United States 

Department of

Agriculture

Forest 

Service

Pacific 

Southwest

Region

Final Environmental 

Impact Statement for 

Sugar Pine Adaptive 

Management Project 

Sierra National Forest, Bass Lake Ranger District 

Madera/Mariposa Counties, CA
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Final Environmental Impact Statement

Summary

SUGAR PINE ADAPTIVE MANAGEMENT PROJECT

Final Environmental Impact Statement

Madera/Mariposa Counties, California; Sierra National Forest; Bass Lake Ranger District 

Lead Agency: USDA Forest Service

Cooperating Agencies: N/A

Responsible Official: Edward Cole, Forest Supervisor 

 Sierra National Forest

1600 Tollhouse Road, Clovis, CA 93611 

For Information Contact: Mark Lemon, District Fuels Officer 

 57003 Road 225, North Fork, CA 93643

 (559) 877-2218 ext. 3110

Abstract: This document examines the environmental effects of a proposal to move towards 

meeting management goals and objectives set forth in the Sierra National Forest Land and 

Resource Management Plan (SNF LRMP; USDA-FS 1992) (as amended in January 2004). The 

purpose of the proposal is multi-faceted and has two primary purposes (1) to strategically place 

area treatments on the landscape to reduce the intensity and spread of wildfires across the 

landscape and near communities and (2) to reduce inter-tree competition to improve tree vigor 

whereby providing increased stand resiliency to drought conditions, insect, disease attack and/or

wildfire. Alternative 1 (No Action): would leave the area in its present condition. Alternative 2 

(Proposed Action): within treatment areas conifers would be thinned from below to reduce stand 

densities and ladder fuels; ladder fuels and brush/shrub patches would be masticated; prescribed 

burning, both understory and pile burning would be utilized to reduce ladder and surface fuels as 

a primary, post-thinning and/or maintenance treatment; noxious weed infestations would be 

manually treated and/or prescribed burn to reduce and/or eliminate known infestations; and site 

preparation and planting of failed conifer plantations would occur. As part of this alternative a 

SNF LRMP/Sierra Nevada Forest Plan Amendment Record of Decision (SNFPA ROD) (USDAFS 1992; 2004b) Forest Plan Amendment would amend Standard and Guideline #86 to allow 

fuels treatments and vegetation treatments designed to meet forest health objectives within 

designated Pacific fisher densite buffers within the Sugar Pine Adaptive Management Project 

boundary during the implementation phase of the project. Alternative 3 (Preferred Alternative): 

would continue to include the same treatment areas and types of treatments as in Alternative 2. 

As part of this alternative a Forest Plan Amendment would amend Standard and Guideline #86 to 

allow fuels treatments and vegetation treatments designed to meet forest health objectives within 

designated Pacific fisher densite buffers within the Sugar Pine Adaptive Management Project 

boundary during the implementation phase of the project. But within the 2008 Sierra Nevada 

Adaptive Management Project F01 female fisher designated densite buffer, treatments would be 

limited to those needed to meet fire/fuels objectives only. Alternative 4, would continue to 

include the same treatment areas and types of treatments as Alternative 2, but would not include 

the Forest Plan Amendment to Standard and Guideline #86. Because of the extent of the 

designated Pacific fisher densite buffers within the Sugar Pine Adaptive Management Project 

boundary, treatments would include only those needed to meet fire/fuels objectives and not 

include vegetation treatments designed to meet forest health objectives.
iv Sierra National Forest

Table of Contents

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

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

Document Structure .....................................................................................................1

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

Purpose and Need for Action.........................................................................................3

Proposed Action ..........................................................................................................4

Decision Framework ....................................................................................................4

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

Public Involvement ......................................................................................................6

Issues .........................................................................................................................7

Chapter 2. Alternatives, Including the Proposed Action.....................................................9

Introduction ................................................................................................................9

Alternatives Considered in Detail.................................................................................12

Alternatives Considered but Eliminated from Detailed Study ..........................................26

Comparison of Alternatives.........................................................................................28

Chapter 3. Affected Environment and Environmental Consequences...............................31

Past, Present and Reasonably Foreseeable Actions.........................................................31

Cultural Resources.....................................................................................................36

Botany: Rare plants and Noxious Weeds.......................................................................41

Geology/Soils............................................................................................................48

Lands/Special Uses....................................................................................................60

Terrestrial Wildlife.....................................................................................................62

Aquatic Wildlife and Management Indicator Species......................................................80

Terrestrial Management Indicator Species...................................................................106

Hydrology/Water Quality..........................................................................................122

Forest Vegetation/Silviculture ...................................................................................133

Fire/Fuels................................................................................................................145

Air Quality..............................................................................................................161

Engineering / Transportation .....................................................................................183

Economics ..............................................................................................................186

Short-term Uses and Long-term Productivity...............................................................189

Unavoidable Adverse Effects ....................................................................................189

Irreversible and Irretrievable Commitments of Resources .............................................189

Legal and Regulatory Compliance .............................................................................190

Chapter 4. Consultation and Coordination....................................................................197

Preparers and Contributors........................................................................................197

Distribution of the Environmental Impact Statement ....................................................198

Glossary ......................................................................................................................199

Literature Cited...........................................................................................................209

Index ...........................................................................................................................219

Appendices ..................................................................................................................221

Appendix A – Map Package for Sugar Pine Adaptive Management Project.....................221

Appendix B – Best Management Practices Associated with Sugar Pine Adaptive Management 

Project....................................................................................................................223

Appendix C – Data Tables for Sugar Pine Adaptive Management Project .......................235

Appendix D- Response to Comments .........................................................................248
Final Environmental Impact Statement

Summary

Sierra National Forest v

List of Tables and Figures

Table S-1. Major Conclusions and determinations ....................................................................... xii

Figure 1. Associated Zones and Treatments within Old Forest Linkages.................................... 22

Table 1. Summary of Relationship between Feature Types, RCA Widths, Stream Classes, SMZ 

Widths, RMA Widths, and Stream Orders (and other GIS data) .............................................. 24

Table 2. Comparison of Alternatives............................................................................................. 28

Table 3. Past, Present and Reasonably Foreseeable Actions Contributing to Cumulative Effects by 

Resources Action is likely to Effect .......................................................................................... 33

Table 4. Threatened and Sensitive Plant Species Considered ....................................................... 41

Table 5. Summary of Soil Map Units............................................................................................ 50

Table 6. Summary of Soil Transect Data ...................................................................................... 53

Table 7. Description of Disturbance Classes................................................................................. 54

Table 8. Determinations of the effects of the Sugar Pine Adaptive Management Project on 

terrestrial wildlife species analyzed in detail in the Biological Evaluation and Biological 

Assessment (BE/BA)................................................................................................................. 63

Table 9: Alternative 2 Changes to CWHR Forest Type within treatment units of the Sugar Pine 

Adaptive Management Project .................................................................................................. 66

Table 10: Alternative 3 changes to CWHR forest type within the treatment units of the Sugar Pine 

Adaptive Management Project .................................................................................................. 78

Table 11: Alternative 4 changes to CWHR forest type within the treatment areas of the Sugar 

Pine Adaptive Management Project. ......................................................................................... 79

Table 12. Watershed Summaries by Stream Classification........................................................... 80

Table 13. Summary of Subwatershed Conditions......................................................................... 82

Table 14. Perennial Streams; Resident Trout Occupancy, Maximum 15-Minute Water 

Temperatures, Percent Stream Shading, and Indices for Benthic Macroinvertebrates ............. 83

Table 15. Woody Debris Data ....................................................................................................... 83

Table 16. Summary of Potential Habitat within Project Area Subwatersheds (Potential Acres 

Includes Marginal Acres).......................................................................................................... 84

Figure 2. 2007 average summer water temperatures for project area streams .............................. 84

Table 17. Sugar Pine Adaptive Management Activities Proposed under Alternative 1 by 

Subwatershed............................................................................................................................. 88

Table 18. Summary from analyses for aquatic Threatened (T), Endangered (E), Sensitive (S) and 

Management Indicator Species (MIS) for effects from Alternative 1....................................... 91

Table 19. Activities Proposed within Project Area Subwatersheds under Alternative 2 .............. 92

Table 20. Overlap of Proposed Treatment Areas and Potential Habitat for species ..................... 92

Table 21. Activities Proposed within Project Area Subwatersheds under Alternative 3 ............ 100

Table 22. Activities Proposed within Project Area Subwatersheds under Alternative 4 ............ 103

Table 23. Summary from Analyses for Aquatic Threatened, Endangered, Sensitive (BA/BE), and 

Management Indicator Species for Effects from Project Alternatives.................................... 105

Table 24. Subwatershed Summaries............................................................................................ 122

Table 25. Activities Proposed under Alternative 1 – No Action Alternative.............................. 124

Table 26. Activities Proposed within Project Area Subwatersheds under Alternative 2 ............. 126

Table 27. Activities Proposed within Project Area Subwatersheds under Alternative 3 ............ 129

Table 28. Activities Proposed within Project Area Subwatersheds under Alternative 4 ............. 131

Table 29. Fire History within the Project Boundary ................................................................... 146

Table 30. Fire History Outside of the Project Boundary (Generally South of Sugar Pine)......... 146

Table 31. Fire History within a 4-mile radius of Sugar Pine....................................................... 147

Table 32. Indicators for IFSL Fuel Models of Brush Covered Areas ......................................... 150

Table 33. Indicators for IFSL Fuel Models in Timber Covered Areas ....................................... 151

Table 34. Principles of Fire Resistant Forests............................................................................. 154
vi

Table 35. Indicators for IFSL Fuel Models of Brush and Timber Covered Areas...................... 156

Table 36. Federal de minimus Threshold Levels for Criteria Pollutants based on Air Basin 

attainment status...................................................................................................................... 164

Table 37. Class I airsheds near the Sugar Pine Adaptive Management Project area. ................ 166

Table 38. Sensitive receptors identified within 10 miles of the Sugar Pine Adaptive Management 

Project...................................................................................................................................... 169

Table 39. Statewide Emission Inventory 2002 for Natural Sources-Wildfire............................. 172

Table 40. Potential emissions if a wildfire were to burn within the entire Sugar Pine Adaptive 

Management Project boundary................................................................................................ 172

Table 41. Total tons of emissions for estimated Prescribed Pile Burning and Prescribed Pile 

Burning estimated per year...................................................................................................... 174

Table 42. Total tons of emissions for estimated Prescribed Understory burning and Prescribed 

Understory burning estimated per year. .................................................................................. 175

Table 43. California Air Resources Board 2008 Estimated Annual Average Daily Emissions for 

Forest Management-Burning and Disposal for the San Joaquin Valley Air Basin and annual 

average for the estimated 200 days of prescribed burning in Alternative 2. ........................... 175

Table 44. Total tons of emissions for mechanical treatments and road maintenancereconstruction activities for the completion of operations in Alternative 2. ........................... 176

Table 45. California Air Resources Board 2008 Estimated Annual Average Daily Emissions for 

On-Road Motor Vehicles for the San Joaquin Valley Air Basin............................................. 177

Table 46. California Air Resources Board 2008 Estimated Annual Average Daily Emissions of 

Heavy Duty Diesel Trucks for the San Joaquin Valley Air Basin and annual average for the 

estimated 260 days of mechanical operations in Alternative 2 . ............................................. 178

Table 47. Other Treatments Cost – All Action Alternatives....................................................... 187

Table 48. Sugar Pine Adaptive Management Project Appraisal Cost Summary ........................ 188

Table 49. Sugar Pine Plot Data Summary, Existing and Proposed Action (Alternative 2) 

Conditions ............................................................................................................................... 237

Table 50. Sugar Pine Plot Data Summary, Existing and Alternative 3 ....................................... 239

Table 51. Sugar Pine Plot Data Summary, Existing and Alternative 4 ....................................... 241

Table 52. Sugar Pine CWHR Data, Main Project Area; Present Compared to Proposed Action 

(Alternative 2) ......................................................................................................................... 244

Table 53. Sugar Pine CWHR Data, Hydrology Study Area; Present Compared to Proposed Action 

(Alternative 2) ......................................................................................................................... 246
Sierra National Forest vii

Summary __________________________________

The Sugar Pine Adaptive Management Project Environmental Impact Statement analyzes the 

direct, indirect and cumulative effects associated with the proposal to move towards meeting 

management goals and objectives set forth in the Sierra National Forest Land and Resource 

Management Plan as amended in January 2004 by the Sierra Nevada Forest Plan Amendment 

Record of Decision (SNFPA ROD (USDA-FS 2004b)). 

SNFPA ROD (USDA-FS 2004b) recommends that projects are to be developed and planned

utilizing an ecosystem management approach that compares the current condition of key 

ecosystem components against desired conditions set by the SNFPA ROD (USDA-FS 2004b). 

Where these conditions significantly depart from the desired condition or have the potential for 

loss, opportunities for management actions to address this departure are to be developed to move 

the ecosystem towards the desired condition. This is to be documented in a landscape analysis. 

The Sierra National Forest, Bass Lake Ranger District completed the Fresno River Landscape 

Analysis in July, 2005. Within this landscape analysis, of particular concern and where 

opportunities existed to move it closer to the desired condition was the State Highway 41 

Corridor with its high concentration of human habitation and activities, the Nelder Grove

Historical Area of Giant Sequoias forests, declining health of forest from overcrowding and 

habitat for species-at-risk (such as California Spotted Owl, goshawk and Pacific fisher). Sugar 

Pine is one of the communities within the State Highway 41 corridor and was used as the first 

point of reference in developing and planning the Sugar Pine Adaptive Management Project.

A variety of wildlife species are highly dependent on conditions provided by functioning 

ecosystems (Pacific fisher, California spotted owl and Northern goshawk, to name a few) and are 

susceptible to loss of viability if the degree of change to their habitat and the ecosystem in which 

they are dependent on is improperly balanced. There is uncertainty (due to gaps in information) 

surrounding what is the proper balance of change that can occur in these species habitat, where 

forest functionality and sustainability can be improved and where human habitation‘s 

vulnerability to wildfire can be reduced. The Sugar Pine Adaptive Management Project Area 

provides habitat for a variety of species (botanical, terrestrial and aquatic species). As part of the 

SNFPA ROD (USDA-FS 2004b), an adaptive management and monitoring strategy designed to 

address high priority, key questions that relate to the uncertainties associated with management 

activities was to be initiated. In 2006, Region 5 (Pacific Southwest Region) of the Forest Service, 

as well as other Federal and State Agencies, entered into an agreement with the University of 

California whereby the university would act as a neutral third party to study the effects of 

management actions associated with implementation of the SNFPA ROD (USDA-FS 2004b)

management direction. This study, known as Sierra Nevada Adaptive Management Project 

(SNAMP) is designed around cause (management actions directed through Standards and 

Guidelines), and effect monitoring (of those management actions) is researched to gain a better 

understanding of how components, structures and processes in four key areas respond to 

management activities, and how ecosystem components interrelate. The four key areas being 

studied include: wildlife (specifically Pacific fisher in the Sugar Pine area and California spotted 

owl in the Tahoe National Forest), fire and forest health, water quality and quantity, and public 

participation. During the seven year study, SNAMP scientist are collecting pre-treatment data 

(approximately 3 years), conducting implementation monitoring (approximately 2 years) and 

collecting post treatment data (approximately 2 years). If an alternative where management 

actions are to take place is chosen, the timeframe for conducting the SNAMP study requires all 

management actions (including post treatment), to be conducted within an approximately 2 year 

implementation period. Because of this timeframe, action alternatives are to propose treatment 

types that minimize the amount of treatment needed to meet fire/fuels and forest health objectives

including post activity treatments. The information collected will be assembled, reviewed, and 
Final Environmental Impact Statement

Summary

viii Sierra National Forest

integrated into a feedback loop that can inform subsequent management decisions. The Sugar 

Pine Adaptive Management Project is one of two projects in the region where these key areas and 

related management questions are to be studied.

The purpose of the Sugar Pine Adaptive Management Project is multi-faceted and has two 

primary purposes: (1) to strategically place area treatments (known in the SNFPA ROD (USDAFS 2004b) as SPLATs) on the landscape to reduce the intensity and spread of wildfires across the 

landscape and near communities and (2) to reduce inter-tree competition (stand density) to 

improve tree vigor and tree growth whereby providing increased stand resiliency to drought 

conditions, insect and disease attack and wildfire effects.

The Sugar Pine Adaptive Management Project consists of treatment areas designed where 

treatments are proposed to meet this purpose and need. The treatment areas are mapped based on 

either their geographic location (such as the pattern of area treatments known as Strategically 

Placed Landscape Area Treatments (SPLATs) and Defensible Fuel Profile Zones (DFPZ)], where 

forest conditions/surface fuel conditions are furthest from desired conditions and/or conditions 

warrant maintenance (such as in the RX treatment areas and fuelbreak) to maintain the desired 

condition. These treatment areas remain the same for all action alternatives analyzed. 

Alternatives to the Proposed Action were developed from issues brought forth during the public 

scoping period, field trips to the project area and SNAMP Integrated Team meetings. These 

issues focused on meeting the purpose and need for the project, the extent and intensity of 

management actions allowed by the SNFPA ROD (USDA-FS 2004b) and the ability to maintain 

adequate habitat elements for species-at-risk. The habitat elements include, but are not limited to,

high canopy cover retention (not below 50%, with preference of > 60%) especially in larger 

diameter trees (>20‖ diameter), snag and down-woody material retention, understory diversity 

and available travel corridors. Treatments within Alternative 2 (Proposed Action) were 

developed based on these issues. In 2008, during pre-treatment data collection, SNAMP scientist 

located densites (birthing and maternal) for one female Pacific fisher (known as F01) within the 

Sugar Pine Adaptive Management Project area. Subsequently, as directed by the SNFPA ROD 

(USDA-FS 2004b), a densite buffer of the highest quality habitat was designated around these 

densites (SNFPA ROD page 39) (USDA-FS 2004b). No Pacific fisher densites had been located 

on the Sierra National Forest prior to this. With the designation of a densite buffer, came the

need to implement a Standard and Guideline from the SNFPA ROD (USDA-FS 2004b) (S&G 

#86), which allows the mechanical treatment of ladder and surface fuels within a Pacific fisher 

densite buffer to meet fire/fuels objectives for the wildland urban intermix zone, but no 

vegetation treatments to meet forest health objectives are allowed. Alternative 3 was developed 

based on this information in conjunction with the issue brought forth during public scoping. In 

2009, during pre-treatment data collection, SNAMP scientist located an additional (3) female 

Pacific fisher densites (birthing and maternal) as well as the densites for female F01, both within 

and outside of the Sugar Pine Adaptive Management Project area. As directed by the SNFPA 

ROD (USDA-FS 2004b), densite buffers were designated around these densites. Alternative 4 

was developed prior to this information, but now is supported by this information for analyzing in 

detail such an alternative. 

As stated above, SNAMP is studying the effects on four key areas to management actions as 

directed by the SNFPA ROD (USDA-FS 2004b). In order to provide the decision maker with the 

full range of management actions available through the implementation of the SNFPA ROD 

(USDA-FS 2004b), all Pacific fisher densite buffer areas are designated in each Alternative, but 

with Alternatives 2 and 3 a non-significant forest plan amendment to SNFPA ROD (USDA-FS 

2004b) Standard and Guideline #86 is included. The Standard and Guideline #86 would be 
Final Environmental Impact Statement

Summary

Sierra National Forest ix

amended in these two alternatives to read as follows. The italicized sentence is the amended 

portion of the Standard and Guideline #86, the remainder of the Standard and Guideline is 

retained as originally written in the SNFPA ROD (USDA-FS 2004b). ―Avoid fuel treatments in 

fisher densite buffers to the extent possible. If areas within densite buffers must be treated to 

achieve fuels objectives of the urban intermix zone, limit treatments to mechanical clearing of 

fuels. Treat ladder and surface fuels to achieve fuels objectives. Use piling or mastication to 

treat surface fuels during initial treatment. Burning of piled debris is allowed. Prescribed fire 

may be used to treat fuels if no other reasonable alternative exists. Vegetation treatments as 

designed to meet Forest Health objectives and defined in Chapter 2, Alternatives Considered in 

Detail of the Sugar Pine Adaptive Management Project FEIS, may occur in designated Pacific 

fisher densite buffer(s) within the Sugar Pine Adaptive Management Project boundary during the 

implementation phase of this project.‖ Chapter 2-Introduction ―Relationship of Alternatives to 

Existing Management Plans‖ (page 9), provides the measures of significance as well as the scope 

and intent of this Forest Plan Amendment. Chapter 2-Alternatives Considered in Detail (pages 

12-16) describes in further detail under Alternatives 2 and 3, the implementation of this Forest 

Plan Amendment. The following are the alternatives being analyzed in detail in this document: 

 Alternative 1 – No Action. Under the No Action alternative, current management plans 

would continue to guide activities in the project area. This includes all ongoing activities 

with existing decisions or permits that would not be changed if this alternative were 

selected including: underburning, plantation maintenance, cattle grazing, recreation, and 

recreation residences.

 Alternative 2 – Proposed Action. Under Alternative 2, treatment areas would be treated 

to meet both fire/fuels (treatments to reduce surface and ladder fuels) and forest health 

objectives (basal area treatments to reduce stand density) to such a level as to improve 

growth and vigor of remaining trees. Treatments included in this alternative are: thinning

from below, either pre-commercially, commercially, biomassing and/or mastication the 

lower and mid- level canopy of conifer stands to reduce stand densities and ladder fuels; 

mastication of ladder fuels and brush/shrub patches; prescribed burning, both understory 

and pile burning as a primary, post-thinning and/or maintenance treatment to reduce 

ladder and surface fuels; manually treat and/or prescribed burn noxious weed infestations 

to reduce and/or eliminate known infestations; and site preparation and planting of failed 

conifer plantations. A non-significant Forest Plan amendment to Standard and Guideline 

#86 would allow fire/fuels (reduction of ladder and surface fuels) and vegetation 

treatments (stand density treatments to meet forest health objectives) within designated 

Pacific fisher densite buffers. 

 Alternative 3 – Lower and Limited Mid-level Canopy Treatments within a Den Site 

Buffer. Under Alternative 3, the 795- acre 2008 Pacific fisher densite buffer area 

designated for SNAMP female fisher F01 (as directed by the SNFPA ROD (USDA-FS 

2004b)) would have mechanical treatment types similar to Alternative 2, but the intensity 

would be limited to that needed to meet fire/fuels objectives (reduction of surface and 

ladder fuels) in the lower-level and limited mid-level canopy. A non-significant Forest 

Plan amendment to Standard and Guideline #86 would allow fire/fuels (reduction of 

ladder and surface fuels) and vegetation treatments (stand density treatments to meet 

forest health objectives) within the remaining designated Pacific fisher densite buffers. 

These treatments would include: thinning from below, either pre-commercially, 

commercially, biomassing and/or mastication the lower and mid- level canopy of conifer
Final Environmental Impact Statement

Summary

x Sierra National Forest

stands to reduce stand densities and ladder fuels; mastication of ladder fuels and 

brush/shrub patches; prescribed burning, both understory and pile burning as a primary, 

post-thinning and/or maintenance treatment to reduce ladder and surface fuels; manually 

treat and/or prescribed burn noxious weed infestations to reduce and/or eliminate known 

infestations; and site preparation and planting of failed conifer plantations. 

 Alternative 4 – Lower and Limited Mid-level Canopy Treatments, All Treatment 

Areas. Under Alternative 4, mechanical treatment types would be similar to Alternative 

2, but intensity would be limited to that needed to meet fire/fuels objectives (reduction of 

surface and ladder fuels) in the lower-level and limited mid-level canopy in designated

Pacific fisher densite buffers as well as areas outside of the densite buffers. This 

Alternative would implement all Standards and Guidelines, as written, from the SNFPA 

ROD (USDA-FS 2004b) and would not include the non-significant Forest Plan 

Amendment.

In developing these alternatives and to give resource specialist information required to 

complete their analysis of effects the following were used to frame the alternatives as well as 

have common terminology:

 All alternatives utilize Standards and Guidelines from SNFPA ROD (USDA-FS 2004b)

designing treatments that will meet the purpose and need of the project. Alternatives 

used to meet both fire/fuels and forest health objectives will thin from below, as current 

stand conditions dictate, trees less than 30‖ in diameter. A commercial market value is 

typically placed on a wood by-product that is greater than 10‖ in diameter (considered 

saw logs). Conifers thinned during the implementation of treatments that are between 

10‖ in diameter up to 30‖ in diameter would be considered and termed ―commercially 

thinned‖. Conifers thinned under 10‖ in diameter and larger than 4‖ in diameter can have 

a market value if operations chip the wood by-products and transport the chip to a facility 

for utilization. This is typically called biomassing. If not biomassed, this size material 

and less, is considered to have a non-commercial value and would be termed precommercial or non-merchantable. If needed to meet the purpose and need, precommercial sized material would be treated utilizing hand thinning, piling and burning or 

would be thinned using a masticator.

 The timeframes associated with the SNAMP study require that all treatments (with the 

exception of prescribed understory burning [RX treatment areas and maintenance 

burning]) proposed in the action alternatives be completed within an approximately 2-

year period once implementation has begun. This includes any post treatments of noncommercial conifers and surface fuels needed to meet fire/fuels objectives. Because of 

this timeframe, as well as the preference to use mechanical treatment of surface and 

ladder fuels in designated Pacific fisher den site buffers versus prescribed fire to thin 

ladder fuels (SNFPA ROD (USDA-FS 2004b), Standard and Guideline #86) alternatives 

propose the utilization of biomass operations to remove excess conifers (defined here as 

conifers between 4‖ and 10‖ in diameter) in areas where hand thinning and/or mastication 

alone would increase surface fuels to such an extent that additional treatments, such as 

piling and burning would be needed to meet fire/fuels objectives. The assumption is that 

typical biomass operations of conifers would significantly reduce the amount of post 

treatments needed in areas where it is used, as evidenced with past use of biomass 

operations on the district.

 All action alternatives include, as part of the alternative, Design Criteria Common to All 

Action Alternatives as listed on pages 16-26. These are part of each action alternative to 
Final Environmental Impact Statement

Summary

Sierra National Forest xi

minimize the potential environmental impacts of the management activities listed under 

each alternative. In some cases the design criteria define how treatments are designed 

and are incorporated into effects analysis of resource specialist.

Major conclusions and determinations from Biological Evaluations/Assessments for each of the 

alternatives are demonstrated in the following table: 
Final Environmental Impact Statement

Summary

xii Sierra National Forest

Table S-1. Major Conclusions and determinations

Resource Area Indicator Alt 1 Alt 2 Alt 3 Alt 4

Cultural Resources

(page 36)

Degree to which prehistoric and historic 

property values are 

diminished

25 sites that have the 

potential to be affected

Direct/Indirect 

Adverse Effects could 

occur if a 

conflaguration was to 

occur especially to 

wooden components of 

sites.

Cumuluative effects 

are unlikely.

25 sites that have the 

potential to be affected

Through Sierran PA, 

All of these cultural 

resource sites and 

historic features will be 

protected through 

avoidance.

By implementing the 

Standard Protection 

Measures outlined in 

the Sierran PA, no 

historic values would 

be diminished as a 

result of implementing 

this alternative.

25 sites that have the 

potential to be affected

Through Sierran PA, 

All of these cultural 

resource sites and 

historic features will be 

protected through 

avoidance.

By implementing the 

Standard Protection 

Measures outlined in 

the Sierran PA, no 

historic values would 

be diminished as a 

result of implementing 

this alternative.

25 sites that have the 

potential to be affected

Through Sierran PA, 

All of these cultural 

resource sites and 

historic features will be 

protected through 

avoidance.

By implementing the 

Standard Protection 

Measures outlined in 

the Sierran PA, no 

historic values would 

be diminished as a 

result of implementing 

this alternative.

Botanical Biological 

Evaluation/Bio 

Assessment (page 41)

Determinations for 

botanical TES species 

(E)=Endangered; (T)=Threatened; (P)=Proposed; (C)=Candidate; (FSS)=FS Sensitive

No effect Calyptridium 

pulchellum (T)

Calyptridium 

pulchellum (T)

Calyptridium 

pulchellum (T)

Calyptridium 

pulchellum (T)

May affect but is not 

likely to adversely 

affect 

N/A N/A N/A N/A
Final Environmental Impact Statement

Summary

Sierra National Forest xiii

Resource Area Indicator Alt 1 Alt 2 Alt 3 Alt 4

Botanical Biological 

Evaluation/Bio 

Assessment (page 

41)

May affect individuals, 

but is not likely to 

result in a trend toward 

Federal listing or loss 

of viability

Epilobium howellii

(FSS)

Peltigera hydrothyria

(FSS)

Hulsea brevifolia (FSS)

Cypripedium montanum

(FSS)

Epilobium howellii

(FSS)

Peltigera hydrothyria

(FSS)

Hulsea brevifolia

(FSS)

Cypripedium 

montanum (FSS)

Epilobium howellii

(FSS)

Peltigera hydrothyria

(FSS)

Hulsea brevifolia

(FSS)

Cypripedium 

montanum (FSS)

Epilobium howellii

(FSS)

Peltigera hydrothyria

(FSS)

Hulsea brevifolia

(FSS)

Cypripedium 

montanum (FSS)

Noxious Weeds

(page 41)

Potential for Noxious 

Weed Spread

Increased risk of spread 

if wildfire was to occur 

in the area and fireline 

equipment does not 

follow Noxious Weed 

Prevention Practices.

Low risk of spread 

through use of design 

criteria for prevention 

of spread.

Low risk of spread 

through use of design 

criteria for prevention 

of spread.

Low risk of spread 

through use of design 

criteria for prevention 

of spread.

Geology/Soils/ (page 

48)

Potential for reduction 

in Soil porosity due to 

compaction

Compacted soils (in 

6.71% of the project 

area) will continue to 

recover over time with 

no additional 

disturbance. 

Design Crieria and 

implementation of 

Best Management 

Practices will 

minimize detrimental 

compaction of soils.

Design Crieria and 

implementation of 

Best Management 

Practices will 

minimize detrimental 

compaction of soils.

Design Crieria and 

implementation of 

Best Management 

Practices will 

minimize detrimental 

compaction of soils.

Reduction of Soil 

Cover/Large woody 

debris (LWD)/Lost 

surface soil

Currently exceeds 

Regional Standards, but 

wildifire could 

significantly affect soil 

productivity through 

loss of cover, LWD 

causing erosion and 

hydrophobic soil 

conditions 

Some Reduction in 

soil cover and LWD

from treatments, but 

through Design 

Criteria and Best 

Management Practices 

levels will continue to 

meet and/or exceed 

Regional Standards.

Some Reduction in 

soil cover and LWD

from treatments, but 

through Design 

Criteria and Best 

Management Practices 

levels will continue to 

meet and/or exceed 

Regional Standards.

Some Reduction in 

soil cover and LWD

from treatments, but 

through Design 

Criteria and Best 

Management Practices 

levels will continue to 

meet and/or exceed 

Regional Standards.
Final Environmental Impact Statement

Summary

xiv Sierra National Forest

Resource Area Indicator Alt 1 Alt 2 Alt 3 Alt 4

Lands/Special Uses

(page 60)

Effects to Special Uses 

Permitted in Project 

Area.

Potential loss of 

permittee improvements 

and loss of revue if 

wildfire and/or loss of 

forest stands from 

drought, insect and 

disease was to occur in 

the area 

With implementation

of Design Criteria 

minimal to no effect

on permitted 

improvements or

operations

With implementation

of Design Criteria 

minimal to no effect

on permitted 

improvements or 

operations

With implementation

of Design Criteria 

minimal to no effect

on permitted 

improvements or 

operations

Terrestrial Wildlife 

Bio Eval/Assessment

(page 62)

*Listed are species 

that do not have 

habitat within or 

adacent to the project 

area, nor are directly, 

indirectly or 

cumulatively effected 

by this project 

therefore the project 

will have no effect on 

them:

Democerus 

californicus (T )

Hailealetus 

leucocephalus ( FSS )

Gulo gulo (FSS )

Vulpes vulpes necator

(FSS)

Empidonax trailli

(FSS)

Determination for

Terrestrial Wildlife

TES Species 

(E)=Endangered; (T)=Threatened; (P)=Proposed; (C)=Candidate; (FSS)=FS Sensitive

No effect Townsend‘s big-eared 

bat ( FSS)

Western red bat ( FSS)

Townsend‘s big-eared 

bat ( FSS)

Western red bat (FSS)

Townsend‘s big-eared 

bat ( FSS)

Western red bat (FSS)

Townsend‘s big-eared 

bat ( FSS)

Western red bat (FSS)

May affect individuals, 

but is not likely to 

result in a trend toward 

Federal listing or loss 

of viability 

California spotted owl 

(FSS)

N. Goshawk (FSS)

Great gray owl (FSS) 

American Marten 

(FSS) 

Pacific Fisher (FSS/C) 

Pallid bat (FSS) 

California spotted owl 

(FSS)

N. Goshawk (FSS)

Great gray owl (FSS) 

American Marten ( ) 

Pacific Fisher ( ) 

Pallid bat ( )

California spotted owl 

(FSS)

N. Goshawk (FSS)

Great gray owl ( ) 

American Marten ( ) 

Pacific Fisher ( ) 

Pallid bat ( )

California spotted owl 

(FSS)

N. Goshawk (FSS)

Great gray owl ( ) 

American Marten ( ) 

Pacific Fisher ( ) 

Pallid bat ( )
Final Environmental Impact Statement

Summary

Sierra National Forest xv

Resource Area Indicator Alt 1 Alt 2 Alt 3 Alt 4

Aquatic Wildlife Bio 

Eval/Assessment

(page 80)

*Listed are species 

that do not have 

habitat within or 

adacent to the project 

area, nor are directly, 

indirectly or 

cumulatively effected 

by this project 

therefore the project 

will have no effect on 

them:

Central Valley 

Steelhead (T)

Delta smelt (T)

Hardhead (FSS)

Limestone 

Salamander (FSS)

Relictual slender 

salamander (FSS)

Determination for

Aquatic Wildlife TES 

Species (E)=Endangered; (T)=Threatened; (P)=Proposed; (C)=Candidate; (FSS)=FS Sensitive

No effect California Red Legged 

Frog (T)

Foothill YellowLegged Frog (FSS)

Western Pond 

Turtle(FSS)

Moutain Yellow 

Legged Frog (C/FSS)

Yosemite Toad

(C/FSS)

California Red 

Legged Frog (T)

Yosemite Toad

(C/FSS)

California Red Legged 

Frog (T)

Yosemite Toad

(C/FSS)

California Red Legged 

Frog (T)

Yosemite Toad (C/FSS)

May affect individuals, 

but is not likely to 

result in a trend toward 

Federal listing or loss 

of viability 

N/A Foothill YellowLegged Frog (FSS)

Western Pond 

Turtle(FSS)

Moutain Yellow 

Legged Frog (C/FSS)

Foothill YellowLegged Frog (FSS)

Western Pond 

Turtle(FSS)

Moutain Yellow 

Legged Frog (C/FSS)

Foothill Yellow-Legged 

Frog (FSS)

Western Pond 

Turtle(FSS)

Moutain Yellow Legged 

Frog (C/FSS)

Aquatic 

Management 

Indicator Species

(page 80)

Habitat conditions or 

alteration and their 

effects on species

For Macroinverttebrates and 

Pacific Tree Frog

No expected direct, 

indirect or cumulative 

effects

For Macroinverttebrates and 

Pacific Tree Frog

Project Design 

Criteria expected to 

eliminate or 

minimize effects.

For Macroinverttebrates and 

Pacific Tree Frog

Project Design 

Criteria expected to 

eliminate or minimize 

effects.

For Macro-inverttebrates 

and Pacific Tree Frog

Project Design Criteria 

expected to eliminate or 

minimize effects.
Final Environmental Impact Statement

Summary

xvi Sierra National Forest

Resource Area Indicator Alt 1 Alt 2 Alt 3 Alt 4

Terrestrial 

Management 

Indicator Species

(page 106)

Habitat conditions or 

alteration and their 

effects on species

Largest effect on some 

species habitat would 

be loss or alteration 

created by uncontrolled 

wildfire.

Although there 

would be alterations 

to habitat, not any 

one particular habitat 

would be adversely 

affected or cause 

effects on species 

dependent on that 

habitat.

Although there would 

be alterations to 

habitat, not any one 

particular habitat 

would be adversely 

affected or cause 

effects on species 

dependent on that 

habitat.

Although there would be 

alterations to habitat, not 

any one particular 

habitat would be 

adversely affected or 

cause effects on species 

dependent on that 

habitat.

Hydrology (page 

122)

Cumulative Watershed 

Effects (CWE‘s)

Threshold Levels 

Reached

Initial CWE analysis 

considered one 

watershed at or near 

threshold (Lewis-Red 

Rock Creek-503.0055). 

Field investigations 

showed little potential 

for CWE in this 

subwatershed or any 

others. Affects to 

riparian habitat and 

water quality would be 

expected if a 

uncontrolled wildfire 

occurred. 

From field 

investigations and 

level of protection 

provided from Best 

Mgmt Practices, 

Stream Mgmt Zones, 

aquatic and wildlife 

Design Criteria, 

CWE‘s not expected.

From field 

investigations and 

level of protection 

provided from Best 

Mgmt Practices, 

Stream Mgmt Zones, 

aquatic and wildlife 

Design Criteria, 

CWE‘s not expected.

From field investigations 

and level of protection 

provided from Best 

Mgmt Practices, Stream 

Mgmt Zones, aquatic 

and wildlife Design 

Criteria, CWE‘s not 

expected.
Final Environmental Impact Statement

Summary

Sierra National Forest xvii

Resource Area Indicator Alt 1 Alt 2 Alt 3 Alt 4

Forest 

Vegetation/Silvi 

(page 133)

*Indicators needed to 

meet purposes and 

need to improve 

Forest Health

Meets desired condition 

for basal area for stand 

composition (Yes/No)

Meets desired condition 

for stocking levels 

(Yes/No) 

Effects of meeting or 

not meeting desired 

conditions for Forest 

Health

Would not meet desired 

conditions for density 

mgmt. nor stocking 

levels. Stands currently 

overstocked would 

continue to decline and 

be at risk from loss due 

to continued drought, 

insect/disease 

epedimics and/or from 

uncontrolled wildfire. 

In implementing 

Design Criteria, 

SNFPA ROD 

(USDA-FS 2004b)

standards and 

guidelines, the 

desired condition for 

basal area or stocking 

levels will not be 

met based on stands 

currently well over 

appropriate stocking 

levels based on 

growing site 

conditions. This 

alternative does 

provide some benefit 

by allowing for 

reduction of some 

stresses created from 

overcrowding and 

allows for some 

increased growth 

capability in 

remaining trees in 

treatment areas.

Same as Alt 2, except 

within the designated 

2008 SNAMP FO1 

Pacific Fisher Den 

Site buffer where 

treatments would 

focus on thinning of 

ladder fuels. 

Although there would 

be reductions in basal 

area and stocking 

levels, it would be 

considered 

insignificant and 

would do little to 

reduce stresses created 

by overcrowding and 

continue to leave trees 

susceptible to drought, 

insect and disease, but 

would reduce to a

moderate extent 

mortality caused from 

wildfire.

Although there would be 

reductions in basal area 

and stocking levels, it 

would be considered 

insignificant and would 

do little to reduce 

stresses created by 

overcrowding and 

continue to leave trees 

susceptible to drought, 

insect and disease, but 

would reduce to an 

moderate extent 

mortality caused from 

wildfire.
Final Environmental Impact Statement

Summary

xviii Sierra National Forest

Resource Area Indicator Alt 1 Alt 2 Alt 3 Alt 4

Forest 

Vegetation/Silvi 

(page 133)

*Indicators Related to 

Wildlife Habitat 

Issues

Estimated Average 

Canopy Cover no less 

than 50%, most of area 

> 60%

 

Average Canopy 

Cover = 69%

Average Canopy Cover

= 57%

Average Canopy 

Cover = 58%

Average Canopy Cover 

= 69%

Fire/Fuels (page 

145)

*Indicators needed to 

meet purposes and 

need to reduce 

intensity and spread 

of wildifres

After Final Treatment 

of Surface and Ladder 

Fuels:

Change in Fire 

Behavior 

Change in Fire Effects 

Surface fuels, from 

natural fuel 

accumulations would 

continue to increase 

not decrease. There 

would be no decrease 

in ladder fuels. With 

this there would 

continue to be 

potential risk for a 

wildfire with 

significant fire 

effects within and 

outside of the project 

area. 

Surface and ladder fuel 

treatments would 

effectively reduce fire 

behavior to desired 

condition levels. Fire 

effects, if a wildfire 

were to occur, would be 

significantly reduced 

by this change in fire 

intensity.

Surface and ladder fuel 

treatments would 

effectively reduce fire 

behavior to desired 

condition levels. Fire 

effects, if a wildfire 

were to occur, would 

be significantly 

reduced by this change 

in fire intensity.

Surface and ladder fuel 

treatments would 

effectively reduce fire 

behavior to desired 

condition levels. Fire 

effects, if a wildfire 

were to occur, would be 

significantly reduced by 

this change in fire 

intensity.
Final Environmental Impact Statement

Summary

Sierra National Forest xix

Resource Area Indicator Alt 1 Alt 2 Alt 3 Alt 4

Air Quality (page 

161)

Potential for Air 

Quality and visibility 

degradation 

If a uncontrolled 

wildfire was to occur 

within the area, 

smoke would 

produce unhealthy to 

severely degraded air 

quality and reduced 

visibility for 

extended period of 

time and effect the 

public as well as 

firefighters. 

Dependent on upper 

level atomosphere, 

Class I airsheds could 

be impacted. 

Through regulations 

and rules set forth by 

Title 17 of the CA 

Health and Safety 

Code, state Air 

Resource Board and 

local air districts any 

prescribed burning 

would require prior 

review and approval to 

ensure minimization of 

potential effects from 

smoke on the public. 

This would include 

potential effects to 

Class I airsheds. A 

General Conformity 

analysis determined 

this alternative would 

conform with the SIP.

Potential air quality 

impacts from wildfires 

would be reduced with 

less ground fuels 

available.

Best Management 

Practices and contract 

specifications would 

minimize impacts 

created by 

implementation of 

other treatments. 

Through regulations 

and rules set forth by 

Title 17 of the CA 

Health and Safety 

Code, state Air 

Resource Board and 

local air districts any 

prescribed burning 

would require prior 

review and approval to 

ensure minimization of 

potential effects from 

smoke on the public. 

This would include 

potential effects to 

Class I airsheds. A 

General Conformity 

analysis determined 

this alternative would 

conform with the SIP.

Potential air quality 

impacts from wildfires 

would be reduced with 

less ground fuels 

available.

Best Management 

Practices and contract 

specifications would 

minimize impacts 

created by 

implementation of 

other treatments.

Through regulations and 

rules set forth by Title 

17 of the CA Health and 

Safety Code, state Air 

Resource Board and 

local air districts any 

prescribed burning 

would require prior 

review and approval to 

ensure minimization of 

potential effects from 

smoke on the public. 

This would include 

potential effects to Class 

I airsheds. A General 

Conformity analysis 

determined this 

alternative would 

conform with the SIP.

Potential air quality 

impacts from wildfires 

would be reduced with 

less ground fuels 

available.

Best Management 

Practices and contract 

specifications would 

minimize impacts 

created by 

implementation of other 

treatments.
Final Environmental Impact Statement

Summary

xx Sierra National Forest

Resource Area Indicator Alt 1 Alt 2 Alt 3 Alt 4

Transportation 

System (page 183)

Effects of 

Transportation System 

With minimal 

maintenance there is 

a continued potential 

for loss of 

infrastructure 

investment from 

erosion, wet weather 

use and brush 

encroachment.

Roads not meeting 

acceptable Standards 

will be required to be 

have maintenance, or 

recontruction done for 

project implementation.

This has the potential to 

reduce erosion 

problems caused by 

transportation 

corridors.

0.2 miles of new road 

will need to be built.

0.5 miles of temporary 

road will need to be 

built.

Implementation of 

BMP and erosion 

control measures will 

reduce the impacts of 

such construction.

 

See Alternative 2. See Alternative 2.
Final Environmental Impact Statement

Summary

Sierra National Forest xxi

Resource Area Indicator Alt 1 Alt 2 Alt 3 Alt 4

Economics (page 

186)

*Indicator based on 

valuation of wood byproduct associated 

with treatments and 

revenue or costs to 

implement treatment.

Estimated Boardfeet 

Estimated Biomass:

Cubic Foot Volume

Bone Dry Ton Volume

Estimated Total 

Revenue/Cost

associated with 

Alternative (Present 

Net Value)

0

0

0

0

4200

1394

3941

$(-592,492)

3378

1145

6228

$(-545,650)

690

406

1852

$(-549,761)

Sierra National Forest – Chapter 1 1

Chapter 1. Purpose of and Need for Action

Document Structure _________________________

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

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

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

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

is organized into four chapters: 

 Chapter 1. Purpose and Need for Action: This chapter briefly describes the proposed 

action, the need for that action, and other purposes to be achieved by the proposal. This 

section also details how the Forest Service informed the public of the proposed action and 

how the public responded. 

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

description of the agency proposed action as well as alternative actions that were 

developed in response to comments raised by the public during scoping. The end of the 

chapter includes a summary table comparing the proposed action and alternatives with 

respect to their environmental impacts.

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

describes the environmental impacts of the proposed action and alternatives. 

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

agencies consulted during the development of the environmental impact statement. 

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

presented in the environmental impact statement.

 Index: The index provides page numbers by document topic.

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

found in the project planning record located at Bass Lake Ranger District office in North Fork, 

California.

Background ________________________________

The Sierra National Forest Land and Resource Management Plan (LRMP or Forest Plan) was 

amended in 2001 by the Sierra Nevada Forest Plan Amendment (SNFPA) Record of Decision

(USDA-FS 1992, 2001b). Standards and Guidelines for project planning were to focus on the 

modification of fire behavior through fuels treatments. These treatments were to have the highest 

priority in areas described as Wildland Urban Interface/Intermix (WUI). In 2004, a Supplemental 

Environmental Impact Statement (USDA-2004a) was written to the SNFPA and a Record of 

Decision (ROD) was signed (USDA-FS 2004b). This ROD replaced the 2001 decision in its 

entirety. This decision recommended an ecosystem approach whereby the development and 

planning of projects would be not only based on fuels reduction treatments, but would create an 

overall approach by looking at all key elements within an ecosystem. WUI continued to be the 

highest priority area for treatments. 

In July 2005, the Bass Lake Ranger District completed the Fresno River Landscape Analysis. In 

the Fresno River Landscape Analysis, the State Highway 41 Corridor was determined as an area 

with greatest departure from desired conditions set-forth in the SNFPA ROD (USDA-FS 2004b)

and where opportunity existed to move it closer to that desired condition. This area includes high 

concentrations of human habitation and activities, the Nelder Grove Historical Area of Giant 

Sequoias, forests with declining health from overcrowding and habitat for species-at-risk (such as 
Chapter 1: Purpose and Need Sugar Pine Adaptive Management Project

2 Sierra National Forest

California Spotted Owl, goshawk and Pacific fisher). Sugar Pine is one of the communities 

within the State Highway 41 corridor and was used as the first point of reference in developing 

and planning the Sugar Pine Adaptive Management Project.

Following management goals and direction from the SNFPA ROD (USDA-FS 2004b), treatment 

areas for the Sugar Pine Adaptive Management Project were developed. These treatment areas 

were based on the basic fire and fuels strategy which remained in the SNFPA ROD (USDA-FS 

2004b); reducing the risk of wildland fire to WUI and to effectively modify wildland fire 

behavior by strategically placing a pattern of area treatments (known in the SNFPA ROD 

(USDA-FS 2004b) as SPLATs) across broad landscapes. In addition, this strategy was broadened 

to include the need to consider and provide for other important objectives to improve forest health

by restoring and maintaining ecosystem structure and composition. A network of land 

allocations, designated as part of the SNFPA ROD (USDA-FS 2004b), have an associated set of 

desired conditions, management intents, and management objectives. From standards and 

guidelines management direction is provided for project planning and implementation. The 

vegetation and fuels treatment standards and guidelines are intended to (1) act as sideboards for 

local managers as they design projects to meet fuels and vegetation management objectives and 

respond to site-specific conditions, and (2) retain important components of habitat that are 

believed to be important to species associated with old forests, including large trees, structural 

diversity and complexity, and moderate to high canopy cover. At the project level, these 

standards and guidelines are used in conjunction with desired conditions, management intents, 

and management objectives for the relevant land allocation to determine appropriate treatment 

prescriptions (SNFPA ROD; USDA-FS 2004b).

As part of the SNFPA ROD (USDA-FS 2004b), an adaptive management and monitoring strategy

designed to address high priority, key questions that relate to the uncertainties associated with 

management activities was to be initiated. In 2006, Region 5 (Pacific Southwest Region) of the 

Forest Service, as well as other Federal and State Agencies, entered into an agreement with the 

University of California whereby the university would act as a neutral third party to studying the 

effects of management actions associated with implementation of the SNFPA ROD (USDA-FS 

2004) management direction. Four key areas where the highest priority management questions

exist (detailed and incorporated from SNFPA FEIS, Appendix E [USDA-FS 2001] and SNFPA 

FSEIS [USDA-FS 2004a]) are the center of this study. These key areas include wildlife 

(specifically Pacific fisher/California spotted owl), fire and forest health, water quality and 

quantity, and public participation. This adaptive management study is known as the Sierra 

Nevada Adaptive Management Project (SNAMP). SNAMP is designed around cause 

(management action directed through standards and guidelines), effect monitoring (of those 

management actions) and research to gain a better understanding of how components, structures 

and processes in these keys areas respond to management activities, and how ecosystem 

components interrelate. During the seven year study, SNAMP scientist are collecting pretreatment data (~3 years), conducting implementation monitoring (~2 years) and collecting post 

treatment data (~2 years). If an alternative where management actions are to take place is chosen, 

the timeframe for conducting the SNAMP study requires all management actions (including post 

treatment), to be conducted within the ~2 year implementation period. Because of this 

timeframe, action alternatives are to propose treatment types that minimize the amount of post 

treatment needed to meet fire/fuels and forest health objectives. The information collected will 

be assembled, reviewed, and integrated into a feedback loop that can inform subsequent 

management decisions. The Sugar Pine Adaptive Management Project is one of two projects in 

the region where these key areas and related management questions are to be studied.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 1 3

As an integral part of SNAMP, stakeholders have been involved in an open and transparent 

process, where the science team holds regular meetings to provide updates on the study. This 

includes providing information on pre-treatment data that has been collected within the study 

area. This allows for a collaborative means in which all parties involved in the study can gain 

knowledge and provide on-going input to the study and the project itself. This group is being 

called the Integration Team. Through these Integration Team meetings and quarterly reports 

from the science team, stakeholders have been presented with information on pre-treatment data 

that has been collected to date, including current movement patterns and 2008/2009 denning sites 

(both birthing and maternal) of Pacific fisher that have been radio collared and intensively 

monitored within and outside of the project area. Previous to SNAMP no densites had been 

located on the Sierra National Forest. Very little to no information about what type of habitat 

conditions are preferred by denning females has been available in the past and is one facet of the 

uncertainty surrounding the Pacific fisher. As well is the uncertainty surrounds the effects of 

management actions (timing, extent and type) on the occupancy and habitat relationships to the 

fisher. 

The SNFPA ROD (USDA-FS 2004b), under Forest Carnivore Den Site Buffers, requires a 700-

acre buffer, consisting of the highest quality habitat (CWHR size class 4 or greater and canopy 

cover greater than 60 percent) in a compact arrangement, be created surrounding verified fisher 

birthing and kit rearing dens in the largest, most contiguous blocks available. Standards and 

guidelines for management actions within this buffer are #85 (creation of an LOP during breeding 

and rearing season); #86 (mechanical treatment of surface and ladder fuels only, if den site buffer 

is within WUI zone) and #87 (mitigation of disturbance by recreational users). As directed by the 

SNFPA ROD (USDA-FS 2004b), fisher densite buffers have been designated utilizing the 

2008/2009 SNAMP fisher densite information within the Sugar Pine Adaptive Management 

Project area. 

Purpose and Need for Action__________________

The underlying need(s) for this proposal include:

1. The need for fuel reduction (in the surface and ladder fuels) that protects human communities 

from moderate/high intensity wild fires as well as minimizes the spread of wildfires that 

might originate in urban areas into the forested lands. The reasons for this need are to 

increase the efficiency of firefighting efforts and reduce risks to firefighters, the public, 

facilities and structures, and natural resources from moderate/high intensity wild fires.

2. The need for conifer stands to be resilient to attack from insects, diseases, drought conditions, 

and/or wildfire. The reason for this need is conifer stands are well above normal stocking 

levels (stand densities) resulting in a decline in growth, health and resiliency thus increasing a 

stands potential for higher rates of mortality.

In meeting the aforementioned needs the action must also achieve the following purposes:

1. A purpose of this proposal is to reduce the intensity and spread of wildfires across the 

landscape and near communities. The reason for this purpose is to provide a buffer between 

developed areas and wildlands where fire suppression capabilities are enhanced by modified 

fire behavior inside the WUI zones as well as provide a safe and effective area for fire 

suppression activities to occur (USDA-FS 2001b, page 9). 

2. A purpose of this proposal is to reduce stand density, within the lower and mid-canopy layers 

of conifer stands, to such a level as to provide for increased stand resiliency, growth and 
Chapter 1: Purpose and Need Sugar Pine Adaptive Management Project

4 Sierra National Forest

vigor. The reason for this purpose is to increase the capability for forested stands to withstand 

fluctuations in temperature and precipitation, attacks from insects and diseases, and from 

wildfires.

Proposed Action ____________________________

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

 Treat surface and ladder fuels (live and dead) to interrupt wildfire spread and fire 

intensity levels. This is proposed to be completed utilizing thinning and biomass thinning

of pre-commercial and commercial conifers, mastication and/or dozer piling and burning 

in order to improve the ability of firefighters to suppress and control wildfires and 

provide a better measure of safety for the public and personnel.

 Commercially thin from below and biomass thin mixed conifer, white fir and pine stands 

as well as pre-commercially thin young conifer plantations and conifer reproduction to 

reduce stand densities. This is being accomplished to improve the vigor of the stands. 

 Masticate brush/shrub patches to tie treatment areas together in strategic locations.

 Utilize prescribed fire as a tool to reduce natural and activity-generated fuels through pile 

burning, understory and/or broadcast burning.

 Use prescribed fire and/or manual methods to treat infestations of noxious weeds, with 

the goal of eradication and preventing their spread into areas treated.

 Replant conifers within specific sites of failed conifer plantations.

The proposed action is described in more detail in Chapter 2 under Alternative 2, pages 12-13.

Decision Framework _________________________

Given the purpose and need, the deciding official will review the proposed action, other 

alternatives, and their environmental consequences, in order to determine whether to implement 

the proposed action as described, select a different alternative or take no action at this time. 

Forest Plan Direction ________________________

The Proposed Action and alternatives are guided by the Sierra National Forest Land and Resource 

Management Plan (SNF LRMP), as amended by the Sierra Nevada Forest Plan Amendment 

Record of Decision, 2004 (SNFPA ROD) [USDA-FS 2004b]. The Sierra National Forest is 

subdivided into land allocations (management areas) with established desired conditions and 

associated management direction (Standards and Guidelines). Land allocations that are found 

within the Sugar Pine Adaptive Management Project boundary are shown on either individual 

maps for the specific land allocation or on the Land Allocations-Map 4. These maps are in the 

Map Package in Appendix A and include:

 Wildland Urban Interface/Intermix (both Defense and Threat Zones). This land 

allocation encompasses 4,674 acres within the Sugar Pine Adaptive Management Project 

boundary and is set in closest proximity to communities, areas with higher densities of 

residences, commercial buildings, and/or administrative sites with facilities. Of this 

acreage; 888 acres are designated as Defense Zone and 3,628 acres are designated as 

Threat Zone. There were no local site-specific adjustments made to these boundaries as 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 1 5

allowed by SNFPA ROD (USDA-FS 2004b) and are the zones mapped in the SNFPA 

FSEIS 2004. As defined in the SNFPA ROD (USDA-FS 2004b), Defense Zones 

designated in the project extend 1⁄4 mile from private property lines. Threat Zones 

designated in this project extend 1 1⁄4 miles out from the Defense Zone boundary. There 

are Forest-wide standards and guidelines for this land allocation. These forest-wide 

standards and guidelines were used to develop the purpose and need (USDA-FS 2004b,

pgs. 49-50).

