summarized in table 1. 

The Klamath National Forest Supervisor is the Responsible Official for this project. In the 

decision, the Forest Supervisor will answer the following questions based on the environmental 

analysis: 

Will the proposed action or one of the additional alternatives to the proposed action proceed 

as proposed or not at all? If one of these alternatives proceeds:

What mitigation measures and monitoring requirements will the Forest Service apply to the 

project?

Will the project require a Forest Plan amendment?
Two Bit Vegetation Management Draft Environmental Impact Statement Summary

ix

Table 1. Summary of alternative components

Component / Objective Alternative 1

No Action

Alternative 2

Proposed 

Action

Alternative 3

No Temporary 

Roads

Alternative 4

Minimized 

Underburn

Total treatment acres (all 

treatments combined) 0 9,530 9,330 2,850

Total underburning acres 0 7,250 7,320 570

Total thinning acres 0 1,980 1,710 1,980

Total specialized treatment 

acres

0 140 140 140

Total meadow enhancement 

acres

0 160 160 160

Total acres of natural stands 

commercially thinned (% of 

thinning treatment)

0 315 (16%) 180 (11%) 315 (16%)

Total acres of plantations 

commercially thinned (% of 

thinning treatment)

0 1,665 (84%) 1,525 (89%) 1,665 (89%)

Total miles of road 

decommissioning 0 4.1 4.1 4.1

Total acres of mastication 0 0 0 1,490

Miles of temporary roads 

constructed 0 2.9 0 2.9

Potential sawlog volume 

produced from thinning

(CCF, hundred cubic feet)

0 46,240 39,785 46,240
Two Bit Vegetation Management Draft Environmental Impact Statement

x

Table of Contents

Abstract ___________________________________________________________________i

Summary ________________________________________________________________ vii

Chapter 1. Purpose and Need for Action ____________________________________ 1

1.1 Document Structure _____________________________________________________ 1

1.2 Management Direction ___________________________________________________ 1

1.2.1 Additional Guidance __________________________________________________________4

1.3 Purpose and Need for Action______________________________________________ 6

1.3.1 Regulated Lands _____________________________________________________________8

1.3.2 LSR_______________________________________________________________________8

1.3.3 Riparian Reserves ____________________________________________________________9

1.3.4 Summary of Purpose and Need_________________________________________________10

1.4 Proposed Action _______________________________________________________ 10

1.5 Decision Framework____________________________________________________ 11

1.6 Public Involvement _____________________________________________________ 11

1.7 Issues ________________________________________________________________ 11

1.7.1 Water Quality, Fisheries and Cumulative Watershed Effects __________________________12

1.7.2 Economics_________________________________________________________________12

1.7.3 Air Quality and Prescribed Burning Implementation ________________________________13

Chapter 2. Alternatives, Including the Proposed Action _______________________ 15

2.1 Introduction___________________________________________________________ 15

2.2 Alternatives Considered in Detail _________________________________________ 15

2.2.1 Alternative 1 - No Action _____________________________________________________15

2.2.2 Alternative 2 - The Proposed Action ____________________________________________15

2.2.3 Alternative 3 - No New Temporary Roads ________________________________________27

2.2.4 Alternative 4 - Minimal Underburning ___________________________________________33

2.3 Summary of Best Management Practices (BMPs) and Project Design Features 

Common to All Alternatives_________________________________________________ 37

2.3.1 Best Management Practices ___________________________________________________37

2.3.2 Project Design Features ______________________________________________________39

2.4 Monitoring Common to All Alternatives ___________________________________ 48

2.5 Alternatives Considered but Eliminated from Detailed Analysis________________ 48

2.5.1 Maximize Harvest___________________________________________________________49

2.5.2 Citizens Alternative _________________________________________________________49

2.5.3 Initial Proposed Action _______________________________________________________51

2.6 Alternatives Compared _________________________________________________ 53

Chapter 3. Affected Environment and Environmental Consequences ____________ 69

3.1 Methodology __________________________________________________________ 69

3.2 Past, Present and Reasonably Foreseeable Actions ___________________________ 69

3.3 Forest Vegetation ______________________________________________________ 76

3.3.1 Methodology_______________________________________________________________76
Two Bit Vegetation Management Draft Environmental Impact Statement

xi

3.3.2 Affected Environment ________________________________________________________78

3.3.3 Environmental Consequences __________________________________________________91

3.4 Fire and Fuels ________________________________________________________ 110

3.4.1 Methodology ______________________________________________________________110

3.4.2 Affected Environment _______________________________________________________113

3.4.3 Environmental Consequences _________________________________________________116

3.5 Air Quality___________________________________________________________ 123

3.5.1 Methodology ______________________________________________________________123

3.5.2 Affected Environment _______________________________________________________124

3.5.3 Environmental Consequences _________________________________________________126

3.6 Water _______________________________________________________________ 129

3.6.1 Methodology ______________________________________________________________129

3.6.2 Affected Environment _______________________________________________________131

3.6.3 Environmental Consequences _________________________________________________137

3.7 Geology _____________________________________________________________ 153

3.7.1 Methodology ______________________________________________________________153

3.7.2 Affected Environment _______________________________________________________155

3.7.3 Environmental Consequences _________________________________________________157

3.8 Soils ________________________________________________________________ 167

3.8.1 Methodology ______________________________________________________________167

3.8.2 Affected Environment _______________________________________________________168

3.8.3 Environmental Consequences _________________________________________________171

3.9 Fisheries_____________________________________________________________ 179

3.9.1 Methodology ______________________________________________________________179

3.9.2 Affected Environment _______________________________________________________181

3.9.3 Environmental Consequences _________________________________________________188

3.10 Botany and Noxious Weeds ____________________________________________ 198

3.10.1 Methodology _____________________________________________________________198

3.10.2 Affected Environment ______________________________________________________200

3.10.3 Environmental Consequences ________________________________________________202

3.11 Terrestrial Wildlife___________________________________________________ 207

3.11.1 Methodology _____________________________________________________________207

3.11.2 Affected Environment ______________________________________________________208

3.11.3 Environmental Consequences ________________________________________________214

3.12 Social and Economic Resources ________________________________________ 244

3.12.1 Methodology _____________________________________________________________244

3.12.2 Affected Environment ______________________________________________________245

3.12.3 Environmental Consequences ________________________________________________249

3.13 Scenery and Recreation Resources ______________________________________ 257

3.13.1Methodology _____________________________________________________________257

3.13.2 Affected Environment ______________________________________________________259

3.13.3 Environmental Consequences ________________________________________________261

3.14 Cultural Resources ___________________________________________________ 267

3.14.1 Methodology _____________________________________________________________267

3.14.2 Affected Environment ______________________________________________________268

3.14.3 Environmental Consequences ________________________________________________270

3.15 Climate Change______________________________________________________ 275

3.15.1 Methodology _____________________________________________________________275
Two Bit Vegetation Management Draft Environmental Impact Statement

xii

3.15.2 Affected Environment______________________________________________________276

3.15.3 Environmental Consequences ________________________________________________277

3.16 Short-term Uses and Long-term Productivity _____________________________ 278

3.17 Unavoidable Adverse Effects ___________________________________________ 279

3.18 Irreversible and Irretrievable Commitments of Resources __________________ 279

3.19 Energy Requirements _________________________________________________ 279

3.20 Legal and Regulatory Compliance ______________________________________ 280

Chapter 4. Consultation and Coordination_________________________________ 281

4.1 Preparers and Contributors_____________________________________________ 281

4.2 Federal, State, and Local Agencies: ______________________________________ 282

4.3 References ___________________________________________________________ 284

4.4 Glossary _____________________________________________________________ 293

4.5 Index________________________________________________________________ 305

Appendix A – Public Scoping Comments and Responses______________________ 307

Appendix B – Treatment Objectives by Thinning Unit________________________ 331

Appendix C – Proposed Logging Systems Descriptions _______________________ 367

Logging Systems _______________________________________________________________367

Appendix D – Aquatic Conservation Strategy Compliance ____________________ 371

No-action Alternative _____________________________________________________ 372

Alternatives 2, 3 and 4 ____________________________________________________ 373

Appendix E – Implementation of Best Management Practices for the Two Bit 

Vegetation Management Project _________________________________________ 377

Introduction_____________________________________________________________ 377

Best Management Practices ________________________________________________ 377

Appendix F – Cumulative Watershed Effects Modeling Summary ______________ 393

Introduction_____________________________________________________________ 393

Summary of Findings _____________________________________________________ 394

Existing conditions, with past and present/current actions _______________________________394

Alternatives ___________________________________________________________________394

Table of Tables

Table 1. Summary of alternative components ...............................................................................ix

Table 2. Klamath National Forest Plan Management Areas in the Two Bit project area...............2

Table 3. Acres of proposed treatments for alternative 2 ...............................................................16

Table 4. Acres of logging systems for commercial thinning in alternative 2 ...............................19

Table 5. Acres of treatments proposed under alternative 2 by Forest Plan Management Area ....22

Table 6. Acres of treatments proposed for alternative 3 ...............................................................27
Two Bit Vegetation Management Draft Environmental Impact Statement

xiii

Table 7. Acres of logging systems proposed for commercial thinning in alternative 3 ...............29

Table 8. Acres of proposed treatment activities for alternative 3 by Forest Plan Management 

Areas.....................................................................................................................................30

Table 9. Acres of treatments proposed for alternative 4...............................................................33

Table 10. Acres of proposed treatments by Forest Plan Management Area for alternative 4 ......34

Table 11. Best Management Practices selected for the Two Bit Project......................................38

Table 12. Project Design Features by resource area and where they apply..................................39

Table 13. Summary of alternative components and how well alternatives achieve project 

objectives..............................................................................................................................53

Table 14. Summary of environmental effects by alternative........................................................58

Table 15. In-progress or planned activities within the Indian Creek Watershed..........................75

Table 16. Acres of completed, in progress or planned activities within the Indian Creek 5th Code 

Watershed, since 1953..........................................................................................................76

Table 17. Existing condition, acres by vegetation cover (canopy closure) ..................................79

Table 18. Existing condition, acres of forest type regenerated to plantation within the Two Bit 

Project Area ..........................................................................................................................80

Table 19. Representative units: existing conditions.....................................................................90

Table 20. No Action Alternative, Comparison of SDI for Existing Condition and 30 Years Out91

Table 21. No Action Alternative for years 2009 and 2039, TPA and QMD................................94

Table 22. Alternative 2, comparison of SDI for Existing Condition, Post Treatment (CT and 

UB), and 30 Years Out .........................................................................................................98

Table 23. Alternative 2 comparison of TPA and QMD for existing condition, post treatment in 

2014, and post treatment in 2039........................................................................................101

Table 24. Comparison of no action alternative and Alt 2, SDI and increase in QMD for Sample 

Stands..................................................................................................................................109

Table 25. Current conditions based on modeling results from FVS-FFE...................................115

Table 26. Descriptions of Historic Natural Fire Regimes ..........................................................115

Table 27. Historic Fire Return Intervals in the Project Area ......................................................116

Table 28. Fire behavior measurement indicator results for the no action alternative.................117

Table 29. Structure, composition and size measurement indicators for no action .....................117

Table 30. Fire behavior and effects measurement indicators for proposed action alternative -

Note that the underburn is not modeled until 2014 ............................................................118

Table 31. Stand structure, composition and size measurement indicators for proposed action. 

Note that the underburn is not modeled until 2014. ...........................................................119

Table 32. Fire behavior and effects measurement indicator results for alternative 4.................120

Table 33. Stand structure, composition and size measurement indicator results for alternative 4. 

Note that underburn is not modeled until 2014. .................................................................121

Table 34. Comparison of alternatives by acres treated and average 90th percentile flame length 

for year 2014 (modeled underburn) and 2029 (15 years post-treatment)...........................123

Table 35. State and federal ambient air quality standards..........................................................125

Table 36. Estimated Emissions by Particulate Type (tons/acre and total tons)..........................127

Table 37. Total miles of unpaved log truck travel. Estimated PM10 fugitive dust emissions from 

log haul and return trips by alternative ...............................................................................128

Table 38. Beneficial uses with the Two-Bit Vegetation Management project area and existing 

watershed conditions ..........................................................................................................132

Table 39. Existing Pool conditions for surveyed stream reaches...............................................134

Table 40. Previously clear-cut stream course Riparian Reserves...............................................135

Table 41. Proposed action comparison of miles of reconstructed temporary roads to 

decommissioned roads located in stream course RRs by 7th –field watershed (percent 

change in parentheses)........................................................................................................140
Two Bit Vegetation Management Draft Environmental Impact Statement

xiv

Table 42. Proposed action acres of reconstructed landings located in stream course RRs by 7th–

field watershed....................................................................................................................141

Table 43. Proposed action commercial treatment acreage located in stream course RRs by 7th

field watershed1

...................................................................................................................142

Table 44. Proposed action prescribed burning acreage located in stream course RRs by 7th field 

watershed ............................................................................................................................143

Table 45. Cumulative watershed effects risk ratios for the existing condition (alternative 1) and 

the proposed action (alternative 2)......................................................................................144

Table 46. Alternative 3 comparison of miles (percent) of reopened/reconstructed temporary 

roads to decommissioned roads located in stream course RRs by 7th field watershed .......147

Table 47. Alternative 3 commercial treatment acreage located in stream course RRs by 7th field 

watershed1

...........................................................................................................................147

Table 48. Alternative 3 influence of cumulative watershed effects risk ratios (change in 

parentheses).........................................................................................................................148

Table 49. Alternative 4 proposed mastication acreage located in stream course RRs in 7th field 

watersheds...........................................................................................................................150

Table 50. Alternative 4 influence of cumulative watershed effects risk ratios (change from 

existing condition in parentheses).......................................................................................151

Table 51. Summary of how alternatives address geologic measurement indicators...................166

Table 52. Existing soil conditions in proposed treatment areas..................................................171

Table 53. Acreage of Detrimental Disturbance across the treatment units for alternative 2 ......176

Table 54. Acreage of Detrimental Disturbance across the treatment units for alternative 3 ......178

Table 55. Salmonid habitat indicators, primary environmental factors determining condition of 

salmonid habitat indicators, and appropriate measures for determining effects of proposed 

action on salmonid habitat indicators..................................................................................189

Table 56. Alternative 2 - Effects on salmonid habitat condition measures.................................192

Table 57. Sensitive Species in the Two Bit Project Area, based on known occurrences or 

presence of suitable habitat.................................................................................................200

Table 58. Direct, indirect and cumulative effects to Sensitive Plants from implementation of 

alternative 2.........................................................................................................................203

Table 59. Sensitive Species in the Two Bit Project Area, based on known occurrences or 

presence of suitable habitat.................................................................................................209

Table 60. Management Indicator Species relevant to the Two Bit Project.................................211

Table 61. Northern spotted owl habitat in the Two Bit project area...........................................219

Table 62. Treatment types in northern spotted owl habitat, all action alternatives.....................220

Table 63. Proposed thinning in NSO foraging habitat................................................................223

Table 64. Proposed Treatments in LSR......................................................................................242

Table 65. County Employment (Number of Jobs) by Economic Sectors...................................248

Table 66. Timber Volume and Values for alternative 2, proposed action ..................................250

Table 67. Timber Volume and Values for alternative 3, No Temporary Roads.........................252

Table 68. Summary of effects to socioeconomic indicators from all alternatives......................255

Table 69. Employment Impacts across Alternatives (number of jobs).......................................256

Table 70. High and Moderate Sensitivity Level Viewpoints......................................................261

Table 71. Proposed Thinning Treatments within Visual Quality Objective Categories.............262

Table 72. Scoping Comment Disposition ...................................................................................307

Table 73. Treatment objectives by thinning unit by alternative..................................................331

Table 74. Modeled sediment delivery and equivalent roaded acres for the existing condition 

(Alternative 1) and Alternatives 2, 3 and 4.........................................................................395

Table 75. Cumulative watershed effects risk ratios for the existing condition and Alternatives 2, 

3 and 4.................................................................................................................................396
Two Bit Vegetation Management Draft Environmental Impact Statement

xv

Table of Figures

Figure 1. Vicinity Map ..................................................................................................................iii

Figure 2. Activities proposed for alternative 2 – proposed action note: stream layers shown on 

this map have not been field verified; for field-verified stream locations, see Two Bit 

Hydrology Specialist Report (Bousfield 2010).......................................................................v

Figure 3. Decision process for Riparian Reserve prescriptions....................................................21

Figure 4. Proposed activities for alternative 2 – proposed action) ...............................................25

Figure 5. Proposed activities for alternative 3 – No temporary roads).........................................31

Figure 6. Proposed activities for alternative 4 –minimized underburning....................................35

Figure 7. Indian Creek 5th field watershed and relationship to Two Bit Project Area and 7th field 

watershed boundaries ...........................................................................................................73

Figure 8. Vicinity of the Two Bit project area large fire history................................................114

Figure 9. Fire Regime Condition Class based on Fire Return Intervals.....................................116

Figure 10. Employment Levels by County, 2001-2007..............................................................247

Figure 11. Mechanical felling using a feller buncher.................................................................367

Figure 12. Skidder operations.....................................................................................................367

Figure 13. Yarder operations......................................................................................................368

Figure 14. Mastication equipment ..............................................................................................369

Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 1

1

Chapter 1. Purpose and Need for Action

1.1 Document Structure

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

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

regulations. This Environmental Impact Statement discloses the direct, indirect, and cumulative 

environmental impacts that would result from the proposed action and alternatives. The 

document is organized into four chapters: 

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

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

achieving that purpose and need. This section also details how the Forest Service informed the 

public of the proposal and how the public responded. 

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

detailed description of the agency’s proposed action as well as alternative methods for achieving 

the stated purpose. These alternatives were developed based on significant issues raised by the 

public and other agencies. This discussion also includes mitigation measures. Finally, this section 

provides a summary table of the environmental consequences associated with each alternative. 

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

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

analysis is organized by resource area.

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

agencies consulted during development of the environmental impact statement. 

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

presented in the environmental impact statement.

Index: The index provides page numbers by document topic.

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

be found in the project planning record located at the Happy Camp Ranger District Office in 

Happy Camp, California.

1.2 Management Direction 

The alternatives are guided by the 1995 Klamath National Forest Land and Resource 

Management Plan (Forest Plan), which subdivides the forest into Management Areas with 

established desired conditions and associated management direction (Standards and Guidelines –

S&Gs). The project is designed to be consistent with the goals, objectives and standards and 

guidelines of all affected Management Areas. The table below shows Management Areas and the 

standards and guidelines that comprise relevant Forest Plan direction for the project and 

summarizes acreage for the ‘most restrictive’ Management Area that applies to any piece of the 
Chapter 1 Two Bit Vegetation Management Draft Environmental Impact Statement

2

forest, as indicated by the Forest Plan Management Area number (the most restrictive 

Management Areas have the lowest numbers in their titles). Multiple Management Areas may 

apply to a given area. Riparian Reserve standards and guidelines apply to lands that meet the 

description of Riparian Reserves, regardless of the Management Area they are within. 

Matrix is a term from the Northwest Forest Plan applied to the portion of the Forest where 

timber harvest is programmed and is categorized in Regulation Classes 1, 2, and 3. These 

Regulated Lands are designated as such in the Forest Plan to provide sustained yield of timber 

with harvest volumes contributing to the Potential Sale Quantity (PSQ). For purposes of this 

document, the term ‘Regulated Lands’ is used instead of Matrix to refer to Management Areas 

where scheduled timber harvest is expected to occur, and harvest volumes contribute to the PSQ.

Regulated Lands are noted in the table below.

Table 2. Klamath National Forest Plan Management Areas in the Two Bit project area

Land Designation

Approximate 

Acreage 

Within Project

Area

Approximate 

Percentage 

of Project

Area

Forest Plan Goals Regulated 

Lands

Non-Forest Service 

System Lands or No 

Data

2347 3

Not under Forest Service 

jurisdiction N/A

Off-Forest (Siskiyou 

National Forest Lands 2236 3 Not under Klamath NF direction N/A

Klamath Forest Plan Management Areas

MA 2 – Wilderness 1230 2

Manage for wilderness 

characteristics, natural 

conditions, ecological 

processes, air quality and 

primitive or semi-primitive 

non-motorized recreation 

opportunity; no timber 

harvest allowed; prescribed 

fire allowed when consistent 

with goals

No

MA 5 – Special Habitat –

Late-Successional 

Reserves

14119 21

Provide habitat that 

contributes to the recovery 

of federally listed 

threatened, endangered and 

sensitive species; 

silvicultural and prescribed 

fire treatments allowed 

when consistent with goals

No

MA 5- Special Habitat -

Threatened and 

Endangered Species

248 <1

Provide habitat that 

contributes to the recovery 

of federally listed 

threatened, endangered and 

sensitive species; 

silvicultural and prescribed 

fire treatments allowed 

when consistent with goals

No
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 1

3

Land Designation

Approximate 

Acreage 

Within Project

Area

Approximate 

Percentage 

of Project

Area

Forest Plan Goals Regulated 

Lands

MA 6 – Managed Wildlife 

Area 2714 4

Manage for late 

successional habitat and 

habitat conditions as defined 

in the Fisher Habitat 

Capability Model; marginal 

timber yield and prescribed 

fire provided consistent with 

areas goals

Yes

MA 1, 7, 8 – Special 

Management (Research 

Natural Area, Special 

Interest Area, Cultural)

330 <1

Manage for ecological 

processes and unique 

features for which the area 

was designated; promote 

public use and enjoyment 

when compatible with area 

values; limited silvicultural 

and fuels treatments 

allowed when consistent 

with goals 

No

MA 10 – Riparian 

Reserves 12457 18

Maintain and restore 

riparian-dependent 

structures and functions of 

intermittent streams; provide 

benefits to ripariandependent and associated 

species; be consistent with 

Aquatic Conservation 

Strategy goals; silvicultural 

and fuels treatments 

allowed when needed to 

reach area goals

No

MA 11 – Retention –

Visual Quality Objective 834 1

Provide attractive, forested 

scenery by maintaining 

areas in their natural or 

natural-appearing condition; 

manage for programmed, 

sustainable harvest in 

capable areas; maintain 

stand health and resilience 

to fire, insects, and disease

Yes

MA 15 – Partial 

Retention – Visual 

Quality

9851 15

Provide attractive, forested 

landscape where 

management activities are 

visually subordinate to 

landscape character; 

manage for sustained yield 

of wood products in capable 

areas; maintain stand health 

and resilience to fire, insects 

and disease

Yes
Chapter 1 Two Bit Vegetation Management Draft Environmental Impact Statement

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Land Designation

Approximate 

Acreage 

Within Project

Area

Approximate 

Percentage 

of Project

Area

Forest Plan Goals Regulated 

Lands

MA 17 – General Forest 21267 32

Provide a programmed, 

non-declining flow of timber 

products, sustainable 

through time; maintain stand 

health; emulate ecological 

processes; provide for 

snags and hardwood habitat 

to maintain viable wildlife 

populations; meet visual 

quality objectives 

Yes

Totals for Project Area 67, 633 acres 100% 52%

1.2.1 Additional Guidance

Several plans, policies and regulations provide management direction for this project, including 

but not limited to: 

Section 7(a)(1) of the Endangered Species Act

Clean Air Act

Clean Water Act

The Roadless Rule of 2001

Endangered Species Act

Consultation for this project is occurring with federal regulatory agencies including the National 

Marine Fisheries Service (NMFS) and the US Fish and Wildlife Service (USFWS) as required by 

the Endangered Species Act. Representatives from these agencies have been involved in the 

project design and analysis for this DEIS. More information is in the Fisheries and Terrestrial 

Wildlife sections of Chapter 3.

Clean Water Act

Water quality standards have been developed by the State of California, as authorized by the 

Federal Environmental Protection Agency and the Clean Water Act of 1972. The Porter-Cologne 

Act, California’s corresponding state law, assigns responsibility for protection of water quality 

within North Coast watersheds to the North Coast Regional Water Quality Control Board 

(NCRWQCB). The NCRWQCB implements and enforces the Porter-Cologne Act, and the Water 

Quality Control Plan for the North Coast Basin (Basin Plan). Water quality objectives are 

outlined in the Basin Plan.

The primary purpose for maintaining water quality is to assure that the beneficial uses of 

water are not adversely affected. When water quality objectives are met, and beneficial uses 

protected, the State then considers that a project meets water quality standards. Best management 

practices and project design features have been developed for this project to comply with the 

provisions and requirements of Sections 208 and 319 of the Federal Clean Water Act and to 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 1

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otherwise ensure protection of water quality consistent with the Basin Plan. More information is 

in Section 3.8-Water in Chapter 3.

Clean Air Act

Air quality is managed through a complex series of federal, state, and local laws and regulations 

designed to assure compliance with the Clean Air Act. Regulations that apply to the Two Bit

Vegetation Management Project are detailed in the Air Quality Report. Air quality and smoke 

management plans have been developed for the airshed surrounding the project area. The project 

is designed to be consistent with these plans.

A Smoke Management Plan (contained in all prescribed fire plans) would be submitted and 

approved by the Siskiyou County Air Pollution Control District prior to using prescribed fire on

federal lands. As part of the Smoke Management Plan the Forest Service must provide a detailed 

meteorological prescription that must be met prior to igniting a prescribed burn. At a minimum, 

the prescription must include acceptable wind direction. Other considerations include wind 

speed, temperature profile, winds aloft, humidity, temperature, actual and predicted inversions, 

burn day status and forecast, precipitation forecast, and any other meteorological conditions that 

may affect smoke dispersion and/or fire behavior.

The Smoke Management Plan would also contain actions the Forest Service would take if 

smoke from burning unexpectedly impacts smoke sensitive areas; including the ability to 

extinguish the fire with equipment on hand. Smoke sensitive areas include any towns and or 

major roads within a 5-mile radius that could be impacted by smoke from the burn project.

One objective of the project is to prevent the occurrence of damaging wildland fires. 

Wildland fires are known to result in high levels of emissions and associated air quality 

problems. Vegetation management treatments provide the opportunity on a long-term basis to 

reduce the magnitude of wildfire air quality problems. Forest thinning is needed to reduce risk of 

catastrophic wildland fires that are likely to exceed air quality standards and result in greater 

releases of greenhouse gasses. More information is in the Air Quality section of Chapter 3.

Inventoried Roadless Areas

Approximately 36 acres of meadow restoration treatment is proposed for a small portion of the 

Siskiyou Roadless Area. Of this 15 acres are proposed for non-commercial thinning to remove 

small encroaching conifers and the remaining 21 acres are proposed for prescribed burning. All 

alternatives are consistent with roadless area management direction contained in the Regional 

Forester’s letter of November 28, 2007(USDA Forest Service 2007b), which directs that the 

2001 Roadless Rule be applied to projects that propose cutting and removal of trees (including 

thinning). Consultation with the State of California has occurred consistent with this letter. 

The Secretary of Agriculture issued a Memorandum (1042-154) on May 28, 2009, 

stating that his office has the authority to approve or disapprove road construction or 

reconstruction and the cutting, sale, or removal of timber in those areas identified in the set of 
Chapter 1 Two Bit Vegetation Management Draft Environmental Impact Statement

6

inventoried roadless area maps contained in Forest Service Roadless Area Conservation, Final 

Environmental Impact Statement, Volume 2, dated November 2000 (USDA Forest Service 

2000a). Since then, the Forest Service has received two re-delegations of decision authority; one 

on August 3, 2009 and one on October 16, 2009. These letters provide re-delegations to allow 

many decisions on roadless area projects to be made by Forest Service officials without going 

through the Secretary of Agriculture. The Two Bit project was submitted to the Regional Office 

for review on December 3, 2009, as directed in a November 5, 2009 letter from the Regional 

Forester.

1.3 Purpose and Need for Action

The overall purpose of the project is to provide a programmed flow of timber products and to 

sustain diverse, fire resilient ecosystems more in keeping with historic conditions, as described 

below:

1. Sustain diverse, fire-resilient ecosystems and a functioning forest and watershed

more in keeping with historic conditions – Actions proposed in the Two Bit project area are 

designed to do this by reducing stand density; improving structural diversity within stands;

maintaining natural meadows and wetlands or restoring meadows and wetlands where 

encroachment has occurred; maintaining hardwood diversity or restoring hardwood diversity 

where loss has occurred or recruitment is low; protecting mid- and early-seral forest from loss 

due to wildfire; developing heavily stocked early-seral stands into later seral conditions, 

reducing the risk of losing northern spotted owl habitat due to wildfire; and maintaining or 

restoring watershed condition and the quality of the Indian Creek water source. 

2. Provide a programmed flow of timber products – Actions proposed in the Two Bit 

project area are designed to do this by improving and maintaining good growth rates; minimizing 

insect and disease damage through stocking control; and continuing maintenance treatments in 

existing plantations. 

Approximately 76 percent of the proposed thinning treatments are within Forest Plan

Management Areas available for scheduled timber harvest (General Forest, Partial Retention 

Visual Quality Objective, and Managed Wildlife Habitat). The remaining areas are within

Riparian Reserves, Special Management Areas, and Late-Successional Reserves; thinning 

activities within these management areas are in existing plantations.

Historical large fire history as well as fire exclusion have played a substantial role in 

vegetation successional patterns throughout the area. Historic conditions within the project area 

as seen in 1944 aerial photos indicate that large fires were a common occurrence in the area and 

vegetation was more open. According to Klamath National Forest Geographic Information 

System maps, there were 17 fires greater than 5 acres in size within the project area between 

1944 and 2004. Historical vegetation classes were primarily Klamath Mixed Conifer and 

Douglas-fir as they are today, but seral stage distribution has changed over time. Historically, 

approximately 95 percent of the project area supported vegetation at or below a fire return 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 1

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interval of 35 years, or fire regime condition class I (moderate to low fire intensity with frequent 

intervals). Currently, 89 percent of the project area is in fire regime condition class III (moderate 

intensity with an infrequent interval), indicating that most of the project area has shifted greatly 

from the natural historic fire regime (Isbell 2010).

Historically, there was variation in the landscape with areas of continuous cover broken up 

by openings of various sizes in the canopy. The lower severity fires of the past maintained open 

understory and kept levels of woody debris low; although this varied as it does today depending 

on weather, local topography and fuels conditions. More recent aerial photo interpretation 

indicates a more continuous cover of forest of various age classes and fewer openings. This 

change has contributed to increased fuel hazard (and the potential for high severity wildland 

fire), decreased habitat quality for some species and increased susceptibility to insect and disease 

impacts and loss of big trees.

Desired conditions for the Two Bit project area include: 

A sustainable flow of wood fiber

Stand conditions that do not promote high severity wildfires

Stand conditions that are more resilient to high intensity wildfires and drought

Stand conditions that include a diversity of vegetation conditions including areas of 

continuous cover, more open stands especially on drier sites, and lower fuel levels similar to 

historic vegetation patterns. 

These desired conditions are consistent with desired conditions and objectives described in the 

1997 Indian Creek Watershed Analysis (USDA Forest Service 1997, pages IV-1 through IV-4

and table 4-1). Selected desired conditions and objectives from the Watershed Analysis 

underscore the need for treatment throughout the project area:

Maintenance of late-seral conditions for extended periods with light fuel loadings (use fire to 

manage understory and reduce fuel loading; some removal of intermediate and suppressed 

trees may be beneficial)

Fuel loadings that pose low risk to resources and investments (use fire to manage understory 

and reduce fuel loading; some removal of intermediate and suppressed trees may be 

beneficial)

Riparian Reserves with vegetative cover with low risk of wildfire loss (manage conditions 

and densities commensurate with site capacities using tools such as thinning and fire)

Stable road system that does not produce chronic sediment load to creek system (Implement 

road stabilization projects)

Progression to late mature condition with light fuel loadings. Vegetation densities 

commensurate with site capacities (commercially thin and apply light underburn)

Watershed contributes to sustainable programmed harvest on regulated lands (prioritize 

programmed harvest on regulated lands upon long-term growth and yield sustainability 

considerations)

The purpose of thinning and burning is to move toward desired conditions that more closely 

resemble the landscape of the past. These conditions would reduce potential for damaging 

wildfire and help sustain older forest habitat through time. 
Chapter 1 Two Bit Vegetation Management Draft Environmental Impact Statement

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1.3.1 Regulated Lands

Approximately 52 percent of National Forest System land in the Two Bit area is allocated to

Regulated Lands, which are lands open and available for commercial timber harvest. The 

management direction for Regulated Lands depends on the Forest Plan Management Area (see 

table 2). Much of the Regulated Lands portion of the project area is General Forest, which 

influences the type and extent of treatments that may occur on these lands.

Forest stands within regulated lands include areas that are overstocked to levels where 

competition for available resources (e.g., sunlight and water) makes them less able to withstand 

periodic drought. This condition also weakens trees’ defense mechanisms and puts them at 

greater risk of damage from insects and disease, which further reduces tree vigor. Thinning is 

needed in these areas to reduce tree density and improve forest health and vigor in order to move 

toward the desired condition of healthy vigorous stands with less risk of loss from fire, insects or 

disease. Approximately 76 percent of the thinning treatments proposed are within Management 

Areas containing Regulated Lands.

1.3.2 LSR 

Approximately 21 percent of National Forest System land in the Two Bit area is allocated to 

Late- Successional Reserve (LSR). The Klamath National Forest, Forest-wide Late-Successional 

Reserve Assessment (USDA Forest Service 1999a) presents a management strategy for 

attainment of LSR goals and objectives. Since the completion of this assessment, biologists from 

the USFWS-Yreka Field Office and the Klamath National Forest have emphasized the need to 

enhance late-successional desired conditions within LSRs. Important elements of the desired 

conditions typically include multiple canopy layers, small understory trees and canopy gaps. 

Only a small percentage of proposed thinning (6 percent) would occur within LSR and 

approximately 18 percent of proposed underburning would occur within LSR. The majority of 

proposed thinning would be within existing plantations. These portions of LSR are not at the 

desired condition. Stands are mostly even-aged and generally too dense to grow large diameter 

trees. Trees would have to die to develop gaps where growing space is available for the 

understory to develop, increasing surface fuels and putting stands at risk to fire damage. Action 

is needed to reduce stocking levels to a point where late-successional characteristics could 

develop.

The desired condition within LSRs is detailed in the 1999 Late-Successional Reserve

Assessment (USDA Forest Service 1999a, page 3-2) as:

“The desired condition within LSRs is to provide late-successional and oldgrowth forest in which structure and composition is consistent with site 

conditions and ecological processes. Important structural attributes include live 

old growth trees, standing dead trees, fallen trees or logs on the forest floor, and 

logs in streams. Additional important elements typically include multiple canopy 

layers, smaller understory trees, canopy gaps, and patchy understory.”
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 1

9

The use of prescribed fire is specifically mentioned in the 1999 LSR Assessment (USDA 

Forest Service 1999c, page 3-2) as follows:

“The introduction of prescribed fire to the LSRs will help encourage the 

processes and attributes that define late-successional and old-growth 

ecosystems. It is expected and even desirable to have low to moderate intensity 

fires burn in LSRs. Low intensity fires will reduce fine fuels and ladder fuels, 

create a seedbed for a diversity of herbaceous plants, and create a patchy 

understory open enough for spotted owl movements.”

Action is needed in LSR to reduce continuity of surface and ladder fuels and competition 

between trees and is consistent with the desired conditions for plantations as also mentioned in 

the 1999 LSR Assessment (USDA Forest Service 1999c, page 3-2) as follows: 

“It is anticipated that plantations are capable of supporting mature and latesuccessional forest, and therefore, the desired condition is to manage them as 

such. Residual snags, hardwoods, and down logs from the previous stand will be 

desired components to maintain within these plantations. Hardwoods should be 

carried through the life of the stand. In the interim, the stands should be healthy 

and fast growing with stocking levels and fuel accumulations that reduce the 

likelihood of loss to catastrophic fire.”

1.3.3 Riparian Reserves

Riparian Reserves are vital for the protection of aquatic dependent species and to provide forest 

connectivity. Riparian areas are essential in maintaining stream temperature, dissolved oxygen 

levels, and other elements of water quality. They also ensure large wood recruitment, stabilize 

the channel, provide for filtration of sediment, and increase habitat diversity. Forested riparian 

ecosystems provide habitat for a diversity of plant communities. Riparian Reserves cover 

approximately 18 percent of the area. 

They are to be managed to maintain mid- to late-seral stands over the long term, connectivity 

for late-seral wildlife and sufficient habitat for sustainable populations of indigenous aquatic 

species. Some Riparian Reserves in the proposed treatment areas are not at this desired condition 

and action is needed to restore desired conditions. 

Desired conditions for Riparian Reserves are described in the Forest Plan on pages 4-106 

through 4-107 and include:

“Vegetative communities contain native and desirable non-native species that 

are in good ecological condition. A multi-layered vegetative canopy is 

present...An overstory of conifers provide shade and thermal cover to streams 

and lakes...An intermediate layer provides thermal buffering, nutrient cycling 

and bank stability...The riparian community includes all age classes and 

sizes....”

The purpose for treatment within Riparian Reserves includes maintaining or restoring 

watershed condition and water quality in Indian Creek and contributing to meeting Aquatic 

Conservation Strategy Objectives, particularly related to the influence of vegetation conditions 

on watershed processes. Riparian Reserve treatments in plantations would promote large woody 
Chapter 1 Two Bit Vegetation Management Draft Environmental Impact Statement

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debris recruitment and stream shade; Riparian Reserve treatments in both plantations and natural 

stands would contribute to reduce wildfire risk.

1.3.4 Summary of Purpose and Need

The purpose of taking management action at this time in the Two Bit project area is to achieve 

two primary goals: to sustain diverse, fire-resilient ecosystems by restoring forest health and 

reducing fuel hazard and to provide forest products. The purpose and need for action is driven by 

the difference between the current and desired conditions of forest vegetation in the Two Bit 

area.

Action is needed within all land designations, including General Forest, LSR, and Riparian 

Reserves, although the emphasis for treatment varies. The project is intended to influence forest 

vegetation toward the desired conditions across the Two Bit area while remaining consistent with 

current management direction.

1.4 Proposed Action

The initial proposed action (as described during the February 2009 scoping period) and 

alternative 2 – the proposed action described in this document are quite similar; however, several 

refinements have been made since the scoping period. These refinements were based on 

additional field review by the IDT and other internal scoping efforts and resulted in the need to 

make some modifications to the initial proposed action. These modifications were mentioned in 

a flyer sent to the project mailing list in June 2009, posted to the project website, and discussed 

during the public field trip on June 22, 2009. No additional comments or concerns were received 

in response to this notification. Alternative 2 – the proposed action described in this document 

better addresses the purpose and need for action and the public input received to date, and more 

accurately reflects on-the-ground conditions; therefore, the initial proposed action was dismissed 

from further detailed analysis.

The action proposed by the Forest Service to meet the purpose and need is to commercially 

thin and conduct prescribed burning on a total of 9,530 acres within the project area. 

Commercial thinning treatments make up 1,980 acres of this; specialized treatments (pole 

harvest, sanitation thinning, and hardwood release) comprise 140 acres; and meadow 

enhancement treatments make up 160 acres. Prescribed burning (underburning) is proposed for 

7,250 acres outside of thinning units. The majority of the treatment units proposed for 

commercial thinning are existing plantations. Approximately 4.1 miles of existing system roads 

would be decommissioned as part of this project. These roads were identified in 2004 through 

the Indian Creek Watershed Road Sediment Source Inventory process as requiring excessive

maintenance, having little value to future management projects, and contributing to unfavorable 

watershed conditions. In order to facilitate tractor and cable logging, 2.9 miles of temporary 

roads would be created and 4.3 miles of existing temporary roads would be reconstructed to 

support this project. All temporary roads and pre-existing reconstructed roads would be 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 1

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hydrologically restored to minimize erosion and sediment production upon completion of the 

project. Approximately 315 acres proposed for treatment are natural stands. The project is 

scheduled for implementation beginning in 2010 and lasting 10 years or more. 

1.5 Decision Framework

Given the purpose and need, the deciding official reviews the proposed action, the other 

alternatives, and the environmental consequences in order to make the following decisions:

Will the proposed action or one of the alternatives to the proposed action proceed as 

proposed or not at all?

If one of the alternatives proceeds:

What mitigation measures and monitoring requirements will apply to the project?

Will the project require a Forest Plan amendment?

1.6 Public Involvement

The Klamath National Forest published a Notice of Intent to prepare an Environmental Impact 

Statement for the Two Bit Vegetation Management Project on February 20, 2009 in the Federal 

Register, initiating the public scoping period for this project. A scoping letter was distributed 

asking for public input and comment on February 18, 2009. The letter was mailed to 

approximately 90 individuals, groups, agencies and tribal governments and posted on the 

Klamath National Forest website. The Forest Service held a public meeting in Happy Camp, CA 

on March 4 to discuss the project and a public field trip was held on June 22, 2009 to show 

interested individuals the project area, discuss proposed treatments and answer questions. Ten 

letters were received in response to the scoping effort and were used in conjunction with internal 

scoping comments from agency specialists to develop a list of significant issues. In addition, as 

part of the public involvement process, the agency participated in coordination meetings and 

discussions with the Karuk Tribe, the US Fish and Wildlife Service, the North Coast Regional 

Water Quality Control Board, the National Marine Fisheries Service and the American Forests 

Resource Council. Meeting notes from these agency coordination efforts are available in the 

project record. Appendix A includes a table that displays the consolidation of all comments 

received during scoping and how these comments have been addressed.

Using the comments from the public, other agencies, and tribes, the interdisciplinary team 

developed a list of issues to consider. 

1.7 Issues

The Forest Service separated the issues into two groups: significant and non-significant issues. 

Significant issues were defined as unresolved conflicts concerning alternative uses of available 

resources that is within the scope of the proposed action, relevant to the Decision to be made, 

supported by scientific evidence and has not already been decided by law, regulation or policy.

Non-significant issues were identified as those: 1) outside the scope of the proposed action; 2) 
Chapter 1 Two Bit Vegetation Management Draft Environmental Impact Statement

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already decided by law, regulation, Forest Plan, or other higher level decision; 3) irrelevant to the 

decision to be made; or 4) conjectural and not supported by scientific or factual evidence. The 

Council on Environmental Quality (CEQ) NEPA regulations explain this delineation in Sec. 

1501.7, “...identify and eliminate from detailed study the issues which are not significant or 

which have been covered by prior environmental review (Sec. 1506.3)...” A list of nonsignificant issues and reasons regarding their categorization as non-significant may be found in 

the project record. Appendix A contains a table that lists scoping comments received and how 

they were categorized.

The Forest Service identified the following significant issues during scoping

1.7.1 Water Quality, Fisheries and Cumulative Watershed Effects

Temporary road construction will increase road density and may result in increased sediment 

production and peak flow that could impact water quality and aquatic habitat, especially when 

combined with the existing high density of roads in the Indian Creek Watershed. Riparian 

Reserve function may be adversely affected by commercial thinning; particularly disturbance 

from tractor logging, and stream water temperature could be adversely impacted. The key 

indicators used to analyze this issue are: 1) Cumulative Watershed Effects model outputs; 2) 

Temporary road length and landings within stream course Riparian Reserves, location within 

sensitive subunit watersheds (as mentioned in the watershed analysis), trend in relation to 

baseline watershed condition; 3) Project effects to anadromous fish habitat, specifically 

sedimentation, channel geomorphology and stream temperature; 4) Compliance with Aquatic 

Conservation Strategy and adherence to Riparian Reserve standards and guidelines (see 

appendix D); and 5) Percent canopy cover retention along perennial streams 

An alternative that eliminates new temporary road construction (alternative 3, see Chapter 2) 

has been created to respond to this issue. 

1.7.2 Economics

Logging costs may be higher than the thinning log value. Lumber prices are currently low and 

there is concern that the timber value and volume projected from the Two Bit project may not be 

enough to provide a financially viable timber sale. In addition, the costs associated with creation 

of roads and road maintenance may be cost prohibitive, considering the revenue created by 

timber harvest. The key indicators used to analyze this issue are: 1) Economic modeling; and 2) 

Log value, logging costs, other project costs, and present net value

An alternative that maximizes the number of treatment units while reducing the associated 

road costs was preliminarily considered to respond to this issue, although was not developed 

further for analysis (titled Maximize Harvest, see Chapter 2). One aspect of the maximize 

harvest prescription development—treatments to increase the thinning interval, which would 

increase economic viability— has been added to all action alternatives.
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 1

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1.7.3 Air Quality and Prescribed Burning Implementation

The amount and location of proposed underburning may result in short-term but adverse impacts 

to local air quality due to the level of smoke produced, exacerbated by the tendency for smoke in 

these areas to settle in the basin. This can result in inconvenience and discomfort for residents 

that live along Indian Creek and in the town of Happy Camp, particularly those with allergies or 

breathing conditions. The amount of prescribed burning outside of treatment units may be 

difficult to feasibly implement, considering time and funding, other District work and the 

sensitivity of the area. The key indicators used to analyze this issue are: 1) Amount of 

particulates released; 2) Acres of burning and proximity to residential neighborhoods; and 3) 

Adherence to state air quality standards.

An alternative that reduces the amount of underburning and increases the non-burning slash 

treatments has been created to respond to this issue (alternative 4, Minimized Underburning, see 

Chapter 2).
14
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

15

Chapter 2. Alternatives, Including the Proposed 

Action

2.1 Introduction

This chapter describes and compares the alternatives considered for the Two Bit Vegetation 

Management Project. It includes a description of each alternative considered in detail, as well as 

those alternatives that were initially considered but not developed for further analysis. 

Alternatives considered in detail are compared based on alternative components and how well 

they achieve project objectives. A summary of the environmental effects of each alternative is 

included at the end of this chapter. 

2.2 Alternatives Considered in Detail

Alternative 1, the no action alternative, is a baseline for comparison of the action alternatives. 

Alternative 2, the proposed action was developed by the interdisciplinary team to respond to the 

purpose and need for action and the project objectives. Alternatives 3 and 4 were then developed 

to address issues raised by the public during scoping of the proposed action. This section 

discusses the no action alternative, the proposed action alternative and the additional two action 

alternatives. 

2.2.1 Alternative 1 - No Action 

Under the no action alternative, no ground disturbing activities would be planned in the Two Bit 

project area. Commercial thinning, specialized treatments (e.g. sanitation thinning or hardwood 

release), prescribed burning and road decommissioning would not be implemented to accomplish 

project goals. On-going routine management activities would continue in the project area under 

Alternative 1, guided by the Forest Plan. 

2.2.2 Alternative 2 - The Proposed Action

Alternative 2 would authorize approximately 9,530 acres of treatment across the 68,000 acre 

project area (Figure 41

The proposed action also includes specialized thinning treatments totaling 140 acres, 

including roadside sanitation thinning, roadside pole harvest and hardwood release treatments. In 

addition, approximately 160 acres of conifer-encroachment thinning would be conducted to 

enhance natural meadows. 

). Of this, underburning is prescribed across approximately 7,250 acres of 

National Forest System lands outside of thinning units (11percent of the project area, see figure 

4). Thinning is proposed for approximately 1,980 acres. Most commercial thinning is proposed 

for plantations; 315 acres (16 percent of proposed thinning) is proposed for natural stands. 

 1 Note: stream layers shown on the map (figure 4) have not been field verified; for field-verified stream 

locations, see Two Bit Hydrology Specialist Report (Bousfield 2010)
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

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These activities would occur in a variety of Forest Plan Management Areas including 

General Forest, Late Successional Reserves, and Riparian Reserves (see Table 2).

Implementation of alternative 2 is expected to last 10 years or more from the time the decision is 

made to completion of the project. This landscape-scale project is intended to provide forest 

products, maintain or improve forest health and reduce fuel hazard over a large area. 

Elements of alternative 2 are summarized in the table below. Appendix B displays treatment 

objectives for individual units.

Table 3. Acres of proposed treatments for alternative 2 

Total Acres that would be treated 9,530 acres

Underburning 7,250 acres

Commercial thinning 1,980 acres

Specialized Treatments 140 acres

Meadow Enhancement 160 acres

Road Decommissioning 4.1 miles in 6 segments

Temporary Road Construction 2.9 miles in 26 segments

Re-Opening/Reconstruction of Existing Temporary

Roads 4.3 miles

Landing Sites 250 landings needed (128 are existing); 122 new 

landings constructed totaling 60 acres

Mastication 0

Tree Thinning and Specialized Treatments

Proposed treatments include thinning of plantations and natural stands with subsequent fuels 

treatment. Specialized treatments are thinning pole-sized trees along roads in two locations, 

sanitation thinning to remove trees badly infected with dwarf mistletoe, and thinning to restore 

hardwoods. Timber products or other forest products would be produced from the thinning 

treatments.

Thinning would generally be from below where smaller trees with poor crowns would be 

removed to favor trees that are higher in the canopy with well developed crowns. There are 

several exceptions for groups of trees or for individual trees. At times, smaller trees would be left 

rather than larger trees in order to maintain species diversity, to remove some damaged or 

diseased trees from the stand, to remove off-site planted ponderosa pine, or where trees are too 

small to be thinned for timber products in this entry. In plantations there is less variation in the 

size of trees, and thinning would tend to be across all diameter classes. Trees of the same size 

within stands are often grouped together because of localized site conditions. In these cases, 

certain sized trees that are large compared to the other trees in one patch, might be the smallestsized trees to remove within a different patch.

Thinning would focus on trees larger than 10 inches in diameter, but many of the trees 

smaller than that would be removed or felled during thinning operations or during post harvest 

fuel treatment (see Underburning and Fuels Treatments below), or other stand improvement 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

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activities. Treatments would vary in the extent of thinning leaving some stands more open than 

others. See appendix B for more details regarding treatment objectives by unit.

Prescriptions for some stands would include a modified version of variable density thinning.

This type of thinning creates a fine scale mosaic pattern by thinning to different densities, 

creating openings, and leaving areas unthinned in small patches within a stand. Most stands 

would have free thinning prescribed to maintain desired species that are not shade tolerant such 

as sugar pine, California black oak and Pacific madrone. Free thinning removes competing trees 

from around the desired tree. For both the latter types of thinning, individual larger trees could 

be removed to meet the objectives.

The Forest Service identified approximately 1,980 acres of stands that are of a size, 

condition, and location suitable for thinning and producing commercial quality timber. Thinning

is proposed primarily for plantations, making up 84 percent of all acres proposed for this 

treatment. Commercial thinning is proposed for LSR, Managed Wildlife Areas, Special 

Management Areas, Riparian Reserves, Partial Retention and General Forest (table 5). Thinning 

proposed in LSR would occur only in plantations, which contain small inclusions or individual 

trees left from the original stand. Within LSR there are few trees over 20 inches in diameter and

these trees would not be cut except in a few cases where it is necessary to facilitate the thinning 

operations. Alternatives have been designed to comply with all applicable Management Area 

standards and guidelines.

Thinning treatments would be designed to maintain or improve the health and vigor of the 

stand. Diseased trees (e.g. dwarf mistletoe, heart and butt rots, etc.) would be targeted for 

removal, as long as overall resource objectives are met. However, snags and a portion of trees 

with decadent characteristics would remain where practicable, particularly in LSR. Firewood and 

other special forest products would be offered where feasible to help meet the thinning or fuels 

treatment prescriptions.

Whole tree yarding would result in creation of slash piles at landing sites. Piles would be 

burned at the landing, after piled material is made available for personal use fuel wood 

gathering. Heavy equipment may be used to pile the slash or slash would be hand piled where 

needed, particularly in areas where trees are limbed on site. The timing of underburning through 

thinned and adjacent stands would be coordinated with slash treatments after thinning.

Specialized treatments, including roadside sanitation thinning, roadside pole thinning, and 

thinning to restore hardwood stands, are proposed for 140 acres. These acres combined with 

commercial thinning totals 2,120 acres proposed for thinning. These specialized treatments make 

up a small percentage of the project area.

Pole harvest is proposed for 84 acres along roadsides that are heavily stocked with small 

diameter (less than 10 inch) trees. These areas are proposed for thinning to meet fuels objectives 

and would be made available to the local community through personal use pole permits.
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

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Sanitation harvest is proposed for 36 acres along a roadside that has dwarf mistletoe 

infestation. Thinning in these areas is proposed to remove a portion of trees with dwarf mistletoe 

to slow the spread to nearby healthy stands.

Thinning to restore hardwood stands is proposed for approximately 18 acres to reduce 

conifer competition with medium- to large-sized oak trees and other hardwoods.

Roads, Landings and Skid Trails

Approximately 2.9 miles of temporary roads in 26 segments located throughout the project area 

would be constructed to more efficiently remove thinned logs. All of the proposed road segments 

have been reviewed by IDT members and found to meet standards. Existing roads, skid trails and 

landings would be used whenever possible and practical to avoid new disturbance. 

Approximately 4.3 miles of pre-existing temporary roads would be re-opened/reconstructed.

Timber hauling would mainly occur on existing Forest System roads or on re-opened 

temporary roads, although some new temporary roads would be constructed to facilitate 

commercial thinning, as described in more detail below. Many Forest System roads in the project 

area are in good condition; however, some would require programmatic maintenance before 

proposed operations would begin in order to bring them up to current standards. Programmatic 

maintenance on Forest System roads is a routine action that is on-going and has been evaluated 

in a separate environmental analysis. Programmatic maintenance includes bringing roads up to 

safe condition for use and to ensure that impacts from road use would not leave the running 

surface (e.g. dip, ditch and culvert cleaning, dust abatement and grading). Earth scientists and/or 

road engineers would determine appropriate treatments if watershed health problems such as 

streams crossings with diversion potential are encountered on re-opened maintenance level 1 

road.

Gravel would be necessary for programmatic road maintenance and in some instances, for 

use of re-opened temporary roads or new temporary roads. There is an existing rock source 

(gravel pit) in the project area that would be used. Project design features for geology and 

noxious weeds include measures for minimizing the potential impacts of rock sources.

Existing skid trails and landings would be used whenever possible and practical to avoid 

new disturbance; however, new skid trails and landings would be required to facilitate thinning 

treatments under alternative 2. As shown in table 3, 250 landings would be required, and 122 of 

these would be new construction. Exact location and total acres of skid trails is not feasible to 

determine at this project planning stage; however it is estimated that fewer skid trails (less need 

for new skid trails and less frequent use of existing skid trails) would be necessary under 

alternative 2 than under alternative 3 due to the use of new temporary roads.

New skid trails with substantial cut and fills would generally not be developed, though safety 

and operational conditions may require a skid trail to cross short, steeper sections within tractor 

units. Some cut and fill may be necessary to safely cross these areas. Any skid trails with 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

19

substantial cut and fills would be reviewed by a geologist prior to construction to ensure slope 

stability. 

New temporary roads and landings would not be constructed in Riparian Reserves. New 

temporary roads would be built, used, and then hydrologically restored in the same season of use 

(prior to winter). Some reconstructed pre-existing roads and landings would occur in Riparian 

Reserves. New disturbance would be avoided in locations where sediment may directly enter 

streams. Rock would come from existing quarries located outside Riparian Reserves. Berms 

would be removed, and conditions which concentrate surface runoff would be eliminated on all 

temporary roads and re-opened existing roads. After use, reconstructed pre-existing roads would 

be hydrologically restored, and rock pits and quarries would be water-barred and shaped for 

drainage. 

Timber sale operators would be required to apply site-specific measures to road work to 

protect water quality. Any new temporary road alignments or skid trails with substantial cut and 

fills added during the implementation phase of the project would be reviewed by a hydrologist 

and geologist to ensure BMPs are properly applied. 

Logging Systems

The majority of the commercial thinning and specialized treatment units are proposed to be 

harvested using ground-based operations (mechanized harvest or conventional tractor skidding 

using feller bunchers and rubber-tired skidders). A small percentage would be cable-logged 

(including skyline and mobile yarders). No helicopter logging is proposed. Logging systems are

summarized in the table below and described in appendix C.

Table 4. Acres of logging systems for commercial thinning in alternative 2

Commercial Thinning Logging Systems Acres

Mechanical harvesting 719

Mechanical harvesting with Tractor Endlining 773

Handwork with Conventional Log Skidding and Tractor Endlining 35

Conventional Log Skidding with Tractor Endlining 339

Handwork Only 87

Cable Yarding 167

Total Thinning 2120

Meadow enhancement (no logging) 160

Total Silvicultural Treatments 2,280

Commercial Harvesting in Riparian Reserves

Riparian Reserves (RR) occur throughout about 18 percent of the project area within 170 feet of 

an intermittent or perennial stream, and extend to 340 feet from fish bearing stream reaches. 

Riparian Reserves are also established for inner gorges, unstable areas, and small wetlands. 
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

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Forests within RR in the project area, and in general, have a wide range of fuel loadings and 

vegetation conditions; past flood damage has left some riparian areas with sparse cover (USDA 

Forest Service1997).

Approximately 300 acres within Riparian Reserves are proposed for commercial thinning 

under alternative 2 (table 4) to achieve the objectives of late-successional stand structure and 

diversity over time, as well as fuel reduction of surface, ladder and crown fuels.

Standards and guidelines apply to silvicultural prescriptions in Riparian Reserve (see MA 10 

Goals in Chapter 1). Appendix B includes a table outlining the commercial thinning units’ 

generalized prescriptions, and identifies where Riparian Reserve thinning is proposed. Appendix 

C includes descriptions of how each alternative complies with the Aquatic Conservation 

Strategy. Riparian Reserve thinning would be conducted according to design criteria that ensure 

woody material is properly maintained, soil compaction and disturbance is minimized or 

eliminated, and important elements of the riparian environment are not degraded, as described in 

Table 13 at the end of this chapter.

Ephemeral streams that do not meet the Riparian Reserve definition ("...having a definable 

channel and evidence of annual scour or deposition"; page C-31; USDA Forest Service 2005) are 

not subject to the decision process outlined in figure 3 and will not be included in the acreage 

calculations in table 5. However, even ephemeral streams lacking annual scour are capable of 

transporting sediment and large wood to intermittent or perennial streams during upcoming flood 

events. Therefore, the project design features for water (table 12) will apply for all ephemeral 

streams regardless of whether they meet the Forest Plan definition of Riparian Reserve or not.

Yarding corridors are designed to avoid crossing streams, however should a crossing be 

necessary, logs would be fully suspended. Tractor skid trails would not cross streams except by 

agreement in rare cases during implementation. Remedial shaping and/or subsoiling of skid trails 

may be prescribed at that time. The decision process below outlines the course of action used to 

determine the Riparian Reserve prescription. Trees larger than prescription felled for operations 

or safety in Riparian Reserves would be retained on the ground unless to do so would pose an 

operational, safety or fuels hazard.
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

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Riparian Reserve Decision Process

1. Would thinning trees greater than 10 inches within this Riparian Reserve promote stand 

conditions needed to meet Aquatic Conservation Strategy Objectives over time/space?

If no, do not commercially thin this Riparian Reserve. Non-commercial thinning and/or 

underburning may still be prescribed depending on existing condition.

If yes, continue to 2.

2. Is this Riparian Reserve located within a plantation? 

If no, continue to 3.

If yes, consider commercial thinning throughout the plantation. Apply Best Management 

Practices and Soil Design Features including keeping tractors on slopes less than 35percent. 

Maintain buffer on Riparian Reserves as described in project design features in table 12.

3. The outer portion of the Riparian Reserve (as described in project design features in table 12) 

may be commercially thinned according to a site-specific prescription that maintains large trees 

and older forest connectivity. No commercial thinning would occur within wetlands, inner 

gorges and unstable areas.

Figure 3. Decision process for Riparian Reserve prescriptions

Meadow Enhancement

Meadow enhancement/restoration is proposed for 160 acres in order to maintain or enhance 

meadow conditions. Treatments would include cutting generally small diameter encroaching 

conifers, handpiling and burning, and limited use of prescribed fire. Cut trees would be left on 

site. No commercial products would be removed.

Underburning and Fuels Treatment 

Proposed prescribed burning activities include hand piling, burning small concentrations of 

debris and slash (jackpot), and low intensity burning under a forest canopy. These activities are 

designed to treat fuel accumulations created during proposed thinning treatments in thinned 

stands, and to reduce fuel loading and buildup of forest debris both within thinned units and 

outside of thinned units (Figure 4). Fuels treatment within thinned stands includes a combination 

of landing pile burning, underburning, hand pile burning and jackpot burning to burn debris. 

Approximately 2,000 acres of underburning in combination with landing pile burning is 

proposed within thinning units and 120 acres is proposed for hand pile burning. Meadow 

enhancement units (160 acres) would also be hand piled and pile burned. 

Outside of thinning units, approximately 7,250 acres of underburning is proposed over 

approximately a ten-year period. Non-commercial thinning of small trees and brush may occur 

within these large underburn areas as needed to promote effective fuel consumption. 
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

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Underburning outside of thinning units would occur within several Forest Plan Management 

Areas, including LSR, RR General Forest and other areas, as shown in the table below.

Table 5. Acres and percent of treatment area for treatments proposed under alternative 2 by Forest 

Plan Management Area

Management Area Underburning Acres and 

Percentage of Treatment Area

Silvicultural Treatment Acres

(does not include meadow 

enhancement) and Percentage 

of Treatment Area

Non National Forest 87 (1%) 0

MA-2 Wilderness 4 (<1%) 0

MA-5 Late Successional Reserve 1299 (18%) 125 (6%)

MA-6 Managed Wildlife Area 447 (6%) 1 (<1%)

MA-1,7,8 Special Management 13 (<1%) 23 (1%)

MA-10 Riparian Area (see 

hydrology specialist report (Bousfield 

2009) for field-verified stream course 

RR and percentages of proposed 

treatment area)

1601 (22%)

353 (17%)

MA-15 Partial Retention VQO 757 (10%) 363 (17%)

MA-17 General Forest 3042 (42%) 1255 (59%)

Total 7,250 2120

Burning operations would be accomplished according to burning and smoke management 

plans intended to meet management objectives and minimize the effects of smoke on adjacent 

communities and the public. Burning would usually be accomplished during times of high fuel 

and duff moisture levels, which limits the burning of large stumps and coarse wood and 

maximizes consumption of smaller-sized fuel.

Burning would occur during favorable weather conditions when smoke is transported away 

from sensitive locations. Slash piles would be constructed to burn with minimal smoke. 

Techniques include covering piles to keep them dry and limiting the amount of soil in the piles. 

For example, ignitions would be slowed or stopped if changing meteorological conditions cause 

smoke to intrude into sensitive areas, or burning may be undertaken on low visitor use days in 

the spring and avoided on high use weekends.

Smoke management plans would be submitted to the Siskiyou County Air Pollution Control 

District for each burn plan. Contingency actions would be undertaken if smoke impacts occur or 

meteorological conditions go out of prescription. Spot weather forecasts would be used to ensure 

favorable “within prescription” weather conditions for the burn itself and for smoke transport.

Underburning is recommended in the Watershed Analysis, LSR Assessment, and various 

Fire Plans. Underburning is also prescribed in Riparian Reserves to meet Aquatic Conservation 

Strategy (ACS) objectives (NWFP S&G FM-4, page C-36). 

The goal of management within Riparian Reserves includes maintaining and restoring 

riparian-dependent structures and functions, providing benefits to riparian-dependent and 

associated species, and maintaining consistency with Aquatic Conservation Strategy goals.
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

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Underburn prescriptions would be designed to result in low severity burns in Riparian Reserves 

so that these processes are maintained over time. Techniques such as allowing fire to back into 

Riparian Reserves and hand piling fuels on potentially unstable areas are methods for reducing 

underburn severity and impacts to other resources.

Specific problem spots, such as high concentrations of fuel located on unstable areas 

(particularly granitic areas), would be field reviewed by fuels and earth science personnel during 

development of the burn plan to implement appropriate burning prescriptions. Effective shade 

would be maintained in riparian areas.

Cumulative watershed effects would be considered in the amount of burning in any 7th field 

watershed during a three-year period (i.e., not all burning would occur at the same time and 

would be staggered across years to meet cumulative watershed objectives). 

Road Decommissioning 

Approximately 4.1 miles of existing Forest System roads are proposed for decommissioning. 

These roads were identified in 2004 through the roads analysis process as requiring excessive 

maintenance, having little value to future management projects, and contributing to unfavorable 

watershed conditions. Road density reduction was also a component of the recommendations 

made as part of the 1997 Indian Creek Watershed Analysis.

The Watershed Analysis did not provide an actual road density reduction figure; but made 

recommendations on road management in the Indian Creek Watershed. Since the Watershed 

Analysis was written, several projects have been undertaken or are planned to reduce road 

densities in this watershed through decommissioning, storm-proofing and hydrological 

stabilization including the Happy Camp Road Decommissioning Project (USDA Forest Service 

1999a), the East Fork Road Project (USDA Forest Service 1999ab) and the 2005 Mill Luther 

Watershed Restoration Project (USDA Forest Service 2005b). 

The proposed road decommissioning as part of this project would continue to implement the 

recommendations from both the watershed analysis and the roads analysis. In addition, road 

decommissioning is also a recommendation made in the 1999 Forest-Wide LSR Assessment 

(USDA Forest Service 1999c).
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

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Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

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Figure 4. Proposed activities for alternative 2 – proposed action
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

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Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

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2.2.3 Alternative 3 - No New Temporary Roads

Alternative 3 would authorize approximately 9,330 acres of treatment across the 68,000 acre 

project area (Figure 52

Figure 5

). Of this, underburning is prescribed across approximately 7,320 acres of 

National Forest System land outside of treatment units (11% of the project area, see ). 

Thinning is proposed for approximately 1,710 acres. Most commercial thinning is proposed for 

plantations; only 180 acres (11% of proposed thinning acres) is proposed for natural stands. 

Alternative 3 also includes specialized thinning treatments, totaling 140 acres, including 

roadside sanitation thinning, roadside pole harvest and thinning to restore a hardwood stand. In 

addition, approximately 160 acres of conifer-encroachment thinning would be conducted to 

enhance natural meadows. 

No new temporary roads would be constructed under alternative 3; however, 3.5 miles of 

pre-existing temporary road reopening/reconstruction would occur under (0.8 miles less than 

alternative 2). Skid trails and reopened roads would be used and then hydrologically restored

following treatment. 

These activities (see table 6) would occur in a variety of Forest Plan Management Areas, 

including General Forest, Late-Successional Reserves, and Riparian Reserves.

Implementation of alternative 3 would last approximately 10 years or more from the time the 

decision is made to full implementation. This landscape-scale project is intended to provide 

forest products, restore forest health and reduce fuel hazard over a large area. 

Elements of alternative 3 are summarized in the table below.

Table 6. Acres of treatments proposed for alternative 3

Total Acres that would be treated 9,330 acres

Underburning outside of thinning units 7,320 acres

Commercial thinning 1,710 acres

Specialized Treatments 140 acres

Meadow Enhancement 160 acres

Road Decommissioning 4.1 miles in 6 segments

Temporary Road Construction 0

Re-Opening/Reconstruction of Existing 

Temporary Roads 3.5 miles

Landing Sites 222 landings needed (126 are existing); 96 new landings 

constructing totaling 48 acres

Mastication 0

The primary differences between alternative 2 and 3 are the total acres treated with 

commercial thinning, temporary road construction, and underburning. All other aspects of 

alternative 3 (thinning and specialized treatment; meadow enhancement; and road 

 2 Note: stream layers shown on the following map have not been field verified; for field-verified stream 

locations, see Two Bit Hydrology Specialist Report (Bousfield 2010)
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

28

decommissioning) are the same as those previously described for alternative 2. Where there are 

differences between these alternatives, these differences are described below. 

Thinning and Specialized Treatments

Thinning on approximately 1,710 acres within Late-Successional Reserves, Riparian Reserves

and regulated lands that are of a size, condition, and location suitable for thinning from below 

are identified for alternative 3. Commercial thinning is proposed primarily for plantations, 

making up 89 percent of all acres proposed for this treatment. This alternative has been designed 

to comply with all applicable Management Area standards and guidelines (see table 2). 

Specialized treatments, including roadside sanitation thinning, roadside pole thinning and 

thinning to restore a hardwood stand are proposed for 140 acres, and are the same as described 

for alternative 2.

As shown in the table above, approximately 222 landings would be required, and 96 of these 

would be new construction. The total amount of skid trails needed, both in segments and total 

miles would be more under alternative 3 than alternative 2. Although exact location and total 

acres of skid trails is not feasible to determine at this project planning stage, it is estimated that 

more skid trails would be necessary under alternative 3 than under alternative 2 since no new 

temporary roads would be constructed under this alternative; skid trails can sometimes result in 

more short-term soil disturbance than temporary roads, as discussed in more detail in the soils 

section of Chapter 3.

Timber hauling would occur only on existing Forest System roads or on existing temporary

roads that are reopened or reconstructed and no new temporary roads would be constructed to 

facilitate commercial thinning. Haul routes on existing roads would receive maintenance where 

needed, such as dip, ditch and culvert cleaning, dust abatement and grading.

New skid trails with substantial cut and fills would generally not be developed; however 

safety and operational conditions may require a skid trail to cross short, steeper sections within 

tractor units. Some cut and fill may be necessary to safely cross these areas. Any skid trails with 

substantial cut and fills would be reviewed by a soil scientist, geologist, hydrologist or other 

earth science specialist prior to construction to ensure slope stability. 

New landings would not be constructed in Riparian Reserves. New disturbance would be 

avoided in locations where sediment may directly enter streams. Landings would be placed along 

the existing road system and new disturbance for landings would be minimized. Landing areas 

outside of existing roadbeds would be rehabilitated for proper runoff drainage, improved 

infiltration, and effective soil cover as prescribed by an engineer and/or earth scientist. This can 

include shaping the slope for better drainage, sub-soiling to 18 inches to break up compaction, 

and mulching/revegetation to provide short- and long-term cover.

Approximately 270 fewer acres of commercial thinning and 5 percent fewer natural stand 

treatments would occur under alternative 3 when compared to alternative 2 due to the deletion of 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

29

several units that would require excessive skidding or had difficult access without creation of 

temporary roads.

Logging Systems

As in alternative 2, the majority of the commercial thinning units under alternative 3 are 

proposed to be harvested using ground-based operations (mechanized harvest or conventional 

tractor skidding using bulldozers, feller bunchers and rubber-tired skidders). A small percentage 

would be cable-logged (including skyline and mobile yarders). No helicopter logging is 

proposed. Logging systems are summarized in the table below and described in appendix C.

Table 7. Acres of logging systems proposed for commercial thinning in alternative 3

Commercial Thinning Logging Systems Acres

Mechanical harvesting 683

Mechanical harvesting with Tractor Endlining 672

Handwork with Conventional Log Skidding and Tractor Endlining 35

Conventional Log Skidding with Tractor Endlining 265

Handwork Only 87

Cable Yarding 108

Total Thinning 1,850

Meadow Enhancement (no logging) 160

Total Silvicultural Treatments 2,010

Commercial Harvesting in Riparian Reserves

Commercial thinning is proposed in terrestrial-influence zones within RR to achieve the 

objectives of late-successional stand structure and diversity over time, as well as fuel reduction 

of surface, ladder and crown fuels.

Like alternative 2, standards and guidelines apply to silvicultural prescriptions in Riparian 

Reserves (see MA 10 S&Gs in Chapter 1). Appendix B includes a table outlining the commercial 

thinning units’ generalized prescriptions, and identifies where Riparian Reserve thinning is 

proposed (maps are available on the Website). Riparian Reserve thinning would be conducted 

according to design criteria that ensure woody material is properly maintained, soil compaction 

and disturbance is minimized or eliminated, and important elements of the riparian environment 

are not degraded, as described in Table 13 at the end of this chapter.

Other components of implementation of treatments within RR are the same as those 

described for alternative 2, including the use of the Riparian Reserve Decision Process (Figure 

3). 

Underburning and Fuels Treatment 

Proposed prescribed burning activities under alternative 3 are the same as those proposed for 

alternative 2; although there are differences in the amount of acres treated due to the differences 

in thinning units treated. Approximately 1,730 acres of underburning in combination with 
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

30

landing pile burning is proposed within thinning units, and 120 acres is proposed for hand pile 

burning. Meadow enhancement units (160 acres) would also be hand piled and pile burned. 

Outside of thinning units, approximately 7,320 acres of underburning is proposed over a tenyear period. Noncommercial thinning of small trees and brush may occur within these large 

underburn areas as needed to promote effective fuel consumption. Underburning outside of 

thinning units would occur within several Forest Plan Management Areas, including LSR, RR 

and General Forest, as shown in the table below.

Table 8. Acres and percent of treatment area for proposed treatment activities by Forest Plan

Management Areas for alternative 3

Management Area Underburning Acres

Silvicultural Treatment Acres 

(does not include meadow 

enhancement)

Non National Forest 87 (1%) 0

MA-2 Wilderness 4 (<1%) 0

MA-5 Late Successional Reserve 1299 (18%) 125 (6%)

MA-6 Managed Wildlife Area 447 (6%) 1 (<1%)

MA-1,7,8 Special Management 13 (<1%) 23 (1%)

MA-10 Riparian Area (see 

hydrology specialist report (Bousfield 

2010) for field-verified stream course 

RR and percentages of proposed 

treatment area)

1623 (22%)

297 (16%)

MA-15 Partial Retention VQO 759 (10%) 343 (19%)

MA-17 General Forest 3088 (42%) 1063 (57%)

Total 7,320 1852
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

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Figure 5. Proposed activities for alternative 3 – No temporary roads
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

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Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

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2.2.4 Alternative 4 - Minimal Underburning

Alternative 4 would authorize approximately 2,850 acres of treatment across the 68,000 acre 

project area (Figure 63

Alternative 4 also includes specialized thinning treatments, totaling 140 acres, including 

roadside sanitation thinning, roadside pole harvest and thinning to restore a hardwood stand. In 

addition, approximately 160 acres of conifer-encroachment thinning would be conducted to 

enhance natural meadows. 

). Of this, underburning is prescribed across approximately 570 acres of 

National Forest System lands (less than 1% of the project area, see figure 6). Thinning is 

proposed for approximately 1,980 acres. Most commercial thinning is proposed within existing

plantations; 315 acres (16% of proposed thinning) are proposed for natural stands. 

These activities would occur in a variety of Forest Plan Management Areas, including 

General Forest, Late-Successional Reserves, and Riparian Reserves (see table 9).

Implementation of alternative 4 is expected to last 10 years or more from the time the 

decision is made to completion of the project. This project is intended to provide forest products, 

restore forest health and reduce fuel hazard over a large area; although the total area treated 

under alternative 4 is substantially less than those proposed for alternatives 2 and 3, due to the 

reduction in underburning. 

Elements of alternative 4 are summarized in the table below.

Table 9. Acres of treatments proposed for alternative 4

Total Acres that would be treated 2,850 acres

Underburning 570 acres

Commercial thinning 1,980 acres

Specialized Treatments 140 acres

Meadow Enhancement 160 acres

Road Decommissioning 4.1 miles in 6 segments

Temporary Road Construction 2.9 miles in 26 segments

Re-opening/Reconstruction of Existing Temporary

Roads 4.3 miles

Landing Sites 250 landings needed (128 are existing); 122 new 

landings constructing totaling 60 acres

Mastication 1,490 acres

The primary difference between alternatives 2 and 4 is total acres treated with underburning. All 

other aspects of alternative 4 (thinning & specialized treatment; logging systems; roads, landings 

and skid trails; meadow enhancement; and road decommissioning) are the same as those 

previously described for alternative 2. Differences between these alternatives are described 

below. 

 3 Note: stream layers shown on the following map have not been field verified; for field-verified stream 

locations, see Two Bit Hydrology Specialist Report (Bousfield 2010)
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

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Underburning and Fuels Treatment 

Proposed prescribed burning activities under alternative 4 are substantially different than that 

described for alternatives 2 and 3. Approximately 505 acres of underburning in combination with 

landing pile burning is proposed within thinning units, and 120 acres is proposed for hand pile

burning. Meadow enhancement units (160 acres) would also be hand piled and pile burned. 

Mastication is proposed instead of prescribed burning to treat fuels within many thinned units to 

minimize the production of smoke. Mastication is proposed for 719 acres within thinning units. 

Mastication with some limited underburning is proposed for 773 acres, for a total of 1,490 acres 

of mastication. 

Outside of thinning units, approximately 570 acres of underburning is proposed over 

approximately a ten- year period. Noncommercial thinning of small trees and brush may occur 

within this underburn area as needed to promote effective fuel consumption. Underburning

outside of thinning units would occur within several Forest Plan Management Areas, including 

LSR, RR and General Forest, as shown in the table below.

Table 10. Acres and percent of treatment area for proposed treatments by Forest Plan Management 

Area for alternative 4

Management Area Underburning Acres and 

Percentage of Treatment Area

Silvicultural Treatment Acres 

(does not include meadow 

enhancement) and Percentage 

of Treatment Area

MA-5 Late Successional Reserve 0 125 (6%)

MA-6 Managed Wildlife Area 0 1 (<1%)

MA-1,7,8 Special Management 0 23 (1%)

MA-10 Riparian Area (see 

hydrology specialist report (Bousfield 

2010) for field-verified stream course 

RR and percentages of proposed 

treatment area)

265 (46%)

353 (17%)

MA-15 Partial Retention VQO 5 (1%) 363 (17%)

MA-17 General Forest 300 (53%) 1255 (59%)

Total 570 2120
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

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Figure 6. Proposed activities for alternative 4 –minimized underburning
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

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Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

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2.3 Summary of Best Management Practices (BMPs) and 

Project Design Features Common to All Alternatives 

This section summarizes the Best Management Practices and Project Design Features associated 

with the project, organized by resource. Some of these design features may be redundant to 

discussion about the alternatives above; however, they are repeated here to provide a 

comprehensive list.

2.3.1 Best Management Practices

Best Management Practices (BMPs) are developed to comply with Section 208 of the Clean 

Water Act. BMPs have been certified by the State Water Quality Resources Control Board and 

approved by the Environmental Protection Agency (EPA) as the most effective way of protecting 

water quality from impacts stemming from non-point sources of pollution. These practices have 

been applied in timber sales and road construction projects in watersheds over the last 25-30

years and have been found to be effective in protecting water quality within the Klamath 

National Forest. Specifically, effective application of the USDA Forest Service Region 5 BMPs 

has been found to maintain water quality that is in conformance with the Water Quality 

Objectives in the North Coast Regional Water Quality Control Board’s (NCRWQCB) Basin 

Plan.

USDA Forest Service Region 5 BMPs (USDA Forest Service 2000) have been monitored 

and modified since their original implementation in 1979 to be more effective. Numerous on-site 

evaluations by the NCRWQCB have found the practices to be effective in maintaining water 

quality and protecting beneficial uses/resources (e.g., domestic use, anadromous and resident 

fish). The Forest monitors the implementation and effectiveness of BMPs on randomly selected 

projects each year. BMP effectiveness requirements were met on 90-100 percent of the sites 

sampled in 2000-2007(USDA Forest Service 2009).

The following list of BMPs (table 11) was selected for the Two Bit Project and was obtained 

from the publication: Water Quality Management for Forest System Lands in California: Best 

Management Practices (USDA Forest Service 2000b). These BMPs would be implemented 

using design features described below and those described as part of the alternatives, and will be 

refined during burn planning and timber sale contract preparation and administrative processes. 

How each BMP would be implemented specific to this project is described in more detail in 

appendix E. The Forest Service also developed the following project design features (table 12) to 

be used as part of all of the action alternatives. 
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

38

Table 11. Best Management Practices selected for the Two Bit Project

BMP ID BMP Title

1.1 Timber Sale Planning Process

1.2 Timber Harvest Unit Design

1.3 Determination of Surface Erosion Hazard for Timber Harvest Design

1.4 Use of Sale Area Maps and/or Project Maps for Designating Water Quality Protection 

Needs

1.5 Limiting the Operating Period of Timber Sale Activities

1.6 Protection of Unstable Lands

1.8 Streamside Management Zone Designation

1.9 Determining Tractor Loggable Ground

1.10 Tractor Skidding Design

1.11 Suspended Log Yarding in Timber Harvesting

1.12 Log Landing Location

1.13 Erosion Prevention and Control Measures during Timber Sale Operations

1.14 Special Erosion Prevention Measures on Disturbed Land

1.15 Revegetation of Areas Disturbed by Harvest Activities

1.16 Log Landing Erosion Control

1.17 Erosion Control on Skid Trails

1.19 Stream Course and Aquatic Protection 

1.20 Erosion Control Structure Maintenance

1.21 Acceptance of Timber Sale Erosion Control Measures before Sale Closure

1.25 Modification of Timber Sale Contract

2.1 General Guidelines for the Location and Design of Roads

2.2 Erosion Control Plan

2.3 Timing of Construction Activities

2.4 Stabilization of Road Slope Surfaces and Spoil Disposal Areas

2.5 Road Slope Stabilization Construction Practices

2.7 Control of Road Drainage

2.11 Control of Sidecast Material During Construction and Maintenance

2.12 Servicing and Refueling Equipment

2.13 Control of Construction and Maintenance Activities Adjacent to Streamside Zones

2.14 Controlling In-Channel Excavation

2.16 Stream Crossings on Temporary Roads

2.17 Bridge and Culvert Installation

2.19 Disposal of Right-of-Way and Roadside Debris

2.21 Water Source Development Consistent with Water Quality Protection 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

39

BMP ID BMP Title

2.22 Maintenance of Roads

2.23 Road Surface Treatment to Prevent Loss of Materials

2.24 Traffic Control During Wet Periods

2.26 Obliteration or Decommissioning of Roads

5.6 Soil Moisture Limitations for Mechanical Equipment Operations

6.1 Fire and Fuel Management Activities

6.2 Consideration of Water Quality from Prescribed Burning Effects

6.3 Protection of Water Quality from Prescribed Burning Effects

7.8 Cumulative Off-Site Watershed Effects

2.3.2 Project Design Features

The following design features apply to all action alternatives. Table 12 displays these features by 

resource area and the land base affected.

Table 12. Project Design Features by resource area and where they apply

Design Features Land Base

Soil and Water

No more than 15 percent of a harvest unit would be disturbed by primary tractor skid 

trails, cable yarding corridors, landings and roads.

All commercial 

harvest units

85 percent of each harvest unit would meet the Regional soil quality analysis thresholds 

for total porosity, soil displacement, soil organic matter, soil hydrologic function, erosion 

and soil buffering capacity.

All commercial 

harvest units

Existing skid trails would be reused whenever practical. Existing skid trails would be used 

unless it is on a slope steeper than 35 percent, on an area where ground-based 

equipment is excluded or on highly erosive soils, unstable areas, wetlands or meadows.

All skid trail locations would be agreed to by the Forest Service. 

All commercial 

harvest units with 

skid trails

Skidding would generally not occur on slopes greater 35 percent. Slopes between 35 

percent and 45 percent within tractor logging units would be felled with a mechanical 

harvester (feller buncher) or by endlining from roads and skid trails.

All areas

Ground-based equipment (e.g. feller bunchers, masticators, tractors) would be restricted 

primarily to slopes of 35 percent or less. However, in certain situations, equipment would 

be allowed to operate on slopes up to 45 percent depending on site-specific conditions. 

All areas

Temporary roads would generally be constructed on ridgetops and flats and on slopes 

less than 20 percent that avoid positions that would deliver sediment directly to streams. 

Temporary roads would not be constructed on slopes greater than 35 percent.

All areas

Generally, new skid trails would not be developed on slopes greater than 35 percent or 

where ground-based equipment is excluded. Skid trails with substantial cut and fill would 

not be created except for short distances to connect benches as determined necessary 

by the Timber Sale Administrator and only when there are no other alternatives. Skid 

trails that connect benches in dormant landslide terrain may have minor sections on 

slopes greater than 35% but skid trails with substantial cut and fill would not be used to 

log slopes steeper than 35 percent. 

All commercial 

harvest units with 

skid trails

All skid trails would be hydrologically stabilized/restored prior to the wet season and/or 

following project implementation. Skid trails would be waterbarred within 25 feet of 

landings and roads, where needed. Waterbars would also be placed on all main skid trail 

sections that exceed 20% gradient. Spacing of waterbars would be a minimum of every 

100 feet or in accordance with Regional standards. Straw mulch or fine slash would also 

be used where needed.

All commercial 

harvest units with 

skid trails
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

40

Design Features Land Base

Skidding equipment and all ground-based equipment would operate during dry soil 

conditions following the wet weather logging guidelines. 

All commercial 

harvest units with 

skid trails

Existing landings would be used instead of creating new landings wherever feasible and 

all landings would be hydrologically restored after use. All areas

Pre-existing temporary roads would be used instead of constructing new temporary roads 

unless the pre-existing road is located on highly erosive soils, unstable areas, wetlands 

or meadows or if the pre-existing temporary road is located within the inner half of a 

stream course Riparian Reserve and adding surface aggregate would not eliminate or 

greatly reduce the risk of sedimentation.

All temporary roads would be hydrologically stabilized/restored prior to the wet season 

and/or following project implementation. Outsloping, waterbarring, berm removal, and 

slash cover would be used when needed, and roads would be blocked to vehicle access. 

Fills and culverts would be removed from channels. 

All commercial 

harvest units with 

temporary roads

Existing levels, or a minimum of 5 logs/acre of coarse woody debris (CWD) greater than 

20 inches in diameter and 10 feet long, if available, would be retained for soil productivity 

needs.

All areas

Existing CWD would be protected by having all ground-based equipment avoid the larger 

diameter logs as much as practical. 

All commercial 

harvest units

Where excessive numbers of downed trees creates a fuel hazard, existing logs (greater 

than 20 inches in diameter and 10 feet long) may be lowered down to the Regional 

minimum of 5 logs/acre (at the landscape scale; although efforts would be made to 

achieve this where possible at the stand level). 

All areas

Post-treatment total soil cover would range from 60-80 percent depending on slope 

steepness and soil texture. All areas

At least 50 percent cover, as fine organic matter (less than 3 inch material), would be 

retained in all units. All areas

Mulching with straw or fine organic matter would be used to minimize soil erosion and 

increase soil productivity in all heavily disturbed areas (include some skid trials and 

landings) to achieve 90 percent or greater cover that is two inches thick.

All areas

Main skid trails in units with projected ≥15% detrimental disturbance (23 units) will be 

evaluated post-project using detailed transects as well as field compaction data to 

determine their need for subsoiling. If subsoiling is required it will be done under dry soil 

conditions (dry down to 24 inches) with winged rippers to a depth of at least 18 inches.

Units 1, 2, 9, 12, 

18, 19, 20, 23, 

29, 49, 53, 64, 

67, 71, 87, 88, 

89, 203, 208, 

226, 237, 255, 

400

All burning would be done under an approved Burn Plan that specifies a burn prescription 

for each area. These prescriptions will account for fuel loading, fuel moisture, soil 

moisture, slope, aspect, etc., and will result in the desired quantity of fuel consumed for 

each prescribed burn. A fuel management specialist, who may utilize recommendations 

from a soil or earth scientist, will prepare prescriptions.

All underburning 

areas

Hand and machine bunching piles will be burned under safe conditions to prevent fire 

spread or excessive scorching of surrounding vegetation.

All underburning 

areas

Underburning would be accomplished in conditions that allow safe burning. Fire crews, 

equipped to control fire spread, will monitor underburning.

All underburning 

areas

Ground cover amounts recommended by Project soil scientist would be retained to keep 

erosion of the underburned sites within the limits of the burn plan and LRMP guidelines 

for soil cover.

All underburning 

areas

Underburning would be designed to ensure that high and moderate soil burn severity 

would not result. All underburning

Stream Course Riparian Reserves

Commercial harvesting in both natural and plantation stands would not occur in inner 

gorges.

Commercial 

harvest units in 

natural stands 

and plantations
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

41

Design Features Land Base

Commercial harvesting would not occur within 10 feet of ephemeral and intermittent 

streams

Commercial harvesting would not occur within 25 feet of a perennial stream 

Restrictions on commercial harvesting within Riparian Reserves of intermittent streams 

(that flow into June on an average water year) outside of the above 10-foot no-treatment 

zone would also apply unless certain criteria are met: 

1) Commercial harvesting would only occur within 10 to 50 feet of the stream if

current overstory canopy cover is equal to or greater than 85% and this 

overstory canopy cover would not be reduced below 85% 

2) Commercial harvesting would only occur within 50 to170 feet of the stream if

current overstory canopy cover is equal to or greater than 65% and this 

overstory canopy cover would not be reduced below 65 %

3) If overstory trees are not at their site potential height and/or site conditions do 

not allow attainment of the above canopy cover percentages then harvesting 

which would retain current overstory canopy cover or potentially enhance future 

overstory canopy cover may occur within 10 to 170 feet of the stream, upon 

consultation with a Hydrologist.

4) No restrictions on commercial harvest apply outside of the 170-foot buffer zone.

Restrictions on commercial harvesting near perennial streams outside of the above 25-

foot no-treatment buffer zone would also apply unless certain criteria are met: 

1) Commercial harvesting would only occur within 25 to 75 feet of the stream if 

current overstory canopy cover is equal to or greater than 85% and this 

overstory canopy cover would not be reduced below 85 % during harvest 

2) Commercial harvesting would only occur within 75 to170 feet of the stream if

current overstory canopy cover is equal to or greater than 65% and this 

overstory canopy cover would not be reduced below 65 % during harvest

3) If overstory trees are not at their site potential height and/or site conditions do 

not allow attainment of the above canopy cover percentages then harvesting 

which would retain current overstory canopy cover or potentially enhance future 

overstory canopy cover may occur within 25 to 170 feet of the stream, upon 

consultation with a Hydrologist.

4) No restrictions on commercial harvest apply outside of the 170-foot buffer zone.

Commercial 

harvest units in 

natural stands; 

units requiring 

canopy cover 

retention include

216; 227; 242; 

243; 244; 253; 

255 

Commercial harvesting would not occur within 10 feet of ephemeral and intermittent 

streams or within 25 feet of a perennial stream (does not apply to off-site pine).

Commercial 

harvest units in 

plantations

Commercial harvesting would not occur on active landslides or toe zones located within 

stream course Riparian Reserves (does not apply to off-site pine).

Commercial 

harvest units

All trees contributing to stream bank integrity or that overhang the stream channel would 

be retained.

Commercial 

harvest units

Harvesting would occur up to the edges of wetlands or meadows that are within or 

adjacent to commercial treatment units, where needed for meadow enhancement goals.

Commercial 

harvest units

Ground based equipment would not operate within a minimum of: 10 feet of ephemeral 

streams, 25 feet of intermittent streams and 50 feet of perennial streams - these 

distances are minimums and may be larger based on site conditions such as continuous 

slopes (> 20%) leading directly into the stream channel, slope breaks, low soil cover, 

unstable ground or erosive soils, to be determined by an Earth Scientist during unit 

layout.

Ground based equipment would not operate within in extremely unstable areas (as 

designated by a geologist), inner gorges or areas with highly erosive soils (as designated 

by a soil scientist); within 10 feet of meadows or wetlands that are within or adjacent to 

commercial treatment units; or on slopes greater than 35 percent in stream course 

Riparian Reserves. Trees may be harvested between the equipment exclusion and 

commercial harvest buffer by a feller buncher reaching in or tractor endlining.

Commercial 

harvest units
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

42

Design Features Land Base

Full suspension cable yarding would be used over stream channels and within 25 feet of 

stream channels and one-end suspension cable yarding would be used in the remainder 

of the surrounding stream course Riparian Reserves.

Commercial 

harvesting with 

cable yarding

No new landings would be constructed within stream course Riparian Reserves and new 

landings would be preferred over pre-existing landings if the existing landing is located in 

a stream course Riparian Reserve or on erosive soils or unstable areas. All landings 

would be re-contoured and hydrologically stabilized prior to winter and/or following 

project implementation.

Commercial 

harvesting units 

with landings

Primary skid trails would generally be at least 50 feet from stream courses; any 

exceptions to this would be approved by an Earth Scientist. 

Secondary skid trails would only cross ephemeral and intermittent streams when dry and 

in locations approved by an earth scientist.

Commercial 

harvesting units 

with skid trails

Temporary roads would not be constructed within stream course Riparian Reserves.

Commercial 

harvesting units 

with temporary 

roads

Predominant/relic or large dominant trees that are not marked for thinning, but are felled 

for operations or safety in Riparian Reserves would be retained on the ground unless to 

do so would pose an operational, safety or fuels hazard.

All areas

Except for controlled ignition to reduce fuel accumulations that, in the case of wildfire, 

could cause moderate to high burn severity, ignition of prescribed fire would generally not 

occur in the inner half of stream course Riparian Reserves or inner gorges; prescribed 

fire would be designed to mimic a backing fire in these areas as much as possible. 

All areas with 

underburning

Pile burning would not occur within 25 feet of any stream course. All areas

Prescribed fire would be designed to mimic a backing fire in the inner half of stream 

course Riparian Reserves or inner gorges. 

All areas with 

underburning

The steep portions of Unit 22 west of Road 18N43 would be excluded from treatment to 

break in slope; A newly constructed temporary road is preferred over an existing 

temporary road in this location due to proximity to a stream.

Unit 22

One culvert and crushed rock (aggregate surfacing) would be used for existing temporary 

road. Unit 29

Steep portions would be excluded in western portion of unit and stream channel would 

not be crossed with equipment. Unit 30

Tom Gray Gulch would be buffered to the north within 10 feet of gorge/break in slope Unit 33

Commercial harvesting would be restricted to the western half of the unit only and would 

not occur within 50 feet of landslide scarp. Skidding would not occur across scarp down 

to Road 18N33B.

Unit 56

Tom Gray Gulch would be buffered to the south within 10 feet of break in slope. Unit 66

Road 17N02 would be surfaced with crushed rock (aggregate) near stream. Unit 94

Stream would be buffered 170 feet. Unit 216

Incised channels would not be crossed with equipment. Unit 244

Portion of unit between Indian Creek mainstem and Road 19N07 would be burned in the 

spring to the maximum extent practical. Underburn Unit 1

Portion of unit bordered by West Branch Creek, Sutcliffe Creek and Road 18N30 and FS 

Highway 48 would be burned in the spring to the maximum extent practical. Underburn Unit 2

Portion of underburn between Indian Creeks mainstem (east) and 18N30 (west) would be 

burned in the spring to the maximum extent practical. Underburn Unit 3

Geology

Temporary roads and landings would not be constructed within geologic Riparian 

Reserves

Harvest units 

with temporary 

roads or landings
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

43

Design Features Land Base

In particularly sensitive areas (as defined by a geologist), proposed roads and landings 

would be jointly reviewed by earth science, timber administration, and engineering 

personnel to assess landslide risk and to resolve potential conflicts. If deemed necessary 

by reviewers, the alignment would be flagged and reviewed in the field. Design measures 

would be developed to increase stability of cuts and fills and eliminate conditions that 

concentrate runoff and protect water quality. 

active landslides

(units 242, 19, 

41, 20, 220, 30, 

112, 115, 258, 

101, 109, 86, 89, 

95); inner gorges

(243, 214, 216, 

59, 46, 6, 42, 41, 

43, 8, 64, 61, 11, 

22, 227, 12, 24, 

55, 18, 28, 33, 

36, 71, 302, 75, 

101, 105, 80, 78, 

77, 94, 96, 219, 

90) and toe 

zones of dormant 

landslides(units 

238, 118, 16)

If rock is needed for the project, rock pits would be evaluated by a geologist on site 

before development. The assessment would address landslide potential, sediment 

delivery potential, asbestos hazard, quantity and quality of material, and potential for 

underlying caves or tunnels. Rock pits would avoid Riparian Reserves, and would be 

water-barred and shaped for drainage after use. Rock quarry development plans would 

be prepared if more than 5000 cubic yards of material were removed from a quarry or 

where further resource damage may occur.

All areas

Treatments in geologic riparian reserves would meet the objectives of the Aquatic 

Conservation Strategy (ACS). All areas

Ground-based equipment would not be used within the unstable land component of 

geologic Riparian Reserves.

Prescribed fire in geologic Riparian Reserves would be low severity. There may be rare 

exceptions where small areas (less than an acre) may burn at high or moderate severity 

due to localized heavy fuel accumulations. The following activities would minimize this 

risk: a) Geology personnel would inform fire personnel of any known active landslides or 

unstable areas are covered with heavy fuels, and coordinate in development of burn 

plans; b) Ignition patterns would be modified, and local fuel concentrations hand piled 

within sensitive landslide areas and other types of Riparian Reserves; c) Prescribed fire 

would generally be backed down into Riparian Reserves and ignition would generally not 

occur there. However, there may be exceptions where the goal of low severity can best 

be met by allowing ignition within Riparian Reserves.

Underburn units

Purchasers of the timber sale would be informed of harvest units and roads underlain by 

ultramafic rock which may contain asbestos. If timber haul routes change during project 

implementation, any additional roads would be checked against the bedrock map to 

determine if they are underlain by ultramafic rock, and the asbestos standards applied.

Standard mitigation measures would be applied, including watering roads during use, 

surfacing with material which does not contain asbestos, and use of OSHA-approved air 

filtering apparatus. Crews constructing fire lines for underburns would similarly be 

informed of areas underlain by ultramafic rock. Mitigation measures would be applied, 

including constructing lines during wet soil conditions, watering lines as appropriate, and 

using OSHA-approved air filtering apparatus.

All areas

Cable yarding corridors would not be placed in geologic Riparian Reserves unless 

assessed in the field by an earth scientist.

Full suspension cable yarding would be used in geologic Riparian Reserves. Outside of 

geologic Riparian Reserves, one-end suspension would be used. 

All areas with 

commercial 

harvest with 

cable logging

Gouging (as a result of logs dragged during one-end suspension) would be water barred 

and covered with logging slash to effectively mitigate erosion and concentration of 

surface runoff. 
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

44

Design Features Land Base

Timber Preparation and Earth Science shops would establish contact prior to the marking 

of units to assure that prescriptions in Riparian Reserves are properly implemented.

Similar coordination would be needed to address any post-planning changes in project 

design. Fire and Earth Science shops would closely coordinate burn plans affecting 

Riparian Reserves. After the sale is sold, the Sale Administration and Earth Science 

shops would establish and maintain contact to allow for field reviews of final flagged road 

alignments and landings as needed.

All areas

Forest Vegetation

Hardwoods would be maintained in thinning units where possible and as needed to meet 

the desired condition. Some larger hardwoods designated by the prescription would have 

competing trees removed from around them to a distance of 25 to 35 feet.

All commercial 

harvest units

Relic and predominant trees within thinning units would be maintained through guidelines 

in the silvicultural prescriptions or by designating them as leave trees.

All commercial 

harvest units

Where appropriate for the site, sugar pine and naturally occurring ponderosa pine would 

be maintained within thinning stands through measures in the silvicultural prescriptions or 

by designating them as leave trees.

All commercial 

harvest units

Approximately 200-300 Port Orford-cedar seedlings would be planted in wet areas where 

the cedar is now being partially replaced by Douglas-fir. Unit 22

Port Orford-cedar would have increased protection from exposure to root disease by 

including measures that require contractors and purchasers coming from areas within the 

natural range of Port Orford-cedar to wash all vehicles and equipment before entering the 

project area

All areas

Identified sugar pine known to be blister rust resistant would be protected during 

underburning by brushing around the tree and/or constructing fire line around the tree 

prior to burning 

1-2 trees located 

in the north 

portion of 

Underburn 1

Protection and/or enhancement measures for areas of weeping spruce, Port Orfordcedar, Pacific yew and western white pine trees would be incorporated into site-specific 

prescriptions, where appropriate. 

Underburn 2

Port Orford-cedar would have increased protection from exposure to root disease by 

including measures that require contractors and purchasers coming from areas within the 

natural range of Port Orford-cedar to wash all vehicles and equipment before entering the 

project area and through measures taken to restrict operations during wet months on 

designated road segments within units.

Units 22, 24, 55, 

206, and 94; 

Road 17N39A, 

18N33B, and 

18N43 between 

Unit 22 and 24, 

and 18N43A

Three genetic test areas located within Underburn Unit 2 would be excluded from 

underburning treatments Underburn 2

Borax –True fir stumps over 14 inches in diameter would have borax applied to them 

after cutting to reduce colonization of annosus spores. Borax would not be applied within 

5 feet of stream courses or 5 feet of sensitive plants. 

Approximately 

403 acres that 

include a 

majority of the 

natural stands 

and plantations 

mostly in the 

higher elevations 

in the north and 

western portions

of the project 

area

Fisheries

Water drafting in streams that support salmon and steelhead would be performed in 

accordance with National Marine Fisheries Service water drafting specifications (USDC 

2001) designed to prevent adverse direct and indirect effects to anadromous salmonids 

by requiring intakes to be screened to prevent entrainment of fish, and by limiting rate of 

water drafting. Existing water drafting sites would be used and no new water drafting 

sites would be constructed.

All areas with 

perennial 

streams that 

support salmon 

and steelhead

Terrestrial Wildlife
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

45

Design Features Land Base

Protocol surveys for northern spotted owls (NSO) will be conducted in 2009 and 2010. 

For areas that include removal or downgrade of NSO habitat, surveys would be 

conducted to the 1992 U.S. Fish and Wildlife protocol. In areas where habitat would not 

be removed or downgraded, a three visit year of action survey may be substituted for the 

1992 protocol surveys. These areas would be primarily thinning in non-suitable NSO

habitat and underburns.

All areas

A seasonal restriction of February 1st to September 15th would apply to all activities that 

modify NSO habitat (including activities that degrade or are beneficial) within 0.25 mile of 

a NSO activity center or unsurveyed suitable habitat. This same restriction also applies to 

activities that remove or downgrade suitable habitat within 0.7 miles of an activity center 

or unsurveyed suitable habitat. A seasonal restriction of February 1st to July 9th would

apply to all activities that create noise above ambient levels within 0.25 mile of an 

occupied activity center or unsurveyed suitable habitat.

A seasonal restriction of February 1st to July 31th would apply to all activities that create 

smoke within 0.25 mile of an occupied NSO activity center or unsurveyed suitable 

habitat.

All areas

If protocol surveys indicate that historic NSO activity centers and/or suitable habitat are 

not occupied by breeding NSOs, seasonal restrictions may be waived.

Prescribed burning will not be implemented in more than 50 percent of a northern spotted 

owl’s 0.5 mile activity center or 1.3 mile home range in any given year. The Wildlife 

Biologist would coordinate with Fuels Specialist on this measure.

All areas

When burning in spring, smoke would be managed so that light to moderate smoke is 

present within a canyon or drainage but dissipates or lifts within 24 hours. If heavy or 

concentrated smoke begins to inundate occupied NSO nesting/roosting habitat or 

occupied activity centers late in the afternoon, ignition would be discontinued.

Underburning

units

No more than 50 percent of the nesting NSO habitat within a 7th field watershed would 

be under-burned within a given year All areas

No more than 50 percent of the suitable habitat within an occupied NSO core area and 

no more than 50 percent of the suitable habitat within an occupied NSO home range 

would be under-burned annually.

Underburning

units

Review of underburns post treatment would be conducted by the district biologist to 

determine amount of NSO habitat degradation. If treated areas are determined to have 

not degraded NSO habitat, then a greater number of acres may be underburned within 

an NSO core, home range or 7th field watershed.

Underburning

units

In unsurveyed “high probability” habitat and known NSO activity centers, no burning 

would occur between 2/1 and 7/9 or spring surveys would be conducted during the year 

of activity (3 visits prior to action, starting after March 1 with visits at least 5 days apart)

Underburning

units

Protect existing course woody debris by having ground-based equipment avoid large 

diameter logs greater than 20 inches and 8 feet long as much as practical. Where 

excessive number of downed trees creates a fuel hazard, existing logs may be lowered 

down to the Regional minimum of 5 logs/acre across the landscape. 

All commercial 

thinning units

Snags greater than 20 inches dbh or groups of snags would not be felled unless 

hazardous to operations. Some wildlife trees greater than 20 inches dbh that posses 

multiple tops, broken tops, cavities or other wildlife features would be maintained with the 

units.

All commercial 

thinning units

Surveys for blue grey tail dropper (BGTD) would be conducted in all riparian reserves 

that are located within proposed units of natural stands prior to harvest of natural stands.

If surveys locate any BTGD, locations would be protected from ground-disturbing 

activities in accordance with forest sensitive species protocol and surveys would be 

conducted in all suitable habitat within proposed units. For known locations of BGTD

project design features have been developed to minimize the likelihood of adverse 

impacts to this occupied habitat

Natural stands

Avoid use of landings and skid trails in the western edge of the unit to minimize 

disturbance to BGTD habitat Unit 116
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

46

Design Features Land Base

Goshawk surveys would be conducted in and around historic goshawk nest locations. If 

nesting goshawks are located a 0.5 mile radius circle buffer (504 acres) would be 

established around nest location. Sixty percent canopy cover in dense mature forest 

conditions (greater than 60% canopy cover with trees greater than 24 inches dbh (4B, 

C+) would be maintained. The remaining 40 percent would be maintained in a mosaic 

dominated by large trees with open understory (3N, G-4P, N G+). Habitat modifying 

activities would be restricted between March 1 and August 31 within the primary nesting 

zone (504 acres). Loud and continuous noise within 0.25 miles of active nests would also 

be restricted between March 1 and August 31 annually. 

All units

Cultural Resources

Flag and avoid all archeological sites with potential to be affected by proposed activities. All areas

Consider cultural use plants when developing prescribed burn plans, including burning 

that would enhance Hazel and Beargrass that are used in traditional Karuk baskets.

Underburning

Units

If previously unidentified cultural resources are located during project activities, all work 

would stop within the area of the site and the Heritage Resources Program Manager for 

the Klamath National Forest would be contacted.

All areas

Lands / Special Uses / Implementation

Where feasible, post-logging slash piles and cull decks in certain areas would be made 

available for firewood removal by the public. All areas

A buffer zone around the spring and waterline near Deadman Point located in Underburn 

Unit 3 would be designated and then excluded from treatment Underburn Unit 3

Water would be used on roads when needed to minimize dust generation during 

implementation All areas

Fuels and Air Quality

Project implementation would adhere to applicable State of California and State of 

Oregon air quality laws and regulations. All burn areas

Smoke management plans would be submitted to the Siskiyou County Air Pollution 

Control District for each burn plan. Burning would occur during favorable weather 

conditions when smoke is transported away from sensitive locations. 

All burn areas

Burning would be conducted to meet course woody debris standards and guidelines. 

Spot weather forecasts would be used to ensure favorable “within prescription” weather 

conditions for the burn and for smoke transport.

All burn areas

Prescribed burn plans would include measures to avoid unacceptable conditions related 

to smoke concentrations, duration, and placement. All burn areas

All burning would be conducted under an approved Burn Plan that specifies a burn 

prescription for each area. These prescriptions would account for fuel loading, fuel 

moisture, soil moisture, slope, aspect, etc. so that the desired quantity of fuel consumed 

for each prescribed burn would result. A fuel management specialist, using 

recommendations from soil or earth scientist, would prepare prescriptions. 

All burn areas

Landing and hand piles would be burned under controlled settings to contain fire spread. All burn areas

Underburning would occur under prescription, when conditions allow for safe burning 

operations. Fire crews, equipped to control fire spread, would monitor underburning. All burn areas

Burn prescriptions would be developed with interdisciplinary team input and approved by 

a line officer. All burn areas

Visual Resources

Tree marking paint would not be visible on trees seen from Road 18N30 to the break in 

slope (at eye level from the road); A post-burn review would be conducted to determine 

the need for flush cut stumps; variable spacing up to a 30-foot maximum, would be used 

for thinning and white fir would be favored for removal; and precommercial thinning to 20-

foot spacing within 20 feet of the road would be used.

Unit 22

Variable density thinning would be used with variable spacing and variable species 

removal and stumps would be cut as close to the ground as possible.

Meadow 

enhancement 

Unit 5

Threatened, Endangered and Sensitive Plants

If any new threatened, endangered or sensitive species populations are discovered 

during project implementation, a botanist would be notified to determine if any additional 

protective measures are necessary.

All areas
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

47

Design Features Land Base

Soil productivity standards would be applied for conservation of surface organic matter 

and large woody material to maintain sensitive fungi habitat components All areas

Aquatic Conservation Strategy and Riparian Reserves Objectives would be adhered to in 

order to maintain species diversity and sensitive fungi habitat components. Silvicultural 

practices in Riparian Reserves would be used to control stocking, reestablish and 

manage stands, and acquire desired vegetation characteristics including species 

diversity needed to attain Aquatic Conservation Objectives. Yarding disturbance within 

Riparian Reserves would be minimized.

All areas

Klamath Mountain buckwheat (Eriogonum hirtellum): Protect all individuals and habitat; 

buffer if necessary to keep equipment off plants and habitat; no-cut buffer not needed.

Only allow low-intensity broadcast prescribed burn. No fireline construction in 

occurrences.

UB-3 and UB-4

Pacific fuzzwort (Ptilidium californicum): Do not-cut individual host trees, and thin thru 

occurrence to 50-60% canopy closure; OR avoid/protect subpopulation in each unit with 

buffer and allow impacts to outlier plants. Hand pull heavier slash in occurrence prior to 

prescribed burning.

Units 200, 201, 

211, 213, 214, 

216,219, 220, 

227, 228, 238, 

242, 243

Clustered lady's slipper orchid (Cypripedium fasciculatum): Protect individual plants 

from direct effects; thin through occurrence to 50-60% canopy closure – end line or 

helicopter log removal only; OR avoid/protect subpopulation in each unit with buffer; 

allow impacts to outlier plants. Only allow low-intensity broadcast prescribed burn 

through populations. 

Unit 302

Howell’s lousewort (Pedicularis howellii): Protect individual plants from direct effects; 

thin through populations to 50-60% canopy closure – end line log removal only; OR 

avoid/protect subpopulation in each unit with buffer and allow impacts to outlier plants. 

Only allow low-intensity broadcast prescribed burn through populations.

Meadow 

Enhancement 

Unit 5

Species-specific mitigations for additional Sensitive/ Survey and Manage plant 

occurrences located during implementation would be followed. For these and the above 

species, district botanist would flag any needed buffers before timber marking

All areas

Avoid placing hand piles and thinning slash directly in meadow areas or on sensitive 

plant populations

Meadow 

enhancements

When fire is prescribed in meadow areas, only low-intensity broadcast burning would be 

used. Fire ignition within meadow areas would mimic natural fire spread with limited drip 

torch use. Drip torches would not be used in wet meadow areas. The district botanist 

would be consulted for further direction. 

Meadow 

enhancements

Noxious Weeds

Equipment would be cleaned to reduce introduction of noxious weeds All areas

Vehicles would not be parked and equipment would not be staged in areas where weed 

populations are known to occur whenever possible. Areas to avoid within the project 

analysis area are to be provided to all implementation staff and contractors.

All areas

Wherever seed, straw mulches or gravel is used to restore or maintain areas within the 

project area, certified weed free seeds straw, mulches, and/or gravel should be specified 

in any contract.

All areas

Seed decommissioned roads, landings, and heavily used skid trails with native grass 

seed and/or non-persistent/sterile cereal grains as needed. All areas

As part of the Forest noxious weed program, inventories for noxious weeds would occur 

for 3 years after the project is completed or as long as it takes the vegetation to recover 

from project disturbance (as measured by ground duff cover and forb and shrub layer 

cover).

All areas

Avoid direct disturbance to the weed populations of Dyers woad (Isatis tinctorum), Scotch 

broom (Cytisus scoparium), Meadow Knapweed (Centaurea pratensis), Star Thistle 

(Centaurea solstitialis) and Spotted Knapweed (Centaurea maculosa)

All areas

Follow species-specific mitigations for additional non-native/invasive plant occurrences

located during implementation. All areas
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

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2.4 Monitoring Common to All Alternatives

Areas underburned would be monitored following treatment to determine how much and 

with what fire intensity northern spotted owl habitat was burned 

Known northern spotted owl sites would be monitored annually through 2011. 

Historic northern goshawk sites would be monitored through 2011.

Best management practice monitoring would be conducted according to USDA 2002 and 

would occur on a random sample. Since many of these actions would not occur all at once, 

they may be included in monitoring pools for up to a decade.

Stream shade on perennial and large intermittent streams adjacent to plantation riparian 

reserves would be monitored to determine whether project design features were successful in 

meeting residual shading requirements 

Marking of trees for harvest or poles would be monitored by District personnel to ensure that 

tree marking guidelines are followed and meet planned objectives.

Timber harvest operations would be monitored by qualified sale inspectors and other District 

personnel to ensure that project design features and BMPs are implemented appropriately 

and that unacceptable levels of damage would not occur.

Prescribed burning activities would be monitored for consistency with burn plans and 

achievement of project objectives. Hand work would be monitored during implementation 

by District contract inspectors. 

After thinning and after fuels treatment, some units would be informally reviewed to see 

how well they met stand objectives. In stands where the objectives include reducing 

ponderosa pine and increasing other species, natural regeneration of desired species would 

be monitored.

Natural regeneration before and after underburning would be monitored in several units 

including Units 3, 11, 51, 64,95, 99,201, and 227. 

Post-project implementation monitoring for noxious weeds would occur in order to detect 

any new sites established within the project area and to quickly treating these areas

Treated riparian reserves would be monitored to evaluate the implementation and 

effectiveness of project design features. 

In the event of a landslide-producing storm in the years following the activity the Riparian 

Reserves would be monitored for landslide response. In particular, such monitoring would 

examine landslide rates in thinned areas relative to undisturbed (unlogged) sites.

Surveys would occur in areas deferred from archeological survey due to heavy impenetrable 

brush that have a high probability to yield cultural sites, after brush has been removed.

2.5 Alternatives Considered but Eliminated from Detailed 

Analysis

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

reasonable alternatives and to briefly discuss the reasons for eliminating any alternatives that 

were not developed in detail (40 CFR 1502.14). 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 purpose and need, 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

49

duplicative of the alternatives considered in detail, or determined to be components that would 

cause unnecessary environmental harm. Therefore, a number of alternatives were considered, but 

dismissed from detailed consideration for reasons summarized below.

2.5.1 Maximize Harvest 

This alternative was developed to respond to the significant issue of economics and includes 

suggestions made by members of the public. The re-entry period would be increased to 30-40 

years (instead of 20-30 years) particularly in plantations. Aim for canopy and stocking 

guidelines, harvest unit location, numbers of harvest units and harvest system design that 

together combine to optimize the economic potential for prospective bidders while at the same 

time meeting the specified purpose and need. 

USFS agrees that a longer re-entry period for plantations is a reasonable way to increase the 

economic potential of the sale while also reducing the resource impact from more frequent 

entries under a 20-30 year rotation period. A longer rotation period (30-40 years instead of 20-30 

years) for some plantations (where the IDT agreed this could be achieved while still meeting the 

standards and guidelines of the Forest Plan) is included in alternative 2 - proposed action. The 

other aspects suggested (unit spacing, harvest design, etc.) are already aspects of project design 

and prescription development routinely used by the USFS. These are considered in context with 

the standards and guidelines in the Forest Plan and other guiding documents. For these reasons, 

this alternative was dismissed from further detailed analysis. 

2.5.2 Citizens Alternative 

This alternative was specifically suggested by the public and includes using only the existing 

road system and previous skid trails, no treatment in natural stands in T19E, R6E sections 34-35, 

post-harvest prescribed fire, underburning, riparian reserves treated only with hand-work, 

helicopter yarding or using existing skid trails, and reducing road densities. The specific 

components of this suggested alternative are addressed separately below, as follows:

Use only existing road system and previous skid trails: Using only the existing road 

system is addressed by alternative 3; however, it is not feasible to use only existing skid trails for 

this project. There are few remaining skid trails in plantations; these were dozer piled and 

planted over in the past and are difficult to locate in many instances. All action alternatives 

include the use of existing skid trails when they can be located and when their use would 

minimize new ground disturbance. This recognizes that some existing skid trails, when they can 

be located, are not necessarily in the best location to minimize new ground disturbance; in some 

instances creating a new skid trail in the proper location would result in less soil erosion than 

using an existing skid trail that is in a bad location (e.g. position on slope, soil type, landslide 

area that could create additional problems). Operations would only occur when soils are dry and 

use would be meet standards. Skid trails would be kept to 15 percent or less of an area and feller 
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

50

bunchers would be used whenever possible since they result in less pressure and thus less 

potential to compact soil. For these reasons, using only existing skid trails was dismissed from 

further detailed analysis. 

Native unlogged (or lightly logged) fire-suppressed stands on moderate slopes (natural 

stands) that have existing logging road access are thinned from below (retaining 60% 

canopy and all large diameter and late-successional trees) and yarding using the least 

damaging method practicable: Stands selected for treatment based on existing road access is 

addressed by alternative 2. Some natural stands such as units 211, 212, and 213 are extremely 

dense and silvicultural prescriptions designed to reduce density that would be applied to these 

units would leave canopy cover above 60 percent. Other natural stands are less dense and have 

either areas of thinner soil with less stocking or have open areas due to past harvest (e.g. units 

208, 225, 243) In these units, thinning of clumps and dense patches to below 55percent of 

maximum stand density index for a period of 20-30 years would bring the canopy cover to less 

than 60 percent. Most stands would likely remain between 50 percent and 60 percent canopy 

cover. Some natural stands (e.g. unit 400 and portions of unit 234) would have heavy thinning in 

order to restore stand structure for oaks, other hardwoods, and older pine; a canopy cover of 60

percent would not provide the open structure necessary to enhance conditions for those species.

Thinning is generally from below (see description of thinning in this chapter). The predominant, 

relic/legacy, dominant, and the best co-dominant trees would be maintained within stands. In 

order to meet the desired stocking levels, which would help maintain the health of older trees, 

some trees that may be considered “large” by some may need to be removed. Relative to the 

other trees within areas of localized competition, the largest trees with the best crowns would be 

left.

No treatment in natural stands in T19N, R6E, Sections 34-35: These seven natural stands 

are accessible by the existing road system and are dense stands in need of thinning. They all 

occur in General Forest and Partial Retention Forest Plan land allocations. Two of these stands 

are near the maximum stand density index (SDI) for Douglas-fir and have the highest SDI in the 

project and most of the stands have not had fire in them for more than 100 years. Underburning 

alone would not reduce the stand density or crown bulk density enough to affect stand structure 

and reduce the risk of crown fire. These stands are experiencing some mortality and fuel is 

accumulating. Proposed treatments in these stands under alternatives 3 and 4 are consistent with 

the direction for these land allocations. One of these stands (Unit 242) and five other natural 

stands would not be treated under alternative 2. Post-harvest slash treatment methods, including 

prescribed fire in treated units, is a component of all action alternatives. 

Only hand work, helicopter yarding or use of existing skid trails in Riparian Reserves:

Use of only hand work and helicopter yarding are not feasible due to cost of implementation. 

Project design features have been developed for Riparian Reserves by specialists on the 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

51

interdisciplinary team in hydrology, soils, geology and fisheries. These design features would 

apply to any action alternative and were developed to minimize the potential for adverse impacts 

to Riparian Reserves and to ensure compliance with all applicable Forest Plan Standards and 

Guidelines for these important areas.

Road densities are reduced as recommended by the watershed analysis (USDA Forest 

Service 1997) and the late successional reserve assessment (LSRA) (USDA Forest Service 

1999c): Road decommissioning is a component of all action alternatives analyzed, for a total of 

4.1 miles of road decommissioning as part of this project. The Watershed Analysis does not give 

an actual road density reduction figure but makes recommendations on road management in the 

Indian Creek Watershed. Since the Watershed Analysis was written, several projects have been 

undertaken to reduce road densities in this watershed through decommissioning, storm-proofing 

and hydrological stabilization (e.g. 1999 Happy Camp Road Decommissioning EA (USDA 

Forest Service 1999a), 1999 East Fork Road EA (USDA Forest Service 1999b), 2005 Mill 

Luther Watershed Restoration EA (USDA Forest Service 2005b). The 2004 Indian Creek Roads 

Analysis (USDA Forest Service 2004b) recommended the decommissioning of 28 miles of road 

and storm-proofing of 136 miles of road. This project contributes to the goal of reducing road 

densities in the Indian Creek Watershed.

As per the management recommendations in the forestwide LSRA (USDA Forest Service 

1999c), the proposed action would reduce road densities in the Runway LSR. 

2.5.3 Initial Proposed Action

Alternative 2 - proposed action is not exactly the same as the initial proposed action that was 

distributed for public input during the scoping period. The initial proposed action included 

thinning treatments on approximately 2,200 acres and underburning across approximately 8,600 

acres. Approximately 3.6 miles of temporary roads were initially proposed and approximately 

4.3 miles or roads were proposed for decommissioning. Thinning and fuels treatment methods 

discussed during scoping are the same as those described for alternative 2 - proposed action.

The initial proposed action and alternative 2 - proposed action described above are quite 

similar; however, several refinements have been made since the scoping period based on 

additional field review by the IDT and other internal scoping efforts that created the need to 

make some modifications to the initial proposed action. These modifications were mentioned in 

a flyer sent to the project mailing list in June 2009, posted to the project website, and discussed 

during the public field trip on June 22, 2009. No additional comments or concerns were received 

in response to this notification. Alternative 2 - proposed action better addresses the purpose and 

need for action and the public input received to date, and more accurately reflects on-the-ground 

conditions; therefore, the initial proposed action was dismissed from further detailed analysis.
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

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Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

53

2.6 Alternatives Compared

Table 13. Summary of alternative components and how well alternatives achieve project objectives

Component / Objective Alternative 1

No Action

Alternative 2

Proposed Action

Alternative 3

No New Temporary Roads

Alternative 4

Minimized Underburn

Alternative Components

Total treatment acres (all 

treatments combined) 0 9,530 9,330 2,850

Total underburning acres 0 7,250 7,320 570

Total thinning 0 1,980 1,710 1,980

Total specialized treatment acres 0 140 140 140

Total meadow enhancement acres 0 160 160 160

Total acres of natural stands 

commercially thinned (% of total 

thinning treatment)

0 315 (16%) 180 (11%) 315 (16%)

Total acres of plantations 

commercially thinned (% of total 

thinning treatment)

0 1,665 (84%) 1,525 (89%) 1,665 (84%)

Total miles of road 

decommissioning 0 4.1 4.1 4.1

Total acres of mastication 0 0 0 1,450

Miles of temporary roads 

constructed 0 2.9 0 2.9
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

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Component / Objective Alternative 1

No Action

Alternative 2

Proposed Action

Alternative 3

No New Temporary Roads

Alternative 4

Minimized Underburn

Potential sawlog volume produced 

from commercial thinning (CFF, 

hundred cubic feet)

0 46,240 39,785 46,240

How Alternatives Achieve Project Objectives 

Reduce stand densities

Not met; existing high 

stand densities would 

persist; self-thinning 

would occur

Met: the majority of 

thinned stands would be 

below desired stand 

density index following 

treatments in 2014 and 

2039

Met: the majority of thinned 

stands would be below 

desired stand density index 

following treatments in 2014 

and 2039; objective would be 

met but would not be realized 

on as many acres as 

Alternative 2 or 4 since 

Alternative 3 would treat fewer 

acres

Met: the majority of thinned 

stands would be below desired 

stand density index following 

treatments in 2014 and 2039

Improve structural diversity within 

stands, where applicable

Not met; existing lack of 

diversity in many stands 

would persist

Met; prescriptions in 

treated stands, 

particularly in natural 

stands and in 

specialized treatment 

areas would encourage 

increased species 

diversity 

Met; prescriptions in treated 

stands, particularly in natural 

stands and in specialized 

treatment areas would 

encourage increased species 

diversity

Met; prescriptions in treated 

stands, particularly in natural 

stands and in specialized 

treatment areas would 

encourage increased species 

diversity; because fewer acres 

would be underburned, species 

diversity would not be achieved 

on as many acres as proposed in 

alternatives 2 or 3

Maintain or enhance natural 

meadows and wetlands

Not met: conifer 

encroachment into 

natural meadows would 

continue; over time 

natural meadows would 

shrink in size 

Met; meadow 

enhancement 

treatments (thinning and 

prescribed burning) 

would occur on 160 

acres 

Met; meadow enhancement 

treatments (thinning and 

prescribed burning) would 

occur on 160 acres

Met; meadow enhancement 

treatments (thinning and 

prescribed burning) would occur 

on 160 acres
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

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Component / Objective Alternative 1

No Action

Alternative 2

Proposed Action

Alternative 3

No New Temporary Roads

Alternative 4

Minimized Underburn

Maintain or enhance hardwood 

diversity

Not met; existing lack of 

hardwood diversity in 

many areas would 

persist; over time the 

hardwood component in 

many stands would die 

out due to shading

Met; thinning to restore 

hardwood stands would 

occur on 18 acres. In 

addition, prescriptions 

for other stands, 

particularly natural 

stands, would 

encourage hardwood 

regeneration as would 

prescribed burning

Met; thinning to restore 

hardwood stands would occur 

on 18 acres. In addition, 

prescriptions for other stands, 

particularly natural stands, 

would encourage hardwood 

regeneration as would 

prescribed burning

Met; thinning to restore 

hardwood stands would occur on 

18 acres. In addition, 

prescriptions for other stands, 

particularly natural stands, would 

encourage hardwood 

regeneration as would 

prescribed burning; because 

fewer acres would be 

underburned, hardwood diversity 

would not be achieved on as 

many acres as proposed in 

alternatives 2 or 3

Protect mid- and early-seral forest 

from loss due to wildfire 

Not met; current stand 

densities and high fuel 

loading in many areas 

would continue to 

promote the likelihood 

of a high intensity fire 

throughout the project 

area 

Met in thinned stands 

and to a lesser extent in 

those areas 

underburned but not 

thinned; while proposed 

treatments would not 

prevent high intensity 

fire and the loss of mod 

and early-seral forest 

due to wildlife in all 

areas, it would move the 

project area toward 

desired conditions

Met in thinned stands and to a 

lesser extent in those areas 

underburned but not thinned; 

while proposed treatments 

would not prevent high 

intensity fire and the loss of 

mod and early-seral forest due 

to wildlife in all areas, it would 

move the project area toward 

desired conditions; because 

somewhat fewer acres would 

be treated, this objective 

would be met on somewhat 

fewer acres than Alternative 2

Met in thinned stands and to a 

lesser extent in those areas 

underburned but not thinned; 

while proposed treatments would 

not prevent high intensity fire and 

the loss of mod and early-seral 

forest due to wildlife in all areas, 

it would move the project area 

toward desired conditions; 

because substantially fewer 

acres are proposed for 

underburning, this objective 

would be met on fewer acres 

than Alternatives 2 or 3. 

Develop late-successional 

conditions, increase patch size and 

reduce risk of loss of northern 

spotted owl habitat from wildfire

Not met; Existing LSR 

areas would not be 

treated to enhance 

development large trees 

and other late 

successional conditions 

Met: actions proposed in 

LSRs (thinning and 

burning is proposed in a 

portion of each LSR) is 

consistent with the goals 

for these areas and 

would promote the 

development of LSR 

conditions, increasing 

patch size and reducing 

risk of loss due to 

Met: actions proposed in 

LSRs (thinning and burning is 

proposed in a portion of each 

LSR) is consistent with the 

goals for these areas and 

would promote the 

development of LSR 

conditions, increasing patch 

size and reducing risk of loss 

due to wildfire

Met: actions proposed in LSRs 

(thinning and burning is 

proposed in a portion of each 

LSR) is consistent with the goals 

for these areas and would 

promote the development of LSR 

conditions, increasing patch size 

and reducing risk of loss due to 

wildfire
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

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Component / Objective Alternative 1

No Action

Alternative 2

Proposed Action

Alternative 3

No New Temporary Roads

Alternative 4

Minimized Underburn

wildfire

Maintain or improve watershed 

conditions and the quality of the 

Indian Creek water source

Not met; while actions 

would not be taken to 

further degrade existing 

conditions within the 

Indian Creek 

Watershed, existing 

road densities would 

remain high. Over time, 

improvements would be 

realized as disturbed 

areas revegetate 

Met; a net reduction of 

1.4 miles of the existing 

road density would be 

realized due to 

decommissioning of 

existing roads, but 

temporary roads would 

be created and existing 

temporary roads reopened (and 

hydrologically restored

following use), 

Riparian Reserve 

treatments would

maintain, and in the long 

term, improve water 

quality; short-term 

effects to temperature 

and sedimentation due 

to RR thinning would be 

small compared to long 

term increases in stream 

shade and reduction of 

high severity wildfire risk 

which could destroy RR 

and cause adverse 

sedimentation.

Met; because no new 

temporary roads would be 

created under Alternative 3, 

the net reduction in road 

density would be 4.1 miles, 

greater than for Alternatives 2 

or 3; however, like 

Alternatives 2 and 3, existing 

temporary roads would be 

reopened and other ground 

disturbing actions, including 

skid trail creation, would 

occur. Riparian Reserve 

treatments would maintain, 

and in the long term, improve 

water quality; short-term 

effects to temperature and 

sedimentation due to RR 

thinning would be small 

compared to long term 

increases in stream shade 

and reduction of high severity 

wildfire risk which could 

destroy RR and cause 

adverse sedimentation.

Met; a net reduction of 1.4 miles 

of the existing road density 

would be realized due to 

decommissioning of existing 

roads. However, because 

temporary roads would be 

created and existing temporary

roads re-opened (and 

hydrologically restored following 

use). Riparian Reserve 

treatments would maintain, and 

in the long term, improve water 

quality; short-term effects to 

temperature and sedimentation 

due to RR thinning would be 

small compared to long term 

increases in stream shade and 

reduction of high severity wildfire 

risk which could destroy RR and 

cause adverse sedimentation.

Improve and maintain good growth 

rates

Not met; existing high 

stand densities in many 

areas, particularly in 

plantations would 

prevent good growth 

rates

Met on 1,980 acres of 

thinned stands; 

prescriptions would be 

designed to promote the 

development of large 

trees and provide 

adequate growing 

space, particularly in 

Met on 1,710 acres thinned 

stands; prescriptions would be 

designed to promote the 

development of large trees 

and provide adequate growing 

space, particularly in thinned 

plantations; because fewer 

acres are thinned under 

Met ion 1,980 acres thinned 

stands; prescriptions would be 

designed to promote the 

development of large trees and 

provide adequate growing space, 

particularly in thinned plantations
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

57

Component / Objective Alternative 1

No Action

Alternative 2

Proposed Action

Alternative 3

No New Temporary Roads

Alternative 4

Minimized Underburn

thinned plantations Alternative 3, this objective 

would be realized on fewer

acres than alternatives 2 or 4

Minimize insect and disease 

damage through stocking control 

Not met; no treatments 

would occur to reduce 

existing levels of insect 

or disease; as stand 

densities increase in 

many areas and 

especially during 

periodic drought, it is 

likely that occurrences 

of insects and diseases 

would increase within 

the project area over 

time; pine plantations in 

particular would have 

heavy mortality from 

beetles 

Met; Met on 1,980 acres 

of thinned stands; 

thinning would reduce 

tree competition for 

water and nutrients 

leaving the remaining 

trees more able to 

produce defenses 

against diseases and 

insects, and would 

remove some of the 

weakest and more 

vulnerable trees,

particularly in thinned 

plantations; dwarf 

mistletoe treatment 

would specifically occur 

on 36 acres 

Met; Met on 1,710 acres of 

thinned stands; thinning would 

reduce tree competition for 

water and nutrients leaving 

the remaining trees more able 

to produce defenses against 

diseases and insects, and 

would remove some of the 

weakest and more vulnerable 

trees, particularly in thinned 

plantations; dwarf mistletoe 

treatment would specifically 

occur on 36 acres

Met; Met on 1,980 acres of 

thinned stands; thinning would 

reduce tree competition for water 

and nutrients leaving the 

remaining trees more able to 

produce defenses against 

diseases and insects, and would 

remove some of the weakest and 

more vulnerable trees,

particularly in thinned 

plantations; dwarf mistletoe 

treatment would specifically 

occur on 36 acres

Maintain existing plantations

Not met; dense 

plantations would 

remain in their current 

condition and would 

continue to self thin 

over time as stand 

density increases

Met on 1,665 acres of 

plantations that are 

thinned to promote the 

development of large 

trees and enhanced 

structural and species 

diversity

Met on 1,525 acres of 

plantations that are thinned to 

promote the development of 

large trees and enhanced 

structural and species 

diversity

Met on 1,665 acres of 

plantations that are thinned to 

promote the development of 

large trees and enhanced 

structural and species diversity
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

58

Table 14. Summary of environmental effects by alternative 

Resource Area Alternative 1

No Action

Alternative 2

Proposed Action

Alternative 3

No Temporary Roads

Alternative 4

Minimized Underburning

Forest Vegetation 

Stand Density Index (SDI) in 

2039

Desired condition is 55 

percent or less of maximum 

SDI

Existing Condition is 69% 

maximum SDI 

78% maximum SDI 45% maximum SDI 45% maximum SDI, but on 

slightly less acres

45% maximum SDI

Trees per Acre in 2039

Desired condition varies by 

tree species and diameter

and stand age 

Existing condition is 357

165; moderate decrease 

due to density-related 

mortality

66: substantial 

decrease due to 

removal by thinning 

and fuels treatment

66; substantial decrease 

due to removal by thinning 

and fuels treatment

66; substantial decrease due 

to removal by thinning and 

fuels treatment

Quadratic Mean Diameter 

(QMD) in 2039 

A larger QMD is desired -

the proportion of large trees 

in a stand compared to the 

proportion of small trees.

Large trees are desired for a 

variety of reasons including 

increased fire resiliency, 

wildlife habitat, and future 

wood value; many trees are 

currently less than 10 inches 

DBH

18: increase in QMD due 

to competition-induced

mortality (self-thinning); 

modeling predicts most of 

the trees that die in a 30 

year period would be 

smaller suppressed trees.

22.4: greater 

increase than 

Alternative 1 in QMD 

due to removal of 

small and moderatesized trees by 

thinning and fuel 

treatment

22.4: greater increase 

than Alternative 1 in 

QMD due to removal of 

small and moderatesized trees by thinning 

and fuel treatment, but 

on slightly less acres

22.4: greater increase than 

Alternative 1 in QMD due to 

removal of small and 

moderate-sized trees by 

thinning and fuel treatment
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

59

Resource Area Alternative 1

No Action

Alternative 2

Proposed Action

Alternative 3

No Temporary Roads

Alternative 4

Minimized Underburning

Existing condition is 11

Achievement of Forest Plan

Management Area Goals Not met

Met and desired 

conditions achieved in 

treated stands

Met and desired conditions 

achieved in treated stands

Met and desired conditions 

achieved in treated stands

Fire and Fuels

Fire behavior in 2029 during 

severe (90th percentile) 

conditions as measured by 

surface flame length 

Desired condition is less 

than 4 feet 

Existing condition is 5.6

6.4

2.8 in areas thinned 

and underburned

6 in areas 

underburned only

Same as Alternative 2 but 

on slightly less acres

2.8 in areas thinned

6 in areas underburned only

6.6 in areas masticated

Fire Type in 2029 (surface 

fire, passive crown fire, 

active crown fire, conditional 

crown fire). 

Desired condition is a 

combination of surface and 

passive crown fire

Existing condition is 

conditional crown fire

Conditional crown fire Surface fire in all 

treated areas 

Same as Alternative 2 but 

on slightly less acres

Same as Alternative 2 but on 

substantially fewer acres 

Summary

Increased fire 

resiliency and reduced 

fire behavior in areas 

treated over time

Increased fire resiliency 

and reduced fire behavior 

in areas treated over time

Increased fire resiliency and 

reduced fire behavior in areas 

treated over time

Air Quality 

Smoke emissions containing 

particulate matter with 

diameters less than 10 

PM10: 1.04 

PM 2.5: 0.88

CO: 11.5

PM10: 0.77 totaling 

5,583 

PM2.5: 0.65 totaling 

PM10: 0.77 totaling 5,636 

PM2.5: 0.65 totaling 4,758

CO: 8.6 totaling 62,952

PM10: 0.77 totaling 439 

PM2.5: 0.65 totaling 371

CO: 8.6 totaling 4,902
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

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Resource Area Alternative 1

No Action

Alternative 2

Proposed Action

Alternative 3

No Temporary Roads

Alternative 4

Minimized Underburning

micrometers (PM10), less 

than 2.5 (PM2.5), and 

carbon monoxide (CO) in 

tons/acre and total tons

All due to wildfire 4,713

CO: 8.6 totaling 62,350

All due to prescribed 

burning 

All due to prescribed 

burning 

All due to prescribed burning 

PM10: Fugitive dust 

emissions from log hauling None 17.8 tons/year 17.8 tons/year 16 tons/year

Summary

Substantially more total 

smoke emissions due to a 

wildfire, often 

concentrated in time

25 percent fewer 

tons/acre emissions 

during prescribed 

burning than a wildfire; 

substantially fewer 

total tons than a 

wildfire; emissions 

staggered through time

These short-term 

adverse effects to air 

quality would be 

minimized by project 

design features and 

compliance with all 

State Standards 

Essentially the same 

emissions as Alternative 2

These short-term adverse 

effects to air quality would 

be minimized by project 

design features and 

compliance with State 

Standards 

92 percent fewer total tons of 

emissions than Alternatives 2 

or 3 due to substantially less 

underburning

These short-term adverse 

effects to air quality would be 

minimized by project design 

features and compliance with 

State Standards

Geology

Thinning and burning 

treatments proposed on 

unstable land in Riparian 

Reserves

0 1042 (87 acres of this 

is thinning)

1041 (86 acres of this is 

thinning)

270 (87 acres of this is 

thinning)

Treatments proposed on 

ultramafic rock 0 3292 (825 acres of this 

is thinning)

3277 (825 acres of this is 

thinning)

2190(825 acres of this is 

thinning)

Cubic yards of sediment 

produced per decade based 

on cumulative watershed 

effects modeling 

Not applicable

19-125 yards of 

sediment per decade 

due to roads; 81-806 

due to other treatments

2-71 yards of sediment per 

decade due to roads; 81-

806 due to other 

treatments

19-125 yards of sediment per 

decade due to roads; 81-806 

due to other treatments
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

61

Resource Area Alternative 1

No Action

Alternative 2

Proposed Action

Alternative 3

No Temporary Roads

Alternative 4

Minimized Underburning

Risk Ratio and Forest Plan

Goals Not applicable

Below established 

threshold and has a 

moderately high to 

high probability of 

meeting all Forest Plan

geological program 

goals

Below established 

threshold and has a 

moderately high to high 

probability of meeting all 

Forest Plan geological 

program goals

Below established threshold 

and has a moderately high to 

high probability of meeting all 

Forest Plan geological 

program goals

Soils

Detrimental Soil Disturbance 

(Percentage of areas 

proposed for treatment). 

Desired condition is less 

than 15 percent.

Existing condition is 7 

percent

7 11 11 11

Achievement of Forest Plan

Soil Standards and 

Guidelines

Not applicable

High probability of 

meeting Forest Plan

Soil S&Gs

High probability of meeting 

Forest Plan

Soil S&Gs

High probability of meeting 

Forest Plan

Soil S&Gs

Water

Proposed acres of 

treatments in stream course 

riparian reserves

0

Thinning: 230 

Underburning: 1530; 

net reduction in road 

density of 1.4 miles 

Thinning: 168

Underburning: 1530; net 

reduction in road density of 

4.1 miles

Thinning: 230 

Mastication: 80; net reduction 

in road density of 1.4 miles

USLE risk ratios for surface 

soil erosion sediment 

volume No change 0.30 0.29 0.27
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

62

Resource Area Alternative 1

No Action

Alternative 2

Proposed Action

Alternative 3

No Temporary Roads

Alternative 4

Minimized Underburning

Threshold of Concern in 1.0 

(so desired condition is less 

than 1.0) 

GEO risk ratios for mass 

wasting (landslides)

Threshold of Concern in 1.0 

(so desired condition is less 

than 1.0)

No change 0.50 0.50 0.50

Equivalent Roaded Area 

(ERA) risk ratios

Threshold of Concern in 1.0 

(so desired condition is less 

than 1.0) 

No change 0.52 0.52 0.52

Achievement of Forest Plan

Standards and Guidelines

Indian Creek watershed 

not currently meeting 

desired conditions due to 

landslide terrain, dense 

road network and long 

history of mining and 

forest management; no 

change in existing 

condition 

Short-term, site-and 

reach-scale adverse 

impacts that would not 

be measurable at the 

watershed scale; longterm beneficial impacts 

to sedimentation, 

stream temperature 

and channel 

morphology due in part 

to greater fire 

resilience and road 

decommissioning; all 

predicted effects within 

established thresholds 

of concern, although 

elevated levels are 

noted in some 5th field 

watersheds; would 

meet Forest Plan

S&Gs 

Short-term, site-and reachscale adverse impacts that 

would not be measurable 

at the watershed scale; 

long-term beneficial 

impacts to sedimentation, 

stream temperature and 

channel morphology due in 

part to greater fire 

resilience and road 

decommissioning; all 

predicted effects within 

established thresholds of 

concern, although elevated 

levels are noted in some 

5th field watersheds; would 

meet Forest Plan S&Gs

Short-term, site-and reachscale adverse impacts that 

would not be measurable at 

the watershed scale; long-term 

beneficial impacts to 

sedimentation, stream 

temperature and channel 

morphology due in part to 

greater fire resilience and road 

decommissioning; all predicted 

effects within established 

thresholds of concern, 

although elevated levels are 

noted in some 5th field 

watersheds; would meet 

Forest Plan S&Gs
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

63

Resource Area Alternative 1

No Action

Alternative 2

Proposed Action

Alternative 3

No Temporary Roads

Alternative 4

Minimized Underburning

Fisheries

Coho salmon, Chinook 

salmon and 

steelhead/rainbow trout 

No direct effects; longterm adverse impacts 

possible if a wildfire were

to start in project area

Via predicted effects to 

17 fish habitat 

indicators: may affect 

but is not likely to 

adversely affect 

federally listed as 

threatened coho 

salmon; may impact 

individual sensitive 

Chinook salmon and 

steelhead/rainbow 

trout but is not likely to 

result in a trend toward 

federal listing or loss of 

viability for steelhead 

and resident rainbow 

trout

Same as Alternative 2 Same as Alternative 2

Botany and Noxious Weeds

12 Forest Service Sensitive 

Species 

No change; adverse 

impacts possible if a 

wildfire were to start in 

project area

No impact to 4 

species; may impact 

individuals of 9 species 

but not likely to result 

in a trend toward 

federal listing or loss of 

viability 

No impact to 4 species; 

may impact individuals of 9

species but not likely to 

result in a trend toward 

federal listing or loss of 

viability 

No impact to 5 species; may 

impact individuals of 8 species 

but not likely to result in a 

trend toward federal listing or 

loss of viability; mastication 

has potential to adversely 

affect fungi species 

3 High Priority and 2 

Moderate Priority Noxious 

Weeds

No change; increased 

susceptibility to noxious 

weeds if a wildfire were to 

start in project area 

Increased risk of 

spread (considered 

low), minimized 

through project design 

features

Increased risk of spread 

(considered low), 

minimized through project 

design features

Increased risk of spread 

(considered low), minimized 

through project design 

features

Terrestrial Wildlife
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

64

Resource Area Alternative 1

No Action

Alternative 2

Proposed Action

Alternative 3

No Temporary Roads

Alternative 4

Minimized Underburning

2 Threatened or 

Endangered species and 

critical habitat; 14 Forest 

Service Sensitive Species

No change; adverse 

impacts possible if a 

wildfire were to start in 

project area

May affect but not 

likely to adversely 

affect the northern 

spotted owl; no effect 

to marbled murrelets or 

their critical habitat or 

to northern spotted owl 

critical habitat; may 

impact individuals of 8 

sensitive species but is 

not likely to result in a 

trend toward federal 

listing or loss of 

viability; no impact to 5 

sensitive species 

Same as Alternative 2 Same as Alternative 2

Managed Wildlife Area

No change; no 

improvement to late 

succession reserve 

conditions

No adverse effect to 

the quality of habitat; 

beneficial effects 

expected over the 

long-term 

Same as Alternative 2 Same as Alternative 2

Late Successional Reserves

No change; no 

improvement to late 

succession reserve 

conditions

No adverse effect to 

the quality of habitat; 

beneficial effects 

expected over the 

long-term 

Same as Alternative 2 Same as Alternative 2

11 Management Indicator 

Species No change

Negligible to minor 

short-term adverse 

impacts during project 

implementation; longterm beneficial impacts 

due to habitat 

improvement

Same as Alternative 2 Same as Alternative 2

Migratory Birds No change

May impact individuals 

during project 

implementation but not 

expected to result in a 

trend toward federal 

Same as Alternative 2 Same as Alternative 2
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

65

Resource Area Alternative 1

No Action

Alternative 2

Proposed Action

Alternative 3

No Temporary Roads

Alternative 4

Minimized Underburning

listing or loss of 

viability 

Socioeconomics

Estimated Revenue (1999 

dollars) 0 $628,471 $523,400 $628,471

Job Creation 0 183 162 173

Net Present Value (NPV; 

sum of total costs 

subtracted from the sum of 

total benefits)

0 (2,595,396) (2,890.486) (1,521,906)

Benefit-Cost Ratio (B-C; 

sum of benefits divided by 

the sum of costs). A ratio 

greater than 1 suggests that 

the benefits are greater than 

the costs. Use with the NPV 

to describe overall benefits

0 0.19 0.14 0.28

Summary

This alternative would

yield no economic benefits 

or costs.

Would create the most 

jobs due treatment of 

more acres compared 

to other alternatives. 

Second highest B-C 

ratio and NPV among 

action alternatives, but 

these do not account 

for benefits to other 

forest resources.

Least amount of economic 

benefits, but these figures 

do not account for benefits 

to other resources.

Highest NPV and benefit-cost 

ratio due in part to lower cost 

of management activities 

(fewer acres) but would yield 

different on-the-ground 

benefits. Does not account for 

benefits to forest resources, 

just revenue from sale of 

sawtimber

Summary 

Highest NPV and benefit-cost ratio for Alternative 4 due in part to lower cost of 

management activities (fewer acres) but would yield different on-the-ground benefits. 

Does not account for benefits to forest resources, just revenue from sale of sawtimber
Chapter 2 Two Bit Vegetation Management Draft Environmental Impact Statement

66

Resource Area Alternative 1

No Action

Alternative 2

Proposed Action

Alternative 3

No Temporary Roads

Alternative 4

Minimized Underburning

Scenery and Recreation 

Visual Quality Objectives No change

Meets all Forest Plan

VQOs; viewsheds 

would remain natural 

or near-natural 

appearing and 

treatments would be 

visually subordinate to 

the landscape; no 

activities seen from 

high sensitivity 

viewpoints

Same as Alternative 2 Same as Alternative 2

Recreational Opportunities No change

Minor, short-term 

adverse impacts to 

dispersed recreational 

opportunities during 

project implementation; 

use and opportunity 

would remain 

essentially the same 

over the long term

Minor differences but 

essentially the same as 

Alternative 2

Minor differences but 

essentially the same as 

Alternative 2

Inventoried Roadless Areas No change

15 acres thinning of 

small encroaching 

conifers and 21 acres 

of prescribed burning 

to restore natural 

meadow conditions; no 

road construction; all 

actions consistent with 

roadless area 

characteristics and 

management direction

Same as Alternative 2 Same as Alternative 2

Cultural Resources
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 2

67

Resource Area Alternative 1

No Action

Alternative 2

Proposed Action

Alternative 3

No Temporary Roads

Alternative 4

Minimized Underburning

Archeological Sites

Minor to major adverse 

effects if a wildfire were to 

start in project area

Negligible to moderate 

adverse impacts, 

minimized through 

project design features

Negligible to moderate 

adverse impacts, 

minimized through project 

design features; less effect 

than Alternatives 2 or 4 

due to no temporary roads

Negligible to moderate 

adverse impacts, minimized 

through project design 

features

Culturally Significant Areas

Minor to major adverse 

effects if a wildfire were to 

start in project area

Negligible to moderate 

adverse effects; 

beneficial effects 

realized due to 

enhanced condition of 

desired plant species 

and reduced risk of 

wildfire

Negligible to moderate 

adverse effects; beneficial 

effects realized due to 

enhanced condition of 

desired plant species and 

reduced risk of wildfire

Negligible to moderate 

adverse effects; beneficial 

effects reduced due to 

substantially less underburning 

Climate Change

Greenhouse gas emissions 

and natural variability 

No direct, immediate or 

short-term change in 

greenhouse gas 

emissions in the project 

area and no direct change 

in climate or vegetation 

patterns; risk of high 

severity fire would 

continue (and the 

subsequent release of 

large pulses of 

greenhouse gases via 

smoke from large wildfire).

Short-term, localized, 

minor adverse impacts 

due to release of 

greenhouse gases 

during prescribed fire 

due to smoke and to a 

lesser extent, through 

use of chainsaws and 

motor vehicles. Would 

not appreciably or 

measurably contribute 

to global climate 

change. Moving the 

area toward a more 

natural range of 

variability would 

contribute to a more 

resilient ecosystem 

less susceptible to 

shifts in temperature or 

rainfall patterns.

Same as Alternative 2

Less greenhouse gas 

emissions due to substantially 

less prescribed burning
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

69

Chapter 3. Affected Environment and 

Environmental Consequences

This Chapter is organized by resource and describes aspects of the environment likely to be 

affected by implementation of alternatives (affected environment) and environmental effects 

(direct, indirect, and cumulative) that would result from implementing alternatives 

(environmental consequences). Together, these descriptions form the scientific and analytical 

basis for comparison of alternatives presented in Chapter 2.

3.1 Methodology

The impact analysis and conclusions contained in this chapter were based on forest staff 

knowledge of the resources and site, reviewing of existing literature and agency studies, 

information provided by specialists within the Forest Service and other agencies, and 

professional judgment. The methodology section at the beginning of each resource heading 

describes any additional specific data collection/analysis or other methods used for that resource.

Potential impacts in this chapter are described in terms of type (direct, indirect, cumulative and 

are the effects beneficial or adverse?), context (are the effects site-specific, local, or even 

regional?) duration (are the effects short-term or long-term?), and intensity.

Direct effects occur at the same time and in the same locations as actions that cause them. 

Indirect effects are those that occur at a later time or in a different location than the actions that 

were their cause. Cumulative impacts result from the additive impacts of this project with past, 

present, and reasonably foreseeable future actions in or near the area. 

For purposes of this analysis, short-term effects are those expected within the next 1 to 10 

years (throughout the course of project implementation) and long-term effects are those that are 

expected between 10 and 20 years or more (after implementation is complete), unless 

specifically defined in individual resource sections below.

3.2 Past, Present and Reasonably Foreseeable Actions

According the Council on Environmental Quality (CEQ) NEPA regulations, “cumulative impact” 

is “...the impact on the environment which results from the incremental impact of the action 

when added to other past, present, and reasonably foreseeable future actions regardless of what 

agency (Federal or non-Federal) or person undertakes such actions” (40 CFR 1508.7).

The project area lies wholly within the Indian Creek 5th field watershed (Figure 7), which is 

approximately 86, 200 acres in size, and was evaluated in detail during 1990-1995 by the Forest 

Service (USDA 1997). Because the Two Bit project area lies completely within this watershed 

and encompasses a large percentage of it, and because of the potential for impacts of multiple 

actions on the natural environment within one watershed, it was selected as the area for 

cumulative impact analysis for most resources analyzed in this chapter. Some resources also 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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consider effects at the smaller 7th field watershed scale as well; figure 7 depicts all 7th field 

watersheds that make up the larger Indian Creek 5th field watershed. However, the area of 

cumulative impact may differ depending on the resource affected. For example, air quality could 

be affected by actions outside of a watershed boundary. If a different cumulative impact area is 

chosen for a specific resource, it is discussed in that specific resource section later in this chapter. 

The Indian Creek watershed has been the focus of two watershed-specific analysis efforts in 

the recent past: The 1997 Indian Creek Watershed Assessment (USDA 1997) and the 2004 Indian 

Creek Roads Analysis (USDA 2004b). The Indian Creek Watershed has approximately 318 miles 

of system roads, with an average road density of 3.1 miles per square mile (Bousfield 2010 and 

USDA 2004b). Populated communities near the watershed include Happy Camp, Seiad Valley, 

Yreka and Scott Valley. Generally, the major use of private property located within the watershed 

is for the rural residential life-style. There are also commercial uses, with some ranching and 

agricultural parcels, mining, and smaller tracts of timberlands. Most residences are occupied 

year-round, while a few are visited by the property owners seasonally.

Contemporary uses by Native Americans in the watershed area include gathering traditional 

resources such as artisan and basketry materials and Native American religious freedom uses. 

Artisan and basketry gathering sites have been identified by Native Americans within the 

watershed area (McCovey 2009).

The baseline for cumulative effects analysis is the current condition. The cumulative effects 

analysis in this EIS is consistent with Forest Service National Environmental Policy Act (NEPA) 

Regulations (36 CFR 220.4(f)) (July 24, 2008), which state, in part:

“CEQ regulations do not require the consideration of the individual effects of 

all past actions to determine the present effects of past actions. Once the agency 

has identified those present effects of past actions that warrant consideration, 

the agency assesses the extent that the effects of the proposal for agency action 

or its alternatives will add to, modify, or mitigate those effects. The final 

analysis documents an agency assessment of the cumulative effects of the 

actions considered (including past, present, and reasonable foreseeable future 

actions) on the affected environment. With respect to past actions, during the 

scoping process and subsequent preparation of the analysis, the agency must 

determine what information regarding past actions is useful and relevant to the 

required analysis of cumulative effects. Cataloging past actions and specific 

information about the direct and indirect effects of their design and 

implementation could in some contexts be useful to predict the cumulative 

effects of the proposal. The CEQ regulations, however, do not require agencies 

to catalogue or exhaustively list and analyze all individual past actions. Simply 

because information about past actions may be available or obtained with 

reasonable effort does not mean that it is relevant and necessary to inform 

decision making. (40 CFR 1508.7)”

A catalog of certain actions occurring within the Indian Creek watershed was done as part of 

a watershed analysis (Bousfield 2010) and is summarized in the table below. In-progress or 

planned actions, known as of this writing, are also included and were compiled from the 

Klamath National Forest Schedule of Proposed Actions (queried on July 22, 2009) and with 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

71

input from district staff. As discussed in Chapter 1, although many Forest System roads in the 

project area are in good condition, some would require programmatic maintenance before 

proposed operations would begin, in order to bring them up to current standards. Programmatic 

maintenance on Forest System roads is a routine action that is on-going and has been evaluated 

in a separate environmental analysis. 

In-progress and planned projects are included in table 15 that follows. 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

73

Figure 7. Indian Creek 5th - field watershed and relationship to Two Bit Project Area and 7th - field watershed boundaries 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

75

The Indian Creek Watershed Analysis (USDA Forest Service 1997) provides a detailed 

description of conditions of the watershed including past history, reflecting the aggregate impact 

of prior human actions and natural events that have affected the environment, and might 

contribute to cumulative effects, up to 1997. Actions and events since 1997 were also considered 

and are included in tables 15 and 16 below.

Approximately 23,500 acres within the 86,200-acre watershed (or 27%) have been treated or 

are planned for treatment in the foreseeable future with either a timber sale or an underburn/fuels 

reduction project, the majority of which has been on Forest System lands. Since 1987, 

approximately 3,500 acres were burned in wildfires. Road decommissioning has also occurred in 

the watershed, totaling approximately 20 miles. These roads are now no longer part of the road 

network. Since the Watershed Analysis was written, several projects have been undertaken to 

reduce road densities in this watershed through decommissioning, storm-proofing and 

hydrological stabilization. The 2004 Indian Creek Roads Analysis (USDA Forest Service 2004b) 

recommended the decommissioning of 28 miles of road and storm-proofing of 136 miles of road. 

There are currently no known plans for logging that affect habitat on private lands, although 

approximately 390 acres of harvest occurred on private lands within the watershed between 1999 

and 2003.

The affected environment sections in Chapter 3 discuss the current conditions in the project 

area. Cumulative watershed effects analysis assumes all planned projects have been completed.

Tables 15 and 16 below display acres of projects within Indian Creek 5th field watershed. 

Table 15. In-progress or planned activities within the Indian Creek Watershed 

Project Type/Timing Approximate Acreage

Happy Camp Fire Protection 03 

Analyzed with a categorical 

exclusion

Fuels management/On-going 742

Happy Camp Fire Protection 

Commercial Phase II Thinning

Analyzed with an environmental 

assessment

Fuels management/On-going 182

Happy Camp Fire Protection 

Phase II Underburning

Analyzed with a categorical 

exclusion

Fuels management/Planned 1168

Happy Camp Fire Protection 

Phase II Roadside Understory 

Fuels Reduction

Analyzed with a categorical 

Fuels management/Planned 328
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

76

Project Type/Timing Approximate Acreage

exclusion

Happy Camp Fire Protection 

Phase II Understory Fuels 

Reduction

Analyzed with a categorical 

exclusion

Fuels Management/Planned 722

Elk Slashing and Reforestation 

Analyzed with a categorical 

exclusion

Timber and Fuels 

Management/On-going

203

Mill/Luther Watershed 

Improvement Project

Watershed/On-going

96.3 miles of road storm-proofing 

and 11.3 miles road 

decommissioning

Totals

3,345 acres

96.3 miles road storm-proofing 

11.3 miles road decommissioning

Table 16. Acres of completed, in progress or planned activities within the Indian Creek 5th Code 

Watershed, since 1953

Activity Type Acres (unless otherwise specified)

Timber harvest or fuels treatments 19,836 

Wildfires 3,613

Road Projects 19.5 road miles decommissioned; on-going 

programmatic maintenance of system roads

Total

23,449

19.5 road miles decommissioned

3.3 Forest Vegetation

3.3.1 Methodology

Data describing the existing condition were collected through site visits, 2008 and 2009 informal 

stand exams, GIS vegetation layers, and the Indian Creek Watershed Analysis. The Classification 

and Assessment with Landsat of Visible Ecological Groupings (CALVEG) system was used to 

provide more recent vegetation information than the 1997 watershed analysis. CALVEG uses 

“existing vegetation” to classify stands and utilizes color infrared satellite imagery and field 

verification at the regional level to classify California existing vegetation communities. The 

latest imagery updates were in 2004 and field verification has continued.
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

77

Stand information was calculated using traditional methods and spreadsheets to derive stand 

averages for various forest measurements. The Forest Vegetation Simulator (FVS) program 

(Dixon 2002) was also used for some stands to generate averages for stand conditions from the 

data collected and to model the effects of treatments on density, diameter growth, and stand 

composition. The sampling and modeling are an approximation of actual conditions. The 

modeling does not replicate exactly the existing conditions or conditions that would occur after 

treatments. For this analysis, FVS was used to generally characterize and display existing 

conditions and the nature and magnitude of treatment effects to support decisions to be made.

FVS provides probable outcomes to compare alternatives and fine tune silvicultural prescriptions 

for treatment stands.

The alternatives are compared using the following indicators 

Post-treatment change in forest density as measured by Stand Density Index (SDI); the 

desired SDI is 55% of maximum or less

Predicted maintenance or improvement in tree vigor, growth, and susceptibility to damage 

from insects and disease as measured by SDI

Species composition and structure related to tree vigor and potential fire damage as 

measured by comparison of before and after treatment trees per acre (TPA) and quadratic 

mean diameter (QMD) 

Acres of existing plantations treated

SDI is used as an indicator to assess stand conditions related to inter-tree competition and 

describe stand characteristics resulting from proposed treatments or no treatments. SDI is a 

widely used measure developed by Reineke in 1933 that expresses relative stand density in terms 

of the relationship of a number of trees to stand quadratic mean diameter (Helms 1998). The 

relationship between the average individual tree-size in tree stands experiencing density-related 

or suppression mortality has been shown to be exceedingly predictable for a number of 

herbaceous and tree species. In the ecological literature, the relationship is commonly referred to 

as the “self-thinning rule”. This fundamental relationship, generally independent of stand age 

and site quality, provides an excellent basis from which to develop an understanding of the 

competitive interactions between individuals in a population (Long 1985).

QMD was chosen as an indicator because of its relationship to the health of trees and 

susceptibility to damage from fire and its relationship to calculating SDI. Low production of 

stem wood (small diameters) per unit of foliage has been associated with the tree’s inability to 

accumulate reserves of nutrients, carbohydrates and water or to produce defensive compounds. 

Stem growth occurs once the resource demands of foliage and root growth have been met 

(Waring 1987, Oliver 1996). Larger trees develop thick bark that isolates the cambium from heat 

damage and have more available surface area; this remains functioning if portions of the tree are 

killed by fire. QMD combined with TPA also reflects the number of small diameter trees that 

may function as ladder fuels. 

Changes in the percent of basal area (BA) for desired species will be discussed qualitatively 

with support from modeling. BA over time is a better measure of establishment in a stand than 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

78

the number of trees. This is because seedlings and saplings may number in the hundreds per acre, 

but most will not survive in the understory if they are suppressed out of the stand by a larger 

overstory. 

3.3.2 Affected Environment

Approximately 76 percent of the project area is classified (using CALVEG) as Pacific Douglasfir and 14 percent as white fir. The rest of the project area (10 percent) includes seven hardwood 

cover types, five shrub types, three herbaceous types, and barren, urban, and water areas. The 

Silviculture Specialist Report (Sharp 2010) contains descriptions of Pacific Douglas-fir and 

white fire types as well as the 15 other cover types that comprise the project area. 

The coastal influence in the northern and western portions of the Two Bit project area is 

particularly noticeable. Within the Douglas-fir and white fir forest types in this area, understory

of Douglas-fir, white fir, and incense-cedar are common. Hardwoods are less common above 

4,000 feet in elevation and are replaced by shrubs and herbaceous plants in the understory. Port 

Orford-cedar only occurs naturally in the western portion (and below approximately 4,400 feet 

on the northern boundary) within or adjacent to streams and wet areas. Western white pine 

replaces sugar pine in cooler areas generally above 3,600 to 4,500 feet and occurs mostly in the 

western portion of the project area. Brewer spruce occurs on cooler sites on north and east 

aspects at elevations above 3,500-4,000 feet in the western and northern portion. Chinquapin is 

the most common hardwood found in the understory in much of the project area.

In the southern and eastern portions of the project area, less precipitation falls and coastal 

influences are more moderate. On mid-slopes and ridges, drier-site species such as sugar pine, 

black oak, and madrone are common. Ponderosa pine is generally only present on ridges below 

4,000 feet on thinner soils with low water- holding capacity. Jeffery pine occurs on ultramafic 

soils. 

Black oak, madrone, and chinquapin occur together or are dispersed by stand conditions. 

Black oak is most abundant on south or western aspects in the southern half of the project area. 

Madrone occupies stands with deeper soils in this area. Chinquapin is more common on moist 

gravelly soils. Tan oak is found on the more mesic sites with deeper soils mostly in the southern 

portion of the watershed at lower elevations. Tan oak is shade tolerant and can also be found in 

shrub or tree form in the understory in stands with high canopy cover throughout the project area 

generally below 3,800 feet. Canyon live oak occurs on thinner and rocky soils and is more 

common in the southern portion of the project area where less precipitation falls. Big leaf maple 

is scattered throughout the project area and grows best on deep, well drained soils with abundant 

moisture. It is quite tolerant to shade and commonly establishes in forest understory. On drier 

upland sites, big leaf maple can replace oaks and madrone in the absence of significant 

disturbance (Niemiec et al. 1995, pgs 12-18). It exists in both of these roles within the Two Bit 

project area.
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

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Canopy Cover 

The generally wet climatic conditions over the last 200 years have contributed to an extensive 

coniferous cover. Additionally, the decrease in the amount of fire over the last 80-100 years has 

allowed understory vegetation to survive and accumulate. White fir has moved into natural 

stands and plantations at lower elevations; within or adjacent to stands proposed treatment, the 

oldest and largest trees are Douglas-fir. White fir trees typically about 150 years old, are 

scattered in cooler areas down to 2,300 in elevation, but the majority of white fir below 4,000 is 

younger regeneration that has come in over the last 100 years. 

Table 17 displays canopy closure within the project area. Nearly 87 percent of the area has a 

canopy closure greater than 40 percent. Canopy cover has increased since the Indian Creek 

Watershed Analysis (USDA Forest Service 1997) was completed.

Table 17. Existing condition, acres by vegetation cover (canopy closure)

CWHR Closure Class Vegetation Cover 

(Canopy Closure) Total Acres Percent of Project 

Area

Not Determined/ Not 

Applicable

4,236 6.3

Dense Cover > 60% 48,535 71.4

Moderate Cover 40.0 – 59.9% 10,539 15.5

Open Cover 25.0 – 39.9% 3,812 5.6

Sparse Cover 10.0 – 24.9% 837 1.2

Grand Total 67,959 100

Past Harvest

Approximately 18 percent of the project area includes plantations from past regeneration harvest.

Table 18 displays the acres by forest type that have been harvested with a regeneration 

prescription in the past. No regeneration harvest has taken place in the Two Bit project area since 

1995. Some of these older plantations are proposed for commercial thinning in this project.
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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Table 18. Existing condition, acres of forest type regenerated to plantation within the Two Bit 

Project Area

Forest Type Acres

Douglas-fir – White fir 65

Jeffery pine 107

Mixed conifer - fir 125

Mixed conifer - pine 17

Pacific Douglas-fir 10,625

Port Orford-cedar 3

Red fir 5

White fir 975

Grand Total 11,922

Plantations between 40 and 50 years old are proposed for thinning. These plantations are on 

moderate to high sites; most often had tractor site preparation in the past to remove competing

vegetation, and had cultural treatments such as release and precommercial thinning. These 

conditions have allowed good tree growth; 40 to 90 percent of the trees in the plantations are 

over 10 inches diameter breast height (dbh). Plantations were also chosen because they could be 

yarded with ground-based systems that make it more economical to thin and harvest small 

diameter trees. 

Nearly 90 percent of the area that was harvested in the past is classified as Pacific Douglasfir. There are, however, small areas within many plantations that have serpentinized soils, 

hardwood and shrub sites, or riparian vegetation. Approximately 25 percent of the plantations 

within the Douglas-fir and white fir types were planted with ponderosa pine; these are often 

referred to as off-site pine.

Insect and Disease Conditions

The last decade included two of the driest years recorded since the early 1900s resulting in

accelerated tree mortality. Increasing density and dry conditions contributed to increased pine 

beetle mortality in sugar pine and other pines. Douglas-fir mortality, including older trees, 

increased on drier sites. Mortality is due to Flatheaded fir borers (Melanophila drummondi), 

Douglas-fir engraver (Scolytus unispinosus), and Douglas-fir beetles (Dendroctonus 

pseudotsugae) and laminated root rot (Phellinus weirii).

Insects and diseases that are most common in the treatment units include pine beetles 

(Dendroctonus ponderosae, D. brevicomis, D. valens , Ips spp), Douglas-fir engraver beetles 

(Scolytus unispinosus), Douglas-fir beetles (Dendroctonus pseudotsugae), western oak bark 

beetles (Pseudopityophthorus pubipennis), wood borers ( Buprestis sp.), red ring rot (Phellinus 

Phellinus Phellinus pini), velvet top fungus (Phaeolus schweinitzii), black stain root disease 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

81

(Leptographium wageneri), and white pine blister rust (Furniss 1977, Scharpf 1993, and Sharp , 

personal observations). Phellinus Phellinus pini conks are the most obvious disease effecting 

Doulgas-fir in the natural stands within project area. Phellinus pini infection occurs most 

frequently in dense stands where self pruning creates entry points for spores that germinate on 

branch stubs remaining after shading has killed the branches (USDA Forest Service 2006).

Douglas-fir beetles have a preference for larger diameter trees and characteristics positively 

correlated with attack include poor growth, high stand densities, and bark and phloem thickness.

Preventive control in inland forests can result from thinning and harvesting (Furniss 1977). The 

Two Bit project is near the transition zone between coastal and inland Douglas-fir, but as 

discussed earlier, much of the project area has a coastal influence. Consequentially, the Douglasfir beetle mainly affects stands in the dryer site in the southwestern portion of the project area.

The Douglas-fir engraver usually attacks weakened, injured, dying and recently dead young 

Douglas-fir and is commonly the final killing agent for suppressed trees. Wood bores also 

commonly attack weaken or dying trees and are common in the project area. The oak bark beetle 

sometimes kills seriously weakened oaks and infests bole and branches of injured, fallen, or 

recently dead trees; they are present in nearly all dead oaks in the project area.

Black stain root disease affects mostly younger trees less than 60 years old on the Happy 

Camp District. It is a fungus that lives in the vascular system of roots and blocks the tree’s water 

supply. Long distance spread is thought to be by root-infesting bark beetles and weevils in the 

project area; disease sites are small with often only 2-10 trees affected.

There are no known infestations of Port-Orford-cedar root disease (P. lateralis) within the 

Indian Creek Watershed.

Vegetation Conditions in Stands Proposed for Treatment 

Treatments are proposed in approximately 142 units. In order to produce a manageable amount 

of stand-specific data to display FVS modeling, similar types of units were grouped into 17 

stand/unit types for sampling and modeling. These 18 unit types are described below to provide 

detailed examples of the stand structures and species compositions of the units proposed for 

thinning. The effects of thinning on structure and composition are described in the environmental 

consequences section below. Individual stands that are represented may differ somewhat from 

the 18 unit types in species composition, stocking, and tree diameter distribution; the data shown 

precisely represent only the stand for which the data is taken. However, units represented by the 

sample units exhibit similarities in stand structure, age, site quality and past history and similar 

treatments are proposed for these representative stands. The units represented by each sample 

group are described in detail below and their characteristics are summarized at the end of the 

descriptions in table 19.
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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Species Key

BM – bigleaf maple (Acer macrophyllum) PP – ponderosa pine (Pinus ponderosa)

BO – California black oak (Quercus kelloggii) WF – white fir (Abies concolor)

CY – canyon live oak (Quercus chrysolepis) SP – sugar pine (Pinus lambertiana)

DF – Douglas-fir (Pseudotsuga menziesii) IC - incense-cedar (Calocedrus decurrens),

Unit 11 – Ponderosa Pine Plantation – 159 acres

Representing Units 2, 11, 12, 20, 30, 42, 81, 95, 96, 99, and 102

These plantations are predominately PP with varying amounts of hardwood, DF, IC, or WF. The 

elevation is low to moderate, the site quality is moderate to high, and PP is growing fairly well 

considering the density. SDI is high to very high for PP, generally around 75-85 percent of 

maximum; small groups of trees show pine beetle effects. In dense pockets, bole and tops of PP 

have broken and some have been up-rooted. Unit 30, in particular, has extensive pockets of pine 

beetle mortality. The more shade tolerant DF, including trees less than 10 inches dbh, are 

growing well with long, full crowns. Some stands (e.g., Unit 99) have heavy natural regeneration 

of DF, WF and IC under the PP canopy.

Objectives include increasing the percentage of DF, reducing pine density, and maintaining

hardwoods that are being shaded out. Proposed thinning under action alternatives would include 

spacing in PP of about 30 feet, leaving most of the DF (including trees 8-10 inches dbh over 

larger PP), and free thinning to release hardwoods and other desired conifer species. Where the 

stands contain 10-20 percent DF or dense patches of DF, DF would be thinned to around 26 to 

28-foot spacing. Some small diameter trees that are not large enough to harvest would be 

retained after treatment and natural regeneration would continue to occur.

Unit 31 – Douglas-Fir Plantation – 306 acres

Representing Units 13, 19, 29, 31, 36, 37, 61, 62, 65, 71, 76, 79, 83, 84, 85, 88, 113, 114, and 

121 

These plantations are generally well stocked with DF and some PP and hardwoods (chinquapin, 

madrone, black oak, canyon live oak). Tree size varies depending on soil depth, slope and water 

drainage within the unit with QMDs of 8-10 inches. Steeper areas and areas with serpentine 

influence have a high percentage of trees from 6-10 inches dbh. Most areas contain greater than 

100 trees per acre less than 10 inches dbh and have pockets of young natural regeneration in 

more open areas. SDI is just over 60 percent of maximum for DF and growth has slowed over 

the last 10 years.

Objectives include reducing stand density and providing more growing space for the 

codominant trees and smaller trees left after thinning and maintaining or encouraging stand 

diversity including some of the hardwoods. Proposed thinning under action alternatives would 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

83

include spacing of DF larger than 10 inches to around 30 feet and leaving only 10-20 percent of 

the stand in small trees after thinning and fuel treatment. Some natural regeneration would occur. 

Unit 33 – Douglas-Fir Plantation – 181 acres

Representing Units 33, 40, 41, 59, 67, 77, 78, 80, 93, and 119 

These plantations have patchy stocking with areas of dense smaller diameter trees and brush or 

hardwood. Sites are generally lower quality. Some have steeper slopes and some are near ridge 

tops where soil is thin. Still the SDI averages over 60 percent of maximum. Most of the trees in 

Unit 67 are less than 10 inches dbh and may be thinned at a later time. Unit 40 also has few 

areas, mostly skid trails and tractor piled areas, where there are many trees over 10 inches dbh.

Objectives include reducing stocking with relatively heavy thinning so that stands would not 

need to be thinned again until the smaller trees grow and stands are approaching mid-maturity. 

Spacing of DF over 10 inches dbh would be around 33 feet and allow more rooting space on 

these less fertile sites. In stands near ridges, wide spacing would reduce the risk of crown fire.

Unit 48 – Douglas-Fir Plantation – 166 acres

Representing Units 4, 6, 7, 9, 16, 27, 28, 47, 48, 49, 50, and 63 

These plantations are higher elevation and contain DF, and some WF, IC and PP. Some WF is 

appropriate at this elevation. Stocking is dense in most area of the stands with SDI around 55

percent-60 percent of maximum. Crowns are generally longer and narrower in these stands 

presenting a lower crown base height when considering fire torching risk. Snowbrush, bitter 

cherry, and chinquapin are common scattered or in patches. Some stands contain dense areas 

dominated by smaller diameter (5-9-inch trees) from natural regeneration.

Objectives include reducing stand density, reducing PP, maintaining IC, and maintaining DF 

as the dominant species over WF. Spacing will be 26-28 feet in trees over 10 inches with smaller 

scattered trees or groups of trees. Natural regeneration would occur; review of the units 10 years 

after treatment to would be recommended to assess for control excessive WF regeneration.

Unit 51 – Ponderosa Pine Plantation – 105 acres

Representing Units 3, 21, 43, 46, 51, 52, 53, 54, 58, 64, and 118 

These stands are at higher elevation and were planted with PP and have only a few natural DF, 

IC, or WF and scattered hardwood. Five to 30 percent of the trees have broken or bent tops and 

many trees have bends or crooks in the upper bole from snow damage. These stands are dense to 

very dense and SDI may be as high as 95 percent of the maximum for PP in stands such as Unit 

51. Pine beetle mortality is low in these stands presently, but stands are at high risk for heavy 

mortality at these densities. There is some natural regeneration or brush where stands are less 

dense or needle retention is so low sunlight can pass through the sparse crowns to the ground. 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

84

Objectives include removing badly damaged trees, maintaining the largest pine with the least 

amount of damage, and providing growing space for natural regeneration of DF, IC, and WF.

Under action alternatives, PP would be thinned to a spacing of around 35 feet. Review of stands 

after fuels treatment is recommended to assess regeneration; planting would be considered if 

natural regeneration was not occurring in adequate amounts to provide stocking to replace the 

maladapted PP over the next 50 years. 

Unit 97 - Ponderosa Pine Plantation – 72 acres

Representing Units 87, 97, 115 (partial 27 acres), 116, and 117 

These are lower elevation PP plantations with few other conifers species. Due to the dense 

canopy, among other things, there is little regeneration of other species. Pines are growing well 

and are more adapted to the lower elevation, however due to the high density, stand heath is 

decreasing. Pine beetle mortality is occurring in Units 116 and 117.

Objectives include reducing stand density below 35 percent of maximum SDI to produce a 

widely spaced pine stand for more than 30 years. Action alternatives would maintain PP over 10

inches dbh at about 33-foot spacing. 

Unit 100 – Douglas-Fir plantation – 376 acres

Representing Units 1, 22, 23, 24, 38, 55, 56, 68, 75, 86, 92, 94, 100, 105, 112, and 50 acres of 

115

Stands are similar to Unit 31, but contain less young regeneration. These plantations are 

generally well stocked with mostly DF and scattered hardwoods (madrone, chinquapin, black 

oak). They contain pockets of deep soil with larger trees and heavy stocking and areas of poorer 

site with smaller trees and some small open areas. SDI is slightly over 60 percent and diameter 

growth has slowed to one half or less in the last 10-12 years from the previous growth. Selfthinning has started to occur, but is generally light. 

Objectives include reducing stand density and maintaining or encouraging stand diversity 

including some of the hardwoods. Proposed treatments under action alternatives would include 

thinning of DF larger than 10 inches to around 28-foot spacing; in addition, some groups or 

scattered smaller trees would be left after treatment especially on thinner soils. Some natural 

regeneration would occur. 

Unit 108 – Douglas-Fir Plantation – 87 acres

Representing Units 8, 10, 32, 60, 108, 120, and 203

These are DF plantations on high or very high site that have consistently 200-220 basal area per 

acre. Stands have high canopy closure (85-95%) and are in the stem exclusion phase; there is 

little natural regeneration and few hardwoods within the stands. Existing spacing among the 

plantations is varied, but stands that were thinned when young, have some plantations trees over 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

85

20 inches dbh. The SDI is just over 55 percent and although growth is still good on these high 

sites, it has slowed in the last 10 to 14 years to less than half of what it was previously growing.

As the density continues to increase, around 57 percent of the trees can expected to die over the 

next 30 years based on modeling.

Objectives include reducing stand density and maintaining enough basal area to support 

another thinning entry in 25-30 years on regulated land. Objectives for stand 108 (within LSR) 

would be to maintain it as foraging habitat in the short-term by retaining 50 percent canopy 

cover or greater, maintaining a residual basal area of at least 120 square feet/acre, and allowing 

greater mortality when most of the trees are over 24 inches in diameter. Other units in this group 

are not considered foraging habitat because they are too dense for owls to use. Proposed 

treatments outside of LSR under the action alternatives would include thinning to about 27-foot 

spacing or removing around half of the basal area.

Unit 110- Douglas-Fir Plantation – Prescription for Stands that are not Foraging Habitat 

-140 acres

Representing Units 18, 26, 66, 70, 71, 89, 91, and 101

These stands are represented by data from Unit 110, but are not NSO foraging habitat. They 

would have a heavier thinning than similar units that are considered foraging habitat. These 

stands are on high sites and are similar to Unit 108 except the trees are generally at closer 

spacing, the basal area is less, the trees are smaller (trees mostly 14 inches dbh and a few larger) 

and there is either more natural regeneration under the canopy or more openings. Stands, such as 

Unit 66, do have sparser areas on steeper slopes or larger trees in areas with wider spacing or 

deep soil. The SDI is at or just over 55 percent of the maximum for DF.

Objectives include reducing stand density to a level where the stands would grow back to 

nearly 55 percent of the maximum in 30 years and improving fire resilient conditions.

Unit 110- Douglas-Fir Plantation with Foraging Habitat/LSR Prescriptions – 51 acres

Representing Units 103, 104, 109, 110, and 111 

These stands are on high sites and are similar to Unit 108 except the trees are generally at closer 

spacing, the basal area is slightly less and the trees are smaller (trees mostly 14 inches dbh) with 

patches of wider spaced larger trees (18-20 inches DBH) and some mixed species. Unit 109 has 

some larger Port-Orford-cedar in wet areas. The majority of the hardwood is big leaf maple in 

more sparse areas of 109, 110, and 111. Units 103 and 104 include steeper slopes near ridge tops 

with thinner soils and madrone is the predominate hardwood in these stands; Unit 103 is outside 

of the LSR. The SDI is generally at or just over 55 percent of the maximum for DF. 

Objectives for these units include maintaining foraging habitat by retaining at least 50 

percent canopy cover and 120 square feet of basal area after treatment. Areas in the stand with 

less than 120 square feet of basal area would not be thinned. Treatments would be designed to 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

86

reduce density, grow larger diameter trees at an accelerated rate, and reduce fire hazard to 

maintain habitat in LSR units in the long term.

Unit 201 – Natural Stand Dominated by Douglas-Fir – 64 acres

Representing Units 200, 201, 209, 244, and 258

These stands are multi-aged and multi-sized and are dense with a variety of species at mid and 

lower elevations. They are mid and late seral stands with some older and relic trees. Unit 201 has 

had previous harvest and contains open areas with dense regeneration from 20 to 50 years old.

Steeper slopes in Unit 200 are occupied by hardwoods with younger conifers at a wider spacing. 

These stands are on high quality sites and the SDI is well over 55 percent of maximum and, in 

parts of the stands, is close to 100 percent of the observed maximum for DF in the Klamath 

Mountains. These sites are high quality with available underground water. Competition mortality 

of species such as sugar pine (including larger trees) and shade intolerant hardwoods are 

occurring. Suppressed DF trees of various sizes are also dying in small amounts.

Objectives include reducing stand density, maintaining some of the more shade intolerant 

species, maintaining good growth rates in individual trees, reducing the risk of heavy 

competition-induced mortality, and utilizing potential mortality for wood products.

Unit 206 - Natural Stand Dominated by Douglas-Fir – 80 acres

Representing Units 205, 206, 214, 216, 218, 226, 228, 229, 236, 254, and 256

These stands are relatively young (many trees 90 to 130 years old), but all have areas that 

include older trees. All stands have unique characteristics, but have the SDI is similar and stand 

options are similar. The stands contain trees of various diameters depending on the spacing 

within each stand. Unit 214 is high elevation. Unit 228 is at mid elevation, but now is 70-80

percent WF and although it is not very active presently, there is WF mortality from annosus root 

disease; armillaria root disease is also present. Unit 256 was naturally regenerated after 

hydraulic mining in the early 1900’s (Huey mine). The stands are dense and the SDI is around 93

percent of maximum. The average crown ratio is decreasing and growth has been decreasing for 

several decades due to density. 

Objectives include reducing stand density, maintaining some hardwoods and sugar pine, 

maintaining good growth rates in individual trees, reducing the risk of heavy competitioninduced mortality, and utilizing potential mortality for wood products.

Unit 213 - Natural Stand Dominated by Douglas-Fir and White Fir – 26 acres

Representing Units 211, 212, and 213

These are very dense stands at high elevations with a mix of DF and WF on south aspects.

Stands are late seral with patches of smaller and younger trees. The SDI is close to the observed 

maximum for DF in this area, and at 68 percent of the maximum SDI for WF. These stands are 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

87

just on the south side of the ridge adjacent to the Oregon border and receive more precipitation 

that other parts of the project area allowing high stand densities. Douglas-fir are the oldest and 

largest trees in the stand. Most of the mortality in the stand has been smaller (20 inches dbh) WF.

There are a few SP snags in the area, but it has died out of these stands due to high density.

Objectives include reducing stand density, maintaining the health of individual trees to retain 

the structural components of this stand, reducing a potentially high level of competition-induced 

mortality and greater fire risk that would be associated with the increase in surface fuels and 

utilizing potential mortality for wood products. The stands would be thinned to around 55

percent of maximum SDI for DF allowing some continued mortality to meet snag and CWD 

needs. Because these stands are older and very dense, they would be maintained at higher a 

density than other stands in the project. 

Unit 225 - Natural Stand Dominated by Douglas-Fir – 76 acres

Representing U nits 208, 217, 220, 225, 243, and 253 

These stands are generally less dense due to past thinning and sanitation harvest or a 

combination of environmental site conditions and harvest. Units 208 and 217 were underburned 

about 15 years ago. Several of the stands have dwarf mistletoe in a few of the older DF or WF. 

The average SDI is around 65 percent of the maximum, but varies throughout the stands. Stands 

contain a mix of trees that are different ages and sizes and include regenerated patches. 

Objectives include reducing stand density especially in clumps, removing some of the 

diseased trees, and maintaining or improving fire resilient conditions across the stand. 

Unit 227 – Natural Stand Dominated by Douglas-Fir – individual stand of 10 acres

This stand has large, old, decadent DF widely spaced with a mix of dense clumps of younger 

(80-130 years old) DF, WF and RF, and sparser areas with DF and true fir, scattered large sugar 

pine, a few small brewer spruce, and a dense layer of sadler oak averaging 3 feet tall. The dense 

portions of the stand are at nearly 80 percent of the maximum SDI and the rest of the stand is 

over 55 percent of maximum. There has been previous sanitation and salvage harvest of 

individual live and dead trees in the stand, mostly the large DF. The most noticeable pathogens in 

the stand are DF and RF mistletoe, cytospora canker in the RF, velvet top fungus, and blister rust 

in the sugar pine. Pine and fire beetles are mostly infesting suppressed trees and although much 

of the WF appears stressed, there are not large centers of mortality from annosus root disease.

Most of the oldest DF have broken tops or are diseased. There is some mortality in all of the age 

classes.

Objectives include reducing stand density and promoting growth of large DF as replacement 

trees, maintaining species diversity including brewer spruce, improving overall stand health, 

utilizing potential mortality to maintain low levels of surface fuels, and reducing ladder and 

crown fuels.
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

88

Unit 234- Natural stand of Douglas-Fir or Ponderosa Pine with Black Oak or Madrone 

Clumps – 27 acres

Representing Units 234 and 400

Both of these stands have or had a large component of oak. Unit 234 is located on a small ridge 

that runs east and west and is mostly on a south aspect. The ridge has large black oak trees that 

have or are being been shaded out by the DF. The remainder of the stand has pockets of DF with 

sugar pine and IC and areas of wider spaced DF stocked at 160 basal area with scattered black 

oak. A few large madrones are growing around the perimeter on the north boundary. The SDI is 

at 55 percent of maximum for DF, but this equates to 79 percent of the maximum for black oak.

The stand was underburned about 15 years ago, but a low level of slash still remains from past 

partial harvesting. Many of the dead oaks that have fallen are contributing to the surface fuel 

loading.

Objectives include reducing the amount of DF, promoting the presence of black oak and 

other hardwoods and maintaining a fire resilient stand on this ridge top.

Stand 400 includes Oregon white oak and black oak, madrone, chinkapin, tan oak, PP, and 

DF of mixed ages. The majority of the conifers are younger than the older oaks. The DF are 

thick in some areas and scattered in others, but have shaded out much of the younger hardwood.

Most DF are in poor health on this “oak and pine” site and a number have dead tops or are dying 

from attacks of bores and beetles. The understory contains small suppressed trees with a ground 

cover of fescue and other grasses. There is yew and azalea in the wet area. Portions of the stand 

are flat so that wood cutter can access the area and about 5 percent of the hardwoods have been 

removed as firewood.

Objectives include removing the DF and tan oak where less shade tolerant oaks are present, 

maintaining large PP and some IC in the stand, and maintaining shade for the yew while 

allowing sunlight for the azalea.

Unit 238- Natural Stand Dominated by Douglas-Fir - Individual stand of 10 acres

This unit is a late seral stage stand with a few patches of younger trees. It is located on a rocky 

knoll on a south aspect. Species include DF, WF, IC and SP with huckleberry oak and grasses in 

the openings. The stand is on relatively poor soil, but there is available underground water. The 

SDI is at 80 percent of the maximum for DF, and appears to have developed under relatively 

open conditions so that the trees grew large and the site is now fully occupied. Nearly all the 

trees less than about 16 inches dbh have been suppressed out of the stand giving this dense stand 

an open appearance. Several of the sugar pine has died. Approximately 15-20 percent of the 

basal area is composed of trees greater than 42 inches dbh, 40-50 percent of the basal area

includes trees from 26 to 40 inches dbh, and 35-45 percent of the basal area includes trees 24

inches dbh or less. The larger trees (34 inches dbh or larger) tend to be grouped together. Overall 

the stand is doing remarkably well considering site condition.
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

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Objectives include reducing stand density to slightly less than 55 percent of the maximum 

SDI to maintain stand health and large trees and reducing risk of accelerated mortality.

Unit 255 - Natural Stand Dominated by Douglas-Fir - 35 acres

Representing Units 219, 242, 255 and 257 

These are stands that average around 240 basal area per acre. Units 219 and 257 are younger and 

include trees generally less than 120 years old. Unit 242 (high elevation) and 255 contain more 

large, older trees; both also contain WF although unit 255 is at 2300 feet. The SDI of these 

stands is about 73 percent of the maximum for DF and some mortality has occurred. Hardwoods 

are scattered and are mostly being shaded out with the exception of big leaf maple. Objectives 

include reducing stand density below 55 percent SDI for not more than 30 years, reducing the 

percentage of WF, and maintaining hardwoods and sugar pine where possible. 

Units 300 and 237 - Natural and Regenerated Stands Dominated by Douglas-Fir –

Individual stands totaling 38 acres

Unit 237 is a stand that was harvested with a partial cut prescription in 1976 and re-entered in 

1987 to be regenerated because the stand had less stocking that the site was capable of growing 

or was stocked with trees that were generally of low vigor. The regeneration harvest maintained 

several overstory trees, second growth patches, and small understory trees that are infected with 

Douglas-fir dwarf mistletoe. In part likely due to better growing conditions for the pathogen, 

these trees are now heavily infected and mistletoe has infected the adjacent Douglas-fir. The SDI 

in unit 237 is low other than a few overstory trees, the stand is composed of conifer seedling and 

saplings and brush; this unit was not modeled with FVS.

Objectives include removing badly infected trees and regeneration to promote conditions to

improve future stand health.

Unit 300 is a strip approximately 200 feet wide on of both sides of Road 19N06 less than a 

mile in length. It contains small groups or individual trees that are infected with dwarf mistletoe.

Larger trees include several co-dominant trees or isolated trees of the same size that are either 

located where they would infect healthy stands or regeneration. This unit is a mix of natural 

stands and stands harvested with varying prescriptions including thinning and regeneration 

harvesting. Due to the variation in condition and the small amount of trees that would be 

removed, this stand was not modeled with FVS

Objectives include removing badly infected mature trees and regeneration and slowing the 

spread of mistletoe along this one section of road.

Units 301 and 302- Dense Natural Regenerated Stands along Roads – Individual 

stands totaling 84 acres

Unit 301 contains IC and DF and Unit 302 is DF. The units contain thickets of saplings and pole 

sized trees that seeded in the fill slope after the roads were constructed and the area within about 

100 of the road. Due to the variation in condition and the irregular intervals in which trees will 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

90

be removed over the next 10 to 20 years, this stand was not modeled with FVS. The SDI is high 

in the thickets (density-induced mortality is taking place) and generally lower away from the 

road fill. 

Objectives include reducing stand density to produce larger trees with adequate growing 

space, improving conditions for road maintenance, and providing products available to the public 

under pole permits.

The sample units and modeling data are displayed in table below. The tables contained in the 

following environmental consequences section compare the SDI, TPA, and QMD of the various 

stand types modeled by the sample units.

Table 19. Representative units: existing conditions 

Sample Unit

SDI (Percent of 

maximum for 

dominant 

species)

TPA QMD

Desired species to 

be 

increased/maintaine

d or less desired 

species to be 

reduced

11 371- (PP – 86%) 429 9.1 Increase DF, IC, 

hardwood

31 (DF portion) 352 (DF- 64%) 446 8.6 Increase Hardwood, 

IC

33 337 (DF- 62%) 452 8.3 Maintain hardwood, 

reduce WF

48 323 (DF - 59%) 464 8.0 Increase DF, IC

51 410 (PP - 95%) 383 10.4 Increase DF, WF, IC, 

hardwood

97 (LSR) 269 (PP - 63%) 399 7.8 Increase DF, IC, 

hardwood; reduce WF 

regen.

100 334 (DF - 61%) 280 11.2 Maintain madrone

108 (LSR) 322 (DF - 59%) 190 13.9 Maintain Big leaf 

maple

110 (not foraging 

habitat)

315 (DF - 56%) 260 11.3 Maintain hardwood, 

reduce WF regen,

110-LSR/foraging 

habitat

315 (DF - 56%) 260 11.3 Maintain hardwood, 

reduce WF regen,

201 544 (DF - 99%) 394 12.2 Maintain SP, IC 

hardwood, reduce 

WF.
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

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Sample Unit

SDI (Percent of 

maximum for 

dominant 

species)

TPA QMD

Desired species to 

be 

increased/maintaine

d or less desired 

species to be 

reduced

206 511 (DF – 93%) 341 12.9 Reduce WF, maintain 

hardwood.

213 517 (DF - 95%) 110 26.3 Favor DF

225 355 (DF - 65%) 253 12.3 Maintain SP, 

hardwood; reduce WF

227 (clumps) 428 (DF - 78%) 206 15.8 SP, DF, BS; reduce 

WF

234 302 (DF - 55%) 

(BO - 79%)

135 16.5 Increase BO, SP

238 436 (DF - 80%) 81 28.6 Maintain SP

255 398 (DF - 73%) 264 12.9 Maintain hardwood; 

reduce WF

Weighted 

Average

69% 357 11

3.3.3 Environmental Consequences

Alternative 1- No Action 

Direct and Indirect Effects

Vegetation in the project area would continue to grow; stands would increase in density and tree 

mortality would increase over time. Table 20 shows modeled SDI values for alternative 1in 30 

years. Thirty years is a reasonable amount of time to expect the modeling to retain accuracy and 

is about the time period identified by the Happy Camp Ranger District before another thinning 

would be considered.

Table 20. No Action Alternative, Comparison of SDI for Existing Condition and 30 Years Out

Stand example Unit No.

SDI (percent of 

maximum for dominant 

species)

2039 SDI (percent of 

maximum for 

dominant species)

Unit meets Desired 

SDI (55 percent of 

maximum)in 30 

years

11 - PP plantation 371 (PP - 86%) 363 (84%) No

31 - DF plantation 352 (DF - 64%) 386 (71%) No

33 - DF plantation 337 (DF - 62%) 424 (78%) No
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

92

Stand example Unit No.

SDI (percent of 

maximum for dominant 

species)

2039 SDI (percent of 

maximum for 

dominant species)

Unit meets Desired 

SDI (55 percent of 

maximum)in 30 

years

48 - DF plantation 323 (DF - 59%) 492 (90%) No

51 - PP plantation 410 (PP - 95%) 329 (77%) No

97 (LSR) - PP 

plantation 269 (PP - 63%) 353 (82%) No

100 - DF plantation 334 (DF - 61%) 454 (83%) No

108 (LSR) - DF 

plantation 322 (DF - 59%) 373 (68%) No

110 - DF plantation

(not foraging habitat) 315 (DF - 56%) 388 (71%) No

110-LSR/foraging habitat 315 (DF - 56%) 388 (71%) No

201 - DF natural 544 (DF - 99%) 431 (79%) No

206 - DF naural 511(DF - 93%) 382 (70%) No

213 - DF natural 517 (DF - 95%) 331 (61%) No

225 - DF natural 355 (DF - 65%) 422 (77%) No

227 (clumps) - DF 

natural 428 (DF - 78%) 384 (70%) No

234 - DF/BO natural 302 (DF - 55%) (BO -

79%)

353 (DF-65%) (BO92%)

No

238 - DF natural 436 (DF - 80%) 280 (51%) Yes with mortality

255 - DF natural 398 (DF - 73%) 402 (73%) No

Weighted Average 69% 78% No

Nearly all the stands in the project area (modeled by the sample stands) are at or above 

desired stocking levels; self-thinning is occurring and they are within the zone of imminent 

mortality (greater than 55% of the maximum SDI). The number of trees that can occupy a site 

decreases exponentially with time and with an increase in the average size of the trees (Oliver 

1996, pg.343). Most of the mortality predicted over the next 30 years would be of regeneration 

in the understory or suppressed trees, but mortality would include some larger trees that would 

succumb to the competition pressure especially within groups of larger trees. Some of the large 

sugar pine and hardwoods in all stands that have those species have died. 

None of the stands, except Unit 238, would be expected to reach the desired SDI of 55

percent of maximum in 30 years without some type of natural disturbance (fire, insects, blow 

down). Unit 238 is an older unit at high density composed mainly of larger trees. Competition-
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

93

induced mortality is predicted to reduce the stocking to less than 55 percent; when the trees are 

big, the death of over half the trees in the stand (table 21) is a substantial reduction in SDI.

The ponderosa pine plantations are at extreme risk to bark beetle mortality based on the 

calculated SDI for these stands, and several of the stands including Unit 11 are presently 

experiencing pockets of mortality from beetles. It is unlikely that these stands would actually 

maintain the calculated SDI for another 30 years without heavier than predicted losses from 

beetles. Unit 51 is near the maximum SDI and growth under the high level of completion as well 

as the fact that the trees are off-site ponderosa pine, has resulted in small, weak trunks and tops 

that are bending and breaking under the snow in about 30 percent of the trees. Nearly all the 

trees in this stand and similar stands have some bends in the top stems as the trees continue to 

grow up, but grow little in diameter. The crown ratios and needle retention is poor in the denser 

portions of all the pine stands. A crown ratio of 30 percent or less and poor growth has also been 

linked to beetle attack in pine (Fettig 2006).

Although codominant Douglas fir trees in plantations are still growing well in height, all 

stands sampled showed a marked decrease in diameter growth over the last 10-15 years. Stands 

have been experiencing low levels of self-thinning in the understory consistent with the onset of 

competition. Crown ratios in denser portions of all units are decreasing and are averaging 40 

percent. The intermediate and suppressed trees have crown ratios less than 30 percent. This self 

pruning has contributed to a higher canopy base height resulting in a more fire resilient stand.

However, as the SDI continues to rise over the next 30 years to the values predicted in table20, 

the average crown ratio would be substantially reduced. If heavy self-thinning occurs, the SDI 

would be maintained at lower levels, but dead trees from self-thinning contribute to the surface 

fuel loading, and can put stands at higher risk to damage from fire.

The natural stands chosen for treatment generally have high average SDI values although 

there is a great deal of variation in stand structure within stands and among stands. Within 

natural stands, irregular spacing creates unequal growing space for each tree, resulting in some 

trees having a little growing space when stand reach crown closure and other having much 

growing space at crown closure. This causes trees to differentiate in crown position and mortality 

occurs throughout the development of these stands, and there are no dramatic waves of mortality 

(Oliver 1996, pg 346). Stands would continue to have mortality and some reduction of tree vigor 

at these high SDIs, and this would put these stands at risk of high intensity fire, if a wildfire were 

to start in the project area. 

Black oak in Unit 234 would likely all be shaded out within 30 years except those few trees 

in stand openings.

The QMD increases as the smaller trees die out of the stands and as the remaining trees 

continue to grow. Where mortality is mostly small trees, little additional growing space would be 

available and diameter growth in the stands would remain close to the decrease rates measured in 

the stands over the last 10-15 years. As stands become denser and trees age over the long term, 

growth rates would decrease to an even greater extent. Low growth rates (production of stem 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

94

wood per unit of foliage) have been associated with a tree’s inability to accumulate reserves of 

nutrients, carbohydrates, and water or to produce defensive compounds (Warning 1987, Oliver 

1996). As tree vigor and growth decline, trees become more susceptible to injury from a variety 

of insects and diseases.

Table 21. No Action Alternative for years 2009 and 2039, TPA and QMD

Stand Example Unit # TPA - QMD , 2009 

existing condition 2039 TPA - QMD

Decrease in TPA 

Increase in stand QMD 

(inches) in 2039

11 - PP plantation 429 - 9.1 198 - 14.6 231 TPA - 5.5 inches

31 - DF plantation 446 - 8.6 146 - 18.3 300 TPA - 9.7 inches

33 - DF plantation 452 - 8.3 187 - 16.6 265 TPA - 8.3 inches

48 - DF plantation 464 - 8.0 268 - 14.6 196 TPA - 6.6 inches

51 - PP plantation 383 - 10.4 116 - 19.2 267 TPA - 8.8 inches

97 (LSR) - PP 

plantation

399 - 7.8 244 - 12.6 155 TPA - 4.8 inches

100 - DF plantation 280 - 11.2 160 - 19.2 120 TPA - 8.0 inches

108 (LSR) - DF 

plantation

190 - 13.9 121 - 20.2 69 TPA - 6.1 inches

110 - DF plantation

(not foraging habitat)

260 - 11.3 128 - 20.0 139 TPA - 8.7 inches

110 - DF plantation

(LSR/ foraging 

habitat)

260 - 11.3 128 - 20.0 139 TPA - 8.7 inches

201 - DF natural 394 - 12.2 149 - 19.4 245 TPA - 7.2 inches

206 - DF Natural 341 – 12.9 107 - 22.1 234 TPA - 9.2 inches

213 - DF natural 110 - 26.3 43 - 35.6 67 TPA - 9.3 inches

225 - DF natural 253 - 12.3 179 - 17.0 74 TPA - 4.7 inches

227 (clumps) - DF 

natural

206 - 15.8 100 - 23.1 106 TPA - 7.3 inches

234 - DF/BO natural 135 - 16.5 86 - 24.1 49 TPA - 7.6 inches

238 - DF natural 81 - 28.6 33 - 37.9 48 TPA - 9.3 inches

255 - DF natural 264 - 12.9 153 - 18.2 111 TPA - 5.3 inches

Weighted Average 357 – 11 165 – 18Decrease due to self 

thinning mortality
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

95

Density of all vegetation in the stands would continue to increase at a higher rate over the 

short and long term in the absence of burning or other natural disturbance. As stands accumulate 

vegetation, some trees and shrubs would die and surface fuel would increase. Under alternative

1, tree bole damage that can occur from underburning would be avoided. Alternative 1 would not 

reduce fire severity through reduction in ladder and surface fuels because there would be no 

underburning. Units 301 and 302 would continue to self-thin at a slightly higher rate than if 

some of the trees were thinned for pole products.

Under alternative 1, meadow treatments would not take place. Trees would continue growing 

and propagating within natural meadows so that open more xeric meadow areas would continue 

to shrink. Sanitation thinning for dwarf mistletoe in Unit 300 would not take place, increasing 

the risk of spread to neighboring stands. No specialized harvest treatments for pole thinning and 

hardwood enhancement would take place.

In Unit 400 (historically dominated by oak), oaks and other hardwoods would continue to be 

over-topped by conifers and would decrease over time. Douglas-fir is also dying in this stand and 

increasing the fuel loading. Dense patches of small trees are producing hazardous fuel conditions 

that could result in higher fire intensity during a wildfire that could kill the older oaks.