 Southern Sierra Fisher Conservation Area (SSFCA). This land allocation 

encompasses the entire Sugar Pine Adaptive Management Project area. The SNFPA ROD 

(USDA-FS 2004b) has set forth standards and guidelines for this land allocation that 

address protection measures for fisher densites as well as direction for projects proposed 

in SSFCA (USDA-FS 2004b, pgs. 61-62). In these standards and guidelines it is left to 

wildlife biologist to develop design criteria that protect important habitat structures 

within fisher habitat. Design criteria for the maintenance and protection of key habitat 

elements for Pacific fisher have been developed based on current scientific information, 

issues raised during public scoping and standards and guidelines in the SNFPA ROD 

(USDA-FS 2004b). These are listed in Chapter 2, Design Criteria Common to All 

Alternatives starting on page 16. 

 California Spotted Owl Protected Activity Centers (PACs) and Home Range Core 

Areas (HRCA). This land allocation encompasses 4,700 acres of the project area as 

suitable nesting habitat and nearly the entire Sugar Pine Adaptive Management Project 

area is suitable foraging habitat. There are six PACs and associated HRCAs either 

entirely or partially within the project boundaries. The SNFPA ROD (USDA-2004b) has 

set forth standards and guidelines for this land allocation that address mechanical 

treatments conducted to meet fuels management objectives in PACs located in the WUI

defense zones and in threat zones where prescribed fire is not feasible and where 

avoiding PACs would significantly compromise the overall effectiveness of the landscape 

fire and fuels strategy (USDA-FS 2004b, pgs. 59-61). These, as well as the remaining 

standards and guidelines for this land allocation are incorporated into design criteria and 

are listed in Chapter 2, Design Criteria Common to All Alternatives starting on page 16.

 Northern Goshawk Protected Activity Centers (PAC). This land allocation 

encompasses 4,700 acres of suitable nesting habitat and nearly the entire Sugar Pine 

Adaptive Management Project area suitable foraging habitat. There are two PACs that 

either are entirely or partially within the project boundaries. The SNFPA ROD (USDAFS 2004b) has set forth standards and guidelines for this land allocation which are similar 

to those for California spotted owl PACs (USDA-FS 2004b, pgs. 59-61). The standards 

and guidelines for this allocation are incorporated into design criteria and are listed in 

Chapter 2, Design Criteria Common to All Alternatives starting on page 16.

 Old Forest Emphasis Areas. This land allocation is designated in approximately 2,870

acres within the Sugar Pine Adaptive Management Project boundary. Mature forest 

habitat is described by California Wildlife Habitat Relationship (CWHR) types 4M, 4D, 

5M, 5D, and 6 where outside of the WUI defense zones standards and guidelines are 

designed to maintain and enhance the structures associated with these forest types and the 

protection of the species habitat associated with these forest ecosystems (SNFPA ROD; 

USDA-FS, 2004b, pages 50-51). As such, standards and guidelines associated with 

wildlife species that prefer mature forest habitat are used as the standards and guidelines 
Chapter 1: Purpose and Need Sugar Pine Adaptive Management Project

6 Sierra National Forest

for this land allocation. These are incorporated into design criteria and are listed in 

Chapter 2, Design Criteria Common to All Alternatives starting on page 16.

 General Forest. This land allocation is designated in approximately 742 acres within the 

Sugar Pine Adaptive Management Project boundary. The standards and guidelines 

associated with this land allocation are the same as those for Old Forest Emphasis Areas. 

As such, standards and guidelines associated with wildlife species that prefer mature 

forest habitat are used as the standards and guidelines for this land allocation. These are 

incorporated into design criteria and are listed in Chapter 2, Design Criteria Common to 

All Alternatives starting on page 16.

 Riparian Conservation Areas. This land allocation encompasses the entire Sugar Pine 

Adaptive Management Project area because of the extensive stream network within the 

project boundary. The standards and guidelines, specifically the Resources Conservation 

Objectives from the SNFPA ROD (USDA-FS 2004b), associated with this land allocation 

are incorporated into design criteria and are listed in Chapter 2, Design Criteria Common 

to All Alternatives starting on page 16. 

Public Involvement __________________________

A Notice of Intent (NOI) to prepare an Environmental Impact Statement for the Sugar Pine 

Adaptive Management Project was published in the Federal Register on October 12, 2007. The 

notice asked that comments on the proposed action be received by October 31, 2007. In addition, 

as part of the public involvement process, the Forest Service sent scoping letters to residents 

within 1.5 mile radius of the project area, to members and groups in the Native American 

community and to publics expressing interest in the project through scoping opened during the 

project posting in the Sierra National Forest Schedule of Proposed Action. These scoping letters 

were sent on August 31, 2007. On September 5, 2007, the Forest Service held a public meeting in 

Oakhurst, California, as well as a public field trip to the project area on September 29, 2007. 

Letters inviting interested publics were mailed to each individual that had been sent an initial 

scoping letter as well as electronically mailed to individuals participating in the Sierra Nevada 

Adaptive Management Project (SNAMP). A news release announcing the public meeting was 

sent to the Sierra Star (local newspaper) on September 3, 2007. The public meeting and public 

field trip were attended by approximately 30 individuals from the local community, local fire safe 

council, and environmental community. In addition to comments received during the public 

meeting and field trip, five comment letters on the proposed action were received.

As part of the public participation portion of the SNAMP study of this project, a group of 

stakeholders designated as the Integration Team, was formed. Throughout the planning process 

the Integration Team has held several open forums with the SNAMP team and the Forest Service, 

Bass Lake Ranger District Interdisciplinary Team to discuss project planning, modifications to 

the proposed action, updates on base information collection and potential effects based on most 

recent information collected by SNAMP. In conjunction with the written comments received 

during the scoping period and the issues associated with written comments (see below), 

recommendations and items of concern at these meetings have been brought forward into this 

analysis and partially led to the development of Alternatives 3 and 4.

The Draft Environmental Impact Statement for the Sugar Pine Adaptive Management Project was 

published in the Federal Register in July 2009 and made available for a 45-day public comment 

period. There were a total of ten comment letters received. Appendix D summarizes the 

comments received and includes the Response to those Comments. 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 1 7

Issues _____________________________________

Comments from the public and other agencies were used to formulate issues concerning the 

proposed action. There were no comments received from members or groups from the Native 

American community. The Forest Service separated the issues into two groups: significant and 

non-significant. Significant issues were defined as those directly or indirectly caused by 

implementing the proposed action. Non-significant issues were identified as those: 1) outside the 

scope of the proposed action; 2) already decided by law, regulation, Forest Plan, or other higher 

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

scientific or factual evidence. The Council on Environmental Quality (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 non-significant issues and reasons why they were found non-significant may 

be found in the project record located at Bass Lake Ranger District Office in North Fork, CA. 

The Forest Service identified the following significant issue during scoping:

Issue: The issue is the proper balance between improved functionality and sustainability and

reducing human habitations (WUI) vulnerability to wildland while retaining important species 

habitat elements. Specifically, retention of important habitat elements for Pacific fisher, 

California spotted owl, Northern goshawk and Management Indicator Species as measured by:

 High canopy cover (average in a stand should not drop below 50% and significant 

portions of the treated stands should be at 60% or greater canopy cover),

 Especially in larger [>20 inch diameter] sized trees,

 Relatively high basal areas,

 Understory structure (provide for understory diversity),

 Adequate large snags and downed wood, and

 Available movement corridors linking to suitable habitat outside of project area (habitat 

connectivity).

These indicators are first addressed in Design Criteria Common to All Alternatives (listed on 

pages 16-26). The design criteria include standards and guidelines directly from the SNF LRMP, 

SNFPA ROD (USDA-FS 1992, 2004b) and additional criteria developed to address the indicators 

above as well as those developed to minimize the potential environmental impacts of 

management activities on any given resource. These design criteria are incorporated into each 

action alternative as part of the alternative and are considered when specialists have analyzed the 

direct, indirect and cumulative effects of the alternatives. Chapter 3-Affected Environment and 

Environmental Consequences (pages 31-190) provides this detailed analysis for each alternative. 

Sierra National Forest – Chapter 2 9

Chapter 2. Alternatives, Including the 

Proposed Action

Introduction ________________________________

This chapter describes and compares the alternatives considered to meet the purpose and need of 

the Sugar Pine Adaptive Management Project. It describes both alternatives considered in detail 

and those eliminated from detailed study. The end of this chapter presents the alternatives in 

tabular format so that the alternatives and their environmental impacts can be readily compared.

Relationship of Alternatives to Existing Management Plans

SNAMP is designed to study and analyze the effects of implementing management direction as 

given by the SNFPA ROD (USDA-FS 2004b). The Sugar Pine Adaptive Management Project‘s 

purpose and need to: 1) reduce the intensity and spread of wildfires and 2) to reduce stand 

densities to improve growth and vigor is from that management direction. The management 

actions are planned to meet the purpose and need and those management actions are designed 

based on guidance given in the standards and guidelines in the SNFPA ROD (USDA-FS 2004b). 

In utilizing the ―best science available‖, in this case the SNAMP 2008/2009 fisher densite 

information the SNFPA ROD (USDA-FS 2004b) directs there to be fisher densite buffers of 700 

acres of the highest quality habitat to be designated around the densites. Within these buffers,

management actions follow standards and guidelines specific to fisher densite buffers. Standard 

and guideline include #85 which provides a Limited Operating Period during breeding and 

rearing season; #86 which limits management actions to that needed to meet fire/fuels objectives 

if in a WUI zone (mechanical treatment of the ladder and surface fuels) and #87 mitigation of 

disturbance by recreational users. With the designation of these densite buffers and the 

associated densite buffer standard and guidelines, SNAMP is given the ability to study and 

analyze the effects of implementing management direction from the SNFPA ROD (USDA-FS 

2004b). But in doing so, it limits the effects from management actions being studied and 

analyzed to those potentially created from implementing treatments to meet fire/fuels objectives 

only and not those potentially created from implementing vegetation treatments to meet forest 

health objectives (mechanical treatments to reduce stand densities). With the uncertainty 

surrounding the effects of various management actions allowed in the SNFPA ROD (USDA-FS 

2004b) (timing, extent and type of management action) on the occupancy and habitat 

relationships to the fisher, the decision maker needs to be given the opportunity to weigh the 

potential direct, indirect and cumulative effects of a range of alternatives with management 

actions that include fuels treatments (reduction in ladder and surface fuels and defined as 

treatments in the lower and limited mid canopy layers) as well as vegetation treatments (reduction 

in stand densities to improve growth and vigor (forest health) and defined as treatments in the

lower and mid canopy layers) that incorporate and are designed based on what is currently 

considered important habitat characteristics (as detailed in the Issue and in Design Criteria 

Common to All Alternatives) and likewise follow management direction provided under the 

SNFPA ROD (USDA-FS 2004b). By designating Pacific fisher densite buffers using 2008/2009 

SNAMP densite information, this is not possible because of the extent these densite buffers 

within the project boundary (in essence the entire project boundary would be designated as a 

fisher densite buffer). A Forest Plan Amendment to Standard and Guideline #86 would need to 

occur if Alternative 2 or Alternative 3 were selected, in order to analyze and implement forest 

health objectives within designated Pacific fisher densite buffers. The Forest Plan Amendment 

Standard and Guideline #86 to read as follows. The Amendment is shown in italics. The rest of 

Standard and Guideline #86 in quotes is retained as written in the SNFPA ROD (USDA-FS 
Chapter 2: Alternatives, Including the Proposed Action

10 Sierra National Forest

2004b): ―Avoid fuel treatments in fisher densite buffers to the extent possible. If areas within 

densite buffers must be treated to achieve fuels objectives of the urban wildland intermix zone, 

limit treatments to mechanical clearing of fuels. Treat ladder and surface fuels to achieve fuels 

objectives. Use piling or mastication to treat surface fuels during initial treatment. Burning of 

piled debris is allowed. Prescribed fire may be used to treat fuels if no other reasonable 

alternative exists.‖ Vegetation treatments as designed to meet Forest Health objectives and

defined in Chapter 2, Alternatives Considered in Detail of the Sugar Pine Adaptive Management 

Project Environmental Impact Statement, may occur in Pacific fisher densite buffer(s) within the 

Sugar Pine Adaptive Management Project boundary (the specific Sugar Pine Project Boundary is 

shown on Map 1 in the Appendix A-Map Package) during the implementation phase of this 

project.

Significance of Forest Plan Amendment

Adoption of either of two of the action alternatives, (Alternative 2 or 3), would result in the above 

amendment of the SNF LRMP/SNFPA ROD (USDA-FS 1992; 2004b). If an amendment to a 

Forest Plan results in a ―significant change in the plan,‖ the National Forest Management Act 

(NFMA) and its 1982 implementing regulations, under which this Environmental Impact 

Statement (EIS) is prepared, require that the amendment process follow the procedures used in 

the initial development of the plan. If the proposed change in the plan is not significant, public 

notification and completion of the National Environmental Policy Act (NEPA) procedures are 

still required (16USC 1604(f)(4) and 36 CFR 219.10(f). Determining whether a plan amendment 

is a significant change uses different criteria than those used in evaluating significance in the 

NEPA process. For the NFMA requirement, the Forest Service Manual (FSM 1922.51 and 52) 

provides specific direction.

Forest Service Manual 1933.51 – Changes to the Forest Plan that are Not Significant. 

Changes to the forest plan that are not significant can result from:

1. Actions that do not significantly alter the multiple-use goals and objectives for the longterm land and resource management.

The actions proposed in these alternatives would not alter the objectives and the multiple-use 

goals of the Sierra National Forest Land and Resource Management Plan (SNF LRMP) 

(USDA-FS 1992) as amended by the SNFPA ROD (USDA-FS 2004b). The purpose of the 

action alternatives is to facilitate achieving these goals and objectives of these. The action 

alternatives will continue to provide species protection in compliance with all applicable laws 

and regulations, while making more Agency resources available for other forest management 

priorities. The underlying need to which the action alternatives are responding is the need to 

achieve the objectives originally established for the SNFPA ROD (USDA-FS 2004b). 

Without the SNF LRMP/SNFPA ROD (USDA-FS 1992; 2004b) amendment the forest health 

objectives are frustrated as fisher densite buffers would encompass the vast majority of the 

5,416 acres in the project boundary.

2. Adjustment of management area boundaries or management prescriptions resulting from 

further on-site analysis when the adjustments do not cause significant changes in the 

multiple-use goals and objectives for long-term land and resource management.

The action alternatives would change Pacific fisher densite protection management. The 

action alternatives would not reduce species protection below legally required levels or 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 2 11

increase timber harvest beyond levels identified in the SNFPA FSEIS (USDA-FS 2004a) or 

SNF LRMP (USDA-FS 1992). The action alternatives improve the Sierra National Forest‘s 

ability to conduct forest management activities at a level described in the SNF LRMP/SNFPA 

ROD (USDA-FS 1992; 2004b). Selection of one of the action alternatives would enable the 

Sierra National Forest to better meet the long-term goals and objectives currently identified in 

the SNF LRMP/SNFPA ROD (USDA-FS 1992; 2004b).

3. Minor changes in standards and guidelines.

The action alternatives would modify a mitigation measure added during preparation of the 

SNFPA FSEIS (USDA-FS 2004a). The action alternatives would not significantly change 

any key elements of the underlying strategy or standards and guidelines. Removing or 

modifying SNFPA ROD Standard and Guideline #86 would be a relatively minor change 

because: (1) the Sugar Pine Adaptive Management Project forest health treatments have been 

developed with an ecosystem based approach that relies primarily on creating and 

maintaining the desired conditions for areas surrounding fisher den sites; (2) the amendment 

of Standard and Guideline #86 is limited in scope (5,416 acres out of the more than 1.3 

million acres in the Sierra National Forest (0.4 percent of the total forest) and in time frame 

(amendment is only applicable during the implementation phase of the Sugar Pine Adaptive 

Management Project); (3)information will be generated on fisher‘s response to the vegetation 

treatments for forest health as this area is part of the SNAMP study that can help inform 

future decisions; and (4) the vegetation treatments for forest health will help sustain the 

habitat conditions needed by the fisher in the long-term. The effects discussion in Chapter 3-

Affected Environment and Environmental Consequences (Terrestrial Wildlife) helps to 

quantify the change within the context of the proposed project.

4. Opportunities for additional management practices that will contribute to achievement of 

the management prescription.

The action alternatives are specifically designed to better and more efficiently meet the 

underlying needs identified in the SNFPA FSEIS (USDA-FS 2004a).

Forest Service Manual 1922.52 – Changes to the Forest Plan that are Significant. The 

following examples are indicative of circumstances that may cause a significant change in a 

forest plan.

1. Changes that would significantly alter the long-term relationship between level of 

multiple-use goals and services originally projected (36 CFR 219.10(e)).

The changes proposed by the action alternatives would help achieve, not alter, the 

relationship between levels of multiple-use goods and services originally projected. The 

Pacific fisher will continue to receive protection as required to meet all applicable laws and 

regulations.

2. Changes that may have an important effect on the entire forest plan or affect land and 

resources throughout a large portion of the planning area during the planning period.

The changes proposed would modify an SNFPA ROD (USDA-FS 2004b) mitigation 

measure. The action alternatives do not change land allocation or other elements of the SNF 
Chapter 2: Alternatives, Including the Proposed Action

12 Sierra National Forest

LRMP (USDA-FS 1992) or SNFPA (USDA-FS 2004b). There will be a reduction in the area 

managed known fisher den site buffers; however, no other SNF LRMP (USDA-FS 1992) or 

SNFPA ROD (USDA-FS 2004b) resource objective is dependent on these sites. There is 

predicted to be an increase in vegetation treatments for forest health from current levels; the 

current levels are well below the predictions displayed in the SNFPA FSEIS (USDA-FS 

2004a). The purpose of the proposal is to achieve levels of vegetation treatments for forest 

health that were expected when the SNFPA ROD (USDA-FS 2004b) was signed in 2004. 

Thus, the action alternatives will help achieve (and not change) the multiple use goals and 

objectives set forth in the SNFPA ROD (USDA-FS 2004b).

Alternatives Considered in Detail ______________

Based on the issue identified through public scoping on the proposed action and comments 

received through the SNAMP Integration Team collaboration, two additional action alternatives 

were considered in detail. In addition, the Forest Service is required to analyze a No Action 

alternative. These alternatives including the proposed action and no action alternative are 

described in detail below. 

Alternative 1 – No Action 

Under the No Action alternative, current management plans would continue to guide management 

of the project area. No thinning, either commercial, pre-commercial and/or biomass operations, of 

mixed conifer and pine stands, mastication of brush/shrub patches, prescribed burning to reduce 

natural fuel accumulations and/or treatment of infestations of noxious weeds and replanting of 

conifers in failed conifer plantations would be implemented to accomplish the purpose and need. 

Alternative 2 – The Proposed Action

Treatment areas within the project area boundary were delineated to include those areas where 

some form of treatment was necessary to meet the purpose and need. First treatment areas were 

designed to create SPLATs to reduce the intensity and spread of wildfires in and around WUI. 

Treatment areas near key transportation corridors (for egress and ingress into the community) and 

within the defense zone of the WUI were designed next. Treatment areas were further designed

to not only focus on those treatments needed to meet fire and fuel objectives (treatments defined 

for fire/fuels are designed to reduce the ladder and surface fuels and occur within the lower and 

limited mid-level canopy[Fire/Fuels Objectives]), but areas where the stands were considered 

overstocked with conifers and are in higher levels than can be sustained with changing 

environmental conditions and are vulnerable to loss from insect, disease and wildfire (Forest 

Health Objectives) (treatments defined for forest health are designed to reduce basal area and 

stocking to such a level that the stands are resilient to changing environmental conditions, 

increase growth and are vigorous with reduced susceptibility to insect and disease attack and 

wildfire. These treatments occur within the lower and mid-level canopy). A treatment area map, 

Map 1, displays these treatment areas and can be found in the Map Package. 

Of the 5,416 total acres within the project boundary, approximately 2,920 acres were analyzed as 

areas where some form(s) of treatment are proposed (so named as treatment areas). The 

remaining 2,496 acres have no treatments proposed due to slopes greater than 35 percent, 

standard and guideline limitations on treatment and/or no treatment is needed to meet the purpose 

and need.

In Alternative 2 (Proposed Action) the treatments would include:
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 2 13

 Commercial and biomass thinning an estimated 850 acres of approximately 90-110 year 

old natural conifer stands (within T areas); 

 Commercial and biomass thinning an estimated 65 acres of approximately 45 year old 

ponderosa pine plantations (within T areas);

 Biomass thin an estimated 150 acres of approximately 70-90 year old natural 4 to 10 inch 

dbh (diameter at breast height) conifer stands (within T areas);

 Pre-commercial hand thin and remove fuel ladders, hand pile and burn on approximately 

17 acres (within T 5 and M2);

 Pre-commercial thin, tractor pile and burn approximately 30 acres of natural conifer

stands (within T areas);

 Masticate brush fields and masticate pre-commercial thin reproduction areas on 

approximately 245 acres (within T areas); 

 Masticate brush fields, masticate fuel ladders, and masticate pre-commercially thin 

reproduction areas on approximately 395 acres (M areas);

 Perform fuelbreak maintenance on approximately 40 acres (M4);

 Pre-commercial thin/release plantations on approximately 115 acres (M10 (part), M11, 

16, 24, and 25, portions of T6, 7, and 35); 

 Plant and hand release site prepared openings on approximately 40 acres;

 Prescribed understory burn, as a primary fuels treatment, approximately 215 acres;

 Maintenance on approximately 28.2 miles of NFTS road;

 Reconstruction on approximately 9.8 miles of NFTS road;

 Construct approximately 0.5 miles of temporary road;

 Construct approximately 0.2 miles of new system road;

 Prescribed burn and/or manually treat infestations of noxious weeds, where located 

within the project treatment areas, with the goal of eradication and prevention of their 

spread.

Though a total of 2,920 acres are analyzed for treatments listed above, design criteria common to 

all alternatives and standards and guidelines from SNFPA ROD (USDA-FS 2004b) dictate areas 

where treatments cannot occur to reduce and/or eliminate adverse effects on particular resources. 

These can include, but are not limited to cultural resource areas, botanical species areas, wildlife 

habitat areas, and aquatic species areas. It is estimated that excluding these control areas from the 

treatment areas where no treatment will occur, a total of 1,908 acres will remain for treatments as 

proposed.

As part of this alternative the non-significant Forest Plan Amendment to SNF LRMP/SNFPA 

ROD (USDA-FS 1992; 2004b) Standard and Guideline #86 would be included. In Alternative 2, 

the Forest Plan Amendment would allow both fuels treatments and vegetation treatments as 

designed to meet forest health objectives to occur within all designated Pacific fisher densite 

buffers within the Sugar Pine Adaptive Management Project boundary during the implementation 

phase of this project.
Chapter 2: Alternatives, Including the Proposed Action

14 Sierra National Forest

Alternative 3 – Lower and Limited Mid-Level Canopy 

Treatments within Known Den Site Buffer

In Alternative 3, treatment areas and the types of treatments would remain the same as in 

Alternative 2. As part of this alternative the non-significant Forest Plan Amendment to the SNF 

LRMP/SNFPA ROD (USDA-FS 1992; 2004b) Standard and Guideline #86 would be included. 

In Alternative 3, the Forest Plan Amendment would allow both fuels treatments and vegetation 

treatments as designed to meet forest health objectives to occur within designated Pacific fisher 

densite buffers within the Sugar Pine Adaptive Management Project boundary during the 

implementation phase of this project. Within the treatment areas that are part of the 2008 795-

acre Pacific fisher densite buffer designated for the SNAMP F01 female fisher, treatments would 

be limited those needed to meet fire/fuels objectives within WUI (reduction in surface and ladder 

fuels; treatment of the lower and limited mid-level canopy) (See Map 5 in the Map Package for 

the location of this designated den site buffer). Map 13 in the Map Package displays the 

additional 2009 designated Pacific fisher densite buffers. 

Of the 5,416 total acres within the project boundary, approximately 2,920 acres were analyzed as 

areas where some form(s) of treatment are proposed (so named as treatment areas). The 

remaining 2,496 acres have no treatments proposed due to slopes greater than 35 percent, 

standard and guideline limitations on treatment and/or no treatment is needed to meet the purpose 

and need.

In Alternative 3, the treatments would include:

 Commercial and biomass thin an estimated 760 acres of approximately 90-110 year old 

natural conifer stands (within T areas, except T4); 

 Commercial and biomass thin an estimated 65 acres of approximately 45 year old 

ponderosa pine plantations (within T areas);

 Biomass thin an estimated 240 acres of approximately 70-90 year old natural 4 to 10 inch 

dbh conifer stands (within T areas);

 Pre-commercial hand thin and remove fuel ladders, hand pile and burn on approximately 

17 acres (within T 5 and M2);

 Pre-commercial thin, tractor pile and burn approximately 30 acres of natural conifer

stands (within T areas);

 Masticate brush fields and masticate pre-commercial thin reproduction areas on 

approximately 245 acres (within T areas);

 Masticate brush fields, masticate fuel ladders, and masticate pre-commercially thin 

reproduction areas on approximately 395 acres (M areas);

 Perform fuelbreak maintenance on approximately 40 acres (M4);

 Pre-commercial thin/release plantations on approximately 115 acres (M10 (part), M11, 

16, 24, and 25, portions of T6, 7, and 35); 

 Plant and hand release site prepared openings on approximately 40 acres;

 Prescribed understory burn, as a primary fuels treatment, approximately 215 acres;

 Maintenance on approximately 28.2 miles of NFTS road;

 Reconstruction on approximately 9.8 miles of NFTS road;
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 2 15

 Construct approximately 0.5 miles of temporary road;

 Construct approximately 0.2 miles of new system road; and

 Prescribe burn and/or manually treat infestations of noxious weeds, where located within 

the project treatment areas, with the goal of eradication and prevention of their spread.

Though a total of 2,920 acres are analyzed for treatments listed above, design criteria common to 

all alternatives and standards and guidelines from SNFPA ROD (USDA-FS 2004b) dictate areas 

where treatment cannot occur to reduce and/or eliminate adverse effects on particular resources. 

These can include, but are not limited to cultural resources areas, botanical species areas, wildlife 

habitat areas, and aquatic species areas. It is estimated that excluding these control areas from the 

treatment areas where no treatment will occur, a total of 1,908 acres will remain for treatments as 

proposed.

Alternative 4 – Lower and Limited Mid-Level Canopy 

Treatments, All Treatment Areas 

In Alternative 4, treatment areas would remain the same as in Alternative 2. This alternative 

would not amend the SNF LRMP/SNFPA ROD (USDA-FS 1992; 2004b) Standard and 

Guideline #86. Treatments within designated Pacific fisher densite buffers would be limited to 

mechanical clearing of fuels (ladder and surface fuels) needed to meet the fire/fuels objectives 

within a WUI zone. Because of the extent of area within the Sugar Pine Adaptive Management 

Project boundary that is designated as Pacific fisher densite buffer, this alternative assumes that 

the entire Sugar Pine Adaptive Management Project boundary is considered Pacific fisher densite 

buffer and treatments are designed accordingly, with no vegetation treatments designed to meet 

for forest health objectives being included. 

Of the 5,416 total acres within the project boundary, approximately 2,920 acres were analyzed as 

areas where some form(s) of treatment are proposed (so named as treatment areas). The 

remaining 2,496 acres have no treatments proposed due to slopes greater than 35 percent, 

standard and guideline limitations on treatment and/or no treatment is needed to meet the purpose 

and need.

In Alternative 4, the treatments would include:

 Biomass thin (fuel ladder reduction) an estimated 1,065 acres of approximately 70-90 

year old natural conifer stands (within T areas);

 Pre-commercially hand thin and remove fuel ladders, hand pile and burn on 

approximately 17 acres (within T 5 and M2, see map);

 Pre-commercially thin, tractor pile and burn approximately 30 acres of natural conifer

stands (within T areas, see map);

 Masticate brush fields and masticate pre-commercial thin reproduction areas on 

approximately 245 acres (within T areas, see map); 

 Masticate brush fields, masticate fuel ladders, and masticate pre-commercially thin 

reproduction areas on approximately 395 acres (M areas, see map);

 Perform fuelbreak maintenance on approximately 40 acres (M4, see map);

 Pre-commercially thin/release plantations on approximately 115 acres (M10 (part), M11, 

16, 24, and 25, portions of T6, 7, and 35, see map); 
Chapter 2: Alternatives, Including the Proposed Action

16 Sierra National Forest

 Plant and hand release site prepared openings on approximately 40 acres;

 Prescribed understory burn, as a primary fuels treatment, approximately 215 acres;

 Maintenance on approximately 28.2 miles of NFTS road;

 Reconstruction on approximately 9.8 miles of NFTS road;

 Construct approximately 0.5 miles of temporary road;

 Construct approximately 0.2 miles of new system road;

 Prescribe burn and/or manually treat infestations of noxious weeds, where located within 

the project treatment areas, with the goal of eradication and prevention of their spread.

Though a total of 2,920 acres are analyzed for treatments listed above, design criteria common to 

all alternatives and standards and guidelines from SNFPA ROD (USDA-FS 2004b) dictate areas 

where treatment cannot occur to reduce and/or eliminate adverse effects on particular resources. 

These can include, but are not limited to heritage resources areas, botanical species areas, wildlife 

habitat areas, and aquatic species areas. It is estimated that excluding these control areas from the 

treatment areas where no treatment will occur, a total of 1,908 acres will remain for treatments as 

proposed.

Design Criteria Common to All Action Alternatives

The design criteria listed by resource area below are included and are an integral part of each 

action alternative analyzed in detail within this document. They direct the design of treatment 

areas, the design of treatment types and/or are direction to follow during implementation. In 

listing these as part of all action alternatives, they are considered when analyzing the direct, 

indirect and cumulative effects of each alternative and are used to minimize potential 

environmental impacts of the management actions proposed by alternatives. As listed, they can 

be direct SNF LRMP (USDA-FS 1992) and SNFPA ROD (USDA-FS 2004b) Standard and 

Guidelines (S&G); Forest Service Manual/Handbook directions; Best Management Practices 

(BMP); based on past implementation experience; legal requirements; and/or based on ―best 

science available‖ where they are used in addition to standards and guidelines.

Cultural Resources

Procedures and standard protection measures from the Programmatic Agreement Among the 

U.S.D.A. Forest Service, Pacific Southwest Region, California State Historic Preservation 

Officer, and Advisory Council on Historic Preservation Regarding the Identification, Evaluation 

and Treatment of Historic Properties Managed by the National Forests of the Sierra Nevada, 

California (the Sierran PA) will be utilized for the protection of Heritage Resources within the 

project area. The primary protection measure will be avoidance, but additional measures, such as 

directional felling and monitoring can be used to minimize potential effects.

Botany: Rare and Noxious Weeds

Project design criteria for protection of Forest Service sensitive plants (Project specific 

implementation of SNF LRMP (USDA-FS 1992) and SNFPA ROD (USDA-FS 2004b) S&G‘s

and Endangered Species Act requirements):

a. All known lady‘s slipper orchid populations will be flagged for avoidance unless they 

occur in streamside management zones where no management activities will occur. 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 2 17

b. Populations of short-leafed hulsea that occur along Forest Roads 5S22Y and 5S06 will be 

flagged for avoidance prior to project implementation. 

Project design criteria for prevention of spread of noxious weeds (SNFPA ROD (USDA-FS 

2004b) S&G, pages 54-55): 

a. All heavy equipment used for implementing the project will be washed before arriving on 

site to remove soil and seeds of noxious weeds so that they are not transported into the 

project area.

b. Infestations of foxglove, klamathweed, oxeye daisy, broom, and bull thistle will be 

removed prior to project implementation, and a buffer zone will be flagged for avoidance 

to prevent heavy equipment from transporting seeds in the soil to other areas within the 

project boundary and beyond. 

c. Any plantings or straw used for erosion control will be approved by the Forest Botanist to 

minimize the likelihood of accidental introduction of noxious weeds and to ensure 

compliance with the FS Pacific Southwest Region Native Plant Policy.

Geology/Soils

1. Leave a 100-foot wide buffer of 100 percent soil cover below large rock outcrops. These 

areas have a high potential to generate runoff that can cause accelerated erosion on soils 

down slope (FS Handbook).

2. Conduct mechanical equipment operations (mechanical thinning and biomass removal 

equipment, log skidders and tractor-piling operations) when the soil is sufficiently dry in the 

top 12 inches to prevent unacceptable loss of soil porosity (soil compaction). Field checking 

by a soil scientist would be done to determine if operations could continue under moist soil 

conditions. ―Maintain 90% of the soil porosity over 85% of an activity area (stand) found 

under natural conditions.‖ (BMP; FS Handbook)

3. Subsoil and water bar skid roads and trails in areas where soil compaction exceeds 15% of a 

treatment area. (BMP; FS Handbook)

4. Limit mechanical operations, where sustained slopes exceed 35%, except where supported by 

on-the-ground interdisciplinary team evaluation (FS Handbook; SNF LRMP S&G).

5. Maintain 50% soil cover over all treatment areas. Where shrub species predominate, attempt 

crushing before piling to create small woody fragments left scattered over the site for soil 

cover and erosion protection (FS Handbook; SNF LRMP S&G).

6. Maintain at least five well-distributed logs per acre as large woody debris (LWD) 

representing the range of decomposition classes defined in the Regional Soil Quality 

Standards and Guidelines (SNF LRMP and SNFPA ROD S&G).

7. Provide for road surface stabilization (gravel) on roads over 5% grade that are located on 

sensitive soils, including Holland and Musick soils (SNF LRMP S&G #129) and are affecting 

soil productivity and/or water quality.

Lands/Special Uses

There are numerous land type special uses authorized under permit in the project area including 

water systems (spring developments, water lines and storage tanks), buried fiber optic and 

telephone lines, a telephone carrier site near Sugar Pine, the Madera Irrigation District gauging 

station, overhead and buried electrical lines, roads, and apiary sites. These Special Use areas are 
Chapter 2: Alternatives, Including the Proposed Action

18 Sierra National Forest

shown in Map 6 in Map Package. Based on past experience and to minimize potential negative 

effects to permitted special uses and associated infrastructure associated with them.

a. To provide a measure of protection, permit holders will be responsible for identifying the 

location(s) of their authorized improvements and/or right-of-ways so they are clearly 

visible during project implementation. Holders shall identify their improvements by using 

a combination of flagging and surveyors stakes; holders shall print their name and contact 

phone numbers on the flagging/stakes with indelible ink that is capable of lasting several 

years. 

b. Roads authorized under permit that are damaged by project activities will be repaired by 

the operator(s) to pre-project condition.

c. The Madera Irrigation District Ditch is located in Treatment Areas T15 and M5 where 

mastication would occur. The Ditch has been in use for over 150 years, and a riparian

vegetation type has developed along the banks of the ditch. There should be a minimum 

setback of 25 feet on either side of the ditch where the use of mechanical equipment 

should be restricted, or project activities are limited to the hand removal of brush. All 

slash that enters the ditch resulting from project activities will be removed by the end of 

the days operating period by the operator to prevent blockage of the ditch. 

Recreation special uses authorized under permit in the project area include the Yosemite 

Mountain Sugar Pine Railroad (YMSRR) and Yosemite Trails Pack Station (YTPS). The 

YMSRR improvements located within their permit area include the railroad right-of-way, office, 

parking areas, amphitheater, bathroom, seating areas, etc. These are easily identifiable and should 

be avoided during project activities. The YMSRR operates the railroad 6 months a year between 

March and October; however, their peak visitor season is between June and mid-August. Project 

activities would occur adjacent to and within the permit area. 

a. During project implementation various contractors and/or operators may need to cross the 

railroad tracks to gain access to treatment units. The Bass Lake Ranger District will 

identify the locations where rail crossings need to occur; and will work with the owner of 

YMSRR to design and construct the crossings to ensure heavy equipment does not 

damage the rail system during project implementation.

b. The district will work with the owner of YMSRR to minimize interruptions to YMSRR 

operations during Project implementation. 

c. Contractors and/or operators will provide advance notification to the YMSRR when 

Project activities occur adjacent to the right-of-way and/or permit area, and advise the 

YMSRR when Project activities may result in a delay of YMSRR operations.

d. Contractors and/or operators will remove all activity slash generated from project 

activities that land on the railroad tracks and/or within the railroad right-of-way. The 

contractor and/or operator will provide a spotter, whose responsibility is to remove slash 

from the tracks and right-of-way concurrent with the operation, or as soon as project 

activities cease, and the right-of-way is safe to enter.

The YTPS offers horseback rides three seasons of the year from their pack station headquarters 

adjacent to Big Sandy road, and offers horse driven sleigh rides from a secondary location south 

of Tenaya Lodge during winter months when snow conditions are favorable. The YTPS is 

authorized to use and maintain many of the horseback riding trails they take their clients on. 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 2 19

Trails used by YTPS and the Lewis Creek Recreation Trail may need to be crossed with 

equipment by operators to gain access to units. These trails are identified in the project folder and 

on the map entitled ―Special Uses‖ within the Sugar Pine Project.

a. All project-related equipment will cross at locations perpendicular to identified recreation 

trails. 

b. All slash will be pulled out of and away from trails. Activity fuels and slash will not be 

piled or treated within 5 feet of those trails. 

Wildlife – Terrestrial

1. Limited Operating Periods (LOPs) (SNFPA ROD, pgs. 37-39)

Should surveys locate activity centers or active nests for California spotted owls or Northern 

goshawks, LOPs will be applied within a 1⁄4 mile radius of the activity center or nest. All 

areas within the project area have been surveyed to Regional Protocol for California Spotted 

owl and Northern Goshawk. Should a great gray owl nest be located, nesting location will be 

protected by an LOP. The district biologist will be notified when a nest or den of any 

Threatened (T) Endangered (E), Candidate (C), Proposed (P), or Forest Service sensitive

species is discovered within or adjacent to a treatment area and an LOP would be established 

for that nest area. 

2. Snags and Down Woody Material (SNFPA ROD, Pg. 51-52): 

Down Woody Material (S&G #10): ―Determine down woody material retention levels on an 

individual project basis, based on desired conditions. Emphasize retention of wood in the 

largest size classes and in decay classes 1, 2, and 3. Consider the effects of follow-up 

prescribed fire in achieving desired down woody material retention levels.‖ This will be met 

by maintaining at least five well-distributed logs per acre as large woody debris (LWD) 

representing the range of decomposition classes from the Geology/Soils design criteria 

throughout the implementation of this project.

Snag Retention (S&G #11): ―Design projects to implement and sustain a generally 

continuous supply of snags and live decadent trees suitable for cavity nesting wildlife across 

a landscape. Retain some mid- and large-diameter live trees that are currently in decline, have 

substantial wood defect, or that have desirable characteristics (teakettle branches, large 

diameter broken top, large cavities in the bole) to serve as future replacement snags and to 

provide nesting structure. When determining snag retention levels and locations, consider 

land allocation, desired condition, landscape position, potential prescribed burning and fire 

suppression line locations, and site conditions (such as riparian areas and ridge tops) avoiding 

uniformity across large areas.

The general guidelines for large-snag retention are as follows:

 Westside mixed conifer and ponderosa pine types – four of the largest snags 

per acre.

 Use snags larger than 15 inches dbh to meet this guideline. Snags should be 

clumped and distributed irregularly across the treatment areas. Consider 

leaving fewer snags strategically located in treatment areas within the WUI. 

When some snags are expected to be lost due to hazard removal or the effects 

of prescribed fire, consider these potential losses during project planning to 

achieve desired snag retention levels.‖
Chapter 2: Alternatives, Including the Proposed Action

20 Sierra National Forest

Snag Felling: Snags can be felled only if they meet the definition of a danger tree (as 

described in the Engineering Design Criteria), have the potential to fall across prescribed fire 

control lines, and/or pose a threat to firefighter safety during prescribed fire implementation. 

Snags that meet this definition and are felled during project implementation will be retained 

on site for down woody debris. All snags not meeting these criteria will remain as standing 

snags within the project area.

2. Protected Activity Centers (PACs) and Home Range Core Area (HRCA) treatments

(SNFPA ROD, page 40): Where treatments will occur within PACs aim to maintain >70% 

canopy closure where available. Where treatments will occur within HRCAs aim to maintain 

>60% canopy closure where available.

3. Pacific Fisher Specific Design Criteria (SNFPA ROD, pgs 39 & 61-62):

Den Site Designation, Standards and Guidelines

―Fisher densites are 700-acre buffers consisting of the highest quality habitat (CWHR size 

class 4 or greater and canopy cover greater than 60 percent) in a compact arrangement 

surrounding verified fisher birthing and kit rearing dens in the largest, most contiguous 

blocks available.‖ 

―Protect fisher den site buffers from disturbance with a limited operating period (LOP) from 

March 1 through June 30 for vegetation treatments as long as habitat remains suitable or until 

another Regionally-approved management strategy is implemented. The LOP may be waived 

for individual projects of limited scope and duration, when a biological evaluation documents 

that such projects are unlikely to result in breeding disturbance considering their intensity, 

duration, timing, and specific location.‖ (S&G #85)

―Avoid fuel treatments in fisher den site buffers to the extent possible. If areas within den 

site buffers must be treated to achieve fuels objectives for the urban wildland intermix zone, 

limit treatments to mechanical clearing of fuels. Treat ladder and surface fuels to achieve 

fuels objectives. Use piling or mastication to treat surface fuels during initial treatment. 

Burning of piled debris is allowed. Prescribed fire may be used to treat fuels if no other 

reasonable alternative exists.‖ (S&G #86)

Additional Design Criteria for Pacific Fisher

―Prior to vegetation treatments, design measures to protect important habitat structures as 

identified by the wildlife biologist, such as large diameter snags and oaks, patches of dense 

large trees typically 1⁄4 to 2 acres, large trees with cavities for nesting, clumps of small 

understory trees, and coarse woody material. For example, use firing patterns, place fire lines 

around snags and large logs, and implement other prescribed burning techniques to minimize 

effects to these attributes. Use mechanical treatments when appropriate to minimize effects 

on preferred fisher habitat elements.‖ (S&G #90)

―Assess the potential impact of projects on the connectivity of habitat for old forest 

associated species‖ (S&G #28) 

―Consider retaining forested linkages (with canopy cover greater than 40 percent) that are 

interconnected via riparian areas and ridgetop saddles during project-level analysis‖ (S&G 

#29)
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 2 21

The following Design Criteria have been developed to protect, maintain, and/or enhance

important Pacific fisher habitat elements for all action alternatives and are based on 

information from Spencer 2008: Baseline Evaluation of Fisher Habitat and Population Status 

and Effects of Fires and Fuels Management on Fishers In the Southern Sierra Nevada, Final 

Report to USDA Forest Service, Pacific Southwest Region; North et. al. 2009: An Ecosystem 

Management Strategy for Sierran Mixed-Conifer Forests and Sierra Nevada Adaptive 

Management Study Integration Team discussions/fieldtrips.

 Maintain highest canopy cover possible to meet the prescription within stands, aim for 

50-60% immediately post-harvest.

 Thinning will not remove any trees larger than 30-inch dbh (SNFPA ROD, pg. 50). 

 Protect all suitable fisher denning habitat with a Limited Operating Period (LOP) from 

March 1 through June 30. Map 7 in the Map Package shows specific treatment areas 

with suitable fisher denning habitat and where the LOP will be implemented.

 Retain groups of larger trees (greater than 20-inch dbh) at the rate of approximately one 

group per 2.5 to 3.5 acres. Ideally these groups would contain ―defect‖ trees, those that 

have cavity and platform creating defects (mistletoe, rot, fork topped, broken limbs and 

tops) for den and rest sites. These groups are being retained to maintain habitat 

heterogeneity throughout the treatment areas. 

 Snag and Down Woody Material retention will meet the criteria listed in Criteria #2

(page 19-20).

 Standard and Guidelines #28 and #29 provide guidance for developing and maintaining 

adequate habitat connectivity within riparian areas. Recent studies (Spencer, 2008; 

North, et.al., 2009) have also shown that fisher utilize riparian areas as travel corridors 

between high quality habitat. To provide for this habitat connectivity, design criteria 

have been developed to incorporate and expand upon established riparian area

management zones; i.e. Streamside Management Zones (SMZ) and Riparian 

Management Areas (RMA) associated with perennial streams (Class I). The forest 

wildlife biologists have termed these zones Old Forest Linkages (OFL). They incorporate 

and expand upon the measures required for SMZs and RMAs. OFLs consist of buffers 

measuring 300 feet total on either side of perennial streams. Design criteria for these Old 

Forest Linkages are detailed in the table and figure below.

 For perennial streams (Class I) within the project area:
Chapter 2: Alternatives, Including the Proposed Action

22 Sierra National Forest

Distance from 

Stream* 

Vegetation Management Activities 

Allowed within zone Zone Designation

0-50 feet No Activities Allowed SMZ/RMA/OFL

50-100 feet

No ground disturbing equipment 

allowed into area (dozers, skidders, 

etc.) Activities allowed include handfelling of trees smaller than 12‖dbh, 

pile-burning, and equipment reach-in 

with boom arm. Canopy cover is to 

remain ≥60%.

SMZ/RMA/OFL

100-150 feet

Mechanical entry is allowed. Trees 

≤12‖ dbh may be removed for fire 

and fuels reduction purposes by 

equipment. Canopy cover is to 

remain ≥60%.

OFL

150-300 feet

Mechanical entry is allowed. 

Thinning from below will occur. 

Canopy cover is to remain ≥60%.

OFL

*Distance from Stream for Activities is measured and applied to each side of the stream from bank-full left 

and bank-full right.

Figure 1. Associated Zones and Treatments within Old Forest Linkages 

 Oaks: Recent studies (see reference listed in Additional Design Criteria for Pacific 

Fisher beginning paragraphs on page 21) have shown that oaks are an important habitat 

element for denning and resting sites. Project surveys revealed that oaks in the project 

area tended to show evidence of cavity development once they had reach 20 inches in 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 2 23

diameter or greater. Although no oaks are proposed for removal within this project, to 

maintain hiding cover for fisher and their prey, a buffer of 35 feet from the bole or to 

dripline whichever is greater around 2-3 black oaks >20-inch dbh per acre will have no 

vegetation treatment occurring.

 Shrub Cover and Understory Diversity: Shrub and understory will be retained 

throughout the project area on a total of 3,458 acres of the 5,416 total project boundary 

acres. This understory diversity will be maintained in Old Forest Linkages associated 

with riparian areas (cooler, moister sites); oak buffer areas; as well as areas where no 

treatment will be conducted such as cultural resource sites, botanical areas, and steep and 

rocky areas. Species associated with riparian areas, such as dogwoods, alders, and 

willows will not be removed.

 Remove unneeded roads in high quality fisher habitat.

 The district wildlife biologist will be notified immediately if any den site(s) are located 

within or adjacent to a treatment area and protection measures will be implemented.

Wildlife – Aquatics

Follow all applicable aquatic wildlife species and riparian habitat standards and guidelines from 

the 2004 Sierra Nevada Forest Plan Amendment, Final Supplemental Impact Statement and 

Record of Decision (USDA-FS 2004b), the existing Sierra National Forest Land and Resource 

Management Plan direction (USDA-FS 1992), Forest Service handbook (FSH) 2509.22 Sierra 

Supplement #1 for treatments within Streamside Management Zones (SMZ, USDA 1989), Best 

Management Practices and other applicable laws and regulations (USDA-FS 2000a). Generalized 

SMZ designation is outline in Table 1.

The Sierra Nevada Forest Plan Amendment (USDA-FS 2001b, amended 2004b) provides an 

Aquatic Management Strategy (AMS). The fundamental principle of the AMS is to retain, 

restore, and protect the processes and landforms that provide habitat for aquatic and ripariandependent organisms, and produce and deliver high-quality waters. The AMS includes 

designation of Riparian Conservation Areas (RCAs). RCAs are designated along streams and 

around water bodies and are areas for specific management direction and analysis, as described 

below (USDA-FS 2004b). RCA consistency with the AMS was evaluated under the project 

Riparian Conservation Objective Consistency Analysis (Strand, Stone, Gallegos, Clines, 2009).
Chapter 2: Alternatives, Including the Proposed Action

24 Sierra National Forest

Table 1. Summary of Relationship between Feature Types, RCA Widths, Stream Classes, 

SMZ Widths, RMA Widths, and Stream Orders (and other GIS data)

Feature Type RCA 

Width

Stream 

Class

SMZ Width RMA 

Width

Corresponding 

GIS Layer 

Stream Order

Perennial Streams 300 feet I At least 100 ft 100 feet 4+

Seasonally Flowing 

Streams 

150 feet II At least 75 ft N/A 3

III At least 50 ft 2

IV At least 25 ft 1

V None required -

Streams in Inner Gorge Top of 

inner 

gorge

Varies

Special Aquatic Features 

(fens, bogs, springs, 

seeps, lakes, ponds, 

wetlands, etc.)

300 feet N/A N/A 100 feet Either identified on 

GIS layers 

(meadows, springs, 

lakes), or identified 

in the field

1. Class I SMZs are within or adjacent to treatment areas: T4, T5, T7, T8, T9, T10, T11, T13, 

T14, T15, T23, T24, T26, T32, T33, M2, M5, M6, M7, M8, M10, M9, M11, M12, M13, 

M16, M24, M25, Rx 1, Rx 3, and Rx 5. Old Forest Linkage Prescriptions apply to these 

SMZs. No treatments within inner 50 feet from stream bank.

2. Protect any Special Aquatic Features (seeps, springs, bogs, fens, and/or wet areas) that may 

be found during project implementation that are not already identified on project analysis 

maps. Treat these areas as perennial (Class I) areas with 300 foot Riparian Conservation 

Areas (RCAs). This includes treatment areas: T3, T4, T7, T26, T30, T32, T33, T34, M11, and 

M16.

3. Within 50-100 feet distance from either side of Class I perennial stream (SMZs), reduce fuel 

loading by:

a. Removing vegetation < 12 inches in diameter;

b. Hand-piling slash as necessary to reduce the effects of under-burning;

4. Apply SMZs as mapped in Project Hydrology report (Stone, K. 2009).

5. General aquatic species and riparian habitat protection measures are:

a. Do not allow mechanical equipment within 100 feet of meadows or other special aquatic

features. Includes treatment areas: T3, T4, T7, T26, T30, T32, T33, T34, M11, and M16.

b. Do not allow mechanical equipment within SMZ.

c. To protect bank stability, do not cut streambank trees (trees with drip line extending to or 

over edge of streambank). 

d. Do not cut any tree located within a channel.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 2 25

e. For water drafting, use a screened intake device and pumps with low entry velocity to 

minimize removal of aquatic species, including juvenile fish, amphibian egg masses and 

tadpoles, from aquatic habitats. A Hydrologist and Aquatic Biologist would approve 

water-drafting sites. See Best Management Practices (BMP) 2-21 in Appendix B for 

specific requirements.

f. Monitor potential project effects to streams and aquatic habitat using the Region 5 (R5) 

Stream-Condition Inventory protocols (Frazier et al. 2005).

g. When lighting piles, start burn from one end only to allow escape route for any species 

inhabiting piles.

h. No lighting into SMZs, but fire can creep into zone.

6. Report any discovery of amphibians or reptiles (e.g. frogs, toads, salamanders, and turtles) 

during project sale preparation and implementation to the district biologist immediately.

7. If newly listed or unknown occurrences of Federally listed threatened, endangered, proposed, 

candidate or Forest Service sensitive aquatic species are found within the affected project 

area during sale preparation and implementation, additional species protection measures may 

need to be imposed by the district fisheries and aquatic biologist. 

Hydrology

Project specific Best Management Practices, listed in Appendix B of this document, will be 

implemented (FS Handbook).

Silviculture

A limited operating period would be imposed in well stocked stands heavy to fir (over 50% fir) 

where operations could begin August 1st or later when the sap is not running (fir bark is much 

more easily dislodged when the sap is running than later in the year). The District Silviculturist 

will determine which stands require a LOP during the thinning layout phase.

Based on SNFPA ROD (USDA-FS 2004b) S&Gs for mechanical treatments, as well as design 

criteria, silvicultural prescriptions will be written utilizing thinning from below techniques with 

basal area levels for stand species composition.

Fuels

The utilization of prescribed fire is considered a viable treatment in all treatment areas within the 

project boundary, as either a primary treatment to maintain appropriate levels of surface and 

ladder fuels to meet fire and fuels objectives (RX treatment areas), as a follow-up treatment 

needed to further reduce surface and ladder fuels, and/or as a maintenance treatment. To reduce 

the potential impacts (fire effects) that may occur with the implementation of prescribed fire, the 

following criteria would need to be considered in the designation of areas where prescribed fire 

would be used: 

1. In treatment areas designated with a (M), Map 1 in the Map Package, prescribed fire should 

first be considered where it is too steep and /or rocky for the masticator to work effectively, 

oak dominates the stand and/or as a maintenance treatment in areas where brush re-growth 

has not been slowed and have not been planted with conifers.

2. In treatment areas designated with a (T), Map 1 in the Map Package, prescribed fire should 

first be considered where there are larger residual trees (of size less susceptible to fire 

damage) with light fuel loadings, areas not being thinned due to steepness, follow-up 
Chapter 2: Alternatives, Including the Proposed Action

26 Sierra National Forest

treatments have been completed or are not required, and/or areas where conifer reproduction 

is not being used for re-generation of openings.

3. Prescribed fire should be used during the late fall, winter or early spring, to minimize effects 

to trees during active growing period and within Pacific fisher denning habitat areas.

Engineering

1. Maintain all National Forest Transportation System (NFTS) roads to standards established in 

the Forest Service Handbook 7709.58. Perform road maintenance, reconstruction and new 

road construction activities to support project access needs. Insure drainage structures are 

functional and stable to prevent potential resource damage and degradation of water quality

(SNF LRMP S&G #78, #79, #124, #206 and BMPs).

2. Perform a final field review of project roads to determine reconstruction needs prior to 

project activities. Where economically feasible, place aggregate on existing native surface 

roads located in areas with High and very High Soil Erosion Hazard ratings (SNF LRMP 

S&G #129). 

3. Close temporary roads required for unit access upon completion of use; remove all culverts, 

rip and ditch landings, construct waterbars, block the entrance with a log and dirt berm, and 

disguise the entrance with brush to discourage additional traffic.

4. Roadways will be managed for safe passage by road users. This will include the management 

of hazards associated with roadside vegetation, including the identification and mitigation of 

danger (hazard) trees. A danger tree, as defined in Forest Service Handbook (FSH) 7709.59, 

Chapter 40, is a standing tree (live or dead) that presents a hazard to people due to conditions 

such as, but not limited to, deterioration or physical damage to the root system, trunk, stem, 

or limbs and the direction of lean of the tree (FSH 6709.11, Glossary). Selection criteria 

guidelines for the marking and removal of danger trees will be tiered to the Bass Lake Ranger 

District Hazard Tree Environmental Assessment, Appendix X (USDA-FS 2006a). 