Because no action would be taken under alternative 1, there would be no resultant short-term 

adverse impacts from harvest operations or associated temporary roads or skid trails. Potential 

damage to trees (wounding) from operations would be avoided. Additional compaction of soils 

would be avoided because machinery would not be used within stands. However, though shortterm adverse effects from operations would be avoided with alternative 1, long-term beneficial 

effects to tree growth and stand health would not be realized. Stands that are less dense could 

have some positive benefit because growth is still good and stands would remain more heavily 

stocked and result in a higher total wood production. However, for most stands in the project 

area, would production would be reduced due to density-related mortality and in the case of pine 

plantations; this would result in mortality from bark beetles.

Approximately 3.5 acres would remain forested if temporary roads are not constructed and 

between an estimated 40 to 60 acres would remain forested if new landings are not constructed.

Many of the roads proposed for decommissioning have become at least partially vegetated 

again with conifers, brush or hardwoods, and over the long-term this natural reclamation would 

slowly continue.

Cumulative Effects

All past activities or events affecting forest vegetation are considered in the description of the 

existing condition. Within the Indian Creek Watershed, in-progress or planned activities with a 

similar purpose and need as the Two Bit project would continue within the watershed; 

underburning and thinning from these projects would total approximately 3,345 acres. Additional 

density reduction and fuels treatment work proposed in the Two Bit project would not occur. An 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

96

opportunity would be missed to accomplish those types of treatments in combination with 

current projects and move the project area towards the desired condition.

Alternative 2 – Proposed Action 

Direct/Indirect Effects

The direct effects of alternative 2 within thinned stands would be a reduction in stand density 

from cutting and removal of trees, crushing of some vegetation during harvest, and burning or 

piling and burning of vegetation for fuels treatment. Indirect effects would include increased 

growing space for trees remaining in the stand, increased individual tree growth, increased 

ability for trees to produce defensive compounds, decreased density-related tree mortality, 

increased retention of shade intolerant species, and decreased potential for crown fire risk.

Burned units would experience reduction in tree density (to a lesser degree than thinned units)

where mostly small vegetation in the understory would be affected. Direct effects are discussed 

together in this analysis with the indirect effects resulting from proposed actions including tree 

removal during thinning. For purposes of this analysis, meadow enhancement treatments and 

specialized treatments (pole harvest and sanitation) are combined with thinning. Effects of 

underburning are discussed at the end of this section. 

Ninety-two percent of the thinning and underburning would take place in the Pacific 

Douglas-fir type, 4 percent in the white fir type, 1 percent in the Upper Montane Mixed 

Chaparral and the other 3 percent would be in 7 of the other vegetation types. Seventy five 

percent would occur in the Calveg dense cover classes with canopy cover greater than 60

percent. Thirty-two percent of the area treated would be in the small tree size class, 32 percent in 

the medium/large tree size class, and the remainder would be in smaller size classes.

Tree Thinning

Treatments would vary by degree of thinning leaving some stands more open than others 

depending on density goals related to Management Areas in the Forest Plan, stand 

characteristics, and environmental conditions. The overall direct/indirect effects of thinning 

treatments in all stands would reduce stocking and provide individual trees enough growing 

space to maintain healthy crowns and adequate rooting space. Individual tree growth would be 

maintained or improved over time depending on the age and condition of the tree. Predominant 

and relic trees would be maintained after thinning and would have reduced stress from 

competition.

Competition-related mortality would decrease in the long-term including pine beetle 

mortality in plantations. In stands where species are not well-adapted to the site or are growing 

as a result of fire suppression or other past conditions, thinning would increase the percentage of 

trees appropriate for the site. This would be done by removing mal-adapted trees and enhancing 

conditions for preferred species including natural regeneration. 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

97

Disease presence and susceptibility would decrease in the long-term after reducing 

competition and removing many of the weaker trees. Free thinning would allow species that 

have a low tolerance to shade such as sugar pine, black oak and madrone to be maintained within 

stands. Forest products would be provided as a by-product to the thinning treatments.

Changes in SDI

Many of the plantations would be thinned to low densities. Thinning to densities below 35

percent of max SDI would generally result in less growth of wood volume per acre over time, 

but is offset by greater volume and diameter growth per tree. For stand growth efficiency and 

production of wood products, an optimal thinning regime may include heavier thinnings when 

stands are younger and most capable of quickly reoccupying available growing space, as in the 

case of plantations. However, light thinnings in older stands would minimize unoccupied growth 

space where large trees are less capable of expanding into newly unoccupied growth space 

available after thinning (Oliver 1996, pg. 352). Within regulated lands, presently, fiber 

production is not practical in this area because of the lack of markets and high transportation and 

harvest costs relative to production costs in other parts of the country or import markets.

Management to grow large trees for high quality, high value lumber or other resource values is 

an option chosen for many units in the Two Bit project. This management scheme is also 

consistent with principles to reduce fire severity within stands and maintain stand health and 

vigor.

Plantations in or adjacent to LSR that have been identified as NSO foraging habitat would 

have a lighter thinning to maintain habitat with greater than 50 percent canopy and at least 120 

square feet of basal acre. This thinning would maintain the SDI below 55 percent of maximum 

for approximately 20 years, but SDI would climb to around 61 percent of maximum in 30 years. 

The QMD would increase (based on the modeling, slightly more than the heavier thinning due to 

the higher proportion of trees with 14-15 dbh retained) and the stands would benefit from an 

improved fire resilient structure. Natural stand that are presently foraging habitat would maintain 

those characteristics post treatment.

Off-site ponderosa pine plantations or those at high risk to bark beetles would have heavy 

thinning to reduce the amount of pine relative to other species in the stands and capture 

imminent mortality (Sample Units 11, 51, 97). Aggressive thinning of off-site pine trees would 

occur in these pine plantations throughout the stand including right up to steam banks (although 

no commercial harvest would occur in any inner gorges); trees contributing to streambank 

stability would not be removed. 

DF plantations near ridges would have heavier thinning to reduce risk of crown fire to a 

greater extent (Sample Unit 33). Other stands identified by the Two Bit IDT as having stand 

health concerns or located in areas where access is unfeasible would also be expected to be 

thinned well below the desired level of 55 percent of maximum SDI to maintain lower densities 

for at least 30 years as modeled by FVS (Sample Unit 31). 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

98

Table 22 displays SDI of sample stands by existing condition, post treatment in 2014 and 

post treatment in2039.

Table 22. Alternative 2, comparison of SDI for Existing Condition, Post Treatment (CT and UB), 

and 30 Years Out

Stand example 

Unit #

Existing 

condition SDI 

(percent of 

maximum for 

dominant 

species)

2014 (Post CT & 

fuels treatment) 

SDI (percent of 

maximum)

2039 (30 years 

after thinning) 

SDI (percent of 

maximum)

Meets Desired 

Condition in 30 

years; stand 

maintained 

below desired 55 

percent of 

maximum SDI

11 - PP 

plantation 371 (PP - 86%) 127 (29%) 182 (42%) yes

31 - DF 

plantation 352 (DF - 64%) 129 (24%) 215 (39%) yes

33 - DF 

plantation 337 (DF - 62%) 113 (21%) 197 (36%) yes

48 - DF 

plantation 323 (DF - 59%) 126 (23%) 243 (44%) yes

51 - PP 

plantation 410 (PP - 95%) 100 (23%) 164 (38%) yes

97 (LSR) - PP 

plantation 269 (PP - 63%) 110 (26%) 150 (35%) yes

100 - DF 

plantation 334 (DF - 61%) 161 (29%) 256 (47%) yes

108 (LSR) - DF 

plantation 322 (DF - 59%) 217 (40%) 321 (59%) yes

110 - DF 

plantation (not 

foraging habitat)

315 (DF - 56%) 173 (32%) 282 (52%) yes

110 – DF 

LSR/foraging 

habitat 

prescription

315 (DF - 56%) 191(35%) 333 (61%) No1

201 - DF natural 544 (DF - 99%) 266 (48%) 326 (60%) No1

206 - DF 

Natural 511 (DF - 93%) 245 (45%) 304 (55%) Yes

213 - DF natural 517 (DF - 95%) 313 (57%) 308 (56%) yes with 

mortality
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

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Stand example 

Unit #

Existing 

condition SDI 

(percent of 

maximum for 

dominant 

species)

2014 (Post CT & 

fuels treatment) 

SDI (percent of 

maximum)

2039 (30 years 

after thinning) 

SDI (percent of 

maximum)

Meets Desired 

Condition in 30 

years; stand 

maintained 

below desired 55 

percent of 

maximum SDI

225 - DF natural 355 (DF - 65%) 204 (37%) 265 (48%) yes

227 (dense 

patches) - DF 

natural

428 (DF - 78%) 259 (47%) 312 (57%) No1

234 - DF/BO 

natural

302 (DF - 55%) 

(BO - 79%)

158 (DF-29%) 

(BO-41%)

225 (DF-41%) 

(BO-59%) DF yes; BO No1

238 - DF natural 436 (DF - 80%) 276 (50%) 273 (50%) yes with 

mortality

255 - DF natural 398 (DF - 73%) 243 (44%) 309 (56%) yes

Weighted

Average

69% 30% 45%

Yes; met in 

most stands; 

moving 

towards desired 

in all stands 1 However, prescribed treatment substantially moves stand towards desired condition

Insects and Disease 

Thinning in this project would remove many smaller insect- and disease-infected trees; crown 

thinning in dense clumps would remove some of the moderate size trees which are infected.

Phellinus (Phellinus pini) rots the heart wood and provides habitat for cavity nesting 

wildlife, particularly in larger trees; ninety-nine to one hundred percent of the largest dominant 

and predominant trees with Phellinus pini will remain after treatment because prescriptions 

include retention of these trees even if they are diseased. Reduction in competition for water and 

nutrients by removing infected and other trees would leave more resources remaining for trees to 

produce chemicals or structural changes which limit the spread of Phellinus pini or other 

diseases.

Velvet top fungus causes severe root and butt decay. It is most often found on older Douglasfir within the project area and consequently few if any trees infected with this disease are likely 

to be thinned in this project. Velvet top can be spread through fire scars, root wounds, and root 

grafting making it important to limit residual tree damage when thinning and underburning.

Thinning will reduce root overlap and root grafting to a small degree. However, the largest 

benefit to thinning related to this disease would likely be reduction in competition for resources 

so that trees that are uninfected would remain vigorous with the ability to resist further 

infections.
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

100

One of the recommended management techniques for several root diseases, some that affect 

Douglas-fir, is to improve the host tree vigor (Fillip 1990). One way to do that is to reduce 

competition by thinning while taking precautions not to produce conditions that could exacerbate 

a situation where root disease is already present. Many of these root diseases are present on the 

District, but do not appear often, or at least are not obvious, in the project area. Thinning

prescriptions for the Two Bit project would consider any new information provided by Forest 

Service insect and disease specialists from the California region as needed.

Various research studies show the positive impact of thinning for reducing competition related to 

insect attack. There is a strong relationship between high densities and pine beetle attack for 

ponderosa (Fillip 2005, Oliver 1995, Fettig 2006). For sugar pine, from local observation and 

discussions with other silviculturists and pathologists, a similar relationship exists between 

density and pine beetles.

Management options to reduce the spread of Black Stain root disease include maintaining 

mixed species and increasing the spacing between trees so that root to root contact is limited 

(Wood 2003). When thinning, utilizing techniques that limit soil compaction can help prevent 

new infections. These techniques would be used for implementing alternative 2, including

reusing existing skid trails and existing roads whenever possible and use of equipment that exerts 

low ground pressure (such as mechanical harvesters) where possible (see project design featuresChapter 2).

Some scientists have suggested caution in using thinning to control various insects (Black 

2005). Awareness needs to be maintained concerning possible unintended consequences such as 

physical injury, soil compaction, temporary stress (thinning shock) due to changed 

environmental conditions, or excess slash available for breeding habitat which could result in 

susceptibility to certain insect and pathogens (Black 2005). Past wildfire or treatment 

underburning may also lead to weakening of residual trees making them more susceptible to 

insects or pathogens (Schmitt 2005). However, with knowledge of these potential risks, prudent 

silvicultural treatment can be implemented to minimize potential unwanted consequences (Fettig 

2006, Filip 1990). Under alternative 2, actions such as designating skid trails in locations that 

reduce residual tree damage, applying borax to true fir stumps, and thinning from below to leave 

the larger trees would be used to minimize the potential for adverse impacts.

Changes in QMD and TPA

Diameter growth is very sensitive to changes in growing space (Oliver 1996, pg 346). As 

suppressed trees die, the average tree size increases. Growing space attained by dominating trees 

equals that relinquished by trees undergoing suppression, since the growing space stays about the 

same in a stand (Oliver 1996, pg 345). In plantations where trees have little difference in crown 

position (undifferentiated stands), thinning at younger ages, when crowns are relatively large, 

increases rate of growth response to thinning (Oliver 1996, 348). Most of the plantations in the 

Two Bit project still have crown ratios of 40 percent or greater on the best codominant trees and 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

101

would respond well to thinning. Denser portions of all plantations are experiencing reduction in 

crowns due to competition. The decrease is quite noticeable in plantations where the calculated 

SDI is over 60 percent. In natural stands, crown ratios vary greatly from 10 to 90 percent

because of the irregular spacing and different ages. Trees with the poorest crowns would be 

identified for removal. 

An average of approximately 40-50 percent of the trees that would be removed during 

treatments would be small trees less than 6 inches dbh. The increase in QMD from 2009 to 2014 

(table 23) is mostly due to the “thinning effect” of removing smaller trees and leaving larger 

trees. Increase in QMD (table 23) due to the thinning effect still has a positive effect on stand 

structure relative to improved fire resiliency. Removal of the smaller trees concentrates growth 

on the remaining larger trees and removes many suppressed, unhealthy trees from the stands.

Table 23. Alternative 2 comparison of TPA and QMD for existing condition, post treatment in 2014,

and post treatment in 2039

Stand Example 

Unit #

TPA - QMD, 2009 

existing 

condition

2014 TPA - QMD 2039 TPA -

QMD

Decrease in TPA 

and increase in 

stand QMD at year 

2039 compared to 

the existing 

condition

11 - PP plantation 429 - 9.1 62 - 15.7 52 - 21.7

377 TPA - 12.6 

inches

31 - DF plantation 446 - 8.6 74 - 14.2 65 - 21.0

381 TPA - 12.4 

inches

33 - DF plantation 452 - 8.3 84 - 12.0 69 - 19.2

383 TPA - 10.9 

inches

48 - DF plantation 464 - 8.0 69 - 14.6 81 - 19.8

383 TPA - 11.8 

inches

51 - PP plantation 383 - 10.4 56 - 14.3 69 - 17.1 314 TPA - 6.7 inches

97 (LSR) - PP 

plantation

399 - 7.8 53 – 15.9 45 - 21.1

354 TPA - 13.3 

inches

100 - DF 

plantation

280 - 11.2 70 - 16.8 67 - 23.0

213 TPA - 11.8 

inches

108 (LSR) - DF 

plantation

190 - 13.9 78 - 19.0 71 - 25.5

119 TPA - 11.6 

inches

110 (LSR) - DF 

plantation (not 

foraging habitat)

260 - 11.3 85 - 15.6 75 - 22.8

185 TPA - 11.5 

inches

110 – DF

plantation 

260 - 11.3 108 - 15.6 87 – 23.0 80 TPA - 11.7 inches
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

102

Stand Example 

Unit #

TPA - QMD, 2009 

existing 

condition

2014 TPA - QMD 2039 TPA -

QMD

Decrease in TPA 

and increase in 

stand QMD at year 

2039 compared to 

the existing 

condition

(LSR/foraging 

habitat 

prescription)

201- DF natural 394 - 12.2 72 - 22.6 84 - 23.2

310 TPA - 11.0 

inches

206 – DF natural 341 - 12.9 77 - 20.6 66 - 25.9 275 TPA - 13 inches

213 - DF natural 110 - 26.3 41 - 35.5 34 - 39.6 76 TPA - 13.3 inches

225 - DF natural 253 - 12.3 45 - 25.8 51 - 27.9

202 TPA - 15.6 

inches

227 (clumps) - DF 

natural

206 - 15.8 67 - 23.2 62 - 27.3

144 TPA - 11.5 

inches

234 - DF/BO 

natural

135 - 16.5 53 - 19.8 50 - 25.4 85 TPA - 8.9 inches

238 - DF natural 81 - 28.6 35 - 36.3 29 - 40.1 52 TPA - 11.5 inches

255 - DF natural 264 - 12.9 69 - 21.9 67 - 25.9 197 TPA - 13 inches

Weighted 

Average

357 - 11 70 – 16.7 66 – 22.4

All stands would 

show reduction in 

TPA and increased 

QMD after treatment, 

moving stands 

towards desired 

conditions

Thinning differs from natural death by suppression in stands by varying extents depending 

on age of the stand thinned and the trees removed. In young stands, trees which die from 

suppression usually occupy little growing space by the time they die; consequently, surrounding 

trees do not expand extensively before refilling the growing space. Thinning under alternative 2 

would reduce density (TPA) more than self-thinning so that growth would increase and crowns 

would remain about 40 percent live crown ratio and the QMD would increase at a greater rate 

(refer to table 23) as compared to the no action alternative.

In older stands, suppressed trees can occupy more growing space at the time of death.

Growing space released in a silvicultural thinning can mimic natural death if suppressed trees are 

removed shortly before they die. If suppressed trees are small, little growing space is release by 

removal of these trees and more dominant trees do not grow dramatically faster. Where 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

103

suppressed trees are larger, increased growth of residual trees upon death or thinning of 

suppressed trees is more dramatic because more growing space is released. Removal of 

progressively more dominant trees by thinning releases more growing space, and creates a longer 

time before the site is occupied again (Oliver 1996, pg 350). In older stands in the Two Bit 

project, thinning under alternative 2 would generally be from below, but would remove a 

combination of suppressed, intermediate, and codominant trees to reduce density without leaving 

these older stands below site occupancy for many years. 

Underburning

Underburning treatments outside of harvest units are not included in table 23, but would slightly 

decrease the SDI of stands with larger trees. Burning would have a greater effect on density of 

smaller-sized vegetation within stands or shrub types because small plants are more easily killed 

by fire. Underburning outside of harvest units representing various stand types was modeled for 

the fire and fuel report (Isbell 2010).

Underburning would reduce the trees, hardwood, or amount of brush per acre, with the most 

mortality in vegetation under 6 to 8 inches in diameter. A few larger trees could also be damaged 

and later die in higher burn intensity patches. As underburning kills mostly smaller vegetation, 

within conifer stands, the QMD would likely be slightly higher post treatment. Plantation trees 

are more likely than natural older stands to sustain fire damage during treatment depending on 

the site preparation completed when the stands were planted. The younger plantation trees have 

thinner bark and are more easily damaged. Very young plantations that have not reached canopy 

closure or a stem exclusion stage have branches near ground level and can torch easily. 

Underburning would reduce stand density to some degree, reduce surface fuel in the short or 

long term, and would allow the natural process of fire to be returned to the ecosystems.

Underburning outside of harvest units would create small openings and reduce understory 

vegetation. Effects would vary depending on vegetation type and flammability, aspect, 

elevation, fuel accumulations, and weather conditions during the burning. At a fine scale, 

underburning would generally increase variety of conditions within stands allowing new age 

groups or species from earlier successional stages to emerge, or regeneration of existing species,.

Likewise, in other areas, developing understory would be burned leaving some stands more 

single storied. Canopy uniformity could be reduced in younger stands that are more susceptible 

to fire. Burning would reduce surface fuels in the short term and could produce additional 

surface fuel overtime as dead material falls, particularly in areas where a larger proportion of 

dense vegetation would be killed.

Specialized Treatments (hardwood release, pole harvest, sanitation)

Thinning in stands 301 and 302 would reduce density to the degree that people chose to harvest 

poles in that area, but thinning would likely be small amounts over time. Although the difference 

might not be great, it would be an incremental step towards reducing fire risk and improving 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

104

stand conditions. In stand 400, thinning would be heavier to maintain the SDI at 55 percent of 

maximum for black oak and pine and vigor of those species would be expected to noticeably 

increase over the long term.

Meadow Enhancement

Alternative 2 would include removing encroaching trees along the edges of natural meadows in 

fifteen areas resulting in restoration of more natural meadow conditions similar to past 

conditions before fire suppression.

Roads and Skid Trails

Effects from creation of temporary roads and skid trails would be minimal. Some trees would be 

wounded along skid trails, but effects would be minor. If trees are wounded badly enough to 

cause long-term damage, they would be removed in the harvest. Careful planning during 

implementation would avoid all but minor damage. The width of skid trails and temporary roads 

would be less than the average spacing between trees, so the transportation system result in little 

impact to the stand. Soil compaction would be increased in main skid trails and temporary roads, 

but can be minimized by avoiding use during wet periods and reusing existing skids (Walters 

2010). Skid trails typically revegetate within a few years and often have good conifer 

regeneration because conifers seed best on bare mineral soil. Thinning would benefit the entire 

stand, while the area with potential compaction would be less than 15 percent.

Road decommissioning would have little direct effect on vegetation within the project area. 

These roads are currently not usable due to a lack of maintenance and slides/washouts during 

floods.

Cumulative Effects

All past activities or events affecting forest vegetation were considered in the description of the 

existing condition. Within the Indian Creek Watershed, in-progress or planned activities with a 

similar purpose and need as the Two Bit project are considered cumulative effects for the 

purpose of this analysis. Underburning and thinning from these projects would total 

approximately 3,345 acres. Additional density reduction and fuels treatment proposed in the Two 

Bit project would potentially add 9,372 treated acres. The additional treatments would result in 

nearly 15 percent of the Indian Creek Watershed having some treatments that move stands 

towards the desired condition.

Alternative 3 – No Temporary Roads

Direct/Indirect Effects

Alternative 3 would thin 270 fewer acres, and would underburn 70 more acres outside of 

thinning units as compared to Alternative 2. The units that would not be thinned in Alternative 3 

are 138 acres of plantations (Units 1, 12, 18, 36, 53, 121) and 132 acres of natural stands (Units 

206, 209, 211, 219, 227, 242, 253, 256, 257, 258). Units 12, 206, 209,244, 256, and 258 are 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

105

within proposed underburns in Alternative 2 and would be underburned without thinning in 

alternative 3. Underburning alone in these 6 units would reduce surface and ladder fuels, but 

would only slightly reduce the stand density and would not reduce the SDI to below 55% of 

maximum in the short or long term.

The direct and indirect effects for the individual units (totaling 1,710 acres) that would be 

thinned with subsequent underburning in Alternative 3 would be the same as the effects for those 

same units under Alternative 2. The silvicultural prescriptions would not change for individual 

units and the modeling for the representative sample stands would be the same. Prescriptions for 

underburning, specialized treatments and meadow enhancement would also be the same and 

have the same direct and indirect effects. Design Features and Mitigation Measures would be the 

same, except that borax would be applied to approximately 54 fewer acres that would not be 

harvested as compared to alternative 2. 

For alternative 3, approximately 1,679 acres would meet the objective of maintaining an SDI 

of below 55 percent of the maximum for 30 years. In comparison, this is approximately 90 acres 

less than what would meet that objective in alternative 2. Increases in stand QMD’s would range 

from 1.3 to 10.9 inches more than under the no action alternative. Approximately 1,526 acres of 

dense plantations would be thinned as compared to 1,664 acres for alternative 2. 

Thinning with subsequent underburning of the 1710 acres proposed in alternative 3 would 

result in a decrease in stand density on approximately two and a half percent of the acres within 

the project area, slightly less than alternative 2. The percent of changes for WHR density classes 

presented for the existing condition would be less than one percent because post harvest canopy 

closures would not change enough to be moved to a lower category for most of the stands.

Stand treatments would generally have little effect on vegetation outside of the stand 

boundaries. Reductions in fuel hazards and reduction in damaging agents, such as pine beetles or 

dwarf mistletoe, are expected to have some benefits to adjacent stands in the short and long term.

Cumulative Effects

All past activities or events affecting forest vegetation is considered in the description of the 

existing condition. Within the Indian Creek Watershed, in-progress or planned activities with a 

similar purpose and need as the Two Bit project are considered cumulative effects for the 

purposed of this analysis. Underburning and thinning from these projects would total 

approximately 3,345 acres. Additional density reduction and fuels treatment work proposed in 

the Two Bit project under alternative 3 would potentially add 9,330 treated acres. The additional 

treatments would result in nearly 11 percent of the Indian Creek Watershed having some type of 

treatment that positively impacts fire behavior as compared to 15 percent under alternative 2.
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

106

Alternative 4 – Minimized Underburning

Direct and Indirect Effects

Direct/indirect effects from implementing Alternative 4 are similar to Alternative 2 and 3 in 

regards to thinning and underburning and the results to measurement indicators. Alternative 4 

would commercially thin 1,980 acres in plantations and natural stands the same as Alternative 2. 

However, mastication after harvest is proposed instead of underburning on 1,490 acres. 

Alternative 4 would include underburning outside of harvest units on 570 acres as compared to 

7,250 acres proposed for underburning in Alternative 2. Other specialized thinning and Meadow 

enhancement treatments would be the same as Alternative 2. 

Mastication

Mastication would affect primarily sub-merchantable trees and would have similar effects in 

reducing density as would underburning, however there would be some variation in treatment 

patterns. Mastication machinery cannot navigate steep pitches within units including those that 

may be steeper ground past the break in slope in Riparian Reserves toward streams. In thinning 

units, less of the steeper inclusions would have reduction of small diameter material from this 

fuels treatment. However, where the remaining leave trees are not too dense for the machine to 

operate, mastication is more likely to kill the unwanted vegetation and result in a more thorough 

job of reducing density in the understory. The same percentage of the ground may be treated 

because underburning would likely not kill small diameter vegetation within units where there is 

inadequate material to carry fire. In burning units where the machine could access, mastication 

only would result in a more continuous and precise thinning treatment compared to underburning 

alone. However, thinning slash would remain as surface fuel although in a different arrangement 

than if material were hand felled and left.

The ecological effect of mastication and similar techniques vary depending on the size, 

composition, and location of fuels left after treatment (Graham 2004).

The fuels assessment (see Fuels section later in this chapter) notes that mastication would be 

less effective in reducing fuel hazards after thinning when compared to underburning. 

Information on the long-term effects of mastication on soil productivity is still sparse (Walters 

2010). Graham notes that the ecological effect of mastication and similar techniques vary 

depending on the size, composition, and location of fuels left after treatment (Graham 2004).

Thin layers may dry and rewet readily and deep layers may have insufficient air circulation to 

decompose. When layers of small woody material are spread on the forest floor and 

decomposition does occur, large amounts of nitrogen are utilized reducing its availability to 

plants (ibid). Based on analysis in the Soils Report, mastication is assumed to have similar 

effects on soil productivity as does harvesting with established skid trails and resulting in 3 

percent additional disturbance; mitigation for these effects includes the same practices and 

BMP’s to reduce soil disturbance as for ground based harvesting.
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

107

Underburning

Alternative 4 would have 570 acres of underburning outside of harvest units. This underburning

was not modeled in FVS for the vegetation analysis, but would slightly decrease the SDI of 

stands with larger trees. Burning would have a greater effect on density of smaller-sized 

vegetation within stands or shrub types because small plants are more easily killed by fire. 

Underburning outside of harvest units representing various stand types was modeled for the fire 

and fuel report (Isbell 2010). Overall, underburning would reduce stand density to some degree, 

reduce surface fuel in the short or long term, and would allow the natural process of fire to be 

returned to the ecosystems. A reduction of underburning in 6,680 acres under alternative 3 as 

compared to alternative 2 would reduce these benefits of burning. 

Cumulative Effects

All past activities or events affecting forest vegetation are considered in the description of the 

existing condition. Within the Indian Creek Watershed, in-progress or planned activities with a 

similar purpose and need as the Two Bit project are considered cumulative effects for the 

purposed of this analysis. Underburning and thinning from these projects would total 

approximately 3,345 acres. Additional density reduction and fuels treatment work proposed in 

the Two Bit project would potentially add 2,850 treated acres. The additional treatments would 

result in only 3 percent of the Indian Creek Watershed having some type of treatment that 

positively impacts fire behavior as compared to 15 percent for alternative 2.

Summary

Alternative 1

Stands proposed for treatment would remain dense and individual tree growth would continue to 

decrease. All stands proposed for thinning are presently at or over the desired 55 percent of the 

maximum SDI for the dominant or desired species and some stands are approaching maximum 

densities. These stands are experiencing inter-tree competition that slows growth, decreases 

vigor, and decreases the trees’ ability to produce defensive compounds and accumulate reserves.

Over the next 30 years as modeled using FVS (table 24), density-related mortality (self-thinning) 

would continue with between 36 to 70 percent of the trees dying over that period. Some of the 

stands that contain mostly older trees would have a net loss in basal area over the 30 year period. 

Although many of the trees that die would be small, surface fuels are expected to increase, 

dramatically in some stands, resulting in increased fire severity within stands if a wildfire were 

to occur (Isbell 2010). Diameter growth would continue, but at a slower rate than if trees had 

more growing space. Snow damage and bark beetle mortality would worsen in the pine 

plantations and heavy losses would be expected over the 30-year period. Mortality from 

breakage or beetles would leave large concentrations of dead material that would be too difficult 

to remove by hand because of the relatively large size of trees that would die.
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

108

None of the dense plantations would be treated. In the densest stands an opportunity would 

be lost to thin these plantations while crown ratios are still good and trees would respond quickly 

to reoccupy the additional growing space. In all stands, many smaller trees that are, or are 

becoming suppressed would remain in the stands and continue to utilize resource with little 

growth return. For all stands, the QMD would continue to increase.

Overall, alternative 1 would not meet project objectives for a fire-resilient ecosystem with 

sustainable densities. No timber products would be produced from alternative 1 and management 

activities would not be implemented to move stands toward desired conditions as outlined in the 

Forest Plan.

Alternative 2

Treatments would maintain the SDI at or below 55 percent of the maximum for the dominant 

species in approximately 94 percent of thinning units; these stands would meet density reduction 

project objectives. Stand 227 and stands similar to Unit 201 would be maintained below an SDI 

of 55 percent for 20 to 25 years. Stands similar to 213 and 238 with a majority of the trees over

20 inches in diameter would continue to have a low level of mortality after thinning which in 

combination with the thinning would keep stands under the 55 percent level for 30 years. This 

level of mortality is acceptable for these older stands and the basal area would remain steady 

over the next 50 years. Inter-tree competition would decrease and result in improved stand vigor 

and increase the trees’ ability to produce defensive compounds and accumulate reserves.

Diameter growth would increase in young stands and be maintained or improved in older stands.

Mortality would be maintained at low levels and would not create a fuels risk. Future potential 

mortality would be utilized for wood products. Increases in the QMD for the stands proposed for 

thinning would be between 1.3 inches to 10.9 inches more than the no action alternative in a 30-

year period. Approximately 1,664 acres of dense plantations would be thinned. Thinning in the 

LSR would increase the QMD an average of about 4 inches over the no action alternative.

Plantations would be thinned when crown ratios are still high and trees can respond well from 

thinning. Off-site ponderosa pine and white fir would be reduced relative to other species in 

stands.

Thinning with underburning would reduce stand density to levels where competition for site 

resources would be reduced over present levels. Individual tree vigor and growth would be 

expected to increase over the next 10 years and be maintained for around 30 years with the 

additional growing space available. When trees have more resources available, they have the 

ability to produce higher amounts of defensive compounds to defend against attack from insects 

and some diseases. Thinning would also change the stand structure in a way that reduces 

potential severity from wildfire by raising the crown base, reducing the crown bulk density, 

reducing the high number of small trees, and increasing the average stand diameter. Stand QMD 

would be increased because many of the smaller trees would be removed and because growth of 

the remaining trees would increase with the additional growing space.
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

109

Overall, alternative 2 would meet project objectives to reduce densities, maintain hardwood 

diversity and protect mid and early-seral stands from loss due to wildfire. Alternative 2 would 

produce timber products and maintain good growth rates, minimize insect and disease damage, 

and accomplish maintenance thinning in plantations. In the LSR, plantation thinning with 

underburning would accelerate development of late successional habitat by providing trees 

enough growing space to maintain good growth or to grow large more quickly; reduction in 

hazardous fuels conditions would increase the chance that stands can be maintained through a 

wildfire.

Table 24. Comparison of no action alternative and alternative 2, SDI and increase in QMD for 

sample stands

Unit # of Stand 

example –

species and

stand condition

No Action Alt. 

SDI of 55 percent

of maximum SDI 

in 2039

Alt 2 SDI of 55 

percent of 

maximum SDI in 

2039

No Action Alt. 

Increase in QMD 

2009 – 2039 

(inches)

Alt. 2 Increase in 

QMD 2009 - 2039

11 - PP plantation No Yes 5.5 12.6

31 - DF plantation No Yes 9.7 12.4

33 - DF plantation No Yes 8.3 10.9

48 - DF plantation No Yes 6.6 11.8

51 - PP plantation No Yes 8.8 6.7

97 (LSR) - PP 

plantation No Yes 4.8 13.3

100 - DF 

plantation No Yes 8.0 11.8

108 (LSR) - DF 

plantation No Yes 6.1 11.6

110 (LSR) - DF 

plantation No Yes 8.7 11.5

201- DF natural No No 7.2 11.0

206 DF Natural No Yes 9.2 13.0

213 - DF natural No Yes 9.3 13.3

225 - DF natural No Yes 4.7 15.6

227 (clumps) - DF 

natural No No 7.3 11.5

234 - DF/BO 

natural No DF - Yes, BO - No 7.6 8.9

238 - DF natural Yes Yes 9.3 11.5

255 – DF natural No Yes 5.3 13.0

Alternative 3

Alternative 3 would thin 270 fewer acres, and would underburn 70 more acres outside of 

thinning units as compared to Alternative 2. The direct and indirect effects for the individual 

units (totaling 1,710 acres) that would be thinned with subsequent underburning in Alternative 3

would be the same as the effects for those same units under Alternative 2. Fifty-one acres that 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

110

would be thinned and underburned in alternative 2 would be only underburned in alternative 3. 

While the these acres would have some reduction in density of small trees and a reduction in 

surface fuels, the underburning is not as effective in meeting desired condition for the stands as it 

thinning with subsequent underburning. Prescriptions for underburning, specialized treatments 

and meadow enhancement would also be the same and have the same direct and indirect effects. 

Under Alternative 3 approximately 1,670 acres would meet the objective of maintaining an 

SDI of below 55 percent of the maximum for 30 years. In comparison, this is approximately 90 

less acres then what would meet that objective in Alternative 2. Increases in stand QMD’s would 

range from 1.3 to 10.9 inches more than under the no action Alternative; this increase is similar 

to Alternative 2, except 270 less acres would be thinned as compared to Alternative 2 and would 

not have the increased QMD. Approximately 1,526 acres of dense plantations would be thinned 

compared to 1,664 acres for Alternative 2. 

Alternative 4

Alternative 4 would commercially thin 1,980 acres in plantations and natural stands the same as 

Alternative 2. However, mastication after harvest is proposed instead of underburning on 1,490 

acres. Alternative 4 would include underburning outside of harvest units on 570 acres as 

compared to 7,250 acres proposed for underburning in Alternative 2. Other specialized thinning 

and Meadow enhancement treatments would be the same as Alternative 2. 

Alternative 4 would thin and underburn on approximately 506 acres where a masticator 

could not be used due to topography. Thinning and underburning would best meet conditions that 

would result in reduced surface fuels and fire hazard. Thinning with mastication on

approximately 1,490 acres would meet project objectives for density reduction and resulting 

benefits, with the exception that it would have a reduced value for fuels reduction. 

Underburning outside of harvest units would be accomplished on 6,680 less acres as 

compared to alternative 2 and on 6,750 less acres compared to alternative 3. On the 570 acres 

that would be burned, underburning would reduce stand density to some degree, reduce surface 

fuel in the short and long term, and would allow the natural process of fire to be returned to the 

ecosystems. 

3.4 Fire and Fuels

3.4.1 Methodology

Fuels, weather and topography influence how a fire will burn. Hazards associated with weather 

and topography cannot be changed but fuel loading, vegetation structure and vegetation 

composition can be modified to affect fire behavior and how fire effects stand conditions. 

For this analysis, the Fire and Fuels Extension to the Forest Vegetation Simulator (FFE-FVS) 

was used to evaluate the predicted effects of implementing any one of the alternatives over a 40-

year period. FFE-FVS is a model linking stand development, fuel dynamics, fire behavior, and 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

111

fire effects. This model was used to compare effects of the management alternatives and describe 

current conditions for the Two Bit project. Inputs for the modeling were obtained through field 

observations, plot data, and photo series (Maxwell and Ward 1980).

Flammap is a fire behavior mapping and analysis program used to analyze fire behavior 

characteristics (spread rate, flame length, fire type, etc.) over an entire landscape with constant 

weather and fuel moisture conditions. Flammap was used as a spatial model to look at crown fire 

potential, rate of spread, and flame length potential under defined burn conditions. It was also 

used to help describe current fuel model conditions associated to fire behavior.

Mastication under alternative 4 was assumed to have flame lengths similar to the no action 

alternative. This was determined due to the compactness of masticated fuels not adding to 

surface flame length, although fuel loading increases. FVS-FFE requires years to be modeled in 

order to interpret results. 

Years modeled (2009 for thinning and 2014 for underburning) does not necessarily indicate 

when actual implementation will occur. The silviculture treatments and underburned areas were 

grouped by aspect (southwest and northeast) and stand type (plantation and natural) to address 

differing fire regimes and vegetation characteristics within the project area. South and west 

facing slopes were used due to more intense fire behavior and effects under current conditions.

Similar trends in each measurement indicator were noticed regardless of aspect or vegetation 

type.

The current condition for each stand category provides a baseline for all treatment 

alternatives. It is anticipated that all proposed treatments other than thinning (i.e. underburning, 

mastication, etc.) would occur within 3 to 5 years post thinning. In this analysis fuels treatments 

are assumed to occur 5 years after silviculture treatment. This analysis builds upon the 

silviculture treatments and analysis in the vegetation report (Sharp 2010). Field observations, 

plot data, and photo series were collected for representative stands for plantations and natural 

stands. The analysis of potential fire behavior and stand characteristics is based on the 

interpretation of the FFE-FVS results. Each alternative is analyzed every 20 years (2009, 2029, 

and 2049) and for the underburn treatment year (2014).

Fire behavior and effects are defined under 50th percentile (dry or moderate) and 90th

percentile (very dry or severe) conditions by aspect.

To model and predict fire behavior, fuels are often broken into fuel models that are 

mathematically put into a fire spread calculation of Rothermel 1972. GIS layers of the 

Stewardship and Fireshed coverage of the California Fuels Landscape were obtained to analyze 

current fuel models within the project boundary.

Fire hazard is a source of danger characterized by fuels. Wildland fire danger can be 

characterized by how a wildfire will burn or fire behavior. Hazardous fuels are excessive live or 

dead wildland fuel accumulations that increase the potential for uncharacteristically intense 

wildland fire and decrease the capability to protect life, property, and natural resources (USDI 

and USDA 2006). Therefore, when assessing wildland fire hazard, fuels and the resultant fire 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

112

behavior are the focus of the fire hazard analysis. The Forest Plan describes hazardous fuels and 

potential flame lengths as low, moderate, and high for use as indicators of potential fire behavior 

and resistance to control for fire suppression purposes. The following describes the fire hazard 

classes used in the Forest Plan that are also used in this section to evaluate the alternatives:

Low Hazard - Flame lengths less than four feet and rate of spread less than 30 chains per 

hour: Fires can generally be attacked at the head or flanks by firefighters using hand 

tools. Hand line should hold the fire.

Moderate Hazard - Flame lengths from 4 to 8 feet: Fires are too intense for direct attack 

at the head of the fire by firefighters with hand tools. Hand line cannot be relied on to 

hold the fire. Equipment such as dozers, engines, water and/or retardant support from 

aircraft can be effective.

High Hazard - Flame lengths are greater than 8 feet: Fire would present serious control 

problems, such as torching, crowning and spotting. Control efforts at the head of the fire 

may be ineffective.

The alternatives are compared using the following indicators. 

Fire Behavior and Effects

o Basal area mortality (percentage of basal area mortality that could be expected 

in a stand with a given species composition and structure under defined burning 

conditions)

o Surface flame length (a visual and measurement indicator of surface fire 

intensity. Flame length is defined as the distance along the slant of the flame 

from the midpoint of its base to its tip)

Fire type 

o Surface fire (S) – The fire remains on the forest floor. The combination of 

surface fire intensity and ladder fuels is not sufficient to move a fire into the 

crowns under the defined burning conditions.

o Passive crown fire (P) – Individual tree or group torching occurs. The 

combination of surface fire intensity and ladder fuels allows for movement into 

the crowns under the defined burning conditions, but canopy bulk density is too 

low for fire to spread through the crowns under the projected wind speeds.

o Active crown fire (A) – The combination of surface fire intensity, ladder fuels 

and canopy bulk density allows fire to move into, and spread through, the 

crowns under the defined burning conditions.

o Conditional crown fire (C) – Canopies are dense enough to carry fire with the 

projected wind speeds, but the surface fire intensities and ladder fuels do not 

allow movement into the crowns. Crown fires may move into the stand from 

outside, but cannot be initiated from within the stand under the projected wind 

speeds.

Stand Structure, Composition and Size

o Crown bulk density is a measure of the compactness of tree crowns. It is defined 

as the mass of available canopy fuel per unit canopy volume. It is a bulk 

property of a stand, not an individual tree, and is represented as the available 

canopy fuel load divided by canopy depth (Scott and Reinhardt 2001). For any 

given species, more widely spaced trees have a lower canopy bulk density, 

which makes it more difficult to maintain crown fires. A canopy bulk density of 

less than 0.10 kg/m3 is recommended to minimize crown fire hazard (Graham et 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

113

al 1999). In general, stands on north aspects have higher canopy bulk densities, 

with greater portions of stands exceeding 0.10 kg/m3. 

o Canopy base height is used as a measure of ladder fuel structure within a stand.

It is defined as the lowest height above the ground at which there is a sufficient 

amount of fuel to propagate fire vertically into the canopy (Scott and Reinhardt 

2001).

o Average stand diameter is used as a measure of the proportion of small and large 

trees in the stand.

The information used in the preparation of this section, including detailed results of model 

runs, comes from detailed analysis in the Fire and Fuels Report (Isbell 2010) and is available in 

its entirety in the project record.

3.4.2 Affected Environment 

The Indian Creek Watershed Analysis (USDA Forest Service 1997) recommends reduction of 

stand density and fuels as a major component in maintaining and restoring ecosystem health. It 

also identified fire as a major disturbance in shaping the historic forest landscape.

Implementation of actions that reduce stand and fuel densities and create functioning forests is 

identified as a priority.

The fire analysis area is the current project boundary. A study of fire history and landscape 

dynamics was done by Taylor and Skinner (1998) along Thompson Ridge; a ridge system that 

makes up the eastern boundary of the analysis area. Approximately half the Taylor and Skinner

research study area is within the project boundary. The study found that the frequency, extent and 

severity of fires strongly-influenced forest structure in Douglas-fir dominated stands. The 

research also concluded that “Tree species composition varied with elevation and aspect, and 

median fire return intervals were similar (12–19 years) among species composition groups. 

However, median fire return intervals (FRI) were shorter on south- (8 years) and west-facing (13 

years) slopes than on northern (15 years) or eastern (16.5 years) aspects..... Patterns of past fire 

severity, inferred from age-classes, indicate that upper slopes, ridgetops, and south- and westfacing slopes experienced more severe fires between 1850 and 1950 than lower slopes or eastand north-facing slopes. Implications are that lower slopes and north and east aspects are more 

likely than other topographic positions to sustain or promote long-term, late-successional 

conditions. Prescribed fire will likely be an integral component of management plans that 

successfully maintain natural processes and structures in newly established late-successional 

reserves in the Klamath Mountains.”

Climate

The climate of the Two Bit project area is best described as Mediterranean; wet, cool winters and 

dry, warm summers. Happy Camp, CA receives approximately 54 inches of annual precipitation, 

primarily between the months of October through April. The higher elevations in the project area 

receive approximately 61 inches of rain. Summer thunderstorms are common, and can release 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

114

significant localized rain. These storms can also be dry with conditions that encourage fire 

ignition and spread from lightning strikes, with the summer of 2008 being the latest example of 

this pattern.

Fire History, 

Hazard and Risk 

There have been 17 

fires (5 acres or greater 

in size) that occurred 

or entered into the 

project boundary over 

a sixty year period 

(1944 to 2004). In this 

same time period, 367 

fire starts have 

occurred within the 

project boundary.

Figure 8 on this page

is a map displaying 

year and acreage 

burned in the vicinity 

of the Two Bit project 

boundary and fire start 

locations within the 

project boundary.

Figure 8. Vicinity of the 

Two Bit project area 

large fire history

The Two Bit project area has a moderate fire risk value (between 0.5 and 0.99 fires expected 

to occur per decade for every thousand acres in the area being analyzed), based on this fire 

history. The primary source of ignition is lightning (70 percent) and humans (30 percent).

As shown in table 25, currently all stands are above the desired condition of less than 4 feet 

flame lengths under severe (90th percentile) and moderate (50th percentile) conditions. Flame 

lengths are similar through all categories, but are higher on average in plantations. Basal area 

mortality is also generally higher in plantations than in natural stands. Basal area mortality is 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

115

highest in south and west aspect plantations. Quadratic mean diameter is highest in natural 

stands; however, substantial components of smaller trees also exist within these stands.

Table 25. Current conditions based on modeling results from FVS-FFE

Current Conditions

Aspect

50th Percentile Conditions 90th Percentile Conditions

Average 

Stand 

Diameter

Canopy 

Base 

Height

Canopy 

Bulk 

Density

Flame 

Length

Fire 

Type

Basal 

Area 

Mortality

Flame 

Length

Fire 

Type

Basal 

Area 

Mortality

North 

and 

East

4.6 S 16 5.9 S 40 14 26 0.105

South 

and 

West

4.9 S 14 5.6 C 55 13.1 29 0.089

Fire Regime and Historic Reference Conditions (Condition Class) 

A natural fire regime is a general classification of how fire played a role in an ecosystem, in the 

absence of modern human intervention but including the influence of aboriginal burning (Agee 

1993, Brown 1995). Coarse scale definitions of fire regimes have been defined by Hardy et al. 

2001 and Schmidt et al. (2002) and interpreted for management of fire and fuels by Hann and 

Bunnell (2001). The five natural (historical) fire regimes as described by historical fire frequency 

(average number of years between fires) and historical fire severity (the effect of the fire on 

dominant overstory species) are described in the following table.

Table 26. Descriptions of Historic Natural Fire Regimes

Historical Natural Fire Regimes

Fire Regime Class Description

I 0–35-year frequencya, low and mixed severityb

II 0–35-year frequency, stand-replacement severity

III 35–100+ year frequency, low and mixed severity

IV 35–100+ year frequency, stand-replacement severity

V 200+ year frequency, stand-replacement severity a- Fire frequency-the average number of years between fires. bSeverity -effect of fire on dominant overstory vegetation.

Historically, vegetation in the project area is the same as it is today (primarily Klamath 

mixed conifer and Douglas-fir) but seral stage distribution has changed over time. Historically, 

approximately 95 percent of the analysis area (table 27) supported vegetation at or below a fire 

return interval (FRI) of 35 years (Fire Regime I) based on Taylor and Skinner (1998) research 

and FRCC GIS data provided by Max Creasy, Ecologist, Northern California Province (USFS 

Region 5).
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

116

Two Bit Analysis Area -- Historic Reference Conditions Based on 

Departure of Fire Return Interval

0

10000

20000

30000

40000

50000

60000

70000

I II III

Condition Class

Acres

I

II

III

Table 27. Historic Fire Return Intervals in the Project Area

Historic FRI Acres Percent of Area

≤ 20 59631 90

>20 and ≤ 35 3305 5

> 35 and ≤ 65 2577 4

>65 and ≤ 100 473 1

Currently, however, 

approximately 89 percent of 

the analysis area is in 

condition class III (severely 

departed), seven percent is 

in condition class II 

(moderately departed), and 

four percent is in condition 

class I (within historical 

range of variability).

Figure 9. Fire Regime Condition Class based on Fire Return Intervals

3.4.3 Environmental Consequences

Alternative 1- No Action 

Direct/Indirect Effects

Silviculture treatments and underburning would not occur. Stands in the project area would 

continue to self- thin and surface fuels would continue to accumulate. Increased amounts of 

surface fuels would result in increased flame lengths, fire intensity, and mortality.

The FVS-FFE model scenarios (current conditions after 20 years with no management action 

taken), indicate that fire hazard would remain moderate to high: flame lengths under both severe 

and moderate conditions would be above the desired condition of 4-foot flame lengths (table 28).

This would influence direct attack suppression by needing mechanized equipment to support 

ground resources, and increase probabilities of crown fire activity. After a 40-year period, the 

trend in increased fuel loading, flame length, fire intensity, and mortality would continue; under 

severe (90th percentile) conditions, all stands are projected to be in the high fire hazard category; 

they would have conditional crown fire with an average flame length over 9 feet. Under 

moderate (50th percentile) conditions, all stands are projected to be in the moderate to high fire 

hazard category, having surface fire with an average flame length over 7 feet.
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

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Table 28. Fire behavior measurement indicator results for the no action alternative

No Action Alternative

Aspect

50th Percentile Conditions 90th Percentile Conditions

Flame 

Length

Fire1

Type

Basal Area 

Mortality

Flame 

Length

Fire1

Type

Basal Area 

Mortality

South and 

West 2009 4.9 S 14 5.6 C 55

South and 

West 2014 4.8 S 14 5.4 C 59

South and 

West 2029 5.3 S 9 6.4 C 100

South and 

West 2049 7.1 S 9 9.7 C 100

1 Fire type S stands for surface and fire type C stands for crown

Table 29. Structure, composition and size measurement indicators for no action

No Action Alternative

Aspect Average Stand 

Diameter Canopy Base Height Canopy Bulk Density

South and West 2009 13.1 29 0.089

South and West 2014 14.1 32 0.090

South and West 2029 17.8 42 0.100

South and West 2049 22.7 50 0.086

Modeled results are consistent with field observations. Dense stands, especially plantations, 

are starting to self thin creating additional fuel loading on the ground. Understory and less 

vigorous vegetation are becoming shaded out and dying. As trees die and fall, they accumulate as 

surface fuels, resulting in higher fire intensity.

Cumulative Effects

Vegetation structure would change over time, leading to increased fire hazard as stands continue 

to grow denser and fuel loading increases. As a result, wildfire-induced tree mortality would also 

increase. Although the effects of other ongoing and reasonably foreseeable actions within the 

watershed (see cumulative effects section at the beginning of this chapter) would decrease the 

density of trees in the watershed, reduce ladder fuels, and slightly decrease the likelihood of 

crown fire and fire behavior potential, these effects would have little impact on the increased fire 

hazard over 40 years because of the generally small spatial scale of these projects.

Alternative 2 – Proposed Action 

Direct/Indirect Effects

After the stands are thinned (modeled in 2009 but applicable even if thinning does not occur 

until later, such as 2010-2011), they would still be susceptible to the effects of wildfire. If a 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

118

wildfire were to start soon after implementation of alternative 2 treatments, flame lengths would 

be at or above 4 feet except for natural stands on northeast aspects that are thinned and 

underburned.

However, FVS-FFE modeling results show that after underburning, by 2014 alternative 2 

thinned stands would meet purpose and need and desired conditions under severe and moderate 

fire conditions. After 20 and 40 years (2029 and 2049) desired conditions would still be met in 

thinned and underburned stands. In underburn-only stands, flame lengths would exceed the 

desired 4 feet with all other measurement indicators showing a positive response in meeting the 

purpose and need. Stands that are both thinned and underburned showed the greatest resiliency 

to fire behavior and effects based on the modeling results. Table 30 and 31 below shows the 

results through time for each measurement indicator. Therefore, fire hazard would be reduced 

with implementation of alternative 2. Under both moderate (50th percentile) and severe (90th

percentile) conditions, all stands are projected to be in the low fire hazard category in 2014 with 

flame lengths less than 4 feet. Fire hazard would remain low through 2049 in thinned and burned 

units but increases somewhat through 2049 in the units that are burned only, as shown below. 

Table 30. Fire behavior and effects measurement indicators for proposed action alternative - Note 

that the underburn is not modeled until 2014

Alternative 2, Proposed Action

Fuels Treatment by Aspect

50th Percentile Conditions 90th Percentile Conditions

Flame 

Length

Fire1

Type

Basal 

Area 

Mortality

Flame 

Length

Fire1

Type

Basal 

Area 

Mortality

Thin SW Aspect 2009 4.4 S 9 5.3 S 11

Underburn SW Aspect 2014 2.5 S 7 3.3 S 7

Thin and Underburn SW Aspect 

2029

2.2 S 5 2.8 S 5

Thin and Underburn SW Aspect 

2049

2.3 S 3 2.9 S 3

Underburn Only SW Aspect 2009 4.9 S 14 5.6 S 55

Underburn Only SW Aspect 2014 3.6 S 10 3.9 S 18

Underburn Only SW Aspect 2029 5.4 S 8 6.0 S 16

Underburn Only SW Aspect 2049 6.8 S 6 8.8 S 17 1 Fire type S stands for surface and fire type C stands for crown
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

119

Table 31. Stand structure, composition and size measurement indicators for proposed action. Note 

that the underburn is not modeled until 2014.

Fuels Treatment by Aspect

Average 

Stand 

Diameter

Canopy Base 

Height Canopy 

Base Height

Canopy 

Bulk 

Density

Thin SW Aspect 2009 18.4 48 0.042

Underburn SW Aspect 2014 21.6 50 0.035

Thin and Underburn SW Aspect 2029 25.0 51 0.038

Thin and Underburn SW Aspect 2049 29.4 48 0.045

Underburn Only SW Aspect 2009 13.1 29 0.089

Underburn Only SW Aspect 2014 13.9 32 0.076

Underburn Only SW Aspect 2029 17.0 39 0.087

Underburn Only SW Aspect 2049 21.0 47 0.087

Therefore, proposed activities would reduce fire hazard in the project area in both the short-term 

(in the first year following treatments) and the long-term (through 2029 and 2049) but the longterm changes in reduced fire risk would vary by treatment type. These long-term changes would 

be noticeable primarily at the stand level in terms of fire behavior and effects through time but 

would have little influence on fire resiliency over the project area as a whole over time.

Cumulative Effects

The proposed activities for alternative 2 would have some effects over time (40 years) in 

reducing the fire hazard in the watershed. Meadow enhancement will restore meadows in the 

short-term but need to be repeated in order to have long-term effects. The effects of ongoing and 

reasonably foreseeable actions, including approximately 3,345 acres of timber and/or fuels 

management, would decrease the density of trees in the watershed, reduce ladder fuels, slightly 

decrease the likelihood of crown fire and fire behavior potential; these are positive changes that 

move toward desired conditions in the project area and across the watershed. However, these 

effects would have little impact on the increased fire hazard in the watershed over a 40-year 

timeframe. Repeated and more widespread management actions would be necessary over time to 

substantially change fire hazard on a large scale across the watershed. Alternative 3 – No 

Temporary Roads

Direct/Indirect Effects

The differences for fire hazard between alternative 2 and alternative 3 are small. In alternative 3, 

approximately 68 more acres of underburning would occur and approximately 268 fewer acres 

of thinning/underburning would occur. Not constructing new temporary roads under alternative 3 

would not measurably affect fire behavior. These small changes would be noticeable only at the 

stand level in terms of fire behavior and effects through time but would have little influence on 

fire resiliency over the project area as a whole. For these reasons, the direct/indirect effects for 

alternative 3 are the same as alternative 2 described in detail above.
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

120

Cumulative Effects

Because the direct/indirect effects of alternative 3 are the same as those for alternative 2, the 

cumulative effects of alternative 3 are also the same as those previously described for alternative 

2. 

Alternative 4 – Minimized Underburning

Direct/Indirect Effects

Proposed thinning treatments, specialized treatments and meadow enhancement treatments

would be the same as those for alternative 2. However, to reduce the amount of smoke-producing 

prescribed burning, thinning units on appropriate slopes would be masticated following thinning 

and would not be underburned.

After the stands are thinned (modeled in 2009), they would still be susceptible to the effects 

of wildfire and contain flame lengths at or above 4 feet, except natural stands on NE aspects for 

thin and underburn or mastication. Generally, fuels treatments (i.e., underburning and 

mastication) would occur within 3 to 5 years after silvicultural treatments occur (modeled in 

2014). Stands both thinned and underburned showed the greatest resiliency to fire behavior and 

effects and met purpose and need and desired conditions throughout the 40-year analysis.

Thinned and masticated stands show increased flame lengths through time, but reduced stand 

density characteristics. Desired conditions of less than 4-foot flame lengths were not met under 

moderate or severe conditions under thinned and masticated units; however, all other 

measurement indicators show this treatment type meeting purpose and need. In stands that were 

underburned only, flame lengths exceed the desired 4 feet with all other measurement indicators 

showing a positive response in meeting the purpose and need. Tables 32 and 33 below show the 

results through time for each measurement indicator. These long-term changes would be 

noticeable primarily at the stand level in terms of fire behavior and effects through time but 

would have little influence on fire resiliency over the project area as a whole over time.

Table 32. Fire behavior and effects measurement indicator results for alternative 4.

Alternative 4 -- Minimize Smoke

Fuels Treatment by Aspect

50th Percentile Conditions 90th Percentile Conditions

Flame 

Length

Fire 

Type

Basal 

Area 

Mortality

Flame 

Length

Fire 

Type

Basal Area 

Mortality

Thin SW Aspect 2009 4.4 S 9 5.3 S 11

Underburn SW Aspect 2014 2.5 S 7 3.3 S 7

Thin and Underburn SW Aspect 

2029

2.2 S 5 2.8 S 5

Thin and Underburn SW Aspect 

2049

2.3 S 3 2.9 S 3
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

121

Alternative 4 -- Minimize Smoke

Fuels Treatment by Aspect

50th Percentile Conditions 90th Percentile Conditions

Flame 

Length

Fire 

Type

Basal 

Area 

Mortality

Flame 

Length

Fire 

Type

Basal Area 

Mortality

Underburn Only SW Aspect 2009 4.9 S 14 5.6 C 55

Underburn Only SW Aspect 2014 3.6 S 10 3.9 S 18

Underburn Only SW Aspect 2029 5.4 S 8 6.0 S 16

Underburn Only SW Aspect 2049 6.8 S 6 8.8 S 17

Masticate SW Aspect 2009 4.1 S 9 4.8 S 11

Masticate SW Aspect 2014 5.0 S 7 5.6 S 7

Masticate SW Aspect 2029 5.8 S 5 6.6 S 5

Masticate SW Aspect 2049 9.0 S 3 10.5 S 3

Note that underburn is not modeled until 2014.

Table 33. Stand structure, composition and size measurement indicator results for alternative 4.

Note that underburn is not modeled until 2014.

Alternative 4 -- Minimize Smoke

Fuels Treatment by 

Aspect

Average Stand 

Diameter Canopy Base Height Canopy Bulk Density

Thin SW Aspect 2009 18.4 48 0.042

Underburn SW Aspect 

2014 21.6 50 0.035

Thin and Underburn SW 

Aspect 2029 25.0 51 0.038

Thin and Underburn SW 

Aspect 2049 29.4 48 0.045

Underburn Only SW 

Aspect 2009 13.1 29 0.089

Underburn Only SW 

Aspect 2014 13.9 32 0.076

Underburn Only SW 

Aspect 2029 17.0 39 0.087

Underburn Only SW 

Aspect 2049 21.0 47 0.087

Masticate SW Aspect 

2009 18.4 48 0.042

Masticate SW Aspect 

2014 21.6 50 0.035

Masticate SW Aspect 

2029 25.0 51 0.038

Masticate SW Aspect 

2049 29.4 48 0.045
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

122

Cumulative Effects

The cumulative effects of alternative 4 would be similar to those of alternative 2, although fewer 

acres of fuels treatments would occur in this alternative than in alternatives 2 or 3. The effects of 

ongoing and reasonably foreseeable actions, including approximately 3,345 acres of timber 

and/or fuels management, would decrease the density of trees in the watershed, reduce ladder 

fuels, slightly decrease the likelihood of crown fire and fire behavior potential; these are positive 

changes that move toward desired conditions in the project area and across the watershed. 

However, these effects would have little impact on the increased fire hazard in the watershed 

over a 40-year timeframe, as discussed for alternative 2. Under alternative 4 these effects would 

be even less apparent because fewer acres would be treated with underburning. Repeated and 

more widespread management actions would be necessary over time to substantially change fire 

hazard on a large scale across the watershed.

Summary

Alternative 2 would have the greatest effect on reducing fire hazard and improving stand 

structure and composition, and would meet the purpose and need for the project through time.

Alternative 3 would improve fuel conditions similar to alternative 2 (and reduce fire hazard) but 

would improve density of vegetation on fewer acres. Alternative 4 would improve stand structure 

and composition on almost as many acres as alternative 2, but would improve fire behavior 

characteristics (and reduce fire hazard) on a much smaller area. Long-term changes would be 

noticeable primarily at the stand level; fire resiliency over the project area as a whole would 

likely be small due to the small amount of treated acres compared to large size of the project 

area. Because alternative 2 would treat more acres than alternatives 3 or 4, fire resiliency would 

be slightly greater at the project area-scale than alternatives 3 or 4.

Table 34 below is a summary of treated acres under each alternative by treatment type. The 

table also shows average flame lengths under severe conditions by treatment type for two given 

years. Flame lengths are displayed over other measurement indicators due to the biggest change 

in trends by treatment types. Under the No Action alternative, fire hazard would be moderate 

(flame lengths between 4 and 8 feet) but this drops to low (flame lengths less than 4 feet) for 

most treated areas in 2014 and remains low into 2029 for units that are both thinned and 

underburned. 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

123

Table 34. Comparison of alternatives by acres treated and average 90th percentile flame length for 

year 2014 (modeled underburn) and 2029 (15 years post-treatment)

Component

Objective

Alternative

1

Alternative

2

Alternative

3

Alternative 

4

Average

90th

percent

Flame 

Lengths 

by 

Treatment 

2014

Average

90th

percent

Flame 

Lengths 

by 

Treatment 

2029

Total Treatment 

Acres 0 9,530 9,330 2,850 //// ////

Total 

Underburning Only 

Acres

0 7,250 7,320 570 3.9 6.0

Total Thin and 

Underburn Acres 0 1,980 1,710 488 3.3 2.8

Total Thin and 

Masticate Acres 0 0 0 1,450 5.6 6.6

No Action –

continuation of 

existing conditions

//// //// //// //// 5.4 6.4

3.5 Air Quality

3.5.1 Methodology

Prescribed burning and wildfire result in smoke production. Smoke affects the quality of the air 

and visibility. These effects may be noticeable to residents and recreational users in the area, to 

adjacent communities, and in sensitive areas such as the Marble Mountain Wilderness Class I 

airshed and the Siskiyou Wilderness Class II airshed. Dust generated from vehicle traffic on 

roads in the project area also affects the quality of the air, and vehicles and equipment emit 

pollutants. 

The Clean Air Act and its amendments require the Environmental Protection Agency (EPA) 

to identify and publish a list of common pollutants that could endanger public health or welfare, 

and to establish criteria for emissions in order to protect the public health and welfare. Six 

criteria pollutants have been identified, and of those, particulate matter with diameters less than 

2.5 micrometers (PM 2.5) is of greatest concern from wildland burning. Most (80-90%) of the 

mass of wildfire smoke falls into the PM 2.5 classification. 

The 1977 amendment to the Clean Air Act established a national goal of prevention of any 

future and remedying of any existing impairment of visibility in mandatory Class I federal areas 

which impairment results from manmade pollution. EPA has delegated to the states the 

responsibility to implement and enforce all laws and regulations pertaining to the Clean Air Act. 

The emissions and impacts of prescribed burning and wildfire on air quality are difficult to 

quantify because of the many site-specific factors involved: fuel type, fuel loading, moisture 

conditions, combustion rate, and meteorological conditions. Particulate matter emissions can be 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

124

estimated through the use of fire modeling (First Order Fire Effects Model or FOFEM). FOFEM 

is recognized by the Forest Service Pacific Southwest Region as being the most current and 

accurate analysis tool available for emissions prediction (Reinhardt et al. 1997). It is based on 

extensive research in western forest ecosystems.

FOFEM was used to estimate emissions from a wildfire in the Two Bit project area 

compared to a prescribed burn. Both scenarios used the same fuel model and fuel loading 

approximations. The wildfire assumes a windy summer day under dry conditions and 20 percent

crown fire. It also assumes that all the project area will be burned in a few days. The prescribed 

burn scenario assumes a typical fall day with moderate moisture conditions and only 10 percent

of the project area to be burned in a given year.

Fugitive dust emissions were estimated using miles of log hauling based on unpaved forest 

service roads. Log hauling on unpaved forest roads was the only source of fugitive dust 

estimated under this project since intensity (total haul miles on unpaved roads) and velocity of 

travel (average of 15 mph) on unpaved forest roads would contribute the majority of the fugitive 

dust emissions. Other vehicles and equipment were not considered in the analysis for dust 

generation because they would operate on less bare ground (small portions of units on primary 

skid trails) and slower operating speeds (average of 5 mph). The alternatives were evaluated by 

estimating PM10 emissions in fugitive dust from logging trucks compared to those estimated for 

Siskiyou County.

The alternatives are compared using the following indicators:

Distance and direction from area of smoke production to sensitive areas 

Predicted smoke emissions from each alternative based on fuel loadings

Consistency of predicted smoke emissions with state and federal standards (The Clean 

Air Act, state guidelines, etc.)

Fugitive dust emissions based on proposed logging haul routes

The information used in the preparation of this section, including detailed results of model 

runs, comes from detailed analysis in the Air Quality Report (Isbell and Bousfield 2010) and is 

available in its entirety in the project record.

3.5.2 Affected Environment

The Two Bit Project Area is located in northern Siskiyou County, California. The project area is 

within the Northeast Plateau Air Basin, which includes all of Lassen, Modoc, and Siskiyou 

Counties and is the fourth largest air basin in the state. Currently, Siskiyou County is in 

attainment for all federal and state standards (i.e. Siskiyou County does not exceed ambient air 

quality standards for regulated/monitored air pollutants) except for state standard for 8-hour 

ozone. Within Siskiyou County, the air quality regulating authority is the Siskiyou County Air 

Pollution District (SCAPCD) in Yreka, CA. The SCAPCD issues permits and specific standards 

and guidelines for prescribed burning including the establishment of emission limits.
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

125

Local communities such as the town of Happy Camp (0.5 miles south of project area and 

Seiad Valley (12 miles east of project area), local residents living in the project area and 

campgrounds are considered sensitive areas and could be affected by smoke and haze in from the 

project. 

Class I airsheds are federally designated wilderness areas, national monuments, and other 

areas of special natural, recreational, scenic, or historical value. Class I designations apply to 

select pristine airsheds including national parks greater than 6,000 acres and wilderness areas 

greater than 5,000 acres. Wilderness areas that were federally designated prior to the 1977 

amendments to the Clean Air Act were designated as Class I airsheds. The Marble Mountain 

Wilderness Class I airshed is approximately 15 air miles from the project area and Kalmiopsis 

Wilderness Class I airshed is approximately 25 air miles from the project area. Class II airsheds 

are clean air areas where a moderate amount of development is permitted. These include 

wilderness areas designated after 1977. The Red Buttes Wilderness Class II airshed is adjacent to 

the northeastern portion of the project boundary, and the Siskiyou Wilderness Class II airshed is 

adjacent to the western portion of the project boundary.

The Northeast Plateau Air Basin is classified as attainment for National Ambient Air 

Quality Standards (NAAQS). Within the State of California Clean Air Act, the basin is classified 

by the California Air Resources Board as nonattainment for particulate matter less than 10 

microns or PM 10. Areas where particulate matter has exceeded standards have been in the 

communities of Alturas and Yreka where monitoring stations are located, and where there are air 

polluting industries and problems with wood smoke. State and federal ambient air quality

standards are shown in table 35. 

Table 35. State and federal ambient air quality standards

Pollutant Averaging Time Primary Standards 

Federal

State Standards 

California

PM10 Annual

24-hour

50* 

(arithmetic mean)

150

20

(geometric mean)

50

PM2.5 Annual

24-hour

15

65

12

---

CO 8-hour

1-hour

10,000 [9]

40,000 [35]

10,000 [9]

20,000 [20]

*Units are micrograms per cubic meter (ug/m3); numbers in brackets are parts per million (ppm). From: 

California Air Resources Board (5/17/06)

The following pollutants would be emitted during fuels and vegetation burning through the

use of prescribed fire: PM10, carbon monoxide (CO), carbon dioxide (CO2), volatile organic 

carbon (VOC), and toxic compounds. PM10 would be emitted in the form of dust from timber 

hauling and logging operations, including road reconstruction and rehabilitation activities.

Review of the highest four daily PM10 measurements for the three stations in Siskiyou County 

indicate Yreka and Mt. Shasta have exceeded the daily PM10 standard two times over the years 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

126

1997–1999. The Lava Beds National Monument exceeded the 24-hour standard one day in 1996 

because of a prescribed underburn in the monument within 100 yards of the monitoring station.

3.5.3 Environmental Consequences

Alternative 1- No Action 

Direct/Indirect and Cumulative Effects

Under the no action alternative, there would be no prescribed burning or logging operations and 

therefore no emissions of PM10, PM 2.5 and CO from burning, road use, fugitive dust 

generation, or vehicle and equipment emissions. 

Alternative 1 would therefore not contribute to the effects of other past, on-going or planned 

activities in the project area or in the change to the cumulative air quality effects from the current 

situation.

If a wildfire were to start in the project area, substantial smoke impacts would result. PM2.5 

concentrations would be 0.88 tons/acre (table 36). Total emissions would be greater than if 

burned under controlled conditions and would be concentrated in a short time frame thus having 

a substantial impact on the health of area residents and to nearby Class I and Class II airsheds. In 

addition, a wildfire may not be restricted to the area of this project so smoke from the burning of 

surrounding areas would make emissions even higher.

Because a wildfire would likely occur under hotter and drier conditions than a prescribed 

burn, burning would be more intense and more fuel would be consumed within the target area.

This would mean more smoke and the hotter fire would cause the smoke to be lifted higher into 

the atmosphere where winds are stronger. Thus smoke would be transported longer distances and 

impact a much larger area than if burning is done under controlled conditions.

Indirect impacts on air quality from fighting a large wildfire would mainly be caused by 

exhaust from fire fighting vehicles.

Alternatives 2, 3 and 4 

Direct/Indirect Effects

The action alternatives would generate short-term smoke emissions that would be suspended in 

the atmosphere, generated from prescribed fire. The action alternatives would also produce 

fugitive dust generated primarily through timber hauling activities. Indirect effects of prescribed 

fire include an expected decrease in wildfire emissions due to a reduction of overall fuel loading.

Dust emissions from hauling would add to the fine particulate emissions locally and regionally.

Table 36 shows the estimated emissions from prescribed fire and wildfire for alternatives 1, 

2, 3 and 4. Wildfire totals were not displayed (only tons per acre) because there was no 

determination on how large a wildfire may get. However, tons per acre estimates were compared 

between wildfire and prescribed fire treatments. It is important to note that total emissions from a 

wildfire would be a one-time event whereas total emissions from a prescribed fire would be over 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

127

a series of burns or multiple events. Table 36 shows that prescribed fire would result in fewer 

particulate emissions per acre burned than a wildfire and that this is the same for each 

alternative. The total tons of particulate emissions would be less for alternative 4 because 

substantially fewer acres would be prescribed burned under this alternative when compared to 

alternatives 2 or 3. Alternatives 2 and 3 are quite similar in total tons of emissions per acre 

because both have similar amounts of prescribed burning proposed. 

Table 36. Estimated Emissions by Particulate Type (tons/acre and total tons)

Particulates

Alternative 

1 No 

Action

Alternative 2 Proposed 

Action

Alternative 3 No New 

Temporary Roads

Alternative 4 Minimum

Smoke

Wildfire 

tons per 

acre

Prescribed 

fire tons per 

acre

Prescribed 

fire total 

tons 

Prescribed 

fire tons 

per acre

Prescribed 

fire total 

tons 

Prescribed 

fire tons 

per acre

Prescribe

d fire total 

tons 

PM10 1.04 0.77 5583 0.77 5636 0.77 439

PM2.5 0.88 0.65 4713 0.65 4758 0.65 371

CO 11.5 8.6 62350 8.6 62952 8.6 4902

Based on the above information, the amount and location of proposed burning may result in 

short-term impacts to local air quality due to the level of smoke produced, exacerbated by the 

tendency for smoke in these areas to settle in the basin and that this is greatest for alternatives 2 

and 3 and substantially less for alternative 4. This can result in inconvenience and discomfort for 

residents along Indian Creek and in the town of Happy Camp, particularly those with allergies or 

breathing conditions. These short-term effects would be minimized through the implementation 

of project design features (Chapter 2) which include burning only on declared “Burn days” as 

determined by Siskiyou County Air Quality Management District’s Smoke Management Plan to 

avoid creating a nuisance, visibility impairment or impacts to public health. Burn-day 

determination is based on metrological conditions that tend to disperse the smoke. Burning on 

worst visibility days and best visibility days would be avoided. Burns would be conducted when 

the prevailing wind direction is away from Class I areas. Public education and information 

release are part of the prescribed burning procedures and would be followed. In addition, burning 

activities would be staggered over an approximately 10-year period; not all burning would be 

conducted at once. 

While alternatives 2 and 3 would result in higher particulate emissions from prescribed 

burning than alternative 4, these alternatives would be more effective in reducing the likelihood 

of a wildfire by reducing fuel loading. Mastication proposed under alternative 4 is an effective 

treatment to reduce fire behavior characteristics such as crown fire potential, but it does not get 

rid of the fuels (like prescribed burning does); instead it changes ladder fuels and brush to 

ground fuels; in the short-term, these are still available to burn in a wildfire event and would 

have similar smoke production (Isbell, pers. comm. 2010). 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

128

Compared to emissions from a wildfire, all action alternatives would result in fewer 

emissions from smoke.

Estimates of fugitive dust generation were compared for all alternatives and are shown in 

table 37.

Table 37. Total miles of unpaved log truck travel. Estimated PM10 fugitive dust emissions from log 

haul and return trips by alternative

Action Alternative Alternative 

2 & 4

Alternative 

3

Total Unpaved Haul Distance (miles) 67,996 60,581

PM10 per year (tons) 17.8 16.0

Relative to Siskiyou County yearly average for 2008 

(%) 0.41 0.37

Average yearly emissions for Siskiyou County Air Pollution Control District can be found at 

http://www.arb.ca.gov/app/emsinv/emssumcat.php

The estimated yearly PM10 emissions from all alternatives are less than 0.5 percent of 

Siskiyou County total. Fugitive dust emissions, dispersion and transport would be mitigated by 

treating selected main unpaved haul routes with water and or chemical dust suppressants thereby 

reducing overall dust emissions and cumulative effects from the project activities (see project 

design features and BMPs, Chapter 2). Dust abatement methods would reduce total emissions 

between 50 to 80 percent (EPA 2006).

Cumulative Effects

Fine particulate matter would contribute to local, air basin, and broader regional pollutant 

loading. Local and air basin effects would include cumulative prescribed burn emissions from 

federal, state, and private lands in the area. Compliance with Burn Day, Marginal Burn Day, and 

No Burn Day designation, and coordination and permitting from the local air pollution control 

district, would minimize cumulative effects.

Because smoke can be transported for hundreds of miles the cumulative impact area may be 

quite large, but the further from the point of origin the more diffuse the smoke becomes; 

therefore impacts would diminish with distance from the project area. Although smoke would 

drain downstream similarly to water at night, during the day it may be transported high into the 

atmosphere and in any direction by the prevailing wind.

This project may contribute to regional haze, which results from the accumulation of diffuse 

pollutants from multiple sources including industry, fireplace and woodstove burning and other 

prescribed burns. Burning may occur simultaneously in other areas within the Northeast Plateau 

Air Basin. Other burns within the Indian Creek Watershed (tables 15 and 16) and other areas 

within the Air Basin contribute to cumulative effects from smoke.

Proposed management activities under the action alternatives, would contribute to the 

emissions that affect air quality. The impacts on air quality are difficult to address in terms of 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

129

cumulative effects. Large fires have occurred near the project over the past century as described 

in the Fire and Fuels report; however, those effects on air quality are gone and cannot be viewed 

cumulatively. If a wildfire occurred, there is a potential for the NAAQS to be exceeded 

depending on the size and duration of wildfire.

It is acknowledged that multiple prescribed burn activities, occurring at the same time, could 

cumulatively increase particulate levels. Generally, the effects of one burn activity are completed 

before another burn activity begins. Impacts to air quality would generally be confined to no 

more than a few hours, or at most a few days. The cumulative effect of prescribed fire on air 

quality is rather short-lived, because once the burn is over and the smoke has dissipated, the 

effect is over.

The effects of the actions alternatives from smoke are not likely to have cumulative effects 

with other activities in the airshed given the oversight by the Siskiyou county APCD that allows 

for good smoke dispersion. Daily regulation of amount of burning is managed to reduce impacts 

and negative effects of smoke. The number of days to accomplish prescribed burning in this 

project would compete with other burning in the airshed on any given day. The Forest Service 

would be responsible for establishing burn priorities and the Siskiyou county APCD would be 

responsible for managing all the burning on a given day. If air quality is exceeding thresholds 

when proposed activities are scheduled to occur, implementing either one of these alternatives 

may result in some delays in burning as a result of this increased demand.

There would also be some impact on air quality from engines used to operate vehicles, 

equipment and chainsaws during thinning and burning operations from any of the action 

alternatives combined with other activities in the Air Basin. These emissions are expected to be 

minimal and able to disperse readily.

3.6 Water

3.6.1 Methodology

The existing conditions within the project area were analyzed through a combination of office 

and field reviews. Existing data such as road sediment source inventories, channel habitat type 

surveys, and watershed analyses were reviewed in the office. Cumulative watershed effects 

models were also used to characterize the existing conditions. Field reviews of stream course 

riparian reserve (RR) function, channel characteristics, stream surveys, and sediment source 

identification confirmed the office assessments. 

The effects of the alternatives were analyzed through field visits, GIS reports, and modeling. 

Field visits were used to develop the project design features based on stream channel 

characteristics and slopes and to correct any inconsistencies with existing GIS stream layers. 

GIS reports summarize the following activities located within stream course RRs: (1) miles of 

temporary roads (reconstructed and constructed), (2) acres of landings (new and existing), and 

(3) acres of commercial treatment and ground-based yarding. These activities in RRs relative to 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

130

the total RR acreage in a watershed helped determine whether there would be measurable effects 

to water quality. 

Cumulative watershed effects (CWE) are analyzed on the Klamath National Forest using 

three models: (1) the equivalent roaded area (ERA) methodology, a Region 5 standard that scales 

vegetative disturbances as being equivalent to a road. It establishes a “threshold of concern” 

(TOC), ranging from 4.5-17 percent, as the acceptable percent ERA within a particular 

watershed; (2) the USLE methodology which predicts sediment volume delivered to stream 

courses by surface soil erosion; and (3) the empirical mass-wasting model (GEO) that predicts 

sediment volume delivered to stream courses by mass-wasting processes. A watershed’s 

threshold of concern is reached when model-predicted sediment delivery exceeds background by 

400 and 200 percent for USLE and GEO models, respectively. The GEO modeling is also used 

and discussed in the Geology section of this chapter. 

CWE models were used to analyze cumulative effects of the existing road system (this 

assumes programmatic maintenance of Forest System roads) and past and present actions, in 

combination with proposed activities under each alternative. The CWE analysis models projectspecific actions within the context of 7th field watersheds (drainages, from 3,000 to 10,000 acres 

in size). Seventh field watersheds are aggregated to characterize 6th and 5th field watersheds. The 

Indian Creek 5th field watershed is composed of four 6th field watersheds and twelve 7th field 

watersheds. Actions are proposed within nine of the twelve 7th field watersheds (figure 7).

Appendix F contains a summary of the CWE modeling results for this project. 

Effects can be neutral, beneficial or negative. All effects of the no-action and action 

alternatives are described in context to their spatial and temporal extent. The spatial scale is 

described at three levels: (1) Site – effects located in the stream channel adjacent to or nearby the 

treatment area and that do not extend downstream; (2) Reach – effects that extend downstream 

for less than 100 meters; and (3) Watershed – effects that can be measured in the response reach 

of a 7th field watershed. The temporal scale is described as being either short- or long-term in 

duration. Short-term (direct and indirect) is usually 1 to 3 years, but can be up to 10 years. Longterm (indirect) is any effect that persists for more than 10 years.

Surface sediment erosion recovers quickly (over several years) due to soil cover from needle 

cast and fallen branches covering disturbed sites. Sediment delivery due to mass-wasting is longterm and can last for several decades before hill slope hydrology is restored. Altered stream 

flows can be short- or long-term, depending on elevation and forest type. 

Cumulative effects are short- and long-term since they combine direct and indirect effects 

resulting from all past, present, and reasonably foreseeable future actions. Since Forest System 

roads are considered permanent, and do not recover like vegetative disturbance, road-related 

sedimentation is constant year after year. Positive changes can occur by storm proofing, 

decommissioning, and administrative decisions that affect use levels.

The alternatives are compared using the following indicators:
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Changes in sedimentation – quantitatively modeled through USLE and GEO 

methodology and qualitatively evaluated using miles of temporary road, acres of 

landings and acres of ground-based equipment operating in stream course RRs.

Changes in stream temperature – qualitatively evaluated through acres of proposed 

commercial treatment in stream course RRs.

Altered channel morphology - measured through ERA-modeled outputs for degree of 

peak flow increase.

These three issues are linked since increased sedimentation could alter channel 

geomorphology, which could increase stream temperature. The results of the analysis using the 

above indicators (as summarized below and also described in appendix F) were then used to 

determine whether negative effects to beneficial uses of water would occur. These indicators 

came from the Forest Plan (USDA Forest Service1995a) and Indian Creek Watershed Analysis 

(USDA Forest Service 1997). 

The Forest Plan (1995a) developed future desired conditions Forestwide and in designated 

management areas. The Forest Service adopted the Aquatic Conservation Strategy (Forest Plan, 

pages 4-6 and 4-7) and management area standards and guidelines to help achieve future desired 

conditions. Forestwide Standard and Guideline #1-3 for best management practices (BMPs) 

helps meet water objectives. Many standards and guidelines for RRs are also included in the 

Forest Plan and apply to this project (MA-10, pp. 4-133 – 4-144).

The information used in the preparation of this section, including detailed results of model 

runs, comes from detailed analysis in the Hydrology Report (Bousfield 2010) and is available in 

its entirety in the project record.

3.6.2 Affected Environment

The project area is located in the 135-square-mile Indian Creek watershed (figure 7). Indian 

Creek is the largest tributary to the Klamath River between the confluences with the Scott and 

Salmon Rivers. The Indian Creek watershed has high concentrations of dormant and active 

landslide terrain (see Geology section for more details) with a dense road network and a long 

history of mining and forest management. The residual effects of these past actions, in 

combination with the effects of past flood events, have led to a watershed whose sedimentation, 

stream temperature and channel geomorphology are not currently meeting desired conditions. 

Fire suppression has also created dense conditions in un-managed stands; reducing diversity and 

increasing the risk for high-severity wildfire (see Fire and Fuels section for more information). 

The Two Bit Vegetation Management Project was designed to help move a portion of the Indian 

Creek watershed towards the desired conditions. 

This section has been organized into the most relevant aspects of water resource 

management and protection: beneficial uses, watershed condition, channel condition, riparian 

condition, and water quality and quantity.
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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Beneficial Uses

The Indian Creek watershed supports coho and Chinook salmon, steelhead/rainbow trout, and a 

few other non-game fish species and Indian Creek provides the most miles of habitat for salmon 

and steelhead than any other tributary within this reach of the Klamath River. Private residents 

located along the South Fork and main stem of Indian Creek withdraw water for domestic use. 

Table 38 summarizes the beneficial uses by 7th, 6th and 5th field watersheds.

Table 38. Beneficial uses with the Two-Bit Vegetation Management project area and existing 

watershed conditions

Watershed Known Beneficial Use Types

Within Acceptable 

Thresholds of Concern 

(less than 1.0), based 

on ESLA, ERA and GEO 

modeling results?

7th – Field Watershed

Indian Creek Headwaters Resident and anadromous fish Yes

West Branch Indian Creek Resident and anadromous fish Yes

Indian/Mill Creek Resident and anadromous fish Yes

Coon-Wagner Domestic supply and resident and 

anadromous fish Yes

Upper South Fork Indian Creek Resident and anadromous fish Yes

Twin Valley Creek Resident and anadromous fish Yes

Little South Fork Indian Creek Domestic supply and resident and 

anadromous fish Yes

Cole-Clauson Domestic supply and resident and 

anadromous fish Yes

East Fork Indian Creek1 Domestic supply and resident and 

anadromous fish Yes

Luther-Ikes Domestic supply and resident and 

anadromous fish Yes

Indian/Doolittle Creek Domestic supply and resident and 

anadromous fish Yes

Perkins-Happy Camp Domestic supply and resident and 

anadromous fish

No, for surface soil 

erosion

6th – Field Watershed

Upper Indian Creek Domestic supply and resident and 

anadromous fish Yes

South Fork Indian Creek Domestic supply and resident and 

anadromous fish Yes

Lower Indian Creek Domestic supply and resident and 

anadromous fish Yes

5th – Field Watershed

Indian Creek Domestic supply and resident and 

anadromous fish Yes

1 East Fork Indian Creek is also a 6th-field watershed Yes

Watershed Condition

The Indian Creek watershed has a long history of mining and timber harvest resulting in altered 

vegetation and stream channels. Three mining sites are still recovering: Grey Eagle (near Luther 

Gulch and Deer Lick Creek), Huey (near Mill Creek and main stem Indian Creek), and Classic 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

133

Hill (near Coon Run Creek and main stem Indian Creek). Suction dredging was prevalent until 

the 2009 statewide ban on dredging, especially on the lower South Fork and on the main stem 

between the South Fork and West Branch Creek. The effects of suction dredging on beneficial 

uses are not well understood. 

Extensive past timber harvest created a dense road network throughout all of the 7th field 

watersheds, except Twin Valley Creek. The average road density in the Indian Creek 5th field 

watershed is 3.1 road miles per square mile with 0.65 road miles per square mile in stream 

course RRs (or approximately 21 percent). Hydrologic connectivity of Forest System and 

temporary roads to stream courses in the Indian Creek watershed ranges from 0.5 to 25.6 percent 

at the 7th field scale.

The Forest Plan Record of Decision (1995a) identified several locations in the Indian Creek 

watershed as areas with watershed concerns (AWWCs). These include all or portions of the 

following 7th field watersheds: Indian Creek Headwaters, Coon-Wagner, East Fork Indian Creek, 

and Luther-Ikes. The Indian Creek Watershed Analysis (USDA Forest Service 1997) recognized 

that watershed conditions in Indian/Mill Creek and Doolittle Creek were also of concern. The 

AWWCs are areas where a “cautious approach” for management will be applied, defined as 

activities that do not retard attainment of Forest Plan desired conditions, are carried out in 

support of forest health objectives, and result in a long-term benefit to the environment (USDA 

Forest Service 2006).

Since the Indian Creek Watershed Analysis (1997) was written, several projects have been 

undertaken to reduce road densities in this watershed through decommissioning, storm-proofing 

and hydrological stabilization (e.g. USDA Forest Service 1999a, USDA Forest Service 1999b, 

USDA Forest Service 2005b). The Indian Creek Roads Analysis (USDA Forest Service 2004b) 

recommended the decommissioning of 28 miles of road and storm-proofing of 136 miles of road. 

The Two Bit project contributes to the goal of reducing road densities in the Indian Creek 

Watershed. 

Current conditions of the Indian Creek watershed based on modeling show that the only 

watershed over acceptable thresholds of concern, or TOC (equal to 1.0) is Perkins-Happy Camp 

for surface soil erosion. Although no activities are planned in the Perkins-Happy Camp 7th field 

under any of the alternatives, it is included in the analysis because it is a sub-watershed of the 

Indian Creek 5th field watershed. The ERA model results for equivalent roaded areas indicate that 

all other subwatersheds are currently below the threshold of concern. The USLE and GEO model 

results for sediment volumes delivered to stream courses by surface soil erosion and landslides, 

respectively indicate that all subwatersheds where treatment activities are proposed are within 

acceptable levels.

Channel Condition

The Indian Creek watershed is characterized by steep gradient, high-energy lower-order streams 

(Rosgen A-type channels), with lower gradient response reaches (Rosgen B-type channels) near 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

134

most of the sub-watershed’s confluences with the South Fork and main stem of Indian Creek. 

The extensive dormant landslide terrain within the watershed has created an alternating benchscarp landform on the upper- to middle-slope position, with deeply incised inner gorges in the 

lower-slope position. This landform has created many 1st-order, low-gradient streams on 

benches with weakly defined channels that eventually drop off of scarps leading down to inner 

gorges of 2nd- and 3rd-order streams. Many of the lower- (2nd and 3rd) order streams have been 

scoured by debris flows with depositional features persisting in the lower gradient response 

reaches and main stem of Indian Creek. Extensive stream surveys of Indian Creek’s 6th field and 

a few 7th field response reaches were conducted in 1997, 1998, 2001 and 2009. Table 39

summarizes the survey results in terms of meeting Forest Plan desired conditions.

Table 39. Existing Pool conditions for surveyed stream reaches

Reach Name

Fine Sediment in 

Pool Tail-outs ( 

percent of 

Average)

Primary Pools /6 

Average Bankfull

Widths (#)

Large Woody Debris 

per 1,000 Feet

Forest Plan Desired Conditions Less than 15 1 20

Indian Creek Headwaters 5 0.1 0.2

Indian/Mill Creek 19 0.01 2.0

East Fork Indian Creek 11 0.04 0.8

Luther-Ikes 13 0.7 0.04

Indian/Doolittle Creek 11 0.1 0.3

Upper Indian Creek 5 0.1 0.8

South Fork Indian Creek 4 0.5 0

Lower Indian Creek 12 1.2 0

All reaches except Mill Creek meet desired conditions for fine sediment in riffles. Only 

Lower Indian Creek meets desired conditions for primary pool frequency. None of the reaches 

meet desired conditions for LWD. The effects of past floods (1955, 1965, 1974, 1997 and 2005) 

combined with one of the highest concentrations of landslides per watershed area on the Forest 

(See Geology section) overlaid by a dense road system are the main factors that have contributed 

to the poor channel characteristics in the Indian Creek watershed. 

Current channel conditions in Indian Creek are strongly influenced by past flood events. The 

1997 flood event (01/01/1997) caused debris slides that created debris flows in the main 

tributaries of Indian Creek. The main stem experienced hyper-concentrated steam flows, causing 

scour and deposition which reduced the size, volume, and depth of pools. The post-1997 flood 

assessment (USDA 1998) inventoried 25 landslides, 92 road related culvert or fill slope failures 

((Emergency Repair (of) Federally Owned (roads) (ERFO sites)), and 11.8 percent of the stream 

channels being altered. The more recent 2006 flood event (12/30/2005) had much less resource 

and facilities damage than the 1997 flood. An official assessment of the 2006 flood was not

conducted, but field reconnaissance discovered five ERFO sites. The most significant site was 
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where West Branch Creek undermined bridge supports, and the high flows reworked and 

mobilized a large alluvial feature. 

Riparian Condition

The Indian Creek watershed has a history of forest management, starting in the mining era where 

trees were harvested to build houses, flumes, and other structures. The forest regenerated

naturally without the use of modern reforestation techniques. Many stream banks in Indian Creek 

were placer -mined, leaving tailings in the riparian zone that persist to this day. Significant placer 

mining sites include Greens Creek, SF Indian Creek, and along the main stem of Indian Creek. 

Several other copper adit mines and open pit gold mines affected the riparian zone in smaller 

tributaries of Indian Creek. 

The vegetation management activities GIS layer used in cumulative watershed effects 

modeling shows Forest Service and private timber harvest from 1936 to the present. Clearcut 

harvesting throughout the stream course RRs was permitted prior to the creation of the Forest 

Plan (USDA 1995a). Table 40 summarizes the acres of clear-cut stream course RRs between 

1936 and 1995. Clearcut harvesting was steady from the 1950s until the 1990s with between 18 

and 31 percent of the total clearcut RR acreage occurring each decade over the 40-year period. 

All of these areas are recovering and contain trees between 20 and 50 years old.

Table 40. Previously clear-cut stream course Riparian Reserves

Watershed

Watershed 

Area 

(acres)

Stream Course RR Clear-cut Stream Course 

RR

Area 

(acres)

Fraction of 

Watershed 

Area (%)

Area 

(acres)

Fraction of 

Stream Course 

RR Area (%)

7th – Field Watershed

Indian Creek Headwaters 8,550 1,915 22.4 319 16.7

West Branch Indian Creek 5,365 1,288 24.0 135 10.5

Indian/Mill Creek 6,247 1,326 21.2 252 19.0

Coon-Wagner 6,624 1,598 24.1 141 8.8

Upper South Fork Indian Creek 7,649 1,869 24.4 141 7.6

Twin Valley Creek 8,782 1,842 21.0 0 0.0

Little South Fork Indian Creek 6,112 1,469 24.0 224 15.3

Cole-Clauson 9,267 2,344 25.3 169 7.2

East Fork Indian Creek1 11,761 2,605 22.2 213 8.2

Luther-Ikes 7,816 1,850 23.7 69 3.7

Indian/Doolittle Creek 5,869 1,480 25.2 342 23.1

Perkins-Happy Camp 2,194 481 21.9 27 5.5

6th – Field Watershed

Upper Indian Creek 26,786 6,127 22.9 847 13.8

South Fork Indian Creek 31,810 7,525 23.7 534 7.1

Lower Indian Creek 15,879 3,811 24.0 438 11.5

5th – Field Watershed

Indian Creek 86,236 20,068 23.3 2,033 10.1
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Water Quality

The intent of the Clean Water Act is met on National Forest System land by complying with 

water quality standards developed by the State of California, as authorized by the U.S. 

Environmental Protection Agency (EPA) pursuant to the Federal Clean Water Act of 1972. The 

Porter-Cologne Act, California’s corresponding state law, assigns responsibility for protection of 

water quality within North Coast watersheds to the North Coast Regional Water Quality Control 

Board (NCRWQCB). The NCRWQCB implements and enforces the Porter-Cologne Act, and the 

Water Quality Control Plan for the North Coast Basin (Basin Plan). Water quality objectives are 

outlined in the Basin Plan. The primary purpose for maintaining water quality is to assure that 

the beneficial uses of water are not adversely affected. When water quality objectives are met, 

and beneficial uses protected, then the State considers that a project meets water quality 

standards.

The Forest Service entered into a Management Agency Agreement (1981) with the 

NCRWQCB and State of California requiring the Forest Service to institute a water quality 

management program to meet applicable water quality objectives and protect beneficial uses. 

Under the agreement, implementation of State-approved and EPA-certified best management 

practices (BMPs) are considered sufficient to protect water quality from non-point sources of 

pollution (USDA 2000b). As long as BMPs are implemented, the Forest Service can apply for an 

exemption from waste discharge requirements under the 2004 Categorical Waiver for Discharges 

Related to Timber Harvest Activities on Federal Lands managed by the USDA Forest Service in 

the North Coast Region (USDA 2004c). The 2004 waiver recently expired, but was extended 

during the development of a new waiver. On August 4, 2009, the State Water Resources Control 

Board unanimously approved a resolution directing their staff to develop a statewide waiver to 

cover all activities with potential for non-point source pollution on National Forest System land 

in California. The statewide waiver will be developed over the next 18 months to replace the 

2004 waiver. This project would most likely fall under the 2004 Waiver. 

Indian Creek is 303(d) listed as impaired for nutrients, organic enrichment/low dissolved 

oxygen, and water temperature. A total maximum daily load (TMDL) action plan for the MidKlamath River is currently in development with a foreseeable completion date of 2011. The MidKlamath Hydrologic Area (HA) was recently listed for sediment in 2008. A TMDL for sediment 

will not be developed until 2021. 

Highest average of maximum daily temperatures over any seven day period (maximum 

weekly maximum temperature, MWMT) range from 13 degrees Celsius on West Branch Creek 

to 25 degrees Celsius in South Fork Indian Creek, as measured in various locations in the Indian 

Creek watershed since 1996 (Welsh et al. 2001). The MWMT recorded on the South Fork and 

main stem sampling locations exceed the theoretical maximum temperature for supporting 

anadromous fish species throughout their life cycle. The MWMT consistently occurs during the 

last two weeks in July. Unfortunately, the only water temperature data available for the smaller 

tributaries is from 1996. The MWMT of the tributaries shows the importance of thermal refugia 
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near the confluences with the warmer main stem. The smaller tributaries are still maintaining 

cold water temperatures despite the dense road system and legacy effects of logging and mining. 

The main stem portion in Upper Indian Creek is substantially colder than downstream locations. 

Below the confluence with the South and East Forks, the main stem has many wide sections with 

little shade to buffer solar loads. The wide alluvial sections are where the majority of the 1997 

flood debris flows were deposited. 

Sedimentation has only been measured through coarse stream surveys and through 

cumulative watershed effects modeling. Turbidity threshold sampling would need to be 

conducted to get an accurate estimate of sediment transport volumes and sediment 

concentrations during peak flow events.

Water Quantity

The USGS stream gage located approximately 3.5 miles upstream from the confluence of the 

Klamath River provides surface water data for 120 square miles of the Indian Creek watershed 

(89 percent of the watershed’s area). The average annual runoff recorded at the stream gage from 

1957 to 2008 is 302,500-acre-feet, or 47 inches. Annual evapotranspiration is approximately 28 

inches, given the isobar-weighted average annual rainfall of 75 inches (Rantz 1964). An 

unknown portion of the 28 inches is drafted from Indian Creek for domestic water use. Minimum 

daily flows consistently occur during September, supporting the concept that the main stem’s 

water temperature is more strongly related to air temperature and solar radiation than to low flow 

conditions.

3.6.3 Environmental Consequences

Alternative 1- No Action 

Direct, Indirect and Cumulative Effects

The no-action alternative would not add any new management-related ground disturbance to the 

Indian Creek watershed in the short- or long-term. Appendix F summarizes existing conditions in 

the watershed based on CWE model results. Channel conditions would continue to recover from 

the 1997 flood event. Subsequent flood events could cause the conditions to worsen. Stream 

flows would not be affected by the no-action alternative.

Riparian vegetation in stream course RRs would continue to persist or recover from past 

harvesting activities (table 44). Areas where stream course RRs were planted with a tight spacing 

and/or did not receive follow-up non-commercial thinning would see trees die due to 

competition which could affect stream temperature due to loss of effective shade. Mortality due 

to snow breakage, insects and disease may occur in plantations where off-site pine was planted, 

which could cause large holes in the riparian canopy, therefore increasing solar loading. It would 

take 30-50 years for conifers to naturally regenerate and restore canopy cover in the stream 

course RRs with dead and dying off-site pine. Wildfire could cause high burn severity in 
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138

overstocked stream course RRs under the no-action alternative; high severity fire could result in 

adverse effects to water quality.

The no action alternative would not cause any negative effect to aquatic habitat conditions 

since actions would not be taken that could measurably affect the stream flow, temperature, or 

sediment regimes. Not treating RRs or decommissioning roads could prolong or cause an 

increase in the current effects to aquatic habitat.

Beneficial uses of water would continue to be supported in their current state under this 

alternative. The current state is considered to be impaired under the 303(d) list for temperature, 

nutrients, dissolved oxygen, and sediment. The no action alternative would not accelerate the 

possibility of delisting Indian Creek for sediment because no road decommissioning would be 

performed, or for temperature because dying densely-stocked and altered stream course RRs 

would not be treated.

Achievement of Forest Plan desired conditions within stream course RRs would take at least 

100 years, especially in plantations with densely stocked stands with off-site pine. No change 

(increase or decrease) in the Forest System road density would occur. 

Aquatic Conservation Strategy Objectives are described in detail in appendix D. Appendix D 

includes a summary of how alternative 1 addresses these objectives and compares this to 

implementation of the action alternatives. 

Common to All Action Alternatives

There are 43 ephemeral and 50 intermittent streams adjacent to or within proposed treatment 

units. Four out of the 50 intermittent streams continue to flow into June contributing cold water 

during warm summer months. Eight perennial streams are adjacent to proposed treatment units 

(although this number is slightly less for alternative 3). The majority of the stream courses with 

proposed RR treatments are located on benches and are low-gradient, with weakly defined 

channels. A smaller portion of the stream courses with proposed RR treatments are high-energy, 

with well defined incised channels. No commercial treatments are located in fish-bearing stream 

course RRs. All of the landscape scale underburns outside of thinning units are adjacent to 

anadromous and/or resident fish-bearing stream course RRs. 

Direct Effects from Road Decommissioning

The same level of road decommissioning is proposed for all action alternatives and the effects 

described here are common to alternatives 2, 3 and 4. Road decommissioning would cause shortterm, negative effects to sedimentation, stream temperature and channel morphology. Removal 

of culverts on perennial stream crossings during road decommissioning would result in direct 

sedimentation effects. These are considered direct effects since the action would occur within the 

stream channel where water would be diverted around the construction site, or dammed, which 

could cause a minor increase in stream temperature. Groundwater inflow at the construction site 

would be hard to control on perennial crossings which may cause turbid water conditions. 
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Turbidity could be highest at the site, but would diminish as it extends through the reach (Foltz 

et al. 2008). If settling ponds were to be installed to lower turbidity from groundwater seepage, 

then an increase in water temperature might occur. All of these negative effects would be shortterm, occur during construction and last for no more than a few days post-construction. Road 

decommissioning would not cause negative short- or long-term effects at the reach or watershed 

scale. 

Excavation in the stream channel for road decommissioning might cause short-term 

sedimentation and channel incision which could occur during the following winter rain storms. 

These effects might last for up to two winters (depending on the magnitude of peak flow) and 

only be detectable at the site scale (Foltz et al. 2008, Madej 2001). The resulting channel incision 

and slope erosion would be a fraction of the total fill removed at the crossings. Two large 

perennial stream crossings (tributaries to Sutcliffe and Doolittle Creek), and seven intermittent 

stream crossings would be decommissioned. 

The long term benefits of decommissioning these crossings far outweigh any short-term 

negative effects to water quality. Beneficial effects due to the proposed decommissioning also 

include a USLE model predicted reduction of 14 cubic yards per year of sediment and a GEO 

model predicted reduction of 2,079 cubic yards of sediment from a 10-year return period masswasting event. These beneficial effects are due to restoration of hill slope hydrology from 

removal of inboard ditches, cross-drain culverts and stabilization of the roads cut and fill slopes.

Meadow Enhancement

Meadow enhancement is proposed for all action alternatives and the effects described here are 

common to Alternatives 2, 3 and 4. The proposed meadow treatments would benefit meadows 

and wetlands by reducing conifer encroachment. Groundwater amounts may actually increase 

from these treatments, prolonging the duration of seasonal water inundation. Increasing the 

duration and extent of the groundwater table would favor plant species adapted to these 

environments. Ground disturbance would be minimal due to hand treatment. Shade would not 

decrease since only small diameter thinning by hand, followed by pile burning would occur.

Alternative 2 – Proposed Action 

Direct/Indirect Effects

Activities within Stream Course Riparian Reserves

Roads and Landings

Re-opened temporary roads located in stream course RRs may cause short-term, negative effects 

to sedimentation and stream temperature. Reopened temporary road stream crossings may cause 

short-term, negative effects to sedimentation, stream temperature and channel morphology. Reopened landings located in stream course RRs may cause short-term, negative effects to 

sedimentation and stream temperature.
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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Table 41 compares the miles and road density of reconstructed to decommissioned roads 

within stream course RRs. The increase in temporary road density is offset by the reduction due 

to decommissioning in the West Branch Creek 7th field watershed and the entire Indian Creek 5th

field; there would be a net reduction in road densities following implementation of alternative 2. 

The proposed reopened/reconstructed roads in the stream course RR are located in the outer 

half of the interim width (170 ft), meaning there would be at least 85 feet between the road and 

the stream course. Some of the reconstructed roads perpendicularly bisect stream course RRs at 

intermittent and ephemeral stream crossings. BMPs and project design features would ensure 

that reopened roads and decommissioned roads would not cause detrimental effects to beneficial 

uses of water. The reopening/reconstruction of existing roads might have less effect than the 

construction of new temporary roads, although some of the old roads may be located in 

undesirable locations. Reconstructed roads may already have an established road prism 

compared to newly constructed ones that would require more soil displacement. The vegetation 

removed on reconstructed roads may not have as substantial of a root system as what would be 

removed on a newly constructed road, so mass-wasting may have a greater effect on newly 

constructed roads. Any possible increase in surface erosion and peak flow from either newly 

constructed or reconstructed roads would be the same. After the temporary roads are used and 

hydrologically restored there would be no difference between newly constructed temporary roads 

and reconstructed roads. 

Short-term, negative indirect effects at an existing temporary road stream crossing may 

occur following hydrologic rehabilitation. These activities would not cause detrimental effects to 

beneficial uses of water. Subsequent road closure may leave some of the reconstructed roads that 

were poorly designed originally in a more properly functioning hydrological state.

Table 41. Proposed action comparison of miles of reconstructed temporary roads to 

decommissioned roads located in stream course RRs by 7th –field watershed (percent change in 

parentheses)

Watershed Reopened/Reconstructed 

Temporary Roads Decommissioned Roads

Indian Creek Headwaters 0.04 (0.41)

West Branch Indian Creek 0.16 (2.9) 0.49 (-8.9)

Coon-Wagner 0.14 (1.6)

Little SF Indian Creek 0.24 (-4.1)

Cole-Clauson 0.11 (1.1)

East Fork Indian Creek 0.11 (1.6)

Indian/Doolittle Creek 0.98 (-7.9)

Total 0.56 (0.64) 1.70 (-1.95)

Acres of reconstructed landings located within stream course RRs are listed in table 42. 

Constructed landings would be located outside of stream course RRs. Landings would be 

hydrologically restored by actions such as removing berms, recontouring, and spreading slash or 

straw as needed. Therefore any negative effects on water quality would be insignificant, short-
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

141

term (3 years prior to revegetation), and only occur at the site scale. BMPs and project design 

features would ensure that landings would not cause significant effects to beneficial uses of 

water.

Table 42. Proposed action acres of reconstructed landings located in stream course RRs by 7th field 

watershed

Watershed

Reconstructed Landings in Stream 

Course

Riparian Reserves (acres)

Indian Creek Headwaters 1.2

West Branch Indian Creek 1.1

Indian/Mill Creek 0.45

Coon-Wagner 0.34

Little SF Indian Creek 0.73

Cole-Clauson 1.59

East Fork Indian Creek 0.68

Luther-Ikes

Indian/Doolittle Creek 0.75

Total 6.84

Thinning

Thinning treatments in stream course RRs may cause short-term, negative effects to 

sedimentation from skid trails and to stream temperature from canopy removal in plantations.

Acres of commercial treatment and ground based equipment operations in steam course RRs are 

summarized in table 43. 

These acres have already been adjusted by the stream course RR buffers prescribed in the 

project design features (Chapter 2). 

These buffers, although not the entire steam course RR interim width, would be adequate to 

avoid substantial detrimental effects to beneficial uses of water. The Forest Service Best 

Management Practice Evaluation Program 2003-2007 Report (USDA Forest Service 2009a) 

indicated that Region 5 Forests were 94 percent effective in preventing sediment from entering 

stream channels. Any possible sediment delivery to streams due to these smaller buffer widths 

for treating previously clear-cut stream course RRs would be minor and at the site scale.
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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Table 43. Proposed action commercial treatment acreage located in stream course RRs by 7th field 

watershed1

Watershed

Total Stream 

Course RR 

(acres)

Stream Course RR treatment acreage with 

project design feature ( percent of all RR)

Commercial 

Treatment Ground-Based

Indian Creek Headwaters 1,915 59.9 (3.1) 42.5 (2.2)

West Branch Indian Creek 1,288 40.0 (3.1) 40.0 (3.1)

Indian/Mill Creek 1,326 9.8 (0.7) 9.8 (0.7)

Coon-Wagner 1,598 46.3 (2.9) 46.3 (2.9)

Little SF Indian Creek 1,469 13.4 (0.9) 13.4 (0.9)

Cole-Clauson 2,344 26.6 (1.1) 24.3 (1.0)

East Fork Indian Creek 2,605 11.1 (0.4) 11.1 (0.4)

Luther-Ikes 1,850

Indian/Doolittle Creek 1,480 23.2 (1.6) 22.0 (1.5)

Total for Indian Creek 5th field 

Watershed 20,068 230 (1 percent) 209 (1 percent)

1 Ground based treatment acres includes feller buncher, tractor endline and traditional tractor yarding.

Buffers and canopy retention project design features have been developed for perennial and 

large intermittent streams (intermittent streams which flow into the month of June) in natural 

stands to eliminate the possibility of stream shade reduction (Chapter 2). All of the perennial 

streams flow adjacent to, not through, treatment units. Therefore, any treatment to perennial 

stream course RRs would only occur on one side of the stream course. There would be no effects 

to stream temperature due to thinning natural stands in the RRs of perennial and large 

intermittent streams because canopy cover would remain above 85 percent in the inner portion 

and above 65 percent in the outer portion (see project design features in Chapter 2). 

Even with the aggressive plantation treatment, the canopies of the young thrifty trees should 

regenerate previous stream shade within a decade. A review of research projects studying effects 

to stream temperature due to stream course RR treatments saw a general trend of onsite stream 

temperature recovery of 10 years, although many of these studies were of clear-cuts (Moore et al. 

2005). The buffering capacity downstream due to stream shade, flow, and tributary and 

groundwater inflow could reduce stream temperatures to background levels a short distance 

downstream (Moore et al. 2005). Increased stream temperature in plantations may occur at the 

site and diminish at the reach scale, but would be undetectable at the 7th field watershed scale 

because of the small percentage, ranging from 0.2-3.1 percent, of stream course RR treatments 

relative to the intact stream course RRs in watersheds as a whole. Commercial treatment in 

plantation stream course RRs would not cause long-term detrimental effects to stream 

temperature.

Underburning

Prescribed fire treatments in stream course RRs could cause short-term, negative effects to 

sedimentation. The proposed landscape-scale underburn acres within stream course RRs are 

summarized in table 44. These underburns would be located in a larger portion of the stream 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

143

course RRs. Prescribed burning in stream course RRs should lower the risk of extreme fire 

behavior that might otherwise result in high soil burn severity during future wildfires. Recent 

high-severity wildfires in the Elk Creek watershed completely burned through and consumed 

much of the vegetation in stream course RRs. Although this was an extreme wildfire event, the 

pre-emptive use of prescribed fire might have limited the high-intensity effects in these often 

heavily fuel-loaded areas. Project design features and BMPs (Chapter 2) ensure effects from 

underburning are minimized. Possible negative effects to water quality due to prescribed fire 

would be short-term (1-2 years) and occur at the site scale. Prescribed fire would not cause 

substantial effects to beneficial uses of water.

Table 44. Proposed action prescribed burning acreage located in stream course RRs by 7th field 

watershed

Watershed Total Stream Course 

RR (acres)

Steam course RR Rx burn 

acres ( percent of all RR)

Indian Creek Headwaters 1,915 412.9 (21.6)

West Branch Indian Creek 1,288 266.1 (20.7)

Indian/Mill Creek 1,326 6.2 (0.5)

Coon-Wagner 1,598 168.0 (10.5)

Little SF Indian Creek 1,469 302.6 (20.6)

Cole-Clauson 2,344 143.1 (6.1)

Indian/Doolittle Creek 1,480 230.8 (15.6)

Total for Indian Creek 5th field Watershed 20,068 1529.7 (7.6)

Cumulative Effects

Changes in Sedimentation and Channel Morphology

For this analysis, all planned projects are analyzed as being completed; therefore, there are no 

other present or reasonably foreseeable actions considered. The CWE analysis is summarized in 

table 45 and in tables 74 and 75 in appendix F. The results indicate that the amount, intensity, 

and locations of the alternative 2 treatments relative to the watershed area have a small effect on 

CWE risk ratios; only small changes are seen when comparing the existing condition to the 

effects of the proposed action. The proposed decommissioning would cause a net decrease in the 

GEO risk ratio in the Indian/Doolittle Creek 7th field watershed and the greater Lower Indian 

Creek 6th-field watershed. Predicted increases in surface soil erosion (USLE) are greatest in 

Coon-Wagner at a 0.12 increase in risk ratio. The USLE model does not factor in the capacity of 

stream course RR buffers to filter sediment before reaching the stream course. Therefore, the 

actual amount of sediment that may enter the channel is a fraction of the predicted amount. 

The indirect effects predicted by the USLE model may be realized from a 6-hour, 2-year rain 

event. Should this design storm not occur prior to revegetation, then the predicted sedimentation 

rates would not occur.
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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Predicted increases in sedimentation due to mass wasting were the greatest in Indian/Mill 

Creek and Coon-Wagner at a 0.03 increase in risk ratio. This increase is outside of the accuracy 

of the GEO models. The GEO model is an empirical model and provides a rough estimate of 

accelerated mass-wasting potential. The predicted mass-wasting might be triggered by a 10-year 

event if one were to occur. It is possible that a recovery of root strength from grass and brush 

species, as well as the retained trees’ root systems extending into the gaps where trees were 

harvested, may promote recovery of the hillslope hydrology prior to the occurrence of the next 

10-year event.

Table 45. Cumulative watershed effects risk ratios for the existing condition (alternative 1) and the 

proposed action (alternative 2)

Watershed

Model

USLE GEO ERA

Existing 

Condition

Proposed 

Action 

Existing 

Condition

Proposed 

Action 

Existing 

Condition 

Proposed 

Action 

7th – Field Watershed

Indian Creek 

Headwaters 0.33 0.44 0.43 0.45 0.48 0.63 

West Branch 

Indian Creek 0.68 0.78 0.36 0.36 0.70 0.84 

Indian/Mill 

Creek 0.23 0.25 0.45 0.48 0.32 0.36 

Coon-Wagner 0.52 0.64 0.79 0.82 0.67 0.85 

Upper South 

Fork Indian 

Creek

0.09 0.09 0.22 0.22 0.26 0.26 

Twin Valley 

Creek 0.00 0.00 0.00 0.00 0.00 0.00 

Little South 

Fork Indian 

Creek

0.34 0.40 0.34 0.35 0.36 0.47 

Cole-Clauson 0.18 0.23 0.55 0.55 0.49 0.54 

East Fork 

Indian Creek 0.15 0.15 0.81 0.81 0.28 0.29 

Luther-Ikes 0.39 0.39 0.75 0.75 0.60 0.61 

Indian/Doolittle 

Creek 0.80 0.87 0.76 0.74 0.60 0.67 

Perkins-Happy 

Camp 1.36 1.36 0.54 0.54 0.59 0.59 

6th – Field Watershed

Upper Indian 

Creek 0.43 0.52 0.51 0.52 0.50 0.63

South Fork 

Indian Creek 0.10 0.12 0.30 0.30 0.29 0.32

Lower Indian 

Creek 0.67 0.69 0.74 0.73 0.59 0.61

5th – Field Watershed

Indian Creek 0.26 0.30 0.50 0.50 0.46 0.52 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

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ERA modeling is used to provide an estimate of peak flow increase, but is hard to analyze 

since its outputs are simply in ERA percentages. Grant et al. (2008) reviewed the results of 

paired watershed studies to come to a consensus on forest harvesting effects on peak flow. The 

review found that forest harvesting in the transient snow zone had a greater influence on peak 

flows than forest harvesting in the rain-dominated zone. In the rain-dominated zone, the percent 

of a watershed’s area that is harvested would have to exceed between 30 and 45 percent to reach 

the 10 percent peak flow increase prediction limit (Grant et al. 2008). In the transient snow zone, 

the percent of a watershed’s area that is harvested would have to exceed between 15 and 20 

percent to reach the 10 percent prediction limit (Grant et al. 2008). Openings in the forest canopy 

can collect more snow which could melt quickly during rain-on-snow events, causing a peak 

flow increase in clear-cut or heavily thinned areas (Moore and Wondzell 2005). This may be 

especially true of plantations located in the transient snow zone where heavy thinning is 

proposed. By converting percent ERA into percent Equivalent Clearcut Acres (ECA), the 

increase in ERA risk ratios of 0 to 0.18 (0 to 1 percent ERA increase or a 0 to 4 percent ECA 

increase) due to alternative 2 may be equal to a 0 to 2 percent increase in peak flow. The 

cumulative increase in peak flow may be 0 to 10 percent (with Coon-Wagner going from and 8 

to 10 percent and Luther/Ikes remaining at 9 percent). This assumes that the entire Indian Creek 

watershed is in the transient snow zone. All of the 7th field watersheds in Indian Creek are larger 

than those of paired watershed studies in Grant et al. (2008), so the possible peak flow increase 

would be equal to or smaller than 0 to 2 percent. The treated smaller sub-watersheds within the 

greater 7th field may experience the 0 to 2 percent increase in peak flow, but this increase, when 

added to the remaining untreated sub-watersheds, would be attenuated and therefore 

undetectable at 7th field scale.

Neither summer low flows nor annual water yield would be affected due to the overall small 

amount of thinning in proportion to a particular 7th field watershed’s drainage area. When 

treatment acres are scaled based on their respective treatment (50 percent for plantations and 25 

percent for natural stands) the relative amount of acres being opened range from 0.2 to 2.6 

percent of an entire 7th field watershed. Based on paired watershed studies, water yield and 

summer low flows may actually increase (Keppeler and Ziemer 1990, Stednick 2008), although 

the amount of basal area removed in these studies is far greater than what would occur on a 

watershed scale under the proposed action.

Modeled pre- and post-project cumulative watershed effects at the 7th field scale are all under 

1.0, each model’s threshold of concern in those watersheds where treatments are proposed. 

Although ERA, USLE and GEO model results are under the threshold of concern, they are 

elevated (any model’s risk ratio greater than 0.75 and less than 1.00) in several watersheds 

(Coon-Wagner, East Fork Indian Creek, Luther/Ikes, and Indian/Doolittle Creek) with proposed 

treatments (table 49). The proposed action may cause a peak flow increase of 0-2 percent, which 

would cause the cumulative peak flow increases to range from 0-10 percent. The peak flow 

increase may be detectable in smaller sub-watersheds where treatments would occur, but not in 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

146

the greater 7th field watersheds. Annual water yields would remain unaltered, although low flows 

could have a short-term increase. 

Conclusion

Alternative 2 would not change aquatic habitat conditions because only minor impacts to water 

quality are expected. All potential negative effects would be short in duration (1-10 years) and 

would occur at the site or reach scales. The negative effects would not measurably affect 

sedimentation, stream temperature, or channel geomorphology at the reach, the 7th field 

watershed scale, or greater.

Beneficial uses of water would continue to be supported in their current state under this 

alternative. The current state is considered to be impaired under the 303(d) list for temperature, 

nutrients, dissolved oxygen, and sediment. Alternative 2 would help accelerate the delisting of 

Indian Creek for sediment due to the reduction in road sediment sources from decommissioning.

Achievement of Forest Plan desired conditions within the stream course RRs would be 

accelerated (when compared to taking no action), especially in densely-stocked stands with offsite pine. While a reduction in road density would be realized across the Indian Creek 5th field 

watershed as a whole, three of the six 7th field watersheds with watershed concerns would have a 

net increase in road density within stream course RRs due to the proposed action. Newly 

constructed and reconstructed temporary roads would be hydrologically restored following use 

causing potential short-term adverse effects to diminish over time. 

Aquatic Conservation Strategy Objectives are described in detail in appendix D. Appendix D 

includes a summary of how alternative 2 addresses these objectives and compares this to 

implementation of the action alternatives. 

Alternative 3 – No New Temporary Roads

Alternative 3 differs from alternative 2 in the following ways: 1) no newly constructed 

temporary roads; 2) 0.8 fewer miles of re-opened/reconstructed temporary roads; 3) 270 fewer 

acres of commercial thinning; 4) 28 fewer landings; and 5) 70 more acres of underburning. 

Direct/Indirect Effects

Activities within Stream Course Riparian Reserves

Roads and Landings

Alternative 3 includes fewer miles of reopened/reconstructed temporary roads in stream course 

RRs than alternative 2 and therefore, benefits of proposed decommissioning and net reduction in 

road density in stream course RRs would be greater under alternative 3 than alternative 2.
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

147

Table 46. Alternative 3 comparison of miles (percent) of reopened/reconstructed temporary roads to 

decommissioned roads located in stream course RRs by 7th field watershed 

Miles in Stream Course RRs (percent change in stream course RR road density)

7th -field Watershed 

name Reconstructed Temporary Roads Decommissioned Roads

Indian Creek Headwaters 0.04 (0.41) None

West Branch Indian Creek 0.16 (2.9) 0.49 (-8.9)

Coon-Wagner 0.03 (0.34) None

Little SF Indian Creek None 0.24 (-4.1)

Cole-Clauson 0.06 (0.59) None

East Fork Indian Creek 0.11 (1.6) None

Indian/Doolittle Creek None 0.98 (-7.9)

Total 0.40 (0.46) 1.70 (-1.95)

The same amount of reconstructed landings would be devegetated for use in alternative 3 as 

in alternative 2 and therefore impacts are the same as those previously described for alternative 

2. 

Thinning

Alternative 3 would include 27 percent less thinning and 28 percent less ground based treatments 

in stream course RRs than alternative 2 (table 47). Therefore, the potential indirect negative 

effects to water quality would be less. Substantial effects to beneficial uses of water would not 

occur since the same BMPs and project design features would be in place for all action 

alternatives.

Table 47. Alternative 3 commercial treatment acreage located in stream course RRs by 7th field 

watershed1

Watershed

Total Stream 

Course Riparian 

Reserve (acres)

Stream Course RR treatment 

acreage with project design 

feature ( percent of all RR)

Commercial 

Treatment

GroundBased

Indian Creek Headwaters 1,915 42.3 (2.2) 24.9 (1.3)

West Branch Indian Creek 1,288 36.3 (2.8) 36.3 (2.8)

Indian/Mill Creek 1,326 6.1 (0.5) 6.1 (0.5)

Coon-Wagner 1,598 21.6 (1.3) 21.6 (1.3)

Little SF Indian Creek 1,469 13.4 (0.9) 13.4 (0.9)

Cole-Clauson 2,344 15.3 (0.7) 15.3 (0.7)

East Fork Indian Creek 2,605 11.1 (0.4) 11.1 (0.4)

Luther-Ikes 1,850

Indian/Doolittle Creek 1,480 22.0 (1.5) 22.0 (1.5)

Total for Indian Creek 5th-field 

Watershed 20,068 168.1 (0.84) 150.7 (0.75)

1 Ground based treatment acres includes feller buncher, tractor endline and traditional tractor yarding.
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

148

Underburning

Prescribed burning in stream course RRs would lower the risk of extreme fire behavior that 

might otherwise result in high soil burn severity during future wildfires. Project design features 

and BMPs (Chapter 2) ensure effects from underburning are minimized. Possible negative 

effects to water quality due to prescribed fire would be short-term (1-2 years) and occur at the 

site scale. Prescribed fire would not cause substantial effects to beneficial uses of water. Slightly 

more (70 acres) underburning is proposed under alternative 3 than alternative 2; but this 

difference is considered negligible at the watershed scale and therefore, the effects are the same 

as those described for alternative 2.

Cumulative Effects

Changes in Sedimentation and Channel Morphology

Except for a few hundredths of a risk ratio less, the cumulative watershed effects modeling 

results are very similar for alternative 3 when compared to alternative 2 (table 52 and appendix

F). Table 48 shows the change from the existing condition in the modeled results (existing 

conditions are shown in table 46 for alternative 2 and also in table 75 in appendix F). Changes in 

sedimentation at the watershed scale are the same as those described previously for alternative 2.

Table 48. Alternative 3 influence of cumulative watershed effects risk ratios (change in parentheses)

Watershed

Model

USLE GEO ERA

7th – Field Watershed

Indian Creek Headwaters 0.44 (0.11) 0.45 (0.02) 0.61 (0.13)

West Branch Indian Creek 0.78 (0.10) 0.36 (<0.01) 0.82 (0.12)

Indian/Mill Creek 0.25 (0.02) 0.47 (0.02) 0.35 (0.03)

Coon-Wagner 0.63 (0.11) 0.81 (0.02) 0.81 (0.14)

Upper South Fork Indian Creek 0.09 (0) 0.22 (0) 0.26 (0)

Twin Valley Creek 0.00 (0) 0.00 (0) 0.00 (0)

Little South Fork Indian Creek 0.40 (0.06) 0.35 (0.01) 0.47 (0.11)

Cole-Clauson 0.23 (0.05) 0.55 (<0.01) 0.53 (0.04)

East Fork Indian Creek 0.15 (<0.01) 0.81 (<0.01) 0.29 (0.01)

Luther-Ikes 0.39 (<0.01) 0.75 (<0.01) 0.61 (0.01)

Indian/Doolittle Creek 0.87 (0.07) 0.74 (-0.02) 0.66 (0.06)

Perkins-Happy Camp 1.36 (0) 0.54 (0) 0.59 (0)

6th – Field Watershed

Upper Indian Creek 0.52 (0.09) 0.52 (0.01) 0.61 (0.11)

South Fork Indian Creek 0.12 (0.02) 0.30 (<0.01) 0.32 (0.03)

Lower Indian Creek 0.69 (0.02) 0.73 (-0.01) 0.61 (0.02)

5th – Field Watershed

Indian Creek 0.29 (0.03) 0.50 (<0.01) 0.51 (0.05)

Modeled pre- and post-project cumulative watershed effects at the 7th field scale are all under 

1.0, each model’s threshold of concern in those watersheds where treatments are proposed. 

Although, ERA, USLE and GEO model results are under the threshold of concern, they are 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

149

elevated (any model’s risk ratio greater than 0.75 and less than 1.00) in several watersheds 

(Coon-Wagner, East Fork Indian Creek, Luther/Ikes, and Indian/Doolittle Creek) with proposed 

treatments (table 48). Alternative 3 may cause peak flow increase of 0 to 2 percent, which would 

cause cumulative peak flow increases to range from 0 to 10 percent. Peak flow increase may be 

detectable in smaller sub-watersheds where treatments would occur, but not in the greater 7th

field watersheds. Annual water yields would remain unaltered, although low flows could have a 

short-term increase. 

Conclusion

Alternative 3-No New Temporary Roads, would not change aquatic habitat conditions because 

only minor impacts to water quality are expected. All potential negative effects would be short in 

duration (1-10 years) and would occur at the site or reach scales. The negative effects would not 

measurably affect stream temperature at the site and reach scale, or sedimentation, and channel 

geomorphology at the site scale. All are not measurable at the 7th field watershed scale, or 

greater.

Beneficial uses of water would continue to be supported in their current state under this 

alternative. The current state is considered to be impaired under the 303(d) list for temperature, 

nutrients, dissolved oxygen, and sediment. Alternative 3 would help accelerate the delisting of 

Indian Creek for sediment due to the reduction in road sediment sources from decommissioning 

and would do so to a higher degree than Alternative 2 due to less temporary road construction.

Achievement of Forest Plan desired conditions within the stream course RRs would be 

accelerated (when compared to taking no action), especially in densely-stocked stands with offsite pine. While a reduction in road density would be realized across the Indian Creek 5th field 

watershed as a whole, three of the six 7th field watersheds with watershed concerns would have a 

net increase in road density within stream course RRs due to alternative 3. Newly constructed 

and reconstructed roads would be hydrologically restored following use causing potential shortterm adverse effects to diminish over time. 

Aquatic Conservation Strategy Objectives are described in detail in appendix D. Appendix D 

includes a summary of how alternative 3 addresses these objectives and compares this to 

implementation of the action alternatives. 

Alternative 4 – Minimized Underburning

Alternative 4 differs from alternative 2 in the following ways: 1) 6,680 fewer acres (92 percent) 

of underburning and 2) mastication to treat slash following thinning would be used instead of or 

in combination with underburning/hand pile burning in 93 units, for a total of approximately 

1,490 acres of mastication. 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

150

Direct/Indirect Effects

Effects described above for alternative 2 related to direct/indirect effects from roads and landings 

in stream course RRs and thinning in stream course RRs are the same as those previously 

described for alternative 2 since all of these treatments are the same for alternative 4. 

Activities within Stream Course Riparian Reserves

Underburning and Mastication

Alternative 4 includes 92 percent fewer acres of underburning than alternative 2 and includes a 

substantial amount of site- preparation mastication following ground-based vegetation treatment. 

Proposed mastication in stream course RRs (table 49) could cause short-term negative effects to 

water quality due to ground disturbance that may cause sediment delivery from an extreme rain 

event (Hatchett et al. 2006). Most of the ground disturbance would be covered by masticated 

vegetation so any effects would be minor and have a low probability of occurring. Project design 

features and BMPs would minimize the potential for adverse effects at the site scale. Effects to 

sedimentation, stream temperature, and channel geomorphology would be undetectable at the 

reach, 7th field scale or greater. 

There would be no substantial direct/indirect effects to water quality due to implementation 

of alternative 4.

Table 49. Alternative 4 proposed mastication acreage located in stream course RRs in 7th field 

watersheds

7th -field Watersheds Total Stream 

Course RR (acres)

Total Stream Course 

RR mastication acreage 

with project design 

feature (% of all RR)

Indian Creek Headwaters 1,915 14.7 (0.77)

West Branch Indian Creek 1,288 3.5 (0.27)

Indian/Mill Creek 1,326 1.5 (0.12)

Coon-Wagner 1,598 5.2 (0.32)

Little SF Indian Creek 1,469 9.1 (0.62)

Cole-Clauson 2,344 9.9 (0.42)

East Fork Indian Creek 2,605 17.6 (0.67)

Luther-Ikes 1,850 2.4 (0.13)

Indian/Doolittle Creek 1,480 15.0 (1.01)

Total for Indian Creek 5th –field Watershed 20,068 78.8 (0.39)

Cumulative Effects

Changes in Sedimentation and Channel Morphology

For USLE, alternative 4 would have a lower effect on risk ratios since there would be less 

underburning and the model assumes that the use of mastication may actually increase soil cover. 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

151

GEO would remain unchanged when compared with the proposed action. ERA would increase 

from mastication, but would decrease due to less underburning treatments. When compared to 

the proposed action, some 7th field watersheds would experience greater increases and others 

would experience smaller increases in ERA risk ratios. There would be no measurable difference 

in ERA risk ratios at the 6th and 5th scale, except in South Fork Indian Creek, which would 

exhibit a risk ratio 0.01 less than the proposed action. Table 50 and appendix F display the results 

of modeling for alternative 4. Table 50 shows the change from the existing condition in the 

modeled results (existing conditions are shown in table 46 for alternative 2 and also in table 75

in appendix F).

Table 50. Alternative 4 influence of cumulative watershed effects risk ratios (change from existing 

condition in parentheses)

Watershed

Model

USLE GEO ERA

7th – Field Watershed

Indian Creek Headwaters 0.37 (0.04) 0.45 (0.02) 0.63 (0.15)

West Branch Indian Creek 0.68 (<0.01) 0.36 (<0.01) 0.87 (0.17)

Indian/Mill Creek 0.25 (0.02) 0.48 (0.03) 0.37 (0.05)

Coon-Wagner 0.55 (0.03) 0.82 (0.03) 0.81 (0.11)

Upper South Fork Indian Creek 0.09 (0) 0.22 (0) 0.26 (0)

Twin Valley Creek 0.00 (0) 0.00 (0) 0.00 (0)

Little South Fork Indian Creek 0.34 (<0.01) 0.35 (0.01) 0.43 (0.07)

Cole-Clauson 0.19 (0.01) 0.55 (<0.01) 0.53 (0.02)

East Fork Indian Creek 0.15 (<0.01) 0.81 (<0.01) 0.29 (0.01)

Luther-Ikes 0.39 (<0.01) 0.75 (<0.01) 0.61 (0.01)

Indian/Doolittle Creek 0.85 (0.05) 0.74 (-0.02) 0.66 (0.06)

Perkins-Happy Camp 1.36 (0) 0.54 (0) 0.59 (0)

6th – Field Watershed

Upper Indian Creek 0.46 (0.03) 0.52 (0.01) 0.63 (0.13)

South Fork Indian Creek 0.11 (0.01) 0.30 (<0.01) 0.31 (0.02)

Lower Indian Creek 0.69 (0.02) 0.73 (-0.01) 0.61 (0.02)

5th – Field Watershed

Indian Creek 0.27 (0.01) 0.50 (<0.01) 0.52 (0.06)

Modeled pre- and post-project cumulative watershed effects at the 7th field scale are all under 

1.0, each model’s threshold of concern in those watersheds where treatments are proposed. 

Although, ERA, USLE and GEO model results are under the threshold of concern, they are 

elevated (any model’s risk ratio greater than 0.75 and less than 1.00) in several watersheds 

(Coon-Wagner, East Fork Indian Creek, Luther/Ikes, and Indian/Doolittle Creek) with proposed 

treatments (table 50). Alternative 4 may cause a peak flow increase of 0-2 percent, which would 

cause the cumulative peak flow increases to range from 0-10 percent. The peak flow increase 

may be detectable in smaller subwatersheds where treatments would occur, but not in the greater 

7th field watersheds. Annual water yields would remain unaltered, although low flows could have 

a short-term increase. 
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Conclusion

Alternative 4, Minimized Underburning, would not change aquatic habitat conditions because 

only minor impacts to water quality are expected. All potential negative effects would be short in 

duration (1-10 years) and would occur at the site or reach scales. The negative effects would not 

measurably affect stream temperature at the site and reach scale, or sedimentation, and channel 

geomorphology at the site scale. All are not measurable at the 7th field watershed scale, or 

greater.

Beneficial uses of water would continue to be supported in their current state under this 

alternative. The current state is considered to be impaired under the 303(d) list for temperature, 

nutrients, dissolved oxygen, and sediment. Alternative 4 would help accelerate the delisting of 

Indian Creek for sediment due to the reduction in road sediment sources from decommissioning.

Achievement of Forest Plan desired conditions within the stream course RRs would be 

accelerated (when compared to taking no action), especially in densely stocked stands with offsite pine. While a reduction in road density would be realized across the Indian Creek 5th field 

watershed as a whole, three of the six 7th field watersheds with watershed concerns would have a 

net increase in road density within stream course RRs due to alternative 4. Newly constructed 

and reconstructed temporary roads would be hydrologically restored following use causing 

short-term adverse effects to diminish over time. 

Aquatic Conservation Strategy Objectives are described in detail in appendix D. Appendix D 

includes a summary of how alternative 4 addresses these objectives and compares this to 

implementation of the action alternatives. 

Summary

The Indian Creek watershed has high concentrations of dormant and active landslide terrain with 

a dense road network, and a long history of mining and forest management. The residual effects 

of these past actions, in combination with the effects of past flood events, have led to a 

watershed whose sedimentation, stream temperature and channel geomorphology are not 

currently meeting desired conditions. Fire suppression has also created dense conditions in 

unmanaged stands, reducing diversity and increasing the risk for moderate to high severity 

wildfire. 

Alternative 1, No Action, would not actively maintain or restore sedimentation, stream 

temperature or channel geomorphology. The no action alternative would passively maintain 

areas that are currently functioning within desired reference conditions and passively restore 

areas that are naturally recovering from past disturbances. 

Alternatives 2, 3 and 4 would all result in short-term negative effects to stream temperature 

at the site and reach scale, and sedimentation, and channel geomorphology at the site scale only, 

and would not be measurable at the watershed scale. Adverse effects on stream temperature 

would only occur in treated plantations due to the removal of canopies in dense RRs in an effort 
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to improve tree growth and vigor and to promote future recruitment of large woody debris. All 

three alternatives would add very little to cumulative watershed effects within Indian Creek.

Except for road stream crossing decommissioning, the effects on sedimentation and channel 

geomorphology would only be realized from either intense thunderstorms or above-average 

rainfall events (greater than one inch per hour, or a ten year event) which would overwhelm soil 

infiltration capacities, resulting in overland flow and sediment transport. If such a storm event 

did not occur within the first few years following treatment, regrowth of vegetation would 

eliminate the risk of sediment transport to stream courses. 

The long-term and short-term beneficial effects from implementing alternatives 2, 3 and 

4 on sedimentation, stream temperature and channel geomorphology would outweigh all of the 

effects listed above. These beneficial effects include:

Increased fire resilience of stream course RRs, reducing the risk of moderate- to highseverity wildfire causing negative effects to water quality.

Plantation (and selected natural stand) stream course RRs moving towards desired 

conditions (future LWD recruitment, diverse understory, more stream shade, etc.).

The removal of nine stream crossing culverts and fills (two perennial and seven 

intermittent), reducing the risk of catastrophic failures causing significant effects to 

water quality and aquatic habitat.

Decommissioning 4.1 miles of chronic sediment producing system roads.

Rehabilitation of re-used existing temporary roads and landings that may currently be 

contributing to sedimentation.

All action alternatives would meet clean water act (CWA) standards, Basin Plan and aquatic 

conservation strategy (ACS) standards and guidelines (appendix D) since there would be no 

measurable change to water quality or aquatic habitat at the watershed scale.

3.7 Geology

3.7.1 Methodology

Landslide potential, volume of landslide sediment produced, and hazards of naturally occurring 

asbestos were the key factors considered. Short-term effects were considered zero to five years, 

during which site conditions would be expected to recover from the proposed thinning and 

underburn activities. Long term effects were considered those greater than five years. The effects 

of high-severity wildfire would likely last up to 50 years. Even though proposed temporary roads 

and re-opened existing temporary roads would be hydrologically restored following use, for 

purposes of this analysis these roads were considered to be permanent fixtures, and would never 

fully recover because of the changes they create in mass balance (cuts and fills), and slope 

hydrology which are associated with roads in steep ground of the Klamath Mountains. Spatial

context is the site level, 7th field watershed level, and 5th field watershed level (figure 7).

Each alternative was evaluated according to: (a) its potential direct, indirect, and cumulative 

effects, (b) the environmental indicators, and (c) how well it would meet the Forest Service’s 
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geologic program goals for the Klamath National Forest. Direct, indirect, and cumulative effects 

were assessed through field and air photo assessments and GIS analyses using bedrock and 

geomorphology coverages. Aerial photos were used to identify geomorphic features in units and 

along roads, to develop a history of landslides and debris flows in the project area dating back to 

1944, and to prioritize units for field visits. Units on unstable lands, as identified on the Forest 

geomorphology coverage or on air photos, were selected for field review. Klamath National 

Forest Sufficiency Standards for geologic investigations (USDA Forest Service 2003) were 

applied.

The geological cumulative watershed effects (GEO) model was used to estimate the potential 

volume of landslide sediment (in cubic yards) which would likely be delivered to the stream 

system under the variety of road, timber harvest, and fire conditions inherent in each alternative. 

Landslide production coefficients for this model were developed in the Salmon River basin, 

about 50 miles southeast of the project area. The GEO model also estimated a risk ratio that was 

used as an indicator of the potential for adverse cumulative watershed effects. The risk ratio was 

determined by comparing post project sediment production to that which would occur under 

background conditions in which there would be no roads, harvest, or fire. The relative change in 

sediment production (percent over background) was computed as the percentage change of post 

project sediment production compared to background sediment production. 

When the modeled percent over background quantity approaches 200 percent, it is assumed 

that the risk for adverse cumulative watershed effects rises rapidly, and ratio value (1.0) is 

considered a management threshold. The risk ratio is computed by dividing the threshold value 

of 200 percent by the estimated post project percent over background. This analysis followed the 

procedure described in 2004 Cumulative Watershed Effects (CWE) analysis (USDA Forest 

Service 2004a). Appendix F contains a summary of the results of all models used as part of CWE 

for this project, including the GEO model.

Areas of ultramafic bedrock were derived through GIS overlay. Road areas were computed 

assuming a road corridor (prism) width of 50 feet. For purposes of this project, temporary roads 

are assumed to have a 10- to 20-foot-wide driving surface, with an average driving surface width 

of 12 feet and a 15- to 30-foot-wide road prism width, depending on steepness of slope. The road 

prism width for purposes of the geology analysis was increased to 50 feet just to ensure all 

disturbed areas were considered; actual disturbance would be less than that modeled, but the 

results would show a relative comparison between alternatives.

The alternatives are compared using the following indicators:

Landslide potential measured by acres of activities proposed on unstable land in Riparian 

Reserves geomorphic terrains including active landslides, inner gorges, and toe zones of 

dormant landslides) or in cubic yards of landslide 

Naturally-occurring asbestos hazard measured by acres of activities proposed in ultramafic

bedrock

How alternatives meet geologic program goals as outlined in the Forest Plan (meeting 

Aquatic Conservation Strategy Objectives; maintaining water quality and quantity; 
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preventing geologic hazards to public health, safety, welfare and property; protecting 

geologic resources; and developing geologic resources in an environmentally sound manner)

For cumulative effects, GEO model outputs for cubic yards of landslide sediment based on 

proposed activities combined with existing conditions and other planned activities 

For cumulative effects, GEO model outputs for risk ratios based on proposed activities 

combined with existing conditions and other planned activities

Project activities that would have the largest effect on model outputs per unit area are 

temporary road construction, re-opening of existing temporary roads, and road 

decommissioning. However, plantation thinning would be applied on many more acres than road 

actions, and as a result, this activity would contribute considerably to model outputs (see GEO 

Model output tables for each action alternative, under proposed actions, in the “Units 4/” 

column). 

The information used in the preparation of this section, including detailed results of model 

runs, comes from detailed analysis in the Geology Report (De La Fuentes and Bell 2010) and is 

available in its entirety in the project record.

3.7.2 Affected Environment

Geologic Resources

This analysis considered potential effects to geologic resources from proposed activities. These 

resources included the following:

Groundwater - Springs are common in the project area, particularly within landslide 

deposits. Since this project consists mostly of thinning and underburning, effects on the 

groundwater resource would be expected to be negligible because transpiration by the 

thinned stand is expected to return to pre-thinned conditions within a few years, and snow 

accumulation and melt rates would not likely change since no openings would be created in 

the canopy. As a result, groundwater is not addressed further in this analysis. 

Rock and Earth Materials - A number of rock quarries exist within the project area, and 

some of them are in ultramafic rock which could contain asbestos. Rock aggregate would be 

developed for use on roads from existing sources, so asbestos hazards could be affected by 

the project. 

Caves - No known caves occur within the project area; this resource is therefore not 

analyzed further. 

Geologic Special Interest Areas - The “West Fork Waterfall and Landslide” Geologic 

Special Interest Area (SIA) lies within the project area, and is located in the West Fork of the 

Little South Fork Indian Creek. It consists of two separate features about 0.7 miles apart, and 

is labeled “Little S Fake Indian Cr Geo Areas” on the 2007 Klamath National Forest 

recreation map, where it is shown as two polygons. A third Geologic SIA, “Elk Lick Pond,” 

lies about two miles west of the project area along the South Fork of Indian Creek. It is 

identified as “Elk Lick Geological Area” on the Forest’s recreation map. No activities are 

planned in the immediate vicinity of these SIAs. As a result, these areas are not considered 

further in this analysis. 
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Geologic Hazards

Landslide and Debris Flow Hazards

Landslides can adversely affect human life and property, watershed condition, and fish habitat. 

Management activities that can increase landslide rates include: (a) roads or landings that are 

improperly located designed or maintained; (b) removal of excessive vegetation from unstable 

areas through logging or prescribed fire, and (c) disturbances to soil in unstable areas associated 

with mechanized yarding of timber. Landslide hazards in the project area are categorized as 

follows:

1. Deep, Slow-Moving Landslides (Earth flows and Slumps) - A large proportion of 

the project area is underlain by dormant landslides characterized by earthflows and 

slumps. Within these deposits, there are numerous active earthflows up to 60 acres 

in size.

2. Shallow Rapid Landslides (Debris Slides) - Several large debris slides occurred in 

the headwaters of Green Creek during the 1964 flood, on steep (more than 65 

percent) slopes. Smaller debris slides occurred in the sandy granitic soils of East 

Fork Indian Creek and are often very prone to debris slides, particularly where 

bedrock is deeply weathered and dissected. Debris slides are common in such areas 

of the Klamath National Forest. 

3. Debris Flows - Debris flows are sediment-laden flows which usually develop in 

channels, and move rapidly downstream, mobilizing bed material, and stripping 

away vegetation. They can be triggered by landslides in the headwaters during 

winter storms or by high intensity short duration summer storms even if they do not 

trigger landslides. 

Naturally Occurring Asbestos Hazards

Airborne asbestos is a human health hazard. There is a potential for asbestos fibers to be 

introduced into the air by vehicles traveling on unsurfaced roads in ultramafic areas, vehicles 

traveling on roads surfaced with ultramafic rock aggregate, rock removed from quarries in 

ultramafic rock, and yarding of timber in ultramafic areas, particularly tractor yarding. 

Ultramafic rock occurs in some portions of the project area.

Disturbance History

Past logging, road building, wildfires and managed fires have all contributed to the current 

conditions in the project area. Past logging included clear cutting and creation of plantations, 

many of which were revegetated by 1999. The majority of the road network was built by 1975 to 

support logging and other uses. Only minor fires have occurred in the project area within the past 

50 years, as described in more detail in the fuels section of this chapter.

Landslide and Storm History

Large landslide-producing storms have been documented on the Klamath National Forest. The

major events occurred in 1955, 1964, 1974, and 1997, with smaller events occurring in 1983 and 

2006 (USDA Forest Service 1998). The 1964 flood triggered many landslides, mainly 

concentrated around stream gorges. However, the largest landslide in 1964 was a major debris 
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slide on the south flank of Spees Peak, known locally as the Spees Peak Landslide. This 

landslide initiated in a tributary, and then scoured Green Creek all the way to its junction with 

Indian Creek, removing a 170-foot wide swath of vegetation along the channel. It deposited a 

large volume of sediment into Indian Creek. 

Other smaller debris slides about a mile to the northwest of Spees Peak occurred just beneath 

a forest road, with two adjacent point sources. The slides coalesced and deposited material into 

Green Creek, scouring the channel a distance downstream roughly equal to the length of the 

slide. Slides which showed up first on the 1975 photos occurred on slopes near stream gorges, 

such as in the Indian/Doolittle Creek watershed near the Doolittle Creek headwaters, but also off 

roads southwest of Slater Butte Lookout in the Luther-Ikes watershed, the latter of which were 

revegetated by 1999. Those slides that first appeared on the 1999 photos were in the East Fork 

Indian Creek watershed, and were concentrated beneath roads and in logging units. By the time 

the 1999 air photos were taken, both the Spees Peak slide and the smaller ones to the northwest 

were about 50 percent revegetated. The photos are in the project record. 

Stream channel scour from the 1964, 1974, and 1997 floods was noted throughout the 

project area. Air photos show that most of Indian Creek, West Branch, East Fork Indian Creek 

and South Fork Indian Creek and its tributaries were stripped of vegetation by debris flows 

resulting from the 1964 flood. The width of the channel alteration on main Indian Creek was 300 

feet a mile south of Granite Creek, and 1,000 feet about 0.75-miles east of Deadman Point. 

Indian Creek still showed scour in the 1975 photos from Green Creek down to its intersection 

with South and East fork. Those creek channels also showed scour one to two miles upstream 

from this intersection. The last two miles of both West Branch and Mill Creek, and the upper five 

miles of East Fork also showed scour in these photos. Scour from the 1997 flood occurred in 

tributaries into East Fork Indian Creek and along a segment of Indian Creek just above and 

below the South Fork/East Fork intersection (see the map attached to the Geology report (Two 

Bit Project Air Photo Analysis Results) which shows altered channels).

Revegetation Rates

Revegetation of previously altered channels and past logging units took about 20 years, though 

in some cases, new vegetation in channels was stripped again during later storms. Revegetation

is defined as appearing in air photos to have been covered by new growth of ground covering 

vegetation since having been stripped or logged. 

3.7.3 Environmental Consequences

Alternative 1 - No Action 

Direct/Indirect Effects

Alternative 1 would not have any direct or indirect effects because no action would be taken in 

the project area. Current conditions would continue.
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Cumulative Effects

There would be no cumulative effects associated with this alternative because there would be no 

direct or indirect effects to accumulate with the effects of other past, present, or reasonably 

foreseeable future activities. There are residual indirect effects that are the result of past timber 

harvest, road construction, and mining. Potential for adverse indirect watershed effects resulting 

from past or ongoing activities are greatest in Coon-Wagner, East Fork Indian, Luther-Ikes, and 

Indian-Doolittle 7th field watersheds, with risk ratios ranging from 0.74 to 0.81, while the 5th

field watershed (Indian Creek) has a risk ratio of 0.50 (see appendix F for the CWE model 

summary). A risk ratio of 0.50 means that under existing conditions, the watershed would be 

expected to produce landslide sediment at a rate 2.0 times the rate it would produce if it had no 

roads, harvest or fire, in response to a 10 year storm. In summary, risk ratios for all 7th field 

watersheds within the project area are below the management threshold established by the 

Forest, which is 1.0. The highest is 0.81 (East Fork Indian).

Alternative 2 - Proposed Action 

Direct/Indirect Effects

Thinning activities using ground-based and cable yarding logging systems can result in soil 

disturbance and compaction, decreased root support and decreased evapotranspiration, rerouting 

of surface runoff, potential disturbance to springs and wet areas if entered with mechanical 

equipment, and disturbance of soil underlain by ultramafic rock. Thinning would result in a 

small to negligible short term increase in landslide risk due to a reduction in root support and 

evapotranspiration. Thinning would result in a small to negligible short term increase in 

landslide risk due to a reduction in root support and evapotranspiration. Effects in thinned 

plantations would be larger than in natural stands because more trees would be removed there 

(greater than 40 percent of the basal area). This is the percent basal area reduction at which a 

measurable change may occur in the landslide potential. The cutoff of 40 percent basal area 

reduction is derived from professional judgment guided by the typical basal area removed during 

a variety of silvicultural treatments (CWE 2004). Although small, this increased potential could 

last for several years after thinning. 

Prescribed underburning can result in the removal of low vegetation and the addition of ash 

to the soil. There would be a small risk of small isolated areas (a few acres in size) burning at 

high or moderate severity. If the fire were to burn at high or moderate severity on an unstable 

area, landslide potential would be increased; however, the likelihood of this is small and in 

general, underburning would be of low intensity and would not increase landslide risk.

Further development of existing rock quarriescould increase landslide potential due to 

changes in hydrology and mass balance on a slope, but this would be avoided with application of 

project design features (Chapter 2). Development of a rock source for road aggregate would 

generate dust and might alter drainage patterns, but these potential adverse effects would also be 

minimized with application of project design features (Chapter 2). 
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Any new roads or landing construction would remove vegetation, disturb soils (including in 

ultramafic rock), alter slopes through cuts and fills, and reroute surface runoff. Landslide 

potential due to these changes could increase due to changes in mass balance associated with 

cuts, fills, and alterations to the hydrology of the hillslope. These effects are minimized by 

design features that would avoid unstable areas, minimize cut and fills and dewatering measures 

if subsurface water is encountered. There would be a slight increase in landslide potential

associated with temporary roads. Most of the proposed new temporary roads are short spurs 

scattered across the landscape, usually on gentle ground and often near ridge tops. None of the 

proposed new temporary roads cross unstable land in Riparian Reserves.

Maintenance and upgrading of existing roads would disturb the road surface and reroute 

surface runoff. The alteration of surface drainage patterns created by maintaining or upgrading 

existing roads would decrease the landslide potential where drainage problems exist and cut and 

fill stability is addressed. Reopening of existing temporary roads would remove trees and brush 

which in some cases might be up to 40 years old. This could locally increase landslide potential, 

but only in the short-term since these roads would be restored shortly after use including 

correction of any drainage problems.

Decommissioning of existing temporary roads would also involve removal of vegetation 

where they are overgrown but decommissioning would greatly reduce landslide potential by 

removing large fills at stream crossings and hydrologically stabilizing road surfaces.

Specialized treatments and meadow enhancement treatments were not result in any measurable 

effects to landslide potential.

Specialized treatments and meadow enhancement treatments would not result in any 

measurable effects to landslide potential because sensitive areas would be protected from 

mechanical soil disturbance and only minor manipulation of vegetation would occur, and 

therefore are not considered further in this analysis.

Unstable Land in Riparian Reserves

A total of 1,042 acres of thinning and underburning would occur within unstable land in Riparian 

Reserves under alternative 2. Road reopening and road decommissioning would also occur, as 

shown below:

0.03 miles of existing road reopening 

0.9 miles of road decommissioning 

80 acres of plantation thinning 

7 acres of natural stand thinning 

955 acres of underburning 

In general, thinning intensity within unstable land in Riparian Reserves would be reduced 

(see project design features in Chapter 2 and Riparian Reserve Decision Tree in Chapter 1) 

compared to areas outside of Riparian Reserves. In the long term, thinning would produce 

healthier stands and would reduce the risk of high intensity fire.
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Thinning in plantations on unstable land in Riparian Reserves would result in short-term 

increases in landslide potential but these short-term increases are considered negligible due to 

the implementation of project design features which provide for limits on the type of activities 

and equipment used in these areas, as discussed above. Effects would be primarily due to 

thinning to less than 40 percent of the basal area in some plantations. This would only occur on 

80 acres of unstable land in Riparian Reserve.

Thinning in natural stands on unstable land in Riparian Reserves would result in short-term 

increase in landslide potential as well, but these short-term increases are also considered 

negligible due to the implementation of project design features (Chapter 2). Effects would 

primarily be due to thinning to less than 40 percent of the basal area in some natural stands. This 

would only occur on about 7 acres of unstable land in Riparian Reserve.

Direct effects from roads and landings would include ground disturbance associated with 2.9 

miles of new temporary road construction (0.0 miles on unstable land in Riparian Reserve), and 

4.3 miles of existing temporary roads reopened (0.03 miles on unstable land in Riparian 

Reserve). New road/landing cuts and fills can trigger landslides. However, all new 

roads/landings avoid unstable land and steep slopes, and project design features would be 

applied so that the potential for landslides related to these roads is considered to be extremely 

low. The fact that such risks cannot be eliminated altogether is reflected in the GEO model 

outputs (table 51 and appendix F) that estimates 617 cubic yards, compared to 2,079 cubic yards 

reduced by decommissioning. The model applies Forestwide averages and assumes that all new 

roads would produce average levels of sediment. Similarly, the risk of sedimentation from the 

0.03 miles of road in unstable land in Riparian Reserve would be negligible because of 

implementation of project design features. Most of the proposed new temporary roads are short 

spurs scattered across the landscape, usually on gentle ground and usually near ridge tops, far 

from streams. Field review by a geologist prior to use or construction (project design features)

would prevent sediment production from these roads.

Road decommissioning would lower landslide potential by an estimated 2,080 cubic yards 

per decade, based on GEO model outputs for West Branch, Little South Fork and 

Indian/Doolittle 7th field watersheds (figure 7). This would be particularly noticeable in the 0.9 

miles of road decommissioned on unstable land in Riparian Reserves. 

Underburning would be of predominantly low severity and would not affect landslide 

production because all the larger vegetation would survive the fire and resource protection 

measures have been developed (project design features and BMPs in Chapter 2) to minimize 

severe fire on unstable lands.

Ultramafic Rock

Airborne naturally occurring asbestos (NOA) is a health hazard. NOA may be released into the 

air through the ground disturbing activities of ground-based and cable yarding, temporary road 

opening, and maintenance of existing roads underlain by ultramafic rock. Approximately 3,392
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acres of treatment (including road work) would occur within areas underlain by ultramafic rock 

under alternative 2 as shown below: 

35 acres of new temporary road construction and reopening of existing roads 

12 acres of road decommissioning

820 acres of tractor yarding

5 acres of cable yarding

2,420 acres of underburning 

Activities in areas underlain by ultramafic rock could introduce asbestos fibers into the air. 

However, the location of ultramafic bedrock bodies would be identified and provided to 

personnel and contractors working in the project area. All applicable state and agency regulations 

regarding NOA would be adhered to for this project (project design features in Chapter 2). 

Therefore, risk would be minimized. 

Geologic Program Goals

Alternative 2 would have a high to moderately high probability of meeting all applicable 

geologic program goals. Those activities with the greatest potential for effects are tractor 

yarding, temporary road construction, road reopening and rock pit development. Because of the 

analysis presented above and the fact that detailed project design features have been developed 

to minimize the potential for adverse impacts to geologic resources, these effects are minimized. 

Cumulative Effects

For this analysis, all planned projects are analyzed as being completed, and there are no other 

present or reasonably foreseeable actions considered. The GEO model outputs predict small 

increases in landslide production (19 to 125 cubic yards per decade) associated with temporary 

roads in all 7th field watersheds except for Upper South Fork Indian, Twin Valley, Luther-Ikes, 

and Perkins-Happy Camp (appendix F). Based on the effects described in the discussion of direct 

and indirect effects, none of the proposed roads are expected to cause landslides or produce 

sediment, with application of project design features. However, the model deals with basin 

averages, and assumes that all roads will produce landslides and sediment, and does not address 

the mitigating effects of all project design features. As a result, these 19 to 125 cubic yards 

would be attributable to the specific components of alternative 2 (roads).

The GEO model outputs also predict small increases in landslide production associated with 

plantation thinning ranging from 81 to 806 cubic yards per decade in all watersheds except for 

Upper South Fork Indian, Twin Valley, and Perkins-Happy Camp. The largest increase is in 

Indian Creek headwaters (806 cubic yards). 

In addition, the GEO model outputs also predict reductions in landslide production per 

decade as a result of road decommissioning proposed under alternative 2 in West Branch (473 

cubic yards less), Little South Fork (207 cubic yards less) and Indian/Doolittle (1,400 cubic 

yards less) 7th field watersheds (appendix F).
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Risk ratios account for the offsetting of these alternative 2 effects described above. Four 

seventh field watersheds (Indian Creek Headwaters, Indian/Mill, Coon/Wagner, Little South 

Fork Indian) show small increases in risk ratio, ranging from increases of 0.01 to 0.03 and one 

watershed shows a small reduction of 0.02 in the risk ratio (Indian-Doolittle). At the 6th field 

scale, there is an increase in risk ratio from current conditions to that after alternative 2 is 

implemented (0.01 in Upper Indian). At the 5th field scale, there is no change in the risk ratio. 

These positive and negative changes associated with the project are extremely small in 

comparison to the effects of past activities (roads and timber harvest).

Therefore, the alternative would result in negligible to minor landslide production that would 

accumulate with the landslide production of past, other present or reasonably foreseeable future 

actions. 

Alternative 3 - No New Temporary Roads

Direct/Indirect Effects

The general effects described for alternative 2 above associated with thinning activities, thinning 

activities in Riparian Reserves, prescribed underburning and rock quarry development are the 

same as those for alternative 2 since all of these actions are also proposed for alternative 3. There 

is a small reduction (270 acres) in the overall amount of thinning proposed for alternative 3 

compared to alternative 2 and therefore reduces the amount of this disturbance across the project 

area. 

Because no new temporary roads would be created under alternative 3, there would no 

associated vegetation removal, soil disturbance, slope alteration or surface runoff increases due 

to temporary road construction. However, maintenance and upgrading of existing roads would 

still occur and would disturb the road surface and reroute surface runoff. The alteration of 

surface drainage patterns created by maintaining or upgrading existing roads and landings would 

decrease the landslide potential where drainage problems exist and cut and fill stability is 

addressed. Reopening (temporarily) existing Forest System roads would remove trees and brush 

that in some cases might be up to 40 years old. This could locally increase landslide potential, 

but only in the short-term since these roads would be restored shortly after use, including 

correction of any drainage problems. Decommissioning of existing temporary roads would also 

involve removal of vegetation where they are overgrown, but decommissioning would greatly 

reduce landslide potential by removing large fills at stream crossings and hydrologicallystabilizing road surfaces.

Specialized treatments and meadow enhancement treatments would not result in any 

measurable effects to landslide potential because sensitive areas would be protected from 

mechanical soil disturbance and only minor manipulation of vegetation would occur. Therefore 

these activities are not considered further in this analysis.
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Unstable Land in Riparian Reserves

Actions proposed under alternative 3 in unstable land are essentially the same as for alternative 

2, except one less acre of natural stand thinning would occur on unstable land in Riparian 

Reserves. Road work and approximately 1,041 acres of thinning and burning would occur within 

unstable land in Riparian Reserves under alternative 3: 

0.03 miles of existing road reopening 

0.9 miles of road decommissioning 

80 acres of plantation thinning 

6 acres of natural stand thinning 

955 acres of underburning 

Because treatments in unstable land are essentially the same as proposed for alternative 2, 

the effects to landslide potential and sediment production are the same as those previously 

described for alternative 2; negligible short-term increases in landslide potential and sediment 

production, minimized through implementation of project design features.

Ultramafic Rock

As described for alternative 2 naturally occurring asbestos is a health hazard. Approximately 15

fewer treatment acres would occur in ultramafic rock areas under alternative 3 than alternative 2 

since fewer existing roads would be reopened in these areas. A total of 3,277 acres would be 

treated as shown below:

20 acres of reopening of existing roads 

12 acres of road decommissioning

820 acres of tractor yarding

5 acres of cable yarding

2,420 acres of underburning 

Activities in areas underlain by ultramafic rock could introduce asbestos fibers into the air. 

However, the location of ultramafic bedrock bodies would be identified and provided to 

personnel and contractors working in the project area. All applicable state and agency regulations 

regarding NOA would be adhered to for this project (project design features in Chapter 2). 

Therefore, risk would be minimized. 

Geologic Program Goals

Alternative 3 would have a high to moderately high probability of meeting all applicable 

geologic program goals. Those activities with the greatest potential for effects are tractor 

yarding, road reopening and rock pit development. Because of the analysis presented above and 

the fact that detailed project design features have been developed to minimize the potential for 

adverse impacts to geologic resources, these effects are minimized. The likelihood of meeting all 

applicable geologic program goals for alternative 3 are slightly greater than for alternative 2 

because no temporary roads would be constructed and fewer acres would be thinned.
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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Cumulative Effects

The GEO model outputs predict small increases in landslide production (2-71 cubic 

yards/decade) associated with reopening of existing temporary roads in all 7th field watersheds 

except for Upper South Fork Indian, Twin Valley, Luther-Ikes, and Perkins-Happy Camp. Since 

no new temporary roads would be built, the GEO model predicts lower sediment production than 

quantities shown in alternative 2, as follows: Indian Creek Headwaters (reduction of 54 cubic 

yards per decade), West Branch Indian (reduction of 62 cubic yards per decade), Indian/ Mill 

(reduction of 31 cubic yards per decade), Coon-Wagner (reduction of 96 cubic yards per decade), 

Little South Fork Indian (reduction of 17 cubic yards per decade), Cole Clauson (no measurable 

change), East Fork Indian (no measurable change), Indian-Doolittle (reduction of 25 cubic yards 

per decade).

In summary, opening of temporary roads in alternative 3 would add 331 cubic yards of 

sediment per decade (no new construction of temporary roads), whereas alternative 2 would add 

616 cubic yards for opening existing and building new temporary roads.

Risk ratios account for the offsetting of these alternative 3 effects described above. Based on 

GEO modeling, four 7th field watersheds (Indian Creek Headwaters, Indian/Mill, Coon/Wagner, 

Little South Fork Indian, (figure 7) would show small increases in risk ratio, ranging from 0.01 

to 0.03, and one watershed (Indian-Doolittle) would show a small reduction of 0.02. These 

results are nearly identical to alternative 2; the only difference is in the Indian-Mill 7th field 

watershed, where the risk ratio in alternative 3 is 0.01 lower than in alternative 2 (appendix F). 

As with alternative 2, the positive and negative changes associated with proposed activities 

are extremely small in comparison to the effects of past activities (roads and timber harvest).

Therefore, this alternative would not result in more than minor landslide production that 

would accumulate with the landslide production of past, other present or reasonably foreseeable 

future actions.

Alternative 4 - Minimized Underburning

Direct/Indirect Effects

Potential direct effects are very similar to alternative 2, except that underburning would be 

reduced considerably, and mastication would be added. The amount and location of thinning, 

new temporary roads, reopening of existing roads, decommissioned roads, and the area of 

ultramafic rock disturbed by temporary roads, tractor units, cable units, and decommissioned 

roads would be identical to alternative 2. 

Specialized treatments and meadow enhancement treatments were not result in any 

measurable effects to landslide potential because sensitive areas would be protected from 

mechanical soil disturbance and only minor manipulation of vegetation would occur. Therefore, 

these actions are not considered further in this analysis.
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

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Unstable Land in Riparian Reserves

Approximately 810 fewer acres of underburning would occur in unstable land for alternative 4

when compared to alternative 2. A total of 270 acres of treatments and road work would occur in 

unstable land, as shown below:

0.03 miles of existing road reopening 

0.9 miles of road decommissioning 

80 acres of plantation thinning 

7 acres of natural stand thinning 

145 acres of underburning 

38 acres of mastication (within thinned stands)

Potential direct/indirect effects would be the same as alternative 2. Root support of large 

vegetation would not be reduced by mastication; therefore, landslide potential would not be 

measurably affected due to mastication and application of project design features (Chapter 2)

would also contribute to minimizing effects. Underburning is greatly reduced compared to 

alternatives 2 and 3 and therefore, the potential for small areas of high intensity burning are 

greatly reduced which decreases the risk of landslide potential.

Ultramafic Rock

Airborne NOA is a health hazard. Fewer treatment acres would occur in ultramafic rock under 

alternative 4 than alternative 2 due to the reduction in the level of underburning. Approximately 

2,190 acres of treatment would occur within areas underlain by ultramafic rock under alternative 

4: 

35 acres of new temporary road construction and reopening of existing roads 

12 acres of road decommissioning

820 acres of tractor yarding

5 acres of cable yarding

508 acres of underburning 

810 acres of mastication (within thinned stands)

Potential direct/indirect effects would be the same as alternative 2. Underburning is greatly 

reduced compared to alternatives 2 and 3 and therefore, the potential for small areas of high 

intensity burning are greatly reduced which decreases the risk of adverse effects associated with 

ultramafic rock. Activities in areas underlain by ultramafic rock could introduce asbestos fibers 

into the air. However, the location of ultramafic bedrock bodies would be identified and provided 

to personnel and contractors working in the project area. All applicable state and agency 

regulations regarding NOA would be adhered to for this project (project design features in 

Chapter 2). Therefore, risk would be minimized. 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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Geologic Program Goals

Alternative 4 would have a moderately high to high probability of meeting all applicable 

geologic program goals. Those activities with the greatest potential for effects are tractor 

yarding, road reopening, rock pit development and mastication. Because of the analysis 

presented above and the fact that detailed project design features have been developed to 

minimize the potential for adverse impacts to geologic resources, these effects are minimized. 

The likelihood of meeting all applicable geologic program goals for alternative 4 is the same as 

for alternative 2. 

Cumulative Effects

For purposes of modeling, underburning and mastication do not have the potential to increase 

landslide potential because underburning is low severity and larger vegetation survives the fire. 

Mastication affects only the understory and downed woody material; mechanized equipment is 

restricted to gentler ground away from unstable lands, as shown in project design features

(Chapter 2). Because of this assumption, there are no differences in the GEO model outputs for 

landslide potential or risk ratios; all other proposed activities are the same as that proposed for 

alternative 2. Alternative 4 would not result in more than minor landslide production that would 

accumulate with the landslide production of past, other present or reasonably foreseeable future 

actions. 

Summary

Table 51. Summary of how alternatives address geologic measurement indicators

Indicator

Alternative 

1 – No 

Action

Alternative 2 –

Proposed Action

Alternative 3 –

No New 

Temporary 

Roads

Alternative 4 –

Minimized 

Underburning

Proposed 

treatment in 

unstable land in 

Riparian Reserves

None

1,042 acres plus 0.03 

miles of reopened road 

and 0.9 miles of 

decommissioned road

1,041 acres plus 

0.03 miles of 

reopened road 

and 0.9 miles of 

decommissioned

road

270 acres plus 

0.03 miles of 

reopened road 

and 0.9 miles of 

decommissioned

road

Proposed 

treatment acres in 

ultramafic bedrock 

areas

None 3,292 total acres 3,277 total acres 2,190 total acres

How alternatives 

meet Forest Plan

Geologic Program 

Goals

Not

Applicable

Moderately high to high 

probability of meeting 

goals

Moderately high to 

high probability of 

meeting goals

Moderately high to 

high probability of 

meeting goals

Cumulative 

Effects: GEO 

model outputs 

(cubic yards of 

sediment, see 

appendix F)

Not 

Applicable

19-125 cubic yards per 

decade due to temporary 

roads in some (not all) 

7th field watersheds: 

81-806 cubic yards per 

decade in 7th field 

2-71 cubic yards 

per decade in 7th 

field watersheds 

due to reopening 

of existing 

temporary roads in 

some (not all) 7th 

Same as 

Alternative 2 

because changes 

in mastication and

underburning 

would not change 

sediment 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

167

Indicator

Alternative 

1 – No 

Action

Alternative 2 –

Proposed Action

Alternative 3 –

No New 

Temporary 

Roads

Alternative 4 –

Minimized 

Underburning

watersheds due to 

plantation thinning in 

some (not all) 7th field 

watersheds; reduced in 

those watersheds that 

include road 

decommissioning

field watersheds production

Cumulative 

Effects: GEO 

model outputs for 

risk ratios (see 

appendix F)

Not 

Applicable

Small changes only at 

the 7th field watershed 

level of 0.01 to 0.03 in 

some (not all) 

watersheds. No change 

in risk ratios at the 5th 

field watershed scale. 

All risk ratios below 

established threshold of 

1.0

Small changes 

only at the 7th 

field watershed 

level: increase of 

0.01 to 0.03 in two 

watersheds and a 

decrease of 0.02 

in another. No 

change in risk 

ratios at the 5th 

field watershed 

scale.

All risk ratios 

below established 

threshold of 1.0

Same as 

Alternative 2

All risk ratios 

below established 

threshold of 1.0

3.8 Soils

3.8.1 Methodology

This soils analysis focuses on how well the proposed alternatives maintain long-term soil 

productivity as defined in the Forest Plan; typically measured by soil cover. The amount, kind 

and distribution of soil cover necessary to avoid detrimental accelerated soil erosion is guided by 

the Region 5 Erosion Hazard Rating system (USDA Forest Service 1990) and locally adopted 

standard erosion models and measurements, such as those described in the following papers: Soil 

Cover Process Paper (Laurent 2000) and Soil Erosion Processes and the USLE (Laurent 2006a).

The Forest Plan (USDA Forest Service1995) Standards and Guidelines are used on the Forest for 

protecting soil productivity and minimizing soil erosion. 

Proposed harvest and fuel treatment units were surveyed in October 2008 and May 2009.

Units were surveyed using a modified version of Region 1 soil quality monitoring protocol 

(Shovic et al. 2007) to determine existing detrimental disturbance percentage. Additional plots 

were established and measurements were taken for aerial extent of ground cover , number of 

large logs (greater than 20 inches diameter and 10 feet long), and coarse woody debris using a 

modified Brown’s line intercept method (Brown 1974). 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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It was assumed that main skid trails would disturb 10 percent of each unit treated. Past 

timber harvest monitoring on the Klamath National Forest showed that 69 percent of skid trails 

used were old skid trails (Laurent 2009). Therefore, it was assumed that 69 percent of the 10

percent (or 7% of each unit) would occur on pre-existing skid trials. The remaining 3 percent

was assumed to new detrimental disturbance; this was then added to the existing level of 

detrimental soil disturbance for each unit to calculate estimated detrimental soil disturbance.

It was also assumed that 5 percent additional disturbance would occur from cable logging 

corridors in cable logged units. The spatial area in yarding corridors has been measured as 

varying between 3 and 8 percent, depending upon the size of trees (Dyrness 1965; Wooldridge 

1960; Klock 1975).

Literature reviews, field notes, geographic information system (GIS) data, and professional 

judgment were used to support conclusions. Sediment movement was modeled using the USLE 

values calculated for similar soils on the Klamath National Forest. Soil erosion hazard ratings 

were calculated for the project area based upon soil mapping units (USDA Forest Service1990).

The alternatives are compared using the following indicators:

Soil erosion potential

Detrimental soil disturbance 

How alternatives meet soil standards and guidelines as outlined in the Forest Plan

(maintain soil productivity; minimize changes in the site’s ability to cycle nutrients; 

retain course woody debris; minimize soil and litter disturbance; minimize consumption 

of litter and course woody debris during prescribed burning; and maintain the 

functionality of the soil ecosystem) 

Effects to soil productivity are primarily through soil disturbance, redistribution of organic 

matter and changes in biological properties. Soil displacement, compaction, reduction and/or 

elimination of soil organisms can occur through tractor yarding and use of heavy equipment. Soil 

chemistry changes can result from high intensity wildfires. Increased surface erosion, reduced 

fertility and reduced vegetative growth are the most common indirect effects from mechanized 

disturbance and fire.

The information used in the preparation of this section comes from detailed analysis in the 

Soil Report (Walters 2010) and is available in its entirety in the project record.

3.8.2 Affected Environment

Soils in the project area are predominately metamorphic with some serpentine properties. The 

landscape is geologically active and prone to landslides. The area is dominated by both active 

and dormant landslide activity, steep slopes, and well incised main stream channels capable of 

sediment transportation. Soils range from a medium to high erosion hazard rating based upon 

Regional soil hazard mapping (USDA Forest Service 1990). 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

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Soil Erosion 

Soil erosion in undisturbed soils is mostly a result of chemical erosion from rainwater leaching 

through the soil. Natural disturbances such as tree windthrow create tip-up mounds when root 

wads pull up soil and expose the bare mineral component. This increases erosion. Another 

natural disturbance is landslides and/or debris torrents which cause erosion.

Surface erosion equal to the thickness of a single sheet of paper (0.004 inches) is equivalent 

to 0.63 tons/acre (1,260 pounds) of erosion. This is a low level of erosion and very difficult to 

observe. Average soil formation from bedrock as reported by Alexander (1988) is about 1.0 

ton/acre/year. Sheet erosion equal to 2 sheets of paper in thickness, exceeds this reported soil 

formation rate, yet this is for the most part unobservable erosion. Most natural erosion on the 

Klamath National Forest is sheet erosion, which consists of raindrop splash displacement of soil 

particles and subsequent down slope deposition of this dislodged material. The average 

calculated soil erosion rates for existing conditions in the project area are 0.029-1.334 tons/acre 

and averages 0.1889 tons/acre. There were very few signs of active soil erosion in the units 

surveyed. There were some inclusions of units that had small soil creeps and landslides. There 

were also some areas with bare soil from road cutbanks that were actively eroding. It is 

postulated that during plantation establishment, much of the loose soil eroded when it was 

exposed postharvest.

Soil erosion hazard ratings were calculated for the project area based upon soil mapping 

units (USDA Forest Service 1990). These ratings were then cross referenced against units in the 

current project area. Forty-five of the 142 proposed treatment units were rated with a high soil 

erosion hazard. The remaining 97 have a moderate soil erosion hazard rating. Soils are generally 

deep with only eight units mapped at 20-60 inches, the remainder all being from 40 to 60 inches

or greater.

Effective Soil Cover 

With the exception of a few units that show signs of past mining activities or recent fires, soil 

cover was very good overall for the project area. Post project soil cover objectives range from 

60-80 percent depending upon slope with at least 50 percent of the area covered by fine organics.

The current conditions are such that only 10 of the surveyed units have less than 90 percent soil 

cover. One of the reasons there is little signs of erosion is because the soil is being held in place 

by the widespread effective soil cover.

Fine Organic Matter 

The vast majority of the soil cover mentioned above is fine organic material in the form of litter 

and duff. Fine organic material includes plant litter, duff, and fine wood less than 3 inches in 

diameter. Of the effective soil cover, approximately 5-8 percent is basal vegetation, 2-5 percent

rock cover, 2-3 percent coarse woody debris, and the rest is all fine organic matter. This is 

indicative of soils which have a high capacity for nutrient cycling. This does not however mean 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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that the soils are generally productive and cycling nutrients for tree growth. It is likely that the 

majority of the nutrients from the last 40 years of accumulation since plantation establishment 

are locked up in the biomass of the fine organic matter and not readily available for plants. Some 

of the organic matter as well as associated nutrients are beginning to decompose and accumulate 

in the mineral portion of the soil as humus. This humus accumulation is limited to the top 1-2 

inches of topsoil and is variable across the landscape. This is indicative of a system that is in a 

recovery stage from plantation establishment and associated widespread disturbance.

Downed Large Logs 

Downed woody material in the form of large logs (greater than 20 inches diameter, 10 feet long) 

has several beneficial soil attributes including, but not limited to, moisture retention, nutrient 

cycling, long-term soil formation, and sites for soil micro-organisms (Graham et al. 1994). There

were very few large logs, with only five units meeting the regional standard of five logs per acre.

Eighty-eight of the surveyed units had no measurable large logs. The beneficial soil attributes 

listed above are therefore not being realized.

Detrimental Soil Disturbance 

Currently, the level of estimated detrimental disturbance from past activities (primarily landings, 

skid trails, and temporary roads) ranges from 0 to 25 percent and averages 7 percent across all 

proposed thinning and specialized treatment units (table 52). Fifteen percent detrimental soil 

disturbance is the acceptable threshold; detrimental soil disturbance below 15 percent is desired, 

based on Regional and Forest standards.

One of the main indices used to determine detrimental soil disturbance is soil compaction.

Excessive soil compaction can alter key soil functions negatively such as: soil porosity, soil 

nutrient cycling capacity, and soil hydrology. Excessive compaction can also lead to increased 

runoff, which in turn will cause erosion of stream channel banks through increased flow into 

stream systems.

The findings for detrimental soil disturbance in the project area were relatively low in 

relation to the amount of widespread disturbance from past plantation development. In relation to 

the plantation stands, it was difficult to determine detrimental disturbance and the reported 

percentages are likely in relation to other stands in the project area, not natural baseline 

conditions for the area. In all likelihood, the majority of the plantation stands have some form of 

detrimental disturbance. However, in identifying the worst percentages of each stand, it allows 

land managers to not negatively alter the recovery path that plantation stands are on. While 7 

percent was the average across proposed treatment areas, there were 23 stands that had a 

detrimental disturbance level greater than 12 percent. These are discussed in project design 

features at the end of Chapter 2.

Soil productivity is very low in the majority of the plantations. At the highest elevations, the 

project area receives an average of 62 inches of rain a year. Tree growth in the majority of the 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

171

plantation stands is well below what it should be for this amount of precipitation, all other things 

being equal. Past removal of the productive topsoil along with associated exposure of less 

productive lower soil layers, increased compaction, and historic removal of fine organic material 

and large logs are presumed to have all created unproductive soils that are on their way to 

recovery.

Table 52 shows existing conditions in the proposed treatment areas surveyed.

Table 52. Existing soil conditions in proposed treatment areas

Total Treatment (Thinning and Specialized Treatment) Acres 2,120

Average Ground Cover 96 percent

Average Logs/Acre 1

Average Detrimental Disturbance 7 percent

Total Acres Detrimental Disturbance 158

3.8.3 Environmental Consequences

Alternative 1- No Action 

Direct, Indirect and Cumulative Effects

Under the no action alternative, no management activities would take place and therefore there 

would be no new soil disturbance. Existing conditions are described above. Without any 

management, a gradual recovery of existing disturbed areas would naturally occur over time and 

large logs and ground cover would increase over time. Nutrient cycling would be maintained as 

fine organic matter increased in the duff/litter layers. Soil fertility would be maintained in 

managed stands due to the increased organic matter on the soil surface and in the soil.

Compacted soils (reduced porosity) in existing main skid trails would slowly increase their 

porosity due to biological activities and thereby regain lost soil productivity over the next 40-50 

years. Existing old temporary roads would remain as they currently are.

Cumulative effects to soils are based upon the number and types of management activities 

occurring within an individual stand (or unit) over time and are measured by effects on soil 

productivity. Table 52 displays the existing detrimental disturbance data which represents current 

cumulative disturbances from past activities. Existing detrimental disturbance averages 7.4

percent. Currently 157 of 2,120 thinning acres within the project are detrimentally disturbed.

This percentage is below the acceptable threshold of 15 percent, indicating that the criteria for 

maintaining surface organic matter in amounts sufficient to prevent short-and long-term nutrient 

cycling deficits and detrimental physical and biological conditions would be met with 

implementation of alternative 1. With no new disturbances, existing detrimental disturbances 

from past activities would slowly recover. Existing erosion processes would continue and soil 

biological functions and nutrient cycling would continue.
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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Overall, alternative 1 has a high probability of meeting the Forest Plan standards and 

guidelines for maintaining long-term soil productivity. However, taking no action to address the 

purpose and need would continue to contribute to the likelihood of high severity wildfire across 

the project area. The effects of wildfire on the soil resource are primarily dependent on 

conditions of the fuels, stand conditions, past fuel reduction actions, time of year, aspect and 

elevation. Klamath Forest soil burn severity data from 1977-2007 indicates that high burn 

severity ranged from 1-24 percent and averaged 9 percent. Moderate soil burn severity ranged 

from 6-53 percent and averaged 19 percent. Low soil burn severity ranged from 24-94 percent

and averaged 69 percent. The 2008 soil burn severities showed that high burn severity ranged 

from 2-6 percent and averaged 4 percent. The moderate soil burn severity ranged from 11-24

percent and averaged 19 percent. The low soil burn severity ranged from 71-84 percent and 

averaged 76 percent (Laurent 2009).

A wildfire burning across the project area under current fuel and vegetation conditions would 

likely be similar to the 2008 soil burn severity data. It would therefore have about 70 percent low 

soil burn severity which roughly translates into the range of ground cover recommended for post 

prescribed burning activity. High and moderate soil burn severities have similar effects on 

nutrient cycling, changes in soil microbial communities but different amounts of soil erosion.

The high burn severity has minimal post burn cover; mainly as surface gravels but moderate 

burn severity has more cover due to needle cast that falls to the ground within a few days after 

the fire. Cover can range up to 90 percent and has been averaged at 35 percent for erosion 

calculations. The erosion rate for moderate burn severity is much lower compared to high 

severity due to increased soil cover. Low soil burn severity has more cover due to a heavier than 

normal needle cast, which is generally higher than that under a moderate burn severity.

Alternative 2 – Proposed Action 

Direct/Indirect Effects

Direct effects to soils result from disturbance and include redistribution of organic matter and 

changes in biological and physical properties. The soil properties that are affected are soil 

volume, soil porosity, soil water availability, soil chemistry and soil biology (Powers 1989).

Indirect effects are secondary reactions to direct effects. The most common secondary reactions 

are increased surface erosion (from ground disturbance, soil cover removal), reduction in fertility 

(compaction, removal of fine organic materials), and reduced vegetative growth (compaction, 

loss of fine organic materials).

Ground-Based Harvesting

Ground-based harvesting would occur on approximately 1,866 acres and includes conventional 

log skidders, mechanical harvester operations and tractor endline operations. Of these, the tractor 

endline operations have the least impact and are generally used in steeper sections of units. 

These operations are all treated the same because one of the primary effects from them is 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

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development and placement of skid trails. Ground-based harvesting would result in increased 

soil disturbance and reduced porosity. However, with proper layout of the skid trail pattern and 

reusing existing skid trails when appropriate (see project design features in Chapter 2), 

detrimental disturbance would be kept within allowable limits (15% of each unit). Some 

compaction would occur in areas outside of main skid trails where machinery makes one or two 

passes but this increased compaction would not exceed threshold values as documented by 

Powers et al. (2002) and Laurent (2006b). A recent study near the project area (Laurent et al.

2002) examined tractor yarding followed by tractor piling. This study concluded that tractor 

harvesting and mechanical slash disposal had no marked detrimental effect on the soil chemical 

properties. Relative to the other slash treatments, tractor piling seemed to result in low levels of 

nutrients and other soil properties important to nutrition—even if total levels were increased.

There is a possibility that the amount of post logging detrimental disturbance (reduction in 

soil porosity) could be greater than 15 percent of the area in units with existing detrimental 

disturbance greater than 12 percent (23 units). Main skid trails in these 23 units would be 

evaluated before the project using detailed transects as well as field compaction data to 

determine their need for subsoiling (project design features in Chapter 2). Subsoiling has been 

shown to be an effective method of reducing compaction and restoring porosity to the soil 

(Andrus and Froehlich 1983; Atzet et al. 1989). 

Soil displacement and skid trail erosion from ground-based harvesting would result in some 

nutrient loss. Soil erosion on skid trails can vary from 1.1-4.1 tons/acre depending on soil cover, 

slope, and soil texture. This is equivalent to 26-98 pounds of soil erosion per 100 feet of skid 

trail. Loss of soil through erosion reduces growth of trees and other vegetation on skid trails after 

the harvest. Implementation of project design features such as installation of water bars on skid 

trails and application of slash would be very effective in controlling runoff and preventing offsite sedimentation and accelerating site recovery. The high amount of soil cover acts as sediment 

filters and prevents skid trail-derived sediment from reaching drainage channels.

Cable Harvesting

Cable harvesting would occur on approximately 167 acres and would cause small amounts of 

soil displacement from dragging logs in yarding corridors. The cable corridor can vary in width 

from 6 to 8 feet with an area in the center that is down cut 9-12 inches from log dragging. There 

would be a loss of nutrients and soil organic matter in the heavily disturbed portions of the 

corridor due to erosion. The amount of reduced soil productivity would be measurable within 

these heavily disturbed portions. However, the amount of area with reduced soil productivity 

would be within the regional and forest guidelines of a cumulative 15 percent.

Hand Work/Thinning

Hand thinning and piling slash would occur on approximately 87 acres. This activity would 

maintain sufficient fine soil cover and would not cause additional ground disturbance. Associated 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

174

burning of this piled material would meet the required soil coverage amounts. Recent data 

(Laurent 2007) collected on the Klamath National Forest shows that hand piles occupy from 4 to 

25 percent of the total hand piled acres. The piles, which are composed of material generally less 

than 10 inches in diameter, is not compacted and therefore most of the material is not in contact 

with the soil. Most of the radiant heat then would not be focused on the soil but dispersed into 

the air. Field observations from other projects that had burned hand piles indicated that the duff 

layer beneath the pile is consumed and the soil surface blackened. This indicates that the burn 

intensity was in the range of low (higher end of low) to moderate (lower end of moderate).

Damage to the soil occurs when the soil color changes to reddish orange (red brick color) which 

normally occurs under logs and in stump holes during wildfire or broadcast burn intensities of 

moderate and high. There would be minimal changes in soil characteristics within the burned 

pile areas (Dyrness and Youngberg 1957). 

Plant-available soil nutrients would peak after burning and decrease to background levels 

within two years as nutrients become locked up in plant biomass (Choromanska and Deluca 

2002). Soil erosion would be minimal (less than 0.8 tons per acre) due to the mosaic nature of 

the burn piles and intact duff layer in the remainder of the stands. The soil biota in the burned 

pile areas would be reduced by the effects of heat but would quickly recover as litter fall adds 

fine organic matter to the soil surface and soil micro-organisms re-establish on these sites 

(Borchers and Perry 1990).

Landings

Landings are central processing zones that are essential for logging operations. Landings are 

approximately 0.33 to 0.50 acres in size, and occasionally up to 0.75 acres in size to 

accommodate slash piles from tree tops. Landings are some of the most disturbed sites from 

logging activities. They have significantly lower site productivity due to compaction and loss of 

nutrients. Trees with stunted growth would slowly establish on these sites after more early 

successional vegetation such as shrubs and grasses. Existing landings would be reused where 

possible. Landings can produce erosion and sediment if not properly designed and maintained.

Rehabilitation of non-road prism landings would minimize short- and long-term erosion. Erosion 

that moves off the landing would be filtered out by the high levels of soil cover retained in the 

areas immediately adjacent to the landings. Project design features (Chapter 2) provide for 

sufficient erosion control. Landings in the project area would be mapped and used for future 

logging operations.

Underburning

Proposed light underburning would not disturb additional soil. As long as underburning is not 

high severity and soil cover standards are met, erosion would be minimal to none according to 

recent monitoring on the Klamath National Forest (Laurent 2007). Low and moderate severity 

burns would show immediate plant availability of nutrients, spiking following the fire, but 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

175

decreasing quickly to background levels over the following two years (Choromanska and Deluca 

2002). Afterwards, those available nutrients would be locked up in plant biomass. Project design 

features (Chapter 2) would ensure soil standards for prescribed burning are met.

Meadow Enhancement 

Conifers encroaching on meadows would be hand thinned across 160 acres. There would be no 

mechanical entry. There would be no detrimental disturbances as long as ground cover standards 

are met. There would be pile burning of thinned conifers as well as some underburning. The 

effects will be the same as described above for hand thinning and underburning. 

Coarse Woody Debris

Coarse woody debris (CWD) would be partially affected by mechanical yarding. Some of the 

more decomposed logs may be disturbed by heavy equipment operations and could therefore 

lose some of their effectiveness. If prescribed fire severity increases beyond low to moderate, 

some CWD may be consumed. Sufficient number of trees would remain on site in the project 

area so that CWD would increase over time by natural falling of standing trees and snags.

Existing Road Reopening/Reconstruction 

Some existing temporary roads would be re-opened to access units with logging trucks and 

machinery. This would include blading and shaping of the road surface, installation of rolling 

dips, culvert replacement, and ditch cleaning and clearing of encroaching vegetation along the 

roadway. This work would disturb soil within the road prism but would also reduce road-related 

erosion by fixing road drainage problems such as rills and gullies and redirecting runoff to dips.

Application of project design features and best management practices (Chapter 2) would ensure 

water quality and mitigate soil erosion potential.

Temporary Road Construction 

Temporary road construction creates detrimental soil disturbance by bulldozing the surface layer 

aside and exposing nonproductive subsoil layers and substantially alters soil productivity.

Temporary roads are typically 12-14 feet wide. On flat to gentle slopes, soil disturbance would 

be minimal (0.5-2 feet) but on steeper slopes where cut and fill techniques are required, cuts 

would be 4-8 feet high. Fill material is deposited on top of the existing soil, thereby increasing 

soil depth which in turn increases soil water holding capacity. Soil organic materials are also 

incorporated into the soil. Increased water holding capacity and organic matter has a positive 

effect on site productivity. The increased soil productivity does not necessarily equal the soil 

productivity lost in the cut portion of the road.

The road surface is compacted by equipment travel during the construction process as well 

as from log truck travel on the road. Road soil compaction is a long-term effect. All constructed 

temporary roads would be hydrologically stabilized after harvest activities. This would assist in 
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site productivity recovery from temporary roads. Soil health would gradually recover over the 

long-term as trees become established in the road bed and fill slopes.

Road Decommissioning 

Road decommissioning would improve watershed health, stabilize soils and decrease soil erosion 

potential. This would increase long-term soil productivity in these areas.

Soil Erosion

Following implementation of alternative 2, post-project first-year calculated erosion rates 

(assuming that minimum recommended soil cover amounts of 60-80% are achieved) would 

range from 0.165-1.237 tons/acre and would average 0.6586 tons/acre. These rates are based 

upon Universal Soil Loss Equations calculated and field verified by the Klamath National Forest 

Soil Scientist. These calculated values are what is mobilized on site and does not represent what 

would actually reach a stream channel. The soil cover previous to prescribed fire is generally left 

in a mosaic pattern, somewhat like a checkerboard pattern. Soil that erodes from a bare area is 

immediately trapped in the first area of soil cover downslope. Any bare, actively eroding soil 

would quickly recover within two years following activities as litter accumulates and plants 

reestablish themselves.

Cumulative Effects

Cumulative effects are based on the number and types of management activities occurring within 

a unit over time and are measured by effects on soil productivity. These effects are measured by 

determining the spatial extent of detrimental disturbance within each unit.

Currently, the level of estimated detrimental disturbance from past activities (primarily 

landings, skid trails, and temporary roads) ranges from 0-25 percent and averages 7.4 percent

across all units. Skid trails from ground-based harvesting are expected to cover a maximum of 10

percent of any unit. Of this 10 percent, 7 percent is assumed to be on existing skid trails and 

taken into account by calculations of current detrimental disturbance. The other 3 percent is 

added to the detrimental disturbance total. 

Project design features (Chapter 2) including the use of subsoiling where needed would 

ensure that detrimental disturbance after harvest activities would be below the forest and 

regional 15 percent threshold. Table 53 displays the cumulative effects of alternative 2 across all 

treatment acres; detrimental soil threshold would be below 15 percent.

Table 53. Acreage of Detrimental Disturbance across the treatment units for alternative 2

Total Treated (Thinning and Specialized Treatment) Acres 2,120

Total Threshold Detrimental Disturbance Acres 318 (15%)

Total Detrimental Disturbance Acres Post Activity 236 (11%)
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The hand piling and burning and broadcast burning would have no long-term cumulative 

effects on soil erosion, nutrient availability, and soil productivity. These types of fuel treatments 

would not expose excessive amounts of soil and would have minimal effects on the soil resource 

since existing down materials would not be treated. The combination of past and planned 

activities would have small short-term negative effects on soil productivity that would not be 

measurable on a stand basis (volume of biomass produced). Long-term soil productivity would 

be maintained. 

Conclusion

The proposed action is expected to meet Forest Plan guidelines and Region 5 Soil Quality 

Analysis Standards (SQAS) for soil cover, porosity, soil organic matter content, surface organic 

matter levels, soil moisture regime, soil hydrologic function, buffering capacity and maintain a 

well functioning soil biological system. 

Alternative 3 – No Temporary Roads

Direct/Indirect Effects

Direct/indirect effects to soil productivity are the same as those described above for alternative 2

because thinning and specialized treatments are very similar. Where there are differences, these 

are described below.

Overall, alternative 3 has a high probability of meeting the six soil standards and guidelines.

Project design features and BMPs would minimize detrimental effects to soil productivity. The 

main soil concerns are the effects of ground based harvest activities (especially skid trails) on the 

soil resource. Increased soil erosion and reductions in soil productivity (compaction and soil 

displacement) would occur primarily in main skid trails, landings and new temporary roads.

Units with existing detrimental disturbance above 10 percent (21 units) would be evaluated for 

the application of subsoiling (project design features in Chapter 2).

Alternative 3 would meet the LRMP and SQAS guidelines for soil cover, porosity, soil 

organic matter content, surface organic matter levels, soil moisture regime, soil hydrologic 

function, and buffering capacity and maintain a well functioning soil biological system.

No new temporary roads would be created under alternative 3 and thus ground disturbance 

from road construction would be less for alternative 3 than for alternative 2. However, when 

temporary roads are created, they typically alleviate the need for long skidding distances. 

Because no new temporary roads would be created under alternative 3, more skid trails would be 

needed in order to get cut trees to landings to be removed by logging trucks. Skid trails are often 

wider than temporary roads, used by ground-based equipment (and not just rubber-tired logging 

trucks as temporary roads are) and not specifically designed for drainage like temporary roads 

are. For these reasons, more skid trails would be created under alternative 3 and this would result 

in more short-term ground disturbance than would occur under alternative 2. However, because 

all skid trails would be hydrologically restored after use, just as temporary roads would be under 
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alternative 2, the long-term adverse impacts to soils would be essentially the same for 

Alternatives 2 and 3 because of the implementation of project design features. 

Cumulative Effects

Table 54 displays the cumulative effects of alternative 3 on the soil resource across all treatment 

acres. This table shows that effects of the logging systems do not exceed the acceptable threshold 

of 15 percent. These percentages are the same as those discussed for alternative 2.

Table 54. Acreage of Detrimental Disturbance across the treatment units for alternative 3

Total Treated (Thinning and Specialized Treatment) Acres 1,850

Total Threshold Detrimental Disturbance Acres 278 (15%)

Total Detrimental Disturbance Acres Post Activity 208 (11%)

Alternative 4 – Minimized Underburning

Direct/Indirect Effects

Alternative 4 includes silvicultural treatments and road decommissioning as described in 

alternative 2. Fuels treatments would focus on thinned units, consisting of jack pot and pile

burning and some limited underburning outside of thinned units, for a total of approximately 570 

acres outside of treatment units. Mastication to treat slash following thinning would be used 

instead of or in combination with jack pot and pile burning in 93 units, for a total of 

approximately 1,490 acres of mastication. 

Direct/indirect effects from alternative 4 are the same as those previously described for 

alternative 2 except for mastication. 

Mastication

Mastication would have similar direct effects as mechanical harvesting. The effects of large 

machinery, in this case masticators, are the same as skidding equipment and harvesters. Proper 

skid trail pattern layout is essential in avoiding excessive soil disturbance. In units that have 

harvest and fuel treatments, care should be taken to ensure that the same skid trails are used for 

each treatment. 

Mastication covers the forest floor with coarse wood chips that add protective groundcover.

The primary purpose of mastication is to reduce fuel loading and decrease chances of future 

burning. A secondary benefit is increased ground cover, which reduces erosion potential and will 

help to stabilize actively eroding soils in the treated units.

Mastication additionally disturbs soils from the excavator turning and the masticating drum 

churning soil. The excavator has to make tight turns to maneuver between trees. These physical 

impacts are offset somewhat by the organic matter left on the soil surface that can protect 

churned soil from eroding and enhance recovery. Information on the long-term effects of 
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mastication on soil productivity is still sparse (Resh et al. 2007). For the current analysis, effects 

are considered similar to those with established skid trail systems in harvested stands (3 percent 

additional detrimental disturbance).

Overall, alternative 4 has a high probability of meeting the six soil standards and guidelines.

Project design features and BMPs will minimize detrimental effects to soil productivity. The 

main soil concerns are the effects of ground based harvest activities (especially skid trails) on the 

soil resource. Increased soil erosion and reductions in soil productivity (compaction and soil 

displacement) would occur primarily in main skid trails, landings and new temporary roads.

Units with existing detrimental disturbance above 10 percent (25 units) will have their main skid 

trails subsoiled in order to lower their detrimental cumulative effects to below the 15 percent

detrimental disturbance threshold. The direction to maintain the soil organic layer intact will 

minimize negative effects on nutrient cycling.

Alternative 4 is expected to meet Forest Plan standards and guidelines for soil cover, 

porosity, soil organic matter content, surface organic matter levels, soil moisture regime, soil 

hydrologic function, buffering capacity and maintain a well functioning soil biological system. 

Without the additional prescribed burning, alternative 4 would not realize the short term 

benefits of soil nutrient availability that the other action alternatives would. Additionally, 

alternative 4 will have a greater amount of ground-disturbing activity via the 1,490 acres of 

mastication. The effects in this acreage will be very similar to acreage of mechanical harvest.

Cumulative Effects

Cumulative effects are the same as those previously described for alternative 2; the estimates for 

detrimental soil disturbance shown in table 40 are the same for alternative 4.

3.9 Fisheries

3.9.1 Methodology

This fisheries analysis describes the current status of salmonid populations and salmonid habitat 

in the proposed treatment areas and how existing salmonid habitat condition relates to the 

desired condition as described in the Forest Plan, and the Table of Population and Habitat 

Indicators for use on the Klamath National Forest (USDA 2007a). The fisheries analysis focuses 

on determining how no action (alternative 1) and the action alternatives (alternative 2, 3 and 4) 

may affect coho salmon, Chinook salmon, and steelhead/rainbow trout (1) directly, (2) indirectly 

via 17 indicators of aquatic habitat and watershed condition, and (3) cumulatively.

Effects are analyzed in the context of short- and long-term. Unless otherwise noted, shortterm effects are zero to five years. Long-term effects are greater than 5 years to 50 years (since 

the effects of high severity wildfire would likely last up to 50 years). The spatial context includes 

the site level, the 7th field watershed scale, and the 5th field watershed scale. Effects are evaluated 

by overlaying proposed activities on potentially affected salmon and steelhead/rainbow trout 
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habitat downslope and/or downstream of proposed activities; for this project, this includes nine 

7th field watersheds (Cole-Clauson, Coon-Wagner, East Fork Indian Creek, Indian Creek 

Headwaters, Indian/Doolittle Creek, Indian/Mill Creek, Little South Fork Indian Creek, LutherIkes, and Westbranch Creek (figure 7)).

Units proposed for thinning with ground-based mechanical systems and/or thinning units 

with intermittent and perennial stream courses were top priority for field assessment because this 

activity has the most potential to cause ground disturbance, and to affect water quality and 

aquatic habitats. In 2008, most of these types of commercial thinning units were inspected in the 

field. The general locations of proposed temporary road segments were assessed. Project areas 

proposed for precommercial thinning and underburning were less intensely assessed in the field 

because these activities, if implemented as proposed, are expected to result in relatively minor 

ground disturbance and effects on watershed function.

Existing conditions of each indicator for each 7th field subwatershed were determined using a 

variety of sources including Klamath National Forest fish population censuses of juvenile and/or 

adult salmon and steelhead from 1989 to 2009; Klamath National Forest stream habitat 

assessment surveys from 1998 to 2009; California Department of Fish and Game fish population 

census surveys conducted prior to 1994; Klamath National Forest water temperature and flow 

monitoring from 1998 to 2006; Klamath National Forest Fish Passage Barrier Inventory (USDA 

Forest Service 2003); Klamath National Forest - 1997 Flood Assessment (USDA Forest Service 

1998); Site visits in 2009 to the Two Bit commercial thin units proposed for treatment that are 

near intermittent and perennial streams; Klamath National Forest GIS data layers needed to run 

the three Forest cumulative watershed effects models (includes roads, historic timber harvest and 

salvage disturbances, historic wildfires, historic mining, reasonably foreseeable future actions, 

slopes, streams, and geomorphic terrains); Salmon, steelhead trout, and resident rainbow trout 

population status reports; Indian Creek Watershed Analysis (USDA Forest Service 1997); and 

professional judgment of fish populations and fish population habitat condition from 15 years of 

working in the project area as fisheries biologist. 