Alternatives Considered but Eliminated from 

Detailed Study ______________________________

Federal agencies are required 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 need for the proposal, 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.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 2 27

Alternatives based on varying the upper diameter limit 

(currently 30-inch dbh) for mechanical thinning to 

ensure a 50 to 60% plus canopy cover is maintained and 

by which wildfire intensity and spread are reduced

The purpose and need for this project is not solely focused on the reduction of wildfire intensity 

and spread into and out of WUI, but includes the need to maintain sustainable forested stands by 

reducing stand density. In considering this alternative, it was determined that it incorporated 

many of the same concerns for the proposed action as were made in the issue listed on page 7, in 

particular, the need to maintain high canopy cover. In bringing forward Alternatives #3 and #4 for 

detailed study, as well as design criteria incorporated to address the issue listed on page 7, the 

effects of varying stand density treatments as they relate to meeting the purpose and need for 

fire/fuels objectives and forest health objectives is addressed. It was determined that any 

alternative based on varying upper diameter limits for mechanical thinning would measure the 

same effects as these two additional alternatives and would be duplicative.
Chapter 2: Alternatives, Including the Proposed Action

28 Sierra National Forest

Comparison of Alternatives ___________________

This table provides a brief summary of the alternatives and their environmental impacts in comparative format.

Table 2. Comparison of Alternatives

Measure or Effect

Alternative 1 – No 

Action

Alternative 2 – Proposed 

Action Alternative 3 Alternative 4

Total Project Area =5,416 acres; Total Acres Analyzed in Treatment Areas = 2,920

Estimated Acres by Alternative to be Treated by Treatment Area Type:

Thinninng 0 Acres 1,356 Acres (Commercial 

Thin= 914 acres; 

biomass/mast/precommercial 

thin= 432 acres; hand thin=10 

acres)

1,356 Acres (Commercial 

Thin = 824 acres; biomass/

mast/ precommercial thin = 

522 acres; hand thin = 10 

acres)

1,356 Acres 

(Commercial Thin= 66 

acres in plantations; 

biomass/mast/precomm

ercial thin= 1,280 acres; 

hand thin=10 acres)

Mastication 0 Acres 532 acres 532 acres 532 acres

Prescribed Fire

(Rx treatment areas)

0 Acres 215 acres 215 acres 215 acres

Miles of Road

Maintenance 0 28.2 28.2 28.2

Reconstruction 0 9.8 9.8 9.8

Temporary 0 0.5 0.5 0.5

New Road 0 0.2 0.2 0.2

Fire/Fuels Objectives: Fire behavior spread and intensity is reduced as measured by crown fire potential is highly unlikely and non-sustainable; flame 

lengths < 4 feet; Rate of Spread 50% of pre-treatment; line construction rates are doubled from pre-treatment (SNFPA ROD (USDA-FS 2004b))

Measures: Brush 

Areas

ForestMod. To 

Heavy Fuel 

level Areas

ForestHeavy Fuel

levels

Forest 

areasthinned

Heavy 

Fuels

Forest 

areasthinned

Fuels 

treated

Forest 

areasthinned

Fuels 

treated

Forest 

areasthinned

Heavy 

Fuels

Forest 

areasthinned

Fuels 

treated

Forest 

areasthinned

Fuels 

treated

Forest 

areasthinned

Heavy 

Fuels

Forest 

areasthinned

Fuels 

treated

Forest 

areasthinned

Fuels 

treated

Fuel Model (Resultant) 4 10 12 12 TU1 9 12 TU1 9 12 TU1 9
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 2 29

Measure or Effect

Alternative 1 – No 

Action

Alternative 2 – Proposed 

Action Alternative 3 Alternative 4

Predicted Rate of 

Spread (chains/hour)

92 10 16 11 8 6 11 8 6 11 8 6

Predicted Flame Length 

(feet)

23 6 10 8 3 3 8 3 3 8 3 3

Predicted Fireline 

Intensity (BTU/ft2)

5131 282 781 531 63 47 531 63 47 531 63 47

Predicted Crown Fire 

Potential (Yes/No; 

Type) 

Y/ 

Crowning

Y/ 

Crowning

Y/ 

Crowning

Y/ 

Torching

N/ 

Surface

N/ 

Surface

Y/ 

Torching

N/ 

Surface

N/ 

Surface

Y/ 

Torching

N/ 

Surface

N/ 

Surface

Resistance to Control 

(High, Moderate, Low)

High High High High Low Low High Low Low High Low Low

Forest Health Objectives: Reduce stand densities and improve tree vigor and overall forest health. Measured Desired Stocking levels by Species:

Pine= 135 ft2/acre; White Fir= 240 ft2/acre; Mixed Conifer= 210 ft2/acre (SNFPA ROD (USDA-FS 2004b)). 

Estimated Range of 

Basal Area Remaining 

(ft2/acre) for >5-inch

dbh conifers

130 to 480 ft2/acre (all 

species)

130 to 330 ft2/acre (all 

species) 

130 to 330 ft2/acre (all 

species)

(Den site buffer area would 

be changed from estimated 

range BA remaining of 130 

to 190 ft2/acre to 130 to 310

ft2/acre with this 

Alternative) 

130-480 ft2/acre (all 

species)

Estimated Range of 

Stems per Acre 

Remaining for >5-inch

dbh conifers (# 

trees/acre)

= 65 to 251 trees/acre (all 

species)

44 to 101 trees/acre 50-142 trees/acre (all 

species) (Den site buffer 

area would be changed from 

estimated range Stems/Acre 

remaining of 57 to 84 to 66 

to 142 trees/acre)

66 to 153 trees/acre (all 

species)
Chapter 2: Alternatives, Including the Proposed Action

30 Sierra National Forest

Measure or Effect

Alternative 1 – No 

Action

Alternative 2 – Proposed 

Action Alternative 3 Alternative 4

Habitat Indicators (From Issue, page 7):

Estimated Range of 

Average Canopy Cover 

Remaining (%)

39 to 100% Average= 69% 39 to 88%; Average= 57% 39 to 97%; Average= 58% 39 to 100%; Average= 

69% 

Estimated Average Tree 

Diameter Removed 

(inches at dbh)

N/A 11 to 20-inch dbh 11 to 20-inch dbh

(Treatment Area 4 would be 

changed from 11 to 20-inch 

dbh to 5 to 10-inch dbh with 

this alternative)

5 to 10-inch dbh

Large Snag and Down 

Wood Standard for 

Treated Areas

N/A Listed in Design Criteria 

Common to All Alternatives 

(pages 10-18)

Listed in Design Criteria 

Common to All Alternatives 

(pages 10-18)

Listed in Design 

Criteria Common to All 

Alternatives (pages 10-

18)

Movement Corridors 

Addressed (Yes or No)

Yes, with assumption 

corridors are present 

currently

Yes, addressed as Old Forest 

Linkage Areas on page 14.

Yes, addressed as Old 

Forest Linkage Areas on 

page 14.

Yes, addressed as Old 

Forest Linkage Areas 

on page 14.
Sierra National Forest – Chapter 3 31

Chapter 3. Affected Environment and 

Environmental Consequences

This chapter describes aspects of the environment likely to be affected by the proposed action and 

alternatives. Also described are the environmental effects (direct, indirect, and cumulative) that 

would result from undertaking the proposed action or other alternatives. Together, these 

descriptions form the scientific and analytical basis for the comparison of effects in chapter 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). 

In order to understand the contributions of past actions to the cumulative effects of the proposed 

action and alternatives, this analysis relies on current environmental conditions as a proxy for the 

impacts of past actions. This is because existing conditions reflect the aggregate impact of all 

prior human actions and natural events that have affected the environment and might contribute to 

cumulative effects.

This cumulative effects analysis does not attempt to quantify the effects of past human actions by 

adding up all prior actions on an action-by-action basis. There are several reasons for not taking 

this approach. First, a catalog and analysis of all past actions would be impractical to compile and 

unduly costly to obtain. Current conditions have been impacted by innumerable actions over the 

last century (and beyond), and trying to isolate the individual actions that continue to have 

residual impacts would nearly be impossible. Second, providing the details of past actions on an

individual basis would not predict the cumulative effects of the proposed action or alternatives. In 

fact, focusing on individual actions would be less accurate than looking at existing conditions, 

because there is limited information on the environmental impacts of individual past actions, and 

one cannot reasonably identify each and every action over the last century that has contributed to 

current conditions. Additionally, focusing on the impacts of past human actions risks ignoring the 

important residual effects of past natural events, which may contribute to cumulative effects just 

as much as human actions have. Third, public scoping for this project did not identify any public 

interest or need for detailed information on individual past actions. Finally, the Council on 

Environmental Quality issued an interpretive memorandum on June 24, 2005 regarding analysis 

of past action, which states, ―agencies can conduct an adequate cumulative effects analysis by 

focusing on the current aggregate effects of past actions without delving into the historical details 

of individual past actions.‖

The cumulative effects analysis in this EIS is also consistent with Forest Service National 

Environmental Policy Act (NEPA) Regulations (36 CFR 220.4(f)) (July 24, 2008), which states, 

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 reasonably foreseeable future actions) on 

the affected environment. With respect to past actions, during the scoping process and 

subsequent preparation of the analysis, the agency must determine what information 
Chapter 3: Affected Environment and Environmental Consequences

32 Sierra National Forest

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)‖

In determining cumulative effects, the effects of the following past, present and future actions 

were added to the direct and indirect effects of the proposed action and alternatives.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 33

Table 3. Past, Present and Reasonably Foreseeable Actions Contributing to Cumulative Effects by Resources Action is likely to Effect

Activity Type Description Year Unit Of 

Measure

Air Quality

Aquatics

Botany/N

W

Fuels/Fire

Fuels/CBD

Human Health

Cultural Res.

Vegetation

Soil

Transportation

Watershed

Wildlife

Roads/Trails USFS, 

County, State 

owned and 

maintained

Includes the network of 

inventoried road/trail 

systems within project 

subwatersheds 

On-going 86 miles X X X X X X X X

Campground and 

other USFS Owned

Facilities

Big Sandy Campground, 

Little Sandy 

Campground, West Fall 

Campground, West Fall 

Fire Station

Existing 4 sites X X X X X

Past/Current USFS 

Timber Sales within 

Sugar Pine 

subwatersheds

Includes:

1) Green Timber Sales

2) Salvage Harvest 

3) Thinning

1) 1980s

2) 1990s

3) 2000-

Current

1) 2,640 acres

2) 1,532 acres

3) 189 acres

X X X X X X X X X X X

Vegetation 

Management

Plantation 

Maintenance 

Clearcutting, thinning, 

hand release, chemical 

release, and planting in 

plantations <30 yrs old.

1980s 115 acres X X X X X X X X X X X

Sugar Pine Railroad

Yosemite Pack 

Station 

Infrastructure

Special Use Permits 

which include buildings, 

amphitheater, RR track, 

corrals, and trails.

Existing Approx. 25 

acres

X X

Power Line Power Line Corridor Existing Approx.4.5 mi X
Chapter 3: Affected Environment and Environmental Consequences

34 Sierra National Forest

Activity Type Description Year Unit Of 

Measure

Air Quality

Aquatics

Botany/N

W

Fuels/Fire

Fuels/CBD

Human Health

Cultural Res.

Vegetation

Soil

Transportation

Watershed

Wildlife

Big Creek Ditch 

Diversion

Madera Irrigation 

Historical Ditch System 1850s Approx. 3 miles X X

Roadside Hazard 

Tree Removal

Removal of damaged, 

rotten, dead trees to abate 

roadside hazard using 

timber sale contracts. 

2003-

present 41 miles X X X/X X X X X X X X

Fire/Fuels 

Management 

Activities

Includes Fuelbreak 

Construction and

Maintenance, Prescribed 

Burning, ladder fuel 

removal, mastication

1980spresentApprox. 600 

acres

X X X X X X X X X X X

Private Land

Infrastructure for 

communities of 

Sugar Pine, Cedar 

Valley and Fish 

Camp

New home construction, 

power, water, private 

roads

Ongoing 378 acres X X X X X X X X X

Private LandVegetation 

Management in 

communities and 

other private lands

Timber harvesting, land 

type conversions

Hazard fuels reduction

Ongoing Individual 

Community 

Private Acres

X X X X X X X X X

Special Use 

Permitted Activities

Waterlines, Water storage 

tanks, fiber optic cable,

apiary

Ongoing Various 

MeasuresMapped 

Locations

X X X X X X X X X X
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 35

Activity Type Description Year Unit Of 

Measure

Air Quality

Aquatics

Botany/N

W

Fuels/Fire

Fuels/CBD

Human Health

Cultural Res.

Vegetation

Soil

Transportation

Watershed

Wildlife

Motorized 

Recreation 

4X4, OHV, snowmobile

uses of system and 

temporary roads

Ongoing 86 miles X X X/X X X X X

Livestock Grazing Soquel Allotment Ongoing Soquel Mdw 

Pasture

X X/X X X X X X

Fish Camp Project Vegetation Mgmt Project Project 

proposal 

being 

developed 

2009-

2010

2,000 to 3,000 

acres

X X X X X X X X X X
Chapter 3: Affected Environment and Environmental Consequences

36 Sierra National Forest

Cultural Resources __________________________

The direct, indirect and cumulative effects below are summarized from the Sugar Pine Adaptive 

Management Project Cultural Resources Report (Popelish, C.; Mogge, M., 2008).

Affected Environment

All throughout the Sierra National Forest are the remnants of past cultures that illustrate the 

centuries-old relationships between people and the land. These cultural resources hold clues to 

past ecosystems and human adaptations to them, provide links between living communities and 

the unique prehistoric and historic land uses of the Sierra National Forest (SNF), and help 

transform a visit to the woods into an encounter with history. These cultural resources comprise 

an irreplaceable and non-renewable resource record of past human life and land use. This record 

is contained in properties with archaeological research value, and locations of cultural importance 

to local Native American groups. 

Archaeological and Historic Values

Cultural resources are the buildings, sites, areas, architecture, and properties that bear evidence of 

human activity and use, and have scientific, historic, and cultural importance. The cultural 

resources are not distributed equally across this acreage, but clustered according to the natural 

resources that were being used (e.g. acorn groves, timber stands, water, mineral locations). With 

new discovery upon almost every new survey effort, there continue to be many undiscovered 

cultural resources in the SNF.

Physical remains of over 10,000 years of human history are found throughout the Sierra National 

Forest. Except for the last century and a half of written history, the only record of this long human 

use is the remains left by the original native people and their descendants. At the time of contact 

with Euro-Americans, in the late 1700s and early 1800s, the Fresno River was the boundary 

between the southern Sierra Miwok to the north and west, and the Chukchansi Yokuts to the 

south and east. The Western Mono occupied the area around what is now Bass Lake. The 

boundaries between the groups were ambiguous, with a lot of overlap in the area between the 

Miwok, Yokuts and Mono. 

The processes of subsistence, the hunter-gatherer lifestyle, and the resulting indigenous land use 

are seen in the archaeological record with features common to the material culture of the native 

people of the Sierra Nevada (e.g. village sites, bedrock mortars, stone tool artifacts). Some of 

these sites have ethnographic documentation that indicates a fairly recent history of tribal use; in 

some cases, tribal use continues at sites that have an occupational history that spans thousands of 

years.

Historic-era cultural resources reflect particularly the cultural and economic products of the rapid 

pace of technological achievement in the last 150 years imposed on the terrain of the Sierra 

Nevada. These resources often reflect environmental changes resulting from industrial and 

technological advances in resource extraction, landscape use, and management. Sites include 

remnants of Forest Service administration, exploration and settlement, grazing/range 

management, mining, transportation, travel, tourism and recreation, and the forest products 

industry. Each of these themes has an array of associated sites and features. For example, features 

associated with railroad logging operations may be work camps, refuse dumps, railroad grades, 

trestles, and discarded equipment.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 37

Native American Cultural Values

Federally recognized tribal governments associated with the SNF, as elsewhere in the United 

States, have a special political and legal relationship with the U.S. Government. Recognized 

tribes are also beneficiaries of a trust relationship with the Federal government. Federal agencies, 

such as the Forest Service, consult with tribes as with other governments and are responsible for 

protecting tribal interests. The Forest Service also consults with non-recognized tribes. 

There is a deep and abiding concern with many Indian people about what occurs in their 

aboriginal territory. The SNF honors the traditional ties that many tribal communities and Indian 

people have to this portion of the Sierra Nevada. Access to and use of the Forest and other public 

lands is critical for many Indian people, as community identity and cultural survival are 

dependent on continued access to ceremonial and sacred places, cemeteries, traditional gathering 

areas, archaeological sites, and resources at a variety of locations on forest land. Certain plants, 

animals, and locations provide for many needs, including food, medicine, utilitarian type 

materials, and ceremonial items. Specific resources insure that significant cultural traditions, such 

as basket weaving, survive and continue. These areas contribute to the tribal communities‘ way of 

life, their identity, their traditional practices and cohesiveness. 

Consultation with tribes, the local Native American communities, and other interested parties to 

identify other cultural values, including contemporary Native American interests, was initiated 

with a Public Scoping Letter that was sent on August 31, 2007, to members and groups in the 

Native American community in accordance with the Sierran PA, National Historic Preservation 

Act (NHRA), and other laws and regulations. Consultation has consisted of meetings, letters, and 

presentations, and is documented in the project record. 

In the area of potential effect, the results of thirty years of cultural resource surveys and 

investigations have identified 15 archaeological properties that are associated with themes of SNF

history. Most sites represent prehistoric life ways; other sites represent historic-era land uses. All 

of the cultural sites were monitored to determine their current condition and risk of adverse 

effects. 

The SNF manages those cultural resources which are eligible for listing on the NRHP. The Forest 

does not manage or protect ineligible properties in project activities, unless there is local interest 

in preservation. NRHP eligibility has not been determined for every archaeological property in

the project area. Unevaluated sites are considered potentially eligible, and managed as if eligible. 

The Sierran PA allows for deferred NRHP evaluation if the property would not be affected by the 

project, usually through application of Standard Protection Measures.

Contemporary Native American interests can include traditional cultural properties (sites 

associated with cultural practices or beliefs that are rooted in history and important in maintaining 

cultural identity), and plant gathering sites for basket materials, medicines, and food resources. 

The Sierra NF manages such known sites as cultural resources under the provisions of the NHPA, 

but where the interests of native people are considered to achieve a mutually beneficial outcome 

during project implementation. The location of these sites is also kept administratively 

confidential. The SNF will maintain appropriate access to sacred and ceremonial sites, and to 

tribal traditional use areas, and has consulted with affected tribes and tribal communities to 

address access to culturally important resources and areas in this project analysis.
Chapter 3: Affected Environment and Environmental Consequences

38 Sierra National Forest

Methodology for Analysis

Data Sources

Existing information from cultural resource records, historic archives, maps, and GIS spatial 

layers was reviewed to provide specific information about historic properties, or the likelihood 

that unidentified properties might exist in non-inventoried areas. 

The majority of the project had been adequately surveyed for prior projects between 1979 and 

1994. In 2007 and 2008, additional surveys were completed in previously unsurveyed areas. For 

areas that had never been surveyed, new survey was conducted using a combination of intensive 

(0 – 30 meter transects) and cursory (50+ meter transects) coverage. Intensive survey was done in 

clear and/or non-steep terrain. Cursory survey was done where terrain was very steep or had 

dense brush cover. 

Information about the survey, location of historic properties, and the nature of past or current 

effects, is available for those cultural resources within the area of potential effect, as documented 

in the archaeological inventory reports for the proposed project (Veilleux/Popelish 2007 and 

2008). These reports, which describe the location and composition of the archaeological sites, are 

kept administratively confidential under the provisions of the Archaeological Resource Protection 

Act of 1979, 36 CFR 296. 

Spatial Analysis 

The location of the historic property is the unit of spatial analysis when considering effects in 

action alternatives. For some historic properties (e.g., Traditional Cultural Property), the setting 

beyond the historic property‘s location must also be considered when determining whether an 

adverse effect will occur.

Effects Timeframes

 Short-term effects occur within one year. 

 Long-term effects occur up to 20 years. 

 Cumulative effects are analyzed at a 20-year interval.

Measurement Indicator and Rationale

When assessing direct, indirect, and cumulative effects, assessments are based on a historic 

property possessing at least one of the following NRHP values (36 CFR 60.4(a – d)) unless 

specific information already exists:

 Prehistoric archaeological site: Criterion D 

 Historic archaeological sites: Criterion D

 Historic structures: Criterion C

An undertaking can have no effect, no adverse effect, or an adverse effect. An adverse effect to a 

historic property can occur when an undertaking directly or indirectly causes alterations in its 

character or use. An adverse effect on a historic property occurs when an undertaking alters its 

important characteristics and is measured by the degree to which it diminishes its location, 

design, setting, materials, workmanship, feeling or association (Integrity Measures) (36 CFR 

800.5(a)(1)). These integrity measures can also be used to characterize the nature of any potential 

effects, whether they are direct, indirect or cumulative effects; and their severity. The degree to 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 39

which historic property values are diminished will be used to measure the direct, indirect and 

cumulative effects of the proposed undertaking.

When the nature and scope of a proposed undertaking is such that its effects can be reasonably 

predicted and appropriate measures can be undertaken to ensure that the values of cultural 

resources or historic properties are not affected in any way, than those cultural resources or 

historic properties may be managed in a manner which ensures that their values are preserved by 

using the Standard Protection Measures outlined in the Sierran PA. 

Alternative 1 – No Action

Direct and Indirect Effects

Direct effects under this alternative could happen should a conflagration occur. The lack of fuel 

reduction management could result in higher intensity wildfires, thereby adversely affecting 

cultural resources, especially those with wooden components. Should a conflagration occur, 

indirect effects could occur as a result of increased access to and visibility of cultural resources, 

increasing the likelihood of artifact looting.

Cumulative Effects

Cumulative effects on cultural resources can be variable as past, current and future actions within 

the project area have occurred and may continue in the future (i.e. logging activities, road 

construction). Historic logging and road construction activities did not account for the presence of 

cultural resources. As no action would occur under this alternative, cumulative effects are 

unlikely.

Alternative 2 – Proposed Action

Direct and Indirect Effects 

There are a total of twenty-five cultural resource sites that have the potential to be affected by 

implementing this alternative. One of these sites is an historic railroad logging system that has 

thirty features that have the potential to be affected. These features include: spur grades, a flume, 

and log chutes that retain intact earthworks; camps and trash dumps; and log chutes with sheave 

posts. All of these cultural resource sites and historic features will be protected through avoidance 

(Sierran PA, Attachment 7, Stipulation II.B). 

In addition, four of the cultural resource sites have forest road or site conflicts on roads identified 

for reconstruction needs through the proposed action. With additional protection measures such 

as padding the site with gravel, staying within the existing road prism or no reconstruction within 

specified site areas, there will be no effect to these sites (Sierran PA, Attachment 7, Stipulation 

II.B). 

By implementing the Standard Protection Measures outlined in the Sierran PA, no historic values 

would be diminished as a result of implementing this alternative. There will be no direct or 

indirect effects to cultural resources under Alternative 2.

Cumulative Effects

As all heritage resource sites will be avoided through project design from current project 

activities and predictable future project activities, it is anticipated there will be no cumulative 

effects from this action alternative.
Chapter 3: Affected Environment and Environmental Consequences

40 Sierra National Forest

Alternative 3

Direct and Indirect Effects

Effects would be the same as Alternative 2.

Cumulative Effects

Cumulative effects would be the same as Alternative 2.

Alternative 4

Direct and Indirect Effects

Effects would be the same as Alternative 2.

Cumulative Effects

Cumulative effects would be the same as Alternative 2.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 41

Botany: Rare plants and Noxious Weeds ________

The direct, indirect and cumulative effects to Threatened, Endangered and Sensitive botanical 

species and noxious weed analysis are summarized below from the Biological Assessment and 

Evaluation for the Sugar Pine Adaptive Management Project (Clines, J. 2008). 

Affected Environment

Rare Plants

Three species of Forest Service sensitive plants occur in the Sugar Pine project area. Generally 

speaking, the project area is relatively homogeneous from the standpoint of rare plant habitat, 

being dominated by various phases of the mixed conifer forest type typical of the western slope of 

the Sierra Nevada. There are no meadows, fens, or significant areas of rock outcrop or open 

gravel habitats. The area is characterized by Sierran mixed conifer forest dominated by white fir 

(Abies concolor), ponderosa pine (Pinus ponderosa), incense cedar (Calocedrus decurrens), 

sugar pine (Pinus lambertiana), with black oak (Quercus kelloggii) as the major hardwood within 

the stands. Areas vary from drier sites with a solid understory of bear clover (Chamabaetia 

foliolosa) to more mesic sites with an understory of dogwood (Cornus nuttallii) and hazelnut 

(Corylus cornuta). Common shrubs are Arctostaphylos viscida var. mariposa, A. patula, 

Chrysolepis sempervirens, Ceanothus integerrimus, C. diversifolius, and C. cordulatus.

The threatened, endangered, or sensitive plants considered in this document are displayed in the 

following table.

Table 4. Threatened and Sensitive Plant Species Considered

Latin Name Common Name Status

Calyptridium pulchellum mariposa annual pussypaws Fed. Threatened

Cypripedium montanum mountain lady‘s slipper orchid FS Sensitive

Epilobium howellii subalpine fireweed FS Sensitive

Hulsea brevifolia short-leafed hulsea FS Sensitive

Peltigera hydrotheria veined water lichen FS Sensitive

The Sierra National Forest botanist checked the U.S. Fish and Wildlife Service web site for 

Federally-listed plants that may be found in the project area (USFWS 2009). The list contains two 

plant species and two categories of critical habitat that may occur within the Forest. Sidalcea 

keckii is only known from outside the Forest to the south, and if it were to occur in the Sierra 

National Forest, it would not be found north of the San Joaquin River at the elevations of the 

Sugar Pine Adaptive Management Project. It grows in clay soils (derived from serpentine) in 

sparsely-vegetated grasslands at elevations between 400 and 1,400 feet in the foothills of 

California's central western Sierra Nevada. The proposed critical habitat for Sidalcea keckii falls 

entirely outside the national forest boundary. 

The proposed critical habitat for vernal pool plants does not fall within the Sugar Pine Adaptive 

Management Project area, and none of the Federally-listed vernal pool plants are known or 

expected to occur in the Sierra National Forest.
Chapter 3: Affected Environment and Environmental Consequences

42 Sierra National Forest

Calyptridium pulchellum (Mariposa annual pussypaws) is known to occur in the Sierra National 

Forest at elevations below 3600 feet, but there are no known occurrences of Mariposa pussypaws 

in or near the project area, and no suitable habitat exists. The elevation of the Sugar Pine Project 

is well above the upper elevation limit for the Mariposa pussypaws. No consultation is necessary 

with U.S. Fish and Wildlife Service, and no further analysis will occur.

Forest Service Sensitive Plant Species in the project area

Populations of mountain lady‘s slipper orchids, short-leafed hulsea, subalpine fireweed, and 

veined water lichen occur within the project area. No other Forest Service sensitive plants were 

found during surveys, and the following effects analysis will focus on these four species.

Mountain Lady’s Slipper Orchid – Cypripedium montanum

The mountain lady‘s lipper orchid is a perennial, rhizomatous herb that ranges in height from 25 

to 70 cm. The large leaves are pleated, oval-shaped, and attached in an alternate arrangement on 

the stem. Each stem has from one to three showy flowers up to 5 cm in length (Hickman, 1993). 

These typical orchid flowers are white, yellow and purple, and are very showy with a large saclike lower lip (―slipper‖). 

Flowering is generally in early June in the central Sierra. Pollination is by a wasp, fruits are 

capsules containing thousands of tiny seeds, which are wind-dispersed (Kaye and Cramer, 2005). 

Seeds require a fungal symbiont to germinate. Mycorrhizal fungi are probably important for the 

entire life of a plant (Kaye and Cramer, 2005). One mountain lady‘s slipper orchid plant can live 

at least 30 years and possibly many more. Plants may not emerge above-ground every year, 

making accurate assessment of population dynamics difficult (Kaye and Cramer, 2005). The 

habitat components required for maintenance of long-term viability of lady‘s slipper orchids are 

not well understood, but maintenance of at least 60% canopy cover appears important, as well as 

adequate soil moisture and maintenance of sufficient organic matter in the form of downed wood 

so that mycorrhizal fungi are sustained (Kaye and Cramer, 2005). 

The Sierra National Forest has the southenmost occurrences of this species in the Sierra Nevada, 

about 20 occurrences are found in or near Nelder Grove of Giant Sequoias and near the town of 

Fish Camp. Habitat for the mountain lady‘s slipper orchid across its range includes Douglas-fir, 

white fir, giant sequoia, and mixed conifer forests in the mid-late seral stages, as well as oak 

woodlands and riparian areas. More than 70% of known occurrences are found in mixed conifer 

forest (Kaye and Cramer, 2005). Kaye and Cramer (2005) identified that a majority of the known 

sites occur between 1,625 and 5,850 feet, but in the central Sierra Nevada (Sierra National Forest 

and environs), the lower limit seems to be about 4,400 feet (Sierra National Forest files, 2005). 

Slope aspect is primarily northerly; slope steepness is usually between 25 and 50%; canopy 

closure is generally between 60 and 80% (Kaye and Cramer, 2005). Soils do not appear to be 

limiting, mountain lady‘s slipper populations have been found on many soil types, including 

ultramafic and limestone (Kaye and Cramer, 2005).

Eight populations of lady’s slipper orchids were discovered within the project area. Most are 

well within the riparian conservation zone and the streamside management zone (see aquatics 

design measures). In the past 5 years, at least 15 new populations have been found in the 

Sierra National Forest, varying in size from a few stems to more than a hundred bringing the 

total number of known populations up to 24 for the Sierra NF. 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 43

Subalpine fireweed – Epilobium howellii

Subalpine fireweed is known from meadows, riparian areas, and seeps at approximately 120 sites

in the Sierra NF. Most of these have been discovered since 2005, showing that this species has 

until recently been overlooked and may be more common than previously thought. This small, 

delicate herb prefers bare soil around riparian areas with little competition, and based on new 

information gathered in recent years, it seems to thrive in areas with at least some disturbance 

(e.g. silt deposits in streambeds, ski runs, roadsides). The species ranges from Sierra County at 

Yuba Pass to Fresno County. One population of subalpine fireweed was found in a meadow 

1,000 feet north of unit RX-08 on road 5S06.

Short-leafed hulsea – Hulsea brevifolia

The short-leaved hulsea is a locally endemic perennial herb found in montane forests of the 

central and southern Sierra Nevada (Hickman 1993). Plants are 3 to 6 dm tall, with leafy stems. 

Leaves are toothed, and stems and leaves are covered with hairs, some of which are glandular, 

making plants sticky to the touch. Flowerheads are bright yellow-orange, less than 20 mm in 

diameter (Hickman 1993). Elevation range is from 5,000 to 9,000 feet, but most occurrences are 

found above 6500 feet in the red fir forest type. This plant grows in dry forests and openings.

Short-leaved hulsea is a perennial herb. There are about 46 occurrences documented on the Sierra 

National Forest, and others on adjacent forests and in Yosemite National Park. Elevational range 

is 5000 to 9000 feet, from Tuolumne County south to Tulare County. Habitat for short-leaved 

hulsea is gravelly or sandy exposed areas as well as densely wooded sites in coniferous forest, 

usually red fir forest. Occurrences range in size from a few dozen plants to many thousand 

plants. Most occurrences appear to represent a variety of age classes, from the current year‘s 

seedlings to older, well established plants (information on file at Sierra National Forest, North 

Fork, CA), and many populations consist of thousands of individuals. Five populations of shortleafed hulsea occur along Forest Roads 5S22Y and 5S06. 

Veined water lichen – Peltigera hydrotheria 

Veined water lichen is found in cold unpolluted streams in conifer forests along the western slope 

of the Sierra Nevada. The California occurrences are disjunct from other U.S. populations. This 

aquatic lichen is a foliose species with a delicate ―leafy‖ thallus. It is a black ―lettuce‖-like lichen 

growing on rocks and on stream bottoms. Clumps range in size from a few centimeters to over a 

decimeter. Reproductive structures have been observed, but how the lichen actually colonizes 

new habitats is unknown. 

Threats are activities that change the water chemistry, alteration of the stream channel, excessive 

alteration of riparian vegetation thereby increasing water temperature or increasing flows that 

scour the gravels and rocks on which the lichen is attached. This species occurs in streams with 

clear, unpolluted, water. Peak flows are probably not of the intensity that would lead to scouring. 

The streams have a rich aquatic bryophyte flora (Shevock 1998). Increased sedimentation, 

nutrients, or a rise in temperature would significantly impact occurrences (Davis 1999). 

The Sugar Pine Adaptive Management project area contains abundant suitable habitat for the 

veined water lichen, and one occurrence was found in 2007 within the project area, in the 

tributary to Lewis Creek flowing from the Westfall area. Additional stretches of perennially 

flowing water within the project area may contain additional veined water lichen populations. 

Appendix A of the Biological Assessment and Evaluation for Plant Species provides a full list 

of the threatened, endangered, and sensitive plants that might be found in the Sierra National 
Chapter 3: Affected Environment and Environmental Consequences

44 Sierra National Forest

Forest, a summary of information about their biology and habitat, and rationale for including or 

excluding them in this analysis.

Noxious Weeds

Noxious weed species known to occur in the Sugar Pine project area are: bull thistle (Cirsium 

vulgare), foxglove (Digitalis purpurea), klamathweed (Hypericum perforatum), oxeye daisy 

(Leucanthemum vulgare), perennial sweet pea (Lathyrus latifolius), and Spanish broom (Spartium 

junceum). Other species that occur in the general vicinity and along roads leading to the project 

area are: yellow starthistle (Centaurea solstitialis), spotted knapweed (Centaurea maculosa), and 

medusahead (Taeniatherum caput-medusae). 

Bull thistle is a biennial herb native to Eurasia that can grow to heights of 2 meters (Hickman

1993). It is fairly common in California, though less so at higher elevations or more pristine sites 

in the Sierra National Forest. Large plants can produce over 100,000 seeds (Randall 2000). Bull 

thistle tends to spread rapidly in disturbed meadows and in areas where soil disturbance favors

weeds such as logged areas or areas cleared for fuels reduction (Randall 2000). There are over 

300 infestations of bull thistle mapped within the Sierra National Forest, ranging from a few 

stems to infestations of several acres. There are 9 infestations within the Sugar Pine project area, 

mostly confined to roadsides and other disturbed areas such as old landings. Hand removal of 

plants within the project area occurred in 2007 and 2008, and will be conducted again in 2009 and 

into the future until infestations are eradicated. 

Foxglove is a tall biennial herb native to Europe and Africa, originally introduced as an 

ornamental that tends to invade wet areas and streamsides. The plants are toxic to livestock and 

wildlife and can form monocultures in riparian areas to the exclusion of the native vegetation 

(Harris 2000). There is at least one small population of foxglove in the project area, possibly 

more along streamsides. 

Klamathweed is a rhizomatous perennial native to Europe. Plants can form dense patches that 

eventually replace native plants and can cause severe problems for conifer regeneration (CDFA 

2009). Spread is by seed and vegetative growth underground (CDFA 2009). Plants produce an 

average of 15,000 to 33,000 seeds, which can remain viable for up to 10 years and are spread by a 

variety of vectors, including tires and heavy equipment (CDFA 2009). There are over 100 

infestations of klamathweed in the Sierra National Forest with several along roads leading to the 

Sugar Pine project area, and this is one of the fastest-spreading weeds in the Forest. One 

infestation of klamathweed was documented and hand-pulled in the project area in 2008. 

Oxeye daisy is a rhizomatous perennial herb that has escaped cultivation in many areas of the 

West. Its potential for spread at high elevations is of concern. The oxeye daisy is native to 

Europe. It displaces native plants in wildlands. When infestations are not controlled early, they 

form large seedbanks of seeds that can remain viable for 20 years. Reproduction is by seed and by 

underground spread via the rhizomes (Alvarez 2000). There is a cluster of oxeye daisy along road 

5S17, which is rumored to have originated from a large infestation on a nearby private parcel. 

Hand-pulling began in 2008 and will continue in 2009. 

Perennial sweet pea is a perennial, sprawling, herb that has escaped cultivation and can form 

large masses that exclude native vegetation. There is at least one small infestation in the project 

area that should be easy to eliminate. 

Spanish broom is an invasive shrub that is native to the southern Mediterranean region, 

originally introduced to California as an ornamental in the 1800s (Nilsen 2000). Shrubs spread in 

wildlands, excluding native plants and posing a fire hazard. There is a dense infestation of 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 45

Spanish broom just south of Tenaya Lodge in the northwest portion of the project area within 

units proposed for fuels reduction activities. This area will be flagged for avoidance to ensure that 

seeds are not spread during project implementation. 

Alternative 1 – No Action

Under the No Action alternative, known sites for botanical resources would continue to be 

managed to maintain present diversity of the species as specified in the SNF LRMP (USDA-FS 

1992) and SNFPA ROD (USDA-FS 2004b).

Direct Effects

No direct effects would occur to threatened, endangered, or Forest Service sensitive plants if the 

no action alternative were chosen because project activities would not take place.

Indirect and Cumulative Effects

Indirect and cumulative effects have the potential to occur to TES plants under the no action

alternative primarily from the increased potential for uncontrolled wildland fire. Uncontrolled 

wildfire has the potential to cause significant disturbance to soil, ground cover and canopy cover, 

placing Forest Service sensitive riparian species at risk. For example, lady‘s slipper orchid 

populations could be extirpated if the canopy and soil organic layers were incinerated under 

extreme fire conditions (Kaye and Cramer 2005). The veined water-lichen population could be 

extirpated if the extreme heat prevailed for long enough to kill the thalli (plants) within the stream 

reach containing the lichens. 

Except for under the most severe of fire conditions, which would kill all the seeds in the soil, the 

short-leafed hulsea would probably survive and perhaps ultimately benefit from wildfire as it 

tends to thrive along roadsides and in post-burn conditions (e.g. the Big Creek fire in 1994 

resulted in vigorous recovery of short-leafed hulsea near Huntington Lake). 

Uncontrolled wildland fire also introduces a higher potential for the spread of weeds through 

suppression actions. Fires can also allow the opportunity for the introduction and spread of 

invasive non-native weeds when seeds or contaminated soil area introduced, which can affect 

Forest Service sensitive species through competition for resources. However, the overall risk is 

probably about the same as under the action alternatives. 

Alternative 2 – Proposed Action

Direct Effects

The following direct effects to sensitive plants are possible as a result of timber harvest or fuels

reduction activities: Direct killing of plants when equipment runs over them or parks on them,

when logs are skidded or dragged over them, when slash piles block their light, and when piles 

are burned directly over them and the heat intensity is too great to survive. Mastication could 

directly kill plants by running them over or by covering them with a dense layer of chipped wood

and limbs.

Indirect Effects

A possible indirect effect to sensitive plants is the degradation or loss of habitat resulting from the 

introduction or spread of noxious or invasive weeds. Noxious weeds are plant species that can 

spread rapidly and compete with native plants for water and other resources, in some cases 

forming solid stands of plants that may crowd out sensitive plant species. Noxious weeds can be 
Chapter 3: Affected Environment and Environmental Consequences

46 Sierra National Forest

transported by vehicles and heavy equipment when equipment passes through or excavates soil in 

contaminated areas and carries weed seeds to new areas. Risk of noxious weed introduction and 

spread can be greatly reduced by power washing all heavy equipment before bringing it onto the 

project site, as recommended by the Forest Service ―Guide to Noxious Weed Prevention Practices

(USDA-FS 2001b).‖ Noxious weed prevention measures have been incorporated into the design 

of this project, thus these indirect effects should be minimal.

Mountain lady’s slipper orchid – Cypripedium montanum

Eight populations of lady‘s slipper orchids were discovered within the project area. Most are well 

within the riparian conservation zone and the streamside management zone (see aquatics design 

measures). Reducing canopy cover below 60% is thought to be damaging to lady‘s slipper 

orchids. Populations are often very small and isolated from each other; therefore, concerns exist 

related to population size, genetic fitness and the overall viability of the species (Kaye and 

Cramer 2005). However, in the past 5 years, at least 15 new populations have been found in the 

Sierra National Forest, varying in size from a few stems to more than a hundred bringing the total 

number of known populations up to 24 within the Sierra NF. 

The eight known populations are well-protected from detrimental changes in canopy cover or soil

parameters because they occur next to streams or are flagged for avoidance such that canopy 

cover will not be reduced and heavy equipment will not be allowed. If any new occurrences of 

lady‘s slipper orchids were to be discovered in the future they would be protected as follows 

(plants do not emerge every year therefore one year of surveying may not reveal all populations 

that are present): Any new populations would have a zone flagged around them where no timber 

harvest or heavy equipment would be allowed within approximately 60 feet (average tree height 

in the area). The buffer was determined to be sufficient to ensure that canopy cover remains at 

60% or higher within the populations. Populations would also be monitored post-project to ensure 

that these measures were followed and to evaluate the status of the populations. The project 

design measures are expected to prevent any negative direct or indirect effects to the mountain 

lady‘s slipper orchids.

Subalpine fireweed – Epilobium howellii

Because meadow habitat will be protected by the project design measures for aquatic species (see 

EIS), and because the only population of subalpine fireweed occurs outside the project by at least 

1000 feet, there will be no direct or indirect effects to this species.

Short-leafed hulsea – Hulsea brevifolia

Because any short-leafed hulsea populations will be flagged for avoidance prior to project 

implementation, there will be no direct or indirect effects to this species. 

Veined water lichen - Peltigera hydrotheria 

One new veined water lichen population was found during field surveys for the Sugar Pine 

Adaptive Management project, and more may exist in areas not directly surveyed (not every mile 

of perennial stream was surveyed). As this species is sensitive to water pollution and prefers cold 

clear water, any activities that alter water quality or raise water temperature could negatively 

impact plants and habitat. Because of the project design measures for RCAs prohibiting grounddisturbing activities within 100 feet of perennial streams, no negative effects are expected. In 

addition, stream temperatures will not rise as a result of the project because canopy cover will not 

change significantly near streams. 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 47

Cumulative Effects

The geographic boundaries delineated for surveys and subsequent effects analysis were defined 

by the boundaries of the Sugar Pine Adaptive Management Project area since this is where the 

proposed activities with potential effects on plant species are to occur. Table 3, on page 25 is a 

listing of past, present and reasonably foreseeable future activity within the project area utilized 

in determining cumulative effects on plant species.

This project and the subsequent maintenance and further vegetation work will move the areas 

treated closer to the pre-European natural range of variability for the area, except for possibly the 

areas where non-native annual grasses become more common after clearing. 

Foreseeable future activity within the project area may include prescribed burning, ongoing 

vegetation maintenance by handwork or possibly heavy equipment, management of the 

plantations (thinning), and road maintenance. Other activities likely to occur include personal fuel 

woodcutting, recreational uses such as hiking, bike riding, OHV and dirt bike use, and dispersed 

camping. 

Because suitable habitats for TES plants will be avoided and noxious weed mitigations will be 

implemented, negative effects to any undiscovered sensitive plants are expected to be minimal to 

non-existent for the Sugar Pine Adaptive Management Project, and therefore should not add to 

any cumulative effects of activities in the project area on sensitive plants.

Alternative 3

Direct, Indirect and Cumulative Effects

Effects for rare plants and noxious weeds would be the same as Alternative 2.

Alternative 4

Direct, Indirect and Cumulative Effects

Effects for rare plants and noxious weeds would be the same as Alternative 2.
Chapter 3: Affected Environment and Environmental Consequences

48 Sierra National Forest

Geology/Soils ______________________________

The direct, indirect and cumulative effects to the geologic and soils resources are summarized 

from the Soils Resource Report for the Sugar Pine Adaptive Management Project (Gallegos, A. 

2009).

Methodology for Analysis

Data used to determine existing soil conditions and projected effects to the soil resource include: 

the Soil Survey of the Sierra National Forest, (Giger 1993), site specific data from soil transects 

collected in 2007, following the Region 5 Protocol for Soil Monitoring (TenPas 2005) and past 

monitoring of similar projects using BMP Monitoring Protocols (USDA-FS 2002) and the Region 

5 Soil Monitoring Protocol.

Effects of the proposed project will be similar to effects of recent, similar past projects 

implemented with current Best Management Practices and equipment that has been used in recent 

projects. These projects include the Cedar Valley Project, Graham Mountain Project, South of 

Shaver Project and several other similar projects.

Soil resource management is achieved by maintaining soil productivity using Regional Soil 

Quality Standard and Guidelines and management direction provided in the SNF LRMP (USDAFS 1992). Soil productivity is evaluated within an Activity Area. An Activity Area is the area of 

land dedicated to growing vegetation which soil quality standards for soil productivity are 

applied. It is that area within a management area where soil disturbing activities take place and is 

of practical size for management, sampling, and evaluation. Activity areas include timber harvest 

units and fuels treatment units within the Sugar Pine Project area. System roads and trails and 

other areas not dedicated to growing vegetation are not included as part of activity areas. 

The project proposal could affect soil productivity in the Sugar Pine Project Area by reducing 1) 

soil porosity, 2) soil cover and 3) large woody debris and 4) displacement of surface soils.

The main soil physical property that can be affected by the proposed action is porosity, the space 

between individual soil particles. Soil hydrologic function is primarily dependent on the size and 

arrangement of soil pores, or pore geometry. Soil pore geometry also controls the transmission of 

air through soils, which is critical for plant growth. When porosity is decreased, the soil becomes 

denser, making it more difficult for roots to penetrate. Maintenance of natural soil porosity is 

important for maintaining healthy native plant communities and for maintaining the hydrologic 

function of the soil. Severe losses of porosity through soil compaction decrease the water and air 

available to plant roots, creating droughty and/or anaerobic conditions as well as physically 

inhibiting root growth. Soil hydrologic function is usually impaired as water storage capacity, 

infiltration, and permeability decrease, thus increasing runoff and the subsequent potential for 

erosion and cumulative watershed effects. Soil compaction diminishes soil porosity, and 

decreases the transmission of water, nutrients, and air to roots. Severe compaction can inhibit root 

growth when the soil becomes too dense for roots to penetrate easily. Finally, compaction 

decreases infiltration and hydraulic conductivity, the movement of water into and through soils, 

which in turn increases surface runoff and erosion potential. Severely compacted soils could take 

at least 50 years to recover. Bulk density (ratio of soil mass to soil volume) and soil strength 

(penetration resistance) are two widely accepted indirect means of measuring changes in porosity 

in the field. Qualitative indicators of compaction include platy soil structure, loss of soil structure 

(e.g. puddling), impressions or ruts in the mineral soil surface, and in some cases, redoximorphic 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 49

features that indicate a recent change in soil aeration. Redoximorphic features are soil properties 

associated with wetness that results from reduction and oxidation of iron and manganese 

compounds after saturation and desaturation with water. Both quantitative and qualitative 

indicators will be used to describe compaction. Use of heavy equipment, especially rubber tired 

skidders, for logging and tractor piling could compact soils, in the upper 12 inches of the soil 

profile. Soil compaction can have a detrimental effect on soil productivity on fine-textured soils 

that are moist or at optimal soil moisture conditions for soil compaction. Soil compaction is not a 

concern in coarse textured soils. In fact, soil compaction has been found to have an increase in 

soil productivity by increasing the available water holding capacity of the soil (Powers, et al 

2008). Soils have been classified into sensitive and non-sensitive soils types for the purpose of 

identifying soils that are susceptible to detrimental soil compaction. Soil porosity should be at 

least 90 percent of total porosity over 85 percent of an activity area (stand) found under natural 

conditions. A 10 percent reduction in total soil porosity corresponds to a threshold for soil bulk 

density that indicates detrimental soil compaction. 

Soil productivity is dependent on the amount of soil organic matter available to prevent 

significant short or long-term nutrient cycle deficits, and to avoid detrimental physical and 

biological soil conditions. Soil organic matter should include fine organic matter and large woody 

debris. 

Fine organic matter provides soil nutrients and protects the soil by providing soil cover. Soil 

cover or the lack of soil cover can affect soil productivity by removal of surface soils from 

accelerated erosion. Accelerated erosion is erosion that occurs at a rate over and beyond normal, 

natural or geological erosion, primarily as a result of human activity. Soil loss should not exceed 

the rate of soil formation (approximately the long-term average of 1 ton/acre/year). Sufficient soil 

cover should be maintained to prevent accelerated soil erosion from exceeding the rate of soil 

formation. Ground cover will be at least 50% on ground slopes less than 35% and on slopes 

greater than 35%, ground cover will be determined by the interdisciplinary (ID) team. 

Replenishment of fine organic matter to preexisting conditions could occur in less than 10 years 

as forests shed their needles and leaves and accumulate on the forest floor.

Large organic matter or large woody debris, provides habitat for soil micro-organisms including 

fungus, soil insects and soil bacteria. All of these organisms are critical for soil health and soil 

productivity. The loss or reduction of large woody debris in a forest could last anywhere from 10

to 50 years, depending on the number of decadent trees or snags that are left in the stand after 

treatment. At least five well-distributed logs per acre, representing the range of decompositions 

classes, should be left on the forest floor after the proposed action is completed.

Soil productivity can be reduced or impacted from displacement of surface soils. Surface soils 

include valuable amounts of organic matter and nutrients that are critical for productive soils. 

Surface soils can be disturbed by logging and mastication equipment operating in the forest, by 

tractors piling slash and by construction of roads and skid roads from excavation of the soil to 

construct a road or skid trail prism. The surface area of new roads will result in a loss of soil 

productivity for that area. Disturbance of surface soils by logging and mastication equipment 

could result in reduced soil productivity. The Sierra NF LRMP provides direction for avoiding 

tractor logging on sustained slopes that exceed 35% (USDA-FS 1992). There are no slope 

limitations for mastication equipment in the LRMP. Mastication equipment can operate on slopes 

up to 55% slopes. There has been no systematic monitoring of mastication work on slopes greater 

than 35% on the Sierra National Forest.

The following information addresses the affected environment or existing pre-treatment soil

condition, the environmental consequences of the proposed action to soil productivity; 
Chapter 3: Affected Environment and Environmental Consequences

50 Sierra National Forest

mitigations measures proposed to reduce the impacts of the proposed action and a monitoring 

plan to ensure that Forest Standard and guidelines are met to maintain soil productivity.

Affected Environment

Soils in the proposed project area vary in their sensitivity to management. Soils with higher clay 

content and soil moisture have the highest potential to reduced soil porosity. Soil compaction can 

occur down to 12 inches deep. 

 There is a concern that areas proposed for ground based harvest have soils that are highly 

susceptible to reduction of soil porosity caused from compaction by heavy equipment 

operating when soils are moist or wet. 

 There is a concern that prescribed fire and tractor piling will reduce soil cover and 

accelerated erosion could result in a loss of soil productivity.

 There is a concern that ground based harvest systems on slopes that are too steep will 

displace surface soil horizons that could result in accelerated erosion and reduced soil 

productivity.

The area is underlain with nine soil types that combine into nine soil map units. The most 

dominant soils affected by the project include: Holland family, Chaix family, Chawanakee 

family, Ledford family, Entic Xerumbrepts, Neuns family, Umpa family, Cagwin family and 

Lithix Xeropsamments. Rockout crop is secondary component of several soil map units and is 

located throughout the treatment areas. The soils vary in characteristics from shallow to deep, 

thermic to frigid temperature regimes, xeric moisture conditions and have developed in 

metamorphic and granitic parent materials (Giger 1993). A map of the Soil Map Units and 

complete unit tables are included in the Soils Report available in the project file. Table 5 displays 

a summarization of this information. 

Table 5. Summary of Soil Map Units 

MUSYM Map Unit NAME Sensitive Acres

137 Holland Family, 35 to 65 Percent Slopes Yes 934

136 Holland Family, 5 to 35 Percent Slopes Yes 488

123 Chaix-Chawanakee Families-Rock Outcrop Complex, 35 to 65 

Percent Slopes

No 446

143 Ledford Family-Entic Xerumbrepts-Rock Outcrop Association, 10 

to 45 Percent Slopes

No 265

140 Holland-Chawanakee Families Complex, 35 to 65 Percent Slopes Yes 245

146 Neuns Family, 25 To 60 Percent Slopes No 176

124 Chaix-Holland Families Complex, 15 to 35 Percent Slopes Yes 155

176 Umpa Family, Deep, 20 to 60 Percent Slopes No 75

114 Cagwin Family-Lithic Xeropsamments-Rock Outcrop Complex, 45 

to 65 Percent Slopes

No 2

Some of the proposed treatment areas are underlain with multiple soil types and multiple soil map 

units. The western part and lower elevations of the proposed project area is underlain with 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 51

Holland soils. Holland family soil consists of deep, sandy loams and sandy clay loams that are 

well drained. Holland soil is the only soil in the Sugar Pine Project area that is a sensitive soil. 

Holland family soils have a moderate soil compaction hazard and high to very high maximum 

erosion hazard rating. These soils are most susceptible to compaction when soils are moist and 

are very erosive without adequate soil cover. Holland soils occur in soil map units 124, 136, 137, 

and 140. Holland soils are deep (60 to 66 feet), well drained soils with a sandy, clay loam subsoil. 

These soil map units occur in treatment areas M2, M6, M7, M8, M9, M10, M11, M12, RX3, 

RX5, T16, T3, T4, T5, T6, T7, T8, T9, T10, and T11. 

The middle part of the proposed project area is underlain with Soil Map Units 123 and 146. Soil 

types within these soil map units include Chaix, Chawanakee and Neuns family soils. Chaix 

family soils consist of moderately deep to deep, coarse sandy loams that are somewhat 

excessively drained or well drained. Chawanakee family soils consist of shallow, coarse sandy 

loam that is somewhat excessively drained. Neuns family soil consists of moderately deep to 

deep, gravelly loam and cobbly loam that is well drained. Neuns family soil has 25% pebbles 

and/or rock fragments. The Chawanakee soils are susceptible to loss of soil productivity from 

displacement of the surface soils. The Neuns family soil has a moderate erosion hazard rating and 

is difficult to compact because of the rock fragment content. Treatment areas M1, M4, M5, RX1, 

RX2, T2, and the east end of T15 are underlain with Soil map Unit 123, which includes Chaix, 

Chawanakee family soils and rock outcrop. Treatment area M4 is underlain with Soil map Unit 

146, which includes Neuns family soil. Treatment area T3 is underlain with Soil Map Units 140 

and 146, which includes Holland family soils in the lower elevations and Neuns family soil in the 

upper elevations of the unit. Treatment area T7 is underlain with Soil Map Units 124 and 136, 

which includes Chaix family soils and Holland family soils. 

The eastern part of the proposed project area is underlain with Soil Map Units 143 and 176. Soil 

types within these soil map units include Ledford family soil, Entic Xerumbrepts, Umpa family 

soils and rock outcrop. A Ledford family soil consists of deep, coarse sandy loams that are 

somewhat excessively drained. Entic Xerumbrept soil consists of shallow, sandy loams and 

coarse sandy loams that are somewhat excessively drained. These Entic Xerumbrepts soils are 

susceptible to loss of soil productivity from displacement of the surface soils. Umpa family soil 

consists of deep, bouldery and stony coarse sandy loam that is well drained and moderately well 

drained. This area has approximately 15% rock outcrop distributed throughout the area. 

Soil map units with high amounts of impervious surfaces such as rock outcrop or shallow soils 

are most susceptible to runoff and subsequent surface erosion of soils adjacent to the rock 

outcrop. Shallow soils and/or rock outcrop occur in soil map units 123, 140, and 143. 