There are 17 indicators for assessing the existing fish habitat condition and the potential for 

changes based on implementation of all alternatives. The indicators are:

Water temperature

Turbidity

Chemical contamination

Fish passage

Substrate character

Amount of large woody debris in stream channels and potential for future LWD 

recruitment

Pool frequency and quality

Off-channel habitat

Refugia

Width to depth ratio
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Streambank condition

Floodplain connectivity

Change in peak and base flows

Drainage network increase

Road density and location

Disturbance history/regime

Riparian Reserves

The information used in the preparation of this section comes from detailed analysis in the 

Fisheries Report (Grunbaum 2010) and is available in its entirety in the project record.

3.9.2 Affected Environment

Coho salmon, Chinook salmon, steelhead trout and resident coastal rainbow trout are the focus 

of this analysis. Project effects on other fish species listed as Sensitive on the October 2007 

Forest Service Region 5 Sensitive Species list (USDA c) and/or listed as Proposed, Threatened, 

or Endangered by the Arcata Office of the US Fish and Wildlife on December 10, 2009, were not 

assessed because these species do not occur in or near the Two Bit project area. There are 

approximately 22 miles of habitat for coho salmon, 19 miles of habitat for Chinook salmon, 47 

miles of habitat for steelhead trout, and 49 miles of habitat for rainbow trout In the Indian Creek 

watershed downstream/downslope of proposed actions.

Southern Oregon/Northern California (SONCC) Coho Salmon –Federally Listed 

as Threatened

The SONCC coho salmon species or Evolutionary Significant Unit (ESU) includes coho salmon 

in the Klamath River and all tributaries to the Klamath River downstream of certain dams. The 

number of tributaries used by coho salmon in the Klamath-Trinity System has significantly 

declined, and estimated numbers of coho salmon in the Klamath basin has decreased 

precipitously since the early 1900s. The life history, habitat requirements, and status of SONCC 

coho salmon is thoroughly outlined in Moyle 2002 and in Moyle et al. 2008 (see Moyle et 

al.2008 at: (www.caltrout.org/SOS-Californias-Native-Fish-Crisis-Final-Report.pdf). SONCC 

coho salmon were listed as “threatened” under the federal Endangered Species Act in 1997 (62 

FR 24588) and Critical Habitat (CH) was subsequently designated (64 FR 24049). Essential Fish 

Habitat (EFH) was designated for SONCC coho salmon by the Pacific Fishery Management 

Council in 1999. 

Upper Klamath-Trinity Rivers (UKTR) Chinook Salmon – Forest Service 

Sensitive

The UKTR Chinook salmon species ESU includes Chinook salmon in the Klamath River and all 

tributaries to the Klamath River upstream of an including the Trinity River. In the Klamath River 

basin, there are two distinct Chinook salmon populations: the spring run and the fall run. UKTR 

Chinook salmon are a Forest Service Sensitive species because the spring run is very limited in 
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current range compared to historical distribution. Spring Chinook are currently extirpated from 

much of their historical range in the Klamath Basin because of dam construction and/or poor 

water quality conditions. The Salmon River supports the only spawning population of any 

significance in the Klamath River above the Trinity River confluence, and this population has 

experienced wide fluctuations of returning adults ranging from under 100 to over 1400. For the 

fall-run, a minimum escapement goal of 35,000 adult Chinook salmon to natural spawning areas 

in the Klamath Basin has not been met for the last four years (2004 to 2008). The Klamath River 

fall Chinook population has been so depressed that Chinook salmon fishing along the west coast 

has had to be severely restricted since 2006. The life history, habitat requirements, and status of 

summer and winter runs of UKTR Chinook salmon is thoroughly outlined in Moyle 2002 and in 

Moyle et al. 2008 (www.caltrout.org/SOS-Californias-Native-Fish-Crisis-Final-Report.pdf). 

Essential Fish Habitat was designated for UKTR Chinook salmon by the Pacific Fishery 

Management Council in 1999. 

Klamath Mountains Province (KMP) Steelhead Trout and Resident Coastal 

Rainbow Trout – Forest Service Sensitive Species and Management Indicator 

Species

The boundary between anadromous steelhead trout and resident coastal rainbow trout is fuzzy. 

Many different populations of rainbow trout presumably had independent origins from steelhead 

trout (Moyle et al. 2008). The Klamath Mountains Province (KMP) steelhead trout species or 

ESU includes steelhead trout in coastal basins from Cape Blanco to just south of the Klamath 

River in California. In the Klamath River basin, there are two distinct steelhead trout 

populations: the summer run and the fall run. KMP steelhead is a Forest Service Sensitive 

species because the summer run is very limited in distribution, and numbers of summer-run 

steelhead in remaining populations are depressed. Resident rainbow trout are found in virtually 

every coastal stream (including tributaries to the Mid-Klamath River) where habitat is 

accessible. The life history, habitat requirements, and current status of summer and winter runs 

of KMP steelhead trout, and of resident coastal rainbow trout, is thoroughly outlined in Moyle 

2002 and Moyle et al. 2008 (www.caltrout.org/SOS-Californias-Native-Fish-Crisis-FinalReport.pdf).

Water Temperature

Water temperature meets desired conditions in all 7th field watersheds except for the Luther Ikes 

subwatersehd where water temperature in mainstem Indian Creek is categorized as ‘at risk’ 

according to the habitat indicator criteria. As state previously in the Water section of this chapter, 

the entire mid-Klamath River and tributaries including Indian Creek are on the EPA 303(d) list as 

impaired for water temperature, nutrients, organic enrichment, and low dissolved oxygen.
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Turbidity

Turbidity is low to moderate in project area streams. Turbidity is slightly elevated or “at risk” in 

the following watersheds that have high road density and/or high hydrologic connectivity 

between roads and the stream network and/or highly elevated modeled surface erosion risk: 

Coon-Wagner, Indian Creek Headwaters, Indian/Mill Creek, Little South Fork Indian Creek, 

Luther-Ikes, and Westbranch Creek. None of these 7th field subwatersheds are rated “not properly 

functioning” for the Sediment-Turbidity Indicator. The California State water quality 

requirements are that “the suspended sediment load and suspended sediment discharge rate shall 

not be altered in such a manner as to cause nuisance or adversely affect beneficial uses” 

(beneficial uses in project area streams are salmon and steelhead habitat, and domestic or 

municipal water supply). This is hard to measure so the Forest Plan and Table of Habitat 

Indicator proxy for turbidity is that “average percent fine (less than 2mm) sediment should not 

exceed 15 percent”.

Chemical Contamination

There are no known point sources of chemical contamination in most 7th field watersheds except 

Coon-Wagner and Luther Ikes. The Classic Hill mine occurs in the Coon-Wagner watershed and 

the Gray Eagle mine occurs in the Luther Ikes watershed.

Runoff from the Gray Eagle Mine and surrounding area contaminates streams. Heavy metals 

were detected in high concentrations in surface water of a side channel of mainstem Indian 

Creek in 2008 (Soto, pers. comm. 2008). Much of the flow of Luther Gulch is treated in a facility 

to remove heavy metals and other contaminates that drains the now inoperative Gray Eagle 

Mine. Tailings from the Gray Eagle Mine that were placed on a 20-acre site (former lumber mill) 

on the valley floor of Indian Creek were capped in a restoration project in the late 1990s;

however, heavy metals and other pollutants still leach into mainstem Indian Creek in wet years 

when there is significant lateral groundwater movement under the cap. Contamination of 

mainstem Indian Creek from the tailing dump is evidenced by metal plating on the rocks at and 

downstream from the tailings dump. There are small areas along mainstem Indian Creek 

upstream from Luther Gulch that do not support fish due to heavy metal contamination in water 

coming from the Gray Eagle Mine; however, most of mainstem Indian Creek is not contaminated 

to the point where salmonids are adversely affected. 

Contamination from the Classic Hill Mine has not been documented but is suspected. 

Chemical contamination from other private lands is unknown but suspected to be insignificant at 

the 7th field watershed scale because there is little to no private land in most of the project 

watersheds, private lands in the project watersheds are generally not industrial and generally 

have light to moderate residential and/or ranching development, and there are no large disposal 

areas. Although water quality of Klamath River tributaries is generally “properly functioning”, 

the entire mid-Klamath River is on the EPA 303(d) list for excessive concentration of the 

following pollutants: temperature, dissolved oxygen, and nutrients/algae.
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Fish Passage

Fish passage was assessed, inventoried, and prioritized for barrier modification or removal at all 

road-stream crossings on National Forest System land in the project area (USDA Forest Service 

2003); one low priority and four high priority sites were documented. Two of the high priority 

sites have been remedied and the Forest Service is in the process of securing funds to restore 

passage at the other three barrier sites. 

Substrate Character

The substrate quality indicator is rated “properly functioning” in the Cole-Clauson and East Fork 

Indian Creek 7th field watersheds but is rated either “at risk” in Coon-Wagner, Indian Creek 

Headwaters, Indian/Doolittle Creek, Indian/Mill Creek, Little SF Indian, and Luther-Ikes 7th field 

watersheds and “not properly functioning” in Westbranch Creek watershed. This is due to: (1) 

high road density in watersheds where there has been little road maintenance or stormproofing, 

(2) high fines and/or embeddedness in stream surveys, (3) low pool frequency and pool depth 

indicating excessive course sediment delivery to the stream, (4) history of numerous major road 

failures and altered stream channels from the 1997 Flood, and/or (5) highly elevated CWEs. 

Large Woody Debris

Levels in stream channels are well below desired condition in all watersheds and the large 

woody debris indicator is rated as either at risk or not properly functioning in all nine project 7th

field watersheds. 

Pool Frequency and Quality

One of the nine 7th field watersheds meets the Forest Plan and habitat indicator pool 

frequency/quality criteria for “properly functioning”. It is likely that the pool frequency/quality 

criteria are not a good fit for many of the smaller streams in the project area. However, it is likely 

that pools are filled in or partially filled in with course sediment in many of the 7th field 

watersheds that have high road density and that have had extensive past stand replacement 

forestry because the rate of mass wasting in these watersheds has been accelerated by these types 

of management actions (USDA Forest Service 1998). Excessive fine sediment from elevated 

mass wasting is transported out of the stream systems relatively quickly (a few years) whereas 

the excessive course sediment from mass wasting can take decades to transport out. Based on 

field data and/or level of watershed disturbance, the pool frequency/quality indicator is “properly 

functioning” in the Little South Fork Indian Creek 7th field watershed, is “at risk” in the ColeClauson, Indian Headwaters, Luther-Ikes, and Westbranch 7th field watersheds, and is “not 

properly functioning” in the Coon-Wagner, East Fork Indian Creek, Indian/Doolittle Creek, and 

Indian/Mill Creek 7th field watersheds.
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Off Channel Habitat and Floodplain Connectivity

Off-channel habitats provide refugia from high flows and increase habitat diversity. Off-channel 

habitat development and floodplains is not characteristic of many of the highly entrenched 

channel types in the Two-Bit Project area (primarily Rosgen A-, B-, C-, and G-channel types), 

consequently, there are few floodplains or areas where off-channel habitats can develop, and 

most of the project 7th field watersheds do not have potential for off-channel habitat 

development. The off-channel habitat and floodplain indicators are not applicable in seven of the 

nine project 7th field watersheds. Unconstrained reaches where off-channel habitat and floodplain 

have potential for development occur only along the lower gradient reaches of mainstem Indian 

Creek in the Coon-Wagner and Luther-Ikes HUC 7 watersheds. The off-channel habitat and 

floodplain connectivity indictors in the Coon-Wagner and Luther-Ikes watershed are “at risk”.

Refugia 

The most important components of refugia for salmonids in project area streams is primarily 

cool clear water and secondarily cover in the form of deep pools and/or large woody debris 

and/or boulders. Water temperature is suitable to optimum in all project 7th field watersheds 

except Luther-Ikes where summer water temperatures often increase to suboptimal levels in 

mainstem Indian Creek. Cover in the form of deep pools is lacking in all project watersheds 

except for Little SF Indian Creek. Cover in the form of large woody debris is lacking in all 

watersheds. Refugia is properly functioning in the Cole-Clauson, Indian Headwaters, 

Indian/Doolittle Creek, Indian/Mill Creek, and Little SF Indian Creek watersheds. The Refugia 

indicator is “at risk” in the Coon-Wagner, EF Indian Creek, Luther-Ikes, and Westbranch Creek 

watersheds. 

Width to Depth Ratio

The effects of past floods combined with high concentration of landslides overlain by a dense 

road system are the main factors that have contributed to poor channel characteristics in the 

Indian Creek watershed (Bousfield 2010). Filling of pools and deep spots in the streambed from 

increased erosion (see Pool Frequency section above) has resulted in a shallowing and widening 

of the stream channel. The Width to Depth Ratio indicator is “properly functioning” in only the 

Little SF Indian Creek project watershed; is “at risk” in the Cole-Clauson, East Fork Indian 

Creek, Indian Headwaters, Indian/Doolittle Creek, Indian/Mill Creek, and Westbranch Indian 

Creek watersheds; and is “not properly functioning” in the Coon-Wagner and Luther-Ikes 

watersheds.

Streambank Condition 

Streambanks along mainstem Indian Creek are impacted by roads (some in the inner gorge), past 

mining, private property development, berming to prevent flooding, and numerous accesses to 

the stream buffer. Streambanks in tributaries to Indian Creek are generally stable and in good 

condition except: (1) at the numerous road-stream crossings, (2) where roads are within the inner 
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gorge of streams, and (3) where channels have been recently altered by floods and/or debris 

flows. Streambank conditions are “properly functioning” in the Little SF Indian Creek and 

Westbranch Creek HUC7 watersheds, and is “at risk” in the remaining seven project watersheds, 

based on Forest Plan and habitat indicator criteria. 

Change in Peak and Base Flows 

The Change in Peak/Base Flow indicator is “not properly functioning” in the Coon-Wagner, 

Indian Creek Headwaters, Indian/Doolittle Creek, Indian/Mill Creek, Luther-Ikes, and 

Westbranch Creek 7th field watersheds and is “at risk” in the other project 7th field watersheds. 

This is primarily due to the relatively high road density in the project area and the fact that 

between 5 percent and 26 percent of the road system (not including Indian Creek Road and 

Grayback Road) in the project 7th field watersheds are hydrologically connected to the stream 

network.

Drainage Network Increase 

The primary cause of drainage network increase in the Indian Creek watershed is hydrologic 

connectivity between the road system and the stream network. As stated above, road density is 

relatively high in the project area. For these reasons, the drainage network is “not properly 

functioning” in the Coon-Wagner, Indian Creek Headwaters, Indian/Doolittle Creek, Indian/Mill 

Creek, Luther-Ikes, and Westbranch Creek watersheds, and “at risk” in the Cole-Clauson, EF 

Indian Creek, and Little SF Indian Creek watersheds. 

Road Density and Location 

Based on GIS data to determine road density and location, the Road Density and Location 

Indicator is “not properly functioning” in the Coon-Wagner, Indian Creek Headwaters, 

Indian/Doolittle Creek, Indian/Mill Creek, Luther-Ikes, and Westbranch Creek watersheds, and is 

“at risk” in the Cole-Clauson, EF Indian Creek, Little SF Indian Creek watersheds. Desired 

conditions include less than 2 miles of roads per square mile of watershed and no roads in valley 

bottoms. Road density in the Indian Creek watershed is estimated at 3.1 miles per square mile.

Disturbance History/Regime 

All of the project 7th field watersheds and the entire Indian Creek 5th field watershed have 

moderate to high levels of watershed disturbance from past road construction, stand-replacement 

forestry, and/or large-scale industrial mining. All of the 7th field watersheds except for East Fork 

Indian Creek and Little South Fork Indian Creek have high watershed disturbance from roads. 

There were 92 major road failures and other management related landslides in the Indian 5th

field watershed during the 1997 Flood, and about 12 percent of the channels were altered by 

debris flows and are still recovering. Rate of recovery from the 1997 Flood and the 2005 Flood is 

slow. 
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The cumulative effect of past management in the Indian Creek 5th field watershed has 

resulted in poor watershed function and poor channel conditions in mainstem Indian Creek and 

many of the tributaries (see Water section earlier in this chapter). Vegetation attributes have been 

significantly altered from their historical range (see Fire and Fuels section earlier in this chapter) 

in riparian and upslope areas due to stand-replacement forestry and fire suppression. 

Consequently, fire frequencies have departed from historical frequencies by multiple return 

intervals and the risk of losing key ecosystem components due to altered vegetation 

characteristics is high. The precarious condition of vegetation in the Indian Creek watershed 

could result in a large high intensity fire that would further degrade watershed function. 

Based on the above factors, the Disturbance History/Regime indicator is “at risk” in all 7th

field watersheds except Luther-Ikes where the Disturbance History/Regime indicator is “not 

properly functioning”. 

Riparian Reserves

All of the project 7th field watersheds have some level of disturbance within stream buffer and 

geologic RRs from past road construction, stand-replacement forestry, and/or large-scale

industrial mining. All of the watersheds except for East Fork Indian Creek and Little South Fork 

Indian Creek have high watershed disturbance from roads within stream buffer RRs. The ColeClauson, Coon-Wagner, Indian Creek Headwaters, Indian/Mill Creek, and Luther-Ikes 

watersheds have significant disturbance in stream buffer RRs from past large-scale industrial 

mining. The Coon-Wagner and Luther-Ikes watersheds have significant disturbance within 

stream buffer RRs from ground compaction, development, and vegetation removal on private 

lands. There were 92 major road failures and other management-related landslides in the Indian 

5th field watershed during the 1997 Flood and about 12 percent of the channels were altered by 

debris flows and are still recovering, however, the majority of riparian vegetation was left intact. 

The 2005 Flood caused additional road failures and riparian vegetation downstream of the bridge 

to the Westbranch campground was lost due to fluvial erosion. The road system in the is 

generally in poor condition due to lack of road maintenance and stormproofing, and is still 

susceptible to failures that could trigger debris flows damaging to riparian vegetation. Between 

5and 26 percent of the road system (not including Indian Creek Road and Grayback Road) in the 

project 7th field watersheds is hydrologically connected to the stream network and road density 

within stream buffer RRs ranges from 0.4 to 1.4 mile of road per square mile of stream buffer. 

See the Geology and Water sections of this chapter for more details on existing watershed 

conditions in the project area. Based on the above factors, the Riparian Reserves indicator is “at

risk” in all watersheds except Luther-Ikes where the Disturbance History/Regime indicator is 

“not properly functioning”.
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

188

3.9.3 Environmental Consequences

Alternative 1- No Action 

Direct/Indirect and Cumulative Effects

Under the no action alternative, there would not be any direct or indirect effects because no 

action would be taken. Therefore, there would be no cumulative effects. However, the potential 

for high intensity fire would continue and subsequent loss of riparian areas and loss of aquatic 

habitat would continue. At the same time, vegetation would recover in previously disturbed areas 

and riparian/aquatic conditions would improve until or unless another disturbance results.

Alternative 2 – Proposed Action 

Direct/Indirect Effects

Direct effects on fish are possible only where there are instream activities. Water drafting is the 

only project activity that would occur in-stream. Water drafting in streams that support salmon 

and steelhead would be performed in accordance with NMFS water drafting specifications 

(USDC 2001) designed to prevent adverse direct and indirect effects to anadromous salmonids 

by requiring intakes to be screened to prevent entrainment of fish, and by limiting rate of water 

drafting. Existing water drafting sites would be used and no new water drafting sites will be 

constructed. Therefore, the proposed action is not likely to have any direct adverse are affect on 

salmon and steelhead. Individual resident rainbow trout could be killed or injured because fish 

screening is not required upstream of the range of salmon or steelhead; however, there would be 

few drafting sites in resident rainbow trout habitat because the range of rainbow trout is just 

slightly greater than the range of steelhead trout in most project area streams and most of the 

drafting sites upstream of the range of steelhead would be in non fish-bearing reaches. However, 

a few individual rainbow trout could conceivably be entrained at water drafting sites that are 

within the range of resident trout, but this loss would not jeopardize the populations of rainbow 

trout in project streams given that rainbow trout are not listed as a threatened or endangered 

species and are ubiquitous in project area streams large enough to support trout.

Indirect effects to salmon, steelhead, and rainbow trout are assessed using habitat indicators 

as described in detail in table 55.
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

189

Table 55. Salmonid habitat indicators, primary environmental factors determining condition of 

salmonid habitat indicators, and appropriate measures for determining effects of proposed action

on salmonid habitat indicators

Salmonid Habitat 

Indicators

Primary Environmental 

Factor(s)

Measures for Determining Affects on

Salmonid Habitat Indicators via Affects on 

the Primary Environmental Factors

Water Temperature

Stream Shading Change in stream shading

Change in rate of landsliding (debris flows)

Channel morphology

Change in rate of landsliding (mass wasting 

and debris flows)

Change in magnitude of peak flows

Base stream flow Change in base flow (see measures for 

Change in Peak/Base Flow indicator below)

Substrate - Turbidity Rate of fine sediment 

delivered to streams

Change in rate of landsliding

Change in amount of disturbed, denuded, 

and/or compacted ground that is hydrologically

connected to the stream system

Change in rate of surface erosion as estimated 

by CWE modeling (USLE model)

Chemical and/or Nutrient 

Contamination

Amount of toxic or 

nutrient substances 

entering surface waters

Change in amount of toxic or nutrient 

substance entering surface water

Physical Barriers

Stream reached made 

impassable by 

construction of roadstream crossings, 

impoundments, diversion 

dams, or other 

obstructions

Change in status of fish passage due to 

construction of road-stream crossings, 

impoundments, diversion dams, or other 

obstructions

Substrate Character

Rate of fine and course 

sediment delivered to 

stream

Change in rate of landsliding.

Change in amount of disturbed, denuded, 

and/or compacted ground that is hydrologically

connected to the stream system

Change in rate of surface erosion and mass 

wasting as estimated by CWE modeling (USLE 

and GEO models)

Pool Frequency/Quality

and

Width to Depth Ratio

Rate of course sediment 

delivery to stream Change in rate of landsliding

Rate of debris flows Change in rate of landsliding

Magnitude of peak flows Change in magnitude of peak flows

Amount/character of 

existing LWD in stream 

channels, and potential 

for future LWD 

recruitment to the stream 

channel

Direct removal or addition of LWD to the 

stream channel.

Change in potential for future recruitment of 

LWD to the stream channel via trees falling. 

(see Measures for LWD Indicator below)

Change in rate of LWD delivered to the stream 

channel via landsliding (see Measures for LWD 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

190

Salmonid Habitat 

Indicators

Primary Environmental 

Factor(s)

Measures for Determining Affects on

Salmonid Habitat Indicators via Affects on 

the Primary Environmental Factors

Indicator below)

Off-Channel Habitat

and

Floodplain Connectivity

Freedom of stream 

channels to move 

laterally without 

obstruction by roads, 

culverts, dams, berms, or 

other obstructions

Change in potential for streams to move 

laterally without restriction due to in-channel 

activities or developments

Amount of disturbance or 

development in offchannel areas or 

floodplains that reduces 

habitat availability or 

suitability

Change in disturbance levels in off-channel 

and floodplain areas.

Large Woody Debris

Amount/character of 

existing LWD in stream 

channels

Direct removal or addition of LWD to the 

stream channel.

LWD recruitment potential 

via trees falling into the 

stream channel

Change in potential for future recruitment of 

LWD to the stream channel via trees falling 

from within stream buffers

LWD recruitment potential 

via trees landsliding into 

the stream channel

Change in rate of landsliding

Change in amount and character of ground or 

vegetation disturbance on unstable or highly 

erodible ground (geologic RRs)

Streambank Condition

Direct ground disturbance 

of streambanks

Amount of direct ground disturbance on 

streambanks

Channel alteration from 

increased rate of debris 

flows

Change in rate of landsliding

Channel alteration from 

increased peak flows Change in magnitude of peak flows

Refugia

Water temperature Same Measures as for Water Temperature 

Indicator

Cover

Change in amount of cover from LWD, 

undercut banks, unembedded cobbles and 

boulders, and deep pools (see Measures for 

Substrate, LWD, and Pool ... Indicators)

Change in Peak/Base 

Flows

Peak Flow: Amount of 

disturbed, denuded, 

and/or compacted ground 

that is hydrologically

connected to the stream 

network (includes roads, 

landings, skid trails, etc)

Change in amount of disturbed, denuded, 

and/or compacted ground that is hydrologically

connected to the stream system

Change in amount of watershed disturbance 

from commercial thinning, underburning, and 

road and landing construction as estimated 

with CWE modeling (ERA/TOC model)

Peak Flow: Increased 

runoff from increased 

area of clearings in the 

snow zone and snow

transition zone

Change in number and total area of clearings 

that are 1.5 acres or greater in size
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

191

Salmonid Habitat 

Indicators

Primary Environmental 

Factor(s)

Measures for Determining Affects on

Salmonid Habitat Indicators via Affects on 

the Primary Environmental Factors

Base Flow: Amount of 

water diversion

Change in amount of water diverted from 

streams

Base Flow: Net stand 

evaporation Change in net stand evapotranspiration rate

Increase in Drainage 

Network

Amount of disturbed, 

denuded, and/or 

compacted ground that is 

hydrologically connected 

to the stream network 

(includes roads, landings, 

skid trails, etc)

Change in amount of disturbed, denuded, 

and/or compacted ground that is hydrologically

connected to the stream system

Road Density and 

Location

Number of miles of road 

and the road locations.

Duration of road before it 

is decommissioned

Change in number of miles of upslope and 

valley bottom road and how long new roads will 

be used before being decommissioned.

Disturbance History

and

Disturbance Regime

Amount and location of 

vegetation clearing and/or 

ground disturbance 

Change in amount of watershed disturbance 

from commercial thinning, underburning, and 

road and landing construction as estimated 

with CWE modeling (USLE, GEO, and ERA 

models)

Deviation from historic 

fuels conditions

Change in fuels conditions from proposed

thinning and underburning

Frequency and/or 

magnitude of stochastic 

events such as intense 

fires, floods, and large 

and/or widespread 

landslides

Change in rate of landsliding

Change in magnitude of peak flows (see 

Change in Peak/Base Flow indicator)

Change in fuels conditions from proposed

thinning and underburning

Riparian Reserves

Amount of ground 

disturbance and/or 

vegetation removal in 

stream buffers (hydrologic 

RRs)

Change in amount of ground disturbance 

and/or vegetation removal in stream buffer 

(hydrologic RRs)

Disturbance of stream 

buffer from debris flows or 

debris avalanches

Change in rate of landsliding

Amount and character of 

ground disturbance and 

vegetation removal on 

unstable and/or highly 

erodible ground (geologic 

RRs)

Change in amount and character of ground or 

vegetation disturbance on unstable or highly 

erodible ground (geologic RRs)

Indirect effects to salmon, steelhead trout, and rainbow trout from implementation of 

alternative 2 are shown in table 56.
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

192

Table 56. Alternative 2 - Effects on salmonid habitat condition measures

Measures of Project 

Effects to Salmonid 

Habitat Condition

Effects of Proposed Action Project Elements on Measures of Salmonid 

Habitat Condition for Alternative 2

Change in stream 

shading

The proposed action would kill and/or consume brush and small trees within 

stream buffer RRs. However, PDFs would maintain adequate stream shading

where needed. At least 85% canopy cover would be maintained (where that 

much currently exists) over perennial and intermittent streams in all natural 

stands and most plantations (the only exception to this is in plantations with 

offsite ponderosa pine; in these stands, more aggressive thinning would occur 

and canopy cover could be reduced below 85%). Field research has shown that 

water temperatures did not increase when taken upstream and downstream of a 

stream reach with 80% canopy cover (McGurk 1988), although other research 

suggests that the impact of past forest harvest activities on stream temperatures 

cannot be entirely mitigated through the reestablishment [or retention] of riparian 

buffers (Pollock et. al., 2009). Thinning and underburning is unlikely to cause 

significant changes in stream shading or microhabitat conditions, therefore, risk 

of Project-related change in stream temperature due to changes in canopy cover 

of vegetation density is negligible. 

Change in rate of

landsliding

The proposed action would slightly increase landslide potential due to: (1) shortterm (up to ten years) reduction in evapotranspiration and root strength in 

thinned, underburned, and cleared areas (roads, landings, skid trails) and (2) to 

increased and/or altered runoff from compacted and/or disturbed ground. These 

effects would not measurably affect landslide rates and would be offset in the 

long-term (10+ years) by increasing vigor of the stands associated with thinning, 

and by reduction in wildfire hazard due to fuel treatments (Geology Report).

Change in number 

and total area of 

clearings that are 1.5 

acres or greater in 

size

Research has shown that canopy openings greater than 1 1⁄2 to 2 acres must be 

created in order to change rain-on-snow dynamics (Christner and Harr, 1982). 

The proposed action would create openings where all vegetation is removed;

however, none of the openings would be larger than the 1.5 acres that could 

lead to changes in magnitude of peak flows from rain-on-snow events.

Change in amount of 

disturbed, denuded, 

and/or compacted 

ground that is 

hydrologically

connected to the 

stream system

The proposed action would increase area of disturbed, denuded, and/or 

compacted ground in each Project watershed, however, there would be 

negligible or no measurable increase in the amount of disturbed, compacted or 

cleared ground that drains overland to a stream system because: (1) roads, 

landings, skid trails, and yarding corridors would be designed and used with 

drainage control, and generally be located well enough away from the nearest 

channel or ditch to provide adequate infiltration, (2) underburning implemented 

to prescription has negligible risk of increasing overland flow or measurably 

altering runoff because low intensity underburning treatments do not typically 

affect the permeability of soil underneath the protective duff and litter layer, and 

little to none of the existing canopy cover over the stream is removed, (3) new 

areas of disturbance would generally be less than one acre - research has 

shown that canopy openings greater than 1.5 to 2 acres must be created in 

order for a change in runoff from rain-on-snow to be measurable (Christner and 

Harr, 1982), and (4) Grant et al (2008) review of paired watershed studies 

indicated that a 1% increase of harvested [clearcut or cleared] areas in a 

watershed relates to a 0.5% increase in peakflow, however, all the clearing (for 

temporary roads, landings, meadow enhancement, etc) caused by the proposed 

action amounts to less than 0.5% clearing of the total area in any of the project 

HUC7 watersheds or within the entire Indian Creek HUC5 watershed.

Change in amount of 

watershed 

disturbance from 

commercial thinning, 

underburning, and 

road and landing 

construction as 

estimated with CWE 

modeling (USLE, 

The proposed action would not significantly increase modeled mass wasting 

(GEO) rate in any of the Project watersheds but would slightly increase modeled 

surface erosion (USLE) and modeled runoff risk (ERA/TOC) rates in many of the 

Project watersheds. All Project watersheds would remain below model inference 

points in all three CWE models.
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

193

Measures of Project 

Effects to Salmonid 

Habitat Condition

Effects of Proposed Action Project Elements on Measures of Salmonid 

Habitat Condition for Alternative 2

GEO, and ERA/TOC 

models)

Change in amount of 

toxic or nutrient 

substance entering 

surface water

Borax treatments are expected to have neutral effect on water quality because: 

(1) application of Sporax® (borax) to fresh cut true fir stumps would be done in 

compliance with all label directions and Forest Service requirements, (2) borax is 

not particularly toxic and is relatively environmentally benign (USDA Forest 

Service 1995a), and (3) borax would be used only on the freshly-cut stumps of 

white fir or Shasta fir in treatment units that are at high enough elevation (about 

4000 feet) to support true fir which means that use would be limited. In the 

Project area, true fir trees grow at higher elevations where there are few 

perennial streams and where perennial streams are usually non fish-bearing or 

support just resident trout but not salmon or steelhead. The Borax Pesticide Fact 

Sheet (USDA-FS 1995) concludes that borax is adsorbed by the mineral portion 

of the soil and borax remains unchanged in the soil for varying lengths of time, 

depending on soil acidity and rainfall. The average persistence is one year or 

more. Borax is less persistent in acid soils and in areas with high rainfall, under 

which conditions it may leach rapidly. The Dost Report further reports that plant

uptake would probably scavenge any boron moving through the soils and that 

dilution over a watershed would hide even a significant spill.

The proposed action could cause drips or spills of oil, hydraulic fluid, and grease 

from use of vehicles and equipment, and/or spray of bar oil from chainsaw use, 

but streams would be protected from this type of contamination through 

application of PDFs, particularly stream buffers, and through enforcement of 

Forest Service contract obligations, such as restricting equipment use in stream 

buffers and forbidding the use of poorly maintained or “leaky” vehicles and 

equipment in the Project. The prescribed burns would be ignited with drip 

torches or through aerial ignition. Most but not all of the fuel from drip torch and 

aerial ignitions is consumed in the prescribed fire. Total amount of petroleum 

products entrained into surface or ground waters from lubricants, hydraulic 

fluids, and drip torch fuels combined is expected to be insignificant and it is 

unlikely that such Project-related chemicals would be detectable in perennial 

streams. 

Change in status of 

fish passage due to 

construction of roadstream crossings, 

impoundments, 

diversion dams, or 

other obstructions

The proposed action has no causal mechanism to affect passage for fish and 

aquatic organisms because there would be no in-channel disturbances in fishbearing streams or reductions in streamflow that could affect passage for fish or 

other aquatic organisms.

Direct removal or 

addition of LWD to 

the stream channel

The proposed action would not remove LWD from a stream channel except in 

infrequent situations of where a piece of large woody debris or fallen hazard tree 

is blocking a drainage structure or presenting a safety hazard. Therefore, little to 

no LWD would be removed from stream channels. Wood could be added to a 

stream channel if a hazard tree was felled into the channel and left there - but 

this would occur infrequently if at all.

Change in potential 

for future recruitment 

of LWD to the stream 

channel via trees 

falling into the 

channel

The proposed action would have neutral short term effect on potential for LWD 

to be recruited by trees falling from the stream buffer because no large qualifying 

trees would be felled or burned up within stream buffers (except for trees 

hazardous to operations which are generally left on site in stream buffers if 

felling is necessary) and the largest and healthiest trees would be retained in 

stream buffers. The proposed action would have slight positive long term effect 

on potential LWD recruitment from stream buffers because thinning, fuel 

treatments, and underburning would improve the health, vigor, and growth rate 

of retained vegetation, and because the treatments would reduce risk of a future 

stand-replacing wildfire that could kill living trees before they are large enough to 

qualify as LWD. No thinning would take place in aquatic influence zones 

(FEMAT 1993) of ephemeral channels where the sediment retaining function of 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

194

Measures of Project 

Effects to Salmonid 

Habitat Condition

Effects of Proposed Action Project Elements on Measures of Salmonid 

Habitat Condition for Alternative 2

live vegetation and woody debris is critical to moderating erosion.

Change in potential 

for streams to move 

laterally without 

restriction from 

roads, levies, berms, 

or other development

The proposed action has no causal mechanism to affect the potential of streams 

to move laterally because the Project would not cause any significant new 

ground disturbance within stream channels, off-channel areas, or floodplains.

Change in 

disturbance levels in 

off-channel areas 

and floodplains

The proposed action has no causal mechanism to cause any significant new 

ground disturbance within stream channels, off-channel areas, or floodplains.

Amount of direct 

ground disturbance 

on streambanks

Only the skidding and water drafting components of the proposed action have 

causal mechanism to affect streambanks. Streambanks would not be disturbed 

except: (1) in infrequent circumstances where logs may have to be skidded 

across a dry intermittent channel – in these instances the channel shape would 

be restored immediately after skidding, and before any precipitation and runoff, 

and (2) in infrequent circumstances where a new water drafting site needs to be 

created – in these instances new water drafting sites would be temporary, would 

not use fill without approval by a fisheries biologist and an earth scientist, and 

would not be constructed on fish-bearing stream reaches, and if fill is used, it 

would be removed and the channel shape restored after use.

Change in amount of 

cover from LWD, 

undercut banks, 

substrate, deep pools

The proposed action would not significantly affect the amount of instream cover 

because: (1) there would be no instream activities other than water drafting 

which would not affect quantity of fish cover, (2) potential for LWD to be 

delivered to stream channels via trees falling from the stream buffer or via 

landslides from upslope areas would not be significantly decreased in the short 

term and may increase in the long term due to proposed action (see LWD 

measures above), and (3) rate of course sediment delivery from mass wasting 

that can fill pools or provide cover in the form of large boulders would not be 

significantly changed (see Landsliding measures above).

Change in net stand 

evapotranspiration 

rate

The proposed action would slightly increase area of denuded ground and/or 

slightly decrease vegetation density. These actions would eliminate 

evapotranspiration in the short term in areas where there is new road, landing, 

skid trail, and yarding, and would reduce evapotranspiration in the short term in 

areas where trees are thinned and/or ladder fuels treated, however, these 

Project disturbances are not expected to affect net evapotranspiration rate in 

any drainage to the point where ground water balance is significantly affected in 

the long term or short term because: (1) the only semi-permanent clearing of 

vegetation is associated with new short temporary road segments and landings -

in these areas all vegetation would be removed during Project implementation 

and post-project regrowth would likely be slow and stunted due to loss of top-soil 

and ground compaction, however, these new disturbances are very small in area 

relative to the HUC7 project watersheds and are widely distributed across the 

project watersheds and (2) in the short term, thinning would slightly reduce net 

evapotranspiration in treated stands but the thinning would also cause the rate 

of evaporation to increase in the treated stand thereby compensating for the 

slight reduction in ground water use - so that ground water balance would be 

approximately the same as pre-treatment in the short term. In the long-term, the 

residual canopy would expand and evapotranspiration would increase, while 

forest floor evaporation would decrease due to the expanding shade. Total 

evapotranspiration would again return to near pre-harvest level. 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

195

Measures of Project 

Effects to Salmonid 

Habitat Condition

Effects of Proposed Action Project Elements on Measures of Salmonid 

Habitat Condition for Alternative 2

Change in amount of 

water diverted from 

streams

Water drafting is the only proposed action with causal mechanism to affect this 

measure. Water would be drafted for dust abatement and to manage 

underburns. Water drafting would follow NMFS Water Drafting Specifications 

(USDOC 2001) that limits the rate of water drafting so that anadromous 

salmonids are not adversely affected. Drafting rate is limited to 350 gallons per 

minute and no more than 10% of the streamflow. Therefore, total amount and 

rate of water drafted from streams during Project implementation would be 

negligible.

Change in number of 

miles of upslope and 

valley bottom road 

and how long new 

roads will be used 

before being 

decommissioned

The proposed action would construct about 2.9 miles of temporary road in 26 

segments, and would decommission 4.1 miles of road in 6 segments. There 

would be a slight increase in road miles in the short-term due to construction and 

use of the temporary roads but most temporary roads would be constructed, 

used, and stormproofed or decommissioned in the same year and dry season. 

Temporary roads leave a long-term imprint on the landscape even if 

decommissioned but the long term increase in disturbance due to temporary 

roads in the Two Bit Project would be minor because Project temporary road 

segments would be constructed on stable ground or ridgetop locations outside of 

hydrologic and geologic RRs. In the long-term, after road decommissioning, 

there would be a slight reduction in non self-maintaining road density in the 

Indian Creek 5th field watershed but a slight increase in density of selfmaintaining temporary roads.

Change in fuels 

conditions from 

proposed thinning 

and underburning

The proposed action would reduce flame length and crown fire potential in 

treated areas in the long term (Fuels Specialist Report). Wildfire risk would be 

slightly increased in treated areas in the short-term because thinning would 

increase ground fuels, and underburning is delayed for several years after 

thinning so residual trees can recover from thinning shock before underburning.

Change in amount of 

ground disturbance 

and/or vegetation 

removal in stream 

buffer riparian 

reserves

The proposed action would increase area of disturbed ground and slightly 

decrease vegetation density in stream buffers in the short term, but would 

increase the vigor and growth rate of residual vegetation in the long term. Buffer 

width would be determined by site condition so that stream bank integrity, 

sediment filtering and nutrient spiraling functions, temperature regulation, large 

wood delivery, and other watershed processes are protected in the short term, 

and improved in the long term. Approximately 234 acres within stream buffer 

RRs are proposed for commercial thinning to reduce density, which is about 

1.2% of the total stream buffer RR acreage in the Indian Creek 5th field

watershed. There would be no commercial thinning or other ground-disturbing 

activities within stream buffers of fish-bearing streams. 

Short term increase in disturbance and decrease in vegetation density in stream 

buffer RRs would not be significant at the 7th field or 5th field watershed scale 

because: (1) there would be only 234 acres of commercial thinning in stream 

buffers across the entire Project area and no more than 60 acres would be 

commercially thinned in stream buffers in any one 7th field watershed, (2) the 

prescriptions in stream buffer RRs retain much of the vegetation and nearly all of 

the overstory, and (3) no road or landings would be constructed within stream 

buffer so there would be minor disturbance legacy. 

Change in amount 

and character of 

ground or vegetation 

disturbance on 

unstable or highly 

erodible ground 

(geologic RRs)

The proposed action would not cause significant ground disturbance and/or 

result in excessive vegetation removal in geologic RRs. Project design features 

for activities in geologic RRs (see project design features in Chapter 2) would 

guide project activities in these sensitive areas. No commercial harvesting would 

occur in inner gorges; ground-based equipment would not operate within 

extremely unstable areas (as designated by a geologist), inner gorges or areas 

with highly erosive soils (as designated by a soil scientist); no new roads or 

landings would be constructed in geologic RRs; mastication and tractor yarding 

would not be used in unstable lands in geologic RRs; careful review of any 

proposed roads or landings in particularly sensitive areas (unit numbers are 

identified in Table 12) would occur; full suspension cable yarding would be used 

in geological RRs; specific guidance on use of prescribed fire in geologic RR’s 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

196

Measures of Project 

Effects to Salmonid 

Habitat Condition

Effects of Proposed Action Project Elements on Measures of Salmonid 

Habitat Condition for Alternative 2

would be implemented to ensure fire would be low severity; and all treatments in 

geological RRs would meet ACS objectives. 

Therefore, increase in ground disturbance and vegetation removal on geologic 

RRs is expected to be insignificant at the HUC7 and HUC5 watershed scales in 

the short and long term.

Alternative 2 would not directly adversely affect salmon or steelhead trout because water 

drafting is the only in-channel activity proposed, and because water would be drafted according 

to NMFS 2001 Water Drafting Specifications designed to prevent adverse affects to anadromous 

fish. Upstream of the range of anadromy, a few individual rainbow trout could be killed or 

injured at a few drafting sites but this loss would not result in a trend toward federal listing or a 

loss of viability. Rainbow trout are ubiquitous in project area streams and not federally listed. 

Proposed activities would not measurably affect these populations. Alternative 2 may impact 

individual Chinook salmon, steelhead trout and resident rainbow trout; but would not result in a 

trend toward federal listing or a loss of viability. Indirect effects are minimized because none of 

the measures for determining indirect effects of proposed action on salmon and 

steelhead/rainbow trout habitat indicators would be significantly affected.

For purposes of Section 7 of the Endangered Species Act, implementing alternative 2 may 

affect but is not likely to adversely affect Coho salmon.

Cumulative Effects

Since there are no significant effects to salmon and steelhead trout at the stream segment or 7th

field watershed scale, the proposed action would not increase cumulative effects at the 5th field 

watershed or larger scales. Since loss of a few individual resident rainbow trout would not 

jeopardize the trout populations in any of the project streams, the effects of the proposed action 

on resident rainbow trout would not be cumulative at the 7th field watershed or larger scales.

Alternative 3 – No New Temporary Roads

Direct/Indirect Effects

Alternative 3 includes 12 percent less thinning, fewer landings, and slightly fewer acres (70 

acres) of underburning than alternative 2. Alternative 3 would not construct new temporary 

roads. The direct effects of alternative 3 would be slightly less than alternative 2 because less 

water would be drafted since no new temporary roads would be constructed—there would be 

less chance of injuring or killing a rainbow trout during water drafting, however, the chance of 

injuring or killing a resident rainbow trout is already low under alternative 2.

Alternative 3 would cause slightly less watershed disturbance than alternative 2, and result in 

slightly less watershed benefit; however, at the 7th field watershed scale, both alternatives would 

have minimal effects on the measurement indicators that serve as proxy for effects to coho and 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

197

Chinook salmon, steelhead trout, and rainbow trout. Therefore, alternative 3 and the proposed 

action would have similar effects on these fish species. Effects from implementation of 

alternative 3 are the same as those described above for alternative 2 and summarized in table 56.

Alternative 3 may impact individual Chinook salmon, steelhead trout and resident rainbow 

trout but would not result in a trend toward federal listing or a loss of viability. Indirect effects 

are minimized because none of the measures for determining indirect effects on salmon and 

steelhead/rainbow trout habitat indicators would be significantly affected.

For purposes of Section 7 of the Endangered Species Act, implementing alternative 3 may 

affect but is not likely to adversely affect Coho salmon.

Cumulative Effects

Since there are no significant effects to salmon and steelhead trout at the stream segment or 7th

field watershed scale, alternative 3 would not increase cumulative effects at the 5th field 

watershed or larger scales. Since loss of a few individual resident rainbow trout would not 

jeopardize the trout populations in any of the project streams, the effects of alternative 3 on 

resident rainbow trout would not be cumulative at the 7th field watershed or larger scales. 

Therefore, alternative 3 would have similar cumulative effects as the proposed action. 

Alternative 4 – Minimized Underburning

Direct/Indirect Effects

Alternative 4 includes 92 percent less burning than alternative 2 and unlike both alternative 2 

and 3, includes 1,490 acres of mastication. The direct effects of alternative 4 would be slightly 

less than alternative 2 because less water would be drafted since substantially less underburning 

would occur—there would be less chance of injuring or killing a rainbow trout during water 

drafting, however, the chance of injuring or killing a trout is already low.

Based on the analysis presented in the hydrology and geology sections of this chapter, the 

indirect effects to fish (based on habitat indicators) of alternative 4 would be approximately the 

same as alternative 2. Both alternatives would have insignificant effects on the measures of 

effects to salmonid habitat indicators that serve as proxy for effects to coho and Chinook salmon, 

steelhead trout, and rainbow trout. Therefore, alternative 4 and alternative 2 would have similar 

effects on these fish species. Effects from implementation of alternative 4 are the same as those 

described above for alternative 2 and summarized in table 56.

Alternative 4 may impact individual Chinook salmon, steelhead trout and resident rainbow 

trout but would not result in a trend toward federal listing or a loss of viability. Indirect effects 

are minimized because none of the measures for determining indirect effects of alternative 4 on 

salmon and steelhead/rainbow trout habitat indicators would be significantly affected.

For purposes of Section 7 of the Endangered Species Act, implementing alternative 4 may 

affect but is not likely to adversely affect Coho salmon.
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Cumulative Effects

Since there are no significant effects to salmon and steelhead trout at the stream segment or 7th

field watershed scale, alternative 4 would not increase cumulative effects at the 5th field

watershed or larger scales. Since loss of a few individual resident rainbow trout would not 

jeopardize the trout populations in any of the project streams, the effects of alternative 4 on 

resident rainbow trout would not be cumulative at the 7th field watershed or larger scales. 

Therefore, alternative 4 would have similar cumulative effects as alternative 2 and alternative 3.

Summary

Under the no action alternative, there would not be any direct or indirect effects. Therefore, there 

would be no cumulative effects. Under the no action alternative, potential for severe wildland 

fires would not be abated and the current risk of intense wildfire that could degrade watershed 

processes and aquatic habitats would continue.

Under the three action alternatives, there would be no direct effects to salmon and steelhead 

trout, and there would be no significant indirect effects to salmon, steelhead, and resident 

rainbow trout via effects to habitat indicators. A few individual rainbow trout could be entrained 

(killed or injured) at a few drafting sites under all action alternatives but this loss would not 

jeopardize the populations of rainbow trout in project streams. The action alternatives would not 

increase cumulative effects on salmon, steelhead trout, or resident rainbow trout. The action 

alternatives would slightly reduce the potential for severe wildfire effects that could degrade 

watershed conditions and aquatic habitats.

3.10 Botany and Noxious Weeds

3.10.1 Methodology

This section discusses effects on botanical species of interest, including special status species 

(federally listed, sensitive, other species of interest, rare plants) and noxious weeds. An office 

prefield review and a preliminary field review were conducted to determine if this project is 

within the range of any federally listed Threatened, Endangered or Proposed species, any 

Klamath National Forest Sensitive Species or other botanical species of interest, or if suitable 

habitat for any of these species is present within the proposed project area (USDA Forest Service 

2009g). The objective of this review was to determine if suitable habitats were present and if 

further surveys would be required. Surveys are not required for species for which suitable habitat 

is not present, and for which the project area is outside of the currently known range of the 

species. Past surveys for other projects within the project area, GIS layers, California Natural 

Diversity Database and past field visits in the project area were used to develop the list of 

species of concern for this project.

The Klamath National Forest has a list of noxious weeds that are being tracked and 

managed. A high priority weed species is one that is of important local management concern 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

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because of its currently limited distribution on the Klamath National Forest, highly invasive 

nature, and demonstrated potential to displace large geographic areas of native plant 

communities. Inadequate funding does not allow for treatment of all nonnative species, so 

emphasis is given primarily to high priority weed species. Information on weed presence and 

abundance was documented with field surveys for sensitive plants.

Numerous past field surveys have been conducted within portions of the Two Bit project 

area since 1980. Project-specific field surveys were conducted for Forest Service Sensitive 

Species during June - September of 2009 and are discussed in the affected environment section 

below. A qualified botanist familiar with the identification of the target species and their habitats 

conducted the surveys. Documentation included traverse routes marked on topographic maps. 

For all surveys, forms were completed which included the location of the unit, date of survey, 

seral stage and vegetation series, other habitat information, and a list of associated species. 

Project surveys and populations, if located, were documented on survey and site report forms. 

Field surveys conducted within the general area, and specifically for this project, were adequate 

to determine the presence of TES plant species.

Ground disturbance and alterations of light, moisture, and nutrient regimes within forest and 

associated plant environments can affect sensitive plants and their habitats through direct 

destruction of individual plants or through modification of habitat. Effects can be both long-term 

and short-term. Proposed activities may have cumulative effects on species viability if 

individually insignificant effects occur over a wide geographic range or on large numbers of 

sensitive plant populations.

The significance of management activities upon sensitive plant species viability depends 

upon many factors, including the size of known populations, the wider geographic range of 

known sensitive plant populations outside of the project area, and the degree of species 

sensitivity to short-term and long-term habitat modification.

Special Interest Areas (as defined in the Forest Plan) will also be described in this section. 

The alternatives are compared using the following indicators:

o Changes in sensitive species (sensitive plants, fungi and bryophytes) population 

viability

o Changes in occurrence of high priority noxious weeds

o Special Interest Areas

The information used in the preparation of this section comes from detailed analysis in the 

Botany and Noxious Weed Report (Rentz 2010a) and is available in its entirety in the project 

record. A Biological Assessment/Evaluation has also been prepared for this project (Rentz 

2010b) that provides additional detailed evaluation of sensitive plant species and is also available 

in the project record.
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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3.10.2 Affected Environment

Sensitive Species

There are no known populations or suitable habitat for plant species federally listed as 

Threatened, Endangered, or those proposed for federal listing within or near the project area. 

Therefore, federally listed and proposed species were not considered further for this analysis. 

Suitable habitat and/or confirmed populations of 13 sensitive species are present in the project 

area (table 57). Other species of concern are those angiosperms, bryophytes, lichens and fungi 

that were previously surveyed following the Survey and Manage standards and guidelines of the 

Northwest Forest Plan (USDA and USDI 1994). These survey and manage species are also listed 

as Sensitive Species on the Region 5 Sensitive Species List and are therefore included in the list 

below.

Table 57. Sensitive Species in the Two Bit Project Area, based on known occurrences or presence of 

suitable habitat

Species Code Common 

Name

Known to 

Occur in 

Project Area?

Field Survey 

Recommended Habitat

Vascular Plants

Cypripedium 

fasciculatum CYFA Clustered 

Lady’s Slipper

Yes – 5 known 

populations Yes

Moist sites on 

northern 

aspects in 

understory of 

mixed conifer 

forests

Cypripedium 

montanum CYMO2 Mountain 

Lady’s Slipper

Yes – 1 known 

population Yes

Moist sites on 

northern 

aspects in 

understory of 

mixed conifer 

forests

Eriogonum 

hirtellum ERHI7

Klamath 

Mountain 

Buckwheat

Yes – 20 known 

populations Yes

Open 

serpentine 

barrens and 

rocky outcrops

Eucephalis vialis EUV18 Wayside 

Astor No Yes

Forest 

openings and 

meadow 

edges; 

roadsides and 

other disturbed 

areas

Pedicularis howelli PEHO Howell’s 

Lousewort

Yes – 26 known 

populations Yes

Partial shade 

or forest 

openings on 

northern 

aspects in 

montane mixed 

conifer forests

Thermopsis 

robusta THRO4 Robust False 

Lupine

Yes – 2 known 

populations Yes Openings 

within forests 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

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Species Code Common 

Name

Known to 

Occur in 

Project Area?

Field Survey 

Recommended Habitat

and shrublands 

often found in 

disturbed areas 

along roads

Bryophytes

Ptilidium 

californicum PTCA5 Pacific 

Fuzzwort

Yes – 43 known 

populations Yes

Moist, mature 

mixed conifer 

forests on 

shaded 

aspects of host 

trees

Buxbaumia viridis BUVI2 N/A No

No, habitat 

evaluation only

Occurs on 

decaying 

stumps and 

logs in shady, 

humid locations

Fungi

Boletus 

pulcherrimus BOPU4

No; low 

potential in 

project area

Found on roots 

in humus of 

mixed conifer 

and hardwood 

trees in older 

coastal forests

Cudonia monticola CUMO2

No; low 

potential in 

project area

Found on 

coniferous 

needles and 

debris in older 

forests

Dendrocollybia 

racemosa

DERA5

No; low 

potential in 

project area

Found on 

rotting 

remnants of 

other fungi or in 

leaf mulch in 

forests

Phaeocollybia 

olivacea PHOL

No; moderate 

potential in 

project area

Older mixed 

forests

Sowerbyella 

rhenana SORH

No; low 

potential in 

project area

Duff, litter, 

mineral soil, 

woody debris 

or roots

Noxious Weeds

There are three high priority weed species within the proposed project area; Scotch broom (3 

known populations), meadow knapweed (14 known populations), and spotted knapweed (1 

known population). There are two moderate priority weeds, dyer’s woad (14 known populations) 

and star thistle (3 known populations).
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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Special Interest Areas

There are four botanical special interest areas located within the project boundary. 

The Indian Creek Brewer Spruce area is a 310 acre stand located in the northwest end of the 

project area and represents a healthy stand of Brewer Spruce, Picea breweriana, a species 

endemic to the Klamath Region. This special interest area is not within or adjacent to areas 

where ground disturbing activities are proposed and therefore will not be discussed further.

The Rhododendron Patch is the westernmost presence of a large patch of Rhododendron 

occidental. This special interest area is not within or adjacent to areas where ground 

disturbing areas are proposed and therefore will not be discussed further.

Poker Flat is a 100-acre are containing mid-elevation (4200 feet) serpentine meadow.

Several sensitive/rare species are located in this meadow including Castilleja elata, 

Pedicularis howellii, and Epilobium luteum. Proposed treatment in this area includes the 

removal of encroaching conifers and reduction of fuels. Proposed treatments are designed to 

maintain an open habitat and to promote plant diversity in the meadow

Port-Orford Cedar Management Area is a 29-acre area located north of Kelly Lake on road 

18N30. This area contains old growth Port-Orford cedar that differs from other populations 

due to its distance from the ocean and its higher elevation (4000 feet). There are two 

proposed treatment units that overlap the management area. Unit 22 is a plantation unit 

within the management area that would be thinned and Port-Orford cedar seedlings resistant 

to root rot would be planted. Unit 24 is a plantation with two small ends overlapping the 

management area that would also be thinned. A more detailed discussion of treatment in this 

area is discussed in the Vegetation section of this Chapter. Proposed project activities in this 

area are designed to enhance old growth characteristics and promote future health of the 

stand.

3.10.3 Environmental Consequences

Alternative 1- No Action 

Direct, Indirect and Cumulative Effects

Sensitive Plants

There would not be direct effects from the no action alternative because no treatments would 

occur. Not implementing the proposed action could increase the possibility of the project area 

experiencing high intensity wildfire, which could result in indirect adverse impacts to habitat for 

sensitive plants. These plant communities have evolved in a fire-dependent ecosystem (Sawyer 

and Thornburgh, 1977) so species would likely survive and respond positively to low or 

moderate intensity wildfire. High intensity wildfires were not typical in the Klamath Mountains 

of California historically and many native plant species are not resilient to impacts of high

intensity wildfire. There is a higher chance of death of native species individuals or populations 

from lethal soil temperatures that can kill underground reproductive structures. Indirectly, severe 

modifications in the forest canopy could be great enough to eliminate necessary habitat 

characteristics, such as shade, necessary for native and rare plant species to survive after high

intensity wildfire has occurred.
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The cumulative effect of increased potential for a high intensity fire with other past, present 

and future actions would be negligible to minor to sensitive species. Changes in species viability 

are not expected due to the distribution of habitats throughout each species’ range.

Noxious Weeds

The no action alternative would not increase suitable habitat for noxious weeds from project 

related activities. Suitable habitat for weeds decreases with full canopy closure. Lack of 

disturbance and maintenance of the canopy would continue to discourage the establishment of 

weeds, allowing native species to occupy the majority of habitat in the project area. Other factors 

that contribute to introduction and establishment of weeds would continue, such as offroad 

vehicle use, transport on vehicles traveling through the Two Bit project area, spread of existing 

roadside noxious weeds. Invasive plant susceptibility may be increased by wildfires.

Alternative 2 – Proposed Action 

Direct, Indirect and Cumulative Effects

Sensitive Species 

The potential for effects to sensitive species are summarized in table 58 below.

Table 58. Direct, indirect and cumulative effects to Sensitive Plants from implementation of 

alternative 2

Species Common Name

Proximity to 

Treatment 

Areas

Effects Sensitive Species 

Determination

Cypripedium 

fasciculatum

Clustered Lady’s 

Slipper

1 site near pole 

harvest unit; 

would be flagged 

and avoided

No direct/indirect 

effect due to 

harvest

No impact

Cypripedium 

montanum

Mountain Lady’s 

Slipper

3 miles from 

nearest 

treatment

No direct/indirect 

effect due to 

harvest

No impact

Eriogonum 

hirtellum

Klamath 

Mountain 

Buckwheat

3 sites near 

underburn units; 

would be flagged 

and avoided by 

handline 

construction

Minor 

direct/indirect/cumu

lative effect due to 

underburning

May impact 

individuals but is 

not likely to cause a

trend toward 

federal listing or a 

loss of viability

Eucephalis vialis Wayside Astor

May be present 

in project area; 

surveys will be 

completed prior 

to 

implementation 

No or minor 

direct/indirect 

effects due to 

harvest

May impact 

individuals but is 

not likely to cause a 

trend toward 

federal listing or a 

loss of viability

Pedicularis howelli Howell’s 

Lousewort

1 site near 

meadow 

enhancement 

unit; species 

favors 

Minor 

direct/indirect/cumu

lative effect due to 

hand thinning and 

underburning

May impact 

individuals but is 

not likely to cause a

trend toward 

federal listing or a 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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Species Common Name

Proximity to 

Treatment 

Areas

Effects Sensitive Species 

Determination

disturbance for 

germination

loss of viability

Thermopsis 

robusta

Robust False 

Lupine

0.5 miles from 

nearest 

treatment

No direct/indirect 

effect due to 

harvest

No impact

Ptilidium 

californicum Pacific Fuzzwort

Several sites 

within or adjacent 

to treatment 

units; project 

design features 

would minimize 

effects

Minor 

direct/cumulative

effects due to 

timber harvest in 

occupied units; no 

indirect or 

cumulative effects

May impact 

individuals but is 

not likely to cause a

trend toward 

federal listing or a 

loss of viability

Buxbaumia viridis N/A

All habitat 

outside of 

harvest units; 

project design 

features for 

riparian reserves 

would protect 

habitat

No 

direct/indirect/cumu

lative effect due to 

underburning in 

riparian reserves, 

minimized through 

project design 

features

No Impact

Fungi

Boletus 

pulcherrimus Fungi habitat is 

present within 

thinning units; 

project design 

features for other 

resources would 

protect habitat

Minor 

direct/indirect/cumu

lative effects due to 

commercial 

thinning and 

underburning; no 

change in 

population viability

May impact 

individuals but is 

not likely to cause a

trend toward 

federal listing or a 

loss of viability

Cudonia monticola

Dendrocollybia 

racemosa

Phaeocollybia 

olivacea

Sowerbyella 

rhenana

Project design features (see Chapter 2) have been developed to minimize the potential for 

adverse effects to sensitive species. Based on implementing these design features, effects would 

be minimal and would range from no impact to minor adverse direct/indirect and cumulative 

impacts, as shown in the table above. 

Cumulative effect determinations considered the number of sites affected in the project area 

in context with the known population size on the Forest and within the range of the species, to 

the extent possible.

Noxious Weeds

Overall, the proposed action would have limited risk of weed spread due to implementation of 

project design features (Chapter 2). However, alteration of habitat in the short- and long-term, 

and presence of known weed occurrences in the project area could provide opportunities for 

weeds to spread or become established. 

Weeds are commonly found on roadsides, in urban developments, in early-seral forested 

habitats and in open valleys. The presence of known weed occurrences in the project area could 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

205

provide opportunities for weeds to spread or to become established. Noxious weed habitat is 

created when soil is disturbed, competing vegetation is removed and bare soil is exposed. 

Noxious weeds have developed strategies that allow them to out-compete native species by 

germinating and occupying land faster than native species under environmental conditions that 

are not as well tolerated by native species. Project activities that result in ground disturbance 

may promote the spread of noxious weeds and increase the potential for noxious weed 

establishment. Commercial thinning would create openings under dense canopies; however, 

shade and duff levels would be retained and would inhibit germination of weed seeds. Weeds 

generally do not invade or persist in areas with moderate to high vegetative cover, which is 

expected to be retained as part of the project design. 

Some soil disturbance would occur through tractor yarding, skid trail development, road and 

landing construction and decommissioning, pile burning, and machine piling near landings. 

Construction of temporary roads causes the greatest habitat alteration that can allow invasion by 

weeds. Decommissioning these roads afterwards, and permanently closing or decommissioning 

other roads is likely to offset the increase in risk from the temporary road construction. The 

ground disturbance from reopening old landings or constructing new landings can create 

additional suitable habitat where introduced noxious weed seed can become established.

Landings, however, represent a small area of the total proposed for project activities. Project 

design features have been developed (see Chapter 2) that would minimize these effects.

Underburning can affect the introduction of noxious weeds by reducing protective duff and 

making bare mineral soil available or by releasing seeds. Studies have found that canopy cover is 

an important factor in the establishment of nonnative plant species as high canopy cover reduces 

available light. All the proposed treatment units would retain adequate overstory, understory, 

shrub and forb layers and area likely to suppress noxious weed invasions. Handpile and 

underburn fuels treatment methods pose a low risk since the treatment prescriptions are designed 

to retain adequate soil cover to prevent erosion. Retaining adequate soil cover will reduce the 

likelihood that new infestations can occur. 

Design features have been developed that would minimize the potential for direct and 

indirect effects. The potential for new weed site introduction through project activities would be 

reduced through equipment washing measures and the use of weed free seed and straw. This is 

expected to greatly reduce the amount of weed seed introduction into the site. Heavy equipment 

would be excluded from the existing weed sites or would be washed prior to leaving an infested 

site. This would prevent the transfer of seed into other areas in the project by equipment. Also, 

treatment of existing populations prior to ground disturbing activities would reduce the number 

of seeds within the soil seed bank and may also reduce the potential for vegetative spread. 

The post-project implementation weed monitoring and treatment would detect any new sites 

that may become established within the project area. Quickly treating these sites has a high 

probability of preventing new weed site establishment.
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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Alternative 3 – No Temporary Roads

Direct, Indirect & Cumulative Effects

Sensitive Species 

The primary difference between alternative 2 and 3 is the construction of temporary roads. 

Locations of sensitive plants or habitats occur in/near thinning treatment units and are not 

specifically affected by road construction. For this reason, the effects to sensitive species are the 

same as that described for alternative 2. 

Noxious Weeds

Changes in noxious weed distribution would be somewhat less for alternative 3 as that described 

for alternative 2 since no new temporary roads would be constructed; road construction and 

subsequent restoration can increase the presence and distribution of noxious weeds. 

Alternative 4 – Minimized Underburning

Direct, Indirect and Cumulative Effects

Sensitive Species

With the substantially less underburn treatments in alternative 4, there would be no ground 

disturbing activities within or adjacent to Klamath Mountain Buckwheat populations. Therefore, 

there would be no direct, indirect or cumulative effects to this species and no change to the 

species’ viability within the project area. Effects to all other sensitive species would be the same 

as those described for alternative 2 because project design features would minimize effects.

Mastication would occur under alternative 4 and not under the other alternatives, but mastication 

would occur within thinned units only; areas that are treated by mastication followed by 

underburning may result in greater impacts to fungi species. Concentrated fuels close to the soil 

surface would produce higher temperatures that could damage mycelium within the soil. Design 

features developed for specific units would also apply to alternative 4. 

Noxious Weeds

Mastication fuel treatment methods (or mastication in plantations) cause greater levels of ground 

disturbance; greater ground disturbance often results in an increase in nonnative species. 

However, mulch levels increase with mastication and this would reduce the germination of 

invasive species that require open, disturbed ground. 

Summary

If alternative 1 were implemented, indirect impacts to sensitive plants could occur, associated 

with the effects of high intensity fire, if a wildfire were to start in the project area. Impacts would 

range from determinations of ‘no impact’ to ‘may impact individuals but is not likely to cause a 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

207

trend toward federal listing.’ Suitable habitat for noxious weeds would not increase under 

alternative 1, although invasive plant susceptibility may increase with high severity fire.

The impacts to sensitive species from implementation of alternative 2, 3 and 4 would range 

from determinations of ‘no impact’ to ‘may impact individuals but is not likely to cause a trend 

toward federal listing.’ Klamath Mountain Buckwheat would not be affected by implementation 

of alternative 4; this is the only difference in effect to sensitive species among the alternatives. 

The overall level of risk related to noxious weeds, given the existing condition and proposed 

activities for alternatives 2, 3 and 4 is low. Project design features would limit the spread of 

noxious weeds under any of the action alternatives.

3.11 Terrestrial Wildlife

3.11.1 Methodology

This section includes discussion of terrestrial wildlife species federally listed as Threatened, 

Endangered, or species proposed for federal listing, and Sensitive terrestrial wildlife species, 

species of interest, late-successional reserves (LSR), Management Indicator Species (MIS), 

migratory birds and Forest Plan Management Area (MA) 6 (Managed Wildlife Area). Effects 

analysis is based on habitat changes and the potential for direct disturbance from proposed 

treatments. 

Field reviews, literature and research review, GIS analysis (forest MIS layer, NSO layers and 

others) and local expertise for the consideration of the direct, indirect and cumulative effects 

from implementation of proposed alternatives were used. Onsite project area field trips and 

review of forest service management indicator species habitat typing was used to analyze effects 

on forest sensitive species and management indicator species. NSO habitat was analyzed using 

the Klamath NSO habitat layer derived from the Habitat Land Management Plan Timber Type 

crosswalk for analysis done on the landscape scale (i.e. LSR, Management Area 6, Project Area 

and 7th field watershed areas). NSO habitat in the 0.5 mile radius core area and the 1.3 mile 

radius home range for all existing and new spotted owl activity centers were habitat typed by 

Timothy D. Burnett (USFS Biologist) using 1-meter resolution digital color imagery, GIS data 

and field confirmation. Field reviews of proposed treatment units were conducted in 2009 by 

biologists of the Yreka Fish and Wildlife Office and USFS. Suitable NSO within 0.5 mile of 

proposed treatment units was surveyed in 2009. Talus habitats in proposed treatment units were 

searched in 2009 for Siskiyou mountain salamanders and mollusks by multiple Forest Service 

specialists (biologist, soils, hydrology, and silviculture) while conducting field reviews of 

proposed units. No suitable talus habitat within the range of the Siskiyou salamander was 

identified. Goshawk surveys were conducted in 2009 in areas with historic Goshawk sightings. 

Sensitive species habitat was assessed using the NSO layer as a basis with field verification of 

habitat components.
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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The terrestrial wildlife analysis area consists of the Two Bit project boundary plus MA 6, a 

peregrine falcon territory and five NSO territories that extend beyond the project boundary. In 

total the wildlife analysis area comprises approximately 77,822 acres and is larger than the 

project area. 

Short term effects are those that occur within ten years of project implementation and long 

term effects are those that occur more than 10 years after project implementation. 

The alternatives are compared using the following indicators: 

Changes in TES species and species of interest habitat, trend toward federal listing or 

loss of population viability, and Critical habitat

MA 6 and LSR habitat changes 

Changes in MIS and migratory bird habitat 

The information used in the preparation of this section comes from detailed analysis in the 

Wildlife Report (Burnett 2010a) and is available in its entirety in the project record. A separate 

Biological Assessment/Evaluation has been prepared for this project (Burnett 2010b) which 

provides additional detailed evaluation of TES species as well as a separate MIS and migratory 

bird report; these reports were all used in preparation of this section and are all available in the 

project record.

3.11.2 Affected Environment

TES Species and Species of Interest

The Region 5 TES species list (USDA 2007) includes two terrestrial wildlife species federally 

listed as Threatened (NSO and marbled murrelet). The Fisheries section of this chapter discusses 

TES fish species with potential to be affected by proposed actions and the Botany and Noxious 

Weed section of this chapter discusses TES plant species with potential to be affected by 

proposed actions. The two Threatened wildlife species, NSO and marbled murrelet occur or have 

the potential to occur (based on available habitat) in the Two Bit analysis area and are discussed 

in more detail below. The Region 5 TES list (USDA Forest Service 2007a) also includes 19 

additional wildlife species designed as sensitive by the Forest Service. These species as well as

other species of concern were evaluated for the Two Bit project to determine which ones occur 

or have the potential to occur (based on available habitat) within the project area; several were 

excluded from detailed analysis. Table 59 includes all TES species with the potential to occur in 

the Two Bit project area.
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

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Table 59. Sensitive Species/Other Species of Concern in the Two Bit Project Area, based on known 

occurrences or presence of suitable habitat

Species Status Known to Occur in 

Project Area? Habitat

Birds

Northern spotted owl Threatened

Yes; 14 confirmed 

territories and designed 

Critical Habitat (CH) in 

the eastern portion of 

the project area; no 

treatments proposed in 

CH, so CH not 

considered further1

Old, forested habitats with 

multilayered canopies, 

large overstory trees, 

snags, and downed wood

Marbled murrelet Threatened

No, but designated 

Critical Habitat and 

Northwest Forest Plan

Zones 1 and 2 overlap 

the project area; no 

suitable nesting habitat 

occurs within 0.25 miles 

of proposed treatments

Nests primarily in 

coniferous forests from 

coastline to 52 miles 

inland

Bald eagle Sensitive

No known nest sites but 

have been observed 

feeding at Kelly Lake

Nests in old-growth 

components of forests 

within 1 mile of water

Northern goshawk Sensitive

Two historical nests 

sites that have not been 

confirmed in recent 

years; no designated 

goshawk management 

areas would be treated

Nests in dense, old 

forests in conifer trees

Willow flycatcher Sensitive

No known locations but 

potential habitat occurs 

along Indian Creek and 

its tributaries

Nests in river valleys or 

lush meadows in willows 

or other riparian 

tree/shrub species

Great grey owl Sensitive

No historic detections 

have been reported 

within the project area; 

suitable habitat occurs 

near the Klamath 

Siskiyou crest and Dry 

Lake Mountain

Mixed conifer and true fir 

forests adjacent to large 

montane meadows

Peregrine falcon

Species of Interest

(removed from list in 

2007 but analyzed 

here due to known 

presence)

Yes; one management 

area (nesting territory) 

occurs within the project 

area; thinning and 

burning treatments are 

proposed within this 

area

Prominent cliffs for 

nesting and perching, 

often near water

Mammals

Wolverine Sensitive

No, but home range 

overlap with project 

area is suspected 

based on available 

habitat and large home

range size

Use meadows, forests, 

riparian habitats and 

montane chaparral; often 

select dens in den logs, 

rocky outcrops and 

burrows in dense forests

Fisher Sensitive No, but suitable 

denning/resting habitat 

Mature, structurally 

complex conifer and 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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Species Status Known to Occur in 

Project Area? Habitat

is present mixed conifer/hardwood 

forests; require multiple 

rest sites that are often 

tree cavities, squirrel and 

raptor nests or brush piles

American marten Sensitive No; habitat potential is 

low in the project area

High elevation true fir 

stands; use large logs, 

snags and live trees for 

denning/resting

Townsend’s big-eared 

bat Sensitive

No, but occurrence is 

likely based on 

available habitat

Variety of wooded habitat 

often in association with 

caves for roosting; will 

use caves, large trees, 

mines, buildings and 

bridges for roosting

Red tree vole Species of Concern

Surveys conducted in 

general area with no 

detections; habitat 

potential is low in the 

project area

Older growth conifer 

forests with multi-layered 

canopies

Reptiles and Amphibians

Northwest pond turtle Sensitive

No, but potential habitat 

occurs along Indian 

Creek and its larger 

tributaries and in small 

ponds adjacent to 

project area

Aquatic habitats of ponds, 

lakes, streams; require 

emergent basking sites; 

use adjacent terrestrial 

habitat for overwintering 

and nesting

Foothill yellow-legged 

frog Sensitive

No, but potential habitat 

occurs along Indian 

Creek and its larger 

tributaries

Streams in a variety of 

vegetation types; requires 

shallow, slow moving 

water for breeding

Siskiyou Mountains 

salamander Sensitive

No, but potential habitat 

is suspected in 

proposed underburn 

treatment areas

Forested slopes with 

rocky soils and talus 

outcrops

Southern Torrent 

salamander Sensitive No, but potential habitat is present

Springs, seeps, and 

headwater streams and 

streamside forests

Invertebrates

Blue-gray taildropper 

(slug) Sensitive

Yes; surveys within 

suitable habitat will 

occur prior to project 

implementation to 

ensure treatment areas 

avoid any known sites

Forests with latesuccessional 

characteristics often with 

hardwoods; prefers moist, 

shady sites below leaf 

litter and duff

1 NSO CH applies to the 1992 and 2008 designation

Management Indicator Species

The full list of Klamath National Forest MIS was evaluated for applicability to this project. Table 

60 below is a subset of the larger Forest list and displays those MIS that have habitat within the

Two Bit project area with potential to be affected by proposed activities. Fourteen of the 25 

Forest MIS were not considered further due to a lack of habitat within the project area.
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

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Table 60. Management Indicator Species relevant to the Two Bit Project

MIS Forest Plan Habitat 

Association

Forest Plan

Recommende

d Level of 

Analysis

Reasons for Selection as 

MIS

Hardwood Species Association

Acorn 

woodpecker

Oak woodlands with associated 

large conifers

Forest Plan

and Project

Indicator for diversity of oak 

species and large conifers

Western gray 

squirrel

Mature hardwood and mixed 

hardwood/conifer

Forest Plan

and Project

Indicator for mature hardwood 

and mixed conifer/hardwood

River/Stream Species Association

Tailed frog Perennial montane streams with 

dense vegetation

Forest Plan

and Project

Indicator for water quality, in

stream woody debris, bottom 

substrate, flows and channel 

condition

American dipper Cold, swift, perennial streams Forest Plan

and Project

Indicator for water quality, 

instream woody debris, 

bottom substrate and flows

Northern water 

shrew

Riparian w/dense grass-forb 

cover

Forest Plan

and Project

Indicator of riparian vegetation 

including canopy, deciduous 

veg, and grass/forb.

Long-tailed vole Mesic habitats, dense riparian 

vegetation

Forest Plan

and Project

Indicator of riparian vegetation 

including canopy, deciduous 

veg, and grass/forb.

Snag Species Association

Red-breasted 

sapsucker

Mid- to late-seral mixed conifer 

and riparian deciduous

Forest Plan

and Project

Indicator of snags as a habitat 

element and of other species 

which depend on sapwells for 

food.

Hairy 

woodpecker

Riparian deciduous habitats with 

large trees for cavities

Forest Plan

and Project

Indicator of snags as a habitat 

element and of other species 

which depend on 

woodpeckers for cavities or as 

prey.

Vaux’s swift Late-successional forests with 

large hollow snags

Forest Plan

and Project

Indicator of large snags as a 

habitat element

Downy 

woodpecker Riparian deciduous habitats Forest Plan

and Project

Indicator of snags as a habitat 

element and for other species 

which depend on 

woodpeckers for cavities or as 

prey.

Pileated 

woodpecker

Late-successional coniferous 

forests

Forest Plan

and Project

Indicator of snags as a habitat 

element and for other species 

which depend on 

woodpeckers for cavities or as 

prey.
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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Migratory Birds

On December 12, 2008, a Memorandum of Understanding was signed by the U.S. Department of 

Agriculture Forest Service (USFS) and the U.S. Fish and Wildlife Service (FWS) to promote the 

conservation of migratory birds (MOU). Section D, 3 of the MOU says, “Within the NEPA 

process, evaluate the effects of agency action on migratory birds, focusing first on species of 

management concern along with their priority habitats and key risk factors.” For the Klamath 

National Forest, the migratory bird species of management concern are those bird species listed 

under the Endangered Species Act as Threatened or Endangered, those species designated by the 

Regional Forester as Sensitive Species and those species listed under Standard and Guideline 8-

21 through 8-34 of the Forest Plan as Management Indicator Species for project level 

assessment. Because several birds are included above as management indicator species and 

special status species, this section focuses primarily on those bird species not previously 

addressed in this document. 

In the early 1990s, habitats along portions of the Klamath River were systematically 

surveyed for songbirds. These surveys detected over 70 avian species including 31 neotropical 

migratory species. The Seiad Valley long-term MAPS station is located 12 miles east from the 

project area and has captured 25 species of neotropical migratory birds (Cuenca personal 

communication).

Studies of mixed conifer forests in the western United States indicate that structural 

diversity—habitat patchiness, layered canopy, well developed understory—are positively related 

to richness (a measure of species diversity) and abundance of avian species (Beedy 1981; Hagar 

et al. 1996; Siegel and DeSante 2003). Hardwood species, even small patches within a mixed 

conifer community can also positively influence the density of some species (Morrison and 

Meslow 1983).

The specific nesting and foraging requirements of the resident and neotropical migrants in 

the project area are diverse. Due to these diverse requirements, any management activities or 

wildfire would likely benefit some species while negatively affecting others. Therefore, impacts 

to avian communities or assemblages would be expected to vary by species, type of treatment, 

wildfire intensity, and time since disturbance.

Management Area 6 (Managed Wildlife Area)

MA 6 is approximately 6,600 acres in size and is located on the west side of Indian Creek on the 

Happy Camp Ranger District; a portion of which occurs within the Two Bit project area. MA 6 

was established to provide habitat for a broad range of species dependent on structural features 

common to late-successional vegetation. This area includes one Sensitive wildlife species, fisher 

(Martes pennanti). Within the Two Bit project area, open to dense stands of mid- to late-seral 

stage conifer habitat is present with inclusions of early seral stage vegetation. Approximately 30 

percent of MA 6 currently provides habitat that is suitable for fisher denning/resting (KNF 

LRMP). Management guidelines for MA 6 include 1) manage the area to provide for late-
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

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successional habitat; 2) manage habitat attributes, compatible with ecological processes, to 

provide moderate to high quality habitat conditions on the Forest as defined in the Fisher Habitat 

Capability Model (appendix I of the Forest Plan EIS1995), and; test and demonstrate the 

effectiveness of treatments for use in LSRs in an adaptive management approach. Underburning

and one acre of roadside pole thinning is proposed within MA 6. 

Late-Successional Reserves

Late Successional Reserves (LSRS) are land allocations established in the Record of Decision 

for Amendments to Forest Service and Bureau of Land Management Planning Documents within 

the Range of the northern spotted owl (NSO), also known as the Northwest Forest Plan (NWFP) 

(USDA Forest Service and USDI Bureau of Land Management 1994a). LSRs in combination 

with other land allocations and associated standards and guidelines were established to maintain 

a functional, interactive, late-successional and old-growth forest ecosystem. They were designed 

to serve as habitat for late-successional and old-growth-related species including the NSO.

Specific to NSOs, LSRs primary function is to support NSO population clusters. The Two Bit 

project area contains the Runaway LSR and six 100-acre LSRs, three of which have treatments 

proposed in portions of them.

Runway LSR

The Runway LSR is about 3,030 acres in size and encompasses portions of West Fork and Little 

South Fork of Indian Creek. The Runway LSR is also designated Marbled Murrelet Critical 

Habitat. Late-successional and mid-successional conditions account for about 68 percent of the 

area and plantations account for about 27 percent. Because many of the early- and midsuccessional stands within the LSR are young and healthy, they are expected to respond 

favorably to silvicultural treatments that reduce stand density. Some legacy late-successional 

components exist in mid-successional stands but generally large-diameter trees, snags, and 

downed woody debris are lacking. The dominant plant series in the LSR is mixed conifer – pine. 

Twelve percent of the Runway LSR has burned historically. This has allowed fuels to build up 

creating heavier fuel loadings and denser stands; fire risk is currently considered moderate.

Based on the Klamath NSO GIS habitat layer, the Runway LSR is 43 percent nesting/roosting 

habitat and 37 percent nonhabitat for NSO. Plantation thinning and underburning are proposed 

within the Runway LSR. 

100-Acre LSR

The 100-acre LSRs represent a network of stands of late-successional habitat that are to be 

retained in their natural condition with natural processes, such as fire, allowed to function to the 

extent possible (USDA Forest Service 1995b). Within the Klamath Province, past management 

practices have decreased the abundance of some types of old growth that are dependent on low 

intensity fires. Vegetation that is less fire resistant or less desirable for long term sustainability of 

late-successional habitat has become more widely distributed. Within and adjacent to the 100-
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

214

acre LSRs within the Two Bit area, the potential for stand replacing events has greatly increased.

There are six 100-acre LSRs within the Two Bit project area, and they total approximately 570 

acres (one is less than 100 acres). Plantation thinning and underburning are proposed within 

three 100-acre LSRs.

3.11.3 Environmental Consequences

Alternative 1- No Action 

Direct, Indirect and Cumulative Effects

Northern Spotted Owl, Marbled Murrelet and Critical Habitat, LSR, and MA 6 

These effects were combined under alternative 1 because all are expected to be similar under the 

no action alternative. All are associated with late-seral conditions and habitat characteristics.

Under alternative 1, no direct effects would occur because no proposed activities would 

occur in the project area. Activities designed to promote late-successional habitat would not 

occur. The indirect effects of alternative 1 include slow development of habitat for latesuccessional dependant species; tree density related mortality would continue and this would 

increase surface fuels over time. As described in the Forest Vegetation and Fuels section of this 

chapter, tree densities and basal area mortality would increase over time, crown fire potential 

would remain constant or would increase over time under both moderate and severe weather 

conditions, and surface fire intensity would increase under alternative 1. Therefore, alternative 1 

does little to promote the development of habitat for late-successional species and increases the 

potential for stand-replacing fire that would remove existing late-successional habitat.

Other Forest Sensitive Species/Species of Concern

Bald eagle

There are no direct, indirect or cumulative effects on bald eagles from the no action alternative 

because there are no know bald eagle nest sites located within the project boundary and no 

management activities would occur under alternative 1 to directly alter existing conditions.

Goshawk

Under the no action alternative no activities would occur and there would be no direct effects to 

goshawks. Indirect effects of increasing stand density and increasing wildfire risk (as described 

above and also in the Forest Vegetation and Fuels section of this chapter) increases the potential 

to remove existing and future goshawk habitat in the event of a high intensity wildfire start 

within the analysis area. With no thinning within the project area, suitable goshawk habitat 

would take longer to develop in the proposed treatment units than if thinning treatments were 

implemented. Thus, the no action alternative does little to promote the development of goshawk 

habitat and increases the potential for wildfire to remove habitat in the long term.
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

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Willow flycatcher

Under the no action alternative no activities would occur and there would be no direct effects to 

Willow flycatcher. It is unlikely that the amount of willow flycatcher habitat in the project area 

would substantially change in the short-term under alternative 1. However, in the event of a high 

intensity wildfire, many riparian areas could lose riparian shrub habitat that provides willow 

flycatcher habitat. Without treatment of meadows, meadows would eventually be replaced with 

conifers, reducing the habitat availability for willow flycatchers

Great grey owl

In the absence of large scale natural disturbance, it is unlikely that the amount of great grey owl 

habitat would change substantially in the short term. Nesting structure would continue to be 

recruited as winter storms in the higher elevation fir stands create broken-topped trees and snags. 

Foraging habitat may decline as conifer encroachment continues to reduce the size of natural 

meadows. Crown fire potential and expected tree mortality would increase over time with 

alternative 1 and this could degrade habitat over the long-term. 

Peregrine Falcon

There will be no direct, indirect or cumulative effects from the no action alternative because no 

changes would occur to peregrine falcon habitat.

Wolverine

There would be no direct effects to wolverine under the no action alternative because no 

management actions would be taken. It is unlikely that the amount of wolverine habitat in the 

project area would substantially change in the short-term. Fire behavior is expected to change in 

the long term, increasing the potential to remove existing habitat in the event of fire starts within 

the project area. Thus, the no action alternative does little to promote the development of or 

maintenance of wolverine habitat and increases the potential for wildfire to remove habitat in the 

long term. Wildfires that burn with mixed severity levels in a mosaic pattern could benefit 

wolverines by improving habitat for deer and elk. Increase in ungulate numbers could benefit 

wolverine especially in winter when more carrion would be available.

Pacific Fisher

Under the no action alternative thinning and fuel reduction activities would not occur and thus 

there would be no direct effects to the Pacific fisher under this alternative. However, high quality 

fisher habitat would be slow to develop and density related mortality would continue under the

no action alternative. As described above, the likelihood of a high intensity fire would increase 

over time with alternative 1. Therefore, the no action alternative does little to promote the 

development of fisher habitat and increases the potential for high intensity wildfire to remove 

existing fisher habitat.

American Marten

There are no historical records of marten in the analysis area. There have been no detections of 

marten in proximity of the project area and there have been only two detections in one area of 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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marten within the known range. The probability of martens occurring in the area is very low.

Thus there are no direct or indirect effects to American Marten

There are no cumulative effects from the no action alternative because there are no other known 

or reasonably foreseeable future projects that will occur within the project area.

Townsend’s big-eared Bat

Under the no action alternative there would be no direct effects to Townsend’s big-eared bats. 

The no action alternative would not promote development of late-successional habitat. Large 

roost trees would be slow to develop and density related mortality would continue, increasing 

surface fuels over time. The no action alternative does little to promote the development of large 

tree/roost habitat and increases the potential for fire to remove existing large snags.

Red Tree Vole

Under the no action alternative there would no direct effects to red tree voles and existing habitat 

conditions would persist over the short-term. Preferred habitat (older growth mixed conifer 

forests with multi-layered canopies) would not be promoted and would be slow to develop over 

the long-term; density-related mortality would continue and surface fuels would increase over 

time, increasing the potential for wildfire. 

Northwestern Pond Turtle

Under the no action alternative there would be no direct or indirect effects to northwestern pond 

turtles because habitat is expected to remain under the no action alternative.

Foothill yellow-legged frog

Under the no action alternative there would be no direct effects on foothill yellow-legged frogs. 

Existing habitat conditions is expected to remain under the no action alternative. In the absence 

of large scale natural disturbance it is unlikely that the amount of foothill yellow-legged frog 

habitat in the project area would substantially change in the near future. However, in the event of 

a high intensity wildfire, fire would burn through many riparian areas, potentially removing 

riparian habitat and high severity fires would increase sediment in the streams. Increase 

temperatures and sediment could adversely affect foothill yellow-legged frogs.

Siskiyou Mountains Salamander

There will be no direct effects to Siskiyou Mountains/Scott Bar Salamanders from the no action

alternative. In the absence of large scale natural disturbance it is unlikely that the amount of 

Siskiyou Mountains/Scott Bar Salamander habitat in the Project Area would substantially change 

in the near future. However, in the event of a fire, fire would burn through many of the talus 

areas, potentially removing overstory habitat. The effects of such a fire on Siskiyou Mountains 

Salamanders are unclear, as they have survived these types of fires in the past. In areas where the 

talus is shallow the lack of an overstory may cause heating and drying of the talus leading to the 

loss of the salamanders at those sites; however in areas with deep talus the salamanders would be 

expected to survive high severity fires and the loss of the overstory vegetation.
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Southern torrent salamander

There will be no direct effects on southern torrent salamanders as a result of the no action

alternative. Southern torrent salamander habitat in the action area would not change substantially 

in the short-term. However, in the event of a fire, fire would burn through many riparian areas, 

potentially removing riparian habitat and high severity fires would increase sediment in the 

streams. Increase temperatures and sediment could adversely affect southern torrent 

salamanders.

Blue-gray taildropper

There would be no direct effects to the blue-gray taildropper as a result of the no action

alternative. Indirect effects of the no action alternative could result in a high intensity wildfire 

that could burn through much of the habitat areas, potentially removing overstory habitat. The 

effects of a fire on blue-gray taildropper are unclear, as they have survived these types of fires in 

the past. In areas where the talus is shallow, the lack of an overstory may cause heating and 

drying of the talus leading to the loss of the mollusks at those sites; however, in areas with deep 

talus or other refugia the mollusks would be expected to survive high severity fires and the loss 

of the overstory vegetation.

Management Indicator Species 

Hardwood species association (Acorn woodpecker and Western gray squirrel)

There would be no direct effect to the hardwood species association as a result of the no action

alternative because no management actions would be taken. In the absence of large scale natural 

disturbance it is unlikely that the amount of hardwood habitat in the Project Area would 

substantially change in the near future. However, in the event of a fire, fire would burn through 

many of the hardwood areas, potentially removing hardwood habitat.

River/stream species association (Tailed frog, Cascade frog, American Dipper, Northern 

Water shrew and Long-tailed vole)

There would be no direct effects on the river/stream species association with the no action

alternative because no management actions would be taken. The no action alternative would not 

result in changes to the amount or quality of habitat for these river/stream associated species in 

the near future. As fuels continue to accumulate with increasing tree mortality wildfire behavior 

is expected to increase with wildfires of higher severity and intensity. Following high intensity 

fire, surface erosion is expected to occur and the potential for landslides increases. These 

processes would contribute sediment to streams potentially impacting turbidity and stream 

substrate. High intensity fire also has the potential to remove riparian vegetation and structure 

such as downed logs. A reduction in riparian vegetation has the potential to increase stream 

temperatures. The extent of these impacts is dependent upon fire intensity and size.

Snag associated species (Red-breasted sapsucker, Hairy woodpecker, White-headed woodpecker, 

Vaux’s swift, Downy woodpecker, Pileated woodpecker, Black-backed woodpecker)
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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There would be no direct effects created by the no action alternative because no management 

actions would be taken. Under the no action alternative indirect effects could result in several 

general patterns regarding fire behavior and fire induced tree mortality over time including 

constant or increased crown fire potential, increased surface fire intensity and constant or 

increased basal area mortality (see Fire and Fuels section in this chapter). These patterns may 

have some benefit to snag associated species by creating nesting and roosting structure and by 

increasing foraging opportunities in the short-term. However, uncharacteristic wildfire has the 

potential to remove existing habitat components such as large snags and down wood, to impact 

recruitment of these components over the long-term, and to substantially reduce or create large 

gaps in the canopy. The actual extent of these effects, whether beneficial or adverse, is dependent 

upon fire intensity and size. Fire behavior that is expected to continue to increase in severity and 

intensity over time would likely result in long-term impacts that would exceed short-term 

benefits for the snag associated species habitat.

Migratory Birds

Under the no action alternative, change in forest structure and composition at the landscape scale 

would be slow in developing. Thus, no significant changes in avian communities would be 

expected. In the event of a fire start within the project area, a high severity is likely (see Fuels 

section of this chapter).

Several studies have shown that some avian species respond favorably to wildfire events 

while the abundance of other species declines (Hutto 1995: Kotliar et al. 2002: Smucker et al. 

2005). Even following high severity fire, Smucker et al. (2005) found that an approximately 

equal number of forest birds increased in abundance as decreased. Thus, under the expected fire 

behavior described above, it is likely that there would be a shift in avian communities but not 

necessarily a decrease in forest bird abundance. Cavity nesting species and species that forage on 

insects and seeds would likely increase in abundance immediately following a fire event. Species 

such as western tanagers and hermit warblers that nest in the foliage of live trees and whose 

foraging strategy includes gleaning insects from foliage would likely decrease following 

moderate to high intensity fire. Over time, as the vegetation regenerates, the avian community 

would likely shift to species that nest in shrubs or are associated with grass understory, 

eventually becoming dominated by species associated with early-successional forests.

Alternatives 2, 3 and 4 

The three action alternatives (alternatives 2, 3, and 4) would have similar effects to NSO, 

Marbled Murrelet, Marbled Murrelet Critical Habitat, LSR, MA 6, Forest Sensitive Species, MIS 

and migratory birds because all three alternatives involve management of habitat and include 

similar implementation methods and project design features for terrestrial wildlife (see Chapter 

2). The alternatives vary primarily in the amount of treatment and not in the type of treatment, 

with a few exceptions. Therefore, all three alternatives are discussed together; where there are 

differences among the effects by alternative, these are noted.
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

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Direct, Indirect and Cumulative Effects

Project design features have been developed for terrestrial wildlife to minimize the potential for 

adverse effects; these would apply to any action alternative selected and are described in detail at 

the end of Chapter 2. 

Northern Spotted Owl

There are 14 historical NSO activity centers in the analysis area. All suitable NSO habitat and 

sites within 0.5 mile of treatment units were surveyed to protocol in 2009. Proposed activities 

that were within 0.5 miles of the historic sites were surveyed and NSOs were located at three of 

these sites in 2009. 

Approximately 62 percent of the project area contains NSO habitat (dispersal, foraging and 

nest/roost); of this, 49 percent is suitable (foraging and nest/roost, table 61). In general, 

nesting/roosting habitat occurs in small, widely scattered patches. Foraging habitat is more 

widely distributed and occurs in somewhat larger blocks. Of the NSO habitat available in the 

project area, approximately 12-13 percent would be treated under Alternatives 2 and 3 and only 

approximately 1 percent would be treated under alternative 4 (table 61). The vast majority of this 

treatment would be underburning (table 62). 

Table 61. Northern spotted owl habitat in the Two Bit project area

Habitat

Total 

Acres in 

Project 

Area

Percent in 

Project 

Area

Alt 2 

Percentage of 

Available 

Habitat 

Treated

Alt 3 

Percentage of 

Available 

Habitat 

Treated

Alt 4 

Percentage 

of Available 

Habitat 

Treated

Dispersal 8981 13 8 8 2

Forage 15578 23 11 10 2

Nest/Roost 17354 26 16 16 Less than 1

Total Available 

NSO Habitat 41913 62 13 12 1

Nonhabitat 23483 35 18 18 9

Off-Forest (land in 

Oregon outside of 

Klamath NF)

2236 3 0 0 0

Total All Acres 67632 100

Combining all proposed treatment acres (underburning and silvicultural), approximately 55 

percent of total treatment acres would occur in NSO habitat for Alternatives 2 and 3 and 24 

percent for alternative 4, due to the limited amount of underburning under alternative 4.
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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Table 62. Treatment types in northern spotted owl habitat, all action alternatives

Treatment

Alternative 2 Alternative 3 Alternative 4

Percent of Total 

Treatment 

Acres

Percent of Total

Treatment Acres

Percent of Total 

Treatment Acres

Dispersal Habitat 

Silvicultural Treatments (thinning and 

specialized treatments) 2 2 7

Underburning Only 6 6 Less than 1

Percent of Total Treatment 8 8 7

Foraging Habitat 

Silvicultural Treatments (thinning and 

specialized treatment) 3 2 11

Underburning Only 15 16 3

Percent of Total Treatment 18 18 14

Nest/Roost Habitat 

Silvicultural Treatments (thinning and 

specialized treatment) 0 0 0

Underburning Only 29 29 3

Percent of Total Treatment 29 29 3

Percent of Total Treatments in NSO 

Habitat 55 55 24

Nonhabitat

Silvicultural Treatments (thinning and 

specialized treatments) 17 16 75

Underburning Only 28 29 Less than 1

Percent of Total Treatment 45 45 76

Percent of Total Treatment 100 100 100

Proposed thinning and underburning treatments are considered activities that would degrade 

NSO habitat. Habitat degradation is a term used to describe the reduction in NSO habitat 

attributes (i.e. down woody debris, trees with mistletoe) but not elimination of these attributes to 

the extent that the habitat cannot be used by NSO. Degrading habitat still retains the quality 

(stand diversity, canopy cover etc.) so that it can continue to be used by NSO. There will be no 

NSO habitat downgrading (habitat removal or habitat category change) from treatments 

proposed in alternatives 2, 3, or 4. For the purposes of this analysis, degraded NSO habitat is 

separated by treatment type; degradation via underburning compared to degradation via thinning. 

These treatments result in different effects: commercial thinning would result in reduction in 

canopy cover and stand density of trees greater than 10 inches and tends to result in stands that 

are more uniform; underburning would result in much more variation and is less likely to result 

in a reduction in canopy closure and/or tree density of trees greater than 10 inches. Therefore, 

underburning, though still considered degrading, would have minimal effects to NSO habitat. No 

thinning is proposed for suitable nesting/roosting habitat; thinning would occur in foraging and 

dispersal habitat only. 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

221

Most plantation units proposed for treatment (except 103, 104, and 108-11) and natural 

stands proposed for treatment (except units 208, 234, 237 and 254) were considered suitable 

NSO foraging habitat; Units 208, 234, 237 and 254, 400, 300 and 301 were considered dispersal 

habitat. All pine plantation units and meadow treatment units were not considered suitable NSO 

habitat.

Effects of Thinning

Thinning is designed to promote the development of NSO habitat and would not remove 

important structural habitat components such as large diameter trees, hardwoods, snags, or 

downed wood. Trees infected with mistletoe may be removed, but prescriptions have been 

designed to ensure that this structural component will remain on the landscape. 

The prescriptions in stands that are suitable foraging habitat are designed to retain all NSO 

foraging habitat postharvest (i.e. 50 percent or greater canopy cover, thinning from below and 

retention of snags, down woody debris, hardwoods, variable density thinning, and tree species 

diversity). Table 63 displays units in foraging habitat proposed for thinning and how they would 

be treated. 
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Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

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Table 63. Proposed thinning in NSO foraging habitat 

Unit# Silvicultural

Treatment

Yarding

System Acres NSO Habitat

Type

Basal

Area

PreHarvest

AVG

Basal

Area

PostHarvest

AVG

Canopy

Closure

AVG

Effect Post

103 Thin Plantation Conventional Log Skidder/Tractor Endline 9 Foraging 188 120 >60 Degrade

104 Thin Plantation Conventional Log Skidder/Tractor Endline 7 Foraging 180 120 >60 Degrade

108 Thin Plantation Mechanical Harvester 11 Foraging 200 130 >60 Degrade

109 Thin Plantation Mechanical Harvester 5 Foraging 180 120 >60 Degrade

110 Thin Plantation Mechanical Harvester 13 Foraging 175 120 >60 Degrade

111 Thin Plantation Mechanical Harvester 17 Foraging 200 120 >50 Degrade

200 Thin Natural Stand Conventional Log Skidder/Tractor Endline 14 Foraging 240 160 >60 Degrade

201 Thin Natural Stand Mechanical Harvester 17 Foraging 300 160 >50 Degrade

203 Thin Natural Stand Mechanical Harvester 3 Foraging 160 120 >50 Degrade

205 Thin Natural Stand Cable 7 Foraging 400 190 >60 Degrade

209 Thin Natural Stand Mechanical Harvester 9 Foraging 240 180 >60 Degrade

212 Thin Natural Stand Mechanical Harvester 3 Foraging 380 180 >60 Degrade

213 Thin Natural Stand Cable 6 Foraging 420 240 >70 Degrade

214 Thin Natural Stand Cable 19 Foraging 280 160 >60 Degrade

216 Thin Natural Stand Cable 7 340 160 >60 Degrade
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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Unit# Silvicultural

Treatment

Yarding

System Acres NSO Habitat

Type

Basal

Area

PreHarvest

AVG

Basal

Area

PostHarvest

AVG

Canopy

Closure

AVG

Effect Post

Foraging

217 Thin Natural Stand Conventional Log Skidder/Tractor Endline 3 Foraging 220 140 >50 Degrade

218 Thin Natural Stand Conventional Log Skidder/Tractor Endline 3 Foraging 340 170 >60 Degrade

219 Thin Natural Stand Cable 15 Foraging 260 140 >50 Degrade

220 Thin Natural Stand Conventional Log Skidder/Tractor Endline 12 Foraging 240 140 >50 Degrade

225 Thin Natural Stand Mechanical Harvester 6 Foraging 220 140 >50 Degrade

226 Thin Natural Stand Conventional Log Skidder/Tractor Endline 8 Foraging 320 150 >50 Degrade

227 Thin Natural Stand Mechanical Harvester 10 Foraging 230 150 >60 Degrade

228 Thin Natural Stand Mechanical Harvester 9 Foraging 320 150 >50 Degrade

229 Thin Natural Stand Mechanical Harvester 5 Foraging 240 140 >60 Degrade

236 Thin Natural Stand Conventional Log Skidder/Tractor Endline 2 Foraging 260 160 >60 Degrade

238 Thin Natural Stand Mechanical Harvester 10 Foraging 360 190 >60 Degrade

243 Thin Natural Stand Cable 4 Foraging 280 120 >50 Degrade

253 Thin Natural Stand Mechanical Harvester 28 Foraging 240 140 >50 Degrade

255 Thin Natural Stand Mechanical Harvester 9 Foraging 240 160 >60 Degrade
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

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Dispersal habitat would be retained postharvest. Prescriptions are designed to increase 

growth in mid-seral and younger trees left after treatment, increasing the development of lateseral conditions sooner than untreated stands. 

Thinning may affect NSO prey species during and immediately following treatment; 

However, where thinning treatments similar to those proposed in this project have been applied, 

effects to small mammal species diets and small mammal biomass have been shown to be 

insignificant or of short duration (Monroe and Converse 2006; Manning and Edge 2008; Suzuki 

and Hayes 2003).

Thinning plantations is expected to open stands to allow foraging habitat conditions to 

develop sooner than if no treatment took place. Many plantations are currently too dense to allow 

for NSO foraging. By thinning stands, NSO would have more accessible habitat to forage in and 

move through. Prey populations may increase due to the creation of openings and burn 

treatments that would increase grasses and forbs for prey species. The majority of plantations 

within the project area have little to no snags, coarse woody debris or trees over 20 inches dbh; 

what is intact would remain so following treatment and in some cases may increase these 

components. 

A home range analysis for all NSO home ranges in the analysis area was done to evaluate the 

proximity of treatments to known nest sites. Activities within 0.5 miles and 1.3 miles of NSO 

activity centers were calculated. Many of the home ranges do not contain recommended 

sufficient amounts of suitable nesting/roosting habitat. However, this project would not thin any 

existing nesting/roosting habitat; underburning only is proposed for nesting/roosting habitat and 

is not expected to reduce the quality of the habitat for nesting/roosting. In addition, in the longterm, both thinning and underburning treatments proposed for foraging and dispersal habitat 

would also contribute to the development of future suitable nesting/roosting habitat. Short term 

effects on prey species within home ranges are expected to minimal with small mammal 

populations recovering in 6 months to 1 year from the date of treatment (Manning and Edge 

2008; Suzuki and Hayes 2003).

Operational trees are those that are cut for road and landing construction and clearing for 

yarder corridors. Placement of yarding corridors would be such that patches of large trees and 

snags would be avoided whenever possible; however in some cases due to yarder anchors and or 

geographical conditions corridors may need to be placed where the cutting of an individual large 

tree may be required. Large trees felled for safety or operational reasons may be removed. The 

removal of large trees for this reason would be uncommon and incidental and therefore, effects 

to NSO would not be measurable. Down wood greater than 20 inches diameter averaged 4.9 

pieces per acre across units surveyed (Walters 2010). Amounts of down wood vary greatly by 

units surveyed ranging for 0 to 14 pieces per acre. Additionally, where stand conditions permit, 

incorporation of recommendations for snags and down wood would ensure that these 

components are retained in the landscape (USDA Forest Service 1994, pgs 4-25 & 4-39).
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

226

Alternatives 2 and 4 propose the same level of NSO foraging habitat degradation via 

thinning. Alternative 3 proposes somewhat fewer acres of thinning in foraging habitat. 

Underburning in NSO nest/roost would be approximately the same for alternatives 2 and 3 but

substantially less under alternative 4. Underburning would have minimal impact to suitable NSO 

nesting/roosting habitat. Alternative 4 is the only alternative that proposes mastication. 

Mastication however would not result in any additional impacts to NSO habitat because it would 

occur in postharvest thinning units only; it would not further reduce canopy cover or stand 

density.

Temporary Road Construction, Existing Road Reopening and Landings

Approximately 0.5 miles (or 1 acre) of temporary road is proposed for construction under 

alternative 2 in NSO foraging habitat. All other temporary road construction and reopening 

would not occur within NSO habitat. Openings created by road construction would be linear and 

at most 20 feet wide. Existing canopy in mid-and late-seral forest would cover all or most of the 

openings. Road clearings may have short term effects on small mammal movements and 

occupation of the road surfaces. All temporary roads would be hydrologically restored after use 

and should be covered by leaf and needle drop and start accumulating down wood within one 

year of their closure. Openings of this size are common in NSO habitat and would have minimal 

short-term negative effects.

New landings proposed within tractor-thinned units are expected to average approximately 

0.33 to 0.50 acres in size, and occasionally up to 0.75 acres in size to accommodate slash piles 

from tree tops, while landings for cable units are expected to average 0.1 acre. Landings in 

tractor units would remove approximately 18 acres of NSO foraging habitat. Landing for cable 

units would remove approximately 6 acres of foraging habitat. Six new landings would be 

constructed within 0.5 miles of a known NSO activity center. Of these, three are proposed in 

plantations and therefore would not be removing suitable NSO habitat. Three cable landings are 

within the same NSO 0.5 mile activity center (core area) and are expected to remove 

approximately 0.3 acres of foraging habitat from that activity center’s core area.

Prescribed burning

Prescriptions for underburns are designed to minimize damage to the existing habitat. To ensure 

the distribution of northern spotted owl prey will not be significantly impacted by fuel reduction 

treatments, project design features will limit the amount of northern spotted owl habitat that can 

be burned annually to less than 50 percent of the suitable habitat within a northern spotted owl 

core area and home range. However, the area within a fire perimeter that actually burns is highly 

variable (Sugihara et al. 2006). Unburned areas within the fire perimeter may act as refugia for 

some small mammals (Lyon et al. 2000). 

Underburn monitoring data collected by the Forest Service from 1998 to 2005, indicates that 

an average of 31 percent of the area within an underburn remains unburned post treatment 

(USDA Forest Service 2005b). Therefore, the actual number of acres burned within a northern 
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227

spotted owl core area or home range is expected to be considerably lower than 50 percent of the 

core and home range.

Prescribed fires can influence prey communities via consumption and creation of snags and 

down wood and effects on understory vegetation. Several important prey species are associated 

with decaying standing and down wood structures, including flying squirrels and voles. 

Prescribed fires typically consumes some of the existing dead wood in a stand, which could 

negatively affect these species; however, low intensity burns do not normally burn all areas 

within the fire and are expected to leave hard down wood and snags in place, providing refugia 

for small mammals. A number of studies have found strong support for positive low severity 

prescribed fire affects on deer mouse densities (Kaufman et al. 1990; Jones 1992) an important 

prey species for northern spotted owls. However, in a study conducted in mixed conifer forest of 

the Sierra Nevada Mountains, deer mice densities did not change significantly as a result of 

prescribed fire and overall small mammal biomass did not change significantly for three years 

following spring and fall prescribed burns (Monroe and Converse 2006). Other effects described 

as, year effects, (weather and food availability), had a greater influence on deer mice and total 

small mammal biomass than did the prescribed fire effects (ibid). Therefore, it is expected that 

low severity and intensity prescribed fires will have minimal short tern negative effects on small 

mammal biomass.

In the long term, fuel reduction treatments are expected to have benefits to northern spotted 

owls by reducing fuels to a level that would result in an acceptable fire behavior and post fire 

stand condition. Fuels treatments will generally reduce crown fire potential and maintain a 

surface fire type and reduce predicted stand mortality in the event of a wildfire start. The area 

susceptible to some type of crown fire in the project area would be reduced and the area that 

would have control problems (flame length greater than 8 feet) would be reduced (Fuels section). 

These factors indicate that stands will be more resistant to large scale fires but will burn with 

sufficient intensity to create small openings within forested habitat. This type of pattern, would 

create a mosaic of stands in different successional stages, and be consistent with patterns under 

historic fire regimes. This pattern of successional stages would likely benefit northern spotted 

owls by creating horizontal diversity of habitat across the landscape.

Additional projects that are ongoing that are within the project area would not remove NSO 

habitat. These projects are generally small and were evaluated for NSO effects and project 

design features were developed to minimize the likelihood of adverse effects. Cumulative effects 

are considered minor for this reason. 

NSO Summary 

For purposes of Section 7 of the Endangered Species Act, implementation of alternatives 2, 3 or 

4 may affect, but is not likely to adversely affect NSO. This determination is based on the above 

detailed analysis and the following key points: 1) suitable (foraging and nest/roost) NSO habitat 

would only be degraded; no habitat would be removed or downgraded; 2) none of the existing 

dispersal habitat within the project area would be removed; 3) effects to prey species would be 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

228

minimal and of short duration; and 4) project design features would minimize the likelihood that 

NSOs would be killed or injured during project implementation or that normal breeding 

behaviors would be disrupted by noise or smoke. Critical Habitat would not be treated and 

therefore would not be affected by implementation of either alternatives 2, 3 or 4.

Marbled Murrelet and Critical Habitat 

No nesting habitat for marbled murrelet was identified in or within 0.25 miles of any proposed 

thinning units under alternatives 2, 3 or 4, based on multiple site visits. At inland sites (12 to 37 

miles from the coast) in southwestern Oregon and northern California, murrelets were absent 

from dry stands where platforms were abundant but moss was scarce (Dillingham et al. 1995, 

Hunter et al. 1998). In the Two Bit project area, most of the treatment units are located in the 

Klamath mixed conifer vegetation association; this is drier and is less likely to contain mosscovered limbs. Moss-covered limbs are the primary nesting substrate used by marbled murrelets. 

Some units have large trees with large limbs but no moss- covered limbs were observed. Units 

are also in the upper third of the slope and away from major creeks and rivers where marbled 

murrelets generally are found nesting. 

The Runway LSR is designated Marbled Murrelet Critical Habitat Unit CA-10a. Only 

approximately 4 percent (120 acres) of the 3,000 acre Critical Habitat Unit (Runway LSR) 

would be thinned under alternatives 2, 3 and 4 and this thinning would be in existing plantations. 

These plantations do not provide the primary constituent elements for Critical Habitat and thus 

primary constituent elements would not be removed or affected by proposed treatments. All of 

these plantations are approximately 50 years old. None of the thinning is in marbled murrelet 

nesting habitat. Thinning is designed to increase growth of trees creating trees with large limbs 

that could provide suitable nest structure for marbled murrelets in the long-term. Thinning would 

reduce the probability of stand-replacing fires. 

In alternatives 2 and 3, underburning is planned for approximately 40 percent (1,200 acres) 

of the Critical Habitat Unit. Under alternative 4, no underburning would occur in Critical 

Habitat. For alternatives 2 and 3, this area would not be underburned in one year and is expected 

to take several years to completely burn the designated area. Underburning would decrease the 

probability of stand replacing fires and is expected to create a more fire resilient ecosystem.

Underburns would not remove or affect any of the primary constituent elements for MAMU 

critical habitat.

There are no cumulative effects because there are no foreseeable future projects within 

Critical Habitat.

Marbled Murrelet Summary 

For purposes of Section 7 of the Endangered Species Act, implementation of alternatives 2, 3 or 

4 would have no effect on marbled murrelets or marbled murrelet Critical Habitat. This 

determination is based on the analysis above and the following key points: (1) no marbled 

murrelet nesting habitat would be removed or downgraded; (2) no marbled murrelets have ever 
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been found nesting in the project area; (3)marbled murrelets are unlikely to be found nesting in 

the project area due to the lack of suitable nesting habitat; (4) there is no suitable nesting habitat 

within 1⁄4 mile of proposed treatments; (5) Proposed treatments would not remove primary 

constituent elements of marbled murrelet Critical Habitat; and (6) proposed thinning and 

underburning would be beneficial to marbled murrelet Critical Habitat.

Other Sensitive Species/Species of Concern

Bald Eagle

There are no direct, indirect or cumulative effects from action alternatives 2, 3 or 4 because there 

are no known nest sites, and therefore no potential to affect bald eagle habitat or individuals.

Northern Goshawk

No goshawk management areas are proposed for treatment within the project area. There are two 

historic “nest” locations within the project area. These two areas were surveyed in 2009 with no 

detection of Goshawks and will be surveyed again in 2010. There are areas of unsurveyed 

suitable goshawk habitat within the project area. 

Nesting/roosting NSO habitat was used to quantify amount of suitable nesting habitat for 

goshawks. Natural stands were considered suitable nesting habitat for goshawks, while 

plantations were considered unsuitable nesting habitat. There is approximately 17,350 acres of 

suitable northern goshawk nesting habitat within the project area. Approximately 2,975 acres (17 

percent of project area) of suitable goshawk nesting habitat would be degraded (see NSO section 

above for the definition of degraded) based on alternatives 2, 3 or 4 proposed treatments. The 

majority of this would be from underburning. Roughly 2,710 acres of nesting habitat would be 

underburned only.

No goshawk habitat would be removed and treatments within plantations would improve 

goshawk foraging in the short-term and nesting habitat in the long-term (greater than 10 years). 

Habitat in historic goshawk nest sites is currently being encroached on by young conifers and 

hardwoods, which, if left untreated, would reduce the value and utility for goshawks. 

Precommercial thinning would reduce the encroaching understory vegetation that would then be 

burned, opening up the understory, and improving foraging habitat. Underburning would also 

reduce potential fire severity, thus protecting the existing stand structure in the short term from 

stand replacing fires.

In the long-term, fuel reduction treatments are expected to have substantial benefits to 

goshawk by reducing fuels to a level that would result in an acceptable fire behavior and post 

fire stand condition. Fuels treatments would generally reduce crown fire potential and maintain a 

surface fire type and reduce predicted stand mortality in the event of a fire. Treated stands would 

be more resistant to large-scale fires but would burn with sufficient intensity to create small 

openings within forested habitat. This burn pattern would create a mosaic of stands in different 

successional stages, consistent with patterns under historic fire regimes. This pattern of 
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successional stages would benefit goshawk prey species by creating horizontal diversity of 

habitat across the landscape.

Implementation of alternatives 2, 3 or 4 may impact individual goshawks but would not 

likely result in a trend toward federal listing or a loss of viability. This determination is based on 

the discussion above, as summarized in the following key points: (1) no goshawk management 

areas would be treated within the project area; (2) no goshawk habitat would be removed; (3) 

suitable goshawk habitat would be treated, but this would primarily be through underburning: 

treatments which would downgrade habitat only; (4) the small amount of thinning proposed in 

goshawk habitat would downgrade habitat only and would be focused on removal of understory 

vegetation which may improve goshawk habitat over the long-term; (5) thinning in plantations 

(unsuitable habitat) could result in development of goshawk habitat over the long-term; (6) fuels 

treatments would reduce the possibility of stand replacing fires that have the potential to 

adversely affect goshawk habitat; and (7) project design features have been developed (table 12) 

to minimize the likelihood of adverse impacts. 

Cumulative effects to goshawks would not be measurable. Because direct/indirect effects 

from implementing this project under any of the action alternatives as described above would be 

minor, adding these effects to those of past and ongoing projects would also be minor. Recent 

past and ongoing projects were evaluated for effects to wildlife, including goshawks, and 

protective measures are implemented for these other projects to minimize the potential for 

adverse impacts. No additional future projects are anticipated in the project area. For this reason, 

cumulative effects would be minimal. 

Willow flycatcher

Habitat for willow flycatchers occurs only in riparian reserves and meadow treatment areas.

Approximately 13 acres of proposed meadow restoration/enhancement under alternatives 2, 3 

and 4 could affect willow flycatchers. Underburns are also proposed within riparian areas that 

have suitable willow flycatcher habitat. The riparian reserves with suitable flycatcher habitat are 

small and patchy and are located adjacent to the wetted edge that is unlikely to have much effect 

from underburning. Implementation of project design features and the aquatic conservation 

strategy for the project (see appendix D) would reduce negative impacts from management 

within riparian reserves and is expected to provide long-term benefits to willow flycatcher 

habitat. 

Spring underburns that back down into riparian reserves may directly affect some willow 

flycatcher habitat. Willow and alder habitat are located in the area directly affected by the water 

in the riparian reserves, these areas will be wet with green herbaceous vegetation and willow and 

alder will also have high live fuel moistures in the spring. It is highly unlikely that these areas 

would burn during the spring nesting season, however smoke may inundate nesting habitat 

resulting in nest abandonment. Treatment of riparian zones with underburns would reduce the 

fuels in these areas. Because underburns are designed to imitate low intensity fire and shrubs 
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such as willow and alder often become established following a disturbance (Petrides 1992), any 

impacts to willow flycatcher habitat are expected to be short term.

Cumulative effects would not be measurable. Because direct/indirect effects from 

implementing this project under any of the action alternatives as described above would be 

minor, adding these effects to those of past and ongoing projects would also be minor. Recent 

past and ongoing projects were evaluated for effects to wildlife, including flycatchers, and 

protective measures are implemented for these other projects to minimize the potential for 

adverse impacts. No additional future projects are anticipated in the project area. For this reason, 

cumulative effects would be minimal.

Because fuel reduction treatments may remove habitat or disrupt breeding activities, 

implementation of alternatives 2, 3 or 4 may impact individuals, but is not likely to result in a 

trend toward federal listing or a loss of viability for willow flycatcher. Due to the substantial 

reduction in underburning under alternative 4, the potential for adverse impacts to willow 

flycatchers is substantially less for alternative 4 than for alternatives 2 or 3. 

Great Grey Owl

Great grey owl habitat will benefit from meadow treatments proposed under alternatives 2, 3 and 

4. Proposed underburning would increase prey availability and the creation of small canopy 

openings would be beneficial for great grey owl foraging. Although no great grey owls have 

been observed in the project area, it is possible that noise disturbance during implementation 

could disturb owls during their nesting period.

Cumulative effects would not be measurable. Because direct/indirect effects from 

implementing this project under any of the action alternatives as described above would be 

minor, adding these effects to those of past and ongoing projects would also be minor. Recent 

past and ongoing projects were evaluated for effects to wildlife, including great gray owls, and 

protective measures are implemented for these other projects to minimize the potential for 

adverse impacts. No additional future projects are anticipated in the project area. For this reason, 

cumulative effects would be minimal.

Based on this, implementation of alternatives 2, 3 or 4 may impact individuals, but is not 

likely to result in a trend toward federal listing or loss of viability of the great grey owl.

Peregrine Falcon

Treatments are proposed within 1.5 miles of a peregrine falcon eyrie and would occur within the 

4,640 acre peregrine falcon management area. Approximately 70 acres of plantation thinning and 

280 acres of underburning (for a total of approximately 8 percent of the management area) 

would be implemented under alternatives 2, 3 or 4. Silvicultural prescriptions in these units are 

designed to promote late-successional forest and would maintain large trees, snags and down 

wood. Maintenance of these structures would sustain populations of cavity nesting birds that are 

prey for peregrine falcons. There may be short-term reduction in some prey species; however, 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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there would be long-term benefits of increased tree diameter and thus, larger snags, and in the 

event of a fire start, reduced fire severity in the thinned and underburned treatment units.

Silvicultural prescriptions for the stands in the peregrine falcon management area are 

designed to develop large trees and snags sooner than untreated stands. Fuels treatment in the 

area would help reduce the possibility of stand replacing fires, thus protecting the existing 

habitat. As a result, alternatives 2, 3 and 4 would have short-and long-term benefits for the 

peregrine falcon, no direct, indirect or cumulative adverse effect.

Wolverine

Direct effects of noise disturbance from use of heavy equipment during project activities can 

lead to displacement of animals or disruption in breeding or feeding activities. Noise disturbance 

related to proposed treatments would be short-lived and last for one season in any given location. 

Given the natural low densities of wolverines, their tendency to avoid human activities, and the 

low likelihood of their presence in the project area, it is expected that disturbance or disruption 

of normal breeding/feeding activities would be unlikely. These activities would have 

inconsequential effects on individuals and no overall effect on populations.

Direct effects on mid- and late-successional habitat would occur through commercial 

thinning, landing construction, and temporary road construction. Commercial thinning in the 

Project Area is designed to retain large trees, snags and large logs; however canopy cover will be 

reduced. Decrease canopy cover should be inconsequential in the ability of the treated areas to 

provide habitat for wolverines. Proposed actions would remove some large trees and create small 

openings in the forest canopy, which may degrade suitable habitat in the short term. In a study in 

Montana, no differences in movements, habitat use, or behavior was noted between wolverines 

occupying logged areas vs. unlogged areas (Hornocker and Hash 1981). 

For purposes of this analysis, NSO nesting/roosting habitat was used as a proxy for suitable 

wolverine habitat because nesting/roosting habitat has large down woody debris that is 

associated with wolverine use. Underburning is the only treatment proposed in NSO 

nesting/roosting habitat. Approximately 16 percent of the available nest/roost habitat would be 

treated with underburning in alternatives 2 and 3 and less than 1 percent would be treated with 

underburning in alternative 4 (table 62). 

Indirect effects from thinning and associated fuels treatments may include beneficial effects 

to prey species habitat. Creating small openings in treated stands, protecting large hardwoods 

and reducing ladder fuels and ground cover may improve habitat for deer, elk and small 

mammals. Thinning and fuels treatments may temporarily reduce snag and large down wood, 

decreasing resting and denning habitat and habitat for small mammals. In addition, fuels 

treatments will reduce the fire behavior potential thereby reducing the risk of loss of forested 

habitat to catastrophic wildfire. Silvicultural prescription will leave suitable habitat for 

wolverines and may increase deer, elk and small mammal numbers increasing the food supply. 
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233

The moderate to heavy existing road density in the project area and the human use that is 

associated with these roads make it unlikely wolverines currently use the project area. The 

project will not increase road densities within the project area.

Cumulative effects would not be measurable. Because direct/indirect effects from 

implementing this project under any of the action alternatives as described above would be 

negligible, adding these effects to those of past and ongoing projects would also be negligible. 

Recent past and ongoing projects were evaluated for effects to wildlife, including wolverines, 

and protective measures are implemented for these other projects to minimize the potential for 

adverse impacts. No additional future projects are anticipated in the project area. For this reason, 

cumulative effects would be minimal.

Because wolverine habitat would not be removed under alternatives 2, 3 or 4 and the 

presence of wolverines is unlikely in the area, implementation of alternatives 2, 3 or 4 would 

have no effect on the California wolverine.

Pacific Fisher

For purposes of this analysis, NSO nesting/roosting habitat was used as a proxy for fisher 

denning/resting habitat because NSO nest/roost habitat contains features that are associated with 

fisher use (large decadent trees, large downed woody debris, etc.). As shown in table 62,

approximately 17,354 acres of suitable denning/resting habitat occurs in the project area (NSO 

nesting/roosting habitat in the table); only 16 percent of this would be treated under alternatives 

2 and 3 and less than one percent would be treated under alternative 4. The only treatment 

proposed under alternatives 2, 3 or 4 in denning/resting habitat would be underburning. 

Thinning would not be conducted in fisher denning/resting habitat. Thinning prescriptions in 

plantations and natural stands outside of denning/resting habitat are designed to maintain and 

promote the development of fisher habitat by creating conditions that would allow for the 

development of large diameter trees, snags, and downed wood. Trees infected with mistletoe 

would be removed, but silvicultural prescriptions have been designed to ensure that this 

component will remain on the landscape. 

Thinning and fuel reduction treatments have the potential to impact fisher prey species by 

removing or reducing the availability of important habitat components. However, where thinning 

treatments similar to those proposed in this Project have been applied, effects to small mammal 

species commonly found in fisher diets have been shown to be insignificant or of short duration 

(Carey and Wilson 2001; Suzuki and Hayes 2003). Underburns carried out at very low and low 

intensity do not normally burn all areas within the fire and will leave hard down wood and snags 

in place, providing refugia for small mammals. In a study conducted in mixed conifer forest of 

the Sierra Nevada Mountains, overall small mammal biomass did not change significantly for 

three years following prescribed fire (Monroe and Converse 2006). Other effects described as 

year effects (weather and food availability), had a greater influence on total small mammal 

biomass than did the prescribed fire effects (Ibid). 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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Following proposed treatments under alternatives 2, 3 and 4, the project area would be more 

resilient if a wildfire were to start in the area; the risk of a high intensity fire would be reduced 

(see Fuels section in this chapter). A more natural fire regime would include fires that would 

burn with sufficient intensity to create small openings within forested habitat. This burn pattern 

would create a mosaic of stands in different successional stages, and be consistent with patterns 

under historic fire regimes. This pattern of successional stages would likely benefit fisher by 

creating horizontal diversity of habitat across the landscape. 

Openings created by the yarding corridors will be narrow and will be covered or partially 

covered by canopies of adjacent trees. These openings will be linear in nature and smaller than 

many natural openings that occur in mid-and late-successional forest. Temporary roads, landings, 

and yarding corridor construction however may remove some large trees suitable for denning or 

resting. Openings created by temporary roads and yarder corridors are not expected to be barriers 

to fisher movements. No temporary roads or landings are located in suitable fisher 

denning/resting habitat.

Direct effects of noise disturbance from use of heavy equipment during project activities can 

lead to displacement of fisher or disruption in breeding/foraging activities. Noise disturbance 

would be relatively short-lived and last for one season in any given location. Given the natural 

low densities of fishers, based on survey data, it is expected that disturbance or disruption of 

normal foraging activities will be minimal. In addition, fishers are highly mobile animals and 

would likely avoid areas of human activity during foraging. The human activity during Project 

activities may disrupt forage or breeding behaviors of individuals. 

Underburns will be carried out in a manner that keeps burns at low severity levels, which 

may remove some snags and down wood. Snags and down wood lost to under burns will likely 

be replaced by trees killed by the underburns. Burn prescriptions are designed to retain snag and 

down wood at the amount recommended in the Forest Plan (1995a) where stand conditions 

permit. Fuel reduction treatments are not expected to have a significant impact to the important 

structural components of fisher habitat. Because fisher have a diverse diet and may switch prey 

in response to changing density (Zielinski et al. 1999), they would likely find abundant prey in 

the event of a short-term reduction in some prey species following a prescribed fire. 

Cumulative effects would not be measurable. Because direct/indirect effects from 

implementing this project under any of the action alternatives as described above would be 

negligible, adding these effects to those of past and ongoing projects would also be negligible. 

Recent past and ongoing projects were evaluated for effects to wildlife, including fisher, and 

protective measures are implemented for these other projects to minimize the potential for 

adverse impacts. No additional future projects are anticipated in the project area. For this reason, 

cumulative effects would be minimal.

Because treatments would remove some large trees and snags (though in small amounts) and 

underburning would occur within denning/resting habitat, implementation of alternatives 2, 3 or 

4 may impact individuals, but is not likely to result in a trend toward federal listing or a loss of 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

235

viability for fisher. Effects to fisher prey species would be minimal and short-term. Over the 

long-term, proposed treatments would benefit fisher habitat by increasing denning/resting habitat 

and reducing the potential for high intensity fire. Due to the substantial reduction in 

underburning under alternative 4, the potential for adverse impacts to fishers is substantially less 

for alternative 4 than for alternatives 2 or 3. 

American Marten

There are no historical records of marten in the analysis area. There have been no detections of 

marten in proximity of the project area. The probability of martens occurring in the area is very 

low. Effect to Marten habitat is expect to be minimal and proposed underburning would benefit 

habitat for marten in the long-term. Based on negative survey data, current range of the species, 

and low likelihood of occurrence, it is expected that the project would have no direct, indirect or 

cumulative effects on American martens.

Townsend’s big eared bat

Thinning and fuels reduction treatments may result in the removal of some individual trees or 

snags that may be used for roosting. By meeting the recommendations for snags in the Forest 

Plan (1995a) and because the felling or removal of large trees would only occur under limited 

circumstances, impacts to roosting habitat are expected to be minimal. Townsend’s big-eared 

bats are more commonly found roosting in caves or mines; caves are located on private property 

near the Klamath River and on the north end of the project area.

Mines occur throughout the project area. Proposed activities would occur within potential 

roosting habitat. Because this species is sensitive to disturbance at roost sites, these actions 

would likely have an effect on roosting behavior if bats are present.

Thinning is expected to have long-term benefits for Townsend’s big-eared bats by promoting 

the development of large diameter trees which may provide suitable roosting sites. Proposed 

thinning and fuel treatments would change expected fire behavior over time, resulting in fires of 

less intensity, reducing the potential that existing habitat will be lost.

Cumulative effects would not be measurable. Because direct/indirect effects from 

implementing this project under any of the action alternatives as described above would be 

minor, adding these effects to those of past and ongoing projects would also be minor. Recent 

past and ongoing projects were evaluated for effects to wildlife, including Townsend’s big eared 

bats, and protective measures are implemented for these other projects to minimize the potential 

for adverse impacts. No additional future projects are anticipated in the project area. For this 

reason, cumulative effects would be minimal.

Due to disturbance and the loss of individual large trees and snags, implementation of 

alternatives 2, 3 or 4 may impact individuals, but is not likely to result in a trend toward federal 

listing or loss of viability for Townsend’s big-eared bats.
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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Red tree vole

The project area is within the suspected range of the Oregon red tree vole (Arborimus 

longicaudus). Oregon red tree voles have been documented in conifer stands ranging in elevation 

from sea level to 5,500 feet (Manning and Maguire 1999 in Biswell et al. 2002). General habitat 

for the red tree vole consists primarily of older growth conifer stands with multi-layered 

canopies and large branches capable of supporting nests and providing travel routes. 

In 2000, distribution of the genus Arborimus in Siskiyou County in general and on the 

Happy Camp Ranger District in particular, was not well known. There is a historical account of 

red tree voles in the Elk Creek area (Zentner 1977). Surveys were conducted in 2000 on the 

Happy Camp Ranger District that included areas within the Two Bit project area; no red tree 

voles were found. Surveys were again conducted in 2002 and 2003 for several projects on the 

Happy Camp Ranger District; no red tree vole nests were detected during any of these surveys.

Based on the fact that (1) no red tree voles are known to occur in the project area and that 

there have been no recent detections during surveys; (2) older trees would be retained, and; (3) 

canopy cover closure would be retained in a high proportion of the project area, implementation 

of alternatives 2, 3 or 4 would have no effect on red tree voles.

Northwestern pond turtle

Habitat for western pond turtles is present along Indian Creek and its larger tributaries.

Underburning conducted in the spring in areas adjacent to Indian Creek could burn in western 

pond turtle winter habitat. Although no studies were found that describe the effects of prescribed 

fire on wintering turtles, it is possible that turtles may be harmed by a low intensity fire. The 

turtles are buried in the leaf litter during this period and are generally within 600 feet of a 

permanent water source (Jennings and Hays 1994). Underburns proposed for alternative 2 and 3 

would occur in areas adjacent to Indian Creek. Underburns proposed for alternative 4 would not 

occur in this habitat. 

Cumulative effects would not be measurable. Because direct/indirect effects from 

implementing this project under any of the action alternatives as described above would be 

minor, adding these effects to those of past and ongoing projects would also be minor. Recent 

past and ongoing projects were evaluated for effects to wildlife, including northwestern pond 

turtle, and protective measures are implemented for these other projects to minimize the potential 

for adverse impacts. No additional future projects are anticipated in the project area. For this 

reason, cumulative effects would be minimal.

Implementation of alternatives 2, 3 or 4 may impact individuals, but is not likely to result in 

a trend toward federal listing or loss of viability for northwestern pond turtle. This is because 

implementation of project design features (see Chapter 2) and adherence to the aquatic 

conservation strategy (appendix D) would reduce adverse effects to riparian species like the 

western pond turtle. 
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237

Foothill yellow-legged frog and Southern torrent salamander

Less than 5 percent of any 7th field watershed would be impacted by thinning under alternative 2, 

3 or 4, as discussed in more detail in Section 3.8- Water of this chapter. While perennial, 

intermittent and ephemeral streams occur in the project area and provide habitat for the foothill 

yellow-legged frog and southern torrent salamander, project design features have been developed 

to minimize the potential for adverse impacts to riparian habitats, including reducing the risk of 

sediment delivery downstream and changes in shading and stream temperatures (see Chapter 2).

Therefore, proposed thinning, underburning and road use may have negligible, short-term 

indirect effects on stream habitat, but this would be reduced through implementation of project 

design features. 

Cumulative effects would not be measurable. Because direct/indirect effects from 

implementing this project under any of the action alternatives as described above would be 

minor, adding these effects to those of past and ongoing projects would also be minor. Recent 

past and ongoing projects were evaluated for effects to wildlife, including frogs and salamanders, 

and protective measures are implemented for these other projects to minimize the potential for 

adverse impacts. No additional future projects are anticipated in the project area. For this reason, 

cumulative effects would be minimal.

Implementation of alternatives 2, 3 or 4 may impact individuals, but is not likely to result in 

a trend toward federal listing or loss of viability for the foothill yellow-legged frog or the 

southern torrent salamander. Alternative 4 would result in less potential for impact to foothill 

yellow-legged frogs than alternative 2 or 3 because substantially less underburning in or near 

riparian areas would occur. 

Siskiyou mountain salamander

No talus habitat was found within proposed thinning units and therefore thinning would not 

affect habitat or individuals. Plantations are not suitable habitat because they lack sufficient 

amounts of large down woody debris.

Proposed underburns were not surveyed specifically for talus habitat and thus there may be 

populations of Siskiyou Mountains salamanders in these areas. Underburn areas were not 

surveyed because underburning would have minor impacts to individuals and habitat.

Salamanders are surface active when conditions are wet and humid; when conditions are best for 

underburning, most salamanders will have retreated deep into the talus. In addition, prescribed 

burns are designed to mimic low intensity fire and therefore have low impact to overstory trees 

that provide shade to talus area. However a few individuals may be in down wood or other 

flammable material and would be susceptible to the effects of the prescribed burns

Cumulative effects would not be measurable. Because direct/indirect effects from 

implementing this project under any of the action alternatives as described above would be 

minor, adding these effects to those of past and ongoing projects would also be minor. Recent 

past and ongoing projects were evaluated for effects to wildlife, including salamanders, and 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

238

protective measures are implemented for these other projects to minimize the potential for 

adverse impacts. No additional future projects are anticipated in the project area. For this reason, 

cumulative effects would be minimal.

Salamanders located in the prescribed burn areas may be susceptible to the effects of the 

proposed burns in the project area. For this reason, implementation of alternatives 2, 3 or 4 may 

impact individuals, but is not likely to result in a trend toward federal listing or loss of viability 

for the Siskiyou Mountain salamander. Effects would be less under alternative 4 than under 

alternatives 2 or 3 because substantially less underburning would occur.

Blue-gray taildropper

Historic locations of this species are located within 100 feet of treatment unit 116. Project design 

features (see Chapter 2) have been developed to minimize the likelihood of adverse impacts to 

this occupied habitat. Surveys in potential habitat (natural stands with riparian reserves) will be 

conducted prior to the implementation of any thinning treatment. If blue-gray taildroppers are 

located, locations would be buffered from ground disturbing activities. 

Proposed underburn areas were not surveyed because underburning would have minor 

impacts to individuals and habitat. Most mollusks will have retreated underground prior to the 

conditions being right for a prescribed fire. However a few individuals may be in down wood or 

other flammable material and would be susceptible to the effects of the prescribed burns.

Cumulative effects would not be measurable. Because direct/indirect effects from 

implementing this project under any of the action alternatives as described above would be 

minor, adding these effects to those of past and ongoing projects would also be minor. Recent 

past and ongoing projects were evaluated for effects to wildlife, including blue-gray taildropper

and protective measures are implemented for these other projects to minimize the potential for 

adverse impacts. No additional future projects are anticipated in the project area. For this reason, 

cumulative effects would be minimal. Implementation of alternatives 2, 3 or 4 may impact 

individuals, but is not likely to result in a trend toward federal listing or loss of viability of the 

blue-grey taildropper. Because alternative 4 includes substantially less underburning than 

alternatives 2 or 3, the potential for impacts would be less.

Management Indicator Species

Harwood associated species (acorn woodpecker /western gray squirrel)

There are approximately 610 acres of oak stands and 90 acres of mature hardwoods within 

the project area (based on GIS analysis). Alternatives 2, 3 and 4 propose 27 acres of thinning to 

restore hardwood stands. Two acres of habitat typed as mature hardwood and 7 acres of habitat 

typed as oak stands would be underburned under alternatives 2 and 3. The objective of 

underburning treatments is to remove conifer encroachment on oaks stands to reduce fuels and 

improve oak woodland habitat.
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Acorn storage trees are actively defended and are very important to the survival of species 

such as the acorn woodpecker and western gray squirrel (CDFG 1990). Acorn storage trees are 

likely to be located in larger areas of oak woodlands; territories usually range from 2 to 20 acres 

(CDGF 1990). Small inclusions of hardwoods in the commercial thin stands would not be 

targeted for treatment and the negative effects on the hardwood species association is expected to 

be minimal because prescription measure will be thinning around large hardwoods to encourage 

growth and mast production.

Prescriptions for the project will maintain and develop large black oaks that are quickly 

disappearing from the stands due to conifer encroachment. The maintenance and development of 

black oak is expected to be a short and long term benefit for the hardwood species association. 

Thinning and fuels treatment in and around oak woodland inclusions are designed in part to 

reduce the risk of high intensity wildfire which can damage oak woodlands. Overall the thinning 

will be beneficial to acorn woodpecker and the western grey squirrel.

Prescribed burns conducted in the spring would also affect acorn woodpeckers and western 

grey squirrels through smoke intrusion through their nesting habitat which could be heavy at 

times. The fuels treatments will help protect oak woodlands from stand replacing fires and would 

benefit both western grey squirrels and acorn woodpeckers by protecting their habitat. Fuels 

treatments have the potential remove some snags for safety reason which will be short term 

effects; however, the potential for reduced fire severity in these hardwood stands will provide an 

overall long term benefit for the hardwood species association habitat.

River/stream associated species (tailed frog/ American Dipper/Northern Water Shrew/Longtailed vole

Less than 5 percent of any 7th field watershed would be impacted by thinning under 

alternative 2, 3 or 4, as discussed in more detail in the Water section of this chapter. While 

perennial, intermittent and ephemeral streams occur in the project area and provide habitat for 

river/stream associated species, project design features have been developed to minimize the 

potential for adverse impacts to riparian habitats, including reducing the risk of sediment 

delivery downstream and changes in shading and stream temperatures (see Chapter 2).

Therefore, proposed thinning, underburning and road use may have negligible, short-term 

indirect effects on stream habitat, but this would be reduced through implementation of project 

design features. 

Underburning is proposed within the 66 acres of riparian habitat. Effects to water quality due 

to prescribed fire will be short-term (1-2 years) and occur at the site scale. Water drafting, for 

road water, has the potential to directly kill or injure tailed frogs or impact habitat for the other 

river/stream associated species. All drafting equipment will be screened and water drafting will 

not reduce naturally occurring flow by more than 10 percent (see fisheries section in this 

chapter). 

New road construction has been limited to 2.9 miles of temporary road (alternatives 2 and 4

only) no new roads will cross stream channels, and best management practices and project 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

240

design features have been developed to minimize the potential for adverse impacts from the use 

of ground-based logging equipment. 

For these reasons, impacts to important components of tailed frogs, American dipper, 

northern water shrew, and long-tailed vole habitat, such as stream turbidity, temperature, and 

substrate; riparian vegetation; and downed woody debris adjacent to streams are expected to be 

negligible and short term under implementation of alternatives 2, 3 or 4. Impacts would be less 

for alternative 4 than for alternatives 2 or 3 due to the substantial reduction in prescribed 

burning.

Snag Associated Species (Red-breasted sapsucker/Hairy woodpecker/White-headed 

woodpecker/Vaux’s swift/ Downy woodpecker/ Pileated woodpecker/Black-backed 

woodpecker)

There are roughly 0-5 snags per acre in the project area. In plantations, most snags are under 15 

inches dbh and are not likely to be used by snag associated species. In the natural stands there 

are approximately 1-2 snags per acre (Carol Sharp pers. com.). 

Temporary road and landing construction, and building yarder corridors would remove some 

large trees and snags suitable for nesting and roosting but would not be targeted for removal; 

snags and large trees would only be removed in these situations for safety reasons. Thus, at the 

scale of the project area, these impacts to large tree and snag habitat are expected to be minimal.

Thinning is designed to promote the development of late-successional habitat and would not 

eliminate important structural components of snag associated species such as large diameter 

trees, snags, and down woody debris. Canopy cover, an important element of pileated 

woodpecker and Vaux’s swift habitat, is not expected to be substantially changed within potential 

habitat for these species because reduction of large trees is expected to be minimal and suitable 

trees will be readily available throughout the project area. Impacts to the distribution and 

abundance of these habitat components are expected to be minimal.

Fuel reduction treatments also have the potential to remove snags and down wood; however, 

prescriptions are designed to imitate low intensity fire and are designed to retain Klamath 

National Forest Plan recommendations for these components. As a result, fuel reduction 

treatments are not expected to have a measurable impacts to important structural components of 

snag associated species habitat.

Over time, thinning and fuel reduction treatments are expected to result in increases in 

amounts and distribution of important habitat components for snag associated species. Thinning

and subsequent fuels treatments are expected to reduce crown fire potential by maintaining a 

surface fire type; reducing potential stand mortality in the event of a fire start. These factors 

indicate that stands would be more resistant to large scale fires but would still burn with 

sufficient intensity to create snags and small openings within forested habitat. Thus, these fire 

behavior patterns have the potential to create important structural components for snag 

associated species without significantly reducing existing components. 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

241

The implementation of alternative 2, 3 or 4 would result in the incidental loss of individual 

large trees and snags. However, new snags would be created by fuels treatments. The overall 

effect to snag habitat from implementation of alternatives 2, 3 or 4 would be minimal and shortterm.

Late Successional Reserve

The size of the 100-acre LSRs and the Runway LSRs is shown in table 63 below and the 

percentage of each LSR that would be treated under alternatives 2, 3 and 4. Underburning is the 

primary treatment in LSRs. 

Thinning in plantations that are within LSR would retain at least 50 percent canopy cover if 

the stand is considered suitable northern spotted owl habitat. Plantations that are within LSR but 

are not considered suitable northern spotted owl habitat may be reduced below 50 percent 

canopy cover. Prescriptions would reduce tree densities by thinning from below (see forest 

vegetation section in this chapter). Treatments would maintain or enhance tree species diversity 

by retaining all species present in the stand and would favor retention of hardwoods. Although 

LSR guidelines suggest retaining 10 percent of units as unthinned, the IDT team determined that 

it would be more beneficial to thin the entire unit and instead ensure that unthinned units remain 

in adjacent units so that unthinned habitat would still be present in the LSR and near the units 

being treated. Thus at a stand level, diversity will be maintained and enhanced in the LSRs.

Thinning would be designed to promote the development of late-successional habitat and 

would not remove important structural components of LSR such as large diameter trees (greater 

than 20 inches in diameter), hardwoods, snags, and down wood. Trees infected with mistletoe 

may be removed, but prescriptions have been designed to ensure that this structural component 

will remain on the landscape. The removal of large diameter trees would only occur under 

limited circumstances and such as operational trees. Operational trees are those that are cut for 

road and landing construction and clearing for yarder corridors in skyline units.

Underburning would benefit the development of LSR habitat. While a small amount (0.08 

miles) of temporary road construction is proposed in LSRs it would be outweighed by the larger 

amount (0.80 miles) of road decommissioning. Therefore, the effects of disturbance to wildlife 

from vehicles traveling on roads will be reduced. All temporary roads will be barricaded and 

hydrologically restored to allow natural revegetation within several years after project 

completion, thus further reducing negative impacts to wildlife.

No cumulative effects are expected because no foreseeable future projects have been 

identified and ongoing project do not remove suitable NSO habitat within the LSR.
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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Table 64. Proposed Treatments in LSR

LSR Acres in 

Project Area Treatment Type Alt 2 Percentage of LSR Treated

Alt 3 Percentage 

of LSR Treated

Alt 4 Percentage 

of LSR Treated

100-Acre LSRs

KL0286 

Thin Plantation 1 1 1

Thin Natural Stand 1 1 1

Total 68 2 2 2

KL0289

Total 100 Underburn Only 45 45 0

KL0342

Thin Plantation 3 3 3

Underburn Only 53 53 0

Total 105 56 56 3

Runway LSR

Thin Plantation 4 4 4

Underburn Only 39 39 0

Total 3034 43 43 4

Management Area 6 

Management Area 6 is approximately 6,400 acres in size and was designated for the purpose of 

providing habitat for furbearers, such as the Pacific fisher. Underburning is proposed within 

approximately 9 percent of MA 6 (585 acres) and roadside pole thinning is proposed on only 1 

acre or less than 1 percent of the MA. Due to size of the area treated and the fact that the 

treatment itself would have minimal effects to forest structure, proposed treatments would not 

adversely affect the quality of the habitat in the MA for furbearers. Available denning/resting 

habitat (approximately 2,720 acres) would not be affected to any measurable degree by proposed 

treatments under alternatives 2, 3 or 4. Because substantially less underburning is proposed for 

alternative 4, effects to MA 6 would be less if alternative 4 were implemented. 

Migratory Birds

Proposed thinning has the potential to disturb and disrupt breeding birds during the year that 

implementation occurs. Nesting seasons for migratory birds occurs from April through July 

depending on elevation. Not all thinning would occur in one year and would be staggered over 

time; not all thinning would occur with primary nesting seasons.

Studies that have addressed the response of avian communities to thinning treatments similar 

to those proposed in this project, have indicated that species richness increases following 

treatments and that density typically increases for more species than it declines (Hagar et al. 

1996; Siegel and DeSante 2003; Hagar et al. 2004). Thinning live conifers would remove 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

243

potential nesting habitat for some species. However, thinning prescriptions would leave portions 

of stands unthinned; ensuring that habitat for species that require shaded forest stands would be 

well distributed throughout the project area. Additionally, thinning prescriptions are designed to 

retain and promote the development of all existing hardwoods and retain important structural 

components such as large diameter trees and snags. Therefore, thinning prescriptions would help 

to maintain a variety of habitat conditions that may effectively reduce the impact to some species 

and promote avian diversity across the landscape (Alexander et al. 2007; Hagar et al. 1996; 

Hagar et al. 2004). Thinning would target early, mid-successional stands that typically lack well 

developed understory. Over time, the thinned early- and mid-successional stands would likely 

support a richer avian community as their understory becomes more developed and the stands 

become more structurally complex. Thus, thinning would likely have little negative impact to 

existing diversity and abundance of avian species and would likely benefit the avian community 

over time.

Fuels reduction treatments such as underburning have the potential to remove habitat and/or 

impact nesting activities for some avian species. Prescriptions for underburns are designed to 

mimic low intensity fire and meet Forest Plan recommendations for down wood. Additionally, 

most underburns would likely occur before or after the nesting season for most of the avian 

species found in the project area. Thus, underburns are not expected to appreciably impact 

habitat components such as shrubs, grasses, and down wood, or damage active nests.

Temporary road, landing construction and yarder corridors would impact habitat for avian 

species by removing a variety of habitat components including live trees, snags, and shrubs. 

Combined, these actions are expected to impact a small percentage of the project area and are 

not expected to appreciable reduce the amount of habitat on the landscape. Where temporary 

roads are constructed through uniform stands they may actually increase avian species richness 

and diversity by creating horizontal heterogeneity in the stand (Hagar et al. 1996).

For this project, the long-term benefits to species (and their key habitats) from implementation of 

alternatives 2, 3 or 4 are maintenance of or increase in stand diversity and an increase in fire 

resiliency in treated stands. Alternatives 2, 3 or 4 would also promote early seral stage vegetation 

via under burning and maintain and enhance meadows. The short- and long-term adverse effects 

to migratory bird species and their key habitats include a potential loss of large snags and large 

down woody from operational hazard trees and underburning.

In balance, the long-term benefits are of greater conservation value to migratory bird species 

than the short- and long-term adverse effects. Implementation of alternatives 2, 3 or 4 may 

impact individual migratory bird species but is not expected to result in a loss of viability for 

these species. 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

244

Summary

Alternative 1 would comply with the Endangered Species Act but would not comply with the 

Forest Plan (1995a) which states that stands are to be managed to develop late-successional 

characteristics and that underburning should be encouraged in LSR and MA 6. 

Alternatives 2, 3 and 4 would have similar effects to Forest Service Sensitive Species and 

species of concern, migratory birds, LSRs and MA 6 because treatments types are the same 

among alternatives, with a few exceptions. Implementation of alternatives 2, 3 or 4 may affect 

but is not likely to adversely affect NSO. Implementation of alternatives 2, 3 or 4 would not 

affect marbled murrelet, marbled murrelet Critical Habitat or NSO Critical Habitat. 

Implementation of alternatives 2, 3 or 4 may impact eight sensitive species and species of 

interest (northern goshawks, willow flycatchers, California wolverines, Pacific fishers, 

Townsend’s big-eared bats, northwestern pond turtles, Siskiyou mountains salamanders and 

blue-gray taildroppers) but is not likely to result in a trend toward federal listing or a loss of 

viability. Implementation of alternatives 2, 3 or 4 would not measurably affect five sensitive 

species and species of interest (bald eagles, peregrine falcons, American martins, foothill yellowlegged frogs, or southern torrent salamanders) or their habitat. 

Implementation of alternatives 2, 3 or 4 would not adversely impact the quality of the habitat 

within LSRs or within MA 6; in the long-term, implementation of either alternative 2, 3 or 4 

would result in beneficial changes to the quality of habitat in these areas due to the development 

of larger trees and the reduction in the risk of high severity fire. 

Alternatives 2, 3 and 4 would comply with the Endangered Species Act and with the Forest 

Plan. Project design features have been developed for all alternatives that would minimize the 

potential for adverse impacts to terrestrial wildlife.

3.12 Social and Economic Resources

3.12.1 Methodology

Alternatives are analyzed and compared using the Quicksilver economic analysis program to 

estimate the Benefit-Cost ratios and the Net Present Values (NPV’s). Quicksilver is a financial 

analysis tool developed by the USDA Forest Service to generate measures of financial efficiency.

A 6-year planning horizon is used in this analysis; activities would begin in fiscal year 2010 and 

end in fiscal year 2015. NPV is a way of comparing all monetarily valued costs and benefits, and 

is calculated by subtracting the discounted sum of total costs from the discounted sum of total 

benefits. Similarly, benefit-cost ratios are the discounted sum of benefits divided by the 

discounted sum of costs. A ratio greater than one suggests that the benefits associated with a 

project are greater than the costs, although this estimate should be used in conjunction with the 

NPV to describe overall benefits. The data utilized in this analysis represents the best available 

estimate of the quantities, costs, and benefits associated with each alternative.
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

245

Economic impacts are estimated by alternatives for the study area. The study area consists of 

Siskiyou and Trinity Counties in California as well as Jackson and Josephine Counties in 

Oregon. Management activities would occur in Siskiyou County near the town of Happy Camp.

For the purposes of this analysis, it is assumed, for all action alternatives, that 75 percent of 

commercial activity would be conducted by local firms.

The alternatives will be compared using the following indicators:

Timber volume

Benefit-Cost ratios and Net Present Values

Jobs

Revenue 

Social implications, including Environmental Justice

The information used in the preparation of this section comes from detailed analysis in the 

Logging Systems Report (North 2010) and the Socioeconomics Report (Wilson 2010) and are 

available in their entirety in the project record.

3.12.2 Affected Environment

Population and Demographics

In recent years, populations in the study area have remained relatively stable; most counties have 

experienced minimal population growth. The 2008 population in Siskiyou County is 44,970; in 

Trinity County it is 13,966; in Jackson County it is 205,305 and in Josephine County it is 83,290 

(www.dof.ca.gov and www.pdx.edu/prc). Jackson County has experienced the most growth in 

recent years; the county seat, Medford, is the largest town in the County, and has experienced 

more growth in recent years in public infrastructure and retail outlets compared to some of the 

other counties.

Age distributions can influence the demand for services on the Klamath National Forest.

Different age groups are likely to participate in different natural resource-based activities. The 

median age in each county is higher than the median age for their respective states (US Census 

Bureau 2000). For example, in Siskiyou County, the median age is 43; but for Oregon it is 38 

and for California it is 34. This could be due to there not being adequate higher educational and 

job opportunities in the area to draw a younger demographic. Likewise, there may be a greater 

influence from retirees in the geographic region surrounding the Klamath National Forest. The 

economic structure of the communities must evolve to meet the demands of its residents. In areas 

with a large retiree influence, this may mean enhancing service-based industries. In the case of 

Happy Camp, however, it is unlikely that substantial population growth will occur that could 

result in the migration of businesses into the area. The infrastructure and services available will 

likely remain static, and will not be substantially influenced by Two Bit. Logging typically 

attracts a younger demographic; but it is likely that any jobs created would be filled by Happy 

Camp residents and would not impact the overall age distribution.
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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The vast majority of local residents in the Study Area are Caucasian. The counties have a 

similar ethnic composition to the State of Oregon; however it is very different than that of 

California. As a whole, California is much more ethnically diverse than the Counties in the study 

area. California’s population is 60 percent Caucasian, where the distribution for the counties 

ranges from 87 percent in Siskiyou County to 93 percent in Josephine County. Nearly 36 percent 

of California’s population comes from a Hispanic origin; whereas counties in the study area 

range from 4 percent to 8 percent. In general, the Native American population has a much higher 

presence around the KNF than in the states as a whole. Native Americans/Pacific Islanders are 

the second most populous race in Siskiyou and Trinity Counties at 4 percent and 5 percent 

respectively (US Census Bureau 2000).

Employment and Income

Employment and income statistics are important indicators of economic health. In recent years 

the study area has not received any extensive positive or negative changes in employment.

Figure 10 displays the total employment levels for the four counties from 2001 to 2007. Total 

employment has remained steady for each county over the specified time period. Jackson County 

has experienced the greatest job growth. Due to the relative remoteness of many communities in 

the study area, including Happy Camp, jobs may not be as vulnerable to swings in market 

structure and labor demands as total employment at the state level. It is particularly important to 

consider the impact to employment in remote areas where jobs supported by the affected 

resources may consist of a large portion of total employment. Such areas may not be as resilient 

to a certain loss in jobs as a more metropolitan area. For example, a loss of 100 jobs in a certain 

sector in Trinity County is likely to have a more devastating effect on the local economy than the 

same loss of jobs in Jackson County. In a more populated and economically diverse county, the 

local economy is likely to be better positioned to absorb the loss in employment in one sector

with job opportunities in other sectors.
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

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Figure 10. Employment Levels by County, 2001-2007

Source: www.bls.gov

Economic sectors are a set of local businesses by industry, grouped together according to 

similarities in the goods and services offered. Assessing employment and income by sector 

assists in the identification of those industries important to the economic sustainability of the 

region, and those potentially dependent on the activities taking place on NFS lands.

Total employment in the study area is 181,855 jobs; however, 68 percent of those jobs are in 

Jackson County (table 65). Proportionately, Josephine, Siskiyou, and Trinity Counties account 

for 20 percent, 10 percent, and 2 percent of total employment respectively. The government 

sector is the largest employer in Siskiyou and Trinity Counties. Retail trade, health and social 

services and construction are the dominant sectors in Jackson County. The largest sectors in 

terms of employment in Josephine County are retail trade and health and social services.

Proportionally, the agriculture, forestry, fishing and hunting sector is an important employer in 

Siskiyou County, accounting for 7 percent of total employment. Activities on the Klamath 

National Forest support jobs in this sector, making them a valuable source of economic stimulus 

for many communities in Siskiyou County, including Happy Camp. Retail trade and 

accommodation and foods services are also important sectors in terms of employment.

Businesses in these sectors likely generate economic stimulus from activities on the Forest due to 

travelers purchasing goods and services while on their way to visit the Forest. The importance of 

such activities varies by county. The more diverse economies of the larger counties may not be 

as reliant on Forest activities for economic stimulus.

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

80,000

90,000

2001 2002 2003 2004 2005 2006 2007

Jobs

Siskiyou Trinity Jackson Josephine
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

248

Table 65. County Employment (Number of Jobs) by Economic Sectors

Ag, Forestry, Fish & Hunting

Siskiyou Trinity Jackson Josephine Total

1,213 147 5,095 1,744 8,200

Mining 15 14 179 97 305

Utilities 53 7 95 27 182

Construction 1,147 208 13,379 2,946 17,680

Manufacturing 739 259 7,036 3,377 11,411

Wholesale Trade 267 6 2,708 1,105 4,086

Transportation & Warehousing 665 58 4,090 927 5,741

Retail trade 1,998 380 20,522 5,267 28,168

Information 270 32 1,993 396 2,692

Finance & insurance 373 65 3,796 1,242 5,476

Real estate & rental 675 109 4,641 1,156 6,581

Professional- scientific & 

technical services 672 122 4,987 1,032 6,812

Management of companies 76 0 1,765 177 2,017

Administrative & waste services 525 25 6,535 1,496 8,581

Educational services 105 36 1,482 363 1,986

Health & social services 1,868 425 14,651 4,959 21,903

Arts- entertainment & recreation 396 104 3,400 609 4,509

Accommodation & food services 1,861 351 8,395 2,930 13,537

Other services 1,297 394 7,439 2,604 11,735

Government 4,214 1,148 11,308 3,582 20,253

Total 18,429 3,889 123,497 36,040 181,855

Source: Minnesota IMPLAN Group (MIG) 2006

Environmental Justice

As stated in Executive Order 12898, it is required that all federal actions consider the potential of 

disproportionate effects on minority and low-income populations in the local region. The 

principals of Environmental Justice require agencies to address the equity and fairness 

implications associated with Federal land management actions. The Council on Environmental 

Quality (CEQ) (1997) provides the following definitions in order to provide guidance with the 

compliance of Environmental Justice requirements:

“Minority population: Minority populations should be identified where either:

(a) the minority population of the affected area exceeds 50 percent or (b) the 

minority population percentage of the affected area is meaningfully greater than 

the minority population percentage in the general population or other 

appropriate unit of geographic analysis...”
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“Low-income population: Low-income populations in an affected area should 

be identified with the annual statistical poverty thresholds from the Bureau of 

the Census' Current Population Reports, Series P-60 on Income and Poverty. In 

identifying low-income populations, agencies may consider as a community 

either a group of individuals living in geographic proximity to one another, or a 

set of individuals (such as migrant workers or Native Americans), where either 

type of group experiences common conditions of environmental exposure or 

effect.”

Native Americans (American Indians/Alaska Natives) comprise a much higher percentage of 

the population in Siskiyou County (3.9 percent) and Trinity County (4.8 percent) than they do 

across the State of California as a whole (0.7 percent). They are the second most populous race 

(the first is Caucasian) in these counties (US Census Bureau 2000). For this reason, the Native 

American population meets the Environmental Justice criterion as a minority population 

meaningfully greater than the general population of the states.

In 2005, all counties in the Study Area except Jackson County had poverty rates higher than 

that of their respective states and poverty rates in Siskiyou, Jackson and Josephine Counties 

increased from 2000 to 2005. As of 2005, Siskiyou County has the highest poverty rate in the 

study area at 17.5 percent. This poverty rate suggests that a substantial proportion of the existing 

population is a low income group (US Census Bureau, Small Area Income and Poverty 

Estimates).

3.12.3 Environmental Consequences

Alternative 1- No Action

Direct and Indirect Effects

There would be no direct/indirect effects on the socioeconomic environment if no action were to 

take place in the project area. No timber would be harvested and no fuels treatments would 

occur. Any change in economic and social conditions would occur as a natural progression of 

economic and social activity in the Study Area. Existing conditions and trends would be 

expected to continue.

Cumulative Effects

Given that there are no measurable direct and indirect effects that would occur under the no 

action alternative, there would also be no measurable cumulative effects.

Alternative 2- Proposed Action

Direct and Indirect Effects

Timber Volume and Values

Commercial thinning proposed under alternative 2 would result in the production of timber 

commodities, primarily in the form of sawlogs. The project could produce fuel for the biomass 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

250

industry but the closest facility capable of utilizing fuel is in Anderson, California; the estimated 

cost of removing, processing and transporting fuel to this location would exceed the delivered 

fuel price. For this reason, this option is not considered further in this analysis. Sawlog volumes 

from small and medium sawtimber (primarily Douglas fir, ponderosa pine and white fir) are 

estimated to be 46,241 CCF. Table 66 below shows the estimated value and price of this volume. 

Table 66. Timber Volume and Values for alternative 2, proposed action

Volume CCF Base Rate Value $/CCF1 Estimated High Bid 

Stumpage Value $/CCF2 Estimated High Bid Total Stumpage Value

46,241 $9.96 $13.59 $628,471

1

Base Rate Value is the minimum the Forest Service can charge for timber. 2Indicated Stumpage Value is the estimate of 

what a timber purchaser would pay for the timber under current market conditions.

Twenty-five percent of the stumpage value would be paid to Siskiyou County because 

counties receive a portion of the revenue generated on National Forest System lands. These 

funds are used for the upkeep and maintenance of public schools and roads. This alternative 

would generate approximately $157,118 in payments to Siskiyou County. 

Benefit-Cost Ratios and Net Present Value

Activities proposed under this alternative have a variety of economic implications. Commercial 

logging would provide a revenue stream back to the USDA Forest Service, and noncommercial 

activities propose costs to the government. The NPV and benefit-cost ratio for all activities is 

negative $2,595,396 and 0.19 respectively. The sale of saw timber is estimated to bring in 

revenue of $628,471 in 2009 dollars; however, the costs associated with preparation and 

administration of the sale, combined with the cost of restoration activities (underburning, 

meadow enhancement, etc.) outweigh the returns of the revenue stream. These values do not 

imply that alternative 2 is economically inefficient. In determining economic efficiency, all costs 

and benefits associated with the management activities are taken into account. This includes 

those that may not directly be monetized. Estimating the value of benefits and costs not 

accounted for in the market place is outside the scope of this analysis. Nonmarket benefits may 

include improved ecosystem health, increase in wildlife, and reduced threat of wildfire, among 

other effects. Thus, the financial measures reported in this document should be considered along 

with all other social and ecological impacts resulting from the management activities.

Jobs 

Alternative 2 proposed actions would require human labor for implementation. This would affect 

the level of jobs and income in the study area. Overall, it is estimated that the activities 

associated with alternative 2 would support 183 jobs in the study area, and $5,388,500 in labor 

income. The agriculture industry would be impacted the most with 38 direct jobs, and 35 indirect 

and induced jobs. The manufacturing industry would also experience substantial growth with 15 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

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direct and 18 indirect and induced jobs. The remaining jobs would be distributed across other 

sectors in the economy as a result of business and household purchasing patterns.

Social Implications, including Environmental Justice

In addition to the economic effects, there would also be implications for the lifestyles and values 

of local residents. The vast majority of social impacts would occur in the community of Happy 

Camp nearest the project area. During the public scoping phase for this project, concerns were 

raised by local residents regarding the level of smoke generated from proposed underburning and 

increases in logging traffic and impacts to recreation during project implementation. A total of 

7,250 acres would be burned under this alternative. The amount and location of proposed 

underburning may result in short-term but adverse impacts to local air quality due to the level of 

smoke produced, exacerbated by the tendency for smoke in these areas to settle in the basin. This 

can result in inconvenience and discomfort for residents that live along Indian Creek and in the 

town of Happy Camp, particularly those with allergies or breathing conditions. Project design 

features have been developed to minimize these effects as much as possible, although not

eliminate them. Effects to air quality are the subject of the air quality section of this chapter and 

the potential for effects to recreation is the subject of the recreation section of this chapter. 

Logging would occur over a period of two or more years and would result in increased traffic 

from logging trucks through Happy Camp and throughout the project area. There could be some 

indirect effects in the form of dust and slower travel times for residents. Volume and seasonality 

of traffic would depend on the plan of operation by the logging companies. Project design 

features have been developed to minimize this effect to local residents as shown in Chapter 2.

Implementation of alternative 2 is unlikely to result in a disproportionate adverse effect on 

minority and low income populations; effects should be experienced by all residents equally.

Individuals in these populations may benefit from any increase in jobs and income in the area.

Cumulative Effects

Cumulative effects include the total change in social and economic conditions that would result 

from the specifications under this alternative in conjunction with the direct and indirect effects of 

other present and reasonably foreseeable activities. Past activities are assumed to be represented 

by existing conditions. The project area lies wholly within the Indian Creek watershed, which is 

approximately 86,200 acres in size. Although resource management is common practice across 

the entire study area, only projects within this watershed (see table 15 at the beginning of this 

chapter) are used. There are currently no known plans for logging or restoration activities on 

private lands. Resource management is expected to occur on 3,345 acres in the watershed, in 

addition to 96.3 miles of road storm proofing and 11.3 miles of road decommissioning. Estimates 

of the economic and social impacts associated with these projects are not readily available; 

however, on the margin, it is expected that they will support additional jobs and income and 

affect the social environment as in alternative 2 alone. In general, the study area has low 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

252

population density, a large proportion of the population is in the working age group, and 

unemployment rates are higher than state averages. Thus, new jobs would likely be filled by 

unemployed residents. This should contribute to reduced unemployment rates and increased 

resident incomes. Social impacts are more difficult to quantify. However, it is not expected that 

the activities associated with this project would substantially alter the social environment.

Communities within or near the Indian Creek watershed would continue to be dominantly rural 

and driven by natural resource based activities.

Potential Sale Quantity

Timber volume harvested from this project contributes to the Klamath National Forest’s 

Potential Sale Quantity. The Klamath National Forest Plan as amended by the Northwest Forest 

Plan forecasted a PSQ of 51 MMBF. The Potential Sale Quantity only considers volume 

produced from matrix (regulated) lands. The average volume sold between 1995 and 2006 was 

25.4 MMBF per year, or 49 percent of the Potential Sale Quantity. Alternative 2 would 

contribute approximately 23.1 MMBF to the annual target, or 45 percent of the Potential Sale 

Quantity.

Alternative 3 – No Temporary Roads

Direct and Indirect Effects

Timber Volume and Values

Commercial thinning proposed under alternative 3 would result in the production of timber 

commodities, primarily in the form of sawlogs, as described for alternative 2. Sawlog volumes 

from small and medium sawtimber (primarily Douglas fir, ponderosa pine and white fir) are 

estimated to be 39,785 CCF; this is lower than alternative 2 due to the fact that 270 fewer acres 

are proposed for thinning under alternative 3. Table 67 below shows the estimated value and 

price of this volume. 

Table 67. Timber Volume and Values for alternative 3, No Temporary Roads

Volume 

CCF

Base Rate Value 

$/CCF1 Estimated High Bid Stumpage Value $/CCF2 Estimated High Bid Total Stumpage Value

39,785 $9.96 $13.16 $523,400

1

Base Rate Value is the minimum the Forest Service can charge for timber. 2Indicated Stumpage Value is the estimate of 

what a timber purchaser would pay for the timber under current market conditions.

Twenty-five percent of the stumpage value would be paid to Siskiyou County because counties 

receive a portion of the revenue generated on National Forest System lands. These funds are 

used for the upkeep and maintenance of public schools and roads. This alternative would 

generate approximately $146,909 in payments to Siskiyou County. 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

253

Benefit-Cost Ratios and Net Present Value

Activities proposed under this alternative have a variety of economic implications. Commercial 

logging would provide a revenue stream back to the USDA Forest Service, and noncommercial 

activities propose costs to the government. A total of 39,785 CCF of timber would be harvested, 

yielding total discounted revenue of $523,400. The NPV and benefit-cost ratio for all activities is 

negative $2,890,486 and 0.14 respectively. There would be slightly more underburning to 

achieve the desired conditions of the landscape, which would add costs to government. There 

would also be a cost savings since no new temporary roads would be built, but there would be 

less revenue from the sale of saw timber.

Jobs 

The activities associated with alternative 3 would support 162 jobs and $4,746,900 in labor 

income. The distribution of jobs across industries is similar to that of the proposed action. The 

agriculture industry would be impacted the most with 33 direct jobs, and 30 indirect and induced 

jobs. The manufacturing industry would experience an increase of 13 direct and 15 indirect and 

induced jobs. In comparison to the other action alternatives, this one generates the fewest jobs 

and income for the study area.

Social Implications, including Environmental Justice

Social impacts would be very similar to that described for alternative 2. There would be a small 

increase in potential for adverse effects from smoke because there would be more acres of 

underburning. Fewer temporary roads would mean less ground disturbance, and less volume 

harvested would mean less traffic from logging operations. However, commercial thinning 

would be such that there would likely not be a noticeable difference in traffic between the action 

alternatives. Implications for recreation would be similar to that described under the proposed 

action.

Cumulative Effects

Other projects in the study area that may contribute to cumulative effects are described under the 

proposed action. Under this alternative there would be no disturbance from new temporary 

roads, more smoke associated with underburning, and less timber commercially harvested. 

Cumulative effects would be similar to those reported for alternative 2 since the differences 

between direct/indirect economic effects are small.

Potential Sale Quantity

This alternative would contribute approximately 19.9 MMBF to the annual target, or 39 percent

of the Potential Sale Quantity.
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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Alternative 4 - Minimized Underburning

Direct and Indirect Effects

Timber Volume and Values

Commercial thinning proposed under alternative 4 would result in the production of timber 

commodities, primarily in the form of sawlogs. Sawlog volumes from small and medium 

sawtimber (primarily Douglas fir, ponderosa pine and white fir) are estimated to be the same as 

that for alternative 2 (46,241 CCF, table 64) because alternative 4 proposes the same level of 

thinning treatments. 

Twenty-five percent of the stumpage value would be paid to Siskiyou County because 

counties receive a portion of the revenue generated on National Forest System lands. These 

funds are used for the upkeep and maintenance of public schools and roads. This alternative 

would generate approximately $157,118 in payments to Siskiyou County, the same as that 

generated for alternative 2. 

Benefit-Cost Ratios and Net Present Value

The primary difference between alternative 4 and alternative 2 is reduced underburning and 

introduction of mastication. Volume harvested and revenue stream would be the same, but there 

would be a different cost structure associated with mastication as a replacement for 

underburning. The NPV and benefit-cost ratio for alternative 4 is negative $1,521,906 and 0.28 

respectively. Although total monetary costs are greater than total monetary benefits, this 

alternative yields the greatest NPV and benefit-cost ratio among the action alternatives.

However, this does not imply that this is the most economically efficient alternative. All other 

benefits and costs must be weighed against those of the other alternatives.

Jobs 

This alternative would support a total of 173 jobs and $5,097,000 in labor income. The 

distribution of job across economic sectors is similar to that of alternatives 2 and 3. The majority 

of jobs would be supported in the agriculture and manufacturing industries. Due to the higher 

unemployment rates, labor required for new jobs would be supplied by the local labor market.

Therefore activities associated with the Two Bit project would not affect household migration 

patterns.

Social Implications, including Environmental Justice

The primary difference in the effects of this alternative compared to the others is the social 

implications of reduced burning. The minimal amount of burning required to meet the desired 

conditions would be conducted. Mastication would replace underburning across much of the 

project area. This would greatly reduce the risk of adverse effects from smoke. Effects from 

logging traffic and impacts to recreational capacity would be similar to those described under the 

proposed action.
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Cumulative Effects

The cumulative effects would be similar to those reported under alternative 2 because timber 

volume is the same. The primary difference would be the reduced presence of smoke from 

underburning. 

Potential Sale Quantity

This alternative would contribute approximately 23.1 MMBF to the annual target, or 45 percent

of the Potential Sale Quantity.

Summary

Table 68. Summary of effects to socioeconomic indicators from all alternatives

Indicator Alternative 1, No 

Action

Alternative 2, 

Proposed Action 

Alternative 3, No 

Temporary 

Roads

Alternative 4, 

Minimized 

Underburning

Timber volume None 46,241 CCF 39,785 CCF

Same as

Alternative 2

Estimated 

Revenue

None $628,471 $523, 400

Same as 

Alternative 2

Net Present Value Not applicable ($2,595,396) ($2,890,486) ($1,521,906)

Cost-Benefit Ratio Not applicable 0.19 0.14 0.28

Jobs Created None 183 162 173

Labor Income 

Created

None $5,388,500 $4,746,900 $5,097,000

Other Social 

Implications No Change

Smoke, logging 

traffic and 

recreation 

impacts, 

minimized through 

project design 

features

Slightly more 

smoke and slightly 

less logging traffic; 

effects slightly less 

than alternative 2

Substantially less 

smoke but the 

same logging 

traffic and 

recreation impacts 

as alternative 2, 

minimized through 

project design 

features

Alternative 4 has the highest NPV and benefit-cost ratio. This means that it has the greatest 

amount of monetary benefits compared to the costs. However, these measures do not imply that 

this alternative is the most economically efficient. All other factors must be taken into account 

including nonmonetary benefits and costs, and how well the alternative meets the purpose and 

need. Under alternative 4 there would be fewer total acres treated with underburning and 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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mastication would be used instead to treat fuels as compared to alternatives 2 and 3. This reduces 

the total cost of management activities, but would yield different on-the-ground benefits. Total 

costs include administration, sale preparation, restoration activities, etc. The only benefit 

accounted for in the marketplace is the revenue from the sale of sawtimber. In order to determine 

economic efficiency, all costs and benefits associated with the management activities should be 

taken into account. This includes those that may not directly be monetized. Nonmarket benefits

and costs include improved ecosystem health, reduced threat of fire, increased logging traffic, 

smoke from underburning and any other impact to the socioeconomic environment.

Impacts to employment and income are reported as direct, indirect and induced effects (table 

69). The total impact is the sum of those effects. Although the primary activities associated with 

resource management lie within the agriculture and manufacturing industries, they also stimulate 

employment in a variety of other sectors. For example, activities associated with alternative 2 

directly increase employment in the accommodation and food services industry by four jobs.

Those jobs are supported in response to the increased economic activity generated by the 

additional production of wood products and other resource management activities. In addition to 

those four jobs, another four jobs are generated in that industry in response to the increased 

interindustry purchasing resulting from the increased demand for the output of the directly 

affected industries, as well as the increased expenditures from households due to the increase in 

local income (i.e. the indirect and induced effects). Thus, the estimated total employment 

supported in the accommodation and food services industry as a result of the activities proposed 

under alternative 2 is eight jobs. Impacts to the remaining industries are reported below in the 

same fashion. Overall, alternative 2 would contribute the most jobs to the study area followed by 

alternative 4 and alternative 3, respectively.

Table 69. Employment Impacts across Alternatives (number of jobs)

Alt. 2 Alt. 3 Alt. 4

Direct

Indirect 

& 

Induced

Direct

Indirect 

& 

Induced

Direct

Indirect 

& 

Induced

Agriculture, Forest, Fish and Hunt 37 34 35 30 29 32

Mining 0 0 0 0 0 0

Utilities 0 0 0 0 0 0

Construction 0 0 0 0 0 0

Manufacturing 15 18 13 15 15 18

Wholesale Trade 2 3 2 2 2 3

Transportation & Warehousing 2 3 2 2 2 3

Retail Trade 6 6 5 6 6 6

Information 1 1 1 1 1 1

Finance & Insurance 2 3 2 2 2 3

Real Estate & Rental & Leasing 2 2 2 2 2 2

Prof, Scientific, & Tech Services 2 3 2 2 2 2

Management of Companies 1 1 1 1 1 1

Admin, Waste Mngt & Rem Serv 2 2 2 2 2 2
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

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Alt. 2 Alt. 3 Alt. 4

Direct

Indirect 

& 

Induced

Direct

Indirect 

& 

Induced

Direct

Indirect 

& 

Induced

Educational Services 1 1 1 1 1 1

Health Care & Social Assistance 6 7 5 6 6 7

Arts, Entertain & Recreation 1 1 1 1 1 1

Accommodation & Food Services 4 4 3 4 4 4

Other Services 4 4 3 4 4 5

Government 0 1 0 0 0 1

Total 89 94 81 81 81 92

Labor income is affected in a similar manner to employment. The greatest change in income 

is experienced by the agricultural industry, followed by manufacturing. Increases in local income 

are typically viewed as an economic benefit; however, such benefits must be weighed in 

accordance with the other social and ecological impacts associated with project implementation.

Overall the management activities would not drastically alter the economic conditions of the 

study area. There could be smaller communities within the study area that would be affected 

more than others. Happy Camp is likely to experience the greatest impact on their local 

economy. Given the high unemployment rates in the region, new jobs created from the 

vegetation management activities would be filled by local residents; thus, household migration 

patterns should not change. Economic impacts should be positive in the form of lower 

unemployment and greater local income.

In addition to the economic implication, three important social concerns were identified 

during the scoping period. Although those effects cannot be quantitatively estimated, they are 

recognized through a qualitative assessment of potential consequences for the social 

environment. The presence of smoke would be greatest under alternative 3; however, burning 

would be spread out over a five year period under each alternative in order to reduce impacts on 

the human environment, and strict burning procedures would be followed in all instances.

Logging traffic would be somewhat less under alternative 3 because less volume would be 

harvested. The total impact from traffic would depend on the plan of operation implemented by 

commercial logging companies. It is unlikely that differences in traffic would be noticeable 

across alternatives. Project design features would reduce the risks of adverse effects from smoke, 

but would not eliminate them. There are no other anticipated effects that would substantially 

alter the social environment under any of the action alternatives.

3.13 Scenery and Recreation Resources

3.13.1Methodology

Scenic Quality of or within National Forests is valued for the aesthetic enjoyment and 

physiological benefits it offers. “Viewing Wildlife” and “Viewing Natural Features” are the top 

two recreation activities of visitors to the Klamath National Forest (pg. 15, August 2002, USDA 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

258

Forest Service, National Visitor Use Monitoring Results). Scenic quality within the project area 

is important to the people who live and work in the area, and travel through the area enjoying 

views from Grayback Road (State of Jefferson Scenic Byway) travel corridor, various County 

and Forest roads, and the rural community of Happy Camp. The scenery of the area contributes a 

small but important part to the Klamath National Forest’s scenic heritage.

Visual Quality Objectives (VQO) are defined in the Forest Plan and apply to site-specific 

projects visible from the Forest’s inventoried Moderate (Level 1) and High (Level 2) Sensitivity 

Viewpoints. VQOs are minimum conditions to be achieved as soon as possible in all 

management areas and within 3 years for all VQOs except Preservation and Maximum 

Modification which must be met immediately. Facilities and developments, such as roads, trails, 

campground facilities, structures, signs, and interpretive stations, are not required to meet the 

Management Area VQOs when viewed in immediate foreground (300 feet).

A landscape with very minimal visual disruption is considered to have high scenic integrity. 

Landscapes that have increasingly discordant relationships among scenic attributes are viewed as 

having diminished scenic integrity. Scenic integrity objectives, for purposes of this analysis also 

called Visual Quality Objectives, are definitions of acceptable degrees of deviations from the 

landscape character that may occur at any given time. It is a continuum ranging over these five 

levels. Visual Quality Objectives are: 

Maximum Modification - very low integrity, or heavily altered – landscapes where 

character appears extremely altered. This is not a management objective, but is 

sometimes used to show landscapes that are in need of rehabilitation. 

Modification - low integrity, or moderately altered – landscapes where character appears 

moderately altered. Deviations begin to dominate the character being viewed but these 

often compliment the character or are compatible with it. 

Partial Retention - moderate Integrity, or slightly altered– landscapes where character 

appears slightly altered. Deviations are noticeable but they remain visually subordinate 

to the character being viewed.

Retention - high integrity, or appears unaltered – landscapes where character appears 

intact. Deviations are present but not evident. 

Preservation – very high integrity, or unaltered – landscapes where character is intact 

with only minute, if any, deviations.

Conditions that may be used to fine-tune Forest Plan VQOs include discrepancies in 

landscape variety classification, changes in visual sensitivity levels, and discrepancies in the 

seen-area mapping (e.g. the ability to view an area from a designated road or trail (USDA Forest 

Service 2008). As stated in the Forest Plan, areas not visible from inventoried Level 1 and 2 

Sensitivity Viewpoints are to be managed so as to appear as little modified as possible consistent 

with management goals, and no more altered in appearance than Maximum Modification (S & G 

#11-8). 

This evaluation applies current National Forest Landscape Management methodology in 

conjunction with existing Forest Plan direction. It relies on previous field studies of similar types 

of projects, as well as observations from sensitive viewpoints, and consideration of public 
Two Bit Vegetation Management Draft Environmental Impact Statement Chapter 3

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preferences for scenic quality. Cumulative scenic quality is evaluated within a larger context than 

the individual project activities themselves, but the potentially affected viewsheds as a whole.

This evaluation is based on the following:

Generally speaking, based on past experience with projects of a similar nature, commercial 

thinning to 60 percent canopy closure would typically meet a Retention VQO and 40% 

canopy closure would typically meet a Partial Retention VQO. However, other factors such 

as viewing angle, viewing distance, viewer orientation, vehicle speed, lighting, season, 

duration of view, etc can influence this. Field review was used to verify these assumptions.

Several field reviews of critical units proposed in this project were conducted during 2009, 

focusing on project activities located in Retention or Partial Retention VQOs, or those that 

were potentially visible from high sensitivity viewpoints. 

Extensive review of project descriptions and maps; assessing project activity locations 

(orientation, slope position, and distance from viewer), logging systems, combined with on 

the ground knowledge of topography and vegetation. 

All proposed project activities in Modification and Maximum Modification VQO areas 

would easily meet their assigned VQOs. Most activities are not even visible from any high 

or moderate sensitivity viewpoint.

The alternatives are compared using the following indicators:

Consistency with Forest Plan VQOs (measured through changes in landscape character, 

sense of place, scenic attractiveness, scenic integrity and visually sensitive areas)

Changes in recreation opportunities

For cumulative effects, qualitative changes across the viewshed

The information used in the preparation of this section comes from detailed analysis in the 

Recreation and Scenery Report (Talley 2009) and is available in its entirety in the project record.

3.13.2 Affected Environment

Visual Quality Objectives

Landscape Character

Landscape Character describes what “kind” of scenery, or visual image, is made by a particular 

landscape. In the project area, low to moderately steep mountainous terrain, bisected by 

numerous side drainages, faces Indian Creek as it winds through the Klamath Mountains. In the 

background, higher elevation ridges and peaks provide a visual backdrop. These ridges of the 

Klamath Mountains dominate the project area’s landscape character, although breaks in the 

forest canopy from previous wildfires, rock outcrops, and older harvest activities are evident. 

These ridges visually frame streams and the wide, winding Indian Creek drainage. Vegetation is 

diverse in both pattern and species, with the Douglas fir/mixed conifer forest being most 

dominant. Conifer species include ponderosa pine, sugar pine, incense cedar, and white fir. Also 

common are riparian forest stringers and mixed hardwood stands of canyon live oak, Pacific 

madrone, and big leaf maple. Some forested areas are extremely dense, where wildfires have 

been artificially suppressed for at least 50 years. This density of vegetation obstructs in-canopy 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

260

views to the forest floor, and also increases the forest risk of extreme wildfire events that could 

be adverse to valued landscape character attributes. Streams display high water clarity. Air 

quality is high, with coastal moisture occasionally adding clouds and haze to the typical clear 

views under blue skies.

Sense of Place

The sense of place in the project area, or landscape character expectations of current user groups 

is defined by an independent, rural residential lifestyle; both the low population density and the 

distance from human population centers contribute to this sense of place. Some local Happy 

Camp residents use the forest as a means of employment such as in logging or commercial 

guiding. Local activities include sightseeing, recreating of all sorts, gathering activities 

(firewood, mushrooms, and other special forest products) and just getting in touch with the land. 

Local residents form a unique interest group that wants a healthy and sustainable watershed in 

what they consider their backyard. Communities of interest include local residents, highway 

travelers and wilderness visitors.

Scenic Attractiveness

The project area is categorized as Distinctive – A along watercourses, high elevation ridges and 

meadows and Common - B along midslopes. 

Scenic Integrity

Scenic integrity is the relative degree of natural appearance displayed by a landscape. In the 

project area, scenic integrity (as viewed from inventoried sensitive viewpoints) includes 

evidence of existing roads and streets, bridges, powerlines, businesses, and isolated residences 

and ranches. These alterations are located primarily on private lands along Indian Creek. As one 

moves upslope onto National Forest System land, there is some evidence of forest roads and 

signs, past logging, and a rock pit. Cumulatively, across the project area as a whole, the 

alterations are minor, and generally a near natural appearance remains dominant and the area 

meets Partial Retention VQOs as defined in the Forest Plan. 

Viewsheds, Visual Sensitivity Levels, and Viewer Position

The table below displays project area viewpoints, their visual sensitivity, and the viewer position 

that project activities may be visible from. The visual assessment of project activities utilized 

these viewpoints. These viewpoints are taken from the inventoried sensitivity level map (Scenery 

Sensitivity Levels map, Klamath National Forest - Westside, 9/19/08) maintained on file in the 

Supervisors Office. There is one National Scenic Byway and three Forest System roads, and one 

campground.
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Table 70. High and Moderate Sensitivity Level Viewpoints

Potential Viewpoint(s) Visual Sensitivity Level 1 Viewer Position 2

Indian Creek Road – #7C01 residences along first 

eight miles (State of Jefferson Scenic Byway) High Inferior

Grayback Road #48 (State of Jefferson Scenic 

Byway) Moderate Inferior

Kelly Lake Trailhead Road (#18N33, #18N30, 

#18N34) Moderate Superior

South Fork Indian Creek Road (#17N32) Moderate Inferior

West Branch Campground High Inferior

Poker Flat Trailhead Road (#18N30, #18N33) Moderate Superior

1 visual sensitivity levels: high=high level of interest in scenery; moderate=moderate use/interest and often characterized 

by a secondary county road or forest road, recreation site or area.

2 viewer positions: inferior=activity is viewed looking up; intermediate=activity is viewed level with the viewer; 

superior=activity is viewed looking down

Recreation 

Recreation use in the project area consists primarily of dispersed recreation activities, including 

camping, swimming, fishing, whitewater rafting, hiking, hunting, and woodcutting. Indian Creek 

is a popular local attraction for swimming, fishing, and whitewater boating. West Branch 

Campground, located along Indian Creek, receives very little use. Two trailheads, Kelly Lake 

and Poker Flat, provide dispersed camping opportunities at the trailhead, hiking and equestrian 

access to the Siskiyou Wilderness and fishing at Kelly Lake. The State of Jefferson Scenic 

Byway traverses the project area, providing an important link for both local residents and 

travelers between the Klamath River corridor and the Illinois Valley in Oregon. One portion 

(Siskiyou-6) of the Siskiyou Roadless Area is located in the project area.

3.13.3 Environmental Consequences

Alternative 1- No Action 

Direct/Indirect and Cumulative Effects

Visual Quality Objectives & Recreation

Under this alternative, there would be no commercial thinning, specialized treatments (e.g. 

sanitation thinning or hardwood release), prescribed burning or road decommissioning. Because 

no actions would be taken in the project area, there would be no changes to Visual Quality 

Objectives; no changes would occur to existing landscape character, sense of place, scenic 

attractiveness, scenic integrity and visually sensitive areas and there would be no changes in 

recreation opportunities. Because no direct/indirect effects would occur, there would be no 

cumulative impacts across the viewshed. 
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Alternative 2 – Proposed Action 

Direct/Indirect Effects

Visual Quality Objectives

VQOs for proposed thinning areas are shown in table 71 below. Other proposed treatments are 

not shown on this table, but are discussed in detail below.

Table 71. Proposed Thinning Treatments within Visual Quality Objective Categories

Proposed Thinning Treatment Visual Quality Objective Category 

(from Forest Plan)

Percent of Treatment 

Area

Thin Natural Stand 

Partial Retention 27%

Modification 68%

Maximum Modification 5%

Thin Plantation 

Retention 1%

Partial Retention 34%

Modification 50%

Maximum Modification 15%

Roadside Pole Thin

Partial Retention 2%

Modification 98%

Roadside Sanitation Thin 

Modification 100%

No proposed treatments would be visible from either of the high sensitivity viewpoints – West 

Branch Campground and the Lower Indian Creek Road (to private land boundary at South Fork 

Indian Creek); these viewpoints are therefore not discussed further.

Underburning

The short term visual impacts from underburning would create brown vegetation, red tree 

crowns, blackened duff layer, scorched trunks, and minor disturbance from fuelbreak 

construction. Recovery times of three years would allow revegetation or “greening up” of many 

of the burn effects. At that point, any residual effects from the underburn would appear as a 

natural occurrence, consistent with the many wildfires that have occurred throughout this area. 

Underburning would create long term positive effects such as the creation of more open stands 

where larger trees can be observed by travelers, greater species diversity, and a reduction in the 

severity of future fires. This activity would easily meet all assigned VQOs and would contribute 

to the Forest Plan Standard and Guideline 11-4 for perpetuating the Forest’s ecologically 

established landscape character. 

Roadside Sanitation Thin & Pole Thin

The thinning of small diameter trees or trees with dwarf mistletoe infection along roads would 

create long term positive effects where travelers can look into more open stands, observe larger 
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trees (where present) and provide greater species diversity. Because none of the roadside 

treatments would occur along high or moderate sensitivity routes and are not visible from them, 

they would easily meet their assigned VQOs.

Commercial Thinning

Most (68%) of thinning in natural stands would occur within Modification VQO; most (65%) of 

thinning in plantations would occur within Modification or Maximum Modification VQOs; most 

(98%) of roadside pole thinning would occur within Modification VQO; and all of roadside 

sanitation thinning would occur within Modification VQO. This means that the majority of all of 

these treatments are consistent with their VQOs since Modification and Maximum Modification 

VQO categories allow for alterations of natural-appearing landscapes.

Proposed thinning treatments would generally create more open stands of varying densities, 

with some openings, and some unthinned areas in small patches. The thinning of small diameter 

trees would create long term positive effects where travelers can look into more open stands, 

observe larger trees (where present) and provide greater species diversity. The retention of taller 

trees with well developed crowns would provide visual screening of units when seen from 

distant viewpoints. 

There are approximately 15 units located in the foreground distance zone (0-1/2 mile) of 

Grayback Road that are in Partial Retention VQO. When traveling this road, its winding nature, 

combined with topographic and/or vegetative screening, severely limit visibility to the road 

itself, except for occasional, brief glimpses thru openings in the trees. None of these units would 

be visible from the road. For this reason, these proposed activities would meet the Partial 

Retention VQO. 

There are numerous commercial thinning units located on the west-facing slope of Indian 

Creek in a Modification VQO area. From the viewpoint near Louse Creek, Units 6, 7, 8, 41, 63, 

and 200 would be visible. Given their distances from the viewpoint, as well as the thinning 

prescriptions, all units would appear natural and meet their respective VQOs. None of the other 

units in the Green Creek, Mill Creek, Doolittle Creek, Deadman Point, and Four Bit Gulch areas, 

as well as any units located west of the Grayback road would be visible from the Grayback Road 

or the viewpoint near Louse Creek.

Units visible along Kelly Lake and Poker Flat roads that have a Partial Retention VQO 

include Units 220, 20, 64, 21, 24, 26, 27, 28, and 227. The thinning of small diameter trees 

would create long term positive effects where travelers can look into more open stands, observe 

larger trees (where present) and greater species diversity from free thinning. All units are located 

in the foreground distance zone and meet the assigned VQO of Partial Retention. Unit 22 is in a 

Retention VQO and project design features have been developed (see Chapter 2) to ensure 

activities are not noticeable. All other units which are not immediately adjacent to these roads 

would not be visible.

Units visible along South Fork Road with a Partial Retention VQO include Units 108, 109, 

110, and 104. Units visible along this road with a Modification VQO include 100, 101, and 103. 
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The thinning of small diameter trees would create long term positive effects where travelers can 

look into more open stands, observe larger trees (where present) and greater species diversity 

from free thinning. These activities would appear near natural and meet the Partial Retention 

VQO. All other units in the South Fork Indian Creek drainage would not be visible when 

traveling along this road. 

Road Decommissioning 

The decommissioning of three road segments would rehabilitate existing visual impacts. At each 

road intersection, the first 100 feet (or more) of the road would be backfilled and recontoured to 

eliminate or hide the intersection. Revegetation of the opening would further disguise the road. 

The three roads are described below:

Road 18N43: This through road intersects with both the 18N30 and 18N33 roads, which are 

both moderate sensitivity routes providing access to the Kelly Lake Trailhead. The west half 

of the road is in a Retention VQO and the east half in a Modification VQO. This activity 

would easily meet the assigned VQOs.

Road 17N28B: This spur is located in a Partial Retention VQO area and is not visible from 

any inventoried sensitivity routes. This activity would easily meet the assigned VQO.

Road 17N02: This through road is located in a Maximum Modification VQO area and is not 

visible from any inventoried sensitivity routes. This activity would easily meet the assigned 

VQO.

Meadow Enhancement

This activity involves the removal of small encroaching conifers, handpiling and burning, and 

limited use of prescribed fire. By eliminating encroachment, this activity would increase plant 

species diversity and perpetuate the Forest’s ecologically established landscape character (Forest 

Plan Standard and Guideline 11-4). ME-5 is located in both the Siskiyou Roadless area and in a 

Retention VQO area and is visible from the Poker Flat Trailhead area. Management activities 

would not be noticeable because project design features have been developed to minimize this 

(see Chapter 2). To eliminate the stark “line effect” between the meadow and adjacent forest, the 

edges would be feathered with a variable spacing, density, and species removal. Burning of cut 

trees and limbs and flush cut stumps would further minimize the noticeability that any 

management activity has occurred. Therefore this area would continue to be natural appearing 

and meet the Retention VQO as well as preserve roadless area characteristics. The elimination of 

conifer encroachment would maintain this area of high scenic quality. All other meadow 

enhancement units (ME1 -4, ME6-14) would not be visible from any sensitive viewpoints, and 

therefore meet their assigned VQOs.

Recreation Opportunities

The operational impacts from the project activities such as traffic, noise, dust, and smoke are 

short-term adverse impacts which would be temporary in nature. Dispersed recreational activities 

such as camping, hiking, hunting and fishing would be affected by these short-term impacts, but 
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due to the large size of the project area and the fact that project activities would be implemented 

over time and not all at once, would minimize these impacts. 

The use of both temporary roads and reconstructed temporary roads would provide 

recreationists approximately seven miles of additional short-term motorized access until these 

roads are hydrologically restored and rehabilitated. The decommissioning of roads would 

eliminate opportunities on these roads for motorized recreation activities such as camping, 

hunting, firewood collection, and driving for pleasure. However, the same types of opportunities 

readily exist on the many miles of roads throughout the project area. 

An indirect beneficial effect of underburning would be a short term increase in forage for 

deer populations and utilization of the area; thus improving the quality of the deer hunt in those 

areas.

Changes in stand structure and composition resulting from different treatments may result in 

some short-term changes in recreational use patterns, but the same recreational opportunities 

would continue following the completion of project activities which is the very nature of 

dispersed recreation. Recreation use and opportunity would not measurably increase or decrease 

as a result of this project.

Cumulative Effects

Individually all project activities would meet or exceed their assigned VQOs; however 

cumulative scenic quality effects are evaluated in a larger context than the individual project 

activities themselves—the potentially affected viewsheds as a whole. The scenery analysis area 

includes the multitude of viewsheds throughout the project area. The cumulative effects from 

past vegetative alterations have slightly diminished scenic quality over the years. However many 

of these past activities have either revegetated or are not visible from sensitive viewpoints. When 

viewed from multiple viewpoints, proposed management activities in all viewsheds would be 

natural or near natural appearing and cumulatively appear visually subordinate to the 

characteristic landscape.

Combining the effects of past, present and foreseeable future projects with the 

implementation of alternative 2 would not result in measurable cumulative impacts to 

recreational opportunities in the project area; all past, present and future actions all have the 

potential for short-term adverse impacts during implementation, but over the long-term these 

would not result in measurable changes in the type or quality of recreational use in the area. 

Alternative 3 – No Temporary Roads

Direct/Indirect and Cumulative Effects

Visual Quality Objectives

The differences between alternative 2 and alternative 3 are small from a scenery and recreation 

point of view. There would be slightly less thinning and slightly more underburning under 
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alternative 3 and no new temporary roads would be built. As discussed for alternative 2, these 

project activities would be consistent with all VQOs for the areas proposed for treatment. The 

project design features developed for Unit # 22 and ME-5 would also apply in this alternative.

Cumulatively, VQOs would be met on all 9,330 treatment acres. As a result, all viewsheds 

would remain natural or near natural appearing and appear visually subordinate to the 

characteristic landscape. 

Recreation Opportunities

The direct, indirect, and cumulative effects of this alternative are essentially the same as 

alternative 2, although there would be less short-term motorized access for dispersed recreation 

activities since there would be no construction of temporary roads.

Alternative 4 – Minimized Underburning

Direct/Indirect and Cumulative Effects

Visual Quality Objectives

The primary difference between alternatives 2 and 4 is total acres treated with underburning. All 

other aspects of alternative 4 (thinning & specialized treatment; logging systems; roads, landings 

and skid trails; meadow enhancement; and road decommissioning) are the same as those 

previously described for alternative 2. Alternative 4 proposes mastication instead of prescribed 

burning to treat fuels within many thinned units to minimize the production of smoke.

A masticator grinds and chops up small diameter trees and brush in place, leaving behind 

crushed vegetation (limbs, brush, trees) which partially covers bare soil. In the short term (1-2 

years), masticated areas would appear lighter in color and more open, thereby increasing textural 

contrasts with adjacent trees or brush. However recovery times for VQOs of three years would 

allow revegetation or “greening up” to reduce effects to acceptable levels. The visual changes in 

color, texture, and scale would appear as natural or near natural appearing occurrences from all 

viewpoints within three years. 

As discussed for alternative 2 and 3, project activities, including mastication, would be 

consistent with all VQOs. The project design features developed for Unit # 22 and ME-5 would 

also apply in this alternative.

Cumulatively, VQOs would be met on all 2,850 treatment acres. As a result, all viewsheds 

would remain natural or near natural appearing and appear visually subordinate to the 

characteristic landscape. 

Recreation Opportunities

The direct, indirect, and cumulative effects of this alternative are essentially the same as 

alternative 2. The significant reduction of the number of acres underburned would provide less 

opportunity to improve the quality of the deer hunt in those areas.
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Summary

Actions proposed under alternatives 2, 3 and 4 would be consistent with Forest Plan VQOs. 

Changes in visual quality and recreational opportunities would be short-term and minor, 

primarily occurring during the time of implementation. Beneficial effects to visual quality would 

occur in the long-term through the development of larger trees and more openings and improved 

recreational access and hunting quality. Treatment proposed in the Siskiyou Inventoried Roadless 

Area would be consistent with roadless area characteristics and management direction.

3.14 Cultural Resources

3.14.1 Methodology

The National Historic Preservation Act (NHPA) requires Federal agencies to take into account 

the effects of their actions on properties listed or eligible for listing on the National Register of 

Historic Places (NRHP). Impacts were assessed using criteria defined by regulations for 

Protection of Historic Properties (36 CFR Part 800). The process begins with the identification 

and evaluation of cultural resources for NRHP eligibility, followed by an assessment of effects 

on eligible resources. If an action could change in any way the characteristics that qualify the 

resource for inclusion on the NRHP, it is considered to have an effect. An effect is a direct or 

indirect alteration of the characteristics of an historic property that qualifies it for inclusion in the

NRHP. Effects are “adverse” when the alterations diminish the integrity of a property’s location, 

design, setting, materials, workmanship, feeling, or association. A “no adverse effect” occurs 

when the project has an effect on the resource but is not harmful to the characteristics that may 

qualify the resource for inclusion on the NRHP.

Archaeological remains are widely recognized as being limited in number, nonrenewable, 

and fragile resources (Nickens 1991; Williamson and Blackburn 1990). These resources consist 

predominantly of the physical evidence or cultural debris left on the landscape by past societies. 

Culturally significant areas may also be classified similarly, and may consist of significant 

concentrations of plants, locations for spiritual practices and sacred viewsheds. Archaeological 

sites and culturally significant areas within the Area of Potential Effect (APE) were identified 

through a field inspection and consultation with the Karuk Tribe. The potential for project 

activities to affect site eligibility to the NRHP was assessed both in the field and after reporting 

on the results of the field inventory and Native American consultation. The KNF is required to 

protect sites from and/or mitigate effects to sites following Section 106 of the NHPA or by using 

Standard Resource Protection Measures (SRPM’s) as outlined in the Programmatic Agreement. 