Chawanakee family soils are shallow (<20 inches), somewhat excessively drained with a coarse 

sandy loam surface soil and subsoil. Entic Xerumbrepts soils are shallow (<18 inches), somewhat 

excessively drained or excessively drained with a sandy loam surface soil. The Chawanakee soils 

are susceptible to loss of soil productivity from displacement of the surface soils. The 

Chawanakee soils are also susceptible to accelerated erosion from runoff off the rock outcrop, 

especially if adequate soil cover is not available. Treatment areas that occur in these soil map 

units include: M1, M11, M-14, M-16, M-20, M5, M7, M8, RX-07, RX-08, RX1, RX2, RX3, 

RX5,T2, T3, T4, T5, T7, T9, T10, T15, T16, T-23, T-24, T-26, T-30, T-31, T-32, T-33, T-35, and 

T-37 (see Table 6). 

Areas proposed for ground based harvest systems are generally less than 35%. However, some 

areas exist where slopes exceed 35% and tractor logging could result in soil disturbance that 

mixes or removes soils below the A horizon. Commercial thin units with sustained slopes greater 
Chapter 3: Affected Environment and Environmental Consequences

52 Sierra National Forest

than 35% include T2, T4, T5, T7 and T10. Mastication units with sustained slopes greater than

55% include M1, M4, M5, and M7. 

Soil conditions have been reviewed in the Sugar Pine Project Area. Soil data along 12 soil

transects were collected using the 20 point transect method and soil data along 6 soil transects 

were collected using the line transect method to characterize soil conditions using the 2005 

Framework Soil Monitoring Methods Protocol and a soil monitoring protocol known as the Iron 

Canyon Intensive Soil Monitoring Protocol (TenPas 2005; Gallegos 2007). Data for soil cover, 

soil disturbance, soil compaction and large woody debris were collected along these 18 transects 

and summarized. This report documents baseline conditions from which to compare soil 

conditions in the future (see Table 6). 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 53

Table 6. Summary of Soil Transect Data

Treatment 

Area 

Transect Soil 

Cover

(%)

Slope

(%)

D1 D2 D3 Total 

Disturbance

LWD 

(#per 

acre)

Percent Unit Detrimental 

Comp/Dist

Core 

Samples 

M6 SP-TR-9 96 37 5 0 0 5 18 0.00% 1

T3 SP-T1-1,SP-T1-

2,SP-T1-3

94 20 27 0 0 27 102 9.67% 31

T4 SP-TR-7,SPTR--8 97 26 18 3 5 25 113 10.00% 6

T7 SP-TR-3 86 21 20 15 0 35 0 5.00% 3

T8 SP-TR-5,SP-T2-

1,SP-T2-1,SP-T2-3

91 31 24 8 1 33 100 9.00% 38

T10 SP-TR-1,SP-TR2,SP-TR-4,SP-TR6

91 21 19 3 5 26 45 2.50% 10

T26 SP-TR-14 62 16 5 5 15 25 20 15.00% 3

T32 SP-TR-13,SP-TR15

76 14 18 3 5 25 122 2.50% 6

Average 87 23 17 4 4 25 65 6.71% 98
Chapter 3: Affected Environment and Environmental Consequences

54 Sierra National Forest

Soil transect data indicates that soil cover and large woody debris are meeting Regional Soil 

Standard and Guideline thresholds. The average soil cover is 87% and the average number of 

large woody debris (LWD) is approximately 65. Several areas within the proposed project area 

are currently not meeting Regional Standard and Guideline thresholds for detrimentally disturbed 

soils. See Table 8 for description of soil disturbance classes. The average for detrimental 

disturbed soils throughout the project area is approximately 6.71%. Detrimentally disturbed soils 

include those areas with D3 soil disturbance or detrimentally compacted soils. Detrimentally 

compacted soil is where soil porosity is below 90 percent of total porosity found under natural 

conditions. A 10 percent reduction in total soil porosity corresponds to a threshold soil bulk 

density that indicates detrimental soil compaction. Some areas have soil compaction or 

detrimental soil disturbance as high as 15 to 20 percent. 

The middle of the treatment area T3 has approximately 20% of the area with detrimentally 

disturbed soils. Treatment area T3 overall has approximately 9.67% of the area with detrimentally 

disturbed soils. Treatment area T4 has approximately 8% of the area with D2 and D3 soil

disturbance and 10% of the area with detrimentally compacted soils. Treatment area T7 has 

approximately 15% of the area with D2 soil disturbance and 5% of the area with detrimentally 

compacted soils. Treatment area T8 has approximately 9% of the area with D2 and D3 soil 

disturbance and 9% of the area with detrimentally compacted soils. Treatment area T10 has 

approximately 8% of the unit with D2 and D3 soil disturbance and 2.5% of the area with 

detrimentally compacted soils. Treatment area T26 has approximately 20% of the area with D2 

and D3 soil disturbance and 15% of the area with detrimentally compacted soils. Treatment area 

T32 has approximately 8% of the area with D2 and D3 soil disturbance and 2.5% of the area with 

detrimentally compacted soils.

Table 7. Description of Disturbance Classes

D0 – Undisturbed D1 – Slightly 

Disturbed

D2 – Moderately 

Disturbed

D3 – Highly Disturbed

Soil Surface:

- No evidence of 

equipment operation

Soil Surface:

- Light tracks, slight 

depressions

- Duff and litter cushion 

mostly in place

- Topsoil in place

Soil Surface:

- Clear tracks

- Duff and litter 

displaced, or reduced 

- Topsoil exposed and 

mixed or compacted

Soil Surface:

- Prominent tracks, main 

skid trail or landing

- Duff and litter displaced

- Topsoil highly 

compacted, and/or eroded

Compaction:

- Soil has natural 

structure and 

resistance to spade

Compaction:

- Soil strength increase in 

top 4 inches

- Structure changes in top 

4 inches

Compaction:

- At threshold of 

detrimental compaction

- Soil strength increase 

in top 4 to 8 inches

- Some structure 

changes below 4 inches

- Platy or massive 

structure is generally 

continuous

Compaction:

- Soil strength and spade 

resistance increased to 

depth > 8 inches

- Structure changes 

continuous to 8 inches

- Platy or massive 

structure
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 55

Alternative 1 – No Action

Direct Effects and Indirect Effects

Under the Alternative 1, soil conditions would not change from the existing conditions. Soil 

transect data indicates that soil cover and large woody debris (LWD) are meeting Regional Soil 

Standard and Guideline thresholds. Soil cover will increase and LWD will increase. The average 

soil cover is 87% and the average number of LWD is approximately 65. This is well over the 

guideline of five logs per acre. Several areas within the proposed project area are not meeting 

Regional Standard and Guideline thresholds for detrimentally disturbed soils. Some areas have 15 

-20% detrimentally disturbed and compacted soils. The average throughout the project area for 

detrimental disturbed and compacted soils is approximately 6.71%. Compacted soils will 

continue to recover over time.

If vegetation is left in its current state of high fuels and high wildfire risk, it is inevitable that a 

wildfire will occur. Many areas within a potential wildfire area would not meet soil quality 

standards in terms of soil cover and surface erosion rates in a fire event. Soil cover would be less 

than 20% and some soils would develop hydrophobic conditions. Accelerated erosion will occur, 

especially during precipitation events. Soil loss could range from 10–60 tons per acre in these 

areas. Soil Productivity will be reduced in some areas by at least one site class. Past monitoring of 

wildfire areas on the nearby Stanislaus National Forest has found that bare ground averaged about 

70% by spring of the first year and by spring of the second year bare ground averaged 27% 

(Janicki, 2003). In a study conducted by Berg and Azuma (2002) bare ground and evidence of 

surface erosion recovered to pre-fire conditions within four to five years after a wildfire. Large 

woody debris would probably be consumed in a fire and long term soil productivity could be 

decreased without large woody debris.

Cumulative Effects 

Cumulative soil effects have been addressed under the cumulative watershed effects (CWE) 

section under the Hydrology/Water Quality Section. Analysis of cumulative soil effects use the 

Equivalent Roaded Acre (ERA) Model, which is used in the CWE analysis. The ERA model 

quantifies disturbance based on the degree of disturbance as compared to an acre of road and 

measured relative to disturbance in a given watershed. ERAs reflect changes to Soil Hydrologic 

Function, and are an indicator of rutting potential, erosion potential and loss of water control. See 

Sugar Pine Adaptive Management Project CWE Analysis (Gallegos 2008) for a full description 

of assessment and assumptions including list of past, present and future foreseeable actions. The 

Forest Service Pacific Southwest Region (R5) methodology is used to determine the overall 

disturbed footprint. The disturbed footprint is a semi-quantitative measure of acres of detrimental 

soil disturbance and hence an approximation of change in Soil Quality as defined by the R5 Soil 

Quality Standards (USDA-FS 1995).

The Sugar Pine CWE Assessment modeled recovery from previous management actions over a 

30 year time span for 12 subdrainages for the existing condition and No Action Alternative. Two 

of those subdrainages (501.5053 and 503.0055) are currently exceeding their lower threshold of 

concern for cumulative watershed effects. A detailed field assessment of those subdrainages did 

not find any evidence that cumulative watershed effects were occurring. Other planned actions 

that are not part of this decision would still occur, but the total ERAs in the project subwatersheds would be lower than if the project was implemented. 
Chapter 3: Affected Environment and Environmental Consequences

56 Sierra National Forest

Alternative 2 – Proposed Action

Direct Effects and Indirect Effects

The following is a discussion of the various kinds of treatments proposed and their potential 

direct and indirect effects to the soil resource. 

Commercial and Biomass Thinning activities (mechanical harvesters), Mastication operations, 

Pre-commercial Thin/Release operations, and Tractor Piling operations use equipment that 

includes steel tracked heavy equipment and rubber tired tractors. These activities have the 

potential to impact the soil resource by mechanically disturbing the soil or compact the soil. 

Planting and hand release operations do not effect the soil resource. 

Soil Disturbance and Soil Porosity or Soil Compaction

Mechanical harvesters and rubber tired tractor skidders used for the proposed commercial and 

biomass thinning, tractor piling, and mastication will cause soil disturbance and their use poses 

increased risk of detrimental soil disturbance, detrimental soil compaction and accelerated soil 

erosion. Standard operating procedures such as cross ditching skid trails for erosion control will 

reduce the risk of erosion and promote surface soil stabilization and re-vegetation. Tractor 

logging is planned for areas with slopes under 35%, which will reduce excessive soil 

displacement. Areas of slopes in excess of 35% should be logged with a cut-to-length logging 

system or logs should be favorable skidded to prevent undue soil disturbance. The soils in this 

project area are highly productive so rapid natural re-vegetation is expected. 

Holland soils are highly susceptible to soil porosity loss, due to compaction from heavy 

equipment, such as rubber tired skidders and mechanical harvesters operating when soils are 

moist or wet. Holland soils occur in treatment areas T3, T4, T5, T6, T7, T8, T9, T10, T11, and 

T16. These units are highly susceptible to detrimental soil compaction exceeding 15% of the 

treatment area. Treatment areas T3, T4, and T8 have detrimentally compacted soils at 9-10% and 

treatment area T26 has detrimentally compacted soils at 15%. Parts of treatment area T3 and T8 

have detrimentally compacted soils at 20%. These treatment units will probably exceed 15% of 

the treatment unit in detrimentally compacted soils immediately after the first phase of project 

implementation. 

In order to minimize detrimental soil compaction, soil moisture needs to be dry enough to reduce 

the susceptibility to compaction during thinning and biomass removal operational periods. The 

ideal moisture content varies between soils and should not be above 12% to prevent soil 

compaction. A soil scientist or other earth scientist will be consulted prior to mechanical 

equipment operating on soils that have a moderate soil compaction hazard. The standard 

operating period from June 1 to October 15, and avoidance of operating mechanical equipment on 

soils with more than 12% soil moisture should minimize detrimentally compacted soils in an 

average rain year (See Soil Design Measure 2 and 3).

Areas with detrimentally compacted soils should be less than 15% for most of the treatment areas. 

Some portions of the commercial thin or biomass treatment areas (Units T3, T4, T8, and T26) 

will have detrimentally compacted soils in excess of 15% until subsoiling is completed in the 

unit. Subsoiling will occur after the last mechanical treatment is needed, generally the 2nd year 

after the initial commercial thinning operation or biomass treatment. Detrimentally compacted 

soils in excess of 15% will probably occur for at least 1 year, until after tractor piling of slash has 

occurred in the second year of project implementation. Subsoiling landings (BMP 1-16) and 

primary and secondary skid trails should result in less than 15% of the treatment areas with 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 57

detrimentally compacted soils. Soil productivity will be reduced in areas with detrimentally 

compacted soils for 1 or 2 years. 

There are no potential indirect effects of the proposed action if soil compaction is kept to less 

than 15% of an activity area and erosion control measures are implemented in a timely manner. 

There could be an occasional summer storm event that could cause accelerated erosion of bare 

exposed soils. In the event that this should occur soil erosion sites will be restored to pre-storm 

conditions.

Large Woody Debris (LWD)

Commercial thinning, biomass removal and tractor piling will probably reduce existing fuel loads 

to levels where fire hazards and fuels have been reduced to achieve the desired conditions for the 

Wildland Urban Interface. After treatment, on the ground fuel loads are expected to be no more 

then 5 – 10 tons/acre (see Fire/Fuel Section). This will probably reduce existing LWD to at least

25% of existing levels, which will be higher than the minimum five logs per acre that is needed to 

meet the Soil Standard and Guideline Threshold for LWD.

Soil Cover

In areas where tractor piling of slash is planned, it is a normal Sierra NF practice to leave at least 

50 percent, well distributed soil cover for erosion protection on slopes under 35%. If slopes are 

greater than 35%, soil cover should be at least 70%. Past observations on the Sierra NF have 

found that this amount of soil cover generally prevents accelerated erosion. A buffer of 100 feet

will be provided around rock outcrop to prevent accelerated erosion of the adjacent soils from 

rapid runoff from rock outcrops. 

Mastication Treatment Areas

Areas planned for mastication pose little risk of reducing soil productivity. This includes all of the 

M treatment areas, including M4, which is proposed for Fuel Break Maintenance. The masticator 

equipment reduces erosion potential by increasing soil cover and generally causes little soil 

disturbance and compaction. Soil masticating equipment generally does not result in compacted 

soils because the equipment has lower ground pressures then conventional logging equipment and 

because this treatment creates a bed of chips that the masticator travels over. All mastication 

treatment units have slopes in excess of 35%. Most mastication treatment will be on slopes less 

the 35%; however some areas with slopes in excess of 35% will be treated. This will probably 

occur in treatment areas M1, M5 and M7. A minor amount of soil disturbance will probably occur 

where the masticator makes turns during the operations. Soil disturbance will be higher on steeper 

slopes.

Prescribed Fire

Areas planned for prescribed fire pose little risk of causing significant effects to soil productivity 

based on the past performance of the prescribed fire program on the Sierra National Forest. Past 

prescribed fires on the forest has resulted in low burn intensity in most areas. Prescribed fire 

burns in a mosaic pattern leaving patches of unburned vegetation and patches of burned areas, 

where duff and litter is completely consumed. Most trees are left undamaged, except for a few 

small patches that have burned at moderate burn intensity with moderate burn severity. Soil 

quality standards have been met from past prescribed fires and are expected to be met from the 

proposed action. Soil cover of 50% is expected to be met in the prescribed fire treatment areas.
Chapter 3: Affected Environment and Environmental Consequences

58 Sierra National Forest

Road Construction

Approximately 0.7 miles of new and temporary road construction is proposed for the Sugar Pine 

Project. Road construction results in removal of surface soils and subsoil and complete loss of 

soil productivity within the road prism. The 0.7 miles of road is approximately 1.2 acres of 

ground with total loss of soil productivity. The direct effect of this new road construction is 

irreversible and irretrievable. Erosion on newly constructed roads is usually higher immediately 

after the road is constructed. There is potential that accelerated erosion could occur off the road 

prism and reduce soil productivity off site and after the road is constructed. Applicable soil and 

water conservation Best Management Practices (BMP) will be implemented, including erosion 

control measures, such as water bars, straw mulching of fills and fertilization of soils to revegetate the bare soils. Road reconstruction and road maintenance operate within the road prism 

and have little effect to the soil resource. However, there can be a positive effect to the soil 

resource out site of the road prism from road reconstruction by restoring proper drainage features 

of the road. Restoration of drainage features will result in less surface erosion and soil loss that 

leads to loss in soil productivity.

Cumulative Effects

Cumulative soil effects have been addressed under the cumulative watershed effects (CWE) 

section under the Hydrology/Water Quality Section. See the discussion in the No Action 

Alternative, Soil Cumulative Effects section for additional discussion on soil cumulative effects. 

The Sugar Pine CWE Assessment, modeled disturbance from the proposed action and recovery 

from previous management actions over a 30 year time span for 12 subdrainages. Five of those 

subdrainages (501.5006, 501.5007, 501.5053, 503.0010 and 503.0055) will exceed their lower 

threshold of concern for cumulative watershed effects after the project is implemented, but not 

their upper Threshold of Concern of 14%. A detailed field assessment for subdrainages 501.5053 

and 503.0055 did not find any evidence that cumulative watershed effects was currently 

occurring. Implementation of Soil and Water Conservation Best Management Practices and other 

design measures, including subsoiling of detrimentally compacted soils will minimize effects to 

the soil resource. No significant impacts to soil productivity are expected if soil cover is over 

50%, detrimental soil disturbance and detrimental soil compaction is limited to no more than 15% 

of a treatment unit; and large woody debris is at least five logs per acre.

Alternative 3

There is virtually no difference between Alternative 2 and Alternative 3 to the soil resource (see 

effects analysis for Alternative 2). The only difference between Alternative 2 and 3 is an 

additional limited operating period for treatment areas T3 and T4. The same acres will be treated, 

but fewer larger trees will be removed in treatment areas T3 and T4. These fewer trees result in 

fewer trips with mechanical equipment, but this will probably have no measurable effect.

Alternative 4

This alternative would, in effect, assume the entire project area as a Pacific Fisher den site, 

whereby, it would be treated to achieve fire and fuels objectives for the urban wildland intermix 

zone and limit treatments to mechanical clearing of ladder and surface fuels. As such, all design 

criteria and SNFPA ROD (USDA-FS 2004b) standards and guidelines associated with Pacific 

Fisher densites would be implemented with this alternative. 

There is no difference between Alternative 2 and Alternative 4 to the soil resource (see effects 

analysis for Alternative 2). The only difference between alternative 2 and 4 is an additional 

limited operating period for the whole project area. The same acres will be treated, but those acres 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 59

that are proposed for commercial thinning in Alternative 2 will be treated for biomass removal. 

Fewer larger trees will be logged in the (T) treatment areas. The same equipment will be used to 

remove the biomass and the potential for disturbing soils is similar to Alternative 2. 
Chapter 3: Affected Environment and Environmental Consequences

60 Sierra National Forest

Lands/Special Uses__________________________

The direct, indirect and cumulative effects to Lands and Special Uses are summarized from the 

Lands and Specials Uses Report for the Sugar Pine Adaptive Management Project (Nooney, K. 

2008).

Affected Environment

There are numerous land-type special uses authorized under permit within the project area 

including: water systems (spring developments, water lines and storage tanks) that provide 

potable water to Sugar Pine Camp/Yosemite Mountain Railroad, and for an individual residence; 

buried fiber optic and telephone lines; a telephone carrier site along the Sugar Pine Road 630; 

overhead and buried electrical lines; the Madera Irrigation District‘s gauging station; private and 

County roads; signs, and apiary sites. 

Recreation special uses authorized under permit in the project area include the Yosemite 

Mountain Sugar Pine Railroad (YMSRR) and Yosemite Trails Pack Station (YTPS). The 

YMSRR operates the railroad 6 months a year between March and October; however, their peak 

visitor season is between June and mid-August. 

The Yosemite Trails Pack Station offers horseback rides three seasons of the year from their pack 

station headquarters. In addition, YTPS offers horse driven sleigh rides during winter months 

when snow conditions are favorable from a secondary location south of Tenaya Lodge. The 

YTPS is authorized to use and maintain some of the horseback riding trails they take their clients 

on. 

The Lewis Creek Recreation Trail crosses through the southern portion of the project area.

Map 5, found in the Map Package in Appendix A, identifies the permitted special uses found 

within the project area and how they relate to the proposed treatment areas. 

Alternative 1 – No Action

Direct, Indirect and Cumulative Effects

Under the No Action alternative, current management plans would continue to guide activities in 

the project area. This includes all ongoing activities with existing decisions or permits that would 

not be changed if this alternative were selected. This would include all current uses as permitted. 

While special use permittees would continue to perform hazardous fuels reduction around the 

facilities they operate, they would be limited to the standard 100 feet required by the State of 

California. Like the community of Sugar Pine, there would be no added protection from moderate

to high intensity fires. 

The continuation of natural fuels build-up could pose a wild fire threat to permit holder 

improvements, and for commercial permit holders, a loss of revenue. Overstocked stands have the 

potential to be effected by epidemic infestations of bark beetles and, in combination with disease, 

and/or drought-induced mortality, the forested areas the commercial permit holders depend on for 

their livelihood are at risk. Commercial permit holders would likely experience loss of revenue 

because forest visitors they depend on may be hesitant to visit parts of the forest that have high 

tree mortality. As public safety concerns (mainly from snag densities and high fire danger) began 

to increase there would be the potential need for areas to be closed to public access.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 61

Alternative 2 – Proposed Action

Direct, Indirect and Cumulative Effects

Alternative 2, like the No Action alternative, would not change the management and currently 

permitted activities within the project area. The activities associated with the proposed action 

would include commercial, pre-commercial and biomass thinning of conifer stands and 

prescribed burning (understory and pile) with associated post-activity treatments. These are the 

actions that have the largest possibility of effecting special use permitted operations. Design 

criteria were developed to minimize the impacts that could occur from the implementation of this 

alternative and are listed on pages 16-26.

Alternative 3

Direct, Indirect and Cumulative Effects

The effects of this alternative would be similar to that of Alternative 2. 

Alternative 4

Direct, Indirect and Cumulative Effects

The effects of this alternative would be similar to that of Alternative 2.
Chapter 3: Affected Environment and Environmental Consequences

62 Sierra National Forest

Terrestrial Wildlife ___________________________

The direct, indirect and cumulative effects to the terrestrial wildlife species are summarized from 

the Biological Evaluation/Biological Assessment (BE/BA) for the Sugar Pine Adaptive 

Management Project (Otto, A.; Schroer, G.; Williams, K., 2010).

Affected Environment

Species specific habitat needs as well as the habitat availability within the project area are listed 

within the following effects analysis. The effects analysis further describes the changes to this 

habitat for each alternative. Habitats in the project area are defined according to the ―California 

Wildlife Habitat Relationship‖ (CWHR), as shown in Map 7 in the Map Package. Tables 52 and 

53, in Appendix C, show the existing acres of CWHR and changes expected according to the 

action alternatives.

Management and Regulatory Framework

The Sugar Pine Adaptive Management Project is primarily designed to reduce fuels through 

forest understory fuels reduction in a Wildfire Urban Intermix Zone (WUI). Two alternatives 

(Alternatives 2 and 3), also include vegetation management (tree thinning of the lower and midlevel canopy), to improve forest health. The project also is designed to retain and enhance 

wildlife habitats over the short-term and long-term. Specific Forest Service requirements for 

managing Federally Listed and Forest Service Sensitive species and their habitats are defined in 

the following documents.

 National Forest Management Act (NFMA) 

 Forest Service Manual and Handbooks (FSM/FSH-2670) 

 Endangered Species Act (ESA)

 Sierra National Forest Land and Resources Management Plan (LRMP) 

 2004 Sierra Nevada Forest Plan Amendment (FSEIS and ROD)

The Record of Decision (ROD) for the 2004 Sierra Nevada Forest Plan Amendment includes 

Standards and Guidelines (S&G) for managing wildlife and wildlife habitats, and one of those is 

S&G No. 86 which restricts vegetation management within fisher densite buffers. This project, 

however, proposes a non-significant amendment to S&G No. 86 so that forest health vegetation 

management can be implemented in fisher densite buffers so that researchers can assess the 

effects of that management on Pacific fisher and fisher habitat. This non-significant amendment 

is limited to only this project and it is applicable to only Alternatives 2 and 3, since Alternative 4 

does not have such forest health vegetation treatments. Chapter 2, of this FEIS, provides 

additional details of this non-significant amendment to S&G No. 86. 

Methodology for Analysis

Initially, 14 terrestrial wildlife species that are Forest Service Sensitive Species or Federally listed 

or candidate species, were identified as potentially present in or near the project area. Further 

assessments showed that 8 of those 14 species, or their habitats, exist, or are believed to exist, in 

or near the project area, and that project management may directly, indirectly, or cumulatively 

affect them. Those 8 species were analyzed in detail in the Terrestrial Wildlife Biological 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 63

Evaluation and Biological Assessment (BE/BA), and a summary of that analysis is provided here, 

including Table 8 which is the final determination of project effects on those species.

Table 8. Determinations of the effects of the Sugar Pine Adaptive Management Project on 

terrestrial wildlife species analyzed in detail in the Biological Evaluation and Biological 

Assessment (BE/BA). 

Determination of Project Effects

Species Alternative 1 Alternative 2 Alternative 3 Alternative 4

Pacific fisher No effect may affect 

individuals, but is 

not likely to lead to 

federal listing or 

loss of viability

may affect 

individuals, but is 

not likely to lead to 

federal listing or 

loss of viability

may affect 

individuals, but is 

not likely to lead 

to federal listing 

or loss of viability

American marten No effect may affect 

individuals, but is 

not likely to lead to 

federal listing or 

loss of viability

may affect 

individuals, but is 

not likely to lead to 

federal listing or 

loss of viability

may affect 

individuals, but is 

not likely to lead 

to federal listing 

or loss of viability

Pallid bat No effect may affect 

individuals, but is 

not likely to lead to 

federal listing or 

loss of viability

may affect 

individuals, but is 

not likely to lead to 

federal listing or 

loss of viability

may affect 

individuals, but is 

not likely to lead 

to federal listing 

or loss of viability

Western red bat No effect No effect No effect No effect

Townsend‘s big-eared 

bat

No effect No effect No effect No effect

Great gray owl No effect may affect 

individuals, but is 

not likely to lead to 

federal listing or 

loss of viability

may affect 

individuals, but is 

not likely to lead to 

federal listing or 

loss of viability

may affect 

individuals, but is 

not likely to lead 

to federal listing 

or loss of viability

California spotted owl No effect may affect 

individuals, but is 

not likely to lead to 

federal listing or 

loss of viability

may affect 

individuals, but is 

not likely to lead to 

federal listing or 

loss of viability

may affect 

individuals, but is 

not likely to lead 

to federal listing 

or loss of viability

Northern goshawk No effect may affect 

individuals, but is 

not likely to lead to 

federal listing or 

loss of viability

may affect 

individuals, but is 

not likely to lead to 

federal listing or 

loss of viability

may affect 

individuals, but is 

not likely to lead 

to federal listing 

or loss of viability

Mitigation and Monitoring

This project integrates management design measures that help mitigate potential impacts to 

wildlife habitat. These measures include, but are not limited to, Limited Operating Periods to 

avoid breeding seasons, forest retention zones for perennial streams and Old Forest Linkages, and 

large tree group and black oak retention. The forest management proposed in this FEIS is part of 

the Sierra Nevada Adaptive Management Project (SNAMP) research, which assesses fisher and 

fisher habitat three years prior to treatment, during treatment, and two years post-treatment. 

Details of this adaptive management research are included in the Terrestrial Wildlife Biological 

Evaluation/Biological Assessment (BE/BA) (Otto, A.; Schroer, G. and Williams, K. 2010).
Chapter 3: Affected Environment and Environmental Consequences

64 Sierra National Forest

Alternative 1 – No Action

Direct Effects

There would be no direct effects to any terrestrial wildlife species under this alternative.

Indirect Effects

There may be indirect effects to terrestrial wildlife habitat if Alternative 1 is selected as no fuels 

treatments would occur and the continued immediate threat of catastrophic wildfire would remain 

unabated. Additionally, in failing to reduce stand density, drought stress and subsequent insect 

and disease mortality would exacerbate the threat of uncharacteristically severe wildfire. 

Furthermore, the high probability of a drying climate change in the Western United States would 

potentially further compound these effects.

Cumulative Effects

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). Effects are spatial 

and temporal. In determining cumulative effects, the effects of the past, present and future actions 

were added to the direct and indirect effects of the proposed action and alternatives. Table 3 on 

page 33 of this document list those other activities. Alternative 1 will not produce impacts to the 

environment that add to cumulative effects.

Alternative 2 – Proposed Action

Treatment areas within the project area boundary include those areas where some form of 

treatment was necessary to meet the purpose and need. First, treatment areas were designed to 

create SPLATs to reduce the intensity and spread of wildfires in and around WUI. Next, 

treatment areas near key transportation corridors (egress and ingress into the local community) 

and within the defense zone of the WUI were designed. Treatment areas also were designed to 

meet fire and fuel objectives (lower and limited midlevel canopy treatments), but also forest 

thinning of mid level canopy trees also will be implemented in overstocked stands to improve 

forest health (basal area and stand densities that are greater than can be sustained with changing 

environmental conditions) (Map 1 in the Map Package). Of the 5,416 total acres within the 

project boundary, approximately 2,920 acres were analyzed as areas where some form(s) of 

treatment are proposed (so named as treatment areas). The remaining 2,496 acres have no 

treatments proposed, such as slopes greater than 35 percent that are too steep for mechanized 

treatments. Additionally, there are areas where Forest Service standards and guidelines limit 

treatment and/or no treatments are proposed.

Project design criteria common to all alternatives were developed through the collaborative 

process of the SNAMP Integration Team and they were designed to maintain habitat connectivity, 

special habitat elements for terrestrial wildlife species, and limits on the amount of behavioral 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 65

disruption during project implementation and post-treatment. Project design criteria are outlined 

in Chapter 2 of this document.

Direct Effects

There are no expected direct effects to the great gray owl, Townsend‘s big-eared bat, and western 

red bat, due to a lack of suitable habitat for those species within the project area. 

Direct effects may occur to California spotted owl, northern goshawk, American marten, Pacific 

fisher, and pallid bat, although that would be limited to the short-term noise disturbance of the 

project management, which potentially could lead to an energetic expense from avoidance 

reactions. No direct mortality from project activities is expected to occur to these species. 

Limited Operating Periods will be implemented, for a variety of species, to protect nest and 

densites, as described in the BE/BA. In particular, a fisher LOP will be implemented for all 

suitable fisher habitat, throughout the project area, regardless of whether a densite buffer is 

present.

Indirect Effects

Effects to Terrestrial Wildlife Habitat: Existing acres of CWHR vegetation type (base 

vegetation layer) were determined using the Sierra National Forest Corporate Geographic 

Information System (GIS) vegetation feature class of 2001 (ExistingVeg2001_pl). This base 

layer was refined using existing structure analysis from more than 50 stand examination plot data 

collected in 2007 and 2008, as well as forest aerial photography interpretation from the 2001 

flightline, and 1 meter resolution satellite imagery from the National Agricultural Imagery 

Program (NAIP). 

Treatment acres relative to existing vegetation were based on mapping and field visits conducted 

by the District Silviculturist. These field visits refined the base vegetation layer and determined 

the net acres of treatment. Table 9 displays the CWHR vegetation changes that are expected to 

occur through implementation of the most aggressive action Alternative: Alternative 2. Due to 

project design criteria designed to maintain canopy closure of at least 50% (with a preference for 

60% or greater when conditions allow) throughout the treatment areas, CWHR type changes are 

projected for 53 acres if Alternative 2 is implemented. Through CWHR habitat analysis, changes 

through the implementation of Alternative 2 are predicted to occur in 8 of the 44 units, or 18% of 

the treatments.
Chapter 3: Affected Environment and Environmental Consequences

66 Sierra National Forest

Table 9: Alternative 2 Changes to CWHR Forest Type within treatment units of the Sugar 

Pine Adaptive Management Project

Alternative 2

CWHR Forest 

Type Pretreatment

CWHR Forest 

Type Posttreatment

Number of Acres 

of Habitat Type 

Change

MHC4D MHC4M 2 acres

PPN3D PPN3M 37 acres

SMC3D SMC3M 3 acres

SMC4D SMC4M 5 acres

JPN3D JPN3M 5 acres

PPN4D PPN4M 1 acre

Total Acres CWHR 

Habitat Density Change 53 acres

These changes to habitat may result in short term effects in the way terrestrial wildlife species 

utilize the habitat. Individuals may leave treatment areas during project implementation, and will 

likely rely more heavily on other areas of their home range. The canopy cover in the project area 

is expected to convert to higher quality habitat within 5-15 years after completion of the 

management actions as the remaining tree crowns grow and the understory develops. The 

resulting stand also should show increased health, growth rate, and resistance to large scale stand 

replacing wildfire.

There are no expected indirect effects to the following species due to lack of suitable habitat 

within the project area: Great gray owl, Townsend‘s big-eared bat, and western red bat.

Indirect Effects are summarized below for the following TES species: Pacific fisher, California 

spotted owl, Northern goshawk, Pallid bat, and American marten.

Pacific Fisher: Alternative 2 is the most aggressive management and shows the greatest amount 

of change in CWHR 2.1 fisher habitat scores. Due to project design criteria designed to maintain 

canopy closure at 50%, with a preference for greater than 60% throughout the treatment areas, 

CWHR type changes are projected for only 53 acres if Alternative 2 is implemented. Through 

CWHR habitat analysis, changes through the implementation of Alternative 2 are predicted to 

occur in 8 of the 44 units, or 18% of the treatments. These changes are relatively minor however, 

because the percentage of CWHR 2.1 habitat retained ranges from 98.57% to 99.75%. Also, as 

the majority of large trees >21‖dbh would be retained through the implementation of Alternative 

2, the Sugar Pine project area will continue to provide adequate numbers of resting and denning 

structures for fisher. As the bulk of the habitat is not being affected through the implementation 

of Alternative 2, the Sugar Pine project area will continue to retain habitat value for fishers 

currently utilizing that habitat.

If Alternative 2 were implemented there would be an average of 41 large (greater than 21‖ dbh) 

live trees per acre remaining that may serve as fisher denning or resting sites post treatment. 

There are also currently 43 standing dead conifers per acre which may be used as fisher denning 

and resting sites throughout the Sugar pine treatment areas. Snags will only be removed if they 

meet the definition of a danger tree. All currently marked danger trees (intended for removal) are 

immediately adjacent to roadways in the project area and on average less than 1 danger tree per 

acre is marked for removal. There are additional black oaks throughout the project area that may 

serve as denning or resting sites that are not accounted for in these numbers of trees per acre. 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 67

Considering 17 trees per acre as an estimate for the numbers of available resting and denning sites 

required by fisher throughout their home range, the remaining numbers of live and dead trees per 

acre calculated for the Sugar Pine project area appears adequate for maintaining these important 

habitat structures throughout the treatment areas, exceeding this figure by 250%.

There may be a short-term reduction in prey availability within some areas of the treatment areas; 

however, long-term positive effects of treatment should promote the growth and re-growth of 

understory vegetation, which provides forage for prey species, as well as hiding and thermal 

cover. The horizontal and vertical diversity of forest vegetation structure and species also may be 

improved in some sites as a result of partially opening the forest overstory, particularly with 

Alternatives 2 and 3. This in-turn would bring greater biodiversity into the stands, promoting 

greater prey species abundance and diversity.

Habitat connectivity will be maintained throughout the project area with the implementation of 

design criteria common to all alternatives including Old Forest Linkages (OFLs), and no 

treatment areas. The inclusion of untreated areas along steep sloped regions and riparian corridors 

(primarily Lewis Creek and several unnamed perennial tributaries) will maintain habitat 

connectivity and fisher dispersal routes. There are additional large areas where no treatments

were designed due to existing California spotted owl PACs within the project boundary. 

The untreated areas, interconnected with Old Forest Linkages will accommodate daily fisher 

movements as well as dispersal movements, providing habitat connectivity throughout the Sugar 

Pine project area and dispersal routes to the north and south. Fisher should also retain movement 

opportunities between adjacent high quality habitat areas such as Nelder grove and Yosemite 

Mountain Ranch. These areas of no treatment are mapped in the project BE/BA and provide a 

visual representation of movement capabilities throughout the project area during project 

implementation and post-treatment. Additionally, the inclusion of large tree groups and the 

preservation of understory vegetation in cooler, moister sites within treatment units will maintain 

heterogeneity of the habitat post treatment and aid in fisher movements.

Due to the time limitations of research being conducted within this adaptive management project, 

treatments are expected to be completed under a service contract that would last approximately 2 

years. Fishers in proximity to work crews and vehicles during project implementation may be 

disturbed sufficiently to leave the immediate area or may miss a foraging opportunity, resulting in 

an energetic expense. Design criteria common to all action Alternatives includes a Limited 

Operating Period (LOP) from March 1 through June 30 which will be applied to all potential 

fisher denning habitat and should limit potential disturbance to females during denning and kit 

rearing. Units with a fisher LOP are outlined in the project BE/BA.

Disturbance of habitat may result in short term effects in the way fisher utilize the habitat. Fisher 

may leave treatment units during project implementation, and will likely rely more heavily on 

other areas of their home range. Individual energetic expenses may be increased if fishers have to 

travel farther to forage, however with areas of adjacent suitable habitat outside treatment areas 

but within their home range, it is unlikely this would result in individual mortality.

Habitat disturbance in the project area may lead to increased predation of fisher by mountain lion, 

bobcat, or coyote. Predation potential could increase if an individual fisher were to move into 

unfamiliar habitat, although this would be unlikely as all male and female home ranges extend 

beyond the Sugar Pine project boundary. Habitat disturbance in the project area may also 
Chapter 3: Affected Environment and Environmental Consequences

68 Sierra National Forest

exacerbate individual fisher mortality induced by disease. The degree of these potential effects 

are unknown, but may be illuminated through the SNAMP research.

Long-term positive effects of fuels treatments (due to the reduction of fire hazard) outweigh the 

short-term negative effects of fuel treatments (due to immediate loss of forest biomass) on fisher, 

especially when assuming a more severe fire regime in the future. Vegetation treatment has 

short-term impacts to habitat quality, particularly over the first year, however, new understory 

growth within the first two years by herbaceous, as well as woody vegetation, can also lead to 

habitat enhancement for a variety of wildlife, including fisher and fisher prey species, in the form 

of new forage and hiding/thermal cover. Habitat recovery following a severe wildfire will take 

considerably longer—based on the silvicultural report prepared for this project an estimated 90-

110 years if brought back to conditions similar to the historical logging that occurred around 

Sugar Pine. 

California Spotted Owl: No treated Protected Activity Center (PAC) will be reduced to less than 

70% canopy cover and no treated Home Range Core Area (HRCA) will be reduced below 60% 

canopy cover where such cover currently exists. Minimal changes in CWHR habitat stages will 

occur in unit T3 where 5 acres of PPN3D are expected to become PPN3M. Habitat that is 

currently suitable for California spotted owl nesting and foraging activities will remain suitable 

for those purposes post treatment.

There are 215 acres of proposed understory burning as a primary fuels treatment throughout the 

Sugar Pine project area. No prescribed burning is proposed in any California spotted owl activity 

centers as a primary treatment; however low intensity prescribed burning may occur throughout 

treatment units as a secondary fuels maintenance treatment. A total of 251 acres of mastication 

are proposed in spotted owl PACs/HRCAs. Understory burning and mastication activities may 

eliminate some woodrat nests within the project area, which could lead to a decrease in available 

prey items and therefore an indirect effect to the California spotted owl. Since the scope of the 

primary proposed burning is limited within the project area to 215 acres, and any burning 

occurring as a secondary fuels treatment will be of low intensity, this effect will be negligible. 

Although there will be a short term decrease in woodrat numbers, it is anticipated that woodrats 

would return to treated areas from adjacent areas within a few years. Additionally, availability of 

other prey items such as flying squirrels should remain constant as their nests/dens occur higher 

in the canopy and would not be affected by an understory burn or through mastication.

Northern goshawk: Goshawk protocol surveys conducted previously for this project located one 

new goshawk activity center within the project area: SIEGH56. All goshawk nest sites within the 

project area will be protected by an LOP from February 15 through September 15. Outside of the 

LOP, portions of the two goshawk PACs will be thinned to the degree allowed under the SNFPA 

ROD (USDA-FS 2004b), considering that the PACs are located within the WUI ―Defense‖ Zone 

around the Sugar Pine community. The PACs will not be reduced to less than 70% canopy cover, 

where available; therefore, will not be diminished to less than nesting habitat. All snags will be 

retained during project implementation except in those cases where they pose a hazard.

There may be a disturbance to Northern goshawk prey base during project implementation. Birds, 

squirrels, and other small animals may leave treatment areas for the short term period when lower 

canopy fuels are being removed. However, these animals should return to the area shortly after 

work is completed. An LOP will be enforced on all goshawk PACs within the project area so no 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 69

work will occur during breeding season. It is expected that any goshawk foraging in areas where 

work is occurring will move to adjacent areas of the forest to forage. 

Pallid Bat: Suitable roosting and maternal cavity habitat may be affected in treatment areas 

where trees from 20‖ to 30‖ dbh may be harvested, since conifer trees in that size class may have 

suitable cavities for pallid bat roosts and maternal sites. As this project proposes to thin from 

below, a relatively small number of trees in that size class have been proposed for removal. 

Potential suitable habitat occurs across the majority of the project area, so it is possible that some 

suitable roost or maternal trees may be removed. Post-treatment foraging opportunities should be 

enhanced or not significantly changed because understory vegetation will be cleared in some 

areas and retained in others which will provide a diversity of microhabitats for ground dwelling 

insect prey.

American Marten: The Sugar Pine Adaptive Management Project proposes to maintain the 

highest canopy closure possible while still meeting fire and fuels objectives, and under 

Alternatives 2 and 3 managing for forest health and stand density as well. The prescriptions aim 

for a canopy closure of >50%, with a preference of greater than 60% immediately post treatment. 

All Standards and Guidelines from the SNFPA ROD (USDA-FS 2004b) will be followed in the 

implementation of this project. As this project proposes thinning from below, very few changes in 

CWHR habitat type are expected to occur throughout the entire Sugar Pine Project area. Under 

the most aggressive Alternative (Alternative 2) 53 acres of CWHR habitat will experience a 

density type change spread across 8 treatment areas. The majority of these habitat changes will 

occur in areas below 6,000 feet in elevation, which is where the lowest marten active grid cell 

was detected. One area, T-33, will change the stand density of 5 acres of Jeffrey pine habitat from 

JPN3D to JPN3M. No habitat that is currently suitable for denning will be reduced below suitable 

denning habitat. Detailed CWHR habitat information for each treatment area can be found in 

Appendix G of the Sugar Pine Adaptive Management Project Terrestrial Biological 

Assessment/Biological Evaluation (Otto, A.; Schroer, G. and Williams, K. 2010). 

Habitat connectivity will be maintained throughout the implementation of all Action Alternatives 

by design criteria common to all alternatives including Old Forest Linkages and no treatment

areas. The inclusion of untreated areas along steep sloped regions and riparian corridors 

(primarily Lewis Creek and several unnamed perennial tributaries) will maintain habitat 

connectivity and marten dispersal routes. There are additional large areas where no treatment 

areas were designed due to existing California spotted owl PACs within the project boundary.

Marten habitat preferences and structure is similar to fisher habitat, though martens have a higher 

elevational range. Project design measures, specifically for fisher habitat, will ensure that 

sufficient legacy structures (large trees with defects, large snags, and large downed logs) will 

remain after treatment and follow-up treatments to maintain habitat suitability for martens as 

well. An LOP from May 1 to July 31 will be applied to a 100-acre buffer around known marten 

densites which will reduce potential disturbance to martens during the reproductive season. There 

are no currently known marten densites in or near (within 1 mile) the Sugar Pine project area.

There may be a short-term reduction in prey availability within some areas of the treatment areas; 

however, long-term positive effects of treatment should promote the growth and re-growth of 

understory vegetation, which provides forage for prey species, as well as hiding and thermal 

cover. The horizontal and vertical diversity of forest vegetation structure and species also may be 

improved in some sites as a result of partially opening the forest overstory, particularly with 
Chapter 3: Affected Environment and Environmental Consequences

70 Sierra National Forest

Alternatives 2 and 3. This in-turn would bring greater biodiversity into the stands, promoting 

greater prey species abundance and diversity.

The project area is at the lowest recorded elevation for marten use in the area, and marten may 

not even use the project area, and if they do, they most likely only would use it and nearby areas 

only occasionally and not as part of core areas of their home ranges, which are known to typically 

be at higher elevations. Further studies of forest carnivores conducted by the adaptive 

management research project will provide further information regarding potential marten use of 

the project area and nearby the project area.

Due to the time limitations of research being conducted within this adaptive management project, 

treatments are expected to be completed under a service contract that would last approximately 2 

years. Long-term positive effects of fuels treatments (due to the reduction of fire hazard) 

outweigh the short-term negative effects of fuel treatments (due to immediate loss of forest 

biomass) on marten, especially when assuming a more severe fire regime in the future. Habitat 

within the Sugar Pine treatment areas is expected to recover within 5-10 years post-treatment, and 

should reach current conditions within 15 years. Habitat recovery following a severe wildfire will 

take considerably longer—based on the silvicultural report prepared for this project an estimated 

90-110 years if brought back to conditions similar to the historical logging that occurred around 

Sugar Pine.

Cumulative Effects

Potential Cumulative Effects by Species

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). Effects are spatial 

and temporal. The following is a cumulative effects assessment for TES terrestrial wildlife 

species considering past, present, and reasonably foreseeable activities. Additional details of 

cumulative effects can be found in the Terrestrial Wildlife Biological Evaluation and Biological 

Assessment (BE/BA), as well as Chapter 3 of this EIS. The Council on Environmental Quality 

issued an interpretive memorandum on June 24, 2005 regarding analysis of past actions, which 

states, ―agencies can conduct an adequate cumulative effects analysis by focusing on the current 

aggregate effects of past actions without delving into the historical details of individual past 

actions.‖ Therefore, we use the existing conditions to reflect the aggregate impact of prior human 

actions and natural events that have affected the environment and might contribute to cumulative 

effects. 

Pacific Fisher

Assessment Area: The assessment area, for cumulative effects analysis of past, present, and 

reasonably foreseeable activities on fisher, is the Southern Sierra Fisher Conservation Area 

(SSFCA), which is approximately 1,018,000 acres in size. This conservation area is defined by an 

elevational band from 3,500 to 8,000 feet on the Sierra and Sequoia National Forests, and 

includes the known occupied range of the fisher in the Sierra Nevada (USDA 2001b: A-45). This 

is an appropriate scale for cumulative effects analysis because the SSFCA is an integral 

component of the conservation strategy described in the SNFPA ROD (USDA-FS 2001b: A- 43).
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 71

Prior Land Use: Native Americans were the inhabitants of the SSFCA, and their uses most 

likely were limited to hunting and gathering, as well as potentially supplementing naturally 

ignited forest fires with fires that promoted wildlife and plant forage. During the early 1900‘s, 

extensive rail-road logging cleared some areas of the SSFCA, including portions of the project 

and nearby areas. Clearcutting and salvage logging occurred from the mid 1960s to about 1972, 

sanitation and salvage harvests occurred from 1972 through 1978, clearcutting, shelterwood 

cutting, and salvage harvests from 1978 through 1992, and commercial thinning from below and 

salvage logging in recent times. The only substantial fires during the past 30 years were the Rock 

Fire in 1981, the Big Creek Fire in 1995 and the North Fork Fire in 2001; each fire burned about 

3000 acres of forest. Clearcuts or areas burned from approximately 1950 to 1972 are most likely 

plantations today, exhibiting size class 3 and density class M, or greater. Other, more recent 

disturbances, while they may be reforested, have probably not yet reached size class 3.

Sugar Pine Project: As discussed in the direct and indirect effects section, the most aggressive 

management action alternative (Alternative 2) of the Sugar Pine Adaptive Management Project 

will have minimal effects to fisher habitat (CWHR 2.1 habitat) (refer to the previous indirect 

effect assessment and the BE/BA for details). Specifically, all action alternatives will retain a 

high degree of overstory forest canopy cover (>50% with a preference for 60%, when conditions 

allow); all trees >30 inches dbh, and all snags, will be retained during mechanized treatments, 

except where they pose an immediate safety hazard. Trees >21 inches dbh will be retained, in 

adequate quantity, to help assure availability of resting and denning structures now and into the 

future. Black oaks also will be retained, as well as large tree groups. The project will not impede 

movement or dispersal to other currently connected suitable habitat areas because habitat 

connectivity will be maintained within and adjoining the project area. And no treatments will 

occur throughout suitable fisher habitat during their breeding season.

All action alternatives also may result in long-term positive effects to the fisher by: 1) reducing 

the potential for large scale, stand eliminating wildfires; and 2) promoting the growth and regrowth of understory vegetation, which provides forage for prey species, as well as hiding and 

thermal cover. The horizontal and vertical diversity of forest vegetation structure and species 

also may be improved in some sites as a result of partially opening the forest overstory, 

particularly with Alternative 2 and 3. This in-turn would bring greater biodiversity into the 

stands, promoting greater prey species abundance and diversity, including promoting the 

establishment and improved growing conditions of black oaks, which are important components 

of fisher habitat. These factors, combined with the project measures implemented to sustaining 

Pacific fisher, outweigh the short-term negative effects of treatments (due to partial loss of forest 

biomass and disturbance), especially considering that a more severe fire regime is predicted for 

the future, and without fuels reduction, large scale, stand replacing wildfires would most likely 

cause serious and significant impacts to the fisher population. 

Other Current and Future Land Management Projects: Currently there are four land 

management projects on the Bass Lake District that are of the size that could influence the 

cumulative effect on fisher habitat. NEPA has been completed for three of the four projects, 

including: Sonny Meadows North (with 955 acres of treatments), Sonny Meadows South (with 

1,400 or more acres of commercial thinning), and Cedar Valley (with approximately 915 acres of 

commercial thinning). There is also one reasonably foreseeable project; Fish Camp, (with 2,000-

3,000 acres of treatments). It was determined that proposed treatments for Sonny Meadows North 

and Sonny Meadows South would not result in loss of suitable habitat, although temporary, 
Chapter 3: Affected Environment and Environmental Consequences

72 Sierra National Forest

activity-related disturbances are expected within proximity of management activities. Overall 

habitat suitability will increase over the long term as a result of the proposed treatments, and the 

project will not increase habitat fragmentation since post-harvest habitat will remain suitable. It 

was determined that the Cedar Valley project may result in a short-term reduction of denning 

habitat on approximately 628 acres. However, this habitat will remain suitable as foraging habitat, 

and is expected to recover within 10-15 years to higher quality habitat. The Cedar Valley project 

will not impede movement or dispersal to other currently connected suitable habitat areas. The 

proposed Fish Camp fuels reduction project is in the initial planning stages, but will include 

provisions similar to those proposed for Sugar Pine for fisher conservation and will be fully 

analyzed through the NEPA process to help ensure management effects are addressed. 

The High Sierra District, of Sierra National Forest, has one current project (Jose Basin 1 – 1,263 

acres of commercial thinning) where habitat would be degraded on 60 acres and 8 acres of 

foraging habitat would be diminished temporarily. This District also has two reasonably 

foreseeable projects, the Dinkey North and Dinkey South projects. Final details of those 

treatments are not known at this time, however both projects will include management provisions 

to sustain or enhance fisher populations. 

Sequoia National Forest has one current forest management project (Ice) (NEPA analysis nearly 

complete) which consists of 743 acres of prescribed burning. Three other projects are currently on 

hold pending the results of fisher impact assessments. There are 3,264 acres of potential future 

projects, in the foreseeable future, involving fuels treatments (prescribed burns and mastication) 

and some potential thinning, however, final details of the size and prescriptions for those projects 

will not be known until final planning is completed. 

All of these current and foreseeable projects will include management provisions that sustain 

fisher populations, as directed by Forest Service Standards and Guidelines and other wildlife 

conservation management requirements. All of these projects also will be analyzed through the 

NEPA process, which will help ensure management effects on species are addressed. 

Conclusion: Implementing the action alternatives (Alternatives 2-4), combined with other past, 

present, and foreseeable land management projects in the SSFCA, are not expected to have 

significant, long-term, detrimental impacts to the fisher population, and they are not likely to 

result in a trend toward Federal listing or loss of viability for the Pacific fisher. Implementing 

Alternative 1 (the no action Alternative) will not affect the Pacific fisher, although by taking no 

action to reduce fuel levels, the threat of large scale stand replacing fires will remain unabated, 

and if such an event occurs, there could be significant detrimental impacts to this species.

California Spotted Owl

At a forest-wide scale, there currently are 321 designated Home Range Core Areas and 258 

Protected Activity Centers encompassing over 113,000 acres. Over 450,000 acres of suitable 

habitat currently exist on the Forest. Considering the proposed activities, ongoing actions, and 

reasonably foreseeable activities, less than two percent of suitable habitat on the Sierra National 

Forest would be affected.

Since about the mid 1960s, past activities have included clearcutting and salvage logging (1960s 

to 1972), sanitation and salvage harvests (1972 through 1978), clearcutting, shelterwood cutting, 

and salvage harvests (1978 through 1992), and commercial thinning from below and salvage in 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 73

recent times. The only fires to burn substantial amounts of timber were the Rock Fire in 1981, the 

Big Creek Fire in 1995 and the North Fork Fire in 2001, with each fire burning about 3000 acres 

of forest. Clearcuts or burned areas that took place prior to 1972 are typically successful 

plantations today exhibiting size class 3 and density class M stands. Other, more recent 

disturbances, while they may be reforested have probably not yet reached size class 3.

In its 12-month finding in which it decided to not list the California Spotted Owl as Threatened or 

Endangered, the USFWS concluded that the scale, magnitude, or intensity of effects on the 

California Spotted Owl resulting from fire, fuels treatments, timber harvest, and other activities 

did not rise above the threshold necessitating protection of the species under the Endangered 

Species Act (USDI-FWS 2006). The USFWS reached this conclusion after considering the 

impacts of the Forest Service‘s implementation of the SNFPA ROD (USDA-FS 2004b). The 

USFWS‘ (USDI-FWS 2006) conclusion is supported by:

 Data which indicate that California Spotted Owl populations in the Sierra Nevada are 

stable and comprise 81% of the species‘ known territories.

 The anticipation that current and planned fuels-reduction activities throughout the 

range of the species will have a long-term benefit by reducing the risk of stand 

replacing wildfire; these activities embrace those described by the SNFPA ROD

(USDA-FS 2004b). 

 Protection measures are being implemented for the California Spotted Owl on private 

lands, including the largest private landholders within the range of the species.‖ 

(FSEIS, USDA-FS 2004a)

All action alternatives also may result in long-term positive effects to the California spotted owl 

by: 1) reducing the potential for catastrophic, stand eliminating wildfires; and 2) promoting the 

growth and re-growth of understory vegetation, which provides forage for prey species, as well as

hiding and thermal cover. The horizontal and vertical diversity of forest vegetation structure and 

species also may be improved in some sites as a result of partially opening the forest overstory, 

particularly with Alternatives 2 and 3. This in-turn would bring greater biodiversity into the 

stands, promoting greater prey species abundance and diversity, including promoting the 

establishment and improved growing conditions of black oaks, which are important components 

of California spotted owl habitat. These factors, combined with the project measures 

implemented to sustaining spotted owls, outweigh the short-term negative effects of treatments 

(due to immediate partial loss of forest biomass and disturbance), especially considering that a 

more severe fire regime is predicted for the future, and without fuels reduction, large scale, stand 

replacing wildfires would most likely cause serious and significant impacts to the population. 

Implementing the action alternatives (Alternatives 2-4), combined with other past, present, and 

foreseeable land management projects on the Sierra National Forest, will not have significant, 

long-term, detrimental impacts to the California spotted owl population, and they are not likely to 

result in a trend toward Federal listing or loss of viability for the California spotted owl. 