The primary factor for determining whether project activities would have an effect on cultural 

resources was the level of ground disturbance within the site vicinity. Implementation activities 

such as temporary road construction, construction of fuel breaks to conduct under burns, and the 

use of heavy equipment to complete timber harvesting activities have the most potential for 

affecting cultural resources. 
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It is assumed that fuels treatments, timber harvesting activities, and protection and habitat 

enhancement of botanical or biological resources will have some level of effect to the cultural 

resources within the APE. Portions of the project area were extensively surveyed in an effort to 

locate and record previously unidentified cultural resources within it. In some areas such as the 

pine plantations, the needle cast, slash and thick vegetation made it difficult to locate artifacts. It 

is therefore assumed that some resources (in general those not eligible for the NRHP) may not 

have been identified.

Alternatives are compared using the following impact thresholds, based on 36 CFR Part 800 

as a guide:

Negligible: The effect on cultural sites and areas would be at the lowest levels of detection –

barely measurable with any perceptible consequences, either beneficial or adverse, on 

cultural resources. For purposes of Section 106, the site's NRHP eligibility would not be 

threatened, and the determination of effect would be no adverse effect.

Minor: The effect on cultural sites and areas would be measurable or perceptible, but it 

would be slight and localized within a relatively small area for a site or group of sites. The 

action would not affect the character or diminish the features of a NRHP eligible or listed 

archaeological site and would not have a permanent effect on the integrity of any cultural 

resource site. For the purposes of Section 106, the site's NRHP eligibility would remain 

intact, and the determination of effect would be no adverse effect. A beneficial minor effect 

would involve the maintenance and preservation of sites. For purposes of Section 106, the 

determination of effect would be no adverse effect.

Moderate: The effect would be measurable and perceptible. The action would change one 

or more character-defining features of a cultural resource, but it would not diminish the 

integrity of the resource to the extent that its NRHP eligibility would be jeopardized. For 

purposes of Section 106, the site's NRHP eligibility would be threatened, and the 

determination of effect would be adverse effect. A beneficial moderate effect would involve 

site stabilization. For purposes of Section 106, the determination of effect would be no 

adverse effect.

Major: The effect on cultural or archaeological sites would be substantial, noticeable, and 

permanent. For NRHP eligible or listed archaeological sites, the action would change one or 

more character defining features of an archaeological resource, diminishing the integrity of 

the resource to the extent that it no longer would be eligible for listing in the NRHP. For 

purposes of Section 106, the site's NRHP eligibility would be lost, and the determination of 

effect would be adverse effect. A beneficial major effect would involve active intervention 

to preserve and improve sites. For purposes of Section 106, the determination of effect 

would be no adverse effect. 

Short Term: The effect anticipated to occur within 1 to 5 years of implementation of the 

activity

Long Term: The effect that would occur after the first five years of implementation.

3.14.2 Affected Environment

Prehistoric

The project lies within territory traditionally ascribed to the Karuk Tribe and is an area that was 

utilized for travel, trade and subsistence activities. For generations, the Indian Creek area has 
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been a travel corridor for Karuk tribal members traveling to Oregon, and the Tribe continues to 

use this route to the present day. The Karuk names for geographic areas are descriptive of the 

environmental and/or ecological features and functions of the area. The Karuk Dictionary states 

that Indian Creek is called athithuuff meaning a location that translates into hazel-stick creek. 

The Two Bit project area has numerous stands of hazel both within and adjacent to natural 

openings, plantations and meadow areas. Important species such as hazel were often managed 

and enhanced by the tribe through the use of fire. According to the oral history of the Karuk 

tribe, fire was set as a routine way of maintaining the health of the landscape. Landscapes 

managed intensively by the Karuk people resulted in fine-grained vegetation mosaics that had a 

short-rotation burn regime. These fine-grained mosaics contained numerous plant species that 

were enhanced by the use of fire and aided in perpetuating the oak woodlands/grasslands, 

basketry material and edible and medicinal plant species.

There have been few archaeological investigations into the prehistoric chronology of 

settlement within the Klamath River corridor and its tributaries (including Indian Creek).

Excavations at the Pilot Ridge site (approximately 90 miles southwest of the project area 

revealed evidence of 8,000 years of human occupation and highlighted the fact that 

archaeological site distributions shifted over time in response to climatically induced vegetation 

shifts (Busam 2006:16, Fitzgerald and Hilderbrandt 2001:4, Hildebrandt and Hays 1993a:113). 

Historic

Euro-American trapping brigades first entered Siskiyou County in 1827, with regular forays 

through the area continuing into the early 1840s. With the discovery of gold along the middle 

Klamath River the Karuk’s extensive territory was suddenly overwhelmed – first by miners and 

then by farmers, ranchers, and other more permanent settlers. With the 1851-52 gold strikes, the 

gentler slopes in the lower elevations of the Klamath watershed steadily became transformed 

into intensive mining areas. Grazing of pigs, sheep and cattle has also occurred in the area since 

the 1850s. 

Archaeological Sites

Approximately 38 previously recorded archaeological sites are located within the project area 

boundary. Thirty of these are historic in nature and are associated with mining operations that 

occurred within and adjacent to the Area of Potential Effects (APE). Typically, historic sites on 

the Forest contain structural, household, or mining materials that are susceptible to damage from 

management activities such as underburning. Many of these sites are gradually deteriorating over 

time due to weathering and human activities, which compromise the integrity of materials or 

features. Natural processes such as wildland fire, flooding, weathering, and erosion significantly 

affect historic features especially those made of materials such as wood and metal. There have 

been relatively few prehistoric sites identified in the Happy Camp area. This is not due to a lack 

of such sites, but rather a lack of inventory and recordation over the last 20 years. However, 
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there are 8 previously recorded prehistoric sites located within the project area boundary. All 

archeological sites within the APE in the project area would be flagged and avoided during the 

project activities.

Culturally significant areas

The Two Bit project area has many culturally significant plants that are not in the proper 

condition to be used by local tribal members for edible, medicinal, ceremonial and utilitarian 

items. Aggressive fire suppression and livestock grazing have affected plant populations for 

more than 80 years in the project area. Approximately 80 percent of the area proposed for 

thinning is within existing plantations. Currently, stands are dense and lack species diversity, 

which limits the gathering opportunities for Native Americans. Beargrass and Hazel found within 

these stands are in need of burning to improve their condition for use in weaving.

3.14.3 Environmental Consequences

Alternative 1- No Action 

Direct/Indirect Effects

Archeological Sites

Because no action would be taken in the project area there would be no direct effect on 

archaeological sites from management actions. There is potential for damage to prehistoric and 

historic sites as a result of high intensity fire if a wildfire were to start in the project area. High 

temperatures and prolonged exposure to heat may affect artifacts and the ability to acquire 

relevant data (such as obsidian hydration readings) that would affect the information potential 

and hence NRHP potential of any given site. Fire is especially destructive to historic resources 

made of wood and some metals and would essentially destroy these materials, likely rendering a 

site ineligible for the NRHP. Short term effects to archaeological resources would be minor, but 

long-term effects would be moderate to major.

Culturally Significant Areas 

Because no action would be taken in the project area, there would be no direct effect to cultural 

significant areas from management actions. However, areas in which plants that would benefit 

from the use of fire to enhance species availability would continue to degrade, resulting in a 

gradual loss of the desired species. Continued encroachment and expansion of conifers would 

result in the loss of hardwood species within the project area. The opportunity to provide Karuk 

cultural resources such as basket material, improved hunting and subsistence opportunities 

would be diminished. In addition, high intensity fire may result in the loss of important settings 

and viewsheds used in spiritual practices.

Effects to culturally significant gathering areas would be related to a gradual loss of such 

resources. Over time, this could result in the abandonment of the gathering areas by the Tribe. 
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These areas provide some economic benefit to Tribal people for subsistence and spiritual 

practices. Short and long term effects would be minor to major as a result of loss of 

archaeological data, plant communities and spiritual sites.

Cumulative Effects

Archaeological sites 

If wildfires were to start in the project area, they would likely be of high intensity. Through time, 

high intensity fire within the project area would likely destroy structures and features of historic 

sites that would result in the loss of potential NRHP eligible districts. Combining taking no 

action in the project area with other wildfires that have burned in the surrounding areas (see fuels 

section) would result in loss of data at prehistoric sites would contribute to their deterioration. 

This has the potential to result in ineligibility for the NRHP. Emergency fire suppression 

activities would have minor to major effects on cultural and archaeological properties as a result 

of fuels buildup.

Culturally Significant Areas

Effects to culturally significant gathering areas and plants from high intensity wildfires would 

accelerate over time, resulting in the loss of tribally important plant communities. Effects to 

culturally significant spiritual sites from fires and fires suppression activities could result in the 

loss of important settings and viewsheds, rendering them unsuitable for use in spiritual practices. 

Alternative 2 – Proposed Action 

Direct Effects

Archaeological sites 

Underburning

Any fire, wild or prescribed, may result in cultural resources being damaged, destroyed or result 

in inadvertent exposure of sites to increased visibility and illegal collection activities. High 

intensity wildland fires and prescribed burns could destroy or alter sensitive scientific data that 

can be gathered through the examination of obsidian hydration profiles. Fire use and fuels 

management actions that increase erosion, runoff and compaction rates of soils through 

vegetation loss and use of heavy equipment could engender minor to moderate adverse effects to 

cultural resources located near or within the project area. However, direct effects to 

archaeological sites from underburning for this project would be minimized through avoidance. 

Sites that are historic in nature would be protected through fireline construction. Prehistoric sites 

would be assessed for the information they contain and either protected by fireline construction 

or monitored during the burn process. Thus, the use of fire within the project area would not 

have a direct adverse effect on appropriately mitigated sites.
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Thinning, Specialized Treatment, Meadow Enhancement and Commercially Thinned 

Acres

Direct effects to archaeological sites would be minimized through the implementation of project 

design features which would ensure site avoidance and onsite monitoring during ground 

disturbance. Thus, vegetation manipulation would not have a direct adverse effect to 

appropriately mitigated sites.

Road Construction/Decommissioning

The construction of new temporary roads and the decommissioning of existing roadways have 

the potential to cause direct negligible to major adverse effects to archaeological resources. 

These effects can be caused by the use of heavy machinery to construct or decommission roads 

that go through existing sites. These routes would be identified before project implementation 

and examined by the district archaeologist to insure that no sites would be affected. New roads 

would be constructed outside of site boundaries. Thus, road construction/decommissioning 

activities would not have an adverse effect on appropriately mitigated sites. Short and long term

effects to archaeological sites would be negligible to minor as a result of road construction and 

decommissioning.

Culturally Significant Areas

Underburning

Direct effects to culturally significant plant locales would be beneficial and improve plant health 

and productivity. The reduction of fuels in the project area would act to reduce high severity fire 

effects to spiritual areas, aiding in maintaining culturally significant viewsheds and sacred areas. 

Thus the use of fire within the project area would not have an adverse effect.

Thinning, Specialized Treatment, Meadow Enhancement and Commercially Thinned 

Acres

Direct effects to culturally significant areas would be minimized by implementation of project 

design features including flagging and avoiding known sites. Thus, the use of vegetation 

treatments would not have an adverse effect on these resources. Short and long term effects to 

culturally significant areas would be negligible to minor as a result of vegetation treatments.

Road Construction/Decommissioning

The construction of new roads and the decommissioning of existing roadways could affect 

existing culturally significant plant populations. These areas will be identified and flagged for 

avoidance as appropriate. Short and long term effects to culturally significant areas would be 

negligible to minor as a result of road construction and decommissioning.

Indirect Effects 

Archaeological Sites and Cultural Significant Areas 

Archaeological sites can be affected by the disclosure of site locations as a result of “flag and 

avoid” mitigation. Long-term potential disclosure of site locations would be a result of untreated 
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islands or vegetation pockets that attract attention within treatment areas. Temporary road 

construction has the potential to indirectly incur minor to moderate impacts to archaeological 

and culturally significant areas by providing access to formerly inaccessible areas. Sites may 

then be illegally excavated and artifacts and features may be removed or damaged. Short and 

long term indirect effects to archaeological sites and culturally significant areas would be minor 

to moderate as a result of all proposed project activities.

Cumulative Effects

Combining the implementation of alternative 2 with past, present and future projects would 

result in an overall beneficial effect to culturally significant areas through vegetation 

manipulation and underburning across a larger area, creating improved conditions for important

plants. Archeological sites have the potentially to be adversely affected with any ground 

disturbing action, minimized through flagging and avoiding all known sites during project 

design. Therefore, cumulative effects to archeological sites would be minor to moderate, 

minimized through project design features applied to all past, present and future projects for 

protection and avoidance. 

Reducing the likelihood of a high intensity wildfire through proposed actions in the APE, 

combined with similar types of other projects already implemented or in progress (see 

description of these actions at the beginning of Chapter 3) would result in a cumulative 

beneficial effect to both archeological resources and culturally significant areas. Viewsheds and 

important settings would benefit from this reduction in high severity fire. 

Alternative 3 – No Temporary Roads

Direct and Indirect Effects

Archaeological Sites and Culturally Significant Areas 

The activities that would take place under this alternative are similar to those of alternative 2 

with the exception of there being no new temporary roads constructed. There would be less 

thinning and slightly more burning under alternative 3 when compared to alternative 2. Because 

the types of treatments are the same as alternative 2 and only vary in the quantity, alternative 3 

would have essentially the same effects to archeological resources and culturally significant 

areas as described above for alternative 2. However, no temporary road construction would result 

in less chance for inadvertent archeological site disturbance. In addition, slightly more prescribed 

burning would result in increased benefit to culturally significant areas through improvements to 

preferred plants in more areas. Short and long term direct/indirect effects to archaeological sites 

and culturally significant areas would be negligible to moderate as a result of all proposed 

project activities.
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Cumulative Effects

Archaeological Sites and Culturally Significant Areas

Because the differences between alternative 2 and 3 are small and very primarily in the quantity 

of treatment and not in the type of treatment, cumulative effects are essentially the same as those 

previously described. Combining the implementation of alternative 3 with past, present and 

future projects would result in an overall beneficial effect to culturally significant areas through 

vegetation manipulation and underburning across a larger area, creating improved conditions for 

important plants. Archeological sites have the potentially to be adversely affected with any 

ground disturbing action, minimized through flagging and avoiding all known sites during 

project design. With no new temporary road building under alternative 3, these impacts are 

slightly less than for alternative 2. Therefore, cumulative effects to archeological sites would be 

minor to moderate, minimized through project design features applied to all past, present and 

future projects for protection and avoidance. 

Reducing the likelihood of a high intensity wildfire through proposed actions in the APE, 

combined with similar types of other projects already implemented or in progress (see 

description of these actions at the beginning of Chapter 3) would result in a cumulative 

beneficial effect to both archeological resources and culturally significant areas. Viewsheds and 

important settings would benefit from this reduction in high severity fire. 

Alternative 4 – Minimized Underburning

Direct/Indirect Effects

Archaeological Sites and Culturally Significant Areas 

The activities that would take place under this alternative are similar to those of alternatives 2 

and 3 except that substantially less underburning would occur under alternative 4 and 

mastication would be used as a treatment method. Because the types of treatments (except 

mastication) are the same as alternatives 2 and 3 and only vary in the quantity, alternative 4

would have similar effects to archeological resources and culturally significant areas as 

described above for alternatives 2 and 3. However, mastication would introduce another grounddisturbing activity with the potential for direct adverse effects to archeological resources. This 

would be minimized through flagging all known sites and avoiding them during project 

implementation. Substantially less prescribed burning would result in substantially less benefit to 

culturally significant areas because fewer areas would receive underburning.

However, less underburning also equates to less smoke production. This would result in 

substantially less adverse short-term impacts to Karuk tribal members living in the project area 

due to smoke (see socioeconomics section for more details on local communities). 

Short and long term direct/indirect effects to archaeological sites and culturally significant areas 

would be negligible to moderate as a result of all proposed project activities under alternative 4.
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Cumulative Effects

Archaeological Sites and Culturally Significant Areas

Because the differences between alternative 2, 3 and 4 are relatively small and vary primarily in 

the quantity of treatment and not in the type of treatment, cumulative effects are essentially the 

same as those previously described. Combining the implementation of alternative 4 with past, 

present and future projects would result in an overall beneficial effect to culturally significant 

areas through vegetation manipulation and underburning across a larger area, creating improved 

conditions for important plants. However, this cumulative beneficial effect would be less for 

alternative 4 than for alternatives 2 or 3. Archeological sites have the potentially to be adversely 

affected with any ground disturbing action, minimized through flagging and avoiding all known 

sites during project design. With mastication introduced as an additional ground disturbing 

activity in alternative 4, these impacts are slightly greater than for alternatives 2 or 3. Therefore, 

cumulative effects to archeological sites would be minor to moderate, minimized through project 

design features applied to all past, present and future projects for protection and avoidance. 

Reducing the likelihood of a high intensity wildfire through proposed actions in the APE, 

combined with similar types of other projects already implemented or in progress (see 

description of these actions at the beginning of Chapter 3) would result in a cumulative 

beneficial effect to both archeological resources and culturally significant areas. Viewsheds and 

important settings would benefit from this reduction in high severity fire. 

Summary

Alternative 1 would have minor to major effects on archaeological and cultural significant areas 

within the project area. The potential for high intensity wildfires would continue and this could 

result in adverse effects to these resources resulting in the loss of archaeological data, important 

plant communities and the spiritual practices of the Karuk Tribe.

Alternatives 2, 3 and 4 would have similar adverse and beneficial effects to archeological 

resources and cultural significant areas because the types of treatment would be the same and 

essentially vary only in the quantity of proposed treatments. Because alternative 3 would not 

construct any new temporary roads, adverse effects to archeological sites are less than for 

alternatives 2 or 4. Because alternative 4 includes substantially less underburning than 

alternatives 2 or 3, the beneficial effects to cultural significant areas are less because fewer areas 

of preferred plant species would be underburned.

3.15 Climate Change

3.15.1 Methodology

The methods used to assess how the success of the alternatives could be affected by climate 

change and the predicted impacts of the alternatives on climate change came from guidance in 

the Climate Change Considerations in Project Level NEPA Analysis (USDA 2009f) and 
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276

information provided by the Climate Change Resource Center found at 

(http://www.fs.fed.us/ccrc/topics/landscape-analysis.shtml). 

Cutting trees and prescribed burning can result in the release of greenhouse gases through 

smoke from prescribed burning and to a limited extent, through operation of chain saws and 

vehicles. These actions may also result in alteration of large pulses of greenhouse gas emissions 

through a decrease in the potential for large-scale wildfire. The effect of climate change on the 

proposed project include such as things as changes in rainfall and temperature patterns over time 

that can influence the success of proposed treatments over the long-term. These two factors are 

used to compare alternatives.

3.15.2 Affected Environment

Temperatures range from an average low of 21.5 oF in January to a high of 83.6 oF in July. 

Mean annual precipitation is 62.64 inches, the majority of that occurring in from NovemberMarch with November being the wettest month. 

The temperature of the earth’s atmosphere is regulated by a balance between amount of 

radiation received from the sun that is reflected by the earth’s surface and clouds, and the amount 

of radiation absorbed by the earth and atmosphere. Greenhouse gases, which include carbon 

dioxide and water vapor, keep the earth’s surface warmer than it would be otherwise because 

they absorb infrared radiation from the earth and, in turn, radiate this energy back down to the 

surface. While these gases occur naturally in the atmosphere, there has been a rapid increase in 

concentrations of greenhouse gases in the earth’s atmosphere from anthropogenic (human) 

sources since the start of industrialization, which has caused concerns over potential changes in 

the global climate. For over the past 200 years, the burning of fossil fuels, such as coal and oil, 

and deforestation has caused the concentrations of heat-trapping "greenhouse gases" to increase 

significantly in our atmosphere. These gases prevent heat from escaping to space, somewhat like 

the glass panels of a greenhouse (EPA 2009).

Forests play a major role in the carbon cycle. The carbon stored in live biomass, dead plant 

material, and soil represents the balance between CO2 absorbed from the atmosphere and its 

release through respiration, decomposition, and burning. Over longer time periods, indeed as 

long as forests exist, they will continue to absorb carbon (USDA Forest Service 2009b).

Ongoing climate change research is summarized in reports by the United Nations 

Intergovernmental Panel on Climate Change (IPCC) (www.ipcc.ch), US Climate Change Science 

Program’s Science Synthesis and Assessment Products, and the US Global Change Research 

Program. These reports concluded that climate is already changing; that the change would 

accelerate, and that human greenhouse gas emissions, primarily carbon dioxide emissions, are 

the main source of accelerated climate change (USDA Forest Service 2009b). 

Projected global climate change impacts include air temperature increases; sea level rise; 

changes in the timing, location, and quantity of precipitation; and increased frequency of 

extreme weather events such as heat waves, droughts, and floods. These changes would vary 
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regionally and affect renewable resources, aquatic and terrestrial ecosystems, and agriculture.

While uncertainties would remain regarding the timing and extent magnitude of climate change 

impacts, the scientific evidence predicts that continued increases in greenhouse gas emissions 

would lead to increased climate changes.

3.15.3 Environmental Consequences

Alternative 1- No Action 

Direct and Indirect Effects

Implementing alternative 1, no action, would not result in direct greenhouse gas emissions or 

direct changes in climate or overall vegetation patterns. Carbon would remain sequestered in the 

forested portions of the project area. Not taking action to reduce tree stocking and improve forest 

health in the project area to a condition more in keeping with the existing range of variability 

would contribute to a less resilient ecosystem that would be more susceptible to long-term shifts 

in temperature and rainfall patterns. If a wildfire were to start in the project area, it is likely to be

a high intensity fire. A high intensity, stand-replacing wildfire would result in substantial 

greenhouse gas emissions, primarily through the release of carbon dioxide. 

Because there would be no greenhouse gas emissions produced as a direct result of taking no 

action, implementing alternative 1 would not contribute to the cumulative impacts of past, 

present and future projects.

Alternative 2 – Proposed Action 

Direct and Indirect Effects

It is not currently feasible to quantify indirect effects of individual or multiple projects on global 

climate change (USDA Forest Service 2009b). Implementation of alternative 2 would result in 

release of greenhouse gases through thinning and burning, primarily through release of carbon 

dioxide from burning and emissions from vehicles and equipment used. However, these 

emissions would be localized and temporary. By reducing the risk of high intensity, standreplacing wildfire in the project area, alternative 2 reduces the risk of subsequent substantial 

release of carbon dioxide during a large wildfire. As shown in Section 3.5, table 36, carbon 

dioxide emissions would be substantially lower for a prescribed burn than for a wildfire. There is 

an indirect beneficial effect by treating these acres because live stands of trees would retain 

higher capacity to sequester carbon dioxide compared to stands killed by uncharacteristically 

severe wildfires.

Cumulative Effects

At this time there are no regulations to limit greenhouse gas emissions. The current state of 

science does not allow for site specific analysis of greenhouse gas emissions at local or regional 

levels. Likewise, global climate change models are not yet able to determine specific impacts of 
Chapter 3 Two Bit Vegetation Management Draft Environmental Impact Statement

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greenhouse gases on local climate patterns. In general, however, moving the project area toward 

its natural range of variability would create an ecosystem more resilient to climate shifts over 

time. This would occur in the project area and in other areas in the region where similar 

restoration projects are underway.

Alternative 3 – No Temporary Roads

Direct, Indirect and Cumulative Effects

The relative amount of prescribed burning and thinning treatment proposed for alternative 3 is 

considered the same as alternative 2, for purposes of analyzing effects to climate change; only 

small differences in acres of treatment are proposed. For these reasons, the direct/indirect and 

cumulative effects are the same as those previously described for alternative 2. 

Alternative 4 – Minimized Underburning

Direct, Indirect and Cumulative Effects

The amount of prescribed burning is much lower for alternative 4 than for alternatives 2 and 3.

Carbon monoxide emissions for alternative 4, based on modeling would be substantially lower 

with 4,500 total tons released over the course of the project, compared to 62,000 total tons for

alternatives 2 and 3 (table 36 in Air Quality Section 3.5). However, as discussed in the Fire and 

Fuels section of this chapter, alternative 4 would not reduce the risk of high intensity wildfire in 

treated areas as successfully as alternative 2 and 3; therefore, large pulses of carbon monoxide 

emissions have a greater likelihood of occurring if a wildfire were to start in the project area 

under alternative 4 when compared to alternatives 2 and 3.

However, alternative 4 would achieve project objectives and would result in a more fire 

resilient ecosystem, just not as well as alternatives 2 or 3. Moving the project area toward its 

natural range of variability would create an ecosystem more resilient to climate shifts over time. 

This would occur in the project area and in other areas in the region where similar restoration 

projects are underway.

3.16 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)

The proposed treatments are designed to accomplish multiple objectives and do not 

necessarily maximize timber volume production from Klamath National Forest lands designated 
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as Management Area 17-general forest; however, one of the goals of the Two Bit project is to 

provide a programmed flow of timber products (Chapter 1). An economic analysis was done for 

this project that is summarized previously in this chapter. All action alternatives would generate 

timber volume, jobs, revenue, and labor income. All action alternatives would also result in 

nonmarket benefits and costs that include improved ecosystem health and reduced threat of fire, 

moving the project area toward desired conditions. 

3.17 Unavoidable Adverse Effects

All action alternatives (alternatives 2, 3 and 4) include the implementation of a substantial list of 

design features and best management practices (Chapter 2 and appendix E) intended to avoid, 

minimize the extent of, or reduce the potential for adverse effects on the environment. All 

practicable measures to protect the environment are included in the action alternatives; however, 

some adverse impacts cannot be avoided. Individual larger, older trees would be felled during the 

course of operations. Individual botanical and wildlife species of concern may be harmed or 

disturbed. Erosion would likely be accelerated in some places. Each section of Chapter 3 

describes the spatial and temporal context for unavoidable adverse effects predicted from 

alternatives 2, 3, and 4.

3.18 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.

This project does not involve any irreversible commitments of resources. The short-term and 

long-term impacts described in Chapter 3 involve some irretrievable commitments, including the 

loss of biomass, loss of productivity in areas cleared for roads and landings (limited in extent and 

to be rehabilitated at the end of the project to hasten recovery), and loss of soil in local areas of 

accelerated erosion (cumulative watershed impacts have been discussed – vegetation recovery is 

included in the modeled results). This project does not involve take of any species listed under 

the federal Endangered Species Act.

3.19 Energy Requirements

This project does not involve any unusual energy requirements. Energy efficiency has been 

considered in the logging systems plan, with the most efficient system proposed where consistent 

with prescription objectives and project design features.
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3.20 Legal and Regulatory Compliance

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.” Alternatives 2, 3, and 4 comply with following laws and 

regulations:

Endangered Species Act

Clean Water Act

Clean Air Act

National Historic Preservation Act

Coastal Zone Management Act

National Forest Management Act

There are no conflicts between alternatives 2, 3 and 4 and the objectives of federal, regional, 

state and local policies and plans. 
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Chapter 4. Consultation and Coordination

4.1 Preparers and Contributors 

The Forest Service consulted the following individuals, Federal, State, and local agencies, tribes 

and non-Forest Service persons during the development of this environmental impact statement:

ID Team Members:

Angie Bell: 18 months experience; BS Geology; MS Geology; expertise in Geomorphology; 

responsible for geologic analysis

Bob Talley: 29 years experience in landscape architecture; Bachelor of Landscape Architecture; 

expertise in Scenery, Wild & Scenic Rivers, and Recreation; responsible for recreation and 

scenery analysis

Carol Sharp: 27 years experience in Silviculture; BA in Psychology and 2 years course work in 

Forestry; expertise in silviculture; responsible for silviculture analysis

Clint Isbell: Experience in fire modeling, condition class modeling, fire and fuels planning, and 

monitoring; knowledge and experience in post fire severity mapping, ecological data analysis, 

and ArcGIS. BS in Natural Resources; MS in Natural Resources-Fire Ecology; expertise in 

firefighting and fire ecology; responsible for fire/fuels and air quality analysis

Dustin Walters: 10 years experience in soils and hydrology; MS in natural resource conservation 

from University of Montana; expertise in NEPA analysis and environmental compliance, 

watershed restoration, watershed improvement assessments, BMP monitoring, timber analysis, 

estimating project costs, NEPA writing

Deborah Lutch McGlothlin: 19 years experience in wildlife management, National 

Environmental Policy Act coordination and implementation and interdisciplinary team 

leadership; responsible for project co-team leadership, document preparation and project record

Erin Rentz: 8 years experience in botany and plant ecology; BS Botay; MS Ecology and 

Systematic Biology; expertise in Botany, weed management, monitoring and plant inventory; 

responsible for botany and noxious weed analysis

Gregg Bousfield: 5 years experience in watershed sciences; BS Forest Hydrology, MS Watershed 

Management; expertise in road sediment source identification, GIS, data analysis and modeling; 

responsible for water analysis and cumulative watershed effects modeling
Chapter 4 Two Bit Vegetation Management Draft Environmental Impact Statement

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Janice Schultz: 9 years experience in writing and editing technical documents for the National

Environmental Policy Act; expertise in formatting, writing and editing, preparing administrative 

records for NEPA, and public affairs; responsible for document compilation 

John Allen: Bachelor’s degree in Natural Resource Management, 30 years in timber sale and 

fuels management project planning and preparation, interdisciplinary team leadership, and NEPA 

coordination and oversight. Assistant team leader for this project

Jon Grunbaum: 20 years experience in fishery and watershed sciences; BS Fisheries Science,

MS Fisheries Science; expertise in fisheries monitoring and inventory, and land/water 

interactions; responsible for fisheries analysis

Joshua Wilson: 4 years experience in resource economics and public lands management; BS 

Managerial Economics; MS Agriculture and Resource Economics; 2 years graduate work in 

Forestry; responsible for socioeconomic analysis

Juan de la Fuente: 35 years experience in geology; BS in Geology; expertise in geomorphic 

processes; responsible for geology analysis 

Kathy McCovey: 8 years experience in forestry, 15 years experience in archaeology and 

anthropology; BS in Anthropology/Archaeology; currently a student in the Environment and 

Community Master's program at Humboldt State University; expertise in 

archaeology/anthropology, forestry, ethnobotany, and Native Americans of northern California; 

30 years of fire experience

Nicholas Larson: 8 years experience in forest management; BS Forest Science; expertise in 

forestry; responsible for project coteam leadership

Richard VandeWater: 17 years experience in GIS; MS in Sociology; expertise in GIS and 

database management; responsible for mapping, database management and GIS

Tim Burnett: 17 years experience in wildlife management; BS in Wildlife Biology

4.2 Federal, State, and Local Agencies:

Since project initiation in 2008, the Forest Service worked with local, state, and federal agencies 

and Karuk tribal representatives to develop the alternatives. The coordination with others has 

occurred as part of public involvement for the project and as part of compliance with laws, 

policies and plans described throughout this document.
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Interagency consultation with US Fish and Wildlife Service and National Marine Fisheries

Service is currently in progress regarding effects to listed species under the Federal Endangered 

Species Act, such as coho salmon, northern spotted owl, and fisher.

Representatives from the state of California reviewed the part of the project in inventoried

roadless area and the State Water Board visited the project in the field.

The project was discussed at regular monthly meetings with Karuk tribal representatives.

Distribution of the Environmental Impact Statement.

This environmental impact statement has been distributed to individuals who specifically 

requested a copy of the document. In addition, copies have been sent to the following Federal 

agencies (or agencies otherwise notified of availability); federally recognized tribes, State and 

local governments, and organizations:

American Forest Resource Council

Office of Environmental Policy and Compliance

U.S. Department of the Interior Fish and Wildlife Service

Environmental Protection Agency, Region 9

National Marine Fisheries Service

North Coast Regional Water Quality Control Board

California Department of Fish & Game

USDA, National Agricultural Library

Karuk Tribe

Klamath Forest Alliance

Klamath – Siskiyou Wildland Center

Klamath Alliance for Resources and Environment

Siskiyou County

Siskiyou County Fish and Game Commission

Cascadia Wildlands Project

Environmental Protection Information Center

Oregon Wild

Sierra Pacific Industries

Advisory Council on Historic Preservation

USDA, APHIS PPD/EAD

NOAA Office of Policy and Strategic Planning

Natural Resources Conservation Service

US Army Engineer Division, South Pacific
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4.4 Glossary

90th Percentile Fire Weather The highest 10% of fire weather days. Fuel moisture, 

temperature, relative humidity, and wind speed are only exceeded 10% of the time based on 

historical weather observations; also called severe conditions

Active Crown Fire A fire that moves into and through the tree crowns, generally due to a 

combination of fire intensity and ladder fuels

Activity Fuels Fuels created by management actions

Anadromous Fish Species of fish that are born in freshwater, move to the ocean to mature, 

and return to freshwater to reproduce
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Annosus root disease (Heterobasidion annosum) Fungus that attacks a wide variety of 

woody plants. Infection may spread by spores that colonize freshly cut stumps or basal wounds, 

or via root contact

Aquatic Living or growing in water

Aquatic Conservation Strategy A strategy “developed to restore and maintain the ecological 

health of watersheds and aquatic ecosystems contained within them on public lands”

(USDA Forest Service and USDI Bureau of Land Management 1994b, B-9)

Aquatic Conservation Strategy Objectives Objectives that “define the context for the agency 

review and implementation of management activities. Complying with the Aquatic Conservation

Strategy objectives means that an agency must manage the riparian-dependent resources to 

maintain the existing condition or implement actions to restore conditions. The baseline from 

which to assess maintaining or restoring the condition is developed through a watershed analysis. 

Improvement relates to restoring biological and physical processes within their ranges of natural 

variability.” (USDA Forest Service and USDI Bureau of Land Management 1994b, B-10)

Areas with Watershed Concerns (AWWC) Areas identified in the LRMP ROD (USDA 

Forest Service 1995b) because cumulative watershed effects are a special concern due to a 

combination of high disturbance levels (roads, timber harvest, fire), potential for landslides, 

potential for surface erosion, and poor aquatic habitat conditions. The LRMP ROD (ibid.) states 

that a “cautious approach will be taken in AWWC, with respect to future land management 

activities,” and that “Watershed Analysis, as part of ecosystem analysis, will be required prior to 

implementing site-disturbing activities”

Basal Area~the term used in forest management that defines the area of a given section of land 

that is occupied by the cross-section of tree trunks and stems at their base.

Beneficial Uses “Beneficial uses” of the waters of the state that may be protected against water 

quality degradation include, but are not necessarily limited to, domestic, municipal, agricultural, 

and industrial supply; power generation; recreation; aesthetic enjoyment; navigation; and 

preservation and enhancement of fish, wildlife, and other aquatic resources or preserves (from 

Section 13050(f) of California’s Porter-Cologne Water Quality Control Act)

Best Management Practices Measures certified by the State Water Quality Control Board and 

approved by the Environmental Protection Agency as effective means of reducing water quality 

impacts from non-point sources of pollution

Black Stain Root Disease ~ a tree root disease that is distinguished from other root diseases by 

dark-brown to purple-black discoloration in the sapwood of the lower bole and root collar. When 

observed in cross section, the black stain appears in arcs roughly concentric with the growth 

rings. L. wageneri var. pseudotsugae (Harrington et Cobb) causes black stain in Douglas-fir

Board Foot A unit of measurement equal to an unfinished board one-foot square by one-inch 

thick

Burn Severity Effects of fire on the soil surface; related to fire intensity and duration

Canopy: Tree crowns in a stand
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Canopy Base Height The distance from the ground to the base of the tree crowns (usually an 

average value for a stand)

Capable Lands Lands where at least 20 cubic feet of commercial wood products can be 

grown per acre per year

Chain ~ Unit of linear measure often used on public lands, particulary in measuring the rate of 

wildfire spread (chains per hour). One chain equals 66 feet.

Classified Road Roads wholly or partially within or adjacent to National Forest System lands 

that are determined to be needed for long-term motor vehicle access, including State roads, 

county roads, privately owned road, National Forest System roads, and other roads authorized by 

the Forest Service

Coarse Woody Debris (CWD) Woody material at least 20-inches in diameter from whatever 

source that is dead and lying on the forest floor. Term used for terrestrial species habitat. See 

Large Woody Debris for aquatic species habitat

Conk ~ A fibrous but sometimes fleshy fruiting body of a wood-rotting fungus that has a definite 

form and structure.

Compacted Soils Soils with reduced porosity

Critical Habitat Defined in the ESA as (1) the specific areas within the geographical area 

occupied by the species, at the time it is federally listed, on which are found those physical or 

biological features essential to the conservation of the species, and which may require special 

management considerations or protection; and (2) specific areas outside the geographical area 

occupied by the species at the time it is listed, when it is determined by the Secretary of the 

Interior that such areas are essential for the conservation of the species

Crowning Situation where fire rises to the tree tops and begins advancing from tree top to tree 

top, or where fire intermittently ignites tree crowns as a surface fire advances.

Cumulative Effects Those effects resulting from incremental effects of actions, when added to 

other past, present, and reasonably foreseeable future actions, regardless of what agency or 

person undertakes such other actions

Cumulative Watershed Effects Model A model for Cumulative Watershed Effects with three 

components: Equivalent Roaded Acres (ERA), sediment delivery from surface erosion (USLE), 

and sediment delivery from mass wasting (GEO). The model quantifies disturbances and land 

sensitivity at the 7th field watershed scale and can calculate them at larger scales. The estimated 

results fall on a continuum. As disturbances increase over time and space, at some point the risk 

of initiating or contributing to existing adverse cumulative watershed impacts becomes a cause 

for concern. Concern thresholds have been identified for each component based on field 

observations in the Forest

Diameter Breast Height (DBH) The diameter of a standing tree at a point 41⁄2 feet above 

ground level, measured from the uphill side.

Direct Attack Any treatment applied directly to burning fuel such as wetting, smothering, or 

chemically quenching the fire or physically separating the burning from unburned fuel.
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Direct Effects Those effects occurring at the same time and place as the initial cause or action.

Dispersal The relatively permanent movement of individual animals from one location to 

another. Usually dispersal is the movement of young animals from where they were born to a site 

where they eventually settle to breed

Douglas-fir beetle ~Adults and larvae of the species Dendroctonus pseudotsugae Hopkins feed 

in the phloem layer of inner bark, girdling tree, and usually killing it. Evidence that a Douglas-fir 

has been successfully attacked is the red-orange boring dust in bark crevices or on the ground 

around the tree.

Dwarf Mistletoe (Arceuthobium spp.) A host specific parasitic seed plant found in all the 

major conifer species (red fir, white fire, Douglas-fir and incense cedar)

Ecosystem A dynamic community of biological organisms, including humans, and the 

physical environment with which they interact

Effects Impacts; physical, biological, economic, and social results (or expected results) from 

implementing an activity

Embeddedness Degree to which large streambed materials such as cobbles and gravel are 

surrounded or covered by fine sediment

Endangered Species Any species that is in danger of extinction throughout all or a significant 

portion of its range

Environmental Justice: Executive Order 12898 requires an assessment of whether minorities or 

low-income populations would be disproportionately affected by proposed actions

Equivalent Road Acres (ERA) An index of average watershed disturbance expressed in road 

equivalent acres relative to a “threshold of concern” assigned for the watershed.

Erosion: A general term for movement of soil particles on the surface of the land initiated by 

rainfall and running water. This includes surface erosion and channel erosion, as opposed to 

landsliding

Filtering Capacity Ability of a riparian reserve to trap sediment and prevent it from reaching 

a stream.

Fine Fuels Fuels less than 3 inches in diameter that is easy to ignite

Fir Engraver Beetle (Scolytus ventralis) A burrowing beetle that attacks most true fir species 

in the western United States; attacks can result in bark kill around the tree bole, top kill, and tree 

mortality

Fire Behavior The manner in which a fire reacts to fuels, weather, and topography

Fire Intensity A general term relating to the heat energy released in a fire

Fire Regime The combination of fire frequency, predictability, intensity, seasonality, and 

distinctive characteristics of fire in an ecosystem; Agee (1993) defines three broad categories of 

fire severity “based on the physical characters of fire and the fire adaptations of vegetation”

Flatheaded Fir Borers ~ Insect larvae of the species Melanophila drummondi (Buprestidae) 

invade previously weakened trees. Adult lays eggs in crevices in the bark and their larvae destroy 

the cambial surface of trees. This species typically attacks injured, mistletoe infected, dying, fire-
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killed and recently felled trees but sometimes it attacks and kills apparently healthy trees, 

especially on dry sites.

Imminent Mortality Mortality is imminent when the majority of the root system is destroyed 

and the remaining roots can no longer support the remaining live portions of the tree (Thies and 

Sturrock 1995). We define “imminent” as likely to occur in several months to, possibly, a few 

years (up to five). Similarly, mortality is imminent in trees with destroyed portions of crowns 

and thus with greatly diminished ability to supply adequate quantities of carbohydrates to the 

bole and roots. Imminent mortality occurs when the carbohydrate budget is in deficit; respiration 

exceeds photosynthesis, and stored carbohydrate reserves become exhausted (Waring 1987).

Laminated Root Rot ~ one of the most damaging root diseases amongst conifers in 

northwestern America. It is caused by Phellinus weirii, a fungus, and affects mostly fir trees and 

cedars

Low Severity Fire Regime Effect of typical fire is benign; fires are frequent (often < 20 

years), of low intensity, and the ecosystems have dominant vegetation well-adapted to survive 

fire

Mixed Severity Fire Regime Fires are of intermediate frequency (25-100 years), range from 

low to high intensity, and have vegetation with a wide range of adaptation

High Severity Fire Regime Fires are usually infrequent (often >100 years) but may be of high 

intensity, most vegetation is at least top-killed

Fire Return Interval Number of years between two successive fire events in a given area.

Fire Risk The statistical probability of a fire start occurring over a ten-year period for a given 

thousand-acre area

Fire Severity The degree to which a site has been altered or disrupted by fire; severity is 

affected by fire intensity and how long the fire remains at the site. In this document, fire severity 

is defined as tree mortality

Fire Suppression All work and activities associated with extinguishing a fire

Force Account Term to refer to Forest Service personnel and equipment

Forest Plan (LRMP) The Klamath National Forest Land and Resource Management Plan, 

approved in 1995. The Forest Plan provides land allocations, Standards and Guidelines, and 

direction for management of the Klamath National Forest.

Fuel Loading The quantity of fuel per acre in a given area

Fuel Treatment The process of removing and/or modifying natural or human created fuels to 

reduce fire hazard and achieve other resource objectives

Fuels Anything within the forest that will burn; usually live and dead woody vegetation

Full-Bench Skid Trails For ground-based equipment skid trails, the entire road surface is cut 

into the hill slope

Geographical Information System Coverage Data layer in a Geographical Information 

System.
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Grapple System A mechanical method of piling fuels using an articulating arm on a low 

ground pressure vehicle that picks up the material and places it on the pile

Green Tree Retention A regeneration cut in an even-aged silvicultural system that maintains a 

portion of the existing stand, creating a two-storied structure with two or more age classes 

present

Ground-based Equipment Equipment that runs on the ground, like tractors, rubbertired 

skidders, and masticators

Group Selection Harvest treatment in an uneven-aged silvicultural system that removes small 

groups of trees, resulting in different age classes in the stand

Hawksworth Rating System A system developed by Hawksworth in 1977 to rate severity of 

infection by dwarf mistletoe in a tree or stand. The rating system forms a basis for defining 

management implications and recommendations

Head of Fire Advancing edge

Healthy Stand (for the Project Area) Exhibits insect and disease levels such that mortality is 

not substantial (snag and coarse woody debris levels are within Forest standard and guidelines); 

little decadence (few dead or dying trees, relatively few large down logs or snags) although the 

area maintains some structural components of older stands; trees per acre (stocking level) within 

the range that can be supported by the land; and conditions such that wildfire would not burn 

more than 25% of the dominant vegetation at a high intensity

Hydrologic Dealing with the movement and properties of liquid water in environmental 

systems. Includes the circulation patterns of water in the biosphere from condensation and 

precipitation to movement both on and under the ground surface to evaporation back into the 

atmosphere

Hydrologic Recovery Harvested timber stand with sufficient canopy closure that snow 

accumulation, melt rates, and soil protection from raindrop impact are comparable to pre-harvest 

levels; this typically is achieved when the average tree size is 8” diameter breast height or 35 feet 

tall. Recovery is complete by around 30 years after harvest on the westside of the Forest

Hydrologic Restoration A term used in this analysis regarding rehabilitation of temporary 

roads, skid trails and landings after use. Actions such as removal of berms, re-contouring,

spreading of slash or straw, and/or installation of water bars or similar measures would be used 

to minimize surface runoff and erosion and encourage natural revegetation. 

Impacts Physical, biological, economic, and social results (or expected results) from 

implementing an activity

Incorporation by Reference A technique used to cut down on the bulk in environmental 

documents without impeding agency and public review of the action. The material included as 

part of the document must be cited in the document and its content briefly described 

Indirect Effects Those effects occurring later in time or that are spatially removed from the 

activity
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Inference Point The midpoint of a zone where disturbances become great enough to cause 

concern about initiating or contributing to adverse cumulative watershed effects

Infiltration (soil) The movement of water through the soil surface into the soil

Interdisciplinary The utilization of individuals representing two or more areas of knowledge 

and skills focusing on the same subject

Irretrievable An irretrievable commitment of resources entails a loss of production, harvest, 

or use of natural resources. Such decisions are reversible, but the production opportunities 

foregone are irretrievable (50 Federal Register 26082)

Irreversible An irreversible commitment of resources entails a loss of future options. This 

applies primarily to the effects of use of non-renewable resources such as minerals or cultural 

resources, or to those factors, such as soil productivity, that are renewable only over a long 

period of time (50 Federal Register 26082)

Issue Point of discussion, debate, or dispute about the environmental effects of the proposed 

action

Ladder Fuels Small trees and brush in the understory that allow fire to move from the ground 

into the tree crowns

Land Allocation The assignment in the LRMP of a management emphasis to particular land 

areas with the purpose of achieving goals and objectives

Late-successional characteristics Characteristics of a stand of trees indicative of maturity, 

including mature and overmature trees in the overstory; multi-layered canopy with trees of 

several age classes; and standing dead trees and down material

Late-successional habitat Older forested stands with moderate to high canopy closure; often 

containing a multilayered, multispecies canopy dominated by large overstory trees; large trees 

with broken tops or other indications of old and decaying wood; numerous large snags; and 

moderate to heavy accumulations of large logs on the ground

Late-successional stands Late-successional stands within the Project Area are defined as 

stands with an average DBH greater than 24 inches. On the north and east facing slopes, theses 

stands contain a mix of conifer species and generally exhibit complex structure and abundant 

DWD. Late-successional stands on south and west facing slope, are typically more open and pine 

dominated with less DWD. True fir late-successional stands are generally single storied with 

little understory

Late-successional reserves (LSR) Large blocks of habitat that are distributed across the range 

of the northern spotted owl and spaced closely enough to facilitate dispersal of owls. Latesuccessional reserves are managed to provide habitat for late successional and “old growth” 

species

Management Area (MA) A distinct geographical area with specified objectives and 

prescriptions
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Management Direction A statement of multiple use and other goals and objectives, along 

with the associated management prescriptions and Standards and Guidelines to direct resource 

management

Mass Wasting Movement of soil material in landslides and debris torrents

Masticator Equipment that grinds or chews up vegetative material

Matrix Lands outside of reserves and withdrawn areas; lands assigned a regulated timber yield

Monitoring Process of collecting information to evaluate if objective and anticipated or 

assumed results of a management plan are being realized or if implementation is proceeding as 

planned

Montane Pertaining to mountain conditions

National Environmental Policy Act (NEPA) The act that governs how federal agencies 

assess impacts of management actions on public lands. The process is interdisciplinary and 

requires consideration of the environmental effects of alternatives and disclosure of those effects.

National Forest System Road A classified Forest road under the jurisdiction of the Forest 

Service. The term “National Forest System Roads” is synonymous with the term “forest 

development roads” as used in 23 U.S.C. 205

Noxious Weed Any plant so designated by the Weed Control Regulations and identified on a 

regional district noxious weed control list. They are generally non-native and resistant to control 

efforts

Overstory The portion of trees in a forest which forms the uppermost layer of foliage

Passive Crown Fire A fire that remains on the ground surface but exhibits some individual 

tree or group torching; fire intensity is still fairly low

Peak Flow The greatest stream or river flow occurring in a year from a single storm event

Port-Orford-Cedar Root Disease ~ the most serious disease of Port-Orford-cedar 

(Chamaecyparis lawsoniana) is a root disease caused by the fungus Phytophthora lateralis. 

Infected trees are often attacked by bark beetles, which speed death and may modify foliage 

discoloration by altering the rate of drying. Recently killed trees are pre-disposed to windthrow.

Quadratic Mean Diameter (QMD) ~ the measure of average tree diameter conventionally used 

in forestry. QMD was chosen as an indicator because of its relationship to the health of trees and 

susceptibility to damage from fire and its relationship to calculating stand density index (SDI).

QMD combined with trees per acre (TPA) also reflects the number of small diameter trees that 

may function as ladder fuels.

Rain-on-Snow Event Rain falling on a snowpack and rapidly melting the snow, causing the 

melt water to be added to the rain, creating flood conditions

Record of Decision A document separate from but associated with an environmental impact 

statement that states the management decision and provides the rationale for that decision

Red Ring Rot ~a wood-decay disease of the inner wood of stems of living conifers. It is caused 

by the fungus Porodaedalea

Residual The trees remaining after harvesting; also known as the crop trees
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Resilience An ecosystem’s ability to maintain structure and patterns of behavior in the face of 

disturbance

Riparian In general, characterized by being situated on the bank of a river or other body of 

water; in ecology, the term is applied both to species that live near streams and to the area 

adjacent to streams where vegetation and microclimate are influenced by the presence of the 

stream

Riparian Reserves A land allocation in the LRMP that includes an aquatic ecosystem and the 

adjacent upland areas directly affecting it. It also includes unstable and potentially unstable lands 

that are not associated with aquatic areas. Specific Standards and Guidelines provide direction 

for these areas as outlined in Management Area 10 of the LRMP

Risk The chance of loss

Risk Ratio (for cumulative watershed effects model) Amount of the disturbance in the 

watershed relative to the hydrologic or sediment inference point

Road A motor vehicle travelway. A road may be classified, unclassified, or temporary (36 CFR 

212.1).

Classified Roads: Roads wholly or partially within or adjacent to National Forest 

Systemlands that are determined to be needed for long-term motor vehicle access, 

including State roads, county roads, privately owned roads, National Forest System 

roads, and other roads authorized by the Forest Service (36 CFR 212.1).

Temporary Roads: Roads authorized by contract, permit, lease, other written 

authorization, or emergency operation, not intended to be a part of the forest 

transportation system and not necessary for long-term resource management (36 CFR 

212.1). For purposes of this project, temporary roads are assumed to have a 10 to 20-

foot-wide driving surface, with an average driving surface width of 12 feet and a 15 to 

30-foot-wide road prism width, depending on steepness of slope.

Unclassified Roads: Roads on National Forest System lands that are not managed as 

part of the forest transportation system, such as unplanned roads, abandoned travelways, 

and offroad vehicle tracks that have not been designated and managed as a trail; and 

those roads that were once under permit or other authorization and were not 

decommissioned upon the termination of the authorization (36 CFR 212.1). The 

regulations at 36 CFR 223.37 require revegetation within 10 years.

Road Cut Soil or rock material removed during road construction, usually from the upslope 

side of the road

Road Decommissioning Activities that result in the stabilization and restoration of unneeded 

roads to a natural state. For purposes of this analysis, decommissioned roads would no longer be 

used by motor vehicles; actions would include such things as removal of aggregate, excavation 

of culverts, stream channel restoration, decompaction of road surfaces, cross-ditching (drainage 

structures), outsloping, seeding or mulching exposed soils, disposing of excavated culverts, and 

blocking vehicular access with a series of berms or barriers.

Road Fill Soil or rock material placed on the ground as part of the road surface

Road Maintenance The ongoing upkeep of a road necessary to retain or restore the road to the 

approved road management objective
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Sanitation The removal of damaged or susceptible trees, essentially to prevent the spread of 

insects or disease; an improvement cut

Scoping The process used to identify the scope of issues to be addressed and to determine the 

significant issues related to a proposed action

Sediment Soil particles in water. Suspended sediment consists of small soil particles carried 

along by the water’s turbulent flow

Silviculture The art and science of growing and tending forest vegetation. It includes 

controlling the establishment, composition, and growth of forests for specific management goals

Silviculture Prescription A site-specific operational plan that describes the forest 

management objectives for an area. It prescribes the method for harvesting the existing forest 

stand, and a series of silviculture treatments that will be carried out to establish a free growing 

stand in a manner that accommodates other resource values as identified

Site Potential Tree Height The average maximum height of the tallest dominant trees (200 

years or older) for a given site class

Skyline Yarding System Moving logs from the stump to the landing either partially or fully 

suspended by a cable

Snag A standing dead tree

Social Analysis Analysis that uses social science information to determine how proposed 

actions would affect humans

Soil Porosity State of having pores or holes in the soil that hold air or water; permeability

Soil Productivity The capability of a soil to produce a specific crop such as fiber, forage, etc., 

under defined levels of management

Stand A community of trees or other vegetation uniform in composition, constitution, age, 

spatial arrangement, or condition to be distinguishable from adjacent communities

Stand Density Index (SDI): A relative measure of the amount of stocking on a forest area. 

Often described in terms of stems per acre

Standard and Guideline A principle requiring a specific level of attainment, a rule to measure 

against

Stocking The degree to which trees occupy the land, measured by BA and/or number of trees 

by size and spacing, compared with a stocking standard; that is, the BA and/or number of trees 

required to fully utilize the land's growth potential. Where tree growth is inhibited due to 

competition from too many trees, the site is said to be overstocked

Stocking Control See thinning

Suppression Forces Resources used to fight a fire, consisting of firefighters with hand tools at 

a minimum; may also include fire engines and bulldozers, helicopters and tanker planes

Suppressed Trees Smaller trees in the lower canopy layer

Surface Fire Fire that remains on the forest floor because the combination of fire intensity and 

ladder fuels is not sufficient to move it into the tree crowns. Only surface fuels and small 

vegetation are burned
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Surface Fuels Loose combustible material on the soil surface, consisting of fallen leaves, 

twigs, bark, and small branches, as well as grasses, small plants, seedlings trees, dead branches, 

and logs

Thinning Removing trees from a stand to redistribute the growth potential or to benefit the 

quality of the residual stand

Threatened Species Any species that is likely to become an endangered species within the 

foreseeable future throughout all or a significant portion of its range

Torching Ignition and subsequent flare-up of a fire, usually burning from the bottom to the top 

of a tree or small group of trees

Tree Crown Leafy portion

Turbidity Deposition of substrate material suspended in water

Understory Vegetation (trees or shrubs) growing under the canopy formed by taller trees.

Variable Density Thinning A thinning treatment that results in an irregularly distributed and 

unevenly stocked stand. Conditions range from widely spaced (40’–60’) trees (those being 

cultured for large tree attributes) to no-thin areas with dense thickets of trees. Between these 

extremes, the remaining stand is thinned with variations according to tree species, crown 

position, tree attributes, slope position, aspect and elevation

Velvet Top Fungus ~ Fungi of the species Phaeolus schweinitzii t attack heartwood in living 

trees and are one of the most common root- and butt-rotting fungi. Many conifer species in 

North America and throughout Eurasia are susceptible. Typically, a tree becomes infected when a 

spore enters at a wound.

Vertical Fuels Standing vegetation, either live or dead.

Watershed The entire land area that drains to a specific point

5th field watershed: A watershed that ranges from about 40,000 to 250,000 acres in size

6th field watershed: A watershed that ranges from about 10,000 to 40,000 acres in size

7th field watershed: A watershed or drainage that ranges from about 2,500 to 10,000 

acres in size

Water Repellency (for soils) Loss of soil porosity, preventing water from infiltrating and 

causing water to run off

Watershed Analysis Watershed analysis is a systematic procedure for characterizing 

watershed and ecological processes to meet specific management and social objectives

Western Oak Bark Beetles ~ Insects of the species Pseudopityphthorus pubipennis are native to 

California and other parts of the western United States and attack stressed, dying, and recently 

dead trees, often those infected by the sudden oak death pathogen. Soon after bleeding or 

seeping on the surface of the main tree stem appears due to sudden oak death infection, oak bark 

beetles aggregate and attack the tree close to the bleeding sites.

Wet Weather Operations Standards Specific information used to help determine when 

activities are at risk of not meeting BMPs. The guidelines are used to determine if conditions are 

favorable for wet weather or winter operations, and to provide guidance as to when conditions 
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warrant suspension of operations, when operations may begin or resume, or when and what 

remedy may be appropriate.

White Pine Blister Rust ~ A non-native rust fungus of the species Cronartium ribicola. The 

disease is often most severe following years with extended, cool, moist conditions during late 

summer and early fall. Infections of pine, typically in young trees, are not consistent from year to 

year, but occur in "wave years," when weather is ideal.
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4.5 Index

A

Aquatic Conservation Strategy, 3, 9, 12, 20, 21, 22, 

43, 47, 131, 138, 146, 149, 152, 154, 292, 294, 

310, 370, 371

Archaeological Sites, 269, 272, 273, 274, 275

B

Best Management Practices, 21, 37, 38, 291, 292, 

294, 376

C

Climate Change, 67, 275, 276, 292

Consultation, 1, 4, 5, 281

Cumulative Watershed Effects, 12, 154, 291, 295

F

Forest Plan, viii, 1, 2, 6, 8, 9, 11, 12, 16, 20, 22, 27, 30, 

33, 34, 49, 50, 51, 59, 61, 62, 66, 96, 108, 112, 

131, 134, 135, 138, 146, 149, 152, 154, 166, 167, 

168, 172, 179, 183, 184, 186, 199, 200, 207, 209, 

211, 212, 213, 234, 235, 243, 244, 252, 258, 259, 

260, 262, 264, 267, 292, 297, 310, 319, 327, 378

K

Klamath National Forest Plan, 2, 240, 252

L

Late-Successional Reserve, 6, 8, 28, 290

Logging Systems, 19, 29, 245, 288, 326, 366

M

Matrix, 2, 300

P

Project Design Features, 37, 39

Public Involvement, 11

R

Riparian Reserves, 2, 3, 6, 7, 9, 10, 12, 16, 17, 19, 20, 

21, 22, 27, 28, 29, 33, 40, 41, 42, 43, 44, 47, 48, 

50, 106, 135, 139, 141, 146, 150, 154, 159, 160, 

162, 163, 165, 166, 181, 187, 191, 301, 308, 364, 

370, 376, 377, 379, 380, 381

Roadless Area, 5, 6, 66, 261, 291

S

Scoping, 302, 306

T

Thinning, 8, 15, 16, 17, 18, 19, 27, 28, 29, 33, 50, 51, 

60, 61, 75, 96, 97, 99, 100, 102, 103, 104, 105, 

108, 141, 147, 158, 160, 171, 173, 176, 178, 192, 

221, 225, 228, 232, 233, 235, 239, 240, 241, 242, 

262, 263, 272, 303, 313, 315, 316, 330, 378

U

Underburning, viii, 13, 16, 21, 22, 27, 29, 30, 33, 34, 

40, 45, 46, 58, 61, 75, 103, 104, 105, 106, 107, 

120, 123, 142, 148, 149, 150, 152, 160, 164, 165, 

166, 174, 178, 197, 205, 206, 213, 220, 226, 228, 

229, 232, 236, 239, 241, 242, 254, 255, 262, 266, 

271, 272, 274, 278, 322, 330, 390

V

Visual Quality Objectives, 66, 258, 259, 261, 262, 265, 

266
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Two Bit Vegetation Management Draft Environmental Impact Statement Appendix A

307

Appendix A – Public Scoping Comments and Responses

Table 72. Scoping Comment Disposition

Comment Commenter Concern1 Disposition

Economics 

Using restrictive limited operating periods (LOPS) 

will result in increased logging costs and difficulties 

in implementing the project. Please limit the use of 

LOPs. 

1 Non-significant Issue 

Limited operating periods are developed 

based on project-specific mitigation 

measures/project design to minimize 

impacts to resources and to meet the 

standards and guidelines in the forest plan. 

However, the USFS recognizes that LOP’s 

can have an impact on the feasibility of 

implementing the project and makes every 

effort to ensure that LOPs are used only 

when necessary. For example, the USFS 

conducts owl surveys prior to project 

implementation to ensure that the best 

available information is used for the project 

and avoids use of “default” LOPs. 

Conduct a thorough economic analysis in order to 

make the project viable. Take recent cost increases 

and lumber price decreases into account

1 Procedural concern

Economic analysis is an important part of 

the analysis for this project. See Chapter 3 

of the DEIS.

Do not implement the project until lumber prices 

rise. It is better to leave trees on site until market 

improves than to sell at bottom price

4 Procedural concern

Economic analysis is an important part of 

the analysis for this project. See Chapter 3 

of the DEIS. The USFS agrees that the 

current economic situation can have an 

impact on the viability of the sale and 

intends to take this into consideration when 

preparing the project for implementation. 

For instance, the USFS would consider 

how best to combine units for treatment 

and expects that multiple smaller sales 

may be necessary. 

Ensure logging system viability is considered 1 Procedural concern See responses above regarding economics
Appendix A Two Bit Vegetation Management Draft Environmental Impact Statement

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Comment Commenter Concern1 Disposition

The project should provide the highest amount of 

revenue back to the local economy 1 Significant Issue

While economics is an important aspect of 

the project that is evaluated in detail in the 

DEIS (see Chapter 3), the USFS agrees 

that an alternative that would maximize 

harvest in order to ensure financial viability, 

has merit worthy of consideration. This 

alternative was initially considered by the 

IDT (see Chapter 2, Alternatives for more 

details and a description of the Maximize 

Harvest alternative) but then dismissed 

from further detailed analysis for the 

reasons described, although one 

component of it was added to all action 

alternatives. 

I will buy the 10-15 snags along property line in 

Section 16, one mile north of Poker Flat, if you 

intend to sell them

8 Suggestion/comment

Thank you for your interest in bidding on 

individual components of the project. The 

USFS may contact you regarding this 

aspect of the project at a later date.

Hand piling is expensive and can lead to a 

nonviable project. Use this as a last resort 1 Suggestion/comment

Most units would be whole tree yarded or 

machine piled. Hand piling is proposed only 

for limited situations as a project design 

feature to minimize impact from other slash 

treatments to a sensitive resource. The 

cost of this treatment would be factored 

into the overall project cost during the 

economic analysis

If the project shrinks in size, it can have an adverse, 

cumulative impact to the local industry infrastructure 

and the ability to accomplish future land 

management objectives

1 Significant Issue - Economics

While economics is an important aspect of 

the project that will be evaluated in detail in 

the DEIS (see Chapter 3), the USFS 

agrees that an alternative that would 

maximize harvest in order to ensure 

financial viability, has merit worthy of 

consideration. This alternative was initially 

considered by the IDT (see Chapter 2, 

Alternatives for more details and a 

description of the Maximize Harvest 

alternative) but then dismissed from 

further detailed analysis for the reasons 

described, although one component of it 
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309

Comment Commenter Concern1 Disposition

was added to all action alternatives.

Providing a programmed flow of timber products 

would be out of the ordinary for the Klamath, 

considering the last 10 years. The few remaining 

timber companies may not be prepared to react to 

available product.

10 Non-significant issue

The USFS agrees that there is currently a 

limited local infrastructure to respond to a 

large sale. Currently, mills within the 

Klamath working circle are able to process 

logs from the smaller, contemporary 

Klamath National Forest program.

Implementation

Please add me to your bid list for the road work, 

meadow restoration, and natural stand thinning 8 Suggestion

Thank you for your interest in bidding on 

this project. Please contact the Forest 

Supervisor’s Office to be put on the timber 

sale bidder’s list

Ensure USFS staff and contractors for this project 

work closely so that water quality protection 

measures are followed during implementation

9 Procedural concern

The USFS agrees in the importance of 

ensuring all project design features and 

best management practices developed for 

this project are implemented correctly. 

Adherence to these measures is a part of 

any contract and is legally binding.

Ensure landings are large enough for whole tree 

yarding, if this is proposed 1 Procedural concern

The USFS will ensure that all landings are 

of appropriate size for the type of use 

during project design and implementation

Water Quality, Riparian Reserves & Fisheries

The project may qualify for a waiver under the 

Categorical Waiver for Discharges Related to 

Timber Activities on Federal Lands Managed by the 

USDA, USFS, in the North Coast Region, if 

eligibility requirements are met

9 Procedural concern

The USFS will work with the North Coast 

Water Quality Control Board on the 

eligibility of this project for a waiver 

Ensure a cumulative watershed effects analysis is 

done and design the project to reduce impacts 

below the threshold of concern

9 Procedural concern

The USFS agrees that a cumulative 

watershed effects analysis is an important 

step in determining the potential for impact 

to water quality and fisheries. This will be 

conducted as part of this project and 

discussed in Chapter 3 of the DEIS. If 

analysis determines that project effects 

would exceed thresholds, further analysis 

will be conducted to address site-specific 

reasons for exceeding, and project 
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310

Comment Commenter Concern1 Disposition

magnitude or project design may be 

modified. See also disposition of comment 

below.

Water quality can be adversely impacted by the 

proposed action. Consider mitigation measures 

such as installation of critical dips, replacement of 

undersized culverts, and application of erosion 

control measures in actively eroding or unstable 

areas

9

Significant Issue – Water 

Quality, Fisheries and 

Cumulative Watershed 

Impacts

The USFS agrees that implementing best 

management practices is an important step 

in minimizing the potential for adverse 

impacts to water quality and fisheries, and 

this is part of the proposed action, as 

described in Chapter 2 and portions of 

Chapter 3 in the DEIS. If analysis 

determines that project effects would 

exceed thresholds, further analysis will be 

conducted to address site-specific reasons 

for exceeding, and project magnitude or 

project design may be modified. While 

project design features are a part of the 

proposed action to ensure watershed 

effects are minimized, the USFS has also 

developed an additional alternative that 

would minimize new road construction and 

tractor logging in riparian reserves. See 

Chapter 2, Alternatives for more details and 

a description of the No New Temporary 

Roads Alternative

Include best management practices in the EIS and 

specifically include discussion of wet weather 

operations, activities in riparian reserves, road 

maintenance, erosion control measures, evaluation 

of treatments in unstable areas and measures 

designed to minimize adverse cumulative effects

9 Procedural concern

See responses above regarding best 

management practices and creation of an 

additional alternative

Ensure the project is designed and implemented so 

that it provides protection and recovery for coho 

salmon, Chinook salmon and steelhead trout

9

Significant Issue – Water 

Quality, Fisheries and 

Cumulative Watershed 

Impacts

The USFS agrees that protection of habitat 

for coho salmon, Chinook salmon and 

steelhead trout is important and this is 

incorporated into the best management 

practices and project design features of the 

proposed action. However, as this concern 

relates to watershed effects, please see 

response above regarding the development 

of an additional alternative
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311

Comment Commenter Concern1 Disposition

Proposed actions could result in a decrease in 

stream shading that can result in increased water 

temperature that can harm water quality. Ensure 

that shading is not reduced on any streams

9

Significant Issue – Water 

Quality, Fisheries and 

Cumulative Watershed 

Impacts

The USFS recognizes the importance of 

shading on the temperature of water within 

important habitats for sensitive fisheries. 

While stream shading impacts are not 

expected on any perennial streams, as 

described in Chapter 3 of the DEIS, this 

important habitat component will be tracked 

through the analysis. The Klamath River 

and all of its tributaries, including Indian 

Creek, are 303d listed as impaired for 

water temperature, nutrients and dissolved 

oxygen.

Road construction and yarding activities in riparian 

reserves violates the Aquatic Conservation Strategy

of the Northwest Forest Plan and the Basin Plan

2 Procedural concern

All action alternatives will be analyzed, and 

modified as necessary, to ensure that all 

ACS objectives can be met.

The USFS recognizes that these activities 

can be detrimental to water quality and 

fisheries if not implemented correctly. Best 

management practices have been 

developed to ensure any activities 

proposed are consistent with the standards 

and guidelines in these guiding documents. 

The USFS has also developed additional 

alternatives that limit certain types of 

treatments in riparian reserves. See 

Chapter 2 in the DEIS. 

The EIS should disclose a comprehensive 

cumulative effects analysis 2 Procedural concern

The USFS agrees that a cumulative 

watershed effects analysis is an important 

step in determining the potential for impact 

to water quality and fisheries. This will be 

conducted as part of this project and 

discussed in Chapter 3 of the DEIS.

Silvicultural Prescriptions & Science

Identify long-range desired conditions and how long 

proposed treatments will be effective when 

developing prescriptions 

1 Procedural concern

The USFS agrees that developing longrange desired conditions is important. 

These are described in Chapter 1 of the 

DEIS. How effective specific proposed 

treatments will be in meeting these is 
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312

Comment Commenter Concern1 Disposition

discussed in detail in Chapter 3 and in the 

appendices to the DEIS.

Do not use residual canopy cover in designing 

prescriptions; it will not be effective 1 Procedural concern

Residual canopy cover projections are 

sometimes made based on prescriptions in 

order to assist in wildlife and other resource 

effects analysis, as part of the DEIS. 

Residual canopy cover is generally not a 

design feature of a prescription. 

Using prescriptions based on a 10-20 year interval 

will not be effective in meeting your objectives 

because it is unlikely you will reenter during this 

period. I suggest you develop prescriptions based 

on a 30-40 year reentry period at a minimum. This 

will achieve your objective and make the project 

more economically viable

1 Significant Issue - Economics

The prescriptions for this project are based 

on a 20-30 year rotation, not a 10-20 year 

rotation, to minimize the number of reentries required while also meeting forest 

plan standards and guidelines for multiple 

resources. However, the USFS recognizes 

that a longer re-entry period could result in 

a more economically viable sale. For this 

reason, a Maximize Harvest alternative

has been developed to respond to this 

issue. See Chapter 2 of the DEIS for more 

details.

Do not set diameter limits; they have no silvicultural 

merit and do not support your purpose and need. 1 Non-significant issue

The USFS recognizes that using diameter 

limits is not always successful in meeting a 

specific objective for a particular stand. 

However, the USFS contends that using a 

diameter limit, as one of several tools, can 

be an appropriate way to develop a 

prescription. Diameter limits are sometimes 

used in developing a prescription for a 

certain stand to achieve other objectives or 

to ensure sensitive species or other 

resource requirements are met. It is not 

likely that diameter limits would be used as 

a tool to develop prescriptions for the Two 

Bit project, except in the few stands within 

Late Successional Reserves.

Logging will not decrease mistletoe in a stand but 

will actually increase it and can result in increased 

mortality of remaining overstory trees

2 Non-significant issue

Logging is a broad term and could include 

implementation methods for a variety of 

silvicultural treatments; some types of 
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313

Comment Commenter Concern1 Disposition

treatments, such as a seed tree that leaves 

infected trees, can increase the spread of 

dwarf mistletoe. The treatment proposed in 

Unit 237 would include several types of 

sanitation thinning designed to reduce 

Douglas-fir mistletoe adjacent to several 

young plantations or naturally regenerated 

areas and at least one high-vigor 

previously thinned mid-seral stand.

Treatment designs would consider long 

established practices for managing stands 

with mistletoe in Douglas-fir. Assistance 

from our Northern Service Area Pathologist 

would be requested as needed. The entire 

36 acres within the proposed unit would not 

be treated; focus would be along stand 

boundaries where spread of mistletoe 

could be reduced to meet management 

objectives within this stand, which is within 

MA-17 -General Forest. The vigor of the 

mistletoe is directly influenced by the vigor 

of the host tree so mistletoe growth may 

increase in infected trees when they are 

thinned. However, there is evidence that 

trees with increased vigor from thinning can 

often grow fast enough to keep ahead of 

the spreading mistletoe and remain 

vigorous during the management period.

This treatment would not include thinning of 

entire stands of trees. 
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Comment Commenter Concern1 Disposition

The EIS should address the scientific literature 

regarding mistletoe. The presence of dwarf 

mistletoe is often beneficial to ecosystems.

2 Procedural concern

The USFS agrees that endemic levels of 

dwarf mistletoe in an ecosystem have a 

variety of benefits, including providing 

nesting substrates for spotted owls, among 

other species. The proposed treatment of 

some Douglas fir trees with dwarf mistletoe 

within 36 acres within a 67,000 acre 

analysis area is not intended to rid the 

ecosystem of dwarf mistletoe; only to 

reduce the risk of infection to regeneration 

and to one uninfected stand in this 

particular area. Literature has been 

reviewed concerning beneficial effects and 

would be considered when designing final 

management strategies for this area.

However, with mistletoe infections in 

Douglas-fir on National Forests reported to 

be from 13% to 50% of trees, this small 

treatment area and other stands in the 

project where a few infected trees may be 

removed, will have an undetectable effect 

on the amount of mistletoe available in the 

ecosystem. We have presently chosen to 

manage this small area in the MA-General 

Forest to reduce mistletoe to protect 

plantations and stands with few infections 

at this time. 

A summary of the scientific literature 

related to dwarf mistletoe is provided at the 

end of this table1.

Thinning a mere 36 acres will not slow the spread of 

dwarf mistletoe already rampant on the Klamath 

National Forest. Regular thinnings over large 

acreages would be necessary to control a forest 

disease.

10 Non-significant issue 

The purpose of the proposed action in Unit 

237 is to reduce the presence of dwarf 

mistletoe in this small area and not to 

control the disease across the forest. 

Removal of infected trees is planned 

mainly to reduce new infections in several 

small plantations and in one healthy natural 

stand. 
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Comment Commenter Concern1 Disposition

Treating stands may result in pest and disease 

problems (such as root rot) by creating simplified 

forests

2 Non-significant issue

This project primarily includes thinning of 

plantations and a lesser extent natural 

stands, most of which have had some 

previous harvest. Treatments would likely 

increase diversity by opening stands to 

where they are not in the stem exclusion 

phase and species other than the dominant 

conifer species could populate a portion of 

the stands. In natural stands, treatments 

would remove smaller trees in the lower 

layers and a portion of the codominant 

trees in the main canopy, but the major 

components of the stand would remain.

Most stands in the project do not have a 

high incident of root disease, but measures 

would be taken to not increase root 

disease. For example, true fir stumps 

would be treated with a borax compound to 

prevent the spread of H.annosum. To 

discourage Douglas-fir black stain root 

disease, soil compaction wouldl be 

minimized by monitoring soil moisture and 

skid trail use during treatments and spacing 

would be relatively wide to minimize root 

stress and root grafting. Tree wounding, 

which can allow infection to enter through 

the cambium, wouldl be minimized by 

yarding design and appropriate oversight 

by sale administrators. One of the 

recommended management techniques for 

several root diseases, some that affect 

Douglas-fir, is to improve the host tree 

vigor (Fillip 1990). One way to do this is to 

reduce competition by thinning while taking 

precautions not to produce conditions that 

could exacerbate a situation where root 

disease is already present. With knowledge 

of these potential risks, prudent silvicultural 

treatment can be implemented to minimize 
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Comment Commenter Concern1 Disposition

potential unwanted consequences during 

stand management treatments (Fettig 

2006, Filip 1990). Stand composition is 

important for minimizing future pest 

damage, including root disease. The 

thinning in the proposed stands is designed 

to maintain a relatively diverse stand 

composition or move the stand towards a 

resilient mix of species. The later would 

include increasing the amount of Douglas 

fir in a planted ponderosa pine stand, 

maintaining minor species, decreasing 

white fir in lower elevations, and 

maintaining hardwoods.

The EIS should address the scientific controversy

regarding logging’s effects on insects and diseases. 

Disease and insect problems may be worse in 

managed stands than in natural stands

2 Procedural concern

The EIS will consider relevant information 

for the project including information 

contained in the Scott Black report for the 

Xerces Society.

Thinning weeping spruce will result in adverse 

impacts to weeping spruce. Protect these 

populations from treatment

4 Non-significant issue 

Additional site review will be done for 

stands that contain weeping spruce and 

most likely, project design features will be 

developed to maintain weeping spruce 

within existing stands during thinning or 

underburning.

Weeping spruce seed and western white pine seed 

should be collected to mitigate possible loss

4 Non-significant issue 

Planned treatments would not eliminate the 

species or the seed source from the project 

area. For underburns, burn plans would be 

developed so that objectives including soil 

cover and tree scorch could be managed; 

burning would not be done during periods 

when it is too dry to meet resource 

objectives. Areas with substantially 

different aspects and elevations would 

generally be broken into separate burns 

and accomplished at times when the burn 

plan criteria could be met. It is correct that 

there is variation in intensities within large 

underburns. Additional design measures 

for the project, including underburning 
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Comment Commenter Concern1 Disposition

would provide better management and 

enhancement of the species and will be 

researched. The District has seed collected 

for weeping spruce in the Indian Creek 

Watershed stored from past collections, 

although planting of this species has not 

been done since the early 1990’s.

Analyzing for collection of seed for genetic 

conservation is beyond the scope of this 

project. However, the District supports the 

need to maintain seed from these important 

species.

Treatments in western white pine stands will result 

in increased susceptibility to blister rust and other 

diseases. Protect seed-producing and young 

reproduction.

4 Non-significant issue 

Thinning prescriptions would include 

components to maintain western white pine 

(WWP) within treatment areas similar to 

that included for sugar pine. Design 

features would likely include some “free” 

thinning around WWP to reduce 

competition stress on healthy individuals.

There are no substantial stands of WWP

within the treatment area but rather consist 

of small groups and individuals. WWP 

occurs most often in cold air drainages and 

glacial circs generally at higher elevation, 

although in colder areas, trees appear 

lower on the slopes. The cooler 

environmental conditions will facilitate, in 

some areas, protection of groups of trees.

Areas that have WWP or WPP 

regeneration as a significant component 

would be excluded from underburns or 

parameters developed for prescribed fire 

would be used to reduce the risk of 

damage to WWP.

Enhance sugar pine stands in prescriptions 4 Non-significant issue? 

The silvicultural prescriptions would follow 

Regional guidelines to maintain sugar pine 

within treatment stands. Discussions with 

the Forest genetic staff would occur 

concerning the treatment of sugar pine.
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Comment Commenter Concern1 Disposition

Prescriptions would include free thinning 

around some of the best individual trees to 

reduce competition and risk pine beetle 

attack, and overall thinning would provide 

more growing space for these pines. Sugar 

pine would not be planned for removal

except in some specific cases: (1) the trees 

are suppressed or have less than 30% 

crown ratio and show extensive blister rust 

and have other signs that there is imminent 

mortality; (2) there are groups/clumps of 

sugar pine over a sustainable stocking 

level for sugar pine (measured locally by 

BA) where the smaller sugar pine in the 

group will be removed until the remaining 

stocking is below a level where the pine is 

at risk to pine beetle, and (3) scattered 

sugar pine with blister rust and other 

damage in stands with a high percentage 

of sugar pine where over the long term, the 

trees would be shaded out of the stands by 

larger conifers. Many sugar pine showing 

signs of blister rust would be retained 

within thinning stands. 

Historic conditions are not clearly defined. Historic 

conditions should more accurately include green 

tree removal and selection treatments that are more 

similar to treatments done 50 years ago, not 

commercial thinning.

10 Procedural concern

Historic conditions are more thoroughly 

described in the DEIS in Chapter 1. Historic 

conditions used for the analysis are 

conditions present before EuropeanAmerican settlement.

Roads

Using long skid trails will result in more 

environmental impacts than creating temporary 

roads to access treatment areas. Consider 

developing an adequate road system to effectively 

and efficiently harvest timber for this project.

1 Non-significant issue

The USFS agrees that an adequate road 

system is necessary to effectively harvest 

timber for this project and proposes this as 

part of the proposed action. The USFS also 

recognizes that roads can have negative 

impacts to resources and so intends to 

minimize the level of new road construction 
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Comment Commenter Concern1 Disposition

to the lowest level necessary while still 

meeting the purpose and need for the 

project.

Construction of new, temporary roads will result in 

long-term adverse impacts to soil health and 

hydrology. Road construction, use and maintenance 

in the Indian Creek Watershed are causing 

watershed degradation. Consider an alternative to 

road construction

2

Significant issue – Water 

Quality, Fisheries and

Cumulative Watershed 

Impacts

The USFS recognizes that roads can have 

negative impacts to water quality, fisheries 

and overall soil health in a watershed. 

While project design features are a part of 

the proposed action to ensure watershed 

effects are minimized, the USFS has also 

developed an additional alternative that 

would minimize new road construction and 

tractor logging in riparian reserves. See 

Chapter 2, Alternatives for more details and 

a description of the Minimize New 

Temporary Roads and No New Road 

Construction alternatives.

Decommissioning roads in the watershed does not 

justify the creation of new ones. Creating new ones 

will result in adverse impacts.

4, 5

Significant issue – Water 

Quality, Fisheries and

Cumulative Watershed 

Impacts

See responses above. The USFS contends 

that any road decommissioning is a 

positive step to take in the Indian Creek 

Watershed. The level of road 

decommissioning and the level of 

temporary road construction are both 

factors evaluated as part of the cumulative 

watershed effects modeling and are 

described in Chapter 3 of the DEIS.

Additional road construction in the Indian Creek 

Watershed will result in adverse cumulative impacts 

to aquatic health

2, 5

Significant issue – Water 

Quality, Fisheries and

Cumulative Watershed 

Impacts

See responses above. 

The proposed action will result in adverse impacts 

to the road system and sediment contributions. 

Ensure road maintenance and closure is funded 

and made part of the project 

4 Non-significant issue 

Temporary road construction is funded by 

the sale, as well as the closing and 

restoration of hydrologic function to the 

roads that were used as part of the sale. 

However, road decommissioning is funded 

by watershed restoration funds, separate 

from the timber sale

The EIS should address and avoid the harmful 

impacts of road construction on ecosystems 2, 5 Procedural concern The DEIS includes an evaluation of the effects of temporary road construction, as 
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Comment Commenter Concern1 Disposition

part of Alternatives 2 and 4. Alternative 3 

would not construct any new temporary 

roads, forming the basis for comparison in 

Chapter 3, including that using the results 

of the cumulative watershed effects 

analysis. 

The EIS should reflect the Medford BLM analysis of 

road impacts on edge effects and microclimatic 

changes shown in the Ashland Resource Area

2 Procedural concern

The small amount of temporary road 

construction proposed would have minimal 

impact to species and habitat. Because of 

the amount of road decommissioning 

compared to temporary road construction, 

there would be a net decrease in open 

roads. Therefore, the effects of disturbance 

to wildlife from vehicles traveling on roads 

would be reduced. All temporary roads 

would be barricaded and hydrologically 

restored to allow natural revegetation to 

occur within several years following project 

completion, thus further reducing negative

impacts to wildlife.

Consider decreasing road density even further in 

the project area to be consistent with the Forest 

Plan.

2

Significant issue – Water 

Quality, Fisheries and

Cumulative Watershed 

Impacts

The action alternatives analyzed in detail 

as described in Chapter 2 have an 

additional road segment proposed for 

decommissioning for a total of 

approximately 4.5 miles of 

decommissioning. See also responses 

above regarding the creation of an 

alternative that does not create any new

temporary roads.

Road construction and log haul routes may 

contribute to the spread of p. lateris and may 

adversely effect Port Orford Cedar and Pacific Yew

2, 5 Non-significant issue 

Project design features have been 

developed to minimize the likelihood of 

adverse impacts to Port Ortford Cedar and 

Pacific Yew. See Chapter 2 in the DEIS

Prescribed Burning, Smoke and Air Quality

Use fire crews to accomplish project objectives 

without burning 4 Procedural concern

The USFS agrees that some project 

objectives can be met without the use of 

prescribed fire and that this is part of the 

proposed action (pile burning at landings, 
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Comment Commenter Concern1 Disposition

for example). The USFS disagrees that all 

project objectives could be met without 

some level of prescribed burning. 

Prescribed burning and other slash 

treatment methods are part of all 

alternatives considered, to varying 

degrees. See Chapter 2 of the DEIS

Analysis should disclose the amount of carbon 

emissions expected 1, 4 Procedural concern

The air quality analysis shows projected 

levels of carbon emissions from 

alternatives. See Chapter 3 of the DEIS. 

The Northern Plateau Air Basin Air 

Pollution Control District monitors (or 

estimate) carbon emissions for the air 

basin. The Air Pollution Control District 

takes this information taken into 

consideration when determining ‘burn days’ 

and coordination with Forest Burn Plans be 

sure the air quality in the air basin adheres 

to air quality standards.
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Comment Commenter Concern1 Disposition

Analysis should discuss the feasibility of actually 

being able to implement the prescribed burning in 

timely and efficient manner

1 Procedural concern

Prescribed burning would be implemented 

as time and funding allows, over the course 

of an approximate ten year period, 

prioritized by treatment areas and with 

other on-going USFS project work. The 

USFS expects burning to be conducted in a 

timely and efficient manner, with the above 

caveats. However, the USFS also 

acknowledges that a substantial amount of 

prescribed burning is proposed and that it 

may be difficult to achieve, particularly that 

which is proposed outside of treatment 

units, within a 10 year period, considering 

all other projects on-going or planned on 

the district. As described in more detail 

below, an alternative that limits 

underburning to just thinned units is a 

component of Alternative 4 and Alternative 

3 has a reduced level of underburning 

compared to the original proposal. See 

Chapter 2 of the DEIS.

Broadcast burning may adversely impact the area 

around the green gate swimming hole. Please do 

not burn this area and use hand piling or chipping 

instead

4 Non-significant issue 

This area is in the Underburn Unit 4 and 

creating an unburned buffer around this 

swimming hole is a component of all action 

alternatives. 

Proposed prescribed burning is too large and 

unmanageable and will result in fires getting out of 

control 

4 Non-significant issue

The USFS recognizes that the original 

proposal of 8,600 acres of underburning 

would be difficult to accomplish in a timely 

fashion, but disagrees that it is essentially

unmanageable. Underburns were designed 

to provide flexibility in implementation to 

break up fuel continuity and take 

advantage of existing roads and 

topography to reduce the need for line 

construction. The large areas allow the 

District a choice for different seasonal 

burning windows within those boundaries. 

None of the large underburns is planned to 

be completed in a single time period. 
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Comment Commenter Concern1 Disposition

However, the USFS recognizes that 

managing a prescribed burn is not always 

exact and that a variety of factors can play 

a role in the success of a burn and whether 

a managed burn goes out of prescription. 

The USFS will follow all agency protocols 

and protective measures when conducting 

any prescribed burning to ensure the safety 

of fire fighters, the protection of life and 

property, and meeting project objectives. 

To respond to issues regarding air quality 

and the feasibility of implementing a high 

level of prescribed burning as part of this 

project, however, the USFS developed 

alternatives with varying levels of 

undeburning, as described in Chapter 2 of 

the DEIS..

It is important to be successful with burning for this 

project to regain the trust of the local community 4 Suggestion

The USFS acknowledges that the local 

community is affected by actions near 

Happy Camp and in proximity to private 

residences. See response above.

Comply with air quality standards for burning 4 Procedural concern

Compliance with state air quality standards 

is a routine procedure that the USFS 

implements prior to initiating any prescribed 

burn. A permit is required from the state 

before a burn is ignited. 

Carbon dioxide emissions should be monitored and 

constrained 4 Procedural concern The air quality analysis discusses carbon dioxide emissions

Underburning will result in adverse impacts to 

weeping spruce, a species that is not fire-adapted 

and could result in cumulative impacts since some 

were lost to wildfire last year. Protect the population 

near 18N33D.

4 Non-significant issue 

A design feature has been added to the 

alternatives that includes establishing a noburn buffer around this population in 

Underburn Unit 2. 

The level of prescribed burning will result in 

unwanted smoke impacts, particularly to those that 

live along Indian Creek and other nearby areas

Public meeting

Significant Issue – Air Quality 

and Amount of Prescribed 

Burning

The USFS agrees that smoke from 

prescribed burning can sometimes be 

heavy and can affect residents and others 

living in proximity to burn operations. While 

these are short-term impacts that dissipate 
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Comment Commenter Concern1 Disposition

over time, the USFS recognizes that these 

adverse impacts should be minimized 

when possible. Burning only when a permit 

has been issued from the state is one way 

to ensure effects from smoke are 

minimized. This is a standard design 

feature of the proposed action. See 

Chapter 2 of the EIS. However, the USFS 

has also developed an alternative that 

limits the extent of prescribed burning. See 

Chapter 2 of the DEIS. However, it should 

be recognized that smoke with low-intensity 

prescribed burning is much less than that 

generated from a high-intensity wildfire. 

Performing prescribing burning treatments 

to reduce fuel loading results in a long-term 

benefit of less smoke production from a 

wildfire.

Wildlife 

Address the unique regional wildlife connectivity 

values provided by the Siskyou Crest in the EIS 2 Procedural concern

Wildlife habitat connectivity is a component 

of the wildlife resource analyzed for this 

project. This is summarized in Chapter 3 of 

the DEIS.

Address the impacts to biological diversity 

(connectivity, habitat linkages, distribution 

opportunities) 2 Procedural concern

Biological diversity is a component of the 

wildlife resource analyzed for this project. . 

This is summarized in Chapter 3 of the 

DEIS.

The EIS should disclose the impacts of the project 

on Management Indicator Species including 

population numbers, locations and trends and that 

snag-dependent species be monitored and 

surveyed for

2 Procedural concern

Management indicator species is a 

component of the wildlife resource 

analyzed for this project. . This is 

summarized in Chapter 3 of the DEIS.

The EIS should include surveys and evaluation of 

effects to American Martins, eagles, deer and black 

bear and avoid adverse impacts as much as 

possible

5 Procedural concern

Wildlife species with the potential to be 

affected by project implementation is a 

component of the wildlife resource 

analyzed for this project. This is 

summarized in Chapter 3 of the DEIS.

The EIS should address the project impacts on the 2, 5 Procedural concern Wildlife species with the potential to be 
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Comment Commenter Concern1 Disposition

Pacific fisher affected by project implementation is a 

component of the wildlife resource 

analyzed for this project. . This is 

summarized in Chapter 3 of the DEIS.

Avoid actions that will remove or downgrade habitat 

suitable habitat for the Northern spotted owl 2, 5 Non-significant issue

Minimal or no downgrading of suitable 

nesting/roosting habitat is expected, 

although some downgrading of foraging 

habitat is possible. The USFS is working 

closely with the US Fish and Wildlife 

Service to ensure the Two Bit project 

follows all interim guidelines. Overall, the 

Two Bit project is expected to have minimal 

effect on suitable Northern Spotted Owl 

habitat. See Chapter 3 of the DEIS. 

The EIS should outline the effects of alternatives on 

game habitat, particularly deer, black bear,

Roosevelt elk, grey squirrel, mountain quail, blue 

grouse, ruffed grouse, and turkey

6 Procedural concern

Game species with the potential to be 

affected by project implementation is a 

component of the wildlife resource 

analyzed for this project. . This is 

summarized in Chapter 3 of the DEIS.

The EIS should disclose the timing, results and 

influence of wildlife and plant surveys on the 

project. Do not rely on the 2007 Record of Decision 

that eliminates the survey and manage program 

2 Procedural concern

Wildlife and plant surveys conducted as 

part of this project are summarized or 

referenced in the Wildllife Specialist Report 

for this project and referenced in Chapter 3 

of the DEIS.

The EIS should disclose the number and location of 

snags that will be felled and consider limiting snag 

removal as much as possible

2, 5 Non-significant issue 

Snags would only be removed if they pose 

a safety threat during operations. See 

project design features in Chapter 2 of the 

DEIS

Suggested Alternatives or Alternative Components

Consider a “Citizens Alternative” to influence project 

layout and implementation. This alternative includes 

using only the existing road system and previous 

skid trails, no treatment in natural stands in T19E, 

R6E sections 34-35, post-harvest prescribed fire, 

underburning, riparian reserves are treated only 

with hand-work, helicopter yarding or using existing 

skid trails, and road densities reduced 

2 Alternative This alternative was considered. See 

Chapter 2 of the DEIS for details.

Remove the fence around Sutcliffe Douglas Fir Test 4 Non-significant issue This suggestion is outside the scope of the 
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Comment Commenter Concern1 Disposition

in Underburn Unit 2 to improve wildlife habitat proposal

Three genetic test areas could be adversely 

impacted by underburning treatments. These 

should be protected

4 Non-significant issue 

The USFS agrees that these areas should 

be protected during prescribed burn 

treatments. This has been added to the 

project design features for this project. See 

Chapter 2 for more details. 

Inventory sites in Units 90-94 where arsenic 

compounds were used in the 1970’s. Mitigate or 

restore these areas if arsenic levels warrant

4 Suggestion

An inventory of arsenic levels is outside the 

scope of the proposal. However, the USFS 

agrees that an investigation into this issue 

may be warranted and agrees to look into 

it, separate from this project.

Honestly evaluate the no action alternative 2 Procedural concern

A detailed evaluation of the no action

alternative is a requirement of a Draft 

Environmental Impact Statement. The no 

action alternative is described in Chapter 2 

and a detailed evaluation is included in 

Chapter 3 of the DEIS.

Include protection of a spring and waterline near 

Deadman Point 3, 7 Non-significant issue 

The USFS agrees these should be 

protected during project implementation. A 

project design feature has been developed. 

See Chapter 2 of the DEIS.

Using diesel and gasoline as burning mix results in 

adverse impacts to water quality and air quality. 

Consider alternatives such as fry oil and alcohol.

4 Non-significant issue

While the USFS agrees that diesel and 

gasoline have the potential for adverse 

impacts to water and air quality at certain 

levels and in certain situations, the USFS 

disagrees that the limited use proposed for 

this project would result in substantial 

adverse impacts. Proper use and disposal 

of diesel and gasoline is included in project 

design features in Chapter 2 of the DEIS 

and would be included in any subsequent 

contract. The USFS cannot legally require 

a purchaser to use an alternative fuel 

source.

Would use of prescribed fire (rather than logging) 

accomplish meadow restoration goals? 2 Suggestion/Question

Logging is not proposed in meadows, only 

removal of small-diameter, submerchantable trees and limited prescribed 

fire. 
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Comment Commenter Concern1 Disposition

Consider additional road decommissioning near 

Port-Orford cedar stands 2, 5 Non-significant issue This is outside the scope of the proposal

Requests for More Detail

The EIS should disclose how many hazard trees will 

be felled, the number and location of trees over 20” 

dbh that will be removed, location of tractor and 

cable logging corridors, activities within NSO critical 

habitat, how survey and manage protocols will be 

followed, how Siskyou Mountain and Del Norte 

salamanders will be managed, and the location and 

functional status of riparian reserves

2, 5 Procedural concern

The DEIS discloses those aspects of the 

alternatives, relative to the significant 

issues, that would result in effects to the 

human environment, including wildlife and 

plant species. While the DEIS includes a 

site-specific analysis of the potential 

impacts to resources from project 

components, it is not possible to have 

every detail of project implementation 

known at the time of the DEIS. Project 

design features, mitigation measures and 

monitoring, identified in the DEIS in 

Chapter 2 and 3 are developed to ensure 

that any site-specific details not known at 

the time of DEIS preparation are accounted 

for during project implementation.

Logging Systems

Ground-based logging systems, including yarding 

and landing construction, will result in root damage, 

scarring of individual trees, and soil damage

2 Non-significant issue 

Project design features and best 

management practices have been 

developed (see Chapter 2 of the DEIS) to 

minimize the likelihood of adverse impacts 

from these activities. Sale administration 

during implementation also provides 

additional oversight to ensure these 

impacts do not occur, or are minimized as 

much as possible.

Visual Quality

Leaving visible stumps in meadows will result in 

adverse impacts to visual quality. Cut or grind 

stumps flush to soil surface 

4 Non-significant issue Because only small, diameter, submerchantable trees would be removed from 

meadows, and the number of these will be 

low, any stumps left are not expected to be 

noticeable to the casual observer. A 

detailed scenery analysis is a part of the 

DEIS and is summarized in Chapter 3.
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Comment Commenter Concern1 Disposition

Invasive Species

Using heavy equipment and intense fire in 

meadows will result in adverse impacts to this 

sensitive resource and could result in increases in 

invasive plants

4 Non-significant issue 

Intense fire is not proposed for meadow 

restoration. Use of heavy equipment would 

be limited. Project design features and best 

management practices have been 

developed to minimize the likelihood of 

increases in invasive plants. See Chapter 2 

of the DEIS.

Establish a monitoring plan for invasive species 

encroachment as part of this project 4 Non-significant issue

While the USFS agrees that proposed 

actions have the potential to result in 

increases in invasive species in some 

areas, best management practices and 

project design features have been 

developed to minimize this as much as 

possible. Invasive species are the subject 

of the Botany and Noxious Weed section of 

Chapter 3 of the DEIS. A Noxious Weed 

Risk Assessment has been prepared for 

this project which includes a monitoring 

component. 

Treatment of Natural Stands

Logging in natural stands will result in soil 

compaction, tree root damage and potentially more 

harm than benefit. Carefully consider treatments in 

riparian reserves, late successional reserves and 

other natural stands to ensure you are meeting the 

guidance in the Forest Plan

5 Procedural concern

The USFS agrees that logging can have 

detrimental impacts. This project is 

designed to meet the guidance in the forest 

plan. Best management practices and 

project design features have been 

developed to minimize the likelihood of 

adverse impacts from logging. See Chapter 

2 of the DEIS.

Follow the Klamath Forest Plan/Other Guiding Documents

The NEPA analysis should clearly tie proposed 

activities to the Forest Plan 1 Procedural concern

Chapter 1 of the DEIS describes the 

purpose and need for the project and how 

the project relates to the Forest Plan.

Ensure that the recommendations made in the 

Indian Creek Watershed Analysis are followed and 2, 5 Procedural concern The Indian Creek Watershed Analysis wasused as a guiding document throughout the 
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix A

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Comment Commenter Concern1 Disposition

that Forest Plan direction is adhered to analysis process for this project. How the 

recommendations of this analysis were 

used to develop the purpose and need for 

the project is described in Chapter 1 of the 

DEIS. In Chapter 3 of the DEIS, watershed 

effects analysis is summarized.

Ensure the project is designed and implemented to 

meet the water quality standards outlined in the 

Basin Plan

9 Procedural concern

The hydrologic analysis for this project 

includes discussion of how the project 

meets the standards and guidelines in the 

Basin Plan. This is summarized in Chapter 

3 of the DEIS in the Water Quality and 

Fisheries section.

Ensure private property owners are aware of the 

proposal since proposed actions may adversely 

impact their land

4 Procedural concern

The initial proposed action was included in 

a scoping letter that was sent to all property 

owners in the analysis area in February 

2009. A public meeting was held on March 

4 in Happy Camp to discuss the proposal 

and hear any concerns or comments.

1 Dwarf mistletoes are parasites that extract water, nutrients, and carbohydrates from the infected host. Where dwarf mistletoe populations 

develop significant, long-term infestations, cumulative tree damages have various ecological and evolutionary effects. Depending on management 

objectives and priorities, these effects are interpreted as positive, negative, or usually of mixed consequences (USDA Forest Service 2002).

Dwarf mistletoes provide forage, foraging sites, protected and special sites, and desirable stand structures for numerous wildlife species 

including creation of snags. Numerous studies have reported use by birds and mammals for food, nesting, and cover. When considering 

silvicultural treatments, an evaluation is recommended that considers management objectives and potential ecological impacts and benefits (USDA 

Forest Service 2002). 

Dwarf mistletoes markedly affect the growth, form, and survival of infected trees and therefore how these trees and their stands develop and 

respond to silvicultural treatments. Effects to trees included: distorted growth from branch and stem infections, changes in wood quality, reduced 

overall tree growth, increased susceptibility to attack by secondary insects and fungi, and increased mortality. These damages aggregate over time, 

affecting forest health, sustainability, and productivity (USDA Forest Service 2002). With regard to fire, several features of mistletoe infection 
Appendix A Two Bit Vegetation Management Draft Environmental Impact Statement

330

increase the tree’s flammability. Infection induces excess resin deposition and increases litter accumulation (including detached brooms). 

Retained brooms and infected branches form a fuel ladder from the ground into the canopy. Mistletoe severity (Dwarf Mistletoe rating (DMR)) is 

related to scorching, mortality, and sanitation (USDA Forest Service 2002). Fire exclusion policies of the last century have increased both infection 

levels and fire hazard (Alexander 1976) 

Several biological and ecological features make dwarf mistletoes especially amenable to silvicultural treatment. Mistletoes are generally host 

specific so retaining immune or less susceptible host trees can reduce mistletoe spread. Numerous infections are required to cause serious damage 

and the effects accumulate slowly. Seed dispersal is limited to about 30 to 50 feet and the amount of seed is limited. Mistletoe infections typically 

begins in the lower trees crown and vertical spread is slow enough that trees with rapid height growth can outgrow or at least keep pace with 

mistletoe intensification ( USDA Forest Service 2002). Greater crown closure does result in reduced light within the canopy which reduces the 

mistletoe reproduction and increases shading out (death) of lower infected branches reducing infections. Seed dispersal within the stand is also 

reduced in dense stands because seeds are intercepted close to the infected tree. 

In the Two Bit project within stands identified for thinning and most of the stands identified for underburning, mistletoe infection is generally 

absent or light with only a few groups or patches of trees heavily impacted. Dwarf mistletoes that occur most often in the project area are 

Douglas-fir dwarf mistletoe (Arceuthobium douglasii) and white fir dwarf mistletoe (Arceuthobium abietinum); red fir dwarf mistletoe (A. 

abietinum f. sp. magnificae) is common in red fir stands in the Two Bit project area, but none of these stands are planned for entry in this project. 

Units 237 and 300 are within regulated lands and include more concentrated infections of Douglas-fir mistletoe. Unit 237 was a small 

regeneration cut where infected overstory trees were left so that the natural Douglas-fir regeneration is being infected. Unit 300 includes some 

heavily and some lightly infected patches along the road where spread could be slowed into non-diseased stands with removal of individual or 

small groups of trees. In both cases, some heavily infected older stands in the vicinity would not be treated under this project. The plantations 

proposed for thinning are nearly all free of mistletoe with the exception of a few residual Douglas-fir, white fir, and occasional incense cedar or 

pine within or adjacent to plantations. In plantations and natural stands, especially within regulated lands, infected trees would be a priority for 

removal during thinning consistent with the purpose and need for the Two Bit project.
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix B

331

Appendix B – Treatment Objectives by Thinning Unit

Table 73. Treatment objectives by thinning unit by alternative

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

1 26 1.1

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products and riparian. 

Restore large trees and 

desired vegetation 

characteristics in riparian. 

Reduce density to below 

55% of max SDI for 20-30 

years; DF spacing 28'-30'.

Maintain IC.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Not 

treated

Thin with 

mechanical 

Harvester and 

tractor 

endlining; 

masticate fuels

100

2 26 1.8

General 

Forest/Riparian 

Reserve

Fire resilient stand with 

appropriate species for the 

site. Reduce density of PP 

to below 35% of max SDI 

for PP (for 10-20 years) 

and increase % of DF, 

spacing on PP 30-35. 

Restore large trees and 

desired vegetation 

characteristics in riparian. 

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

11

3 12 0

General 

Forest/Riparian 

Reserve

Fire resilient stand with 

appropriate species for the 

site. Reduce density of PP 

to below 35% of max SDI 

for PP (for 20-30 years), 

spacing on PP 30-35; 

Thin with cable 

logging; underburn

Same as 

Alt 2 Same as Alt 2 51
Appendix B Two Bit Vegetation Management Draft Environmental Impact Statement

332

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

maintain other species 

within stand. Restore large 

trees and desired 

vegetation characteristics 

in riparian. 

4 14

General 

Forest/Partial

Retention VQO

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Reduce density 

to below 55% of max SDI 

for 20-30 years; DF 

spacing 28'-30', maintain 

IC and scattered chinkapin 

by thinning to allow 

growing space. Harvest 

and underburning would 

raise the crown base 

height.

Thin with 

conventional log 

skidder and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2 Same as Alt 2 48

6 19 10.0

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian. Reduce % of 

PP and WF Reduce 

density to below 55% of 

max SDI for 20-30 years; 

DF spacing 28'-30', PP 

spacing 30-35'. Harvest 

and underburning would 

raise the crown base 

height.

Thin with cable 

logging; underburn

Same as 

Alt 2 Same as Alt 2 48
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix B

333

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

7 20 4.4

General 

Forest/Riparian 

Reserve

Similar to Unit 7

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

48

8 10 2.0

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian. RR had historic 

rare lilies (habitat needed?)

Thin to remove PP and 

WF. Reduce density to 

below 55% of max SDI for 

20-30 years; DF spacing 

28'-30', Maintain some 

clumps of Chinkapin/BLM 

(12-20" dbh).

Thin with 

conventional log

skidder and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2 Same as Alt 2 108

9 19 0.3

General 

Forest/Riparian 

Reserve

If merchantable, review 

options for increasing other 

conifer species and 

removing additional small 

PP.

Thin with 

conventional log 

skidder and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2 Same as Alt 2 48

10 22 0.03

General 

Forest/Riparian 

Reserve

Fire resilent stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian. Reduce density 

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

masticate fuels

108
Appendix B Two Bit Vegetation Management Draft Environmental Impact Statement

334

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

to below 55% of max SDI 

for 20-30 years; DF 

spacing 28'-30'.

11 12 3.8

General 

Forest/Riparian 

Reserve

Thin wide to reduce risk of 

bark beetles.

Thin with 

conventional log 

skidder and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2 Same as Alt 2 11

12 19 10.0

General 

Forest/Riparian 

Reserve

Thin wide to reduce risk of 

bark beetles.

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

11

13 15 General Forest

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Maintain large 

trees and desired 

vegetation characteristics 

in riparian. Reduce density 

to below 55% of max SDI 

for 20-30 years; DF 

spacing 28'-30' with some 

clumps in patches with preplantation residuals.

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

31
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix B

335

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

16 7 0.03

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian. Reduce the % 

of PP and WF; enhance 

the presence of IC where 

there are trees large 

enough to maintain in the 

stand.

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

48

18 25 4.3

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian.

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Not 

treated

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

110

19 31 11.5

General 

Forest/Riparian 

Reserve/Partial 

Retention VQO

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian.

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

31

20 31 6.2

General 

Forest/Riparian 

Reserve/Partial 

Retention VQO

Increase % of DF, enhance 

conditions for BS and 

POC. Restore large trees 

and desired vegetation 

characteristics in riparian.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

11
Appendix B Two Bit Vegetation Management Draft Environmental Impact Statement

336

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

21 29 General Forest

Reduce PP stocking to 

below 55% of max SDI for 

20-30 years. Increase % of 

DF and WF. Snow damage 

in PP in increasing.

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

51

22 23 12.0

Port Orford 

Cedar/Riparian 

Reserve/Partial 

Retention VQO

Enhance POC; thin DF that 

are suppressing the POC 

regen and larger residuals. 

Thin suppressed clumps of 

POC (1-10" dbh) to 

produce vigorous trees.

Around wet area and 

springs, approx. 100 

resistant POC could be 

planted after thinning. Thin 

DF to produce large old 

trees. (Similar to LS/OG 

portions of POC Mgt area 

to south. Reduce % of WF.

Thin with 

conventional log 

skidder, handwork 

and tractor endlining; 

hand pile fuels

Same as 

Alt 2

Thin with 

conventional log 

skidder, 

handwork and 

tractor 

endlining; 

underburn; 

hand pile fuels

100

23 16 General Forest

Fire resilient stand 

managed to grow large 

trees for future forest 

products and other values.

Reduce density to below 

55% of max SDI for 20-30 

years; DF spacing 28'-30'.

Many small trees. 

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

31

24 16 0.5

Late 

Successional 

Reserve/Port 

Orford 

Cedar/Riparian 

Enhance POC; thin DF that 

are suppressing the POC.

Thin DF to produce large 

old trees and LS/OG 

habitat with the 100-acre 

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

100
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix B

337

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

Reserve/Partial 

Retention VQO

LSR and riparian. In partial 

retention, thin to produce 

fire resilient stand 

managed to grow large 

trees for future forest 

products.

underburn;

masticate fuels

26 13 2.4

Riparian 

Reserve/Partial 

Retention VQO

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

108

27 21 2.1

Riparian 

Reserve/Partial 

Retention VQO

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

48

28 7 0.2

Riparian 

Reserve/Partial 

Retention VQO

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

48

29 22 10.0

Riparian 

Reserve/Partial 

Retention VQO

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

Thin with 

conventional log 

skidder and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2 Same as Alt 2 31
Appendix B Two Bit Vegetation Management Draft Environmental Impact Statement

338

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

in riparian.

30 20 5.3

General 

Forest/Riparian 

Reserve/Partial 

Retention VQO

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian.

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

11

31 25 7.6

General

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Below road, 

favor DF and IC and 

reduce PP. DF IC spacing 

30-33. PP spacing 33-35'. 

Protect scarp and wet 

area. In RR, increase the 

% of DF for long term 

shade. 

Thin with 

conventional log 

skidder and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2 Same as Alt 2 31

32 28 General Forest

Fire resilent stand 

managed to grow large 

trees for future forest 

products. DF spacing 28-

29.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

108

33 48 4.5

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Especially on 

steeper slopes, there is an 

option to leave DF spacing 

at 33-35'; thin wide leaving 

SDI below 35% so stand 

would not have another 

Thin with mechanical 

harvester and tractor 

end lining; 

underburn; pile burn 

at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

33
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix B

339

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

intermediate thinning. 

36 45 2.1

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Provides 

reduced fuel hazard for 

progeny site. Restore large 

trees and desired 

vegetation characteristics 

in riparian. 

Thin with 

conventional log 

skidder and tractor 

endlining; underburn;

pile burn at landings

No 

treatment Same as Alt 2 31

37 23 2.0

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian.

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

31

38 21 0.1

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian.

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

100

40 10 Partial Retention 

VQO

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Reduce % of 

WF. Plantation with many 

trees less than 10” dbh and 

patches of 

brush/hardwood, esp. 

steeper slopes. Denser, 

Thin with 

conventional log 

skidder and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2 Same as Alt 2 33
Appendix B Two Bit Vegetation Management Draft Environmental Impact Statement

340

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

larger DF concentrated on 

old temp roads, skids and 

benches.

41 27 2.1

General 

Forest/Riparian 

Reserve

Maintain POC where 

possible. Brewer spruce in 

area, maintain if in Unit.

Reduce % of PP & WF, 

increase DF & IC. Fire 

resilient stand managed to 

grow large trees for future 

forest products. Restore 

large trees and desired 

vegetation characteristics 

in riparian.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

33

42 5 0.7

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian. Increase % of 

DF.

Thin with 

conventional log 

skidder and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2 Same as Alt 2 11

43 7 2.5

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian. Increase % of 

DF: clumps of PP have 

snow damage.

Thin with 

conventional log 

skidder and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2 Same as Alt 2 51
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix B

341

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

46 7 1.9

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian. Reduce PP and 

maintain/encourage DF&IC 

and some SF regen.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

51

47 23 General Forest

Fire resilient stand 

managed to grow large 

trees for future forest 

product by reducing 

density. Increase % of DF 

over WF; encourage IC 

regeneration. 

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining;

underburn;

masticate fuels

48

48 9 General Forest

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Favor DF and IC 

over WF. Also reduce 

density in trees less than 

10 “ dbh (esp. below road).

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

48

49 5 General Forest

Fire resilient stand 

managed to grow large 

trees for future forest 

product by reducing 

density. Increase % of DF 

over WF and PP; 

encourage IC 

regeneration.

Thin with 

conventional log 

skidder and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2 Same as Alt 2 48
Appendix B Two Bit Vegetation Management Draft Environmental Impact Statement

342

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

50 9 General Forest

Fire resilient stand 

managed to grow large 

trees for future forest 

product by reducing 

density. Increase % of DF 

over WF and PP; 

encourage IC regeneration

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

48

51 2 0.9

General 

Forest/Riparian 

Reserve

Reduce density of PP and 

maintain hardwoods and 

other conifers. Maintain 

SDI below 55% of 

maximum for at least 30 

years to allow growing 

space of other species.

Remove snow- damaged 

PP. 

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

51

52 9 2.6

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

product by reducing 

density. Increase % of DF 

and WF over PP; 

encourage IC 

regeneration.

Thin with 

conventional log 

skidder and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2 Same as Alt 2 51

53 10 General Forest

Fire resilient stand 

managed to grow large 

trees for future forest 

product. Increase % of DF 

and WF over PP.

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

No 

treatment

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

51
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix B

343

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

54 5 General Forest

Fire resilient stand 

managed to grow large 

trees for future forest 

product. Increase % of DF 

and WF over PP. Manage 

DF regeneration. Maintain 

IC & residual SP.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

51

55 26 6.1

General 

Forest/Riparian 

Reserve/Partial 

Retention VQO

Fire resilient stand 

managed to grow large 

trees for future forest 

products and other values.

Restore large trees and 

desired vegetation 

characteristics in riparian.

Wide spacing in PP 

pockets to reduce 

mortality.

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

100

56 12 7.4

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products and other values.

Restore large trees and 

desired vegetation 

characteristics in riparian.

Top bench/well stocked 

area managed at SDI 

<55% of max. Lower 

portion (hand work) is mix 

of trees 6”-18” dbh and 

regeneration; manage to 

increase DF and well 

distributed trees.

Thin with 

conventional log 

skidder, handwork 

and tractor endlining; 

hand pile fuels

Same as 

Alt 2

Thin with 

conventional log 

skidder, 

handwork and 

tractor 

endlining; hand 

pile fuels

100
Appendix B Two Bit Vegetation Management Draft Environmental Impact Statement

344

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

58 3 0.5

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products and other values.

Reduce density to be 

effective for at least 30 

years due to poor access. 

Thin with 

conventional log 

skidder and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2 Same as Alt 2 51

59 3 0.4

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products and other values.

Increase DF and IC over 

PP and WF.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

33

60 10 0.6

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products and other values.

High site DF can be 

managed 2nd thinning in 

<30 years.

Thin with cable 

logging; underburn

Same as 

Alt 2 Same as Alt 2 108

61 4 1.9

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products and other values.

Restore large trees and 

desired vegetation 

characteristics in riparian

and protect springs.

Maintain IC with good 

crowns and some WF 

without disease. 

Thin with 

conventional log 

skidder and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2 Same as Alt 2 31
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix B

345

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

62 5 General Forest

Maintain the scattered old 

growth and relic trees and 

madrones > 16”. Reduce 

stand density by thinning 

suppressed, intermediate 

and codominant trees.

Favor DF and IC over WF.

Thin with cable 

logging; underburn

Same as 

Alt 2 Same as Alt 2

31 

(understory 

portion)

63 13 2.3

General 

Forest/Riparian 

Reserve 

unmapped stream

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Maintain IC.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

48

64 9 0.03

Riparian 

Reserve/Partial 

Retention VQO

Reduce PP density and 

remove snow-damaged PP 

as priority. Increase DF 

and WF in the stand.

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

51

65 6 Partial Retention 

VQO

Dense young DF stand, 

most trees > 10” dbh. Fire 

resilient stand managed to 

grow large trees for future 

forest products and other 

values.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

31

66 41 14.0

General 

Forest/Riparian 

Reserve

Reduce density in heavily 

stocked portions of the 

stand. Steep slopes 

(including riparian) have 

less conifer stocking.

Thin with mechanical 

harvester and tractor 

end lining; 

underburn; pile burn 

at landings

Same as

Alt 2

Thin with 

mechanical 

harvester and 

tractor end 

lining; 

underburn;

masticate fuels

110
Appendix B Two Bit Vegetation Management Draft Environmental Impact Statement

346

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

67 45 1.8

General 

Forest/Riparian 

Reserve

Dense young DF stand, 

most trees > 10” dbh. Fire 

resilient stand managed to 

grow large trees for future 

forest products and other 

values.

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

33

68 21 2.5

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

100

70 16 General Forest

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Opportunities of 

maintain IC, few open 

areas, few pines, and 

some hardwoods.

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

110

71 43 11.8

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian. Thin wide to 

reduce fuel hazard to 

progeny site. Free thin 

some hardwoods and pine. 

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

31
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix B

347

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

72 14

General 

Forest/Partial 

Retention VQO

Fire resilient stand 

managed to grow large 

trees for future forest 

products.

Thin with cable 

logging; underburn

Same as 

Alt 2 Same as Alt 2 108

75 25 9.3

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

100

76 5 General Forest

Ridge top unit, thin to 

produce fire resilient stand 

and to grow large trees for 

future forest products.

Thin with cable 

logging; underburn

Same as 

Alt 2 Same as Alt 2 31

77 8 2.0

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian. Also reduce 

number of trees < 10” dbh.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

33

78 5 1.6

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian. Also reduce the 

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

33
Appendix B Two Bit Vegetation Management Draft Environmental Impact Statement

348

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

number of trees < 10” dbh.

79 18 0.5

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian. Fireline from 

2007 within unit.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

31

80 20 General Forest

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian. Remove/thin 

trees, <10” where in dense 

patches; maintain vigorous 

8 & 9” trees.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

33

81 6 3.3

General 

Forest/Riparian 

Reserve

Reduce density on the 

small flat on SW corner of 

unit with harvester. On 

steeper portions with trees 

< 10” dbh, reduce stocking 

with hand treatments, 

masticator or fire. Maintain 

and thin POC in draw/wet 

areas. 

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

11

83 3 0.1

General 

Forest/Riparian 

Reserve

Keep mix of DF/PP.

Reduce WF. Fire resilient 

stand managed to grow 

large trees for future forest 

products. Restore large 

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

31
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix B

349

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

trees and desired

vegetation characteristics 

in riparian. Remove/thin 

trees, <10” where in dense 

patches

84 4 1.7

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian. Remove/thin 

trees, <10” where in dense 

patches.

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

31

85 2 0.7

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian. Remove/thin 

trees, <10” where in dense 

patches.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

31

86 18 0.3

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian. Remove/thin 

trees, <10” where in dense 

patches. Increase % of DF.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

100
Appendix B Two Bit Vegetation Management Draft Environmental Impact Statement

350

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

87 9 0.1

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian. Thin PP to 30-

33” spacing; maintain most 

DF and IC.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

97

88 8 0.9

General 

Forest/Riparian 

Reserve

Reduce density and 

increase % of DF.

Decrease the amount of 

damaged or diseased WF 

and PP. 

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

31

89 13 0.2

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian.

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

110

90 3 0.75

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Trees are large 

to thin with hand treatment; 

would reduce clumps or 

scattered trees < 10”.

Thin by handwork 

and hand pile fuels Same as 

Alt 2 Same as Alt 2 33

91 13 General Forest

Fire resilient stand 

managed to grow large 

trees for future forest 

products and other values.

High site DF to be 

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

110
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix B

351

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

managed at higher 

densities.

92 61 3.5

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products and other values.

High site DF to be 

managed at higher 

densities.

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

100

93 10 0.7

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian.

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

33

94 34 7.5

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian. Thin dense 

patches of tree < 10” dbh.

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

100

95 12 10.0

General 

Forest/Riparian 

Reserve

Thin to PP 33'- 35' spacing 

to allow growing space for 

DF and IC regen. Consider 

protecting regen during 

harvest and fuels 

treatment; consider other 

fuels treatment than 

burning. Regeneration may 

need precommercial 

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

11
Appendix B Two Bit Vegetation Management Draft Environmental Impact Statement

352

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

thinning after harvest. 

96 6 1.0

General 

Forest/Riparian 

Reserve

Thin PP to maintain < 55% 

of max SDI for 30 years.

Maintain other DF, IC and 

some hardwoods within 

stand.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

11

97 6

Late 

Successional 

Reserve/General 

Forest

Ridge top unit; manage to 

produce fire resilient stand 

managed to grow large 

trees for late successional 

characteristics. Thin PP to 

maintain < 55% of max SDI 

for 30 years. Maintain 

other DF, IC and some 

hardwoods within stand.

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

97

99 11

Late 

Successional 

Reserve

Most PP are < 20" dbh; 

thin PP to 33-35' spacing. 

DF/IC regeneration would 

replace the off-site PP in 

the long term. Consider 

regeneration during 

harvest and fuel treatment.

Adjacent to private. 

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

11

100 8 5.7

General 

Forest/Riparian 

Reserve

Maintain all 20" trees. Thin 

DF to 28' spacing to keep 

stand relatively well 

stocked. Free thin around 

some madrone. 

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

100
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix B

353

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

101 5 0.1

General 

Forest/Riparian 

Reserve/Late 

Successional 

Reserve

Reduce WF, increase the 

% of DF. Retain all trees 

over 20".

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

110

102 11

Late 

Successional 

Reserve

Fire resilient stand 

managed to grow large 

trees for late successional 

characteristics. Maintain 

patches of PP at wider 

spacing. Maintain POC 

and yew where possible.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

11

103 9 General Forest

Fire resilient stand 

managed to grow large 

tree for products and other 

values. Reduce tree 

density in well stocked DF 

patches. Maintain larger 

hardwoods in open areas 

and steep areas.

Thin with 

conventional log 

skidder and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2 Same as Alt 2 11

104 7

Late 

Successional 

Reserve/General

Forest

Maintain as foraging 

habitat. Manage to reduce 

density and produce large 

trees. 

Thin with 

conventional log 

skidder and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2 Same as Alt 2 110

105 16 3.0

Late 

Successional 

Reserve/Riparian 

Reserve

Manage to produce 

foraging habitat. Maintain 

residual trees including 

most damaged trees that 

would live over the longterm. Reduce density in 

dense patches. Culture 

existing regeneration in 

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

100
Appendix B Two Bit Vegetation Management Draft Environmental Impact Statement

354

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

open areas. Maintain 

larger hardwoods.

106 24 0.8

Late 

Successional 

Reserve/Riparian 

Reserve

Manage to produce 

foraging habitat. Maintain 

POC in stand mix (most in 

ultramafic area below 

road). Thin out PP and 

smaller DF to produce 

larger DF and IC.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

100

108 11

Late 

Successional 

Reserve

Maintain as foraging 

habitat. Manage to reduce 

density and produce large 

trees.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

108

109 5 0.1

Late 

Successional 

Reserve/Riparian 

Reserve

Maintain as foraging 

habitat. Manage to reduce 

density and produce large 

trees.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

100

110 13 7.5

Late 

Successional 

Reserve/Riparian 

Reserve

Maintain as foraging 

habitat. Manage to reduce 

density and produce large 

trees.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

110

111 17

Late 

Successional 

Reserve

Maintain as foraging 

habitat. Manage to reduce 

density and produce large 

trees.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester;

underburn;

masticate fuels

100
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix B

355

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

112 3 1.2

Late 

Successional 

Reserve/Riparian 

Reserve/Partial 

Retention

Mange NE portion in the 

100-acres LSR to produce 

nesting/Roosting habitat in 

the long term. Fire resilient 

stand managed to grow 

large trees for future forest 

products and other values.

Restore large trees and 

desired vegetation 

characteristics in riparian.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

100

113 19 0.2

Riparian 

Reserve/Partial 

Retention VQO

Fire resilient stand 

managed to grow large 

trees for future forest 

products and other values.

Thin dense patches.

Maintain some large PP 

and hardwoods in the more 

open areas. Restore large 

trees and desired 

vegetation characteristics 

in riparian.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

31

114 15 Partial Retention 

VQO

Fire resilient stand 

managed to grow large 

trees for future forest 

products and other values.

Thin dense patches.

Maintain some large PP 

and hardwoods in the more 

open areas. Restore large 

trees and desired 

vegetation characteristics 

in riparian.

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

31
Appendix B Two Bit Vegetation Management Draft Environmental Impact Statement

356

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

115 77 11.1

Riparian 

Reserve/Partial 

Retention VQO

Fire resilient stand 

managed to grow large 

trees for future forest 

products and other values.

Thin dense patches.

Maintain some large PP 

and hardwoods in the more 

open areas. Restore large 

trees and desired 

vegetation characteristics 

in riparian.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

100 (50 

acres)

116 11 3.2

Riparian 

Reserve/Partial 

Retention VQO

Fire resilient stand 

managed to grow large 

trees for future forest 

products and other values.

Maintain PP stocking < 55 

% of max SDI for at least 

30 years. Increase % of 

DF. Restore large trees 

and desired vegetation 

characteristics in riparian.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

underburn;

masticate fuels

97

117 19 0.1

General 

Forest/LSR/Ripari

an 

Reserve/Partial 

Retention VQO

Fire resilient stand 

managed to grow large 

trees for future forest 

products and other values.

Restore large trees and 

desired vegetation 

characteristics in riparian.

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

97

118 10 3.6

General 

Forest/Riparian 

Reserve

Trees mostly < 10” dbh, 

lower site. Larger residuals 

in bottom. Fire resilient 

stand managed to grow 

large trees for future forest 

products and other values.

Thin with 

conventional log 

skidder and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2 Same as Alt 2 51
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix B

357

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

Restore large trees and 

desired vegetation 

characteristics in riparian.

119 5 LSR/General 

Forest

Ridge top and west aspect.

Manage to produce 

foraging habitat and a fire 

resilient stand. 

Thin with 

conventional log 

skidder and tractor 

endlining; underburn;

pile burn at landings

Same as 

Alt 2 Same as Alt 2 33

120 3 LSR

Fire resilient stand 

managed to grow large 

trees for owl habitat and 

buffer adjacent old growth.

Plantation and natural 

stand. Reduce % of WF. 

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

masticate fuels

108

121 13 General Forest

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Restore large 

trees and desired 

vegetation characteristics 

in riparian.

Thin with cable 

logging; underburn

No 

treatment Same as Alt 2 31

Natural Stands

200 14 General Forest

Thin lower area to 240 in 

densest areas and 160 on 

edges and free thin at least 

one SP. Option to leave 

steeper areas as is or to 

thin a few conifers and 

maintain more growing 

space for hardwoods 

(Madrone, black oak)

Thin with 

conventional log 

skidder and tractor 

endlining; underburn;

Same as 

Alt 2 Same as Alt 2 201
Appendix B Two Bit Vegetation Management Draft Environmental Impact Statement

358

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

201 17 2.2

General 

Forest/Riparian 

Reserve 

unmapped 

stream/wetland 

Reduce stocking in 

densest areas over 400 BA 

to around 200-240 BA, 

other well stocked areas to 

160 BA. In areas that have 

dense trees with small 

diameters, reduce stocking 

to 120 BA. Reduce the 

amount of WF including 

some of the larger trees.

Free thin hardwoods and 

SP in areas where they 

can maintain room to grow 

without removing many 

large DF. Post harvest, 

review for precommercial 

thinning of the younger 

regeneration in previously 

harvested, more open 

areas.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

masticate fuels

201

203 3 General Forest

Fire resilient stand 

managed to grow large 

trees for future forest 

products. Management 

would include thinning of 

dense areas of trees < 10” 

dbh and removal of 

disease residual trees.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

masticate fuels

108

205 7 0.2

General 

Forest/Riparian 

Reserve/Partial 

Retention VQO

Reduce stocking to 200-

240 BA in dense patches 

and 140-160 in areas of 

smaller trees. Maintain 

largest trees by reducing 

density. 

Thin with cable 

logging; underburn

Same as 

Alt 2 Same as Alt 2 206
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix B

359

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

206 13 General Forest

Fire resilient stand 

managed to grow large 

trees for future forest 

products and other values.

Reduce % of WF and 

manage to maintain a mix 

of SP, IC, DF, and few of 

larger hardwoods. Maintain 

higher BA/ac in older 

portion of stand on top180-

220.

Thin with 

conventional log 

skidder and tractor 

endlining; underburn;

No 

treatment Same as Alt 2 206

208 23 7.0

General 

Forest/Riparian 

Reserve

Light thinning to 120-140 

BA to produce open stand.

Previously thinned and 

underburned; 

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

Same as

Alt 2

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

225

209 9 3.4

General 

Forest/Riparian 

Reserve

Reduce density around 

some of the large old trees 

and in areas with smaller 

diameter trees. Thin from 

below to 140-180 BA/ac.

Maintain shade and 

riparian vegetation around 

stream channel.

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

No 

treatment

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

201

211 17

General 

Forest/Partial 

Retention VQO

Reduce density to maintain 

a vigorous stand, reduce 

mortality, and produce a 

more fire resilient stand. 

Favor DF over WF. Few 

SP on edges where still 

some growing space. Vary 

leave BA dependent on 

Thin with cable 

logging; underburn

No 

treatment Same as Alt 2 213
Appendix B Two Bit Vegetation Management Draft Environmental Impact Statement

360

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

species and local structure. 

212 3 Partial Retention 

VQO

Thin form below to 160 BA 

in more open areas, and 

200 BA in densest areas.

(canopy likely 55-60% 

closure post thinning)

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

masticate fuels

213

213 6 Partial Retention 

VQO

Reduce density to maintain 

a vigorous stand, reduce 

mortality, and produce a 

more fire resilient stand. 

Favor DF over WF. Vary 

leave BA dependent on 

species and local structure.

Thin with cable 

logging; underburn

Same as 

Alt 2 Same as Alt 2 213

214 19

General 

Forest//Partial 

Retention

Reduce density to maintain 

a vigorous stand, reduce 

mortality, and produce a 

more fire resilient stand. 

Favor DF over WF. Vary 

leave BA dependent on 

species and local structure.

Thin with cable 

logging; underburn

Same as 

Alt 2 Same as Alt 2 206

216 7 2.9

Riparian 

Reserve/Partial 

Retention VQO

Reduce density to maintain 

a vigorous stand, reduce 

mortality, and produce a 

more fire resilient stand. 

Favor DF over WF. Vary 

leave BA dependent on 

species and local structure. 

Maintain riparian buffer. 

Thin with cable 

logging; underburn

Same as 

Alt 2 Same as Alt 2 206

217 3 General Forest

Thin dense pockets from 

below to maintain the 

larger trees and increase 

vigor of the stand. 

Thin with 

conventional log 

skidder and tractor 

endlining; underburn;

Same as 

Alt 2 Same as Alt 2 225
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix B

361

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

218 3 General Forest

Fire resilient stand 

managed to grow large 

trees for future forest 

products and other values.

Thin with 

conventional log 

skidder and tractor 

endlining; underburn;

Same as 

Alt 2 Same as Alt 2 206

219 15 1.4

General 

Forest/Riparian 

Reserve

Fire resilient stand 

managed to grow large 

trees for future forest 

products and other values.

Maintain the few old 

growth trees. Maintain 

riparian vegetation.

Thin with cable 

logging; underburn

No 

treatment Same as Alt 2 255

220 12 1.11

Riparian 

Reserve/Partial 

Retention VQO

Reduce density in heavily 

stocked areas. Remove 

some of diseased trees.

Manage existing 

regeneration in harvest 

areas to produce large 

trees. Reduce % of WF.

Thin with 

conventional log 

skidder and tractor 

endlining; underburn;

Same as 

Alt 2 Same as Alt 2 225

225 6 General Forest

Light thin to reduce density 

in clumps and free thin 

around some of the larger 

trees. 

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

masticate fuels

225

226 8

General 

Forest/Partial 

Retention VQO

Manage to produce a more 

fire resilient stand near 

powerlines. Thin to 140-

160 BA but maintain all the 

large old trees (most not a 

threat to powerlines).

Thin with

conventional log 

skidder and tractor 

endlining; underburn;

Same as 

Alt 2 Same as Alt 2 206

227 10 5.9

Private/Riparian 

Reserve/Partial 

Retention VQO

Thin dense patches to 

reduce pressure on old DF 

and grow some 

replacement DF with 

enough growing space to 

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

No 

treatment

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

227
Appendix B Two Bit Vegetation Management Draft Environmental Impact Statement

362

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

reach 70" dbh. Reduce % 

of WF, but keep mix of 

various species. Remove 

diseased RF. Maintain 

small buffer around BS. 

underburn;

masticate fuels

228 9 General Forest

Reduce WF stocking 

(borax stumps) by thinning 

out around pockets and 

denser clumps. Make 

several openings, monitor 

for DF/IC regen or plant 

DF/IC in openings 

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

masticate fuels

206

229 5

General 

Forest/Partial 

Retention VQO

Manage to produce a more 

fire resilient stand adjacent 

to serpentine area with 

powerlines. Remove 

decadent knobcone pine.

Reduce density and 

provide enough growing 

space to keep the percent 

of IC at its present portion 

in the N 1⁄2. Light thin of 

smaller trees in the S 1⁄2.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

masticate fuels

206

234 9 General Forest

Ridge top unit with 

previous thinning and 

underburn. Produce open 

fire resilient stand. Thin DF 

to 80-120 BA to enhance 

area for black oak.

Maintain SP.

Thin with 

conventional log 

skidder and tractor 

endlining; underburn;

Same as 

Alt 2 Same as Alt 2 234
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix B

363

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

236 2 0.1

General 

Forest/Riparian 

Reserve/Partial 

Retention

Reduce stand density to 

maintain vigor. Remove 

some of the DF with Dwarf 

Mistletoe, especially where 

infecting young vigorous 

DF on flat. 

Thin with 

conventional log 

skidder and tractor 

endlining; underburn;

Same as 

Alt 2 Same as Alt 2 206

237 2 0.01

General 

Forest/Riparian 

Reserve

Stand was previously 

harvested with a 

regeneration prescription, 

but leaving a border of 

overstory trees infected 

with DF dwarf mistletoe.

Remove infected overstory 

trees and infected 

regeneration. Cultural 

remaining regeneration to 

improve growth. 

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

masticate fuels

237

238 10 5.0

General 

Forest/Riparian 

Reserve

Remove smaller trees in 

the stand to reduce 

competition on remaining 

stand and maintain SP in 

stand. Leave BA will vary 

throughout the stand with 

local structure and vigor. 

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

masticate fuels

238

242 6 0.67

General 

Forest/Riparian 

Reserve/Partial 

Retention

Fire resilient stand 

managed to grow large 

trees for future forest 

products and other values.

Near Ridge top. Reduce % 

of WF. Buffer riparian. 

Thin with cable 

logging; underburn

No 

treatment Same as Alt 2 255
Appendix B Two Bit Vegetation Management Draft Environmental Impact Statement

364

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

243 4 0.2

Riparian 

Reserve/Partial 

Retention 

Fire resilient stand 

managed to grow large 

trees for future forest 

products and other values.

Near Ridge top, west 

aspect. Reduce % of WF.

Buffer riparian. 

Thin with cable 

logging; underburn

Same as 

Alt 2 Same as Alt 2 225

244 16 10.6

General 

Forest/Riparian 

Reserve

Leave large old trees and a 

moderate stocking of 

cohorts that seeded in 

about 100 years ago.

Maintain a good mix of 

species. Thin to maintain 

vigor and produce a fire 

resilient stand managed to 

grow large trees for future 

forest products and 

maintain stocking on 

dormant landslide.

Thin with 

conventional log 

skidder and tractor 

endlining; underburn;

No 

treatment Same as Alt 2 201

253 28 16.9

General 

Forest/Riparian 

Reserve

Reduce stocking in denser

groups; light thinning to 

120-160 BA.

Maintain species mix of 

DF, SP and IC. Maintain 

stand with a low fire hazard 

adjacent to Classic 

progeny site. 

Thin with mechanical 

harvester and tractor 

endlining; underburn;

pile burn at landings

No 

treatment

Thin with 

mechanical 

harvester and 

tractor 

endlining; 

underburn;

masticate fuels

225

254 2

Late 

Successional 

Reserve/Partial 

Retention VQO

Manage portion in 100-

acre LSR to produce 

nest/roosting habitat in the 

long-term. Manage 

remainder of stand to 

produce large trees for 

forest products and/or 

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

masticate fuels

206
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix B

365

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

other values. 

255 9 3.0 Riparian Reserve

Reduce density to maintain 

individual tree vigor and 

produce large trees for 

forest products and other 

values. Reduce the % of 

WF in stand. Buffer 

Riparian Reserves.

Thin with mechanical 

harvester; underburn;

pile burn at landings

Same as 

Alt 2

Thin with 

mechanical 

harvester; 

masticate fuels

255

256 5 3.7 Riparian Reserve

Ground is heavily impact 

by hydraulic mining. Dense 

clumps of DF are growing 

on the deep clay loam soil.

Reduce stand density 

where tree are accessible 

to maintain vigor.

Thin with mechanical 

harvester; underburn;

pile burn at landings

No 

treatment

Thin with 

mechanical 

harvester; 

masticate fuels

206

257 5 General Forest 

Ground is heavily impact 

by hydraulic mining. Light 

to moderate thin to 

maintain stand vigor and 

produce wood products. 

Buffer center mining 

channel. 

Thin with mechanical 

harvester; underburn;

pile burn at landings

No 

treatment

Thin with 

mechanical 

harvester; 

masticate fuels

206 

258 8 3.3 Riparian Reserve

Reduce density around 

some of the large old trees 

and in areas with smaller 

diameter trees. Thin from 

below to 140-180 BA/ac.

Maintain shade and 

riparian vegetation around 

stream channel.

Thin with cable 

logging; underburn

No 

treatment Same as Alt 2 201
Appendix B Two Bit Vegetation Management Draft Environmental Impact Statement

366

Unit Acres

Riparian 

Reserve 

Acres

Management 

Area Treatment Objectives Alt 2 - Proposed 

Action 

Alt 3 –

No New 

Roads

Alt 4 –

Minimized 

Underburning

Similar 

Stand 

Structure 

and Species 

Composition

300 36 2.1

General 

Forest/Riparian 

Reserve

Remove some of the DF 

infected with dwarf 

mistletoe that are adjacent 

to plantations or uninfested 

stands. Remove smaller 

infested trees by hand 

methods. 

Roadside sanitation 

using conventional 

log skidder and 

tractor endlining; 

hand work for trees 

less than 10” dbh;

underburn

Same as 

Alt 2 Same as Alt 2 300

301 44 General Forest

Reduce density; area to be 

used for supplying 

products for pole permits.

Roadside pole 

thinning with 

handwork; hand pile 

fuels

Same as 

Alt 2 Same as Alt 2 301

302 40 1.0

Riparian 

Reserve/Wildlife 

Management

Reduce density; area to be 

used for supplying 

products for pole permits.

Roadside pole 

thinning with 

handwork; hand pile 

fuels

Same as 

Alt 2 Same as Alt 2 302

400 18 2.0

General 

Forest/Riparian 

Reserve

Manage stand to maintain 

and increase percentage of 

oak similar to the historic 

condition. Remove most of 

DF except in the few dense 

patches where site is 

better. Thin PP, but 

maintain the largest PP 

with good crowns. Thin IC 

and retain the best and 

largest. Thin near wet area 

with azalea to reduce 

conifer encroachment.

Block temp road that is 

presently being used for 

fire wood cutting. Remove 

some of the small trees 

and brush before burning if 

necessary after harvest. 

Hardwood 

release/enhancement 

using mechanical 

harvester; thin 

smaller vegetation in 

the understory using 

hand methods;

underburn; pile 

burning at landings

Same as 

Alt 2 Same as Alt 2 234
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix C

367

Appendix C – Proposed Logging Systems

Descriptions

Logging Systems

Proposed harvest removal systems for the Two Bit project include mechanized falling and 

skidding, mechanized falling with tractor endline and skyline systems.

Mechanized Falling and Skidding

This system includes mechanical felling of trees using a feller buncher (figure 11). Felled trees 

would be piled and then skidded to landings using a skidder (figure 12). This type of harvest 

removal system is generally used for units with average slopes less than 25 percent. The feller 

buncher generally has a single-pass trail every 60 feet. Skid trails are spaced approximately 200 

feet apart. Landings are approximately one-third to one-half acre in size, and occasionally up to 

three quarters of an acre in size to accommodate slash piles from tree tops. For this project, it 

was assumed that the tops would be left attached to the trees and then skidded to the landing for 

processing and disposal. If no biomass market 

exists at the time of harvest, the tops and slash 

would be piled and burned at the landing.

Figure 11. Mechanical felling using a feller 

buncher

Figure 12. Skidder operations

Mechanized Falling with Tractor Endlining

This system includes mechanical felling of trees using a feller buncher. Felled trees would be 

piled and then skidded to landings using a tracked-skidder (e.g. bulldozer). This type of harvest 

removal system is generally used for units with average slopes greater than 25 percent. The feller 
368

buncher generally has a single-pass trail every 60 feet. Skid trails are spaced approximately 200 

feet apart. Landings are approximately 0.33 to 0.50 acres in size and occasionally up to 0.75 

acres in size to accommodate slash piles from tree tops. For this project, it was assumed that the 

tops would be left attached to the trees and then skidded to the landing for processing and 

disposal. If no biomass market exists at the time of harvest, the tops and slash would be piled and 

burned at the landing. It is assumed that 10 percent of the volume in the unit would require hand 

falling with chainsaws and endlining (winching to the skid trails) in areas with slopes steeper 

than 35 percent.

Skyline System

This system includes hand falling of trees (using chainsaws). Felled trees would be yarded to 

landings using a yarder (figure 13). A yarder is a machine with a tower or gantry crane which 

uses suspended cables to pull the trees to the landing. During the inhaul portion of the yarding 

cycle (up the corridor to the landing), the leading end of the log is suspended off the ground 

(partial suspension) to reduce ground disturbance. To minimize damage to residual trees, yarding 

corridors are mostly parallel on the fall line (straight down the slope) and are located 

approximately 200 feet apart. This means that the yarder is moved to each corridor. Swing 

yarders are the preferred yarder for 

this type of harvest. They are set 

up on an existing road, generally 

requiring little or no earthwork at 

the landing. Trees below the 

landing may need to be cleared 

to accommodate the slash pile, 

with no associated earthwork.

Clearings are approximately onetenth- acre in size, depending on 

the amount of slash generated.

For this project, it was assumed 

that the tops would be left 

attached to the trees and then 

yarded to the landing for 

processing and disposal. If no 

biomass market exists at the time 

of harvest, the tops and slash 

would be piled and burned at the 

landing. 

Figure 13. Yarder operations
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix C

369

Mastication

Mastication is the operation of reducing forest vegetation in the stand by grinding, shredding or 

chopping material. This treatment can lower fuel bed depth, raise crown base height, increase 

fuel-ground contact to promote decomposition, and generate more fine materials.

Figure 14. Mastication 

equipment
Appendix C Two Bit Vegetation Management Draft Environmental Impact Statement

370
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix D

371

Appendix D – Aquatic Conservation Strategy

Compliance

The Klamath National Forest Land and Resource Management Plan (USDA Forest Service 

1995b) contains the components, objectives and standards and guidelines for compliance with 

the Aquatic Conservation Strategy (ACS). Although the ACS Amendment (USDA and USDI 

2004) limited the scope of the effects analyses to the long-term at the watershed scale (5th-field), 

the March 30, 2007 Pacific Coast Fed. of Fishermen’s Assn. et al v. Natl. Marine Fisheries 

Service, et al and American Forest Resource Council, Civ. No. 04-1299RSM (W.D. Wash 

(PCFFA IV)) court case ruled adverse to federal agencies. As a result we must address the nine 

ACS objectives at the site rather than only at the watershed scale and consider short-term as well 

as long-term impacts of the proposed action and action alternatives (USDA and USDI 2007).

The four components of the ACS, as given on pages 4-34 through 4-36 of the LRMP, are: 1) 

Riparian Reserves, 2) Key Watersheds, 3) Watershed Analysis and 4) Watershed Restoration. 

The Project does not occur in a Key Watershed, the project planning team used information from 

the Watershed Analysis when locating and designing the proposed activities, and the project is 

recognized as one step toward overall forest health. Watershed Restoration, which includes fish 

passage improvement, decommissioning, and storm damage repair, is an ongoing program on the 

District and the Forest. This project also proposes direct Watershed Restoration through 

decommissioning of 4.1 miles of Forest system roads. The proposed treatments should reduce 

the amount of watershed degradation that can occur from a high intensity wildfire in the area by 

changing vegetative condition classes to reduce the extent and intensity of a wildfire. 

Activities in Riparian Reserves were developed to improve, protect or have neutral effects to 

RRs conditions in the long term. Particular objectives were designed for thinning in RRs (see 

figure 3 and appendix B). Activities in RRs consist of mechanical thinning, underburning and 

hand piling, water withdrawal, hazard tree removal, re-construction of temporary road segments 

maintenance of existing landings, road maintenance, and decommissioning of twelve road 

stream crossing sites. These activities were evaluated to determine the effects to RRs at the site, 

reach, and 7th-, 6th- and 5th-field watershed scales in the short and long term to meet the ACS 

requirements. The effects of these activities were evaluated in detail in the Hydrology Report 

(Bousfield 2010), the Geology Report (De la Fuente and Bell 2010), the Biological 

Assessment/Evaluation for effects to anadromous fish (Grunbaum 2010b), and the Fisheries 

Specialist Report (Grunbaum 2010a). Bousfield, De la Fuente and Bell, and Grunbaum 

concluded that the activities in RRs met the ACS objectives, as stated on pages 4-6 and 4-7 of 

the LRMP (USDA 1995). There may be adverse, short term impacts at the site- and reach-scales 

but there would be no significant adverse changes to stream temperatures or flow and sediment 

regimes.
Appendix D Two Bit Vegetation Management Draft Environmental Impact Statement

372

The nine Aquatic Conservation Strategy (ACS) objectives listed on pages 4-6 and 4-7 of the 

LRMP are discussed as applicable to the no-action alternative and as applicable to all action 

alternatives of the Two Bit Vegetation Management Project. These are addressed individually in 

the following paragraphs.

No-action Alternative

Maintain and restore the distribution, diversity, and complexity of watershed and 

landscape-scale features to ensure protection of the aquatic systems to which species, 

populations and communities are uniquely adapted. The No-action alternative would 

maintain, but not attempt to actively restore the characteristics listed above. Wildfire could cause 

high burn severity in overstocked stream course RRs under the no-action alternative.

Maintain and restore spatial and temporal connectivity between watersheds. The 

No-action alternative would maintain, but not attempt to actively restore the characteristics listed 

above. Overly dense stands would continue to restrict connectivity for several more decades or 

until a stand-replacing wildfire occurs.

Maintain and restore the physical integrity of the aquatic system, including shorelines, 

banks, and bottom configurations. The No-action alternative maintains, but would not actively 

restore, the characteristics above because there would be no direct or indirect disturbances in 

these areas.

Maintain and restore water quality necessary to support healthy riparian, aquatic, and 

wetland ecosystems. The No-action would maintain, but not actively restore riparian, aquatic 

and wetland ecosystems. The No-action alternative would passively restore water quality due to 

slow recovery from past disturbances and due to slow recovery from over-densification resulting 

from decades of fire suppression.

Maintain and restore the sediment regime under which aquatic ecosystems evolved.

Elements of the regime include the timing, volume, rate and character of sediment input, storage 

and transport. The No-action alternative would maintain, but not restore sediment regimes 

because road impacts would not be reduced and because risk of high intensity wildfire would not 

be reduced.

Maintain and restore instream flows sufficient to create and sustain riparian, aquatic, 

and wetland habitats, and to retain patterns of sediment, nutrient, and wood routing. The 

timing, magnitude, duration, and spatial distribution of peak, high, and low flows must be 

protected. The No-action alternative would maintain current but not restore instream flows that 

have likely decreased from reference condition due to higher than reference condition tree 

density. 

Maintain and restore the timing, variability, and duration of floodplain inundation and 

water table elevation in meadows. The No-action alternative would meet the objective for 

floodplain inundation, but not water table elevation in meadows. Meadows are currently 

experiencing conifer encroachment due to wildfire suppression and the conifer encroachment 
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix D

373

may be lowering water tables due to increased evapotranspiration. With no-action, conifer 

encroachment is expected to increase over time in the absence of wildfire.

Maintain and restore the species composition and structural diversity of plant communities 

in riparian areas. The No-action alternative may meet this objective in the natural stands riparian 

reserves that would not receive treatment due to the decision tree process outlined in figure 3 of 

Chapter 2. The other natural stands riparian reserves are experiencing overstocked conditions 

that may be eventually reduce species composition and structural diversity dues to the absence of 

creeping ground fires from nearly a century of fire suppression. In the plantation stands, that 

were clearcut, aggressively tractor piled, burned, and then planted with Douglas fir and off-site 

pine, the no-action alternative would maintain current poor conditions of species composition 

and structural diversity of plant communities in riparian areas and would not restore species 

composition and structural diversity towards reference and desired conditions. With no-action, it 

will take many decades for species composition and structural diversity of plant communities in 

riparian areas that were clearcut and replanted to recover.

Maintain and restore habitat to support well distributed populations of native plant 

and invertebrate riparian dependent species. The No-action alternative may meet this 

objective in the natural stands riparian reserves that would not receive treatment due to the 

decision tree process outlined in figure 3 of Chapter 2. The other natural stands riparian reserves 

are experiencing overstocked conditions that may be undesirable to native plants and 

invertebrates due to the absence of creeping ground fires from nearly a century of fire 

suppression. In the plantation stands that were clearcut, aggressively tractor piled, burned, and 

then planted with Douglas fir and off-site pine, the no-action alternative would maintain current 

poor conditions of riparian habitat and would not restore riparian habitat towards reference and 

desired condition. With no-action, it will take many decades for habitat conditions for native 

plant and invertebrate riparian-dependent species to recover in most of the stands proposed for 

treatment.

Alternatives 2, 3 and 4

Maintain and restore the distribution, diversity, and complexity of watershed and 

landscape-scale features to ensure protection of the aquatic systems to which species, 

populations and communities are uniquely adapted. In the short term, all action alternatives 

would: (1) insignificantly increase chronic sedimentation due to ground disturbance and/or 

vegetation removal in stream buffer RRs, and (2) slightly decrease risk of moderate to high 

intensity wildfire. In the long-term, all action alternatives would maintain and restore the 

characteristics listed above by: (1) reducing potential for chronic and acute sedimentation of 

streams through decommissioning of segments of system roads, (2) reducing the density of 

conifers towards reference conditions by thinning, (3) restoring vegetative species composition 

towards reference condition by thinning and fuels treatments, (4) reducing fuel loading towards 

reference condition by thinning and fuel treatments, and (5) slightly decrease adverse effects that 
Appendix D Two Bit Vegetation Management Draft Environmental Impact Statement

374

wildfires could cause. Short- and long-term effects on the characteristics listed above would be 

manifested primarily at the site and reach scale. Effects of the action alternatives would be 

neutral at the 7th field and larger scales.

Maintain and restore spatial and temporal connectivity between watersheds. In the 

short-term, all action alternatives would not result in any physical or chemical barrier to 

migration routes for wildlife species or access to spawning and rearing areas for aquatic species. 

In the long-term, all action alternatives would improve the characteristics listed above by

opening up these dense stands to restore the greater connectivity which was historically present 

in these watersheds and (2) decommissioning of nine stream crossing (2 perennial and 7 

intermittent) to restore the longitudinal connectivity of aquatic species. Long-term effects on the 

characteristics listed above would be manifested primarily at the site and reach scale, with slight 

benefits at the 7th field watershed and larger scales.

Maintain and restore the physical integrity of the aquatic system, including shorelines, 

banks, and bottom configurations. In the short-term, the stream crossing decommissioning 

would cause minor direct and indirect impacts to the stream channel at the site scale, but the 

long-term beneficial impacts would greatly outweigh the short-term minor site-scale impacts. In 

the long-term, action alternatives meet this objective because any direct disturbances (from 

steam crossing removals) would not cause a measurable change in channel geomorphology at the 

reach or watershed scales.

Maintain and restore water quality necessary to support healthy riparian, aquatic, and 

wetland ecosystems. All action alternatives meet this objective. In the short-term, there may be 

insignificant effects to water quality, sedimentation, and/or channel geomorphology at the sitescale but not at larger scales. In the long-term, decommissioning system roads and accelerating 

large tree growth in previously clear-cut stream course riparian reserves would improve water 

quality and outweigh any minor short-term effects. Long-term beneficial effects to water quality 

would be realized at all scales.

Maintain and restore the sediment regime under which aquatic ecosystems evolved.

Elements of the regime include the timing, volume, rate and character of sediment input, storage 

and transport. Slight short term increase in turbidity and slight increase in potential for mass 

wasting would negligibly affect the sediment regime at the reach or watershed scale. In the long 

term, the action alternatives would restore sediment regimes at the site, reach, and watershed 

scales by decommissioning system roads. Although temporary roads would be constructed or reconstructed their impacts are minor compared to system roads which cause chronic and 

potentially catastrophic sedimentation. No new temporary roads would be constructed in stream 

course RRs.

Maintain and restore instream flows sufficient to create and sustain riparian, aquatic, 

and wetland habitats, and to retain patterns of sediment, nutrient, and wood routing. The 

timing, magnitude, duration, and spatial distribution of peak, high, and low flows must be 

protected. All action alternatives meet this objective. Short-term, but not long-term, peak flows 
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix D

375

at the site and reach scale may be slightly increased. In the short- and long-term, peak flows at 

the 7th field and larger scales would not be altered. In the short- and long-term, low flows may 

actually slightly increase at all scales due to the action alternatives.

Maintain and restore the timing, variability, and duration of floodplain inundation and 

water table elevation in meadows. All action alternatives would meet this objective. Under all 

action alternatives, peaks flows causing floodplain inundation would remain unchanged in the 

short- and long-term. All action alternatives would sustain or restore water table elevation in 

meadows in the short- and long-term by removing conifers that have been encroaching on these 

meadows due to decades of fire suppression.

Maintain and restore the species composition and structural diversity of plant 

communities in riparian areas. All action alternatives would meet this objective. Between 4 

and 23 percent of the managed 7th -field watersheds stream course RRs had been clear cut 

harvested other the last half century. These locations are homogeneous stands with little 

structural or understory species diversity. With treatments, these stands would begin to have a 

greater species composition due to additional light reaching the forest floor, and would have 

greater structural diversity as new seedlings create an understory and as residual trees increase in 

growth and vigor in response to thinning and underburning. Treatments under all action 

alternatives would restore species composition and structural diversity of plant communities at 

the site scale in the short- and long term.

Maintain and restore habitat to support well distributed populations of native plant and 

invertebrate riparian dependent species. All action alternatives would meet this objective. Most 

plantations were aggressively tractor piled and burned, followed by planting of Douglas-fir and 

off-site pine. Native hardwoods and other conifer species may have naturally established, but are 

scarce in many of the plantation stream course RRs. Treatments would help accelerate the 

recovery of these altered stream course RRs at the site scale in the short- and long-term.

Invertebrates in aggressively burned and tractor-piled plantations may have been destroyed 

especially in areas were extensive stream clearing of woody debris had taken place. In both 

plantations and natural stands, treatments would result in more water, nutrients, and sunlight 

being available for improving the growth, resilience, and vigor of residual trees in the stream 

course RRs.
Appendix D Two Bit Vegetation Management Draft Environmental Impact Statement

376
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix E

377

Appendix E – Implementation of Best 

Management Practices for the Two Bit Vegetation 

Management Project

Introduction

Best Management Practices (BMPs) were developed to comply with Section 208 of the Clean 

Water Act. BMPs have been certified by the State Water Quality Resources Control Board and 

approved by the Environmental Protection Agency (EPA) as the most effective way of protecting 

water quality from impacts stemming from non-point sources of pollution. These practices have 

been applied in timber sales and road construction projects in watersheds over the last 20 years 

and have been found to be effective in protecting water quality within the Klamath National 

Forest. Specifically, effective application of the US Forest Service Region 5 BMPs has been 

found to maintain water quality that is in conformance with the Water Quality Objectives in the 

North Coast Regional Water Quality Control Board’s (NCRWQCB) Basin Plan.

USFS Region 5 BMPs have been monitored and modified since their original 

implementation in 1979 to make them more effective. Numerous on-site evaluations by the 

NCRWQCB have found the practices to be effective in maintaining water quality and protecting 

beneficial uses/resources (e.g., domestic use, anadromous and resident fish). The Forest monitors 

the implementation and effectiveness of BMPs on randomly selected projects each year. BMP 

effectiveness requirements were met on 90-100 percent of the sites sampled in 2000-2007. The 

success rate for effectiveness has been in the high 80s and 90s each year since 1993.

[Please refer to http://www.fs.fed.us/r5/klamath/projects/forestmanagement/ to view a 

compilation of KNF annual BMP implementation and effectiveness monitoring reports].

The following list of BMPs was developed for the Two Bit Project and is current as of 

November 24, 2009. The objective of each BMP is described first then is followed by 

descriptions of the specific measures or project design features (PDFs) that will be implemented 

to achieve compliance with each BMP. For additional information on the BMPs and their 

objectives, see Water Quality Management for Forest System Lands in California, USDA Forest 

Service, and Pacific Southwest Region (USDA Forest Service 2000b).

Best Management Practices

BMP 1.1 – Timber Sale Planning Process: The objective is to incorporate water quality and 

hydrologic considerations into the Timber Sale Planning Process. This requires the 

Interdisciplinary Team (IDT) to consider methods of reducing water quality impacts during the 

planning phase of a project. PDFs incorporated to reduce water quality impacts include:

Streams will be protected from commercial thinning with an appropriate width stream 

buffer. For determining stream-buffer Riparian Reserves (RR) widths, one site potential 

tree height was designated 170 feet for the project area. Within stream course RRs, a 
Appendix E Two Bit Vegetation Management Draft Environmental Impact Statement

378

silvicultural prescription will retain all trees a minimum of 10 feet from ephemeral and 

intermittent streams, and 25 feet of a perennial streams. However, allow for the 

sanitation of diseased, pest infested, or off-site pines to meet long term ACS objectives.

In natural stands a restrictions on commercial harvesting within Riparian Reserves of 

intermittent streams (that flow into June on an average water year) outside of the above 

10-foot no-treatment zone would also apply unless certain criteria are met: 

1. Commercial harvesting would only occur from 10 to 50 feet of the stream if

current overstory canopy cover is equal to or greater than 85 percent and this 

overstory canopy cover would not be reduced below 85 percent

2. Commercial harvesting would only occur within 50 to170 feet of the stream if

current overstory canopy cover is equal to or greater than 65 percent and this 

overstory canopy cover would not be reduced below 65 percent

3. If overstory trees are not at their site potential height and/or site conditions do 

not allow attainment of the above canopy cover percentages then harvesting 

which would retain current overstory canopy cover or potentially enhance future 

overstory canopy cover may occur within 10 to 170 feet of the stream, upon 

consultation with a Hydrologist

In natural stands a restrictions on commercial harvesting near perennial streams outside 

of the above 25-foot no-treatment buffer zone would also apply unless certain criteria 

are met: 

1. Commercial harvesting would only occur within 25 to 75 feet of the stream if 

current overstory canopy cover is equal to or greater than 85 percent and this 

overstory canopy cover would not be reduced below 85 percent during harvest 

2. Commercial harvesting would only occur within 75 to170 feet of the stream if: 

current overstory canopy cover is equal to or greater than 65 percent and this 

overstory canopy cover would not be reduced below 65 percent during harvest

3. If overstory trees are not at their site potential height and/or site conditions do 

not allow attainment of the above canopy cover percentages then harvesting 

which would retain current overstory canopy cover or potentially enhance future 

overstory canopy cover may occur within 25 to 170 feet of the stream, upon 

consultation with a Hydrologist.

Streams will be protected from ground-disturbing activities with an equipment exclusion 

buffer. Equipment will be excluded from slopes greater than 35 percent within RR. A 

minimum equipment exclusion buffer will be 10 feet from ephemeral streams, 25 feet 

from intermittent, and 50 feet from perennial streams. Minimums may be larger based 

on site conditions such as continuous slopes ( > 25%) leading directly into the stream 

channel, slope breaks, low soil cover, unstable ground or erosive soils, to be determined 

by an Earth Scientist during unit layout.

Commercial thinning and other ground-disturbing activities will not be implemented on 

ground that is geologic RR (inner gorges, unstable ground, or highly erosive terrains). 

Exceptions to this would could occur: (1) in situations where a small patch (a few acres 

or less) of trees in an unstable area is in imminent danger of mortality from 

insects/disease or is overly dense, in which cases equipment would still be excluded and 

thinned trees would be endlined out from the unstable area – a Forest geologist must 

approve all thinning on geologic RRs, and (2) use of existing system roads and/or 

landings that can be used without significant risk of resource damage. 

Tractor skidding will occur on designated skid trails. Existing skid trails will be re-used 

whenever possible. Tractors may leave skid trails to access isolated logs if ground 

conditions permit.
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379

Tractor yarding is generally limited to slopes less than 35 percent (short sections of skid 

trails connecting flat benches may exceed 35 percent slope, and endlining from 

designated skid trails may occur on slopes greater than 35 percent).

Low ground-pressure track mounted harvesters can operate on slopes up to 45 percent

on soils formed from metasediments and ultramafic rock types. On slopes >35 percent

equipment will operate perpendicular to the contour and avoid sideslope travel.

On soils formed from granitic rock types (units 106, 288, 543) ground-based skidders 

and harvesters are limited to slopes <35 percent.

Maintain at least 85 percent of the land dedicated to growing vegetation in a condition 

that meets Forest Plan Standards and Guidelines, as well as Regional Soil Analysis 

Quality Standards.

No new constructed, full bench skid trails will be created.

During Project implementation, temporary roads will be outsloped, covered with slash 

(where needed), and blocked to vehicle access after the harvest season and before onset 

of the wet season. Temporary roads will be hydrologically restored upon Project 

completion using methods given on page 79 of the 2004 NMFS Biological Opinion on 

programmatic implementation of the KNF Land and Resource Management Plan (USDC

2004).

Existing landings will be reused whenever possible - minimizing need for new landings. 

New landings will be kept as small as feasible, yet will meet safe working standards.

Roads and landings will not be constructed or enlarged in hydrologic and geologic RRs. 

Existing roads and landings in RRs may be used where suitable facilities currently exist 

and risk of resource damage is negligible. Existing landings within 30 feet of the slope 

break to a stream channel or inner gorge will not be used.

Meet Forest Plan standards and guidelines for soil cover as measured before the fall 

rainy season. Within all timber sale units, post-treatment soil cover will range from 50-

70 percent (where that much currently exists) depending on slope steepness and type of 

fuel reduction treatments, as measured before the fall rainy season. At least 50 percent

cover, as fine organic matter (<3 inch material), would be retained in all timber sale 

units.

BMP 1.2 – Timber Harvest Unit Design: The objective is to ensure that timber harvest unit 

design will secure favorable conditions of water quality and quantity while maintaining desirable 

stream channel characteristics and watershed conditions. The design should consider the size and 

distribution of natural structures (snag and down logs) as a means of preventing erosion and 

sedimentation.

Retain existing course woody debris (CWD) to Forest Plan Standards whenever 

feasable, providing the amount of CWD does not exceed fuel management objectives.

Thinning prescriptions leave largest oldest trees that are providing snags and/or are most 

likely to provide snags and CWD in the near future.

The IDT reviewed all units to select logging methods (cable, tractor, feller-buncher, 

yoder) and fuel treatments appropriate to site conditions. Equipment will be kept 

approximately 10 feet from the break in slope to a wetted stream channel or to the inner 

gorge of an intermittent stream channel or to hydraulic mining scarps and slumps.

Trees will not be thinned closer than 10 feet to the edge of the old hydraulic mining 

scarps. 
Appendix E Two Bit Vegetation Management Draft Environmental Impact Statement

380

BMP 1.3 – Determination of Surface Erosion Hazard for Timber Harvest Unit Design: The 

objective is to identify high erosion hazard areas in order to adjust treatment measures to prevent 

downstream water quality impacts.

Based on field review and site data (percent slope distribution, soil texture), a Soil 

Scientist determined surface erosion hazard for each treatment unit (Walters 2010).

Selected management activities were designed to achieve predominately low erosion 

hazard ratings for project implementation in treatment units.

BMP 1.4 – Use of Sale Area Maps (SAM) and/or Project Maps for Designating Water 

Quality Protection Needs: The objective is to ensure recognition and protection of areas related 

to water quality protection delineated on a SAM or Project Map.

All protected springs, wetlands, stream courses, and stream buffer RRs will be shown on 

the SAM.

All protected unstable land features (geologic Riparian Reserves) will be shown on the 

SAM.

Appropriate logging methods will be shown on SAM.

BMP 1.5 – Limiting the Operating Period (or Sale Operation Schedule) of Timber Sale 

Activities: The objective is to ensure that the purchasers conduct their operations, including, 

erosion control work, road maintenance, and so forth, in a timely manner, within the time 

specified in the Timber Sale Contract.

Most project operations will be implemented during the normal operating season (NOS) 

from May 15 to October 15, and in dry periods outside the NOS with earth scientist 

recommendation and Line Officer approval. Activities will be restricted during periods 

of wet weather during the NOS.

The KNF Wet Weather Operation Standards and Guidelines (WWOS – Klamath 

National Forest, 2002) will be used to guide operations during periods of wet weather. 

The TSA will examine field conditions to determine when the soil and/or road have 

dried out enough to enable operations to resume without risk of watershed impacts. The 

project earth scientist may be called upon to make recommendations to the TSA who 

will provide direction to the Timber Sale Contractor (TSC) as to when operations may 

resume to insure that BMPs will be met and adverse impacts avoided.

All erosion control prevention measures shall be kept current immediately preceding 

expected seasonal periods of precipitation or when operating outside the NOS. 

Operations will be suspended when not in compliance with WWOS. Operations will not 

resume until suitable ground conditions exist.

Forecast periods will be of a suitable length to allow completion or winterization of the 

task undertaken before precipitation events occur.

BMP 1.6 – Protection of Unstable Lands: The objective is to provide special treatment of 

unstable areas to avoid triggering mass slope failure with resultant erosion and sedimentation.
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix E

381

Project watershed personnel conducted field reviews of all proposed harvest units and 

identified and documented unstable areas.

All protected unstable land features (geologic Riparian Reserves) will be shown on the 

SAM and/or Unit Information Card, and equipment will be excluded from these areas

(except for use of existing system roads and/or landings that can be used without 

significant risk of causing resource damage).

Equipment will not operate closer than approximately 10 feet to the edge of hydraulic 

mining scarps. Trees will not be thinned within 10 feet of old hydraulic mining scarps.

Project watershed personnel will be available for consultation during project 

implementation when activities occur in or adjacent to unstable areas.

BMP 1.8 – Streamside Management Zone Designation: The objective is to designate a zone 

along riparian areas, streams and wetlands that will minimize potential for adverse effects from 

adjacent management activities. Management activities within these zones are designed to 

improve riparian values.

Protected stream buffer RRs have been designated and will be shown on the SAM.

Equipment exclusion will be designated on the ground as well as in the timber sale 

contract.

Water drafting areas for dust abatement will be designated on the SAM by the Forest 

Service and agreed to by the TSC. Water drafting will be in compliance with NOAA 

Fisheries 2001 Water Drafting Specifications. 

Existing landings within 30 feet of the slope break to a stream channel or inner gorge 

will not be used. Landings will not be constructed or enlarged in RRs. There will be no 

yarding of trees or logs through, in, or across perennial stream channels.

BMP 1.9 – Determining Tractor Loggable Ground: The objective is to minimize erosion and 

sedimentation resulting from ground disturbance by tractor logging systems.

A soil scientist field reviewed all the tractor log units to verify that they were reasonable 

to tractor log from a soil resource perspective based upon the combination of erosion 

hazard rating for bare soil, soil displacement potential, terrain complexity and the 

presence and lengths of scarps with slopes >35 percent.

BMP 1.10 – Tractor Skidding Design: The objective is to design skidding patterns to best fit 

the terrain, the volume, velocity, concentration, and to control the direction of runoff water in a 

manner that will minimize erosion and sedimentation.

Skid trail locations will be determined on site by agreement between the contractor and 

the TSA.

Skid trails will be laid out on slopes generally less than 35 percent. Where needed, earth 

scientists will assist the TSA in skid trail location.

Existing skid trails will be reused whenever practical.

New skid trails would be limited to slopes less than 35 percent except where necessary 

to cross short steeper sections that connect flatter benches. No new constructed (full 

bench) skid trails will be created.
Appendix E Two Bit Vegetation Management Draft Environmental Impact Statement

382

Main skid trails will be spaced to minimize the number of trails, minimizing the amount 

of ground affected. 

The use of existing, or the location of new skid trails across any intermittent or 

ephemeral channel will be by agreement between the Timber Sale Contractor, the TSA, 

and an earth scientist. The channel’s shape at skid trail crossing will be restored per 

BMP 1.17. Skid trails will not cross perennial streams.

Linear depressions perpendicular to the contour (up and down the slope – such as 

ephemeral draws or remnant channels) that can concentrate runoff will not be used for 

skid trails.

Skid trails that intersect Forest Roads will be blocked or hydrologically restored at the 

intersection to prevent unauthorized traffic, prevent surface flow, and hydrologic 

connectivity.

BMP 1.11 - Suspended Log Yarding in Timber Harvesting: The objective is to protect the soil 

mantle from excessive disturbance; to maintain the integrity of the streamside management zone 

(SMZ) and other sensitive watershed areas, and to control erosion on cable corridors.

Ground-based skidding and skyline yarding will require front-end suspension of logs. 

Front-end suspension is not used for endlining.

Full suspension cable yarding would be used over stream channels and within 10 feet of 

stream channels and one-end suspension cable yarding would be used in the remainder 

of the surrounding stream course Riparian Reserves.

BMP 1.12 – Log Landing Location: The objective is to locate new landings or reuse old 

landings in such a way as to avoid watershed impacts and associated water quality degradation.

New and old landings would be selected for use that involves the least amount of 

excavation, and the least erosion potential.

Existing landings will be used to the maximum extent possible.

Existing landings within 30 feet of the slope break to a stream channel or inner gorge 

will not be used.

Landings will not be constructed or enlarged in RRs.

BMP 1.13 – Erosion Prevention and Control Measures during Timber Sale Operations: The 

objective is to insure that the purchaser’s operations will be conducted reasonably to minimize 

soil erosion.

Erosion control measures are discussed during the pre-operations meeting with the TSC 

and/or purchaser and the Forest Service. They are updated throughout the operations 

phase of the timber sale.

During project implementation, final locations and design characteristics for landings 

and new temporary roads will be reviewed by earth science personnel prior to 

construction as needed.

TSAs are responsible for administering the Forest Service Timber Sale Contract and will 

periodically inspect the contractor’s operations to assure that erosion control measures 

are implemented in a timely manner.
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix E

383

The Project earth scientist will make periodic inspections of the sale to insure that the 

erosion control measures are having the desired effect and are in compliance with BMPs.

The earth scientist will make recommendations to the TSA or Forest Service 

Representative as to any action needed to comply with BMPs.

The Klamath WWOS (USDA-FS KNF 2002) will be used.

All erosion control prevention measures shall be kept current immediately preceding 

expected seasonal periods of precipitation or when operating outside the Normal 

Operating Season. Operations will be suspended when not in compliance with Wet 

Weather Operating Guidelines. Operations will not resume until suitable ground 

conditions exist.

Also see BMP 1.5 and 1.11.

BMP 1.14 – Special Erosion Prevention Measures on Disturbed Land: The objective is to 

provide appropriate erosion and sedimentation protection for disturbed areas.

Main skid trails in RR will have slash spread on them as necessary to control surface 

erosion.

Slash will be spread on disturbed ground as necessary, according to the Sale 

Administraor’s descresion in order to minimize erosion.

BMP 1.15 – Revegetation of Areas Disturbed by Harvest Activities: The objective is to 

establish a vegetative ground cover on disturbed sites to prevent erosion and sedimentation.

Landings that will not be used again will be contoured ripped to break up compaction so 

that brush and trees can revegetate the area and thrive.

BMP 1.16 – Log Landing Erosion Control: The objective is to reduce the impacts of erosion 

and subsequent sedimentation associated with log landings by use of mitigating measures.

New and old landings would be selected for use that involves the least amount of 

excavation, and the least erosion potential.

New landings and expansion of existing landings will not be constructed within RRs. 

New and expanded landings will be kept as small as possible to meet OSHA safety 

standards of operating.

Landing areas within 30 feet of the slope break to a stream channel or inner gorge will 

not be used.

Landings will be shaped to disperse drainage and direct runoff away from watercourses 

at the time of construction. Rock armoring and silt fences with straw bales may be used 

as necessary to direct water to areas of suitable drainage and to capture sediment. Where 

necessary to prevent excessive erosion, new landing cut and fill slopes will be covered 

with slash and the slash layer will be maintained throughout the life of the project.

Landings will be covered with slash as necessary to minimize surface erosion.

BMP 1.17 – Erosion Control on Skid Trails: The objective is to protect water quality by 

minimizing erosion and sedimentation derived from skid trails.

Skid trails will be water-barred in accordance with TSA Handbook.
Appendix E Two Bit Vegetation Management Draft Environmental Impact Statement

384

Where special erosions prevention measures are needed and identified the spreading of 

slash will be applied to surface disturbed areas to minimize soil erosion.

Skid trails that intersect Forest Roads will be blocked or hydrologically restored at the 

intersection.

Skid trails that cross ephemeral or intermittent channelswill be restored before any storm 

with the potential for rain arrives. This will be done with consultation with an earth 

scientist and generally consists of removing excess soil, reshaping and waterbarring 

former approaches, and spreading slash on former crossing approaches.

Cable yarding corridors with exposed soil will be waterbarred and or covered with slash.

BMP 1.18 – Meadow Protection During Timber Harvesting: The objective is to avoid 

damage to ground cover, soil, and hydrologic function of meadows.

Meadows within and adjacent to commercial timber units will be identified on the SAM 

and equipment will be excluded from operating in the meadow areas.

BMP 1.19 – Stream Course and Aquatic Protection: The objective is to conduct management 

actions within these areas in a manner that maintains or improves riparian and aquatic values; to 

provide unobstructed passage of stormflows; to control sediment and other pollutants entering 

streamcourses; and to restore the natural course of any stream as soon as practicable, where 

diversion of the stream has resulted from timber management activities.

Service landings are located away from channels. Fuel containment systems will be used 

at service landings according to contract specifications.

Purchaser shall furnish oil-absorbing mats for use under equipment being serviced to 

prevent petroleum-based products from contaminating soil and water resources.

Straw bales, rock, and containment dikes may be used as needed at water drafting sites 

and service landings to capture any spilled water and prevent runoff to streams.

Same as first bullet under BMP 1.1.

BMPs 2.12, 2.13, 2.21, 2.23, 5.10, and 5.11 are also applicable

BMP 1.20 – Erosion Control Structure Maintenance: This objective is to ensure that 

constructed erosion control structures are stabilized and working.

All waterbars will be maintained during the period of the Timber Sale Contract for at 

least one year after their construction.

A barrier to prevent vehicle traffic use will be placed at all temporary road takeoffs at 

the end of the operating season.

BMP 1.21 – Acceptance of Timber Sale Erosion Control Measures before Sale Closure: The 

objective is to ensure the adequacy of required erosion control work on timber sales.

During the final contract inspection, Forest Service personnel will inspect erosion 

control measures and make sure they are working as intended before releasing the 

purchaser from the contract responsibility.
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix E

385

BMP 1.25 – Modification of the Timber Sale Contract: The objective is to modify the Timber 

Sale Contract if new circumstances or conditions indicate that the timber sale will damage soil, 

water, or watershed values.

The contract will be modified as needed to insure maintenance of water quality in the 

event of unforeseen circumstances that could result in resource impacts.

BMP 2.1 – General Guidelines for the Location and Design of Roads: The objective is to 

locate and design roads with minimal resource damage.

Potential locations for temporary roads were identified on the Project planning map and 

these areas were field evaluated by earth scientists.

New temporary road will not be constructed on unstable ground geologic RRs or within 

stream buffer RRs.

New temporary road construction will be located on gentle ground or on or near ridges 

and will require little to no cut and fill. New temporary road will be constructed so that 

runoff is dispersed not concentrated. Water will be drained toward the downhill side of 

the road not into an inboard ditch.

BMP 2.2 - Erosion Control Plan: The objective is to limit and mitigate erosion and 

sedimentation through effective planning prior to initiation of construction activities and through 

effective contract administration during construction.

PDFs developed by the IDT to protect Forest resources and other ecosystem components 

will be incorporated into timber sale contract specifications and provisions.

During the timber sale pre-operations meeting, the Forest Service and the timber sale 

contractor and/or purchaser will reach agreement on a project erosion control plan that 

includes the PDFs developed by the IDT. This plan is implemented during the operations 

phase of the Project.

TSAs are responsible for administering the Timber Sale Contract including the erosion 

control plan, and ensuring compliance with the plan and all other applicable standards 

and guidelines.

BMP 2.3 - Timing of Construction Activities: The objective is to minimize erosion by 

conducting operations during minimal runoff periods.

See BMP 1.5: Limiting Operating Period of Timber Sale.

All landing construction and road work will be conducted during appropriate periods of 

weather and soil moisture to insure BMP attainment and the avoidance of adverse 

watershed effects. Forecast periods will also be of a suitable length to allow completion 

or winterization of the task undertaken before precipitation events occur.

BMP 2.4 – Stabilization of Road Slope Surfaces and Spoil Disposal Areas: The objective is 

to minimize erosion from exposed cut slopes, fill slopes, and spoil disposal areas.

As necessary to attain stabilization of landing and temporary road fill slopes, erosion 

control measures such as out-sloping, drainage dips, and water bars shall be 
Appendix E Two Bit Vegetation Management Draft Environmental Impact Statement

386

implemented. Where special erosions prevention measures are needed and identified, the 

spreading of slash may be applied to minimize erosion of exposed soils.

BMP 2.5 - Road Slope Stabilization Construction Practices: The objective is to reduce 

sedimentation by minimizing erosion from road slopes and slope failures along roads.

New temporary road will not be constructed on steep, erosive, and/or unstable ground, or 

within inner gorges.

Roads would be surfaced as needed to minimize surface erosion and road wear that can 

concentrate runoff and cause gullying or failure of road fill.

Temporary road drainage will be handled by outsloping the road surface so that runoff is 

not concentrated and drainage is self-maintaining.

Temporary roads used in the project would be opened and constructed with minimal 

clearing limits.

BMP 2.7 – Control of Road Drainage: The objective is to minimize the erosive effects of water 

concentrated by road drainage features; to disperse runoff from disturbances within the road 

clearing limits; to lessen the sediment yield from roaded areas; and to minimize erosion of the 

road prism by runoff from road surfaces and from uphill areas.

Existing drainage and surfacing problems on System roads to be used by the Project will 

be repaired before commercial thinning is initiated. The Project will maintain roads used 

for implementation in acceptable functioning condition throughout Project use, so that 

addition resource damage does not occur

Temporary road drainage will be handled by outsloping the road surface so that runoff is 

not concentrated and drainage is self-maintaining.

BMP 2.11 - Control of Sidecast Material during Construction and Maintenance: The 

objective is to minimize sediment production originating from sidecast material during road 

construction or maintenance.

Sidecasting during road maintenance and clearing operations should not extend beyond 

the road prism of any road, or into any streamside management zone.

During road blading, loose material should be incorporated back into the road prism and 

utilized in the road subgrade to the maximum extent possible, or deposited at designated 

disposal sites.

BMP 2.12 - Servicing and Refueling of Equipment: The objective is to prevent pollutants such 

as fuels, lubricants, bitumens and other harmful materials from being discharged into or near 

rivers, streams and impoundments, or into natural or man-made channels.

Fuel containment systems will be in place on landings as necessary.

Oil-absorbing mats will be used under equipment being serviced to prevent petroleumbased products from contaminating soil and water resources.

Refueling and maintenance of Project motorized equipment will occur at least 200 feet 

away from any channel.
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix E

387

BMP 2.13 – Control of Construction and Maintenance Activities Adjacent to Streamside 

Management Zones: The objective is to protect water quality by controlling construction and 

maintenance actions within and adjacent to any streamside management zone so that the 

following functions are not impaired: 1) Effectively filtering sediment generated by erosion from 

bare surfaces, road fills, dust drift, and oil traces; 2) Maintaining shade, riparian habitat (aquatic 

and terrestrial), and stabilizing the channel; 3) Keeping the floodplain surface in a resistant, 

undisturbed condition to slow water velocities and limit erosion by flood flows.

New landings and expansion of existing landings will not be constructed within RRs. 

Existing landing areas within 30 feet of the slope break to a stream channel or inner 

gorge will not be used.

Earth Scientists and Engineers will determine appropriate treatments when re-opened 

maintenance level 1 roads pose a high risk to watershed health. Treatments on re-opened 

roads may include spot rocking of wet areas, rolling dip construction on stream crossings 

with diversion potential, and rip-rap placement on spillways of "shotgun" culverts.

BMP 2.14 – Controlling In-channel Excavation: The objective is to minimize stream channel 

disturbances and related sediment production. 

Culverts will be replaced at existing temporary and existing system stream crossing, 

where none currently exist. Stream channels were culverts are scheduled to be pulled, 

post project implementation, will be realigned to restore natural stream flow.

Excavation will occur where culverts will be removed during decommissioning.

Mitigation measures are incorporated into the contract by design engineers. Contract 

specifications and operating plans will be adhered to during excavation activities. 

BMP 2.15 Diversion of Flows Around Construction Sites: To ensure that all stream diversions 

are carefully planned, to nimimize downstream sedimentation, and to restore stream channels to 

their natural grade, condition, and alignment as soon as possible. 

On decommissioned system roads,the streamflow will be diverted for all live streams 

prior to construction activities. Mitigation measures are incorporated into the contract by 

design engineers. No existing temporary road crossings have perennial streams, so no 

streamflow diversion is required.

BMP 2.16 – Stream Crossings on Temporary Roads

Culverts will be replaced at existing temporary and existing system stream crossing, 

where none currently exist. Stream channels were culverts are scheduled to be pulled, 

post project implementation, will be realigned to restore natural stream flow. No new 

temporary roads will cross streams.

BMP 2.17 – Bridge and Culvert Installation: To minimize sedimentation and turbidity 

resulting from excavation for in-channel structures.

Excavated materials should be kept out of channels, and removed from floodplains prior 

to the rainy season. Mitigation measures are incorporated into the contract by design 

engineers.
Appendix E Two Bit Vegetation Management Draft Environmental Impact Statement

388

BMP 2.19 – Disposal of Right-of-Way and Roadside Debris: The objective is to ensure that 

organic debris generated during road construction is kept out of streams so that channels and 

downstream facilities are not obstructed. Also, to ensure debris dams are not formed which 

obstruct fish passage, or fish could result in downstream damage from high water flow surges 

after dam failure.

Slash and debris created in RR as a result of reopening roads will be either piled and 

burned in the riparian or removed to a disposal site.

Pile burning will not occur within 25 feet of any stream course.

BMP 2.21 - Water Source Development Consistent with Water Quality Protection: The 

objective is to supply water for roads and fire protection while maintaining existing water 

quality.

Straw bales, rock surfacing, and containment dikes will be used as needed to prevent 

surface erosion and sedimentation runoff back into a stream. 

Water will be drafted in accordance with NOAA Fisheries 2001 Water Drafting 

Specifications designed to avoid adverse effects to water quality and anadromous fish.

BMP 2.22 – Maintenance of Roads: The objective is to maintain roads in a manner which 

provides for water quality protection by minimizing rutting, failures, sidecasting, and blockage 

of drainage facilities all of which can cause erosion and sedimentation, and deteriorating 

watershed conditions.

Road surfaces will be watered and/or rocked as needed to reduce road wear and 

minimize loss of road fines.

Road drainage (ditches, culverts, dips) facilities will be kept in acceptable functioning 

condition during the life of the TSC, so that additional resource damage does not occur. 

The Klamath WWOs guidelines will be followed. 

Earth Scientists and Engineers will determine appropriate treatments when re-opened 

maintenance level 1 roads pose a high risk to watershed health. Treatments on re-opened 

roads may include spot rocking of wet areas, rolling dip construction on stream crossings 

with diversion potential, and rip-rap placement on spillways of "shotgun" culverts.

BMP 2.23 – Road Surface Treatment to Prevent Loss of Materials: The objective is to 

minimize the erosion of road surface materials and consequently reduce the likelihood of 

sediment production from those areas.

Road surfaces will be watered and/or rocked as needed to reduce road wear and 

minimize loss of road fines.

Temporary road drainage will be handled by outsloping the road surface so that runoff is 

not concentrated and drainage is self-maintaining.
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix E

389

BMP 2.24 – Traffic Control during Wet Periods: The objective is to reduce road surface 

disturbances and rutting of roads and to minimize sediment washing from disturbed road 

surfaces.

The Klamath WWOs guidelines will be followed.

BMP 2.26 – Obliteration or Decommissioning of Roads: The objective is to reduce sediment 

generated from temporary roads, unneeded system (classified) and temporary (unclassified) 

roads by obliterating or decommissioning them at the completion of the intended use.

This BMP applies to all temporary roads used in this project.

Temporary roads will be water-barred as needed when not in use during project 

implementation.

Temporary roads will be decommissioned (hydrologically restored) at the end of the 

Project by outsloping to return the road prism to near natural hydrologic function.

Road prisms requiring more sediment reduction would be stabilized through appropriate 

special treatment such as covering with slash.

Road take-offs would be hydrologically restored or effectively blocked to vehicle access.

As a part of this project all or portions the following roads will be decommissioned; 

17N02, 17N02A, 17N04, 17N28, 18N43, and 18N43A.

BMP 5.6 – Soil Moisture Limitations for Mechanical Equipment Operations: The objective 

is to prevent soil compaction, rutting, and gulling with resultant sediment production and 

turbidity.

Ground-based equipment operation will only be permitted when soil moisture is 

determined to be dry enough to avoid negative soil and watershed impacts. Site-specific 

direction will be given by the TSA in conjunction with an earth scientist using the Wet 

Weather Operating Standards as guidance. Refer to BMP 1.17.

Low ground-pressure equipment (feller bunchers) may operate off skid trails when the 

soil moisture is dry enough to avoid negative soil and watershed impacts. Site-specific 

direction will be at the discretion of the TSA with advice from an earth scientist using 

the Wet Weather Operating Standards as guidance.

BMP 5.7 – Pesticide Use Planning Process: The objective is to introduce water quality and 

hydrologic considerations into the pesticide use planning process.

Application of Sporax® (borax) to fresh cut true fir stumps will be done in compliance 

with all label directions. 

BMP 5.8 – Pesticide Application According to Label Directions and Applicable Legal 

Requirements: The objective is to avoid water contamination by complying with all label 

instructions and restrictions for use.

Application of Sporax® (borax) to fresh cut true fir stumps will be done in compliance 

with all label directions. 
Appendix E Two Bit Vegetation Management Draft Environmental Impact Statement

390

No effluent containing boron products will be discharged into any waterbody. No such 

effluent may be discharged into sewer systems without previously notifying the local 

sewage treatment plant authority.

BMP 5.9 – Pesticide Application Monitoring and Evaluation: The objectives are: 1) to 

determine whether pesticides have been applied safely, restricted to intended target areas, and 

have not resulted in unexpected non-target effects; 2) to document and provide early warning of 

possible hazardous conditions resulting from possible contamination of water or other non-target 

areas by pesticides; and 3) to determine the extent, severity, and possible duration of any 

potential hazard that might exist.

The need for a monitoring and evaluation plan was considered as part of the 

environmental and analysis process. Given the risk level once BMP 5.8, 5.10 and 5.11 

are implemented; only compliance monitoring will be required.

Contract inspectors will be on-site during pesticide applications and will monitor the 

work for contract specification and label requirement compliance.

BMP 5.10 – Pesticide Spill Contingency Planning: The objective is to reduce contamination of 

water by accidental pesticide spills.

A Project Safety Plan will be prepared that includes pesticide spill contingency measures 

as part of the contract requirements.

BMP 5.11 – Cleaning and Disposal of Pesticide Containers and Equipment: The objective is 

to prevent water contamination resulting from cleaning or disposal of pesticide containers.

Cleaning, storage, and disposal of containers will be done in accordance with Federal, 

State, and local laws, regulations and directives. 

BMP 6.1 – Fire and Fuel Management Activities: The objective is to reduce public and private 

losses and environmental impacts which result from wildfires and/or subsequent flooding and 

erosion by reducing or managing the frequency, intensity and extent of wildfire.

Project fuels staff and fire suppression staff determined acceptable levels of slash to 

retain on the site following harvest activities, and identified areas and methods where 

slash and/or existing fuels need to be reduced to prevent unacceptable fire risk.

On-going fire management work maintains fire access plans and restricts public 

activities, such as woodcutting, on days when fire weather predictions indicate 

significant risk from such activities in the Project Area. Project activities, such as 

chainsaw use, can also be restricted during periods of high fire danger.

BMP 6.2 – Consideration of Water Quality in Formulating Fire Prescriptions: The objective 

is to provide for water quality while achieving management objectives through the use of 

prescribed fire.
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix E

391

Different fuel reduction treatments are prescribed to protect soil and water resources.

Review project design features for harvest unit and underburn unit specific 

recommendations and mitigations.

All burning will be done under an approved Burn Plan that specifies a burn prescription 

for each area. These prescriptions will account for fuel loading, fuel moisture, soil 

moisture, slope, aspect, etc., and will result in the desired quantity of fuel consumed for 

each prescribed burn. A fuel management specialist, who may utilize recommendations 

from a soil or earth scientist, will prepare prescriptions.

Hand and landing piles will be burned under safe conditions to prevent fire spread or 

excessive scorching of surrounding vegetation.

Underburning will be accomplished in conditions that allow safe burning. Fire crews, 

equipped to control fire spread, will monitor underburning.

BMP 6.3 – Protection of Water Quality from Prescribed Burning Effects: The objective is to 

maintain soil productivity, minimize erosion, and minimize ash, sediment, nutrients, and debris 

from entering water bodies.

Retain soil cover amounts recommended by Project soil scientist (Walters 2010) to meet 

Forest plan standards. Burn plan prescriptions are designed to retain desired levels of 

soil cover.

Maintain the functionality of riparian vegetation and stream buffer RRs.

Use of prescribed fire in stream buffer RRs will predominately result in low intensity 

burns except for burning small (six by six foot) isolated hand piles where higher 

intensities occur when piled slash is consumed. Pile burning will not occur within 25 

feet of any stream course.

Low-intensity prescribed fire should be allowed to back down into stream buffer RRs.

Prescribed fire will be ignited in stream buffer RRs only in situations where necessary to 

minimize the potential for burning material to roll down into a RR that could start a 

moderate or high intensity burn. Prescribed fire backed into or ignited within stream 

buffer RR will be controlled to maintain a low-intensity burn.

If it is determined necessary for a handline to be constructed as a control point within a 

stream buffer RR, it should be constructed no closer than 30 feet to a watercourse.

Handline construction in stream buffer RRs shall be avoided where practical.

Prescribed fire backed into wet meadows will be controlled to maintain a low-intensity 

burn.

BMP 7.8 – Cumulative Off-Site Watershed Effects: The objective is to protect the identified 

beneficial uses of water from the combined effects of multiple management activities which 

individually may not create unacceptable effects but collectively may result in degraded water 

quality conditions.

A cumulative watershed effects analysis was completed for the Project, as summarized 

in the Water section of Chapter 3 and in appendix F. The Project does slightly increase 

modeled CWE risk ratios in the analyzed 7th –field watersheds but no watersheds are at 

or over threshold in the model due to Project implementation. 
Appendix E Two Bit Vegetation Management Draft Environmental Impact Statement

392
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix F

393

Appendix F – Cumulative Watershed Effects 

Modeling Summary

Introduction

Cumulative watershed effects (CWE) are analyzed on the Klamath National Forest using three 

models. The USLE model predicts sediment volume delivered to stream courses by surface soil 

erosion and the GEO model predicts sediment volume delivered to stream courses by masswasting (e.g. landslides). The third model, equivalent roaded area (ERA), is a Forest Service 

Region 5 standard that scales vegetative disturbances as being equivalent to a road. These 

models are briefly discussed in Chapter 3 under in the water, soils and geology sections. 

Potential increases in sedimentation were evaluated through the degree of change in CWEmodeled risk ratios for accelerated surface soil erosion (USLE model) and mass-wasting (GEO 

model). Altered channel geomorphology was evaluated by the degree of peak flow increase 

which can be indirectly measured using the ERA model. Risk ratios greater than or equal to 1.00 

indicates a threshold of concern.

Klamath National Forest GIS layers of roads, past vegetative disturbances (wildfires and 

management), and the actions proposed under Alternatives 2, 3 and 4 for the Two Bit Project 

were used in these three models. The models assessed the cumulative watershed effects in the 

twelve 7th field watersheds within four 6th field watersheds within the Indian Creek 5th field 

watershed. Proposed treatment units occur within nine of the twelve 7th field watersheds: Indian 

Creek Headwaters, West Branch Indian Creek, Indian/Mill Creek, Coon-Wagner, Little SF 

Indian Creek, Cole-Clauson, East Fork Indian Creek, Luther-Ikes and Indian/Doolittle Creek. All 

twelve 7th fields were analyzed since they represent the combined cumulative watershed effects 

in the Indian Creek watershed as a whole. Detailed results of this analysis are contained in the 

Two Bit Hydrology Report (Bousfield 2010). Table 72 below displays USLE, GEO and ERA 

modeling results for the existing condition compared to conditions after implementation of 

Alternatives 2, 3 and 4. Table 73 below displays the risk ratios from the USLE, GEO and ERA 

modeling results for the existing condition compared to conditions after implementation of 

Alternatives 2, 3 and 4. 

Existing conditions in the Indian Creek Watershed were modeled based on past and recent 

projects, some of which are not yet completed on the ground, but for which NEPA decisions 

have been signed. Past and in-progress/current actions include timber harvest, wildfires, fuels 

treatments, roads and mining activities and are summarized in Table 16 in Chapter 3. No other 

future actions are planned for the project area. 

While models are useful tools in determining the potential for effects, results are not 

absolute; in other words modeling results are most useful as a relative comparison between 

alternatives and should not be considered absolute predictions of sediment generated or of risk 
Appendix F Two Bit Vegetation Management Draft Environmental Impact Statement

394

ratios; results should be used with caution and as a general comparison between the existing 

condition and the predicted impacts of Alternatives 2, 3 and 4.

Summary of Findings

Existing conditions, with past and present/current actions

Prior to modeling the results of proposed actions for Alternatives 2, 3 and 4, existing conditions 

(all past actions plus all current/in-progress actions) in the twelve 7th field watersheds were 

modeled (Tables 72 and 73). Existing conditions for 7th field watersheds in the project area based 

on modeling results showed: 

Perkins-Happy Camp 7th field watershed was over threshold for surface soil erosion 

(USLE model value 1.36) 

None were over the threshold of concern for mass-wasting (GEO model)

None were over the threshold of concern for ERA

Existing condition modeling also showed that none of the 6th field watersheds or the Indian 

Creek 5th field watershed was over the threshold of concern for any of the three models.

Alternatives 

After the inclusion of actions proposed for Alternatives 2, 3 and 4, the models indicated (Tables 

72 and 73) that of the twelve 7th field watersheds: 

None exceeded or further exceeded the threshold of concern for surface soil erosion 

(USLE)

None exceeded the threshold of concern for mass-wasting (GEO)

None exceeded the threshold of concern for ERA

Modeling proposed actions under Alternatives 2, 3 and 4 combined with existing conditions 

and all past/current actions also showed that none of the 6th field watersheds or the Indian Creek 

5th field watershed exceeded the threshold of concern for any of the three models. Alternatives 2, 

3 and 4 would all result in some increases in sediment delivery to streams and in equivalent 

roaded acres (Table 72) but these changes would be small and would all be below thresholds of 

concern, meaning that implementation of any of the three action alternatives would add little to 

cumulative watershed effects within Indian Creek.
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix F

395

Table 74. Modeled sediment delivery and equivalent roaded acres for the existing condition (Alternative 1) and Alternatives 2, 3 and 4

Watershed

Model

USLE – sediment delivery in cubic 

yards per year

GEO – sediment delivery in cubic yards 

per decade

ERA – acres

Existing

Condition Alt 2 Alt 3 Alt 4 ExistingCondition Alt 2 Alt 3 Alt 4 Existing Condition Alt 2 Alt 3 Alt 4

7th Field Watershed

Indian Creek 

Headwaters 472.4 563.1 560.4 508.1 44,867 45,798 45,566 45,798 286.9 375.0 365.8 378.7

West Branch 

Indian Creek 486.7 544.3 541.9 491.6 31,285 31,390 31,221 31,390 188.1 226.4 220.5 232.3

Indian/Mill 

Creek 278.0 290.4 288.8 287.8 22,565 23,081 22,968 23,081 158.3 178.9 173.1 185.1

Coon-Wagner 600.1 697.7 692.4 624.2 46,438 47,291 47,049 47,291 267.4 336.0 323.0 322.7

Upper South 

Fork Indian 

Creek

444.3 444.3 444.3 444.3 34,921 34,921 34,921 34,921 118.9 118.9 118.9 118.9

Twin Valley 

Creek 549.8 549.8 549.8 549.8 15,513 15,513 15,513 15,513 0.10 0.10 0.10 0.10

Little South 

Fork Indian 

Creek

408.9 456.4 455.8 413.5 31,661 31,879 31,846 31,879 142.1 186.0 185.2 171.8

Cole-Clauson 447.8 496.1 495.8 458.1 50,292 50,487 50,484 50,487 317.4 350.2 346.9 344.5

East Fork 

Indian Creek 600.0 602.3 602.3 601.2 51,037 51,189 51,189 51,189 266.4 270.9 270.9 271.6

Luther-Ikes 384.7 386.2 386.2 386.0 35,950 36,032 36,032 36,032 354.3 359.2 359.2 359.3

Indian/Doolittle 

Creek 532.3 566.9 564.8 556.4 52,335 51,527 51,464 51,527 266.2 293.5 291.1 289.5

Perkins-Happy 

Camp 227.1 227.1 227.1 227.1 6,100 6,100 6,100 6,100 110.0 110.0 110.0 110.0

6th – Field Watershed

Upper Indian 

Creek 1837.1 2095.6 2083.5 1911.7 145,155 147,560 146,805 147,560 900.7 1116.3 1082.4 1118.8

South Fork 1850.8 1946.6 1945.7 1865.6 132,388 132,801 132,765 132,801 578.4 655.2 651.2 635.3
Appendix F Two Bit Vegetation Management Draft Environmental Impact Statement

396

Watershed

Model

USLE – sediment delivery in cubic 

yards per year

GEO – sediment delivery in cubic yards 

per decade

ERA – acres

Existing

Condition Alt 2 Alt 3 Alt 4 ExistingCondition Alt 2 Alt 3 Alt 4 Existing Condition Alt 2 Alt 3 Alt 4

Indian Creek

East Fork 

Indian Creek

600.0 602.3 602.3 601.2 51,037 51,189 51,189 51,189 266.4 270.9 270.9 271.6

Lower Indian 

Creek 1144.2 1180.2 1178.2 1169.5 94,385 93,658 93,595 93,658 730.5 762.7 760.3 758.7

5th – Field Watershed

Indian Creek 5432.0 5842.6 5809.6 5548.1 422,964 425,207 424,354 425,207 2476.0 2805.0 2764.7 2784.4

Table 75. Cumulative watershed effects risk ratios for the existing condition and Alternatives 2, 3 and 4

Watershed

Model

USLE GEO ERA

Existing

Condition Alt 2 Alt 3 Alt 4 ExistingCondition Alt 2 Alt 3 Alt 4 Existing Condition Alt 2 Alt 3 Alt 4

7th Field Watershed

Indian Creek 

Headwaters 0.33 0.44 0.44 0.37 0.43 0.45 0.45 0.45 0.48 0.63 0.61 0.63

West Branch

Indian Creek 0.68 0.78 0.78 0.68 0.36 0.36 0.36 0.36 0.70 0.84 0.82 0.87

Indian/Mill

Creek 0.23 0.25 0.25 0.25 0.45 0.48 0.47 0.48 0.32 0.36 0.35 0.37

Coon-Wagner 0.52 0.64 0.63 0.55 0.79 0.82 0.81 0.82 0.67 0.85 0.81 0.81

Upper South

Fork Indian 

Creek

0.09 0.09 0.09 0.09 0.22 0.22 0.22 0.22 0.26 0.26 0.26 0.26

Twin Valley

Creek 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Little South 

Fork Indian 0.34 0.40 0.40 0.34 0.34 0.35 0.35 0.35 0.36 0.47 0.47 0.43
Two Bit Vegetation Management Draft Environmental Impact Statement Appendix F

397

Watershed

Model

USLE GEO ERA

Existing

Condition Alt 2 Alt 3 Alt 4 ExistingCondition Alt 2 Alt 3 Alt 4 Existing Condition Alt 2 Alt 3 Alt 4

Creek

Cole-Clauson 0.18 0.23 0.23 0.19 0.55 0.55 0.55 0.55 0.49 0.54 0.53 0.53

East Fork 

Indian Creek 0.15 0.15 0.15 0.15 0.81 0.81 0.81 0.81 0.28 0.29 0.29 0.29

Luther-Ikes 0.39 0.39 0.39 0.39 0.75 0.75 0.75 0.75 0.60 0.61 0.61 0.61

Indian/Doolittle 

Creek 0.80 0.87 0.87 0.85 0.76 0.74 0.74 0.74 0.60 0.67 0.66 0.66

Perkins-Happy 

Camp 1.36 1.36 1.36 1.36 0.54 0.54 0.54 0.54 0.59 0.59 0.59 0.59

6th – Field Watershed

Upper Indian 

Creek

0.43 0.52 0.52 0.46 0.51 0.52 0.52 0.52 0.50 0.63 0.61 0.63

South Fork 

Indian Creek

0.10 0.12 0.12 0.11 0.30 0.30 0.30 0.30 0.29 0.32 0.32 0.31

East Fork 

Indian Creek

0.15 0.15 0.15 0.15 0.81 0.81 0.81 0.81 0.28 0.29 0.29 0.29

Lower Indian 

Creek 0.67 0.69 0.69 0.69 0.74 0.73 0.73 0.73 0.59 0.61 0.61 0.61

5th – Field Watershed

Indian Creek 0.26 0.30 0.29 0.27 0.50 0.50 0.50 0.50 0.46 0.52 0.51 0.52