Implementing Alternative 1 (the no action Alternative) will not affect the California spotted owl, 

although by taking no action to reduce fuel levels, the threat of large scale stand replacing fires

will remain unabated, and if such an event occurs, there could be significant detrimental impacts 

to this species.
Chapter 3: Affected Environment and Environmental Consequences

74 Sierra National Forest

Great Gray Owl

While this species may move through the project area during winter movements, as there is no 

suitable breeding habitat within the project area, there are no expected direct or indirect negative 

effects to great gray owl from the project; therefore, there are no expected cumulative effects 

from the proposed project alternatives.

Northern Goshawk

The Northern Goshawk has a continuous distribution throughout the Sierra Nevada with a 

network of 56 managed territories on the Sierra National Forest. Given the scope and scale of the 

Sugar Pine Project relative to the size of the Sierra Nevada and the goshawk‘s overall North 

American distribution, the area considered in determining the cumulative effects of past, present, 

and reasonably foreseeable activities on the Northern Goshawk will focus on the Sierra National 

Forest (SNF). A determination of viability for the Northern Goshawk was made based on the 

following analysis.

Biological Evaluations for many of the past projects in the SNF were reviewed to help inform the 

present analysis. Our review of these documents revealed the following basic information about 

effects to Northern Goshawks from these activities:

 Twenty-six (26) total project Biological Evaluations (BEs) were reviewed, dating 

back to 1993 on the SNF.

 Determinations reached were:

o No effect – 4 BEs

o May affect individual goshawks, but not likely to lead to a trend toward

federal listing or loss of viability – 20 BEs

o May affect individual goshawks, and likely to lead to a trend toward federal 

listing or loss of viability – 0 BEs

o Northern Goshawk was not addressed in the document we reviewed due to 

lack of habitat or other reasons – 2 BEs

 Types of Projects: Fuels reduction, harvest, hazard tree removal, thinning, and 

underburning were the proposed activities that were most often represented in the 

sample of BEs in which the Northern Goshawk was analyzed.

 Relative to ―May Affect‖ projects, the described impacts to Northern Goshawks most 

often fell in the following categories:

o Noise disturbances

o Loss of foraging area if underburn gets out of control

o Loss of plucking trees

o Habitat quality reduction

As with other species, the SNFPA (USDA-FS 2001) provided our analysis of Northern Goshawks 

with useful historical and habitat information. Evidence suggests the low number of goshawk 

breeding territories (ranging from 12 reported in the SNFPA (USDA-FS 2001) to the 56 such 

territories known to exist today) has increased since some of the earliest data were reported by 

Grinnell and Miller (1944 – as cited in USDA-FS (2001)), because there has been no apparent 

change in the geographic distribution of Northern Goshawks in the Sierra Nevada since then. 

Thus, goshawk numbers in the SNF remain fairly stable. Reasons for this, as put forth by the 

SNFPA (USDA-FS 2001), include (1) vegetation management practices, (2) the fact that the SNF 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 75

is near the southernmost edge of the goshawk‘s range, and (3) survey efforts for goshawks may 

be lower on the SNF.

The major risk factors identified by the SNFPA (USDA-FS 2001) for goshawks are the effects of 

vegetation management and wildfires on the amount and distribution of quality habitat. 

Unfortunately, goshawk biologists are unsure of what constitutes ―high quality‖ Northern 

Goshawk habitat in the Sierra Nevada, and as a result, historical patterns of land-use and its 

effects on goshawks are difficult to interpret. Brian Woodbridge (pers. comm., 8 Sept 2006), 

however, stated that the 4D CWHR size/density class, and perhaps also 5D, is used most 

frequently by nesting goshawks. Immediately after the implementation of the Proposed Action, 

the amount of suitable habitat would not appreciably decrease.

Because the alternatives put forth in this project will result in long-term increases in Northern 

Goshawk suitable habitat over time, along with the relatively stable geographic distribution and 

population levels of goshawks in the area, and the project‘s goal of increasing large diameter 

trees, the cumulative effects of vegetation management activities in the Sugar Pine treatment 

areas taken together with past, present, and reasonably foreseeable activities on the Forest will not 

result in a loss of viability for the Northern Goshawk.

Pallid Bat

Biological Evaluations for many of the past projects in the SNF were reviewed to help inform the 

present analysis. Our review of these documents revealed the following basic information about 

effects to pallid bats from these activities:

 Twenty-six (26) total project Biological Evaluations (BEs) were reviewed, dating 

back to 1993 on the SNF. The species was not listed as Forest Service Sensitive 

until the updated list from June 1998. 

 Determinations reached were:

 No effect – 4 BEs

 May affect individual bats, but not likely to lead to a trend toward federal 

listing or loss of viability – 10 BEs

 May affect individual bats, and likely to lead to a trend toward federal 

listing or loss of viability – 0 BEs

 Pallid bat was not addressed in the document we reviewed due to lack of 

habitat or other reasons – 12 BEs

 Types of Projects: Fuels reduction, hazard tree removal, thinning, and 

underburning were the proposed activities that were most often represented in the 

sample of BEs in which the pallid bat was analyzed.

 Relative to ―May Affect‖ projects, the described impacts to pallid bats most often 

fell in the following categories:

 Loss of roosting trees/snags

 Displacement because of smoke from underburning

 Noise disturbance

Pallid bats occur most frequently below 6,000 feet and are especially sensitive to the removal of 

hardwoods (USDA-FS 2001). Except for 4D and 5D, CWHR rates all size classes and densities in 
Chapter 3: Affected Environment and Environmental Consequences

76 Sierra National Forest

blue oak woodlands as High for pallid bat, in terms of meeting its foraging needs. Montane 

hardwood conifer and montane hardwood habitats are rated low for pallid bat by CWHR 

(California Department of Fish and Game, 2005). Currently, there are 32,600 acres of blue oak 

woodlands and 251,000 acres of montane hardwoods and montane hardwood conifers below 

8,000 ft on the SNF in CWHR size classes 2 and higher. The protection, maintenance, and 

enhancement of such westside foothill oaks and montane oaks are expected to benefit pallid bats 

by ensuring the continued availability of roosting sites. Indeed, all alternatives proposed in the 

SNFPA FEIS would lead to an increase in oak species (USDA-FS 2001).

Cumulative effects discussed in the SNFPA FEIS stated that there have been no recent changes in 

the range or distribution of the pallid bat (USDA-FS 2001). For these reasons, and given the longterm objective for increasing the number of large trees across the landscape, the intention of 

reducing fuels to reduce the potential for large stand replacing wildfire, and the foregoing 

discussion of effects, the cumulative effects of vegetation management activities in the Sugar

Pine Project treatment areas taken together with past, present, and reasonably foreseeable 

activities on the Forest will not result in a loss of viability for the pallid bat.

Townsend’s Big-Eared Bat and Western Red Bat

There are no expected direct or indirect negative effects to either of these species from the 

proposed project; therefore, there are no expected cumulative effects from the project.

American Marten

The area considered in determining the cumulative effects of past, present, and reasonably 

foreseeable activities on marten encompasses the SNF. This is an appropriate scale for cumulative 

effects for a wide-ranging species (such as the marten) that has also been selected as a 

Management Indicator Species for the SNF. Based on the following analysis, a determination of 

viability for the marten will be made.

In addition to the previously mentioned habitat risk factors, there are two important 

uncontrollable habitat risk factors for martens: (1) development and (2) climate change. Climate 

change is beyond the scope of this analysis and areas of large-scale development are not planned 

for the Sugar Pine Project area. 

Biological Evaluations for many of the past projects in the SNF were reviewed to help inform the 

present analysis. Our review of these documents revealed the following basic information about 

effects to marten from these activities:

Twenty-six (26) total project Biological Evaluations (BEs) were reviewed, dating back 

to 1993 on the SNF.

Determinations reached were:

o No effect – 7 BEs

o May affect individual marten, but not likely to lead to a trend toward federal 

listing or loss of viability – 15 BEs

o May affect individual marten, and likely to lead to a trend toward federal listing 

or loss of viability – 0 BEs

o Marten were not addressed in the document we reviewed due to lack of habitat 

or other reasons – 4 BEs
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 77

Types of Projects: Fuels reduction, harvest, hazard tree removal, and thinning were the 

proposed activities that were most often represented in the sample of BEs in which the 

marten was analyzed.

Relative to ―May Affect‖ projects, the described impacts to marten most often fell in the 

following categories:

o Temporary disturbances

o Foraging area may be burned if underburning gets out of control

o Removed hazard trees could serve as resting or denning sites

o Habitat altered or removed

o Reduction of habitat quality (e.g., reduction in canopy cover)

o Habitat will be entered

o Noise disturbance‖ (FEIS)

There are no currently known marten densites in or near (within 1 mile) the Sugar Pine project 

area, and the project area is at the lowest recorded elevation for marten use in the area. Marten 

may not even use the project area, and if they do, they most likely only would use it and nearby 

areas occasionally and not as part of core area of their home ranges, which are known to typically 

be at higher elevations. 

As stated previously, the Sugar Pine Adaptive Management Project proposes to maintain the 

highest canopy closure possible while still meeting fire and fuels objectives, and under 

Alternatives 2 and 3 managing for forest health and stand density as well. These treatments are 

expected to have little, if any effect on marten. 

Implementing the action alternatives (Alternatives 2-4), combined with other past, present, and 

foreseeable land management projects on the Sierra National Forest, will not have significant, 

long-term, detrimental impacts to the American marten population, and they are not likely to 

result in a trend toward Federal listing or loss of viability for the American marten. 

Implementing Alternative 1 (the no action Alternative) will not affect the American marten, 

although by taking no action to reduce fuel levels, the threat of large scale stand replacing fires 

will remain unabated, and if such an event occurs, there could be significant detrimental impacts 

to this species.

Alternative 3

In Alternative 3, treatment areas and the types of treatments would remain the same for all areas, 

as in Alternative 2, except for those portions of treatment areas T-4 and T-3 that are designated 

within the 795-acre F01 Pacific Fisher den site buffer for 2008. Treatments would be altered 

within the designated F01 2008 den site buffer to treat the lower and limited mid-level canopy 

(surface and ladder fuels) to address fire and fuels objectives within WUI (see Map 2 in the Map 

Package). There would be no additional treatment of the mid-level canopy (stand density) within 

the designated F01 2008 den site buffer. All other treatment areas would continue to have 

treatments similar to those listed in Alternative 2, which includes treatment of lower and mid 

level canopies. This alternative is being analyzed in detail to measure the effects as they relate to 

the implementation of the SNFPA ROD (USDA-FS 2004b) Standards and Guidelines, with the 

non-significant amendment as defined in Chapter 2. There would continue to be approximately 

2,920 acres treated under Alternative 3. 
Chapter 3: Affected Environment and Environmental Consequences

78 Sierra National Forest

Direct Effects

The Direct Effects for Alternative 3 will be similar to those for Alternative 2 with the exception 

that the designated 2008 F01 Fisher den site 795 acre buffer area would not have forest health 

treatments, therefore an even lower level of disturbance will occur, as compared with Alternative 

2.

Indirect Effects

The Indirect Effects for Alternative 3 will be similar to those for Alternative 2 with the exception 

of no forest health treatments within the designated 2008 F01 Fisher den site 795 acre buffer area. 

Throughout all treatment areas there will be a total of 33 acres (20 acres less than under 

Alternative 2) of CWHR habitat density changes as outlined in the following table.

Table 10: Alternative 3 changes to CWHR forest type within the treatment units of the 

Sugar Pine Adaptive Management Project

Alternative 3

CWHR Forest 

Type Pretreatment

CWHR Forest 

Type Posttreatment

Number of Acres 

of Habitat Type 

Change

MHC4D MHC4M 2 acres

PPN3D PPN3M 17 acres

SMC3D SMC3M 3 acres

SMC4D SMC4M 5 acres

JPN3D JPN3M 5 acres

PPN4D PPN4M 1 acre

Total Acres CWHR 

Habitat Density Change 33 acres

Cumulative Effects

The Cumulative Effects for Alternative 3 will be identical to those for Alternative 2, but with 

even a lower potential of effects due to less forest thinning within the mid-level canopy treatment 

of the designated 2008 F01 Fisher densite 795 acre buffer area.

Alternative 4

In Alternative 4, treatment areas would remain the same as in Alternative 2, but the treatments 

within these areas would include only those needed to reduce the surface and ladder fuels (within 

the lower and limited mid-level canopy levels) needed to achieve fire and fuels objectives. Under 

Alternative 4 there would be no additional treatments (i.e. additional thinning in the mid-level 

canopy) to fully address stand density/forest health objectives. 

Direct Effects

The Direct Effects for Alternative 4 will be similar to those for Alternative 2.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 79

Indirect Effects

There will be no changes to CWHR habitat types through the implementation of Alternative 4 as 

shown in the following table.

Table 11: Alternative 4 changes to CWHR forest type within the treatment areas of the 

Sugar Pine Adaptive Management Project.

Alternative 2 Alternative 3 Alternative 4

CWHR Forest 

Type Pretreatment

CWHR Forest 

Type Posttreatment

Number of Acres 

of Habitat Type 

Change

Number of Acres 

of Habitat Type 

Change

Number of Acres 

of Habitat Type 

Change

MHC4D MHC4M 2 acres 2 acres 0 acres

PPN3D PPN3M 37 acres 17 acres 0 acres

SMC3D SMC3M 3 acres 3 acres 0 acres

SMC4D SMC4M 5 acres 5 acres 0 acres

JPN3D JPN3M 5 acres 5 acres 0 acres

PPN4D PPN4M 1 acre 1 acre 0 acres

Total Acres CWHR 

Habitat Density Change 53 acres 33 acres 0 acres

It is poorly understood as to the rate of recovery of those areas that are manipulated, whether they 

will be immediately begin to be reused or whether there will be some lag time. That is one of the 

questions we are attempting to address with the Sierra Nevada Adaptive Management Study; 

however it is expected that without some form of density management of the stands, eventual 

higher levels of mortality and reduced growth rates within those stands will occur. Insect and 

disease induced mortality of trees throughout overstocked stands will remain a threat to terrestrial 

wildlife habitat. Minor outbreaks of disease or insect infestation can be beneficial in creating 

decadent habitat characteristics; however, extensive outbreaks which can occur during drought 

periods can drastically affect large contiguous blocks of land. Habitat effects could be similar to 

those that would occur with severe wildfire and could ultimately lead to habitat fragmentation or 

vegetation type conversions. 

Cumulative Effects

Alternative 4 has less mid-level canopy thinning as compared with Alternative 2, although the 

understory and limited mid-level canopy fuels reduction will be the same. There will be no 

significant changes in habitat availability for all species analyzed, and the cumulative effects of 

Alternative 4 will be similar to those described for Alternative 2. 
Chapter 3: Affected Environment and Environmental Consequences

80 Sierra National Forest

Aquatic Wildlife and Management Indicator 

Species____________________________________

The direct, indirect and cumulative effects to the aquatic wildlife species and management 

indicator species habitat are summarized from the Biological Assessment and Evaluation (Strand, 

P. 2009) and the Aquatic Management Indicator Species Report (Strand, P. 2009a) for the Sugar 

Pine Adaptive Management Project.

Affected Environment

The Sugar Pine Adaptive Management Project drains to two watersheds, Lewis Creek and Big 

Creek, comprised of two 6th code Hydrologic Units (HUC6s). Lewis Creek is tributary to the 

Fresno River, and Big Creek flows directly into the Merced River. Each of these basins is further 

divided into HUC7s and HUC8s. Analysis was conducted at the HUC8 scale, which ranges from 

466 to 2,564 acres in the project area. For this analysis, the term  ̳subwatershed‘ is used to refer to 

these HUC 8s. The Analysis Area is the 12 HUC8 subwatersheds that include the treatment areas 

proposed under the Sugar Pine Project. Table 12 indicates stream drainage and flow regime 

within the aquatic analysis area based on Geographic Information Systems (GIS). 

Table 12. Watershed Summaries by Stream Classification

Main 

Stream 

System(s)

Watershed

(HUC 5)

Subwatersheds

(HUC 8)

Stream Miles

Perennial Intermittent Ephemeral Total

Lewis 

Creek

Fresno River

(1804000701)

503.0008

503.0009

503.0010

503.0011

503.0055

503.3001

16.6 11.5 112.2 140.3

Big Creek SF Merced 

(1804000803)

501.5003

501.5005

501.5006

501.5007

501.5053

501.5054

17.1 13.5 90.5 121.1

The project area drainage is considered part of the Sacramento-San Joaquin zoogeographic 

province as described by Moyle (1976, 2002). It is not known whether salmonids are native to the 

two watersheds within the project boundaries. Moyle (et al. 1996, 2002) identifies much of the 

west slope of the Sierra Nevada range above 5,000 feet elevation as being historically fishless due 

to glaciation during the Pleistocene and steep topography. The fish community for the project 

area elevation and zoogeographic province is described by Moyle (2002) as the rainbow trout 

(Oncorhynchus mykiss) assemblage. That species is found in clear high-gradient, perennial 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 81

streams at high elevations. Such habitats are characterized as having more riffle than pools, with 

water temperatures seldom exceeding 21 degrees Celsius (o C).

Between 1991 and 2007, primary streams and meadows were surveyed over various times and 

locations. Surveys have been conducted for aquatic species, stream channel characteristics, and 

watershed restoration needs. Channels were defined by reach type based on observed channel 

gradient, width/depth ratios, channel meander, substrate material, channel stability (Pfankuch 

1975), riparian zone, large woody debris and fish habitat. Channel reach types (Rosgen 1996) 

were determined based on observed channel attributes such as channel morphology, along with 

sediment and transport characteristics. Channel types are evaluated in terms of sensitivity to 

disturbance as presented by Rosgen (1996), which varies by channel gradient and size of 

substrate. Five Stream Condition Inventory (SCI) (USDA-Forest Service 2005a) plots were 

established along possible response or depositional channels (Montgomery and Buffington 1997) 

(low gradient, fine substrate) to evaluate current conditions and establish a possible baseline 

comparison for future monitoring. Benthic macroinvertebrates were evaluated using biotic indices 

from Hilsenhoff (1987) and Winget et al. (1979). Separate surveys for reptiles and amphibians

(Fellers and Freel 1995) were completed in 2007. 

Surveys within the aquatic analysis area have identified that rainbow and brown trout occur in all 

the larger perennial tributaries within the project area. These two species are collectively referred 

to as resident trout. Upstream fish movements are limited by areas of high channel gradient, falls, 

and several small dams (private property). A put-and-take fishery is maintained by the California 

Department of Fish and Game (CDFG) within the project area, although streams are selfsustaining. Both Lewis and Big Creek are subject to angling pressure. There are 34 miles of 

perennial streams occurring in the project area subwatersheds. The perennial streams are 

potentially habitat for resident trout, aquatic macroinvertebrates, and herpetofauna, although 

intermittent and ephemeral channels can serve as migration corridors for herpetofauna and also 

influence habitat in the perennial streams. Map 9 located in the Appendix A, Map Package, 

displays the perennial stream systems and subwatersheds for the Sugar Pine Adaptive 

Management Project area. 

A number of special interest amphibian or reptile (herpetofauna) species may occur or have 

suitable habitat in the project area subwatersheds. The U.S. Fish and Wildlife Service (USDIFWS 2009) indicated that potential habitat may be present for the threatened, endangered, or 

candidate species: California red-legged frog (Rana aurora draytonii); mountain yellow-legged 

frog (R. muscosa); and Yosemite toad (Bufo canorus). Additionally, suitable habitat may be 

present for the Forest Service sensitive western pond turtle (Clemmys marmorata) and foothill 

yellow-legged frog (R. boylii). Potentially suitable habitat for these species would be perennial 

streams, meadows, and ponds. Additionally, foothill yellow-legged frog and western pond turtle 

may also utilize intermittent streams. Elevations less than 5,000 feet may provide habitat for 

California red-legged frog, foothill yellow-legged frog, or western pond turtle. Elevations greater 

than 5000 feet may provide habitat for mountain yellow-legged frog, and meadows at elevations 

greater than 6000 feet could provide Yosemite toad habitat.

Existing Condition Summaries

The following tables and figures summarize information within project area HUC8 

subwatersheds. Information is summarized from the Project Hydrology, Aquatics, Aquatic 

Species Biological Assessment/Evaluation, and Management Indicator Species reports. Table 13

indicates present stream channel conditions and overall sensitivity to disturbance.
Chapter 3: Affected Environment and Environmental Consequences

82 Sierra National Forest

Table 13. Summary of Subwatershed Conditions

Subwatershed Acres Current Channel 

Stability

Sensitivity to 

disturbance

501.5003 466 Stable Low

501.5005 2229 Stable Moderate

501.5006 638 Stable Moderate

501.5007 668 Stable Moderate

501.5053 1817 Stable Low

501.5054 1480 Stable Low

503.0008 945 Stable Moderate

503.0009 2010 Stable High

503.0010 1549 Stable High

503.0011 645 Stable Moderate

503.0055 2564 Stable Low

503.3001 1381 Stable Moderate

Table 14 displays miles of perennial streams, miles occuppied by resident trout, 2007 maximum 

(15-minute) summer water temperatures from the larger perennial streams, stream shading, and 

results from benthic macroinvertebrate sampling expressed as Hilsenhoff Biotic Index (HBI), and 

Biotic Condition Index (BCI) (Vinson 2008). Table 5 presents woody debris data from the project 

SCI plots and stream channel surveys, while Table 6 notes potential habitat for threatened, 

endangered, proposed or sensitive (TEPS) herpetofauna, along with Aquatic Management 

Indicator Species (MIS). Figure 2 displays mean daily water temperatures through the summer of 

2007.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 83

Table 14. Perennial Streams; Resident Trout Occupancy, Maximum 15-Minute Water 

Temperatures, Percent Stream Shading, and Indices for Benthic Macroinvertebrates 

Subwatershed Perennial 

(mi)

Resident 

Trout 

occupied 

(mi)

Max Water 

Temp ( oC)

Stream 

Shading

HB 

Index

BCI

501.5003 1.1 0.5 13.3 >70% ND ND

501.5005 4.2 3.0 ND ND 4.14 140

501.5006 1.6 1.2 19.2 70% 4.09 85

501.5007 1.1 0.3 ND ND ND ND

501.5053 4.8 4.8 19.4 70% 4.13 86

501.5054 4.3 4.3 ND ND ND ND

503.0008 1.5 0.2 ND 70% ND ND

503.0009 3.7 3 ND 70% ND ND

503.0010 2.4 1.7 17 78% 4.14 82

503.0011 1.2 0 ND 84% 4.60 119

503.0055 5.4 5.4 18.3 70% 3.14 100

503.3001 2.4 1.8 ND ND ND ND

(ND= No SCI data)

Table 15. Woody Debris Data 

Subwatershed Min length (m) Mean density/100 m 

(d >=0.1 m)

LWD/100 m (0.3 x 3 m)

501.5003 ND ND ND

501.5005 ND ND ND

501.5006 1.1 110 7

501.5007 ND ND ND

501.5053 7.7 22.3 1.4

501.0054 ND ND ND

503.0008 3 ND 5.3

503.0009 3 ND 8.9

503.0010 1.4 167 2

503.0011 0.9 135 0.7

503.0055 3.6 140 2.5

503.3001 ND ND 11.1

(ND= No SCI or stream survey data)
Chapter 3: Affected Environment and Environmental Consequences

84 Sierra National Forest

Table 16. Summary of Potential Habitat within Project Area Subwatersheds (Potential 

Acres Includes Marginal Acres)

Note: foothill yellow-legged frog acres are within western pond turtle habitat (overlap).

Species Potential Habitat (ac) Marginal (ac)

California red-legged frog 5 0

Foothill yellow-legged frog 900 590

Western pond turtle 1740 1150

Mountain yellow-legged frog 670 330

Yosemite toad 110 0

Benthic macroinverbrates 34 (mi) 0

Pacific tree frog 172 0

Figure 2. 2007 average summer water temperatures for project area streams
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 85

Environmental Consequences

This section analyzes the effects of the Sugar Pine Adaptive Management Project on 

aquatic/riparian species and their habitats. A list of past, present, and foreseeable projects for the 

project area is located in Chapter 3. Proposed management actions have the potential to directly 

alter stream shading (solar radiation); and indirectly or cumulatively alter water temperature; 

water quantity; water quality; sediment, nutrient, and litter inputs; woody debris; and channel 

structure. All of these elements can affect aquatic habitat and nutritional resources of aquatic 

organisms (Gregory et al. 1987; Chamberlin et al. 1991; Furniss et al. 1991; Dwire et al. 2006). 

Aquatic (benthic) macroinvertebrates (a Management Indicator Species or MIS) are recognized 

for their importance in the aquatic/riparian systems within the project area. Thus, if the project 

alters stream temperature, canopy cover, hydrologic regime, sediment inputs, 

seeps/springs/headwater areas, and nutrient cycling (LWD or litter inputs), it could affect 

aquatic/riparian species indirectly through affects to the invertebrate community. Various life 

stages of resident trout and herpetofauna utilize benthic macroinvertebrates as a food source.

Stream flow may increase as basal area (and evapotranspiration) declines, and peak flows can be 

indirectly affected by vegetation removal (Chamberlin et al. 1991; Kattleman 1996). Troendle 

(2006) indicated increased water yields following timber harvest, although treatments were 

primarily clearcuts rather than thinnings that are being proposed for the Sugar Pine project. 

Alteration of the hydrologic regime (timing, duration or magnitude of flows) from the combined 

effects of silviculture and underburning could affect spawning for fish, amphibian breeding, and 

MIS habitat (benthic macroinvertebrates and Pacific tree frog). Such an alteration could also 

result in channel downcutting, bank instabilities and degradation of aquatic habitat through 

additional accumulations of sediment in pool habitat and covering of spawning gravels. In snowdominated areas, such as the Sugar Pine drainage area, nearly all of the change in flows would 

occur during spring runoff, and spring runoff may occur slightly sooner if reductions in canopy 

allow faster melting of the snowpack.

Fire Effects

One of the objectives of the Sugar Pine Adaptive Management Project is to modify the intensity 

and spread of fire in the Wildland Urban Interface near the communities of Sugar Pine and Fish 

Camp. This would be accomplished using a combination of thinning and fuels reduction. 

Nakamura et al. (2008) noted some success with reducing crown fire after thinning and burning 

for the Cone and Megram Fires. They also note that some fires are so large (McNally or Cedar 

Fires) that would likely continue to burn through or around treatment areas.

Little is known about fire history of riparian areas in the west, but it is expected to vary from 

those experienced in upland areas (Dwire and Kauffman 2003; Bisson et al. 2003). Riparian areas 

differ from upland areas in topography, microclimate, geomorphology, and vegetation. Further 

they are characterized as having cooler air temperatures, lower daily maximum air temperatures, 

and higher relative humidity. These characteristics may contribute to higher moisture content of 

live and dead fuels, and riparian soils, which presumably lowers the intensity, severity and 

frequency of fire (Dwire and Kauffman 2003). 

Fire, both prescribed and wild, has potential to affect aquatic/riparian systems. Prescribed burning 

could indirectly affect streambank stability, aquatic foodwebs, stream temperature, and large 

wood dynamics (Dwire et al. 2006; Bêche et al. 2005). High intensity fires can severely disrupt 

aquatic ecosystems, and that these affects can be prolonged (up to 300 years for LWD). Specific 

influences may include decreased channel stability; greater and more variable stream discharge; 
Chapter 3: Affected Environment and Environmental Consequences

86 Sierra National Forest

altered woody debris delivery and storage; increased nutrient availability; higher sediment 

delivery and transport; and increased solar radiation and altered water temperature regime (Bisson 

et al. 2003; Dunham et al. 2003). 

Impact of fire on the benthic macroinvertebrate community varies by burn intensity and extent; 

steam size and gradient; precipitation and amount of runoff; vegetative cover; geology; and 

topography. Some indicators of community health may return to pre-fire conditions within 1 to 2 

years, but the overall community will probably vary for 5 to 10 years after the fire (Minshall 

2003; Reardon et al. 2005). 

The extent of fire effects on fish populations would be related to recovery of suitable water 

temperatures, suitable water quality, and connectivity to population refugia. Trout are noted as 

being resilient and adapted to disturbance (Rieman and Clayton 1997; Dunham et al. 2003; Rinne 

and Jacoby 2005), but recovery could take a decade or more. Sestrich (2005) reported that native 

trout populations recovered rapidly, with some sites exceeding pre-fire population levels within 

three years following fires in the Bitterroot River Basin (2000). Greswell (1999) considered the 

disturbance regime resulting from wildfire could facilitate invasion by nonnative fish species.

The ecological diversity of riparian corridors is maintained by natural disturbance regimes 

including fire and fire-related flooding, debris flows, and landslides (Dwire and Kauffman 2003). 

Many species have adapted life histories that are shaped by, and may depend on disturbance 

events (Dunham et al. 2003; Bisson et al. 2003; Rieman et al. 2005). There remains debate among 

Aquatic Ecologists regarding the need to treat riparian areas, and the types of treatments. Part of 

the controversy is related to the diverse and complex effects that fire can have on aquatic systems 

(Dunham et al. 2003). Researchers agree that aquatic systems have developed under a disturbance 

regime. Some aquatic biologists believe that wildfire poses additional risk to endangered species, 

while others feel affects from treatments are more likely to damage aquatic systems than fire 

(Erman 1996; Bisson et al. 2003). Analysis following the Angora Fire (USDA-FS 2007), 

identified fire spread was facilitated in part by corridors provided in the no-treatment Streamside 

Environmental Zones. 

Desired Conditions

Desired conditions for the project area were described in the Fresno River Landscape Analysis 

(USDA-FS 2005a). Indicators are measures that can be used to describe the condition of 

aquatic/riparian ecosystems. They represent elements that might change as a result of 

management activities. There are two riparian vegetation indicators identified in the Landscape 

Analysis; canopy cover and large woody debris. While not identified in the Fresno River 

Landscape Analysis, water temperature will also be used as an aquatic indicator. The Sierra 

Nevada Ecosystem Project (SNEP) (Jennings 1996; Moyle et al. 1996; Erman 1996) notes that 

these aquatic indicators could be potentially be affected by the types of activities being proposed. 

The aquatic indicators are described in the following:

Canopy Cover

Canopy cover is the degree to which tree canopies obscure the sky or block the sun. Canopy 

cover was measured as the percentage of stream shading and varies by the width of the stream 

channel, which is generally a function of stream order. Stream shading is important in 

maintaining water temperature with the effect varying by the height of adjacent vegetation, 

proximity to the stream, topography, angle of the sun, and aspect (Beschta et al. 1987; USGS 

1997, 2000; Moore et al. 2005). The Fresno River Landscape Analysis (USDA-FS 2005a) 

identifies stream shading of 70 to 80% within the riparian zone as a desired condition. 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 87

Large Woody Debris

Large woody debris (LWD) is of both physical and biological importance within stream channels 

and riparian zones (Bisson et al. 1987; Sedell et al. 1988). LWD provide sediment traps, affect 

stream channel morphology to create pool habitat, increase channel roughness to dissipate energy, 

provide complexity to habitat, provide structural cover, and provide nutrient inputs (Bisson et al. 

1987). LWD provide cover for fish and animal species, are directly consumed by specialized 

macroinvertebrates. Factors influencing LWD in the Sierra Nevada mountain range may include 

geomorphology, decay resistance of local species, floods and past management (Ruediger and 

Ward 1996). The desired condition from the Fresno River Landscape Analysis is that project 

streams should average (over the watershed) between 3 to 15 LWD/100 m of the larger (stable) 

class. 

Water Temperature

Water temperature has multiple effects on aquatic/riparian species and their behavior. Thermal 

effects relate to directing behavior (trigger migration or spawning); controlling factors (time of 

incubation and emergence); lethal (lead to breakdown of homeostatic system and increased 

susceptibility to disease); and growth (metabolic regulation; affected by food supply) (Beschta et 

al. 1987; Armour 1988; USGS 1997; 2000; Sauter et al. 2001). Elevation, aspect, stream width, 

channel roughness coefficient, riparian shading, solar radiation, air temperature, cloud cover, and 

stream discharge levels can affect water temperature. Of these elements, direct effects on riparian 

shading and indirect effects on stream discharge level could have the most effect on stream 

temperature (Beschta et al. 1987; Moore et al. 2005). A desired condition for water temperature 

was not identified in the Fresno River Landscape Analysis. The CDFG discontinues trout 

stocking if water temperatures exceed 21° C (CDFG 2009), thus the Desired Condition for this 

analysis is that water temperatures be less than 21° C. This temperature is also consistent with 

that described by Moyle (1976; 2002) within the rainbow trout assemblage. 

Alternative 1 – No Action

Under the No Action alternative, current management plans would continue to guide activities in 

the project area. This includes all ongoing activities with existing decisions or permits that would 

not be changed if this alternative were selected including: underburning, plantation maintenance, 

cattle grazing, recreation, and recreation residences. No treatments would be implemented in any 

subwatershed as displayed in Table 17.
Chapter 3: Affected Environment and Environmental Consequences

88 Sierra National Forest

Table 17. Sugar Pine Adaptive Management Activities Proposed under Alternative 1 by Subwatershed

Subwatershed

501.5003501.5005501.5006501.5007501.5053501.5054503.0008503.0009

503.001

503.0011503.0055503.3001

Total

Commercial or precommercial thinning

or tractor piling 0 0 0 0 0 0 0 0 0 0 0 0 0

Precommercial Thin 0 0 0 0 0 0 0 0 0 0 0 0

Mastication 0 0 0 0 0 0 0 0 0 0 0 0 0

Underburn 0 0 0 0 0 0 0 0 0 0 0 0 0

No Treatments 466 2229 638 668 1817 1480 945 2010 1549 645 2564 1381 16392

Subwatershed Acres 466 2229 638 668 1817 1480 945 2010 1549 645 2564 1381 16392
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 89

The No Action Alternative would not implement the Sugar Pine Adaptive Management Project to 

reduce fire ladder conditions or stand densities (thinning); pile slash for burning; burn slash piles; 

masticate and/and or precommercially thin stands; plant trees; reduce fuel loading through 

controlled burning; construct handline around jackpot burn areas; manually remove noxious 

weeds, or construct and reconstruct roads. Potentially affected habitat for aquatic threatened, 

endangered, sensitive and MIS species is displayed in Table 14. Indicators for aquatic/riparian

habitat and species are canopy cover, water temperature, and large woody debris. 

Direct Effects

Canopy Cover

No commercial timber removal or underburning would occur under this alternative. No direct, 

indirect, or cumulative affects to riparian canopy cover (current stream shading > 70%) are 

anticipated from Alternative 1. There would be no direct effects on TES aquatic species or their 

habitat. Stream shading would meet the desired condition of > 70 to 80%.

Water Temperature

There would be no anticipated direct effect on water temperature as a result of the Alternative 1.

Large Woody Debris

There are no activities proposed under Alternative 1. There would be no direct effects on LWD 

recruitment.

Indirect Effects

Canopy Cover

No indirect effects on canopy cover from stand density alteration or fuel treatment would occur 

under Alternative 1. Pilliod et al. (2003) suggest that no action may have consequences for 

amphibians due to overgrown forests changing the quality of amphibian habitat and increasing 

susceptibility for a high intensity and severity fire.

Water Temperature

Water temperature data collected from the project area in 2007 indicate project area streams are 

within the desired condition and within the range for resident trout species. 

It is anticipated that Alternative 1 would maintain water temperatures within the desired condition 

(< 21° C) and no indirect affects would be anticipated. 

Indirect and Cumulative Effects on Large Woody Debris

There are no anticipated indirect or cumulative effects on LWD from the No Action Alternative. 

LWD would remain lower than desired within subwatersheds 501.5053, 503.0010, 503.0011, and 

503.0055. Several other subwatersheds have no LWD data and may also be less than desired.

Cumulative Effects 

Past, present, and reasonably foreseeable actions within the project areas are displayed in Chapter 

3 on page 25. Under Alternative 1, the Sugar Pine Project would not be implemented. Within the 

project area, other known activities are off-highway vehicle use, fuels, culture, and timber 

projects (past Federal and activities on private property), cattle grazing, road and road 

maintenance, and recreational use (both developed and undeveloped). Of the actions evaluated 
Chapter 3: Affected Environment and Environmental Consequences

90 Sierra National Forest

within the analysis area, timber harvesting on private land and cattle grazing have the greatest 

potential to alter aquatic habitat. 

Timber harvesting on private land requires a Timber Harvest Plan (THP) that evaluates 

compliance with State and Federal rules and laws (CDF 2005). The THP includes a cumulative 

effects analysis that considers effects on water temperatures, stream shading, and measures to 

reduce sediment movement. Most of the Forest Service actions over the past decade, along with 

those proposed in the next decade, relate to fuels reduction or forest thinning. These actions have 

Best Management Practices (BMPs) (USDA-FS 1983, 2002), along with Forest standards and 

guidelines to restrict off-site erosion and activities within Streamside Management Zones

(SMZs). Stream channels would be expected to remain stable, with some sites of localized 

instability. LWD would remain below desired in subwatersheds 501.0053, 503.0010, 503.0011, 

and 503.0055. Approximately 0.8 miles of road cross wet meadows, representing impacts to 

roughly 2 acres (18 foot road template) of wet meadow habitat

The project area is primarily within the Soquel grazing allotment. Most of the primary and 

secondary grazing areas occur in subwatersheds 501.5005, 501.5006, and 501.5007. Proper 

Functioning Condition (USDI-BLM 1995) was conducted at Boggy and Soquel Meadows within 

the allotment in 2007. Both sites were at Properly Functioning Condition. It is expected that cattle 

grazing will locally result in exposed streambanks and erosion. 

The Cumulative Watershed Effects Analysis (CWEA) prepared for this project (Gallegos 2009) 

includes consideration of actions on private lands in addition to Forest Service permitted actions. 

The Project CWEA does not indicate that a cumulative effect to watersheds would be expected 

from Alternative 1. However, it does note that subwatersheds 501.5053 and 503.0055 would 

remain above the lower bound threshold of concern (TOC). The bounds are guidelines developed 

to indicate risk of cumulative effects, and to identify areas for field review. The stream channel 

within subwatershed 503.0055 is the main stem of Lewis Creek. The creek through this 

subwatershed is primarily high gradient, with a bedrock and boulder substrate, thus has limited 

probability of stream channel instabilities developing. Observations of the water temperatures 

were recorded from Lewis Creek (within subwatershed 503.0055) during the summer of 2007. 

Water temperatures never exceeded 18.3° C (15 minute step) or had a daily average greater than 

16.6° C. It does not appear that current upstream uses are negatively affecting conditions within 

the subwatershed. Benthic macroinvertebrate sample data indicates water quality presently is in 

good condition within this subwatershed.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 91

Table 18. Summary from analyses for aquatic Threatened (T), Endangered (E), Sensitive 

(S) and Management Indicator Species (MIS) for effects from Alternative 1

Species (status) Potential 

Habitat 

(ac)

Marginal 

(ac)

Potential 

Habitat in 

Treatment 

Area (ac)

Marginal 

Habitat in 

Treatment 

Area (ac)

Determination

California red-legged 

frog (T)

5 0 0 0 No effect

Foothill yellowlegged frog (S)900 590 0 0 No effect

Western pond turtle 

(S)

1740 1150 0 0 No effect

Mountain yellowlegged frog (S)670 330 0 0 No effect

Yosemite toad (S) 110 0 0 0 No effect

Benthic 

macroinvertebrate 

habitat (MIS)

34 mi. 0 0 0 Stable

Pacific tree frog 

habitat (MIS)

170 0 0 0 Stable

Source: Strand 2009, Strand 2009a

Alternative 2 – Proposed Action

Under Alternative 2, the development of Strategically Placed Area Treatments (SPLATs) would 

occur. Additional areas would be treated to provide a defensible fuels profile near key 

transportation corridors and within the defense zone of the wildland urban intermix. In addition to 

those treatments needed to meet fire and fuels objectives treatments would be created to reduce 

stand densities (basal area) to such a level as to improve the growth and vigor of remaining trees. 

Treatments included in this alternative are: thinning from below in conifer stands, either precommercially, commercially, biomassing and/or mastication to reduce lower and mid-level 

canopy stand densities; mastication of brush and shrub patches; prescribed burning, both 

understory and piles; manual reduction and/or prescribed burning of noxious weed infestations; 

and prepare and plant failed conifer plantations. Proposed treatments by subwatershed are 

displayed in Table 16. 

Table 19 displays herpetofauna and MIS habitat potentially affected by the Proposed Action.
Chapter 3: Affected Environment and Environmental Consequences

92 Sierra National Forest

Table 19. Activities Proposed within Project Area Subwatersheds under Alternative 2

Subwatershed

501.5003501.5005501.5006501.5007501.5053501.5054503.0008503.0009503.0010503.0011503.0055503.3001

Total

Commercial/pre-commercial 

thinning or tractor piling 0 5 194 132 124 11 297 323 627 33 162 1908

Mastication 19 8 79 0 34 18 110 294 3 139 80 14 797

Underburn 0 9 15 0 21 22 15 113 22 0 0 215

No Treatments 447 2207 352 536 1638 1429 524 1280 897 473 2322 1367 13472

Subwatershed Acres 466 2229 638 668 1817 1480 945 2010 1549 645 2564 1381 16392

% Subwatershed treated 4% 1% 45% 20% 10% 4% 45% 35% 42% 27% 9% 1% 18%

Table 20. Overlap of Proposed Treatment Areas and Potential Habitat for species

CRLF acreage represent suitable breeding habitat (most acres evaluated under the site assessment did not represent suitable breeding during 

site review.) RABO acres are within WPT habitat (overlap). Marginal acres are included in Potential Habitat acres. No treatment zones are 

core areas along perennial streams (50 ft) and intermittent streams (25 ft) that would have no activity.

Species Potential 

Habitat (ac)

Marginal 

(ac)

Potential Habitat in 

Treatment Area (ac)

Marginal Habitat in 

Treatment Area (ac)

No Treatment 

Zones (ac)

California red-legged frog (CRLF) 5 0 0 0 0

Foothill yellow-legged frog (RABO) 900 590 320 230 90

Western pond turtle (WPT) 1740 1150 630 440 90

Mountain yellow-legged frog (RAMU) 670 330 90 50 28

Yosemite toad (BUCA) 110 0 30 0 2

Benthic Macroinvertebrates (MIS) 34 mi 0 8 mi 0 8 mi

Pacific tree frog (MIS) 170 0 7 ac 0 7 ac
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 93

Commercial or pre-commercial thinning, along with tractor piling, would occur over 1900 acres 

(gross treatment area) under the Proposed Action. The actual area treated would be less 

considering SMZs, Old Forest Linkage corridors, controlled areas, aggregations within treatment 

areas not requiring treatment to achieve project objectives, and access limitations due to 

topography. Commercial thinning would occur over approximately 850 acres under the Proposed 

Action. Underburning is proposed over approximately 215 acres (<2 % of the project area). 

Within the 34 miles of perennial stream channel, approximately 7.6 miles are either within or 

bordered by a proposed treatment unit. Additionally, approximately 7 acres of wet meadow are 

within or adjacent to proposed treatment units. Project implementation would incorporate Best 

Management Practices (BMPs). BMPs (USDA-FS 1983; 2002) were developed to reduce erosion 

and off-site transport of sediment to stream channels. BMPs implemented with this project are 

detailed under Project Design Criteria and were identified in the project Hydrology Report (Stone 

and Kaplan-Henry 2008). Literature indicates that BMPs are effective in minimizing the erosion 

in harvest units and at preventing sediment from reaching streams. In a study of sediment 

redistribution after harvesting, Wallbrink and Croke (2002) found that sediment eroded from skid 

trails was deposited in the harvest unit and the 23 to 30 m wide stream buffers. MacDonald and 

Stednick (2003) note that forest harvest and fuels treatments should have little effect on water 

quality if they are well-planned and BMPs are implemented. Monitoring of BMP on Forest 

Service lands in California has shown that, when implemented, timber management BMP are 95

to 98% effective (USDA-FS 2004a). 

Aquatic habitat indicators are canopy cover, water temperature, and large woody debris.

Direct Effects 

The 5 acres of potential habitat for California red-legged frog are the private ponds in the Sugar 

Pine and Fish Camp areas, which are not part of this project. Potential effects on foothill yellowlegged frog (RABO), western pond turtle (WPT), mountain yellow-legged frog (RAMU), or 

Yosemite toad (BUCA) could occur from crushing of individual animals by tractor thinning, 

tractor piling, or mastication, or from burning of animals. Most direct effects would not be 

expected to occur due herpetofauna primarily occupying riparian areas where proposed 

treatments are limited. During primary periods of project operations (May through Sept) it is 

expected that frogs and turtles would remain within the riparian areas due to presence of water, 

the microclimate provided, and riparian connectivity, except during rainy periods. The possibility 

of direct effects from crushing would be most likely in October when species leave streamside 

areas for overwintering sites or during rainy periods when species may move beyond riparian 

areas. Operation of heavy equipment ceases during periods of prolonged precipitation to prevent 

compaction.

Introduced fire could directly affect herpetofauna. Some species may use slash piles for cover or 

for estivation. The possibility of direct effects on individual animals from burning piles within the 

Old Forest Linkage Corridors would be reduced by implementing the project design measure to 

light piles on one side to allow an escape from the pile. Underburning may also represent a direct 

effect to herpetofauna. Underburning is proposed adjacent to perennial streams in units RX 1, 3, 

and 5. RX units 3 and 5 represent approximately 7 acres of RABO and 13 acres of WPT habitat. 

RX 3 contains approximately 5 acres of RAMU habitat. All of these potentially effected habitats 

were considered marginal due to dense canopy cover, but could serve as dispersal corridors. 

Prescribed burning would be expected to occur during the spring or fall. During spring, 

amphibians may be moving to breeding sites or dispersing after breeding. During the fall, 

herpetofauna may be moving to overwintering sites or estivating within areas to be burned. 

Allowing fire to creep into the SMZ (as opposed to active introduction) would provide 
Chapter 3: Affected Environment and Environmental Consequences

94 Sierra National Forest

opportunity for herpetofauna to move away from areas burning, but not eliminate the possibility 

of mortality. 

Direct effects to listed herpetofauna would not be anticipated from implementing the Proposed 

Action due to project design measures; non-detection of listed species during surveys; and no 

records of these species occurring within the project area subwatersheds.

Canopy Cover

Current levels of stream shading for project area perennial streams are presented in Table 11. 

These levels are currently within the desired condition of 70 to 80%. Naiman et al. (2000) note 

that riparian forests strongly influence stream microclimate; including air, soil, and surface 

temperatures; relative humidity; and solar radiation. The proposed commercial thinning and 

underburning have the potential to directly affect canopy cover or stream shading. If canopy 

altering treatments occurred in streamside areas there could be an increase solar radiation to the 

stream channel. 

Streamside shading affects the amount of solar radiation that filters to the surface of the water. 

During late summer, solar radiation potential is greatest, air temperatures are warmest, and stream 

flows are lowest. Only perennial channels flow are expected to flow during this period, thus 

concerns over water temperature focus on these stream channels. Perennials also comprise the 

potential habitat for resident trout, benthic macroinvertebrates, and herpetofauna. Base flows may 

be augmented by the reduction in vegetation (an indirect effect), but no effect is expected within 

the stream channels (Stone and Kaplan-Henry 2008). Possible increases in soil moisture would be 

utilized by the remaining vegetation, so it would not likely be available for stream flow. 

Benthic macroinvertebrates serve as food source for various lifestages of fish and herpetofauna. 

Kattleman (1996) notes several studies have demonstrated that communities of aquatic

invertebrates changed significantly in response to upstream logging, with some of these effects 

persisting for two decades. Much of the food base for stream ecosystems is derived from adjacent 

terrestrial ecosystems with litter fall from deciduous stands exceeding that of coniferous stands. 

Deciduous input (leaves) generally breaks down in less than half the time necessary for the 

breakdown of coniferous input (needles; Gregory et al. 1991). Buffer strips 30 m (98.4 feet) wide 

are noted as protecting invertebrate communities from logging induced changes (Gregory et al. 

1987; EPA 1991). 

Dwire et al. (2006) suggest that prescribed fire may top-kill some riparian trees and shrubs. A 

study at Blodgett Forest in northern California introduced prescribed fire into the riparian zone 

and found that a 4.4% mortality rate resulted, occurring in trees 11 to 40 centimeters (4.5 to 15.7 

inches) dbh (diameter at breast height; Bêche et al. 2005). Prescribed fire is not proposed for 

introduction into the perennial SMZs for this project, but it would be allowed to creep within the 

SMZ. 

Perennial stream channels, which represent the potential habitat for aquatic/riparian species, 

would have Class I SMZs. Class I SMZs are a minimum of 100 feet from each streambank, with 

widths adjusted for slope as presented under project design criteria. Class I SMZs are within the 

Old Forest Linkage corridors. These corridors extend 150 feet from both streambanks along the 

perennial streams within the project area. There are no proposed treatments within the inner 50 

feet from each streambank. The outer 50 feet would implement hand treatments to remove the 

understory ladder fuels. No alteration of the existing stream shading (> 70%) would be 

anticipated from the Proposed Action. 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 95

Water Temperature

As measured during the summer of 2007 (displayed in Figure 2), daily mean water temperatures 

in the project area was less than 21 C (desired condition). The maximum water temperatures (15

minute data) during the 2007 monitoring period are presented in Table 11. No maximum water 

temperatures recorded during 2007 exceeded the desired condition. There are no anticipated 

alterations to canopy cover, thus there would be no direct effects on water temperature anticipated 

from the Proposed Action. 

Large Woody Debris

Table 12 indicates that subwatersheds 501.5053; 503.0010; 503.0011; and 503.0055 are lower 

than Desired Condition for large woody debris. Other subwatersheds lacking LWD data may also 

be less than desired. This condition is likely a result of historic logging that occurred throughout 

the project area, including riparian areas. Naiman et al. (2000) project that 80% of LWD has a 

stream channel residence of less than 50 years. Trees are now of sufficient size and are large 

enough, in combination with individual mortality, to provide additional input. The element within 

the SMZs that represents the most immediate source of LWD is snags. There is no proposed 

felling of snags, unless the snag meets criteria set forth in the design criteria. Some snags to be 

removed may have contributed to LWD recruitment. 

Indirect Effects

Thinning to reduce ladder fuels would occur on over 800 acres under this alternative. 

Underburning is proposed over approximately 215 acres, and mastication on 800 acres. Table 17

identifies that perennial streams adjacent to treatment areas represent approximately 320 acres of 

foothill yellow-legged frog; 630 acres western pond turtle; 90 acres mountain yellow-legged frog; 

and 30 acres of Yosemite toad habitat, 8 miles of benthic macroinvertebrates, and 7 acres of 

Pacific tree frog habitat. The foothill yellow-legged frog habitat acreage is within western pond 

turtle habitat (overlap). Within the foothill yellow-legged frog and turtle habitat are 90 acres that 

would have no treatments (corridors along perennial and intermittent streams). Similarly, 30 acres 

of mountain yellow-legged frog habitat occurs along no treatment corridors. The perennial 

streams and wet meadows (MIS habitats) are also buffered by no treatment areas. The Proposed 

Action has a risk of compacting soil (tractor thinning, mastication, new road construction, and 

machine piling or slash), which could result in both short and long-term sediment delivery to 

riparian and aquatic habitats. Reduction in stand densities could affect canopy cover (indirectly 

affecting micro-climate and water temperatures), availability of large woody debris; 

macroinvertebrate community, and changes to water yield (indirectly affecting stream channel 

stability). Alterations to habitat complexity, air temperature, decreased soil moisture or relative 

humidity within areas adjacent to perennial streams could influence herpetofauna.

Canopy Cover

Indirect effects on canopy cover (stream shading) could occur if the Proposed Action results in an 

alteration to the hydrologic regime. Such alteration could be expressed in bank and channel 

instabilities, widening of the stream channel, and undermining of bank trees. The widening of the 

stream channel would increase the level of reduced canopy cover over the stream (less stream 

shading). Unit T-11 is proposed adjacent to a segment of stream channel that is currently has poor 

channel stability, within a subwatershed (503.0010) that is considered sensitive to disturbance. 

Project design criteria have been developed to protect the channel from further degradation, and 

indirect effects would not be anticipated. 
Chapter 3: Affected Environment and Environmental Consequences

96 Sierra National Forest

Effects to canopy cover would be similar to direct effects. Alterations to habitat complexity, air 

temperature, decreased soil moisture or relative humidity within areas adjacent to perennial 

streams could influence herpetofauna.

Water temperature

Solar radiation through forest canopies depends on the heights of the crowns and density, along 

with the foliage (Moore et al. 2005). In evaluating possible project direct effects to canopy cover 

it was noted that large changes in overhead canopy from stands adjacent to perennial streams 

would not be anticipated. Stream shading would meet the desired condition of > 70 to 80%. 

However, in addition to direct solar radiation, Beschta et al. (1987) addresses possible affects 

from angular solar radiation and describes how canopy cover can be evaluated as angular canopy 

density. In the outer 50 feet of treated Old Forest Linkage (riparian corridors) there is a possible 

increase of open space within the understory component of the treated stand. This provides an 

opportunity for increased angular solar radiation. It is anticipated that the majority of the trees 

would be retained and the inner 50-foot no treatment zone would intercept angular solar radiation. 

Wilkerson et al. (2006) found that a 23 m (75 feet) buffer resulted in no change to water 

temperature, while a 11 m buffer (>60% canopy retention) resulted in an increased weekly 

maxima of 1.0 to 1.4° C. There would be no anticipated indirect change to water temperatures. 

Some underburning would take place within Old Forest Linkage corridors. When this occurs 

there are design measures that allow for creeping into the SMZ, but not for active introduction of 

fire. It is expected underburning would occur within the 100-foot zone and some understory trees 

could be killed as a result. It is not expected that overstory trees contributing to stream shading 

and blocking solar radiation would be killed by the underburning proposed under the Sugar Pine 

Adaptive Management Project. 

Changes in stream discharge level could be potentially affected by the proposal. Altered stream 

discharge would be an indirect effect from the proposal, since basal area (and evapotranspiration) 

decline due to changes in stand density (Chamberlin et al. 1991; Kattelman 1996). If more water 

were available as baseflow during the late summer, there would be a possible reduction in stream 

temperature. Researchers have concluded that if less than 10% of the basal area is removed, there 

is little impact on flows (Troendle et al. 2006). Removal of between 10 and 20% of basal area 

may affect flow, but the change is not detectable due to the natural variability of flow. Other 

investigators found that approximately 20% of the basal area must be removed before a statistical 

change in flow is detected (Troendle et al. 2006). MacDonald and Stednick (2003) report that 

15% basal area must be removed before a change in flow can be detected in small research 

watersheds, and detection becomes more difficult as watershed size increases. Huff et al. (2002) 

modeled water yield for similar treatments (thinning) in the Feather and Yuba River basins, 

estimating an increase of 0.3% in water yield. However, individual areas could have higher water 

yields within the range of variability estimated. 

The Sugar Pine Adaptive Management Project Hydrology Report (Stone and Kaplan-Henry 

2008) considered anticipated changes to hydrologic regime. The Project Hydrology Report notes 

that base flows may be augmented by the reduction in vegetation, but the effect is not likely to 

persist into the dry summer season where it would be detectable. The increase in soil moisture 

would be utilized by the remaining vegetation, so it would not be available for stream flow. 

Thinning trees is not expected to have much effect on hydrologic regime. It is anticipated that 

project design measures for Alternative 2 would maintain water temperatures within the current 

and desired condition (< 21° C), within the project area. 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 97

Large Woody Debris

Of the treatments that would be implemented under the Proposed Action, delivery of large woody 

debris could be affected by reduction in stand density through commercial harvest or 

underburning. It has been identified that stream channels within subwatersheds 501.0053; 

503.00010; 503.0010; and 503.0055 are below desired condition for LWD. There are 

approximately 200 miles of stream channels within project area subwatersheds. However, this 

evaluation focuses the perennial and intermittent stream channels (approximately 60 miles) 

within project area subwatersheds. Perennial channels have Class I SMZs and are within the Old 

Forest Linkage corridors. However, intermittent channels (Class II SMZs) contribute water over 

half of the year and may be important for herpetofauna dispersal. Additionally, intermittent 

channels may have sufficient flow to transport smaller pieces of LWD, thus influence LWD in the 

perennial channels. The ephemeral channels are more likely to retain LWD rather than transport it 

due to limited channel capacity. 

Modeling LWD recruitment has been challenging considering that tree fall patterns may be 

chronic or episodic and influenced by geomorphology; tree or snag angle; bank steepness; 

prevailing wind direction; fragmentation; decomposition; mortality rates; and stem failure (Van 

Sickle and Gregory 1990; Bragg et al. 2000; Bragg and Kershner 2002, 2004; Mellen and Ager 

2002; Meleason et al. 2002). The models attempt to address direction of tree fall and assign 

probability to angle of fall or assume angle is random. The random scenario could occur if tree 

failure is not influenced by disturbance or geomorphology. However, Naiman et al. (2000) 

suggest the probability of fall direction is strongly influenced by local topography, thus trees are 

more likely to fall toward the channel than other directions. It appears the more mature and intact 

the adjacent riparian forest is, the greater the likelihood of sustained LWD recruitment (Bragg et 

al. 2000). 

McDade et al. (1990) indicated that 70% of LWD originated within 1⁄2 stand height (20 m in that 

study) of the stream channel and approximately 85% of LWD would have been provided within a 

30 meter (98.4 ft) buffer. Meleason et al. (2002) noted that 90% of woody inputs were found to 

originate within 26 meter (85 ft) for mature conifer stands. To maintain LWD recruitment, the 

SMZs should be between 0.75 and 1.0 tree heights. The basic premise presented by Robison and 

Beschta (1990) is that the probability of LWD entering a stream by direct fall is zero when the 

distance exceeds the tree height. 

The perennial streams have Class I SMZs and are within the Old Forest Linkage (riparian

corridors). There are 34 miles of perennial streams in the aquatics analysis area. Approximately 

7.7 miles of stream are adjacent to or within a treatment area. The Old Forest Linkage corridors 

have a 50-foot no treatment buffer on the inner 50 feet of the stream channel. The remaining outer 

50-feet excludes heavy mechanical equipment, but understory trees could be removed to reduce 

fire ladder conditions. There is no proposed removal of snags within the first 50 feet from the 

perennial stream channel within the Old Forest Linkage corridors or unless meeting design 

criteria for felling. Some of these snags may have contributed to LWD. 

Class II (intermittent channels) are not likely to have flow during late summer. Class II SMZs are 

75 feet (each side), and exclude heavy equipment. There are 25 miles of intermittent streams in 

the aquatics analysis area. Approximately 8.7 miles of stream are adjacent to or within a 

treatment area. When project treatments are to occur within Class II SMZs, it is primarily 

removal of suppressed and intermediate trees contributing to ladder fuels. It is anticipated that 

commercial thinning could be implemented within 25 feet of the stream. Robison and Beschta 

(1990) discuss the concept of effective height of the tree, which is the height to the minimum 

diameter and length necessary to qualify as LWD. If a diameter of 10 cm (4 inches) is applied, the 
Chapter 3: Affected Environment and Environmental Consequences

98 Sierra National Forest

top 10 feet of the tree would not meet the LWD criteria. Thus, it is more probable that 35 feet is 

the minimum height that might have a probability of contributing LWD to a stream channel. 

These trees have potential to reach the stream channel if the occur in the band between 25 and 50 

feet from the stream channel and it is probable that some would have contributed to LWD. 

Underburning proposed in Rx Units 1 and 3 would take place within Class I/II SMZs. When this 

occurs there are design measures that allow for creeping into the SMZ, but not active introduction 

of fire. Dwire et al. (2006) speculate that fuels reduction could potentially directly and indirectly 

affect aquatic/riparian habitat by altering the recruitment of LWD. They further note that 

prescribed fire would not necessarily remove LWD from riparian areas, and that mortality 

resulting from prescribed fire would likely contribute LWD to aquatic systems. In a limited (60 

acre) study of active burning within the riparian zone, Bêche et al. (2005) noted a loss of 4.4% of 

trees, with mortally occurring between 11 to 40 cm (4.5 to 15.7 in) dbh. In that study several 

snags fell after being burned, but no overall increase in the amount or movement of LWD relative 

to unburned control sites. These effects were similar to those theorized by Dwire and Kauffman 

(2003) that moister, cooler microclimates within riparian areas likely contribute higher moisture 

content in fuels and soils, which could lower the intensity and severity of burns. Skinner (2002) 

also noted that fire often consumes material in the advanced stages of decay, but also creates 

snags and downed logs. It is expected underburning would creep within the SMZs and some 

understory trees could be killed a result and possibly contribute to LWD.

Limited indirect negative effects to LWD recruitment would be anticipated as a result of 

implementing the Proposed Action, primarily contribution from intermittent stream segments. It 

is expected that LWD would remain lower than desired condition within subwatersheds 

501.0053; 503.0010; 503.0011; and 503.0055 for several decades. Several other subwatersheds 

did not have LWD data and may also be less than desired.

Cumulative Effects 

Past, present, and reasonably foreseeable actions within the project areas are displayed in Chapter 

3 page 33. For the Sugar Pine Project Area, other known activities are off-highway vehicle use; 

fuel, culture, and timber projects (including activities on private property); cattle grazing, road 

maintenance; and recreational use (both developed and undeveloped). Of the actions elevated 

within the analysis area, timber harvesting, (including that occurring on private lands), and cattle 

grazing have the greatest potential to alter aquatic habitat. 

Of the actions evaluated within the analysis area, timber harvesting, including that occurring on 

private lands, has the greatest potential to alter aquatic habitat. Effects from timber harvesting on 

private land would be similar to those discussed under Alternative 1. For actions considered 

under Alternative 2, changes to microclimate could affect air temperature, which is one of the 

components affecting water temperature and quality of habitat for herpetofauna. No treatments 

would occur within the inner 50 feet of a Class I SMZ. When timber removal occurs in SMZs, it 

would be primarily from suppressed and intermediate trees that are creating fuel ladder 

conditions. It is not expected that overhead canopy reductions would result in large changes in 

solar radiation or air temperature. It is anticipated that water temperatures within the project area

would be maintained within the desired condition (< 21o C) under the Proposed Action. The 

combination of the Federal and private timber removal is not expected to cumulatively effect 

LWD recruitment, which would remain lower than desired, within subwatersheds 501.0053, 

503.0010, 503.0011, and 503.0055. Several other subwatersheds did not have LWD data and may 

also be less than desired.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 99

The CWEA prepared for this project (Gallegos 2009) includes consideration of actions on private 

lands in addition to Forest Service permitted actions. The lower bound threshold of concern 

(TOC) in subwatersheds 501.5053 and 503.0055 are currently exceeded. Additionally, 

subwatersheds 501.5006, 501.5007 and 503.0010 would exceed their lower TOC as a result of 

implementing the proposed action. Upper bound TOC would not be exceeded if Alternative 2 

were implemented. Upper and lower bounds are guidelines developed to indicate risk of 

cumulative effects, and to identify areas for field review. The probable result from a cumulative 

effect would be an increase in sediment, which would negatively affect aquatic habitat. The 

stream channel within subwatershed 503.0055 is the main stem of Lewis Creek. The creek 

through this subwatershed is primarily high gradient with a bedrock and boulder substrate, thus 

has limited probability of stream channel instabilities developing. Further buffering the 

subwatershed from sediment effects is the lower pond at Sugar Pine. The pond is not within 

subwatershed 503.0055, but functions as a settling basin for any sediment generated upstream of 

the site. The effect of the pond decreases the amount of sediment in the system, further reducing 

the probability of a cumulative effect in the downstream subwatershed. A cumulative watershed 

effect would not be anticipated from Alternative 2 (Gallegos 2009). Stream channels would be 

expected to remain overall stable, with some sites of localized instability. Habitat for benthic 

macroinvertebrates (34 miles) and Pacific tree frog (170 acres) would be expected to be stable.

The project area is primarily within the Soquel grazing allotment. Most of the primary and 

secondary grazing areas occur in subwatersheds 501.5005, 501.5006, and 501.5007. Proper 

Functioning Condition (USDI-BLM 1995) was conducted at Boggy and Soquel Meadows within 

the allotment in 2007. Both sites were at Properly Functioning Condition. It is expected that cattle 

grazing will locally result in exposed streambanks and erosion. The majority of the primary use 

areas are within subwatersheds that drain to North Fork Willow Creek, rather than the Fresno or 

Merced Rivers.

Table 23 summarizes anticipated effects from the action alternatives (Alternatives 2, 3, and 4) on 

aquatic threatened (T), endangered (E), sensitive (S) species, along with habitat for management 

indicator species (MIS).

Alternative 3 

Under Alternative 3, gross acres of proposed treatments by subwatershed are displayed in Table 

21. The actual area treated is expected to be less (approximately 85%) similar to Alternative 2.
Chapter 3: Affected Environment and Environmental Consequences

100 Sierra National Forest

Table 21. Activities Proposed within Project Area Subwatersheds under Alternative 3

HUC8 Subwatershed

501.5003501.5005501.5006501.5007501.5053501.5054503.0008503.0009503.0010503.0011503.0055503.3001

Total

Commercial/precommercial thinning or 

tractor piling

0 5 194 132 124 11 119 181 627 33 99 0 1525

Lower canopy 

treatment/precommercial thinning or 

tractor piling

0 0 0 0 0 0 178 142 0 0 63 0 383

Mastication 19 8 79 0 34 18 110 294 3 138 80 14 797

Underburn 0 9 13 0 21 22 15 113 22 0 0 215

No Treatments 447 2207 352 536 1639 1429 523 1280 897 474 2322 1367 13473

Subwatershed Acres 466 2229 638 668 1817 1480 945 2010 1549 645 2564 1381 16392

% Subwatershed treated 4% 1% 45% 20% 10% 3% 45% 36% 42% 27% 9% 1% 18%
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 101

Direct Effects 

Similar to Alternative 2, there could be potential direct effects from crushing of RABO, WPT, 

RAMU, or BUCA by tractor thinning, tractor piling, or mastication, or from burning of animals. 

The 5 acres of potential habitat for CRLF are the private ponds in the Sugar Pine and Fish Camp 

areas, which are not part of this project. 

Also similar to Alternative 2, direct effects would not be expected to occur due herpetofauna 

primarily occupying riparian areas where proposed treatments are limited. Project design 

measures include the Old Forest Linkage corridors for Pacific fisher. These migration corridors 

extend 150 feet from both streambanks along the perennial streams within the project area. There 

are no proposed treatments within the inner 50 feet from each streambank. The outer 50 feet 

would implement hand treatments to remove the understory ladder fuels. No heavy equipment 

would be allowed within 100 feet of the streambank within these corridors. During primary 

periods of project operations (May through Sept) it is expected frogs and turtles would remain 

within the riparian areas due to presence of water; the microclimate provided; and riparian 

connectivity, except during rainy periods. The possibility of direct effects from crushing would be 

most likely in October when species leave streamside areas for overwintering sites, or during 

rainy periods when species may move beyond riparian areas. Operation of heavy equipment 

ceases during periods of prolonged precipitation to prevent compaction.

Introduced fire could directly affect herpetofauna similar to Alternative 2. Allowing fire to creep 

into the SMZ (as opposed to active introduction) would provide opportunity for herpetofauna to 

move away from areas burning, but not eliminate the possibility of mortality. 

Direct effects to listed herpetofauna would not be anticipated from implementing Alternative 3 

due to project design measures; non-detection of listed species during surveys; and no records of 

these species occurring within the project area subwatersheds.

Indirect Effects 

Thinning to reduce ladder fuels would occur over approximately 760 acres under Alternative 3, 

90 acres less than Alternative 2. Underburning is proposed over approximately 215 acres, and 

mastication on 800 acres. Table 17 identifies that perennial streams adjacent to treatment areas 

represent approximately 320 acres of foothill yellow-legged frog; 630 acres western pond turtle; 

90 acres mountain yellow-legged frog; 30 acres of Yosemite toad; 8 miles of benthic 

macroinvertebrates, and 7 acres of Pacific tree frog habitat. The RABO habitat acreage is within 

WPT habitat (overlap). Within the RABO and WPT habitat are 90 acres that would have no 

treatments (corridors along perennial and intermittent streams). Similarly, 30 acres of RAMU 

habitat occurs along no treatment corridors. Effects from compaction and stand density would be 

similar to Alternative 2. 

Canopy Cover

Currently the levels of stream shading (based on 2007 data) are within the desired condition of > 

70%. Similar to Alternative 2, there would be no indirect effects on water temperature anticipated 

from Alternative 3. Changes to microclimate beyond the riparian corridors may affect habitat and 

dispersal of herpetofauna through changes to air temperature, wind speed, and relative humidity. 

Water Temperature

Similar to Alternative 2, there would be no anticipated alterations to canopy cover, thus there 

would be no direct effects on water temperature expected from Alternative 3.
Chapter 3: Affected Environment and Environmental Consequences

102 Sierra National Forest

Large Woody Debris

Table 10 indicates that stream channels in subwatersheds 501.5053; 503.0010, 503.0011, and 

503.0055 are lower than the desired condition for large woody debris. There is no proposed 

felling of snags, unless the snag meets criteria set forth in the design criteria. Some snags to be 

removed may have contributed to LWD recruitment. Thinning to remove ladder fuels would also 

remove some trees that could have potential to reach a stream channel. Indirect negative effects to 

LWD recruitment would similar to those presented under Alternative 2. 

Cumulative Effects

Past, present, and reasonably foreseeable actions within the project areas are displayed in Chapter 

3 on page 25. For the Sugar Pine Project Area, other known activities are off-highway vehicle 

use, fuel, culture, and timber projects (including activities on private property), cattle grazing, 

road maintenance, and recreational use (both developed and undeveloped). Similar to Alternative 

2:

 The combination of the Federal and private timber removal is not expected to 

cumulatively effect LWD recruitment, which would remain lower than desired within 

HUC8 subwatersheds 501.5053, 503.0010, 503.0011, and 503.0055.

 A cumulative watershed effect would not be anticipated from Alternative 3 (Gallegos 

2009). Stream channels would be expected to remain overall stable, with some areas of 

localized instability. 

 It is expected that cattle grazing will locally result in exposed streambanks and erosion. 

The majority of the primary use areas are within subwatersheds that drain to North Fork 

Willow Creek, rather than the Fresno or Merced Rivers.

Table 23 summarizes anticipated effects from the action alternatives (Alternatives 2, 3, and 4) on 

aquatic threatened (T), endangered (E), and sensitive (S) species, along with habitat for 

management indicator species (MIS).

Alternative 4 

Gross acres of proposed treatments by subwatershed are displayed in Table 22. The actual area 

treated is expected to be less (approximately 85%) similar to Alternatives 2 and 3.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 103

Table 22. Activities Proposed within Project Area Subwatersheds under Alternative 4 

HUC8 Subwatershed

501.5003501.5005501.5006501.5007501.5053501.5054503.0008503.0009503.0010503.0011503.0055503.3001

Total

Biomass/mastication/ precommercial thinning or 

tractor piling 0 5 194 132 124 11 297 323 627 33 162 1908

Mastication 19 8 79 0 34 18 110 294 3 138 80 14 797

Underburn 0 9 13 0 21 22 15 113 22 0 0 215

No Treatments 447 2207 352 536 1638 1429 523 1280 897 474 2322 1367 13472

Subwatershed Acres 466 2229 638 668 1817 1480 945 2010 1549 645 2564 1381 16392

% Subwatershed treated 4% 1% 45% 20% 10% 3% 45% 36% 42% 27% 9% 1% 18%

(Acres generated by GIS)
Chapter 3: Affected Environment and Environmental Consequences

104 Sierra National Forest

Direct Effects

The 5 acres of potential habitat for CRLF are the private ponds in the Sugar Pine and Fish Camp 

areas, which are not part of this project. Similar to Alternatives 2 and 3, there could be potential

direct effects from crushing of RABO, WPT, RAMU, or BUCA by biomass thinning, tractor 

piling, or mastication, or from burning of animals. 

Similar to Alternatives 2 and 3, it would be expected that direct effects to herpetofauna would be 

limited. Project design measures include the Old Forest Linkage corridors for Pacific fisher. 

These migration corridors extend 150 feet from both streambanks along the perennial streams 

within the project area. There are no proposed treatments within the inner 50 feet from each 

streambank. The outer 50 feet would implement hand treatments to remove the understory ladder 

fuels. No heavy equipment would be allowed within 100 feet of the streambank within these 

corridors. During primary periods of project operations (May – Sept) it is expected frogs and 

turtles would remain within the riparian areas due to presence of water; the microclimate 

provided; and riparian connectivity, except during rainy periods. The possibility of direct effects 

from crushing would be most likely in October when species leave streamside areas for 

overwintering sites or during rainy periods when species may move beyond riparian areas. 

Operation of heavy equipment ceases during periods of prolonged precipitation to prevent 

compaction.

Introduced fire could directly affect herpetofauna similar to Alternatives 2 and 3. Allowing fire to 

creep into the SMZ (as opposed to active introduction) would provide opportunity for 

herpetofauna to move away from areas burning, but not eliminate the possibility of mortality. 

Direct effects to listed herpetofauna would not be anticipated from implementing Alternative 4 

due to project design measures; non-detection of listed species during surveys; and no records of 

these species occurring within the project area subwatersheds.

Indirect Effects

Biomass thinning to reduce ladder fuels would occur on over approximately 1,065 acres under 

Alternative 4, which is 850 acres more than Alternative 2. Underburning is proposed over 

approximately 215 acres, and mastication on 800 acres. Table 17 identifies that perennial streams 

adjacent to treatment areas represent approximately 320 acres of foothill yellow-legged frog; 630 

acres western pond turtle; 90 acres mountain yellow-legged frog; 30 acres of Yosemite toad; 8 

miles of benthic macroinvertebrate, and 7 acres of Pacific tree frog habitat. The RABO habitat 

acreage is within WPT habitat (overlap). Within the RABO and WPT habitat are 90 acres that 

would have no treatments (corridors along perennial and intermittent streams). Similarly, 30 acres 

of RAMU habitat occurs along no treatment corridors. Effects from compaction and stand density

would be similar to Alternatives 2 and 3, although somewhat less due to fewer trees being 

removed. Alterations to habitat complexity, air temperature, decreased soil moisture or relative 

humidity within areas adjacent to perennial streams could influence herpetofauna.

Canopy Cover

Currently the levels of stream shading (based on 2007 data) are within the desired condition of > 

70%. Similar to Alternatives 2 and 3, there would be no indirect effects on water temperature 

anticipated from Alternative 4. Changes to microclimate beyond the riparian corridors may affect 

habitat and dispersal of herpetofauna through changes to air temperature, wind speed, and relative 

humidity. 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 105

Water Temperature

Similar to Alternatives 2 and 3, there would be no anticipated alterations to canopy cover, thus 

there would be no direct effects on water temperature expected from Alternative 4.

Large Woody Debris

Under Alternative 4, there is no proposed felling of snags, unless the snag meets criteria set forth 

in the design criteria. Some snags to be removed may have contributed to LWD recruitment. 

Thinning to remove ladder fuels would also remove some trees that could have potential to reach 

a stream channel, although the number would be fewer than Alternatives 2 or 3. Indirect negative 

effects to LWD recruitment would similar, but less than those presented under Alternatives 2 and 

3 due to greater retention of commercial sized trees. 

Cumulative Effects 

Past, present, and reasonably foreseeable actions within the project areas are displayed in Chapter 

3 on page 25. For the Sugar Pine Project Area, other known activities are off-highway vehicle 

use, fuel, culture, and timber projects (including activities on private property), cattle grazing, 

road maintenance, and recreational use (both developed and undeveloped). Similar to 

Alternatives 2 and 3:

 The combination of the Federal and private timber removal is not expected to 

cumulatively effect LWD recruitment, which would remain lower than desired, within 

HUC8 subwatersheds 501.5053, 503.0010, 503.0011, and 503.0055.

 A cumulative watershed effect would not be anticipated from Alternative 4 (Gallegos 

2009). Stream channels would be expected to remain overall stable, with some sites of 

localized instability. 

 It is expected that cattle grazing will locally result in exposed streambanks and erosion. 

The majority of the primary use areas are within subwatersheds that drain to North Fork 

Willow Creek, rather than the Fresno or Merced Rivers.

Table 19 summarizes effects to TES species and MIS habitat.

Table 23. Summary from Analyses for Aquatic Threatened, Endangered, Sensitive 

(BA/BE), and Management Indicator Species for Effects from Project Alternatives

Species (status) Determination

California red-legged frog (T) No effect

Foothill yellow-legged frog (S) May affect individuals, but is not likely to lead to 

Federal listing or loss of viability. 

Western pond turtle (S) May affect individuals, but is not likely to lead to 

Federal listing or loss of viability. 

Mountain yellow-legged frog (S) May affect individuals, but is not likely to lead to 

Federal listing or loss of viability. 

Yosemite toad (S) No effect

Benthic Macroinvertebrates Habitat (MIS) Stable

Pacific tree frog Habitat (MIS) Stable

Source: Strand 2009, Strand 2009a
Chapter 3: Affected Environment and Environmental Consequences

106 Sierra National Forest

Terrestrial Management Indicator Species _______

The purpose of the terrestrial MIS report is to evaluate and disclose the impacts of the Sugar Pine 

Adaptive Management Project on the habitat of terrestrial Management Indicator Species (MIS) 

identified in the SNF LRMP (USDA-FS 1992) as amended by the Sierra Nevada Forests 

Management Indicator Species Amendment (SNF MIS Amendment) Record of Decision (USDAFS 2007a). The MIS report documents the effects of the proposed action and alternatives on the 

habitat of selected project-level MIS. The direct, indirect and cumulative effects to the terrestrial 

management indicator species are summarized from the Terrestrial Management Indicator 

Species Report for the Sugar Pine Adaptive Management Project (Otto, A. and Williams, K. 

2008).

MIS are animal species identified in the SNF MIS Amendment Record of Decision (ROD) signed 

December 14, 2007, which was developed under the 1982 National Forest System Land and 

Resource Management Planning Rule (1982 Planning Rule) (36 CFR 219). The current rule 

applicable to project decisions is the 2004 Interpretive Rule, which states ―Projects implementing 

land management plans...must be developed considering the best available science in accordance 

with §219.36(a)...and must be consistent with the provisions of the governing plan.‖ (Appendix 

B to §219.35). Guidance regarding MIS set forth in the Sierra NF LRMP (USDA-FS 1992) as 

amended by the 2007 SNF MIS Amendment ROD directs Forest Service resource managers to 

(1) at project scale, analyze the effects of proposed projects on the habitat of each MIS affected 

by such projects, and (2) at the bioregional scale, monitor populations and/or habitat trends of 

MIS, as identified in the Sierra NF LRMP (USDA-FS 1992)as amended.

Affected Environment

MIS Habitat Status and Trend 

All habitat monitoring data are collected and/or compiled at the bioregional scale, consistent with 

the SNF LRMP (USDA-FS 1992) as amended by the 2007 Sierra NF MIS Amendment ROD 

(USDA Forest Service 2007a).

Habitats are the vegetation types (for example, early seral coniferous forest) or ecosystem

components (for example, snags in green forest) required by an MIS for breeding, cover, and/or 

feeding. MIS for the Sierra Nevada National Forests represent 10 major habitats and 2 ecosystem 

components (USDA-FS 2007a and project record). These habitats are defined using the 

California Wildlife Habitat Relationship (CWHR) System (CDFG 2005). The CWHR System 

provides the most widely used habitat relationship models for California‘s terrestrial vertebrate 

species (ibid). Appendix D includes tables explaining the acronyms used for available habitat 

stages in the CWHR system. It is also described in detail in the Sierra NF Bioregional MIS 

Report (USDA-FS 2008). 

Habitat status is the current amount of habitat on the Sierra Nevada Forests. Habitat trend is the 

direction of change in the amount or quality of habitat over time. The methodology for assessing 

habitat status and trend is described in detail in the Sierra NF Bioregional MIS Report (USDA-FS

2008). 

MIS Population Status and Trend

All population monitoring data are collected and/or compiled at the bioregional scale, consistent 

with the LRMP as amended by the 2007 Sierra NF MIS Amendment ROD (USDA-FS 2007a). 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 107

The information is presented in detail in the 2008 Sierra NF Bioregional MIS Report (USDA-FS 

2008).

Population monitoring strategies for MIS of the Sierra NF are identified in the 2007 Sierra 

Nevada Forests Management Indicator Species (SNF MIS) Amendment ROD (USDA-FS 2007a). 

Population status is the current condition of the MIS related to the population monitoring data 

required in the 2007 SNF MIS Amendment ROD for that MIS. Population trend is the direction 

of change in that population measure over time.

There are a myriad of approaches for monitoring populations of MIS, from simply detecting 

presence to detailed tracking of population structure (USDA-FS 2001, Appendix E, page E-19). A 

distribution population monitoring approach is identified for all of the terrestrial MIS in the 2007 

SNF MIS Amendment, except for the greater sage-grouse (USDA-FS 2007a). Distribution 

population monitoring consists of collecting presence data for the MIS across a number of sample 

locations over time. Presence data are collected using a number of direct and indirect methods, 

such as surveys (population surveys), bird point counts, tracking number of hunter kills, counts of 

species sign (such as deer pellets), and so forth. The specifics regarding how these presence data 

are assessed to track changes in distribution over time vary by species and the type of presence 

data collected, as described in the Sierra NF Bioregional MIS Report (USDA-FS 2008). 

Methodology for Analysis 

Project-level effects on MIS habitat are analyzed and disclosed as part of environmental analysis 

under the National Environmental Policy Act (NEPA). This involves examining the impacts of 

the proposed project alternatives on MIS habitat by discussing how direct, indirect, and 

cumulative effects will change the habitat in the analysis area. 

These project-level impacts to habitat are then related to broader scale (bioregional) population 

and/or habitat trends. The appropriate approach for relating project-level impacts to broader scale 

trends depends on the type of monitoring identified for MIS in the LRMP as amended by the SNF 

MIS Amendment ROD. Hence, where the Sierra NF LRMP as amended by the SNF MIS 

Amendment ROD identifies distribution population monitoring for an MIS, the project-level 

habitat effects analysis for that MIS is informed by available distribution population monitoring 

data, which are gathered at the bioregional scale. The bioregional scale monitoring identified in 

the Sierra NF LRMP, as amended, for MIS analyzed for the Sugar Pine Adaptive Management 

Project is summarized in Section 3 of the Terrestrial MIS report.

Adequately analyzing project effects to MIS generally involves the following steps:

 Identifying which habitat and associated MIS would be either directly or indirectly 

affected by the project alternatives; these MIS are potentially affected by the project.

 Summarizing the bioregional-level monitoring identified in the LRMP, as amended, for 

this subset of MIS.

 Analyzing project-level effects on MIS habitat for this subset of MIS. 

 Discussing bioregional scale habitat and/or population trends for this subset of MIS. 

 Relating project-level impacts on MIS habitat to habitat and/or population trends at the 

bioregional scale for this subset of MIS.

These steps are described in detail in the Pacific Southwest Region draft document ―MIS

Analysis and Documentation in Project-Level NEPA, R5 Environmental Coordination‖ (May 25, 

2006). This Management Indicator Species (MIS) Report documents application of the above 
Chapter 3: Affected Environment and Environmental Consequences

108 Sierra National Forest

steps to select project-level MIS and analyze project effects on MIS habitat for the Sugar Pine 

Adaptive Management Project.

Mitigation and Monitoring 

Special project design measures for the Sugar Pine Adaptive Management Project were 

developed in concert with the Bass Lake Ranger District interdisciplinary team, USFWS, PSW 

Research scientists, and concerned public participation groups. These design measures would be 

implemented under any of the three action Alternatives. Within this project area special 

considerations have been given to maintaining higher levels of biodiversity through actions such 

as delineating Old Forest Linkages (OFLs) surrounding perennial streams (see Design Criteria in 

FEIS and Otto, A. et. al. 2010 for a description of OFLs). Higher levels of biodiversity have also 

been planned for by marking retention groups of large diameter trees. Two hundred and eighty 

(280) such tree groups were identified in the main project area, and an additional 74 were 

identified in the hydrology study area. These tree groups are composed of a cluster of three or 

more trees, 30 inch dbh or greater, with touching crowns, and will benefit those species which 

utilize dense groupings of large trees. Another project design measure which will maintain 

biodiversity is the identification of retention areas around large oaks within treatment units. Two

to three large oaks per acre were identified and marked with paint. These oaks will retain a zone 

of no activity around them measuring 35 feet, or dripline circumference around the oak 

(whichever is greater). The delineation of OFLs, retention of large tree groups, and oak no 

treatment zones will ensure a heterogeneous post treatment landscape resulting in the continued 

accessibility of both hiding cover and prey availability within these areas of biodiversity (USDAFS 2009b).

The project is designed to improve habitat conditions through the acceleration of latesuccessional habitat characteristics, while still maintaining current functional habitat. Specific 

project design criteria include: canopy cover will be maintained at 50 to 60% or greater where 

available; ground disturbance will be limited to those guidelines with the LRMP as amended; 

vegetation species diversity and composition will be maintained; management activities will be 

limited in designated riparian management areas; and retention of snags and downed logs would 

be retained at levels defined in the Design Criteria Common to All Action Alternatives. All 

riparian management areas within the project have been identified and buffers established. In 

addition, no operations will occur during the wet weather season. (USDA-FS 2009b)

Category 1 MIS

Species that will not be discussed further in this document include Category 1 and Category 2 

MIS. Category 1 defines MIS whose habitat does not occur in or adjacent to the project area. For 

the Sugar Pine Adaptive Management Project Category 1 MIS include the greater sage-grouse 

and the black-backed woodpecker. No sagebrush (SGB) or burned forest habitat is currently 

present in or adjacent to the project area. 

Category 2 MIS

Category 2 defines MIS whose habitat is in or adjacent to the project area, but whose habitat 

would not be directly or indirectly affected by the project. For the Sugar Pine Adaptive 

Management Project, Category 2 MIS include: yellow warbler, sooty grouse, California spotted 

owl, American marten, and northern flying squirrel. Though habitat for these species occurs 

within the project area, that habitat will not be directly or indirectly affected by the project. The 

primary reasons for this appraisal are the Sugar Pine Adaptive Management Project design

features which limit the activities reducing canopy closure. These design features, as well as 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 109

applicable Forest Service standards and guidelines protecting species habitats are discussed 

further in the Sugar Pine Adaptive Management Project MIS Report for each of the Category 2 

MIS.

Category 3 MIS

The MIS whose habitat would be either directly or indirectly affected by the Sugar Pine Adaptive 

Management Project, identified as Category 3, are carried forward in this analysis, which will 

evaluate the direct, indirect, and cumulative effects of the proposed action and alternatives on the 

habitat of these MIS (see project record). The MIS selected for project-level MIS analysis for the 

Sugar Pine Adaptive Management Project are: fox sparrow, mule deer, mountain quail, and hairy 

woodpecker.

The following section documents the analysis for the following Category 3 species: fox sparrow, 

mule deer, mountain quail, and hairy woodpecker. The analysis of the effects of the Sugar Pine 

Adaptive Management Project on the terrestrial MIS habitat for the selected project-level MIS is 

conducted at the project scale. The analysis used the California Wildlife Habitat Relationship 

model (CWHR (Mayer and Laudenslayer 1988)) data to determine vegetative type within the 

entire Sugar Pine Adaptive Management Project Boundary. Existing acres of vegetation type 

(base vegetation layer) were determined using the Sierra National Forest Corporate GIS 

vegetation feature class of 2001 ExistingVeg2001_pl. This base layer was refined using existing 

structure analysis from more than 50 stand examination plot data collected in 2007 and 2008, as 

well as forest aerial photography interpretation from the 2001 flightline, and 1 meter resolution 

satellite imagery from the National Agricultural Imagery Program (NAIP). Treatment acres 

relative to existing vegetation were based on mapping and field visits conducted by the Bass Lake 

Ranger District Silviculturist. These field visits refined the base vegetation layer and determined 

the net acres of treatment. Detailed information on the MIS is documented in the SNF 

Bioregional MIS Report (USDA-FS 2008), which is hereby incorporated by reference. 

MIS Project-level Effects Analysis - Shrubland (West-Slope 

Chaparral) Habitat

Current Condition of the Habitat Factor(s) in the Project Area: There are a total of 71 acres 

of shrubland (chaparral) habitat within the project boundary. Sixty-five (65) acres are classified as 

montane chaparral (MCP) and the remaining 6 acres are classified as mixed chaparral (MCH). Of 

the 71 acres of chaparral within the project boundary, only 38%, or 27 acres occur within 

treatment analysis areas and have the potential to be treated under this project while only 21 acres 

are actually proposed to be treated. Please refer to Tables 40 and 41 in Appendix D (Sugar Pine 

CWHR Data Table, Main Project Area and Hydrology Study Area, Present Compared to 

Alternative 2 Proposal) for a full breakdown of all CWHR habitat types within the project 

boundary pre- and post-treatment.

Alternative 1 – No Action

Alternative 1 is the No Action Alternative. Under the No Action Alternative, current management 

plans would continue to guide management of the project area. This includes all ongoing 

activities with existing decisions or permits that would not be changed if this alternative were 

selected including: underburning, plantation maintenance, cattle grazing, recreation, and 

recreation residences. The No Action Alternative would not implement the Sugar Pine Adaptive 

Management Project to reduce fire ladder conditions (thinning); pile slash for burning; burn slash 

piles; masticate and/and or precommercially thin stands; plant trees; reduce fuel loading through 
Chapter 3: Affected Environment and Environmental Consequences

110 Sierra National Forest

controlled burning; construct handline around jackpot burn areas; or construct and reconstruct 

roads.

Direct and Indirect Effects to Habitat

There are no direct effects to shrubland habitat under this alternative. There is a potential for 

indirect effects under the No Action Alternative as the continued immediate threat of wildfire 

would remain unabated. In failing to make an attempt at density management of the stands, the 

eventual changes through drought stress and subsequent insect and disease mortality acceleration 

would exacerbate the threat of stand replacing fire. Additionally, the high probability of a drying 

climate change throughout the Western United States would have the potential to further 

compound these effects (USDA-FS 2009a, Stalter 2008, Smith 2008). 

Cumulative Effects to Habitat in the Analysis Area 

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 cumulative effects boundary area was identified as the extent of the 12 HUC 8 subwatersheds 

contained in or adjacent to the project boundary: 503.0008, 503.0009, 503.0010, 503.0011, 

503.0055, 503.3001, 501.5003, 501.5005, 501.5006, 501.5007, 501.5053, and 501.5054 and 

covers an area of 16,381 acres. Past, present, and reasonably foreseeable actions within all 12 

subwatersheds surrounding the project area are displayed in Table 3 of the Sugar Pine Adaptive 

Management Project Environmental Impact Statement (USDA-FS 2009a, Gallegos 2008). 

Cumulative Effects Conclusion

Under Alternative 1 the Sugar Pine Project would not be implemented. The immediate effect of 

wildfires in shrubland habitat would be a loss of function for that portion of the habitat until 

shrubs recovered enough to provide foraging, nesting, and cover habitat. However because most 

shrubland ecosystems are fire adapted, and because most fires burn with a mosaic of severity and 

intensity across the landscape, post fire shrub habitats may still provide forage, nesting, and cover 

for many species. Unfortunately, without fuels treatments, the extent of shrublands severely 

impacted by wildfire is expected to be much greater and take much longer for recovery, having 

more lasting impacts on the distribution and abundance of this habitat type on the landscape. 

Within the cumulative effects analysis area, other known activities are off-highway vehicle use, 

fuel, culture, and timber projects (past Federal and activities on private property), cattle grazing, 

road maintenance, and recreational use (both developed and undeveloped). Many of the ongoing 

management activities within the cumulative effects boundary do not contribute to significant 

cumulative impacts upon shrubland habitat. Of the actions elevated within the analysis area, road 

maintenance along the 86 miles of road and plantation maintenance of the 115 acres of existing 

plantation within the extended subwatershed boundary area would be the most likely actions to 

affect shrubland habitat. Changes in shrubland densities would be relatively short-lived because 

many shrubs would sprout within a year (depending on shrub type, treatment type, and treatment 

intensity). There are a total of 861 acres of MCH and MCP habitat within the cumulative effects 

boundary of this project, of which a very small percentage may be treated during road and 

plantation maintenance activities. Any cumulative effects to shrubland habitat would be minimal 

as a result of choosing Alternative 1, and in the absence of a catastrophic wildfire, habitat would 

be expected to remain in fair condition. 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 111

Alternative 2 – Proposed Action

Direct and Indirect Effects to Habitat

Under Alternative 2 direct effects to 21 acres of shrubland habitat are proposed through 

mastication and prescribed burning treatments. These 21 acres would be treated to maintain the 

growth and vigor of existing trees, or to create conditions suitable for the establishment of planted 

trees. The change in seral stage of 21 acres of chaparral out of 71 acres within the project 

boundary is a treatment of 38% of the total chaparral available within the Sugar Pine Project 

Boundary. There are an additional 50 acres of shrubland habitat identified within the project 

boundary that are not proposed for treatment under the current project, and would still provide 

suitable habitat for fox sparrow during implementation of mastication and burning activities. 

Two (2) acres of proposed prescription burning would occur in MCP habitat in the hydrology 

study area, and 19 acres of proposed mastication treatments would occur in MCP habitat in the 

main project area. Immediately after treatment, these 21 acres would not be useable as shrubland 

habitat because shrubs would be reduced below 20 percent cover. This shrub cover reduction 

would be temporary, and shrubs would likely begin to recover in less than one year since 

chemicals would not be used in either treatment. Shrubland habitat that is currently senescent 

would be brought back to an early seral stage chaparral, increasing its vigor and habitat value. 

Cumulative Effects to Habitat in the Analysis Area

A table of current and future projects within the analysis area for the Sugar Pine Adaptive 

Management Project was presented in the Cumulative Effects discussion of Alternative 1. There 

are a total of 861 acres of MCH and MCP habitat within the cumulative effects boundary of this 

project. This project proposes treating at most 3% of the existing shrubland habitat within the 

cumulative effects boundary. 

Cumulative Effects Conclusion

There are a total of 861 acres of MCH and MCP habitat within the cumulative effects boundary 

of this project. This project proposes treating at most 3% of the existing shrubland habitat within 

the cumulative effects boundary. Further activities taking place within the cumulative effects 

boundary that may alter shrubland habitat include road brushing and plantation maintenance. 

These activities may alter a very small percentage of the available shrubland habitat through 

removal of senescent chaparral bordering roads and inside plantations, resulting in natural 

regeneration of early seral stage chaparral habitat.

Alternative 3

Direct, Indirect, and Cumulative Effects to Habitat and Conclusion

The proposed treatments for the shrubland habitat within Alternative 3 are the same as for 

Alternative 2, therefore the direct, indirect, and cumulative effects for Alternative 3 would be the 

same as those discussed under the Proposed Action.

Alternative 4

The proposed treatments for the shrubland habitat within Alternative 4 are the same as for 

Alternative 2; therefore the direct, indirect, and cumulative effects for Alternative 4 would be the 

same as those discussed under the Proposed Action.
Chapter 3: Affected Environment and Environmental Consequences

112 Sierra National Forest

Summary of Fox Sparrow Status and Trend at the Bioregional Scale

The Sierra NF LRMP (as amended by the SNF MIS Amendment) requires bioregional-scale 

habitat and distribution population monitoring for the fox sparrow; hence, the shrubland effects 

analysis for the Sugar Pine Adaptive Management Project must be informed by both habitat and 

distribution population monitoring data. The sections below summarize the habitat and 

distribution population status and trend data for the fox sparrow. This information is drawn from 

the detailed information on habitat and population trends in the Sierra Nevada Forests 

Bioregional MIS Report (USDA-FS 2008), which is hereby incorporated by reference.

Habitat Status and Trend

There are currently 922,000 acres of west-slope chaparral shrubland habitat on National Forest 

System lands in the Sierra Nevada. Within the last decade, the trend is stable. 

Population Status and Trend

The fox sparrow has been monitored in the Sierra Nevada at various sample locations by avian 

point counts and breeding bird survey protocols, including: 1997 to present – Lassen National 

Forest (Burnett and Humple 2003, Burnett et al. 2005); 2002 to present – Plumas and Lassen 

National Forests (Sierra Nevada Research Center 2007); on-going monitoring through California 

Partners in Flight Monitoring Sites (CPIF 2002); 1992 to 2005 – Sierra Nevada Monitoring Avian 

Productivity and Survivorship (MAPS) stations (Siegel and Kaschube 2007); and 1968 to present 

– BBS routes throughout the Sierra Nevada (Sauer et al. 2007). These data indicate that fox 

sparrows continue to be present at these sample sites, and current data at the rangewide, 

California, and Sierra Nevada scales indicate that, although there may be localized declines in the 

population trend, the distribution of fox sparrow populations in the Sierra Nevada is stable.

Relationship of Project-Level Habitat Impacts to Bioregional-Scale Fox Sparrow 

Trend 

The 861 acres of shrubland habitat that exists within the Cumulative Effects (CE) boundary 

account for less than 1% of the 922,000 acres that exists at the bioregional scale, and only 21 of 

these acres are proposed for treatment. Therefore, cumulative impacts within the CE boundary 

would not alter the existing bioregional trends in this habitat, nor would they lead to a change in 

the distribution of fox sparrows across the Sierra Nevada bioregion. 

Oak-Associated Hardwoods and Hardwood/Conifer Habitat (Mule 

deer)

Current Condition of the Habitat Factor(s) in the Project Area

There are currently 850 acres of montane hardwood and montane hardwood conifer habitat within 

the Sugar Pine Adaptive Management Project boundary of which 53% or 450 of these acres are 

within treatment analysis areas. Please refer to Tables 40 and 41 located in Appendix D (Sugar 

Pine CWHR Data Table, Main Project Area and Hydrology Study Area, Present Compared to 

Alternative 2 Proposal) for a full breakdown of all CWHR habitat types within the Project 

boundary pre- and post-treatment.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 113

Alternative 1 – No Action

Direct and Indirect Effects to Habitat

There would be no direct effects to montane hardwood or montane hardwood-conifer habitat 

under this alternative. There is a potential for indirect effects under the No Action Alternative as 

the continued immediate threat of wildfire would remain unabated. In failing to make an attempt 

at density management of the adjacent conifer stands, the eventual changes through drought stress 

and subsequent insect and disease mortality acceleration would exacerbate the threat of stand 

replacing fire. Additionally, the high probability of a drying climate change throughout the 

Western United States would have the potential to further compound these effects (USDA-FS 

2009a, Stalter 2008, Smith 2008). 

Cumulative Effects to Habitat in the Analysis Area and Conclusion

Past, present, and reasonably foreseeable actions within the 12 subwatersheds inside and adjacent 

to the project area are displayed in Table 3 of this document, referenced from the Sugar Pine 

Adaptive Management Project Environmental Impact Statement (USDA-FS 2009a). Under 

Alternative 1 the Sugar Pine Project would not be implemented. The immediate effect of 

wildfires in hardwood and hardwood/conifer habitat would be a loss of function for that portion 

of the habitat until the hardwoods recovered enough to provide foraging, and nesting habitat. 

However because most hardwood ecosystems are fire adapted, and because most fires burn with a 

mosaic of severity and intensity across the landscape, post fire hardwood habitats may still 

provide forage, nesting, and cover for many species. Unfortunately, without fuels treatments in 

the conifer types, the extent of hardwood habitat severely impacted by wildfire is expected to be 

much greater and take much longer for recovery, having more lasting impacts on the distribution 

and abundance of this habitat type on the landscape. 

Many of the ongoing management activities within the cumulative effects boundary do not 

contribute to significant cumulative impacts upon montane hardwood or hardwood/conifer

habitat. Of the cumulative effects actions elevated within the analysis area, private land 

residential development and roadside hazard tree removal have the greatest potential to alter 

hardwood and hardwood conifer habitat. There is a total of 3341 acres of MHC and MHW habitat 

within the cumulative effects boundary. Hardwood and hardwood/conifer habitats account for 

20% of the total available habitat in the cumulative effects boundary. It is possible that a very 

small percentage of MHC and MHW habitat may be removed as hazards during roadside hazard 

tree removal or as residential construction continues within the cumulative effects boundary. Any 

cumulative effects to hardwood and hardwood/conifer habitat would be minimal as a result of 

choosing Alternative 1, and in the absence of a catastrophic wildfire, habitat would be expected to 

remain in good condition.

Alternative 2 – Proposed Action

Direct and Indirect Effects to Habitat 

A direct effect of implementing Alternative 2 would be a change in CWHR type for 2 acres of 

mule deer habitat. Although not the intent of the proposed prescribed burning, it is possible that 2

acres of MHC4D habitat would be converted to MHC4M habitat through flare-ups during 

burning activities. This would represent a less than 1% decrease in the amount of MHC4D habitat 

within the project boundary, and a 3% increase in the amount of MHC4M habitat available within 

the project boundary. With the application of the LRMP standards and guidelines, direct and 

indirect effects to deer will be minimal because the most important habitat types to deer will 

receive the management emphasis called for in the LRMP, and the Sugar Pine Adaptive 
Chapter 3: Affected Environment and Environmental Consequences

114 Sierra National Forest

Management Project uneven-aged silvicultural treatments and prescribed burning will tend to 

improve deer foraging habitat. Forest Service standards and guidelines pertaining to hardwood 

habitat are included in the project record. Additional protections for hardwood habitat that will be 

applied to this project include the formation of oak no treatment areas, described on page 15 of 

this document and in the project EIS and BE/BA (USDA-FS 2009a, Otto et.al. 2010). 

Cumulative Effects to Habitat in the Analysis Area and Conclusion

Of the cumulative effects actions elevated within the analysis area, private land residential 

development and roadside hazard tree removal have the greatest potential to alter hardwood and 

hardwood conifer habitat. There is a total of 3341 acres of MHC and MHW habitat within the 

cumulative effects boundary. The proposed treatment of 2 acres would constitute a treatment of 

less than 1% of the total available habitat within the cumulative effects boundary. Additional 

effects to habitat through roadside hazard tree work and private land residential development will 

be insignificant compared with the amount of habitat available.

Alternative 3

Direct, Indirect, and Cumulative Effects to Habitat and Conclusion

The proposed treatments for the montane hardwood and montane hardwood/conifer habitat within 

Alternative 3 are the same as for Alternative 2, therefore the direct, indirect, and cumulative 

effects for Alternative 3 would be the same as those discussed under the Proposed Action.

Alternative 4 

Direct, Indirect, and Cumulative Effects to Habitat and Conclusion

The proposed treatments for the montane hardwood and montane hardwood/conifer habitat within 

Alternative 4 are very limited in scope and will not change any CWRH habitat type, size, or 

density, therefore no direct effects to montane hardwood and montane hardwood/conifer habitat 

would be expected to occur with implementation of Alternative 4. Indirect effects can be 

expected by failing to make an attempt at density management of the stands, the eventual changes 

through drought stress and subsequent insect and disease mortality acceleration would exacerbate 

the threat of stand replacing fire. Additionally, the high probability of a drying climate change 

throughout the Western United States would have the potential to further compound these effects. 

(USDA-FS 2009a, Stalter 2008, Smith 2008). 

Summary of Mule Deer Status and Trend at the Bioregional Scale

The Sierra NF LRMP (as amended by the SNF MIS Amendment) requires bioregional-scale 

habitat and distribution population monitoring for the mule deer; hence, the oak-associated 

hardwood and hardwood/conifer effects analysis for the Sugar Pine Adaptive Management 

Project must be informed by both habitat and distribution population monitoring data. The 

sections below summarize the habitat and distribution population status and trend data for the 

mule deer. This information is drawn from the detailed information on habitat and population 

trends in the Sierra Nevada Forests Bioregional MIS Report (USDA-FS 2008), which is hereby 

incorporated by reference.

Habitat Status and Trend

There are currently 809,000 acres of oak-associated hardwood and hardwood/mixed conifer

habitat on National Forest System lands in the Sierra Nevada. The trend is slightly increasing 

(within the last decade, changing from 5% to 7% of the acres on National Forest System lands). 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 115

Population Status and Trend

The mule deer has been monitored in the Sierra Nevada at various sample locations by herd 

monitoring (spring and fall) and hunter survey and associated modeling (CDFG 2007a). 

California Department of Fish and Game (CDFG) conducts surveys of deer herds in early spring 

to determine the proportion of fawns that have survived the winter, and conducts fall counts to 

determine herd composition (CDFG 2007a). This information, along with prior year harvest 

information, is used to estimate overall herd size, sex and age rations, and the predicted number 

of bucks available to hunt (ibid). These data indicate that mule deer continue to be present across 

the Sierra Nevada, and current data at the rangewide, California, and Sierra Nevada scales 

indicate that, although there may be localized declines in some herds or Deer Assessment Units, 

the distribution of mule deer populations in the Sierra Nevada is stable.

Relationship of Project-Level Habitat Impacts to Bioregional-Scale Mule Deer 

Trend

The 3341 acres of montane hardwood and montane hardwood/conifer habitat that exists within 

the Cumulative Effects boundary account for less than 1% of the 809,000 acres that exists at the 

bioregional scale. The change of 2 acres out of 809,000 acres of oak-associated hardwood and 

hardwood/conifer habitat in the Sugar Pine Adaptive Management Project Area will not alter the 

existing trend in the habitat, nor will it lead to a change in the distribution of mule deer across the 

Sierra Nevada bioregion.

Early and Mid Seral Coniferous Forest Habitat (Mountain quail)

Current Condition of the Habitat Factor(s) in the Project Area

There is currently 3,566 acres of early and mid seral coniferous forest habitat within the Sugar 

Pine Adaptive Management Project boundary of which 58% or 2064 acres of this habitat are 

within treatment analysis areas. Please refer to Tables 40 and 41 located in Appendix D (Sugar 

Pine CWHR Data Table, Main Project Area and Hydrology Study Area, Present Compared to 

Alternative 2 Proposal) for a full breakdown of all CWHR habitat types within the Project 

boundary pre- and post-treatment.

Alternative 1 – No Action

Direct and Indirect Effects to Habitat

There would be no direct effects to early and mid seral coniferous habitat under this alternative. 

There is a potential for indirect effects under the No Action Alternative as the continued 

immediate threat of wildfire would remain unabated. In failing to make an attempt at density 

management of the stands, the eventual changes through drought stress and subsequent insect and 

disease mortality acceleration would exacerbate the threat of stand replacing fire. Additionally, 

the high probability of a drying climate change throughout the Western United States would have 

the potential to further compound these effects (USDA-FS 2009a, Stalter 2008, Smith 2008). 

Cumulative Effects to Habitat in the Analysis Area and Conclusion

Past, present, and reasonably foreseeable actions within the 12 subwatersheds inside and adjacent 

to the project area are displayed in the Sugar Pine Adaptive Management Project Environmental 

Impact Statement (USDA-FS 2009a). Under Alternative 1 the Sugar Pine Project would not be 

implemented. The immediate effect of wildfires in early and mid seral coniferous habitat would 

be a loss of function for that portion of the habitat until the habitat recovered enough to provide 

foraging, and nesting habitat. Without fuels treatments, the extent of early and mid seral habitat 
Chapter 3: Affected Environment and Environmental Consequences

116 Sierra National Forest

severely impacted by wildfire is expected to be much greater and take much longer for recovery, 

having more lasting impacts on the distribution and abundance of this habitat type on the 

landscape. 

There is a total of 8171 acres of early and mid seral coniferous habitat within the cumulative 

effects boundary. These habitat types constitute 50% of the total available habitat in the 

cumulative effects boundary. Many of the ongoing management activities within the cumulative 

effects boundary do not contribute to significant cumulative impacts upon early and/or mid seral 

coniferous forest habitat. Of the cumulative effects actions elevated within the analysis area 

private land residential development, roadside hazard tree removal, on-going plantation 

maintenance, and past and future timber sale activity have the greatest potential to alter early and 

mid seral coniferous habitat. 

It is possible that a small percentage of early and mid seral stage coniferous habitat may be 

removed as residential construction continues within the cumulative effects boundary. It is 

reasonable to assume that some portion of the roadside hazard trees are in the later stages of early 

seral habitat, as well as mid and late seral habitat. Nevertheless, removal of a few trees within a 

stand does not change its habitat rating. Therefore, roadside hazard tree removal would not 

impact either early, mid, or late seral habitat. Early and mid seral habitats treated under ongoing 

plantation maintenance projects likely have or will experience better health, vigor, and growth by 

being released from competition.

About 2,640 acres of thinning occurred within the CE boundary during the 1980s, with an 

additional 2000 to 3000 acres proposed for future treatment under the Fish Camp Adaptive 

Management project in the next few years. Due to the thinning prescriptions implemented under 

previous projects, seral stages did not change. Stands merely reflected less density. It is expected 

that those stands treated have experienced better health, vigor, and growth and will be less 

susceptible to wildfires. Proposed Fish Camp Project prescriptions should mirror those proposed 

under the Sugar Pine Adaptive Management project, including any special design measures for 

wildlife recently developed for the Sugar Pine Project. Any cumulative effects to early and mid 

seral coniferous habitat within the cumulative effects boundary would be minimal as a result of 

choosing Alternative 1, and in the absence of a catastrophic wildfire, habitat would be expected to 

remain in good condition.

Alternative 2 – Proposed Action

Direct and Indirect Effects to Habitat

Under Alternative 2, minimal changes in CWHR composition of early and mid seral coniferous 

habitat are proposed for a little over 1% of the 3,566 acres of habitat within the project boundary. 

37 acres of PPN3D would be converted to PPN3M through proposed mechanical thinning

treatments. One (1) acre of PPN4D would likely be converted to PPN4M through proposed 

prescribed burning. Three (3) acres of SMC3D would be converted to SMC3M through proposed 

mechanical thinning work, and 5 acres of SMC4D would be converted to SMC4M through 

proposed prescription burning. The remaining 2,018 acres of early and mid seral coniferous 

habitat within the treatment analysis acres will not experience a change in CWHR habitat type, 

size, or density under the Alternative 2 proposal. Due to the thinning prescriptions proposed, 

additional seral stage changes beyond those described will not change. Stands will merely reflect 

less density. Where stand density is at 60% or greater, it will not be brought below this level. It is 

expected that those stands treated will experience better health, vigor, and growth and will be less 

susceptible to wildfires.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 117

Cumulative Effects to Habitat in the Analysis Area and Conclusion

There is a total of 8,171 acres of early and mid seral coniferous habitat within the 12 

subwatershed cumulative effects boundary. These habitat types constitute 50% of the total 

available habitat within that boundary. Many of the ongoing management activities within the 

cumulative effects boundary will not contribute to significant cumulative impacts upon early 

and/or mid seral coniferous forest habitat. Of the cumulative effects actions elevated within the 

analysis area private land residential development, roadside hazard tree removal, on-going 

plantation maintenance, and past and future timber sale activity have the greatest potential to alter 

early and mid seral coniferous habitat as discussed under the cumulative effects section for 

Alternative 1. Additional effects through Alternative 2 proposed canopy cover changes of 0.5% 

of the total habitat in the cumulative effects boundary are insignificant, especially when one 

considers the vast amount of available early and mid seral coniferous habitat present within the 

cumulative effects boundary.

Alternative 3

Direct, Indirect, and Cumulative Effects to Habitat and Conclusion

The proposed treatments for the early and mid seral stage coniferous habitat within Alternative 3 

are nearly the same as for Alternative 2. Under Alternative 3, minimal changes in CWHR 

composition of early and mid seral coniferous habitat are proposed for a little over 1% of the 

3,566 acres of habitat within the project boundary. Seventeen (17) acres of PPN3D would be 

converted to PPN3M through proposed mechanical thinning work. One (1) acre of PPN4D would 

likely be converted to PPN4M through proposed prescribed burning. Three (3) acres of SMC3D 

would be converted to SMC3M through proposed mechanical thinning work, and 5 acres of 

SMC4D would be converted to SMC4M through proposed prescription burning. The remaining 

2,018 acres of early and mid seral coniferous habitat within the treatment analysis acres will not 

experience a change in CWHR habitat type, size, or density under the Alternative 3 proposal. 

Additional effects through Alternative 3 proposed canopy cover changes of 0.3% of the total 

habitat in the cumulative effects boundary are insignificant considering the vast amount of 

available habitat within the cumulative effects boundary. Due to the thinning prescriptions 

proposed, additional seral stage changes beyond those described will not change. Stands will 

merely reflect less density. Where stand density is at 60% or greater, it will not be brought below 

this level. It is expected that those stands treated will experience better health, vigor, and growth 

and will be less susceptible to wildfires.

Alternative 4 

Direct, Indirect, and Cumulative Effects to Habitat and Conclusion

The proposed treatments for the early and mid seral stage coniferous habitat within Alternative 4 

are very limited in scope and will not change any CWHR habitat type, size, or density, therefore 

no direct effects to early and mid seral coniferous habitat would be expected to occur with 

implementation of Alternative 4. 

Indirect effects can be expected by failing to make an attempt at density management of the 

stands, the eventual changes through drought stress and subsequent insect and disease mortality 

acceleration would exacerbate the threat of stand replacing fire. Additionally, the high probability 

of a drying climate change throughout the Western United States would have the potential to

further compound these effects (USDA-FS 2009a, Stalter 2008, Smith 2008). 
Chapter 3: Affected Environment and Environmental Consequences

118 Sierra National Forest

Summary of Mountain Quail Status and Trend at the Bioregional Scale

The Sierra NF LRMP (as amended by the SNF MIS Amendment) requires bioregional-scale 

habitat and distribution population monitoring for the mountain quail; hence, the early and mid 

seral coniferous forest effects analysis for the Sugar Pine Adaptive Management Project must be 

informed by both habitat and distribution population monitoring data. The sections below 

summarize the habitat and distribution population status and trend data for the mountain quail. 

This information is drawn from the detailed information on habitat and population trends in the 

SNF Bioregional MIS Report (USDA-FS 2008), which is hereby incorporated by reference.

Habitat Status and Trend

There are currently 546,000 acres of early seral and 2,766,000 acres of mid seral coniferous forest 

(ponderosa pine, Sierran mixed conifer, white fir, and red fir) habitat on National Forest System 

lands in the Sierra Nevada. Within the last decade, the trend for early seral is slightly decreasing 

(from 9% to 5% of the acres on National Forest System lands) and the trend for mid seral is 

slightly increasing (from 21% to 25% of the acres on National Forest System lands). 

Population Status and Trend

The mountain quail has been monitored in the Sierra Nevada at various sample locations by 

hunter survey, modeling, and breeding bird survey protocols, including California Department of 

Fish and Game hunter survey, modeling, and hunting regulations assessment (CDFG 2004, 

CDFG 2004a) and 1968 to present – BBS routes throughout the Sierra Nevada (Sauer et al. 

2007). These data indicate that mountain quail continue to be present across the Sierra Nevada, 

and current data at the rangewide, California, and Sierra Nevada scales indicate that the 

distribution of mountain quail populations in the Sierra Nevada is stable.

Relationship of Project-Level Habitat Impacts to Bioregional-Scale Mountain 

Quail Trend

The 8,171 acres of early and mid seral coniferous habitat that exists within the cumulative effects 

boundary account for 1.5% of the 546,000 acres that exists at the bioregional scale. The change in 

canopy closure of 46 acres out of 809,000 acres of early and mid seral coniferous habitat in the 

Sierra Nevada bioregion will not alter the existing trend in the habitat, nor will it lead to a change 

in the distribution of mountain quail across the Sierra Nevada bioregion.

Snags in Green Forest Ecosystem Component (Hairy woodpecker) 

Habitat/Species Relationship

The hairy woodpecker was selected as the MIS for the ecosystem component of snags in green 

forests. Medium (diameter breast height [dbh] between 15 to 30 inches) and large (diameter 

breast height greater than 30 inches) snags are most important. The hairy woodpecker uses stands 

of large, mature trees and snags of sparse to intermediate density; cover is also provided by tree 

cavities (CDFG 2005). Mature timber and dead snags or trees of moderate to large size are 

apparently more important than tree species (Siegel and DeSante 1999). 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 119

Project-level Effects Analysis – Snags in Green Forest Ecosystem 

Component

Current Condition of the Habitat Factor(s) in the Project Area 

Prior to 2004, the forest implemented standards and guidelines (S&Gs) from the Sierra NF LRMP

(USDA-FS 1992) which called for maintaining an average of 1.5 snags per acre in sizes 15 to 24-

inch dbh and an average of 0.5 snags per acre in sizes 25-inch dbh or greater. All countable snags 

had to be 20 feet or greater height (S&G #64, p. 4-16). Additionally, a sufficient number of live 

trees had to be left in appropriate sizes to serve as replacement snags. The Sierra Nevada Forest 

Plan Amendment (SNFPA) (USDA-FS 2004a), modified the Sierra NF LRMP with the 

followings guidelines: (1) in westside mixed conifer and ponderosa pine types, Forests should 

maintain 4 of the largest snags per acre, (2) in red fir forest type, they should maintain 6 of the 

largest snags per acre, (3) in eastside pine and mixed conifer forest types, they should maintain 3 

of the largest snags per acre, and (4) in westside hardwood ecosystems, they should maintain 4 of 

the largest snags (hardwood or conifer) per acre, or if standing live hardwood trees lack dead 

branches, they should maintain 6 of the largest snags per acre (S&G #11, p. 51).

Current conditions within the project boundary meet and in many areas exceed the snag and down 

woody material retention guidelines laid forth in the SNFPA ROD (USDA-FS 2004). The 

following standards and guidelines for Snags and Down Woody Material apply to this project 

(USDA-FS 2004a, Pg. 51-52).

Alternative 1 – No Action

Direct and Indirect Effects to Habitat

There would be no direct effects to snags in green forest habitat under this alternative. There is a

potential for indirect effects under the No Action Alternative as the continued immediate threat of 

wildfire would remain unabated. In failing to make an attempt at density management of the 

stands, the eventual changes through drought stress and subsequent insect and disease mortality 

acceleration would exacerbate the threat of stand replacing fire. Such a wildfire would convert 

current snags in green forest habitat to snags in burned forest habitat. Additionally, the high 

probability of a drying climate change throughout the Western United States would have the 

potential to further compound these effects (USDA-FS 2009a, Stalter 2008, Smith 2008). 

Cumulative Effects to Habitat in the Analysis Area and Conclusion

Past, present, and reasonably foreseeable actions within the 12 sub-watershed cumulative effects 

boundary are displayed in Table 3 of this document, referenced from the Sugar Pine Adaptive 

Management Project Environmental Impact Statement (USDA-FS 2009a). Under Alternative 1 

the Sugar Pine Project would not be implemented. The immediate effect of wildfires would 

convert current snags in green forest habitat to snags in burned forest habitat.

There is a total of 12,015 acres of mid and late seral forest habitat that provides the green forest 

snag component within the cumulative effects boundary. These habitat types constitute 73% of 

the total available habitat in the cumulative effects boundary. Many of the ongoing management 

activities within the cumulative effects boundary do not contribute to significant cumulative 

impacts upon mid and/or late seral forest habitat. Of the cumulative effects actions elevated 

within the analysis area private land residential development, roadside hazard tree removal, ongoing plantation maintenance, and past and future timber sale activity have the greatest potential 

to alter snags within mid and late seral coniferous habitat. 
Chapter 3: Affected Environment and Environmental Consequences

120 Sierra National Forest

It is possible that a small percentage of snags may be felled as residential construction continues 

within the cumulative effects boundary. It is reasonable to assume that all of the roadside hazard 

trees are snags in varying stages of decay. Roadside hazard tree removal is slated for 41 miles of 

road within the cumulative effects boundary. However, only trees that are considered a public 

safety hazard (SNFPA ROD (USDA-FS 2004a), Appendix A, page 29) and up to a potential 

maximum distance of 300 feet on either side of the road is slated for removal (USDA-FS 2006a). 

This removal of public safety hazard trees along linear features is not expected to bring the 

available snag levels within the proposed project area below the current standards set forth in the 

ROD.

Alternative 2 – Proposed Action

Direct, Indirect, and Cumulative Effects to Habitat and Conclusion

There would be minimal direct effects to snags under the Alternative 2 proposed action. No snags 

are proposed for removal by any of the Action alternatives in the Sugar Pine Adaptive 

Management Project, except where they constitute a safety concern. Current conditions within the 

project boundary and cumulative effects boundary meet and in many areas exceed the snag and 

down woody material retention guidelines laid forth in the SNFPA ROD (USDA-FS 2004a). It is 

reasonable to assume that a few stage 4 through 7 snags may be lost in prescribed fire treatment 

areas, however this treatment is also likely to produce stage 2 and 3 snags. It is not expected that 

removal of snags that pose a safety concern along roadways or in treatment units will alter the 

available snag levels below the current standards set forth in the ROD. 

Alternative 3

Direct, Indirect, and Cumulative Effects to Habitat and Conclusion

The proposed treatments for forest snags within Alternative 3 are the same as for Alternative 2;

therefore the direct, indirect, and cumulative effects for Alternative 3 would be the same as those 

discussed under the Proposed Action.

Alternative 4

Direct, Indirect, and Cumulative Effects to Habitat and Conclusion

The proposed treatments for forest snags within Alternative 4 are the same as for Alternative 2;

therefore the direct, indirect, and cumulative effects for Alternative 4 would be the same as those 

discussed under the Proposed Action.

Summary of Hairy Woodpecker Status and Trend at the Bioregional Scale

The Sierra NF LRMP (as amended by the SNF MIS Amendment) requires bioregional-scale 

habitat and distribution population monitoring for the hairy woodpecker; hence, the snag effects 

analysis for the Sugar Pine Adaptive Management Project must be informed by both habitat and 

distribution population monitoring data. The sections below summarize the habitat and 

distribution population status and trend data for the hairy woodpecker. This information is drawn 

from the detailed information on habitat and distribution population trends in the SNF 

Bioregional MIS Report (USDA-FS 2008), which is hereby incorporated by reference.

Ecosystem Component Status and Trend

The current (based on 2001-2004 inventory sources) average number of medium-sized and largesized snags (> 15-inch dbh, all decay classes) per acre across major coniferous and hardwood 

forest types (westside mixed conifer, ponderosa pine, white fir, productive hardwoods, red fir, 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 121

eastside pine) in the Sierra Nevada ranges from 1.4 per acre in eastside pine to 8.3 per acre in 

white fir. Detailed information by forest type, snag size, and snag decay class can be found in the 

SNF Bioregional MIS Report (USDA-FS 2008). 

Data from the mid-to-late 1990s were compared with the current data to calculate the trend in 

total snags per acre by Regional forest type for the 10 Sierra Nevada national forests and indicate 

that, during this period, snags per acre increased within westside mixed conifer (+0.80), white fir 

(+1.98), and red fir (+0.68) and decreased within ponderosa pine (-0.17), productive hardwoods (-

0.17), and eastside pine (-0.16).

Population Status and Trend

The hairy woodpecker has been monitored in the Sierra Nevada at various sample locations by 

avian point counts and breeding bird survey protocols, including 1997 to present – Lassen 

National Forest (Burnett and Humple 2003, Burnett et al. 2005); 2002 to present – Plumas and 

Lassen National Forests (Sierra Nevada Research Center 2007); 1992 to 2005 – Sierra Nevada 

Monitoring Avian Productivity and Survivorship (MAPS) stations (Siegel and Kaschube 2007); 

and 1968 to present – BBS routes throughout the Sierra Nevada (Sauer et al. 2007). These data 

indicate that the hairy woodpecker continues to be present at these sample sites, and current data 

at the rangewide, California, and Sierra Nevada scales indicate that the distribution of hairy 

woodpecker populations in the Sierra Nevada is stable. 

Relationship of Project-Level Habitat Impacts to Bioregional-Scale Hairy 

Woodpecker Trend

The 12,015 acres of mid and late seral forest habitat that provides the green forest snag 

component within the cumulative effects boundary account for less than 1% of the 3,835,000 

acres of mid and late seral coniferous forest habitat within the Sierra Nevada bioregion. 

Therefore, none of the alternatives would alter the bioregional trend in the snag component of the 

coniferous forest habitat, nor would they lead to a change in the distribution of the hairy 

woodpecker across the Sierra Nevada bioregion.
Chapter 3: Affected Environment and Environmental Consequences

122 Sierra National Forest

Hydrology/Water Quality _____________________

The direct, indirect and cumulative effects to the hydrologic resource and water quality are 

summarized from the Hydrology Report (Stone, A. and Kaplan-Henry 2008) and Cumulative 

Watershed Effects Analysis (Gallegos, A. 2008) for the Sugar Pine Adaptive Management Project.

Affected Environment

The project area has been affected by a history of past fires and historic logging. Currently the 

Sugar Pine Railroad is active today and serves as a destination for recreation. The current 

condition of creeks in the project area shows current uses and effects of past activity.

The Sugar Pine Adaptive Management Project is located in the Upper Lewis Creek Watershed 

and a portion of the Big Sandy Creek watershed. Upper Lewis Creek, Lewis Fork of the Fresno 

River is tributary to the Fresno River Watershed. Fresno River is tributary to the San Joaquin 

River, which supplies water to a four billion ($4,000,000,000) a year agricultural industry in the 

Central Valley. All of the discharge from Big Sandy Watershed, White Chief Branch and 

headwaters to Big Creek at one time flowed into Big Creek, which is tributary to south fork of the 

Merced River. Big Creek drainage has had up to 6000 acre-feet of water is diverted between 

December 1st and July 15th into the Lewis Fork of the Fresno River along a ditch located in 

section 30 just east of the project boundary. This diversion has occurred since the 1870s. Channel 

conditions have adjusted since the time of diversion to reach equilibrium. Table 24 provides a 

summary of the affected drainages and associated water bodies in the project area. Map 9, found 

in the Map Package displays the location of perennial streams and subwatersheds associated with 

the project. 

Table 24. Subwatershed Summaries

Main 

Stream 

System(s)

Watershed

(HUC 5) Subwatersheds

(HUC 8)

Stream miles

Perennial Intermittent Ephemeral Total

Lewis 

Creek

Fresno River

(1804000701)

503.0008

503.0009

503.0010

503.0011

503.0055

503.3001

16.6 11.5 112.2 140.3

Big Creek

SF Merced

(1804000803)

501.5003

501.5005

501.5006

501.5007

501.5053

501.5054

17.1 13.5 90.5 121.1
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 123

Summary of Existing Conditions

Although there is evidence of past logging practices, channels appear to have recovered. Stream 

Condition Inventories and Channel Stability Analysis were performed in most of the watersheds 

associated with the project. The locations of these inventories were selected based on their 

potential to respond to disturbance. They are by definition ―response reaches‖ and represent the 

most delicate reach along the drainage surveyed. These areas provide the best locations to 

monitor as these areas would be the first to change. The current condition for most of the stream 

reaches is good or fair for channel stability using modified Pfankuch, after Rosgen (2004). The 

one exception is upper Lewis Creek, which rated a poor. 

Alternative 1 – No Action

Direct effects associated with not treating fire/fuels objectives and forest health objects in the 

project area would result in a lost opportunity to reduce potential for catastrophic fire. This lost 

opportunity has the potential to affect not only the communities at risk; it also affects the riparian

habitat and water quality in the project area. As described in the affected environment, riparian 

areas have large amounts of organic material throughout the drainages. This material is not lying 

on the forest floor; it is intermingled with standing material. In the event of a wildfire, riparian 

habitat, channel characteristics and riparian vegetation would be greatly affected.

Direct Effects

Direct effects of no actions would be continued increase of fuels and potential for catastrophic 

wildfire.

Indirect Effects

Indirect Effects of no action would be basin wide increases of fuels and potential for catastrophic 

wildfire.

Cumulative Effects 

Cumulative Effects of no action would be displayed under the Pre project condition of the 

Cumulative Watershed Effects (CWE) analysis described under Best Management Practices 

(BMP) #7-8. Essentially the only watershed considered at or near CWE prior to field 

investigations was Lewis-Red Rock (503.0055). Field investigations indicated that this drainage 

is predominately bedrock controlled and has little potential to be affected by the project. 

Additionally SCI investigations indicate Channel Stability using modified Pfankuch (Rosgen, 

2001) is good. 
Chapter 3: Affected Environment and Environmental Consequences

124 Sierra National Forest

Table 25. Activities Proposed under Alternative 1 – No Action Alternative

Subwatershed

501.5003501.5005501.5006501.5007501.5053501.5054503.0008503.0009

503.001

503.0011503.0055503.3001

Total

Commercial or pre-commercial 

thinning or tractor piling 0 0 0 0 0 0 0 0 0 0 0 0 0

Precommercial Thin 0 0 0 0 0 0 0 0 0 0 0 0

Mastication 0 0 0 0 0 0 0 0 0 0 0 0 0

Underburn 0 0 0 0 0 0 0 0 0 0 0 0 0

No Treatments 466 2229 638 668 1817 1480 945 2010 1549 645 2564 1381 16392

Subwatershed Acres 466 2229 638 668 1817 1480 945 2010 1549 645 2564 1381 16392
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 125

Alternative 2 – Proposed Action

The Proposed Action would implement treatments designed to meet fire/fuels and forest health 

objectives. Proposed treatments by subwatershed are displayed in Table 23.

Limited or no treatment would occur in SMZs. Direct treatments would be excluded from SMZs; 

in general, all vegetation and fuel treatments conducted in RCAs would focus on improving forest 

health, enhancing or maintaining hydrologic function and maintaining or enhancing the key 

attributes of riparian habitats. Attributes comprise cool, moist soil conditions; high water quality; 

retention of large snags and down logs in sufficient quantities to provide habitat and woody 

debris recruitment in stream channels; and retention of woody material to provide stability to 

riparian and aquatic habitats. Well-functioning channels have good riparian vegetation, good 

sediment transport, and stable streambanks. These characteristics work together to maintain 

channel function and stability.

A wide range of activity-specific BMPs are designed to minimize detrimental soil disturbance, 

protect water quality, maintain physical stability, and hydrologic connectivity of riparian and 

aquatic habitats. There is little potential for the Proposed Action to adversely affect the 

geomorphic, hydrologic, or riparian characteristics and aquatic habitats in affected watersheds 

because of the low-impact characteristics of the proposed stand treatments, the limitations that 

would be imposed on operations within RCAs and SMZs, and the use of activity-specific BMPs. 

The greatest potential for the Proposed Action to affect the hydrologic connectivity of streams 

and aquatic habitat exists at stream crossings. To minimize the potential for project-related effects 

on hydrologic connectivity, existing crossings would be used whenever possible. In the event that 

it is necessary to construct a temporary crossing, the methods used for construction would be 

selected to avoid or minimize detrimental soil and vegetation disturbance and to maintain 

hydrologic connectivity between upstream and downstream features. All temporary crossings 

would be removed following the completion of project-related activities and would be treated as 

necessary to restore pre-project conditions. Implementation of the activity-specific BMPs would 

further ensure that hydrologic connectivity in streams and special aquatic features is not adversely 

affected by the Proposed Action. 
Chapter 3: Affected Environment and Environmental Consequences

126 Sierra National Forest

Table 26. Activities Proposed within Project Area Subwatersheds under Alternative 2

Subwatershed

501.5003501.5005501.5006501.5007501.5053501.5054503.0008503.0009503.0010503.0011503.0055503.3001

Total

Commercial/pre-commercial 

thinning or tractor piling 0 5 194 132 124 11 297 323 627 33 162 1908

Mastication 19 8 79 0 34 18 110 294 3 139 80 14 797

Underburn 0 9 15 0 21 22 15 113 22 0 0 215

No Treatments 447 2207 352 536 1638 1429 524 1280 897 473 2322 1367 13472

Subwatershed Acres 466 2229 638 668 1817 1480 945 2010 1549 645 2564 1381 16392

% Subwatershed treated 4% 1% 45% 20% 10% 4% 45% 35% 42% 27% 9% 1% 18%

(Acres Generated by GIS)
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 127

Direct Effects

Direct effects are those occurring at the same time and place as the triggering action. The 

Proposed Action could directly affect aquatic resources, primarily as a result of vegetation 

removal, road construction, slash piling, and prescribed fire immediately following treatment; 

such activities could lead to soil disturbance and its associated effects on aquatic habitats (e.g., 

accelerated erosion and sedimentation). Any soil displacement, compaction, or change in ground 

cover would cause a direct effect on watershed condition and aquatic habitat. Most treatment 

units have avoided crossing stream channels. The exception is 4th order ephemeral draws. Fuels 

treatments have been laid out to utilize designated and/or existing crossings. Streamcourses are to 

be protected under C6.5 of the Timber Sale Contract. Any additional streams identified during 

operations will receive protection appropriate for the stream and the treatment.

Subwatershed 503.0008

There are approximately 3.8 miles of National Forest Transportation System (NFTS) road

currently in need of maintenance or reconstruction to reduce sediment. Lower gradient reaches 

are sensitive and have the potential to be affected by units T4 and M8. The main channel draining 

the 503.0008 subwatershed is a Class I perennial creek that begins in unit RX3 and runs adjacent 

to M7, T4, and through M8. There is a 100 foot SMZ assigned to this section of the drainage. 

Road 6S90 intersects the headwaters of the creek. There are no small tributaries to the main 

drainage of this watershed affected by road 5S18 as drainages were not noticed above this road. 

Other tributaries to the main stem channel in the watershed have SMZs that range from 25 to 75 

feet. 

Subwatershed 503.0010

Upper Lewis Creek forms the west fork to Lewis Fork Creek. This channel has low to moderate 

gradients below road 5S17 and steeper gradients upstream of the road. Above the road the 

channel exhibits a marshy character suggestive of past logging practices when streamside zones 

were not protected as they are today. This thick, very wet accumulation of organic and 

sedimentary debris has been downcut 2+ feet. The channel flows in this downcut reach. The 

downcut reach has a very wide flood plain. The riparian area should be avoided by management 

activity because it is easily damaged due to its wet character. 

The only units that propose to have new road construction are units T-7 and T16 (Section 26). 

There are two possible routes that could be constructed: an east-west route that would connect FS 

road 6S07 to State Highway 41; and a roughly north-south road connecting FS road 5S17 to State 

Highway 41. The possible east-west route crosses a Class II stream with an SMZ of 75 feet; the 

possible north-south route crosses a Class I stream with an SMZ of at least 100 feet. The location 

of these potential crossings would be done in close coordination with aquatics and earth science 

to alleviate any concerns relative to riparian dependent species and follow applicable Standards 

and Guides (100, 101) in accordance with RCO#2. Moreover, any effects from the crossings 

would be mitigated by applicable BMPs for road and building site construction (in USDA-FS 

2000a p. 53-81).

Tributary drainages in subwatershed 503.0010 are Class I to Class IV drainages. The drainage in 

unit T8 paralleling road 5S79, sec. 35/36, was closely evaluated. At the creek crossing along this 

road a culvert is non functional and water is concentrating along the roadbed. This is causing 

rilling down the road and should be fixed during road reconstruction. This area is recovering from 

past logging and is currently stable, but very delicate. Crossing this channel has the potential to 

affect the stability of the channel. Unit T-11 is proposed adjacent to a stream channel that is 
Chapter 3: Affected Environment and Environmental Consequences

128 Sierra National Forest

currently in poor condition, within a subwatershed (503.0010) that is considered sensitive to 

disturbance. Project design criteria have been developed to protect the channel from further 

degradation. Thinning trees is not expected to have much effect on annual yield or increase peak 

flows.

Indirect Effects

Indirect effects are those that occur at a later time or at a distance from the triggering action. 

Indirect effects are expected to be minor. Conservation measures incorporated into the project 

would be implemented to control erosion and sedimentation. The implementation of BMPs would 

avoid or minimize potential increases in sediment loads to streams during project implementation 

such that prescribed fires are not expected to affect aquatic habitats. Over the longer term, 

potential adverse effects on water and soils from implementing the Proposed Action are expected 

to be minor, and substantially less than if an uncontrolled wildfire were to occur.

Cumulative Effects 

Based on field investigations and level of protection provided by BMPs, specifically SMZ width 

and associated treatment prescribed in RCAs in addition to wildlife considerations, it is not 

expected that any CWE would occur. 

The only watershed considered being at or near CWE prior to field investigations was Lewis-Red 

Rock (503.0055). Field investigations indicated that this drainage is predominately bedrock 

controlled and has little potential to be affected by the project. 

Alternative 3

Under Alternative 3, treatments would continue to focus on meeting the fire/fuels and forest 

health, similar to Alternative 2 (proposed action). Alternative 3 would differ from the proposed 

action in that the designated 2008 F01 Pacific fisher densite would be buffered and a Limited 

Operating Period (LOP) implemented in all suitable fisher habitat. Treatment within this densite 

buffer would include ladder and surface fuels (within the lower and limited mid-canopy levels) 

needed to achieve fire/fuels objectives within the WUI zones. Treatments outside the buffer 

would remain the same as Alternative 2. Table 24 shows a comparison of acreage between 

Alternative 2 and 3. The mastication and Rx burn methodologies would not change within the 

buffer, but the thinning treatment would differ as described above.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 129

Table 27. Activities Proposed within Project Area Subwatersheds under Alternative 3

HUC8 Subwatershed

501.5003501.5005501.5006501.5007501.5053501.5054503.0008503.0009503.0010503.0011503.0055503.3001

Total

Commercial/pre-commercial 

thinning or tractor piling 0 5 194 132 124 11 119 181 627 33 99 0 1525

Lower canopy treatment/precommercial thinning or 

tractor piling 0 0 0 0 0 0 178 142 0 0 63 0 383

Mastication 19 8 79 0 34 18 110 294 3 138 80 14 797

Underburn 0 9 13 0 21 22 15 113 22 0 0 215

No Treatments 447 2207 352 536 1639 1429 523 1280 897 474 2322 1367 13473

Subwatershed Acres 466 2229 638 668 1817 1480 945 2010 1549 645 2564 1381 16392

% Subwatershed treated 4% 1% 45% 20% 10% 3% 45% 36% 42% 27% 9% 1% 18%
Chapter 3: Affected Environment and Environmental Consequences

130 Sierra National Forest

Direct Effects

Direct effects are those occurring at the same time and place as the triggering action. The direct 

effects would be similar to those described under Alternative 2, except in subwatersheds 

503.0008, 503.0009, 503.0055 in that there would be less impact because the thinning

methodology would only concentrate on ladder and surface fuels (within the lower and limited 

mid-canopy levels).

Indirect Effects

Indirect effects are those that occur at a later time or at a distance from the triggering action. Like 

Alternative 2, indirect effects are expected to be minor. Conservation measures incorporated into 

the project would be implemented to control erosion and sedimentation. The implementation of 

BMPs would avoid or minimize potential increases in sediment loads to streams during project 

implementation such that prescribed fires are not expected to affect aquatic habitats. Over the 

longer term, potential adverse effects on water and soils from implementing the Alternative 3 are 

expected to be minor, and substantially less than if an uncontrolled wildfire were to occur.

Cumulative Effects

Based on field investigations and level of protection provided by BMPs, specifically SMZ width 

and associated treatment prescribed in RCAs in addition to wildlife considerations, it is not 

expected that any CWE would occur. 

The only watershed considered being at or near CWE prior to field investigations was Lewis-Red 

Rock (503.0055). Alternative 3 has less ground disturbing activities and field investigations 

indicated that this drainage is predominately bedrock controlled and thus has little potential to be 

affected by the project. 

Alternative 4

Under Alternative 4, treatments would be used to meet fire/fuels objectives only and no 

vegetation management treatments designed to meet forest health objectives would be 

undertaken. Gross acres of proposed treatments by subwatershed are displayed in Table 25. The 

actual area treated is expected to be less (approximately 85%) similar to Alternatives 2 and 3.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 131

Table 28. Activities Proposed within Project Area Subwatersheds under Alternative 4

HUC8 Subwatershed

501.5003501.5005501.5006501.5007501.5053501.5054503.0008503.0009503.0010503.0011503.0055503.3001

Total

Biomass/mastication/pre-commercial 

thinning or tractor piling 0 5 194 132 124 11 297 323 627 33 162 1908

Mastication 19 8 79 0 34 18 110 294 3 138 80 14 797

Underburn 0 9 13 0 21 22 15 113 22 0 0 215

No Treatments 447 2207 352 536 1638 1429 523 1280 897 474 2322 1367 13472

Subwatershed Acres 466 2229 638 668 1817 1480 945 2010 1549 645 2564 1381 16392

% Subwatershed treated 4% 1% 45% 20% 10% 3% 45% 36% 42% 27% 9% 1% 18%

(Acres Generated By GIS)
Chapter 3: Affected Environment and Environmental Consequences

132 Sierra National Forest

Direct Effects

Direct effects are those occurring at the same time and place as the triggering action. The direct 

effects would be less than those described under Alternative 2, in that there would be less impact 

because the thinning methodology would only concentrate on ladder and surface fuels within the 

lower and mid-canopy levels.

Indirect Effects

Indirect effects are those that occur at a later time or at a distance from the triggering action. Like 

Alternative 2, indirect effects are expected to be minor. Conservation measures incorporated into 

the project would be implemented to control erosion and sedimentation. The implementation of 

BMPs would avoid or minimize potential increases in sediment loads to streams during project 

implementation such that impacts to aquatic habitats are not expected. Over the longer term, 

potential adverse effects on water and soils from implementing Alternative 4 are expected to be 

minor, and substantially less than if an uncontrolled wildfire were to occur.

Cumulative Effects

Based on field investigations and level of protection provided by BMPs, specifically SMZ width 

and associated treatment prescribed in RCAs in addition to wildlife considerations, it is not 

expected that any CWE would occur. 

The only watershed considered being at or near CWE prior to field investigations was Lewis-Red 

Rock (503.0055). Alternative 3 has less ground disturbing activities and field investigations 

indicated that this drainage is predominately bedrock controlled and thus has little potential to be 

affected by the project. 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 133

Forest Vegetation/Silviculture _________________

The direct, indirect and cumulative effects to forest vegetation are summarized from the 

Silvicultural Report for the Sugar Pine Adaptive Management Project (Smith, D. 2008).

Affected Environment

The Sugar Pine Adaptive Management Project area has a history of numerous past logging 

activities. Over the past 125 years several small lumber mills have been supplied with logs from 

conifer stands within and adjacent to the proposed project area. During the 1880s a lumber mill 

along California Creek within Nelder Grove processed giant sequoia trees from Nelder Grove. 

Other small mills in the vicinity of the project as well as larger mills in the Oakhurst area also 

processed trees from within the project boundaries. Between 1923 and 1927 heavy railroad 

clearcut logging was carried out by the Madera Sugar Pine Company through much of the project 

area. Logs from railroad logged stands were transported to the mill at Sugar Pine over its 140 

miles of track. The mill operated for 32 years averaging a 40 million board foot cut each year. 

Seven locomotives and 100 log hauling cars were in use during its peak.

During the railroad logging at the beginning of the last century, logs were yarded by a system of 

cable settings. Deep gouging occurred in a number of places where logs dug into the soil as they 

were yarded to landings. As logs approached landings, more soil was generally displaced. In 

many cases, this reduced soil depths to almost bare rock. Settings can often be distinguished by a 

lack of conifer reproduction and an abundance of brush still today. However, between cableways, 

existing reproduction was often protected from damage. Logging slash was not treated following 

harvest. Today, much of this early reproduction remains as stands of generally 90 to 110 year old 

6 to 24 inch dbh incense cedar, sugar pine, ponderosa/Jeffrey pine, and white fir.

During the 1960s, a significant effort was made throughout California to reforest, previously 

forested areas that were understocked. Approximately 180 acres that were railroad logged within 

the proposed project boundaries were planted during this period. 

Exclusion of fire from the vast majority of the area since the fires of the early 1900s resulted in 

the development of multi-layered stands. The understory layers consist of fir and incense cedar 

beneath young growth stands of ponderosa/Jeffrey pine, sugar pine, incense cedar, and white fir 

with, in some cases, an additional layer of brush beneath or adjacent. In pine plantations, incense 

cedar and white fir and /or brush have seeded in, thus creating significant fuel ladders. 

Although pockets of older trees can be found scattered through the proposed project area, past 

railroad and other logging as well as stand replacing fires have resulted in little of the area being 

vegetated with trees older than 130 years. The natural stands proposed for thinning within the 

project area generally consist of approximately 90 to 110 year old trees that were young saplings 

during the railroad logging era. Due to the warmer and drier predominately west and south 

aspects within the project area, the majority of stands present are considered to be pine types. 

These stands, once heavy to more fire resistant ponderosa and sugar pine, have become very 

heavy to less fire resistant incense cedar and fir. Plot data indicates that in many areas incense 

cedar comprises 40 to 80 percent of the basal area sampled. Mixed conifer aggregations and 

stands occupy areas near cooler, damper draws and at the higher elevations within the project 

area. Pine, mixed conifer and white fir stand basal area stocking varies from 120 ft2per acre in 

more open areas to oak pockets to densely stocked pockets of 350 to 400 ft2per acre or more. 

Canopy cover varies substantially across the project area. Canopy cover ranges from quite dense 
Chapter 3: Affected Environment and Environmental Consequences

134 Sierra National Forest

(80 to 100%) in overstocked areas to clumpy dense patches in less uniformly stocked areas to 

more moderate (50 to 70%) to fairly light in other locations. A number of brushfields, resulting 

from previous fires and early 1900s logging, are broken up by clumps of live and black oak and 

are found throughout the project area.

Climatic Changes

Tree ring studies have established that compared to the previous two centuries weather during the 

20th Century was relatively moist without the decades-long droughts that occurred earlier (Ferrell

1996). Beginning in the 1970s temperatures began to warm noticeably. This warming resulted in 

a greater fraction of the Sierra Nevada precipitation falling as rain rather than snow, earlier 

snowmelt and earlier streamflow peaks (Dettinger 2004). The combination of reduced stand vigor 

and excessive stocking combined with increasing temperatures and decreasing soil moisture 

availability is greatly increasing the threat of loss due to mortality from insect attack, diseases, 

competition, or fire.

The wetter than normal 20th Century coupled with the exclusion of fire has set the stage for stands 

to become overcrowded with competing conifers, oaks and other vegetation. Wide swings in 

weather conditions over the past 30 years have placed stress on many of these stands. Inter-tree 

competition, drought, rising temperatures, and insect attacks are beginning to take a toll on both 

plantation and wild stand trees. White pine blister rust has also been killing a number of sugar 

pine over the past 10 to 15 years. Dead and down fuel loadings have been on the rise. These 

conditions are not unique to the Sugar Pine area. More extreme examples can be found in the 

Lake Tahoe Basin, San Bernardino National Forest and in Arizona and New Mexico where entire 

stands of trees are dieing. In southern California the amount of ponderosa pine mortality 

associated with western pine beetle, D. brevicomis Le Conte, infestations reached unprecedented 

levels after years of extended drought (Fettig 2007).

Recurrent droughts are characteristic of the Sierra Nevada climate. Summers are usually hot and 

dry, with the bulk of the precipitation occurring in winter, much of it as snow. But in addition to 

the dry summers, there have been droughts of 1 or more years in duration in every decade of this 

century. Increased mortality usually occurs first at the lower and middle elevations on both 

western and eastern slopes of the range and spreads to the upper elevations only if the drought is 

protracted. During droughts, lack of spring precipitation has a particularly large influence, not 

only by increasing the susceptibility of the trees, as indicated by their rates of growth and beetlecaused mortality, but also probably aiding dispersal of and host selection by the flying beetles. In 

the ponderosa pine type because of the relatively low elevation, water availability, not 

temperature, is the strongest factor limiting forest growth (Ferrell 1996).

As stated previously, beginning in the 1970s temperatures began to warm noticeably. Seasonal 

snowmelt and streamflow is projected to occur a month earlier during the current century. By the 

end of the 21st Century, 30 percent less water is anticipated to arrive in reservoirs between April 

and July. Soil moistures will dry out earlier and by summer be more severely depleted. 

Substantial changes in extreme temperature episodes (fewer frosts, more heat waves) are 

anticipated (Dettinger 2004). Over the past 17 to 29 years noncatastrophic mortality rates were 

found to have doubled over a series of 76 western forest plots. Increasing mortality rates could 

result in substantial changes in forest structure, composition, and function. This doubling of 

background mortality could cause a >50% reduction in average tree age in a forest, and a 

potential reduction in average tree size (van Mantgem 2009). Current projections of warming 

climates provide a greater opportunity for fire ignitions due to longer fire seasons. A higher 

probability of fire starts coupled with the changes in forest fuel conditions that occurred over the 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 135

past century lead many to predict that large, generally more intense fires will become more likely 

than occurred historically (Skinner and Stephens 2004). 

Desired Condition 

The Sierra Nevada Forest Plan Amendment Record of Decision, 2004 (USDA-FS 2004b) 

addressed the desired condition, management intent and management objectives for individual 

land allocations. These were brought forward in the Fresno River Landscape Analysis (USDA-FS 

2005). 

The Sugar Pine Adaptive Management Project boundary encompasses many different land 

allocations, some with specific desired conditions, i.e. spotted owl/goshawk/pacific fisher habitat 

and some with generalized desired conditions. In effect, all center on the need to restore both the 

structure and processes of old forest habitat ecosystems as a long-term strategy and with shortterm goals of reducing the adverse effect of wildfire and reducing stand susceptibility to 

insects/pathogens, competition and drought-related tree mortality.

Density Management Measures

Basal Area Stocking Levels

Normal basal area stocking is considered to be that level at which mortality begins as additional 

growth takes place. Normal is generally described as basal area per acre and is the maximum 

amount of vegetation an acre can be adequately sustain over time. For a short period of time, 

basal areas in excess of normal can be maintained in some areas. A normal stand—or fully 

stocked stand—is a stand that, so far as any practical consideration is involved, utilizes its site 

completely. Maximum stocking is not implied; it practically never exists over a continuous area 

of more than a few acres (Meyer 1938). These normal stocking levels were calculated during the 

abnormally wet 20th Century and are most likely too dense to be maintained during the drier 

periods that are more likely the norm. Fairly recent studies have indicated that the exclusion of 

fire may have also resulted in normal basal area densities in excess of what would have been 

found during previous centuries. 

Four different yield tables are being used to determine normal stocking within the project area:

 Yield of Even-aged Stands of Ponderosa Pine, Technical Bulletin No 630 (Meyer 1938). 

 Preliminary Yield Table for Second-growth Stands in the California Pine Region, 

Technical Bulletin 354, Mixed Conifer (Dunning and Reineke 1933). 

 Yield, Stand, and Volume Tables for White Fir in the California Pine Region, Bulletin 

407 (Schumacher 1926).

 Growth Models for Ponderosa Pine: I. Yield of unthinned plantations in northern 

California, Research Paper, PSW-133 (Oliver and Powers 1978).

As stands approach 80 to 90 percent of normal stocking, growth rates begin to decline 

significantly, stand vigor begins to suffer, and susceptibility to insect and disease attacks and 

drought stress increases. To reduce growth losses, maintain more viable stands, and retain canopy 

covers less susceptible to crown fires, this entry would thin stands to stocking levels that with 

growth will result in reaching 80 percent of normal in 15 to 20 years when the next thinning entry 

would need to take place. Utilizing basal area to describe desired stocking automatically takes 

into account varying diameters of trees within stands. For a given basal area, more trees per acre 

are retained in the residual stand in areas with smaller diameter trees than in areas of larger trees. 
Chapter 3: Affected Environment and Environmental Consequences

136 Sierra National Forest

The silvicultural prescriptions for ponderosa pine, mixed conifer and fir will be described 

utilizing basal area per acre. 

The desired condition for stocking levels and the measure used for comparison of alternatives is:

 Average basal area in pine, mixed conifer, and white fir grouped by lightly and heavily 

stocked aggregations

 Average potential basal area growth

 Basal area following thinning - ponderosa pine - 135 ft2per acre (50% normal)

 Basal area following thinning - mixed conifer - 210 ft2per acre (60% normal)

 Basal area following thinning - white fir - 240 ft2per acre (60% normal)

Stand Density 

Another approach to stocking density management is Stand Density Index (SDI). This method 

compares stocking density to the maximum number of stems found by species which is 

substantially greater than that utilized for normal yield. Mortality studies completed in pine stands 

have been described using this density management approach rather than normal yield tables. 

Since SDI was used as a frame of reference for ponderosa pine in these studies, it will be used as 

well as basal area to describe the silvicultural prescriptions for pine stands. SDI studies have 

determined that the onset of competition between trees begins when stands reach 25 percent of 

SDI max. At 35 percent of SDI max the lower limit of full site occupancy and susceptibility to 

bark beetle attack begins, and at 60 percent SDI max is where the lower limit of self-thinning

begins (normal stocking). Stands that approach SDI 365 usually suffer large losses from bark 

beetle epidemics—losses that equal or exceed periodic growth. The limiting SDI for ponderosa 

pine stands in northern California as defined by Dendroctonus bark beetles is 365 (45 percent of 

SDI max—approximately 200 ft2 basal area). Studies have shown that the vigor of trees in a stand 

is related to their ability to quickly respond to thinning and their susceptibility to various pests. A 

live crown ratio of at least 40 percent has been cited for a number of conifers as representing a 

generally acceptable level of individual tree vigor. For several coniferous species, a live crown 

ratio of 40 percent seems to correspond with an SDI of about 50 percent of the maximum SDI for 

the species. Catastrophic (extremely high) tree mortality from bark beetles can be prevented by 

reducing stand density below 150 ft2per acre in basal area (33 percent of SDI max) (Long 1985). 

To ensure prompt response to thinning and minimize mortality, pine stands should be maintained 

between 30 and high of 50 percent of SDI max.

For this proposed project, forested stands would meet stocking (as measured by percent of normal

for the given site) and the associated density levels (as measured by basal area for a given site) 

that would maintain or improve growth rates, would increase resistance to mortality agents 

(insects/pathogens/fire) and would provide the potential to begin the perpetuation of both the 

structure and processes of old forest habitat ecosystems. This desired condition incorporates both 

short and long-term goals, but is focused on the need for continued maintenance of stands that are 

healthy and sustainable.

The desired condition for Stand Density Index and the measure used for comparison of 

alternatives is:

 SDI - ponderosa pine 30 percent of SDI max (135 ft2per acre) 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 137

Methodology for Analysis

In determining the existing condition and analyzing the effects of the alternatives associated with 

the Sugar Pine Adaptive Management Project, many sources of information were utilized. These 

included aerial photography interpretation, field verification of stand conditions, cruise plot data 

validation, evaluation and summarization, California Wildlife Habitat Relationship site-specific 

vegetation type correction and verification, and experience in the implementation of similarly 

designed past projects. Scientific and research documentation was utilized to evaluate the 

potential effects of all alternatives and in determining the measures to be evaluated for meeting 

the purpose and need with regards to forest health.

The SNFPA ROD (USDA-FS 2004b) describes the use of thinning from below as the primary 

silvicultural prescription to utilize in managing stand densities to provide resiliency and 

sustainability during drought conditions and climate variations. Stand density index and basal 

area (ft2per acre) are used as common measures in determining the effects of management 

actions on coniferous stands. For retention of maximum growth and vigor, thinning entries should 

be timed to occur before growth rates in potential leave trees begin to slow. At this point, leave 

trees are still retaining substantial crown ratios and have the greatest potential for maximum 

growth. Thinning should be undertaken before crown ratios drop below 40 percent (Emmingham

1983) (Long 1985). As competition between trees increases, crown vigor decreases. A stand‘s 

ability to respond to thinning progressively declines the longer it remains in competition. Some 

stands proposed for treatment are currently at this maximum potential response level while others 

are beginning to decline and should have already been treated. 

For this project stand density (number of stems per acre) as well as basal area (ft2per acre) is used 

to determine which stands/aggregations are considered overcrowded and in need of thinning

(treatment area designation), at what stocking level the stand/aggregation needs to be (desired 

condition), the silvicultural prescription for each alternative and the associated short (immediate) 

and long-term (length of effectiveness of treatment) effects of design criteria (specifically those 

associated with old forest habitat dependent species), and the effects the standards and guidelines 

and land allocations have on meeting the purpose and need for forest health.

Alternative 1 – No Action

Direct Effects

With this alternative, no commercial, biomass or pre-commercial thinning would be 

accomplished. Understory incense cedar, white fir and brush cover would continue to increase in 

size and density. Fuel ladders and competition between trees would increase. Growth rates and 

vigor would continue to decline as stands, or portions of stands, continue to approach or exceed 

normal stocking. Understocked plantations would not be replanted. 

Indirect and Cumulative Effects

Wide swings in weather conditions as have been experienced over the past thirty years would 

continue to place increased stress on these untreated stands. Trees in overstocked and/or brush 

choked plantations would continue to experience increased competition. Mixed conifer and fir 

aggregations and stands with stocking levels approaching or exceeding normal would become 

increasingly susceptible to mortality. Excessive stand/aggregation densities in ponderosa pine 

stands would result in the likelihood of heavy mortality. Drought and insect induced mortality 

would escalate. Insect infestation centers would likely move onto private property and 

organizational camps. Snags and jack-strawed down material would increase. Basal area tree 
Chapter 3: Affected Environment and Environmental Consequences

138 Sierra National Forest

growth of only 15 to 20 ft2 per acre would occur over a 15 to 20 year period (if excessive 

mortality does not occur) in more densely stocked aggregations. Forest health in the area would 

decline and elevate the risk of loss due to wildfire. Not only would the potential for loss of these

stands to insect attack and drought increase, but their ability to respond to future thinning would 

continue to decline as crown vigor deteriorated as treatment was postponed. Experience has 

shown that even a course of no action is not without consequence (Fettig 2007). Doing nothing 

will result in forests that continue to deteriorate over time because wildfire today no longer 

operates in its historical fashion, that of frequent low-intensity surface fires (Fitzgerald 2005). 

Fuel continuity would not be broken up. Brushfields and over stocked precommercial size conifer

pockets would not be treated. The threat of fire moving into or out of population centers within 

the Wildland Urban Intermix (WUI) would increase, not decrease. Nelder Grove would remain 

highly susceptible to significant damage from fire. The threat of loss of wildlife habitat 

designated as Protected Activity Centers (PACs), Home Range Core Areas (HRCAs) and fisher 

den site buffers would increase. Agee (2005) concludes in his report that the No Action

Alternative is not a risk-free option, as dry climates regularly predispose forests to burn in a 

typical dry summer. He further states that the impacts of no action in dry forest ecosystems must 

recognize the likelihood of stand-replacing, intense fire where stand density has increased and 

dead fuel accumulated in excess of historical levels. 

Alternative 2 – Proposed Action

Direct Effects

Commercial thinning needs to be undertaken in the approximately 90 to 110 year old stands and 

pine plantations to reduce competition and provide room for crown expansion by removing the 

more poorly growing trees, excess trees, and fuel ladders from these stands before competition 

results in much additional reduction in growth, or competition, insect, disease or fire related 

mortality increases. 

Studies have shown that active management through thinning is critical to maintaining healthy 

trees that are less susceptible to mountain pine beetle attack. In particular, a 1998 study assessed 

the effects of thinning from below (alone and in combination with prescribed burning) on tree 

growth, leaf physiology and several environmental factors in ponderosa pine on the Gus Pearson 

Natural Area in Arizona (Fettig 2007). Soil water content was greater in thinned treatments than 

in the unthinned control. Similar findings have been reported in northern Arizona and western 

Montana, and can be attributed to increased water availability resulting from decreased tree 

competition (Fettig 2007). Trees in thinned treatments had greater foliar nitrogen content, needle 

toughness and basal area increment (Fettig 2007). The results suggest that restoration treatments 

improved tree vigor, growth and decreased the likelihood of bark beetle attacks on individual 

trees (Fettig 2007). A similar study compared measures of tree susceptibility to bark beetle attack 

in thinned ponderosa pine plots in northern Arizona (Fettig 2007). Phloem thickness significantly 

increased with decreasing stand density (Fettig 2007). Duration of resin flow and 24 hr resin flow 

were significantly higher in thinned plots (Fettig 2007). Increases in these variables suggest 

improved host vigor and reduced likelihood of bark beetle attack (Fettig 2007). An increase in 

predawn xylem water potential, net photosynthetic rate, foliar nitrogen concentration and bud and 

needle size resulting in increasing foliar growth and uptake of water and nutrients was reported in 

similar stands (Fettig 2007). It has been noted that phloem thickness and basal area increment 

were lower in unmanaged stands than in managed (Fettig 2007). Studies have shown that thinning 

significantly reduced the amount of ponderosa pine mortality caused by mountain pine beetle in 

northeastern California (Fettig 2007). The largest increase in photosynthetic rate and predawn 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 139

water potential increases due to thinning was found to be during periods of drought (Feeney

1998). Several studies have shown that thinning from below not only reduces ladder fuels and the 

risk of torching, but by reducing stand density tree vigor is improved and risk to bark beetle 

attack reduced (Fitzgerald 2005). By reducing competition through thinning, mistletoe infected 

residual trees will experience increased height growth thus slowing the upwards spread of 

mistletoe into tree crowns (Ferrell 1996). By increasing tree vigor, diseased trees will be better 

able to withstand the effects of drought or insect attack. 

This entry would commercially or biomass thin stands on slopes generally less than 35% outside 

of PACs, and Old Forest Linkages to stocking levels that, with current growth, would result in 

returning stands to 80 percent of normal basal area stocking 15 to 20 years following harvesting

(Table 49 in Appendix C) displays a sampled data comparison of existing to proposed action 

conditions for species composition, age, site, numbers and sizes of trees, basal area, crown 

closure, mean diameters and number of plots taken). Maintaining a stocking level that remains at 

80 percent or less of full (normal) stocking will ensure a healthy rate of growth while retaining a 

level of stocking that will be better able to survive the lower levels of yearly precipitation that 

were common prior to the past century. Black oaks will be retained in treated stands longer by 

reducing competition and overtopping by nearby conifers. Treated stands would also be less 

susceptible to climatic fluctuations and longer summer dry spells which appears to be becoming 

more and more prevalent. Reentry in 15 to 20 years was chosen for several reasons: (1) reduce 

the number of entries into the stand, (2) increase the volume removed to make the entry more 

economically viable, (3) open the stand sufficiently to permit harvest operations with a minimum 

of damage to the residual stand, (4) treat the stand to a level where for a period of at least 10 

years, fires except under the most extreme conditions, would remain as ground fires and not 

become crown fires as directed by the National Fire Plan, (5) retain canopy covers that meet or 

exceed those directed under the SNFPA ROD (USDA-FS 2004b) while opening the canopy to 

maintain or improve growth and vigor over 15 to 20 years.

To obtain some benefits from thinning, while retaining species specific canopy cover levels 

following harvest, thinning in wild pine stands is proposed to generally reduce stocking to leave 

basal areas of around 150 to180 ft2per acre depending on age, site, and existing crown condition 

(55 to 60 percent of normal—32 to 40 percent SDI max). This entry will still result in the 

retention of basal areas substantially above the stand density index recommends for thinning (150 

ft2should be in locations where leave trees have full crowns and 180 ft2per acre should be in 

areas with poorer crown leave trees, higher growing sites, older trees and in HRCAs). Normal 

stocking for this site and age is 270 to 290 ft2per acre. Portions of stands with larger diameter 

trees present will generally have fewer residual trees per acre than those with smaller diameter 

trees. Because this entry would retain a higher basal area than the desired condition, to maintain 

stand resiliency, the next thinning entry may need to take place at 10 to 15 years in these pine 

stands rather than the planned 15 to 20 as the more limited growing space becomes reoccupied. 

Where diameter restrictions permit, mixed conifer and white fir stands would be thinned to 55 to 

65 percent of normal. Leave basal areas, depending on site index and age, would be around 210 

ft2per acre (Mixed Conifer) and 240 ft2(White Fir). (Normal basal area stocking for mixed 

conifer stands on similar sites ranges from 330 to 360 ft2per acre. Normal for White Fir ranges 

from 420 to 445 ft2per acre). Canopy covers that meet or exceed those directed under the SNFPA 

ROD (USDA-FS 2004b) would be retained following treatment. To obtain maximum growth and 

reduce fuel ladders, 4 to 9 inch dbh trees not needed for stocking are planned to be removed with 

this entry within the treatment areas not designated as mastication or prescribed fire. Portions of a 

number of units include short, steep pitches to 50 percent. These can be harvested by directional 
Chapter 3: Affected Environment and Environmental Consequences

140 Sierra National Forest

felling and endlining logs to more gentle slopes where they can be skidded to landings. Except for 

mastication equipment, equipment use on these steeper slopes should be avoided.

Thinning to these target basal areas in these stands should result in basal area increases of 70 to 

80 ft2per acre over 15 to 20 years. If thinning did not occur, this increase in growth over the same 

time period would be 15 to 20 ft2per acre within the more heavily stocked aggregations if 

mortality does not occur. 

Except where retained for wildlife purposes and based on the trees canopy position, suppressed, 

intermediate, damaged and diseased then finally co-dominant trees, in order of removal, would be 

harvested until the prescribed stocking level has been reached. This is known as thinning from 

below as directed in the SNFPA ROD (USDA-FS 2004b) and recommended in the North et. al.

2009 paper. The poorest quality trees are removed first, leaving the best trees in the stand. 

Thinning from below retains the majority of the crown cover and generally the largest trees. 

Many small, poor crowned trees are removed during the operation. Some poorer crowned codominant trees are removed, as needed, to create openings on one or more sides of other codominant and dominant trees. These openings provide room for crown expansion of the residual 

trees. Without room for expansion, remaining tree crowns will become less vigorous resulting in 

reduced photosynthesis and declining growth. Removal of only trees considered as intermediate 

and suppressed when considering their crown position results in ―little more than the salvage of 

trees which will inevitably die‖ (Smith 1962). Removal of some of the trees that compete for the 

limited water and soil nutrients will make more water and nutrients available for the remaining 

trees. Thinning also opens the stand‘s crown canopy, making more light available for the 

remaining trees. The increased water, nutrients, and light that result from thinning increase 

photosynthesis in the remaining trees. More food is produced making more carbohydrate 

available for new cell formation and growth. After competition begins and the stand develops all 

crown classes, removing only intermediate and suppressed trees may not significantly reduce the 

competition faced by the larger dominant and co-dominant trees. Suppressed trees, in particular 

do not compete significantly with larger trees. Intolerant species (pines) require nearly full 

sunlight to thrive and grow. A successful low thinning removes all suppressed, most 

intermediates, many co-dominants, and even some dominant trees (Emmingham 1983).

The effects of fuel treatments on tree based carbon storage are currently being studied. Healthy 

forests play an important role in carbon sequesterization. Studies indicate that ―in wildfire-prone 

forests, tree-based C stocks were best protected by fuel treatments that produced a low-density 

stand structure dominated by large fire resistant pines (Hurteau 2009). Average stand diameters 

increase significantly following thinning as smaller diameter trees are removed in favor of 

retaining larger trees. Concentrating removal on the smaller diameter trees also reduces fuel 

ladders and susceptibility to fire loss as average residual diameters and fire resistance increases. 

Biomass and follow-up treatments to remove submerchantable trees and brush will further reduce 

stress on the remaining stand. Where choices exist, more fire resistant pines would be favored 

over fir and incense cedar as leave trees. In most areas, stand composition following treatment 

will consist of a greater percentage of more fire and drought resistant ponderosa and sugar pine as 

recommended in the North et.al. paper (2009). Although current stand composition averages 

about 40 percent pine and sugar pine, 39 percent incense cedar, 15 percent white fir, and 6 

percent oaks, it is estimated that 75 percent of the trees to be removed will be incense cedar, 10 

percent will be white fir and 15 percent will be ponderosa and sugar pine. Thirty (30) inch harvest 

tree diameter limitations dictated by the SNFPA ROD (USDA-FS2004b) will, in many areas, 

result in basal area retention levels in excess of proposed residual basal areas. In some cases in 

pockets of larger trees, no trees will be harvested. In these types of thinnings, the smaller size of 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 141

the product to be removed makes harvest operations much more expensive than those where

larger trees are removed.

Thinning to the proposed basal areas will result in increased diameter growth and crown 

expansion on the remaining trees as the residual trees respond to reduced competition. Since 

increased diameter growth will occur over fewer stems per acre, substantial increases in diameter 

will result. Repeated thinning will result in larger diameter, taller, healthier crowned trees over 

much shorter time frames than in unthinned stands. Shade intolerant pines and oaks will be 

retained in a more vigorous condition as a result of more available sunlight due to reduced 

competition. As the diameters of the residual trees become larger, they will become better able to 

survive a fire should one occur. Thinning is an effective technique for creating stands that more 

closely represent those present prior to railroad and other extensive logging and the exclusion of 

fires during the 20th Century.

Biomass, hand and mastication thinning and release of natural stands/aggregations of conifers and 

plantation trees generally less than 10 inches dbh would be undertaken as part of this proposal. 

These thinned aggregations would occupy large and small openings surrounded by larger trees as 

described in North, et.al. (2009). Depending on tree size these stands would be thinned to around 

150 to 200 leave trees per acre. Hand thinning slash concentrations would generally be tractor 

piled and piles burned. Slash concentrations on steeper slopes would generally be hand piled and 

burned. Areas of only light slash (10 to 20 tons per acre) would be lop and scattered to 18 inches. 

Stand heterogeneity would be maintained through retention of these precommercially thinned 

clumps as well as untreated clumps on steeper slopes, the more dense clumps of larger diameter 

trees, SMZs, archaeological sites, and the two to three untreated larger oaks per acre.

Some underburning is proposed as a fuels reduction and understory management treatment within 

the proposed project boundaries. Underburning should only be done in portions of those stands 

with larger, more fire resistant residual trees and fairly light slash concentrations. Where scattered 

heavy slash concentrations are present, some piling of slash may need to be done prior to 

underburning. Due to the location of much of the proposed underburning, it is anticipated that late 

fall and early winter (after wetting rains) as well as early spring underburning may be possible. 

Late spring burning should not be attempted due to the high susceptibility of new growth to heat 

damage. In most cases, areas that have been masticated should not be underburned. Brush seed 

requires heat scarification to germinate; underburning will only help germinate brush seed present 

in the soil. Since white leaf manzanita is a non-sprouting species, in those areas where large white 

leaf manzanita has been masticated below the lowest live limb, reestablishment of manzanita 

brushfields would mostly occur through germination of manzanita seed. The masticated mulch 

layer covering the ground will reduce soil temperatures which will assist in keeping brush seed 

dormant and reduce the likelihood of brushfield reestablishment. The fuels officer and 

silviculturist should field coordinate all areas to be underburned prior to undertaking 

underburning.

Indirect and Cumulative Effects

Within HRCAs (Home Range Core Areas) and Old Forest Linkages the aim as stated in the 

SNFPA ROD (USDA-FS 2004b) is to retain 60 percent or greater canopy cover, where available. 

(The intent of the Sugar Pine project is to retain canopy cover of 60 percent or greater in CWHR 

4 and 5 size classes where it presently exists.) Within those portions of Spotted Owl and 

Goshawk PACs (Protected Activity Centers) where thinning is proposed, the aim is to retain 70 

percent or greater canopy cover, where available. 
Chapter 3: Affected Environment and Environmental Consequences

142 Sierra National Forest

In addition to the denser canopy cover proposed for PACs and Old Forest Linkages, groups or 

patches of five or more larger trees, generally 30 inches and larger, are planned to be retained 

through the project area. These small groups will have residual basal areas of 240 ft2or more for 

mixed conifer and 210 ft2or more for pine and in many instances may reach 300 to 400 ft2per 

acre. Approximately 2 to 3 black oaks 20 inches dbh and larger per acre would also have a 35 

foot buffer, measured from the bole, around them where no fuels treatment would occur.

Retention of these higher basal areas to provide a denser canopy cover will result in not fully 

meeting the silvicultural objectives for maintaining or improving forest health. The impact will 

not be as great in mixed conifer and fir stands as it will be in pine. Retaining 60 percent or greater 

basal area in pine stands leaves them at a level where stand density index studies have shown 

them to be susceptible to insect attack. Pine stands left at 70 percent or greater will remain at SDI 

max levels of 50 percent or greater (SDI 400 or more) and will be highly susceptible to insect 

attack. Oliver 1995, stated that a SDI 365 (200 ft2per acre), defines the threshold for a zone of 

imminent bark beetle mortality where pine stands suffer large losses from bark beetle epidemics. 

These losses can equal or exceed periodic growth. Subsequent growth of these stands will add 

further to the problem. Sufficient thinning will occur in some of the proposed scattered clumps to 

provide a short term benefit to stand vigor while in other clumps little, if any, thinning will occur 

resulting in a continued decline in clump vigor. Pine clumps left at these higher basal area 

retention levels will continue to be at a very high risk of loss due to insect, disease, competition, 

and/or drought induced mortality. A 2004 report found that plots infested by mountain pine beetle 

had significantly higher total basal area, ponderosa pine basal area, stem density and stand density 

index (Fettig 2007). Heavily stocked pine clumps attacked by insects have the potential to serve 

as infection centers for increased mortality in the surrounding pine stands as insect populations 

build and move into adjacent stands. To maintain more vigorous, drought and insect resistant 

stands, a shorter reentry period will be needed. The reentry time frame within HRCA, PAC, and 

Old Forest Linkage pine stands and these more heavily stocked clumps will likely be reduced by 

5 or more years. 

Since the vast majority of the crown covers and ground cover will remain in place following 

thinning operations, properly conducted thinning has only a minor short term affect on the 

environment. Leave trees will continue to contribute needles as well as small branches to the 

forest floor. Little soil movement and little, if any, increased runoff should occur as a result of 

this entry. Standard Streamside Management Zones will be maintained with any thinned trees 

being endlined out of the SMZs. Therefore, stream course stability will not be adversely affected. 

Long term affects will be to maintain or increase growth and vigor of treated stands, accelerate 

development of old forest characteristics in plantations, and improve the protection of human 

communities from wildland fires as well as minimize the spread of fires that might originate in 

urban areas, and reduce the threat of wildfire burning into and significantly damaging Nelder 

Grove. Over the past fourteen years, the district has planned and completed several projects, 

treating several thousand acres, similar to the proposed action. Canopy cover retention following 

harvest has met or exceeded expectations. Residual crowns have rapidly filled in openings created 

by harvest treatments.

In addition to the benefits obtained through density management several other benefits have been 

noted in treated stands. Several studies have shown that in addition to increasing residual tree 

vigor, increasing temperatures and windspeed are common in recently thinned stands. This may 

accelerate development of certain bark beetle species and force them to overwinter in stages that 

are more susceptible to freezing or cause turbulences that disrupt pheromone plumes used for 

recruiting conspecifics during initial phases of host tree colonization (Fettig 2008). Moderate 

thinning may result in less potential extreme fire behavior compared to unmanaged stands. 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 143

Greater fuel depths, mid–flame wind speeds and lower fuel moistures in heavily treated stands 

(>60 percent basal area reduction) might increase potential fire behavior compared to unmanaged 

stands. Thinning followed by sufficient treatment of surface fuels usually outweighs changes in 

fire weather factors (wind speed and fuel moisture) resulting in an overall reduction in expected 

fire behavior (Jenkins, et al 2008). Thinning followed by tractor piling and burning or whole tree 

yarding have been shown to be effective in reducing fire intensity and severity under severe fire 

weather conditions. Thinning from below where the largest trees are retained within the stand 

contributed to increased fire resistance (Stephens 2009). Thinning makes fire suppression more 

efficient. Once heavy fuels are removed, the residence time (duration) of the fire is reduced, often 

resulting in a non-lethal surface fire (Fitzgerald 2005). The thinning proposed within the Sugar 

Pine project is designed to reduce existing basal area by generally 30 percent or less. Biomass and 

post sale treatments are designed to remove fuel ladders as well as slash concentrations. This 

relatively light level of thinning should both realize the benefits of thinning stands to reduce the 

adverse effect of bark beetles while reducing expected potential fire behavior.

Alternative 3

This alternative is the same as Alternative 2 except within the designated 2008 F01 Fisher densite

buffer only surface and ladder fuels would be removed.

Direct Effects

Except for the designated F01 Fisher densite buffer, the effects of thinning will be the same as 

described under Alternative 2. Within the designated 2008 F01 Fisher densite buffer very little to 

no density management will occur. Fuel ladder removal will be concentrated on suppressed and 

some intermediates. Few, if any, co-dominant trees would be removed. Table 50, Appendix C

displays a sampled data comparison of existing to Alternative 3 conditions for treatment areas

predominantly in the designated 2008 F01 Fisher densite buffer. Except for some intermediate 

trees greater than 10 inches dbh with green crowns growing to within 10 feet of the ground, few 

trees greater than 10 inches dbh would be removed. It is estimated that within this buffer area 

only about 74 trees per acre would be removed instead of the proposed 159. One-hundred and 

forty-two (142) trees would remain instead of 57. A large percentage of these additional trees 

would be fire prone incense cedar. The average stand diameter within the buffer would increase 

only slightly. Of the existing 320 ft2of basal area sampled, 310 ft2 would remain in the stand 

following treatment. This compares to 190 ft2that would be remaining under Alternative 2 (The 

prescribed leave basal area for this pine stand is 150 to 180 ft2per acre—normal stocking is 270 

to 290 ft2per acre). 

As stated previously, Smith (1962) stated that removal of only trees considered as intermediate 

and suppressed when considering their crown position results in ―little more than the salvage of 

trees which will inevitably die‖. Emmingham (1983) stated that a successful thinning from below 

requires the removal of many codominants as well as most intermediates and suppressed trees. 

Fuel ladder removal alone would not remove sufficient competition to meet density management 

objectives. Failure to remove some of the co-dominants and intermediates growing into the 

bottom portion of the co-dominant layer of the stand will not create openings in the canopy to 

provide room for crown expansion of the residual trees. Shade intolerant oaks and pines will not 

be able to benefit from increased light and rates of photosynthesis provided by openings created 

in the canopy cover. 
Chapter 3: Affected Environment and Environmental Consequences

144 Sierra National Forest

Indirect and Cumulative Effects

Except for the designated 2008 F01 Fisher densite buffer, the indirect and cumulative effects of 

thinning will be the same as described under Alternative 2. The indirect and cumulative effects 

for density management (Forest health) for the designated 2008 F01 Fisher densite buffer will be 

the same as in the No Action Alternative. Post treatment stocking levels within the buffer would 

be too dense to withstand the stresses of drought and climatic variances.

Alternative 4

This alternative proposes treatments to meet the fire/fuels objective with no additional treatments 

designed to meet the forest health objectives.

Direct Effects

Very little to no density management would be accomplished with this alternative. Fuel ladder 

removal would be concentrated on suppressed and some intermediates. Few, if any, co-dominant 

trees would be removed. (Table 51 in Appendix C displays a sampled data comparison of existing 

to Alternative 4 conditions). Except for some intermediate trees greater than 10 inches dbh with 

green crowns growing to within 10 feet of the ground, few trees greater than 10 inches dbh would 

be removed. Ninety (90) to 100 percent of the existing basal area 5 inches dbh and larger would 

remain. Two to three times as many trees 5 inches dbh and larger would remain compared to 

Alternative 2. The percentage of fire prone incense cedar and fir would remain close to existing. 

The average stand diameter would increase only slightly. Shade intolerant pine and oaks would 

become less vigorous and continue to drop out of the stands. Post treatment stocking levels would 

be too dense to withstand the stresses of drought and climatic variances.

As stated previously, Smith (1962) stated that removal of only trees considered as intermediate 

and suppressed when considering their crown position results in ―little more than the salvage of 

trees which will inevitably die‖. Emmingham (1983) stated that a successful thinning from below 

requires the removal of many co-dominants as well as most intermediates and suppressed trees. 

Fuel ladder removal alone does not remove sufficient competition to meet density management 

objectives. Failure to remove some of the co-dominants and intermediates growing into the 

bottom portion of the co-dominant layer of the stand will not create openings in the canopy to 

provide room for crown expansion of the residual trees. Shade intolerant oaks and pines will not 

be able to benefit from increased light and rates of photosynthesis provided by openings created 

in the canopy cover. This alternative does not meet the purpose and need for density management 

emphasized in the SNFPA ROD (USDA-FS 2004b) and being examined as a part of this project. 

Indirect and Cumulative Effects

The indirect and cumulative effects for density management (Forest health) for this alternative 

will be the same as in the No Action Alternative. Post treatment stocking levels within the buffer 

would be too dense to withstand the stresses of drought and climatic variances.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 145

Fire/Fuels __________________________________

The direct, indirect and cumulative effects to wildland fire and fuels are summarized from the 

Fire/Fuels Report for the Sugar Pine Adaptive Management Project (Stalter, B. 2008).

Introduction 

Presettlement fire strongly influenced the structure, composition and dynamics of most Sierra 

Nevada ecosystems. Many species and most communities show clear evidence of adaptation to 

recurrent fire, further demonstrating that fire has long been a regular and frequent occurrence. 

This is particularly true in the chaparral and mixed conifer communities, where many plant 

species take advantage of or depend on fire for their reproduction or as a means of competing 

with other biota. In many areas frequent surface fires are thought to have minimized fuel 

accumulation, keeping understories relatively free of trees and other vegetation that could form 

fuel ladders to carry fire into the main canopy (USDA-FS 1996).

Forest structure and species composition in many western U.S. coniferous forests have been 

altered through fire exclusion, past and on-going harvesting practices, and livestock grazing. The 

effects of these activities have been most pronounced in seasonally dry, low and mid-elevation, 

coniferous forests that once experienced frequent, low to moderate intensity fire regimes. 

Increased stand density, decreased overall tree size, and increased surface fuel loads are well 

documented for many forests of this type (Stephens, S. et al. 2009). Conifer stands generally have 

become denser, mainly in small and medium size classes of shade-tolerant and fire-sensitive tree 

species (USDA-FS 1996). These changes concern fire managers because the increased fuel loads 

and altered forest structure have made forest vulnerable to fire intensities and severities outside of 

the desired conditions and outside of historic fire regimes for these ecosystems. Changing 

climates in the next several decades may further complicate fire management by increasing 

temperatures and fire season length (Stephens, S. et. al. 2009). Fires now occur less frequently 

and cover much less area, but are likely to be large and severe when they do occur (USDA-FS 

1996).

Fire represents both one of the greatest threats and one of the strongest allies in efforts to protect 

and sustain human and natural resources in the Sierra Nevada. Residents and visitors alike are 

well aware of the threats posed by summer wildfires. A growing density of homes and other 

structures coupled with the increased amount and continuity of fuels resulting from twentiethcentury fire suppression have heightened concern about threats to life and property, as well as the 

health and long-term sustainability of forests, watersheds, and other natural resources. Yet fire 

has been an integral part of the Sierra Nevada for millennia, influencing the characteristics of 

ecosystems and landscapes. Today, State, Federal and local agencies put enormous resources into 

efforts to reduce fire occurrence while at the same time advocating the need to use fire to promote 

healthy ecosystems. The challenge faced is how to restore some aspects of a more natural fire 

regime while at the same time minimizing the threat wildfire poses to human and natural 

resources and values (USDA-FS 1996). 

Affected Environment

The Sugar Pine Adaptive Management Project area encompasses five distinctive vegetation 

complexes. These include: (1) conifer plantations, (2) 90 to 110 year old mixed conifer stands, (3) 

mixed chaparral stands, (4) white and red fir conifer stands and/or (5) a combination of these. 
Chapter 3: Affected Environment and Environmental Consequences

146 Sierra National Forest

These vegetative complexes are results of various processes including wildland fires, effective 

fire suppression efforts, turn of the century timber harvesting and reforestation efforts. 

Fire History

This area has a history of large fire occurrence. On September 10, 1922 a fire starting in the area 

of Sugar Pine occurred when the Madera Sugar Pine Lumber Company sawmill caught on fire 

and burned towards the Westfall area. By the time containment was reached, a total of 540 acres 

had been consumed. In 1924, three fires burned around the Sugar Pine Community. One fire 

burned just south of present day Westfall Fire Station below Highway 41, this fire was 

approximately 160 acres in size. To the north and west of Sugar Pine a fire originating in the 

vicinity of Happy Camp along Highway 41 burned up to the private property of the Yosemite 

Mountain Ranch. This fire was contained at 800 acres. To the east of Sugar Pine along road 5S18 

(Dillon Orchard Road) a fire burned 106 acres before being contained. 

Tables 29, 30, and 31 show the Fire History Records (fires >100 Acres) within and outside of the 

Sugar Pine Adaptive Management Project area (henceforth known as the Sugar Pine Project). 

Map 11 in the Map Package shows the approximate perimeters of these fires and their proximity 

to the community of Sugar Pine and the project area.

Table 29. Fire History within the Project Boundary

Year Size/Acres General Location

1922 540 Into Sugar Pine Community

1924 800 North West of community/In Yosemite Mtn. Ranch

1924 160 West of Community

1926 106 East of Community

Table 30. Fire History Outside of the Project Boundary (Generally South of Sugar Pine)

Year Size

1917 139

1920 99

1930 701

1934 304

1942 359
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 147

Table 31. Fire History within a 4-mile radius of Sugar Pine

Year Size

1911 162

1917 2,236

1917 1,159

1924 10,310

1928 21,194

1934 304

1942 359

1958 803

1957 647

1959 11,076

1961 43,330

Logging

Heavy railroad logging entries (1900 through 1931) in the Sugar Pine and Nelder Grove area 

coupled with fire exclusion since the 1920s have resulted in development of dense fuel ladders. 

These consist of understory layers of fir and incense cedar beneath young growth stands of 

ponderosa pine, and sugar pine. Also in many of the pine plantations, incense cedar and white fir 

and brush have seeded in beneath the canopy, creating significant fuel ladders.

Fire Behavior in Current Fuel Loading

The Sugar Pine Adaptive Management Project (hence forth known as Sugar Pine Project) area 

has three dominant arrangements of fuels that influence fire behavior. These are: ground, surface 

and crown fuels. Ground and surface fuels can be described utilizing the Intermountain Fire 

Science Laboratory (IFSL) Fuel Models (Anderson 1982) and Scott and Burgan fuel models 

(2005) for estimating fire behavior. This is used to aid in describing the type and average amount 

of fuel given a particular vegetation type and the prediction of the type of fire behavior expected 

under certain weather and topographic conditions. Crown fuels are generally described in 

relationship to the density of crowns (canopy bulk density) and their height above the surface 

fuels (canopy base height). 

Surface Fuels

Ground and surface fuels within the Sugar Pine Project area can be described by using the IFSL 

Fuel models, IFSL Fuel Model 6 (intermediate brush) best describes the surface and ground fuels 

in plantations, mixed conifer stands and mixed chaparral areas. 

In areas within plantations where bear clover has re-established itself with minimal amounts of

dead natural fuel accumulations, an IFSL Fuel Model 2, Timber (grass and understory) is used. 

The ground and surface fuels within the mixed conifer stands that do not have brush as the main 

understory component fall into three IFSL Fuel Models 9, 10 and 12. The difference between 

these three fuel models comes from the increasing amounts of ground and surface fuels. IFSL 
Chapter 3: Affected Environment and Environmental Consequences

148 Sierra National Forest

Fuel Model 9 has the lightest amount of ground and surface fuels associated with it and is used to 

describe the conifer stands in Sugar Pine Project area that have not started to deteriorate from 

drought stress and/or overcrowding and the trees have not begun to fall on their own. This fuel 

model would also describe where there are large areas where small saplings and suppressed trees 

have begun to fill in the understory of larger trees. Surface fuel loadings in the Sugar Pine Project 

area that are representative of IFSL Fuel Model 9 average between 3 and 10 tons per acre. 

IFSL Fuel Model 10 and 12 are used to describe those conifer stands where natural fuel and 

activity generated accumulations of ground and surface fuels are beginning to increase. These 

surface fuels are of larger size, mostly 3 or more inches in size and can increase the intensity of 

surface fires within the area. These fuels include not only the branches and needles of fallen trees, 

but also include the boles, increasing the tons per acres of natural fuels on the ground rapidly. 

Surface fuel loadings in the Sugar Pine Project area that are representative of IFSL Fuel Model 10 

average between 12 and 25 tons per acre. Surface fuel loadings that are representative of IFSL 

Fuel Model 12 average between 25 and 40 tons per acre. 

Crown Fuels

The crown fuels in the Sugar Pine Project area can be described in two ways; (1) crown fuels that 

can lead to the propagation of a crown fire and (2) crown fuels available to sustain a crown fire. 

There are two elements that need to fall into place for a crown fire to start and for it to sustain 

itself, fuel ladders (vegetation that ―stair-steps‖ up in height and can allow a fire to reach the 

crowns of trees) and canopy density (in simple terms, how close together individual tree crowns 

are, usually given as a percentage of space taken up by the tops of trees).

In the Sugar Pine Project area, fuel ladders are heavy and continuous, consisting of natural 

regeneration of conifers (mainly white fir and incense cedar) and in some areas regeneration of 

conifers and brush. These fuel ladders start at the surface layer and have grown to the point of 

having a continuous ―stair-step‖ of available fuels into the bases of the canopy trees.

The canopy fuels in the Sugar Pine Project area are varied from open to heavily closed 

(approximately 100% canopy closure). Areas where there is a combination of heavy, continuous 

fuel ladders and canopy closure is closed (interlocking of crowns in the canopy) the potential for 

initiation and sustainability of a crown fire is the greatest.

Wildland Urban Intermix (WUI)

Communities (wildland urban intermix zones) within and surrounding the project area have been 

rapidly developing over the last several years. The community of Sugar Pine is encompassed by 

the project area with scattered residences and businesses along the Highway 41 corridor. To the 

north is the community of Fish Camp, with Teneya Lodge (popular visitor destination outside of 

Yosemite National Park) directly adjacent to the project area and Wawona in Yosemite National 

Park. South of the Sugar Pine Project area lies the community of Cedar Valley. Farther south lays 

the community of Oakhurst. To the east, lies the Nelder Grove Historical Area of giant sequoia. 

With the continuity of the fuels within the Sugar Pine project area, a wildland fire originating 

from along Highway 41 or Cedar Valley area, under the right conditions, has the potential to 

spread northward or eastward to the communities of Sugar Pine, Fish Camp, Yosemite National 

Park and/or Nelder Grove. 

Desired Condition

The SNFPA ROD (USDA-FS 2004b) establishes a desired condition for each land allocation. In 

particular, the desired condition for each land allocation incorporates how and what type of
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 149

vegetation complexes are desired for each. These are referenced in short and long term conditions 

and are influenced by the temporal and spatial influences of fire. With this in mind, the land 

allocations and their specific desired conditions used in this report include:

Wildland Urban Interface

As stated as in the SNFPA ROD (USDA-FS 2004b), the desired condition for 1⁄4 mile wide 

Defense Zones (USDA-FS 2004b; pg 40) would have: 

 Stands are fairly open and dominated primarily by larger, fire tolerant trees.

 Surface and ladder fuel conditions are such that crown fire ignition is highly unlikely.

 The openness and discontinuity of crown fuels, both horizontally and vertically, result in 

very low probability of sustained crown fire.

As stated as in the SNFPA ROD (USDA-FS 2004b), the desired condition for 1 1⁄4 mile wide 

Threat Zones (USDA-FS 2004b; pg 41) should, under high fire weather conditions, in treated 

areas display wildland fire behavior characterized as follows:

 Flame lengths at the head of the fire are less than four feet;

 The rate of spread at the head of the fire is reduced to at least 50 percent of pre-treatment 

levels;

 Hazards to firefighters are reduced by managing snag levels in locations likely to be used 

for control prescribed fire and fire suppression consistent with safe practices guidelines;

 Production rates for fireline construction are doubled from pre-treatment levels; and

 Tree density has been reduced to a level consistent with the site‘s ability to sustain forest 

health during drought conditions.

Fuel treatments outside of the WUI and within other land allocations are to establish and maintain 

a pattern of area treatments (referred to as SPLATs; DFPZs) that are effective in modifying 

wildfire behavior (USDA-FS 2004b; pages 45-48). There are specific means and conditions by 

which treatments can be conducted within some land allocations because of maintaining habitat 

needs as well as perpetuating such conditions (i.e. old forest emphasis areas).

Alternative 1 – No Action

Under Alternative1, current management plans would continue to guide activities in the project 

area. This includes all ongoing activities with existing decisions or permits that would not be 

changed if this alternative were selected including: underburning, plantation maintenance, cattle 

grazing, recreation, and recreation residences.

Under Alternative 1 there would be no thinning; precommercial, commercial and/or biomass, 

accomplished. Fuel ladders and competition between trees would not be reduced and/or removed. 

Forest health in the area will continue to decline. No connection and augmentation of fuel 

treatments within and adjacent to the Wildland Urban Interface would be completed. No 

fuelbreak maintenance work would be completed. Aerial fire suppression would not support 

ground forces due to the inability of retardants to reach ground fuels because of closed canopy 

cover. 
Chapter 3: Affected Environment and Environmental Consequences

150 Sierra National Forest

Direct Effects

Natural fuel accumulations would continue to increase as more trees begin to succumb to 

overcrowding, drought, insect and pathogens. This would increase the amount of ground and 

surface fuels within the area. This increase in ground and surface fuels would gradually begin to 

shift the potential fire behavior in the area, to a more severe stature if a wildfire were to start. This 

increase would be to a more severe surface fire as the type of fuels changed from branches and 

needles (0 to 1 inch material) to the larger size material (3 or more inches). This change is best 

represented by fuel model changes or conversions. Brush covered areas would gradually become 

older and more decadent, converting from an IFSL Fuel Model 6 into an IFSL Fuel Model 4. 

Mixed conifer areas that begin as IFSL Fuel Model 9 would convert to IFSL Fuel Model 10. As 

accumulated natural surface fuel loadings increased, a further conversion from IFSL Fuel Model 

10 to IFSL Fuel Model 12, similar to that of a moderate slash fuel loading could occur in some 

areas. IFSL Fuel Model 2 is used to represent the surface fuel conditions existing in some conifer 

plantation. Under Alternative 1, this would not change, but additional accumulations of larger 

diameter branch wood, twigs and perhaps boles of trees could increase the average tons/acre of 

surface fuels, increasing the fireline intensity and resistance to control. Firefighters with 

handtools or water from fire engines would become less effective. Crown fire potential would 

also remain high because none of the elements needed to propagate and sustain a crown fire 

would be removed (fuel ladders and canopy density). Because of the increased amount of surface 

fuels and the increased fire behavior associated with them, these potential crown fires would have 

the potential to propagate over a larger area. Tables 32 and 33 show the indicators for current 

existing conditions and those associated with the conversions in IFSL Fuel Models under 

Alternative 1.

Table 32. Indicators for IFSL Fuel Models of Brush Covered Areas

Indicator Existing With No Treatment

Fuel Model 6 4

Average Rate of Spread (ch/hr) 24.8 91.6

Average Flame Length (feet) 5.8 22.9

Average Fireline Intensity (Btu/ft/s) 258 5131

Crown Fire Potential (transition and type) Yes; Crowning Yes; Crowning

Resistance to Control (low, mod., high) High High

Average Fuel Loading (tons/acre) 6.0 13.0

Average Mortality (%) N/A N/A

It is assumed that mortality in the brush species would be from stand replacing (100%) or patchy 

dependent on the percent cover of the brush. For mortality to occur in brush there need only be 

enough fire to girdle the main stem. With the predicted fire behavior, as shown above, it is 

anticipated that in Fuel Model 6, as currently exist, there would be mortality, but not as great as in 

Fuel Model 4, because of the lower amount of dead woody material found on the brush.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 151

Table 33. Indicators for IFSL Fuel Models in Timber Covered Areas

Indicator Existing Existing With No 

Treatment 

change to:

With No 

Treatment 

change to:

Fuel Model 9 2 10 12

Average Rate of Spread (ch/hr) 10.3 48.3 10.3 16.2

Average Flame Length (feet) 3.5 7.8 6.0 9.6

Average Fireline Intensity (Btu/ft/s) 84 500 282 781

Crown Fire Potential (transition and type) Yes; 

Crowning

Yes; 

Crowning

Yes;

Crowning

Yes;

Crowning

Resistance to Control (low, mod., high) Moderate 

to High

Low to 

Moderate

High High

Average Fuel Loading (tons/acre) 3.5 4.0 12.0 34.6

Average Mortality in White Fir / 

Ponderosa Pine (%)

35 / 22 97 / 94 79 / 65 99 / 97

The above tables give an indication of what type of fire behavior could be expected if a fire were 

to occur within these fuel beds as they currently exist and in the anticipated fuel beds into the 

future with no management action taken. Because of the variability in the three facets needed to 

predict fire behavior; fuel, weather and topography that exist within the Sugar Pine Project area, 

there would be variations in the conditions and results of wildfire. On northern aspects, conditions 

would be expected to be cooler than southern aspects, lending to slightly slower and slightly less 

intense fires. Lower fuel loadings could produce slower rates of spread and intensities than 

predicted above. There are conditions that could produce higher rates of spread and intensities 

than in the above tables as well. These would include increased slopes, wind conditions, greater 

surface fuel loadings (both small and large down-woody debris) and increased density of ladder 

fuels. 

Indirect and Cumulative Effects

Past, present and reasonably foreseeable actions, as listed in the project file for the Sugar Pine 

Project area, along with fire management policy of full suppression at the smallest size (97 

percent of all fires will be controlled at 10 acres or less from Sierra NF LRMP (USDA-FS 1992),

have contributed to the current existing condition for the Sugar Pine Project area and are used to 

depict the existing condition and the resultant fire behavior within the project area. 

Fire Suppression / Fire Use 

As surface fuels continue to accumulate naturally, with no additional management actions, 

suppression efforts will gradually become more difficult, whereby direct attack could no longer 

be used in suppressing a fire, but have to be changed to more indirect tactics, whereby more area 

has the potential to be affected by fire, in some cases high intensity and more severe fire. With the 

increases in fire behavior generated by these surface fuel changes, fire suppression forces would 

have higher resistance to control (the relative difficulty of constructing and holding a control line 

as affected by resistance to constructing line due to fuel loading and by fire behavior), and aerial 

retardants would be less effective due to closed continuous canopy. If fire were to start in or burn 
Chapter 3: Affected Environment and Environmental Consequences

152 Sierra National Forest

into the Sugar Pine Project area, ground and aerial initial attack operations as well as extended 

attack would become less effective and firefighter and public safety would be difficult to ensure.

Under Alternative 1, full suppression would continue to be the management direction for the 

Sugar Pine Project area. Because of the continued and potential increased threat to life and 

property, under Alternative 1, firefighting resources would focus strategies and tactics on 

reducing the impacts on communities, protecting infrastructure and private property as the highest 

priority followed by protection of natural resources. 

Under Alternative 1, there would be very limited to no potential to allow fire to play its natural 

role on the landscape. The risk of escape and the consequential effects associated with utilizing 

fire without some form of management activity to reduce current surface fuel loadings and ladder 

fuels would be too great. Although prescribed fire could be implemented under more controlled 

conditions than those conceivably present during the summer fire season, it would be a very 

narrow prescription window that could produce reasonable outcomes that would be beneficial 

versus detrimental. Just like wildfire, prescribed fire produces air quality concerns, risk of escape, 

potential negative impacts to resources (from control lines and fire itself), resource commitments 

and political and social impacts. 

Fire Effects

Fire influences many portions of a fire dependent ecosystem by either its presence or even its 

absence. Forest stand structures, wildlife habitat, aquatic communities, watersheds, plant 

communities and soil conditions, to name a few can be influenced. Without frequent fire to clean 

the understory of stands, excessively dense stands lead to drought stress and bark beetle 

outbreaks, resulting in wide spread mortality of trees in many areas and the potential for extensive 

mortality. This leads to a large increase in the amount and continuity of both live and dead forest 

fuels, resulting in a substantial increase in the probability of large, severe wildfires

(Weatherspoon 1996). These are directly correlated to the conversions of IFSL Fuel Models 

discussed in the direct effects section. 

With increased rates of spread, flame lengths, and fireline intensities there is potential for greater 

fire effects to occur. Because of existing changes in tree species composition, from fire resistant 

to fire susceptible, tree mortalities would increase with small incremental changes in wildfire 

intensity. This, in combination with drought or insect/pathogen induced mortality in overstocked 

stands, could greatly increase the amount of surface fuel loading, thus increasing fire behavior 

and intensity of subsequent wildfires. Under Alternative 1, there would be no reduction in surface 

and ladder fuels, to raise mean canopy base heights and/or decrease canopy bulk densities as has 

been suggested in the desired condition for creating fire resilient stands. Vertical continuity of 

fuels from the forest floor to the crowns of overstory trees would be present and with sufficient 

radiant/convective heat could produce crown fire. Some studies and models, however, suggest a 

crown fire entering a stand is rarely sustained (i.e., sustained only under extreme weather

conditions) (North, M., et. al. 2009). Calculated and predicted crown fire potential (see Tables 32 

and 33) show that conditions are present in the Sugar Pine Project area to produce the potential 

for crown fire. This could be in the form of torching single trees, groups of trees and/or active 

crown fire dependent on weather, fuels and topography of where the fire were to occur.

Crown fires remove much or the entire tree canopy in a particular area, essentially resetting the 

successional and growth processes of stand and forests. These fires typically, but not always kill 

or temporarily reduce the abundance of understory shrubs and trees. Crown fires have the largest 

immediate and long-term ecological effects and the greatest potential to threaten human 

settlements near wildland areas (Graham 2004). For wildlife species dependent on diverse 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 153

forested landscapes (heterogeneity) and old forest characteristics for habitat, this successional 

―set-back‖ could pose negative consequences. 

Although crown fires would be considered of higher consequence of negative effects, surface and 

ground fires with higher intensities similar to those predicted and anticipated in this alternative, 

can also have negative impacts. While surface fires can reduce vegetation and woody, moss, 

lichens and litter strata, ground fires that consume large amounts of woody fuels and organic soil

horizons can produce disproportionately large amounts of smoke. Ground fires reduce the 

accumulation of organic matter and carbon storage and contribute to smoke production during 

active fires and long after flaming combustion has ended. These fires can also damage and kill 

large trees by killing their roots and the lower stem cambium. Because ground fires are often of 

long duration, they may result in greater soil heating than surface or crown fires, with the 

potential for reducing organic matter, volatilizing nutrients, and creating a hydrophobic layer that 

contributes to erosion. Areas where the ground cover is removed and severely burned will likely 

see decreased infiltration of water, increased surface runoff and peak flows, and the formation of 

pedestals, rills and gullies (Graham 2004).

Depending on the setting (in particular topography and soil), perennial streams downstream from 

fires can be impacted by large volumes of sediment. Depending on the recovery of the hillslopes, 

these fire effects can be long lasting, and relatively little can be done to stop the problem. Large 

amounts of sediment can be delivered to reservoirs, reducing water storage capacity and 

potentially affecting fish and macroinvertebrate habitat (Graham 2004). 

Alternative 2 – Proposed Action

Creating Fire Resistant Forests

Fire resistant forests combine fire resistant tree species suitable to a site in a spatial arrangement 

that discourages surface fires from moving to the crowns. Crowns are made more resistant to fire 

by reducing surface and ladder fuels as well as increasing the height of the base of the canopy. 

Canopy Base Height (CBH):

 Is the lowest height above the ground at which there is sufficient canopy fuel to 

propagate fire (Van Wagner 1993);

 Is the average crown base height for the stand;

 Is the lowest 20th percentile of all crown base heights in the stand (Hoffman 2005, Fulé 

et al. 2001, 2002);

 The height at which a minimum bulk density of fine fuel (30 lb/acre/ft, 0.011 kg/m3 ) is 

found (Beukema et al,1997); and

 CBH is the lowest height above the ground at which there is sufficient canopy fuels to 

propagate fire vertically through the canopy (Scott and Reinhardt 2001).

Also decreasing the crown density and removing smaller trees while retaining larger more fire 

resistant trees reduces the risk of crown fire. 
Chapter 3: Affected Environment and Environmental Consequences

154 Sierra National Forest

Table 34. Principles of Fire Resistant Forests 

Recommendation Physical Effects Fire Advantage Concerns

Reduce surface and 

ladder fuel

Reduces potential 

flame length

Fire control easier, 

less torching

Surface disturbance less with 

fire than other techniques

Increase canopy base 

height

Requires longer flame 

length to ignite tree 

crowns

Less torching Opens under story, may allow 

surface wind to increase

Decrease crown density Makes independent 

crown fire less 

probable

Reduces crown fire 

propagation

Surface wind may increase, 

surface fuel may be drier

Retain larger trees Thicker bark and 

taller crowns

Increases 

survivability of 

trees

Removing only smaller trees 

is economically less feasible

Retain fire resistant tree 

species

Promotes trees most 

likely to survive fires

Reduces mortality 

from future fires

Repeated treatments may be 

necessary to promote desired 

trees

Source: Adapted from Agee 2002 by Graham et. al. 2004

The table above is displayed in this report to assist in demonstrating the types of treatments 

proposed to achieve the purpose and need of the Sugar Pine Project, the physical effects, fire 

advantage and concerns associated with each recommended means to affect fire behavior. The 

following associates the predicted fire behavior results of each level of treatment proposed by this 

and all action alternatives. 

Direct Effects

Under this alternative, thinning from below, through biomass, precommercial and/or commercial 

means would focus first on the smaller trees for removal gradually moving through the lower 

canopy levels with the potential to remove trees within the mid-level canopy to reach a 

silviculturally-prescribed basal area and stocking level. Through the treatments in Alternative 2, 

the recommendations in Table 34 are accomplished by reducing surface and ladder fuels, 

increasing canopy base height, decreasing crown density, retaining larger trees and retaining fire 

resistant tree species.

Fuel Model Changes

Under Alternative 2, existing fuel model would be converted to another fuel model, typically a 

fuel model with lower surface fuel loadings and reduced fire behavior. In areas currently 

represented by IFSL Fuel Model 6, mastication would be used to convert it to an IFSL Fuel 

Model Timber/Understory (TU) 1. Mastication in effect does not remove the fuel from the site, 

but changes the structure of the fuel from a vertical orientation to a horizontal orientation. Small 

chips, shredded material and/or crushed fuels (dependent on masticator head) are left on site. A 

fuel model that represents an increase in fuel loading in the 10 and 100-hour time lag categories is 

needed to show this. TU1 is used as the base fuel model with increases in 10 and 100-hour fuel 

loadings to approximately 2 tons per acre each and the removal of live woody fuel loading to 

approximate this conversion.

In timbered stands represented as IFSL Fuel Model 9, there would be or no conversion to a 

different fuel model. In stands represented by IFSL Fuel Model 10, biomass and thinning from 

below would convert them to an IFSL Fuel Model 8 or 9, dependent on the overstory and surface 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 155

fuels remaining. In some cases, a short-term conversion to an IFSL Fuel Model 12 may occur 

until post activity treatments were completed, then a conversion to an IFSL Fuel Model 8 or 9 

would result.

The fuel model conversions shown are used to depict the conditions anticipated in the surface fuel 

bed changes as a result of the treatments proposed in this alternative. This alternative is also 

anticipated to raise canopy base heights, with the thinning or removal of ladder fuels from an 

average of 0 to 10 feet to an average of 20 feet. Canopy bulk density will also be decreased 

through the thinning of lower and mid-level canopies. It is estimated that, on average the canopy 

bulk density will be changed from 0.19 kg/m3 to 0.14 kg/m3 under Alternative 2.

Surface and Ladder Fuels

The removal and/or thinning of the lower canopy in effect removes the ladder fuels that can 

provide the means for surface fires to ―climb‖ into the overstory canopy. In areas where there is a 

significant amount of ladder fuels present, biomass operations will be used to remove excess 

material. It is anticipated there would be small amounts of additional fuels added to the current 

surface fuel loading through this type of operation because the material would be taken in whole 

tree form to a landing for removal versus limbs/tops cut off and left within the stand (known as 

lop and scatter). In areas where brush species are the dominant vegetation cover, masticators will 

be used to in effect change the vertical continuity of the fuel. While mastication does not actually 

remove fuel from the area, it does change the structure from a vertically oriented fuel (ladder 

fuel) to a horizontal fuel potentially making fire suppression resistance to control lower and fire 

effects less in most cases. In areas where there are lower amounts of ladder fuels and/or smaller 

areas, mastication and/or hand cutting will be used to open or separate the lower canopy from the 

mid to upper level canopy. Typically, these areas have lower levels of surface fuels existing 

(smaller amount of trees/vegetation, less amounts of naturally accumulated or activity generated 

surface fuels).

Dependent on the type of harvest system used for removal of excess commercial-sized material, it 

is anticipated there may be a short-term increase in surface fuel loading or no significant increase. 

Whole-tree yarding, used as a harvesting system, can minimize the amount of activity generated 

fuels (Stephens, S. 2009). If whole tree yarding is not used, additional post harvest treatments will 

be needed to reduce surface fuel loadings that are in excess of 20 tons/acre (USDA-FS 2004b). 

These post activity treatments would include dozer and/or hand piling and burning and/or 

broadcast/jackpot burning.

Fire Behavior / Fire Effects 

Table 35 shows the predicted results of fuel model conversions anticipated with this alternative. 
Chapter 3: Affected Environment and Environmental Consequences

156 Sierra National Forest

Table 35. Indicators for IFSL Fuel Models of Brush and Timber Covered Areas

Indicator Existing

(Brush 

Areas)

Existing

(TimberAreas 

with 

Light 

Fuel 

loading)

Existing

(TimberAreas 

with 

Light 

Fuel 

loading)

Heavy 

Surface 

Fuel 

Loading, 

but ladder 

fuels 

removed 

Timbered areas post 

treatment to reduce 

ladder/surface fuels

Fuel Model 6 9 10 12 TU1 9

Average Rate of 

Spread (ch/hr)

24.8 10.3 10.3 11.0 7.5 5.8

Average Flame 

Length (feet)

5.8 3.5 6.0 8.1 3.0 2.7

Average Fireline 

Intensity 

(Btu/ft/s)

258 84 282 531 63 47

Crown Fire 

Potential 

(transition and 

type)

Yes;

Crowning

Yes;

Crowing

Yes;

Crowning

Yes;

Torching

No; Surface No; Surface

Resistance to 

Control (low, 

mod., high)

High Low to 

Moderate

High High Low Low

Average Fuel 

Loading 

(tons/acre)

6.0 3.5 12.0 34.6 6.0 3.5

Average 

Mortality in 

White Fir / 

Ponderosa Pine 

(%)

N/A 35 / 22 79 / 65 96 / 93 N/A 15 / 8

The above table gives an indication of what type of fire behavior could be expected if a fire were 

to occur within these fuel beds as they currently exist and in the anticipated fuel beds after 

treatments were to occur. Because of the variability in the three facets needed to predict fire 

behavior; fuel, weather and topography within the Sugar Pine Project area, there would be 

variations in the conditions and results of wildfire. On northern aspects, conditions would be 

expected to be cooler than southern aspects, lending to slower and less intense fires. Lower fuel 

loadings could produce slower rates of spread and intensities than predicted above. There are 

conditions that could produce higher rates of spread and intensities than in the above tables. 

These would include increased slopes, wind conditions, greater surface fuel loadings (both small 

and large down-woody debris) and increased density of ladder fuels. 

Indirect and Cumulative Effects

Past, present and reasonably foreseeable actions, as listed in the project file for the Sugar Pine 

Project area, along with fire management policy of full suppression at the smallest size (97 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 157

percent of all fires will be controlled at 10 acres or less from Sierra NF LRMP (USDA-FS 1992) 

have contributed to the current existing condition for the Sugar Pine Project area and are used to 

depict the existing condition and the resultant fire behavior within the project area.

Fire Suppression and Fire Use

Alternative 2 in effect reduces ladder fuels which in turn increases canopy base height. Canopy 

density (in the form of canopy bulk density) is decreased through the thinning of the mid-level 

canopy, but to a small extent through the reduction in fuel ladders. These, in combination, reduce 

rates of spread, flame length, fireline intensity, resistance to control and the potential for a fire to 

transition into crown fires. If full fire suppression continues as the management strategy for 

unplanned ignitions within the project area, fire suppression resources will have an increased 

capacity to control fires at initial attack with minimized risk to their safety (and the public) and 

increased ability to keep these fires small in size with the use of direct attack tactics versus 

indirect tactics. Fires would typically drop from the crowns to the forest floor. Aerial firefighting

resources would be better able to penetrate the canopy to aid ground resources with reduced 

canopy density, even moderate amounts as an indirect effect of treatments in Alternative 2.

Design features used to minimize effects and/or retain habitat structures preferred by wildlife 

species such as; grouping of larger trees, oak retention with ladder fuels retained under them and 

Old Forest Linkages with limited treatments will have lower potential for loss since there will be 

treated areas between them and are not continuous. This would be similar to the variability in 

forest conditions produced by frequent fire (North 2009).

In utilizing mechanical treatments, as in Alternative 2, stand structures are modified quickly and 

more precisely than with prescribed fire alone (North 2009). Under this alternative, treatments are 

effective in breaking up the horizontal and vertical continuity of live fuels in the lower canopy 

layers and/or in effect pre-treating the stands to more readily allow prescribed fire to be reintroduced. Silvicultural cuttings can only partially substitute for fire (Weatherspoon 1996). This 

alternative allows increased potential to utilize prescribed fire as either a maintenance treatment 

and/or in conjunction with mechanical treatments as a follow-up process to achieve forest 

resilience. Fire could mimic the natural ecosystem functions of frequent low-to-moderate 

intensity and severity fire. Under this alternative, prescribed fire, whether burning of piles and/or 

broadcast burns can be implemented with less risk of escape, with a broader range of acceptable 

conditions and in some cases less impacts to air quality (Weatherspoon 1996). 

Fire Effects

With the removal of what is considered the suppressed, intermediate and some co-dominates 

within a stand, the vegetation considered ladder fuels would be removed. Conifer species such as 

Ponderosa Pine and Sugar Pine, which are considered more fire resistant, would be favored to 

remain in a stand over shade tolerant and fire sensitive species, such as incense cedar and white 

fir. Incense cedar and white fir make up the largest percentage of conifers found in the understory 

of stands in the Sugar Pine Project area (based on sampled plot data). These species also tend to 

have increased susceptibility to wildfire as well tend to have limbs that stay closer to the ground 

providing increased ability to take surface fires into the crowns in the form of single tree torching 

or group torching. With species composition favored towards the more fire resistant, shade 

intolerant species and fire behavior modified, effects to stands (mortality) would be decreased.

As part of this alternative, treatments would be implemented to reduce surface fuels, where 

needed. In most cases, as been experienced in past projects similar to this alternative, these areas 

are not continuous over the entire treatment area. If a fire was to start in an area where these 

surface fuels have not been reduced, fire behavior would be increased (as represented by IFSL 
Chapter 3: Affected Environment and Environmental Consequences

158 Sierra National Forest

Fuel Model 12). The results of wildfire impacts on areas treated only with mechanical methods 

are mixed. Some burned with higher intensity, than those where mechanical treatments were 

followed by prescribed burning, though with lower severity than untreated control areas 

(Stephens 2009). The timing and sequence of these ―clean-up‖ treatments are dependent on 

several factors, such as adequate funding and completion of harvesting operations. Those 

treatment areas closest to WUI will be treated first and then will progress into other areas from 

there. As stated earlier the surface fuel load changes would be largely based on harvesting system 

used. If whole-tree yarding is used, post treatment areas where natural fuel accumulations are 

above 20 tons/acre would be the areas where secondary treatment would be used. These are areas 

expected to be less (acres) in need of surface fuel reduction.

With reduction in fire behavior, the effects of fire on other ecosystem components would be 

reduced and perhaps enhanced. Many are resistant or often have favorable responses to low to 

moderate fire intensity and severity. The idea of preemptive work that restores historic fire 

regimes has not been widely discussed, considered, or used to address both the ecological and 

social issues surrounding fires and watershed resources. The same can be said for many of the 

wildlife species that live and depend on the forested ecosystem. At risk species, and the 

ecological functioning systems they depend on, cannot be sustained or recovered without the 

immediate and longer-term ecological functioning provided by fire. In Alternative 2, integrating 

fire and fuels management objectives and forest health restoration with at-risk species 

conservation and protection are made. This is needed to provide both the viability of human 

communities and at-risk species where both overlap (Sugihara 2006).

Climate Change and Fire Severity Relationships

As stated earlier, weather (climate) has a large influence on fire behavior and is also the most 

difficult to predict. Associated with the purpose and need to reduce stand densities to levels where 

trees would be more resilient to drought conditions, reducing surface and ladder fuels to reduce 

wildfire intensity and spread, can also produce benefits in drought conditions. Research suggests 

global mean minimum temperatures may have already begun to rise. One effect of this change for 

western forests would be earlier spring melt of mountain snow packs. An analysis of western U.S. 

fire season length over the last 50 years suggests that during the last two decades, fires begin 

earlier in the spring and occur later in the fall possibly due to this trend in elevated nighttime 

minimum temperatures. Though there are variations in predictions and models, one point of 

consensus is that most agree the climate will become more extreme, suggesting oscillations 

between wet and drought conditions will be more common (North 2009).

Managing forests under these conditions will be challenging. In the face of uncertainty, adaptive 

strategies should focus on three responses; resistance (forestall impacts and protect highly valued 

resources), resilience (improve the capacity of ecosystems to return to desired conditions after 

disturbance), and response (facilitate transition of ecosystems from current to new conditions) 

(North 2009). All of these are focuses that Alternative 2 is attempting to address through its 

purpose and need for changes in forest structure capable of surviving climate changes and 

reduction in fuels to adapt fire behavior that occurs under current climate and ignition conditions 

(North 2009). 

Alternative 3

Direct Effects

Under Alternative 3, there would be no significant change in the direct effects from those listed 

under Alternative 2. There is a potential for a decreased amounts additive surface fuel loading 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 159

within the designated 2008 F01 fisher densite buffer resulting from less conifers being removed. 

As stated in Alternative 2, resultant increases or decreases in surface loadings from harvesting 

operations are dependent on the type of harvesting operations that are used. By increasing canopy 

base heights and reducing surface fuel loadings, fire and fuels objectives are met. 

Indirect and Cumulative Effects

Under Alternative 3, there would be no significant change in the indirect and cumulative effects 

from those listed under Alternative 2. There is a potential for aerial firefighting resources to be 

less effective in the designated Pacific fisher densite buffer with no reduction in mid-level canopy 

densities. Increased crown densities in the den site area would make it difficult for retardant 

and/or water dropping from helicopters to penetrate to the ground. In assuring the reduction in 

ladder fuels to raise canopy base heights from 0 to 10 to 20 feet and reducing surface fuel 

loadings, fire intensity and spread are reduced to desired condition levels and meet the fire and 

fuels objectives stated in the purpose and need of the project. 

There is little to nothing is done to reduce forest stand densities within the designated Pacific 

fisher densite buffer though with this alternative and could produce losses from drought induced 

mortality, insect and disease. Long term, these types of disturbances could induce increases in 

surface fuel loadings and/or increased snag levels producing conditions similar to those already 

existing in the project area with resultant fire behavior (intensity and spread rates) similar to those 

predicted in Alternative 1, with the exception of crown fire potential. It is assumed that with the 

reduction in ladder fuels, there would be increases in rates of spread, increase flame lengths, 

increased fireline intensity, and increased resistance to control, similar to that seen in IFSL Fuel 

Model 9 and/or 10 in Alternative 1, but this would be as a surface fire with potential for crown 

fire reduced and/or eliminated. Fire intensities could cause the potential for single or group tree 

torching because of the increased number of fire susceptible trees such as white fir and incense 

cedar left in the stand, but this is expected to be less than in Alternative 1. 

Alternative 4

Under Alternative 4, all treatment areas would be carried forward from Alternative 2, but 

treatments would include only those needed to achieve fire and fuels objectives (treatment of 

surface and ladder fuels).

Direct Effects

Under Alternative 4, there would be no significant change in the direct effects from those listed 

under Alternative 2. As in Alternative 3 direct effects, there is a potential for decreased amounts 

additive surface fuel loading within all ―T‖ treatment areas resulting from less conifers being 

removed. As stated in Alternative 2, resultant increases or decreases in surface loadings from 

harvesting operations are dependent on the type of harvesting operations that are used. By 

increasing canopy base heights and reducing surface fuel loadings, fire and fuels objectives are 

met. 

Indirect and Cumulative Effects

Under Alternative 4, there would be no significant change in the indirect and cumulative effects 

from those listed under Alternative 2. There is a potential for aerial firefighting resources to be 

less effective in all ―T‖ treatment areas with no reduction in mid-level canopy densities. Increased 

crown densities in the den site area would make it difficult for retardant and/or water dropping 

from helicopters to penetrate to the ground. In assuring the reduction in ladder fuels to raise 

canopy base heights from 0 to 10-20 feet and reducing surface fuel loadings, fire intensity and 
Chapter 3: Affected Environment and Environmental Consequences

160 Sierra National Forest

spread are reduced to desired condition levels and meet the fire and fuels objectives stated in the 

purpose and need of the project. 

There is little to nothing done to reduce forest stand densities. This alternative could produce 

losses from drought induced mortality, insect and disease. Long term, these types of disturbances 

could induce increases in surface fuel loadings and/or increased snag levels producing conditions 

similar to those already existing in the project area with resultant fire behavior (intensity and 

spread rates) similar to those predicted in Alternative 1, with the exception of crown fire 

potential. It is assumed that with the reduction in ladder fuels, there would be increases in rates of 

spread, increase flame lengths, increased fireline intensity, and increased resistance to control, 

similar to that seen in IFSL Fuel Model 9 and/or 10 in Alternative 1, but this would be as a 

surface fire with potential for crown fire reduced and/or eliminated. Fire intensities could cause 

the potential for single or group tree torching because of the increased number of fire susceptible 

trees such as white fir and incense cedar left in the stand, but this is expected to be less than in 

Alternative 1. 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 161

Air Quality _________________________________

The direct, indirect and cumulative effects to air quality and visibility are summarized from the 

Air Quality Report for the Sugar Pine Adaptive Management Project (Tolmie, D. 2009).

Introduction

Fire is an important part of California ecosystems, but it also produces combustion by-products 

that are potentially harmful to human health and welfare. Carbon dioxide and water are the two 

products of complete combustion and generally make up 90 percent of the total emissions from 

wildfire. In incomplete combustion that occurs under wildfire conditions, smoke is composed of 

carbon dioxide, water vapor, carbon monoxide, particulate matter, hydrocarbons, and other 

organic compounds, nitrogen oxides, trace minerals and several thousand other compounds. 

Particulate matter is the principle pollutant of concern to human health from wildfire smoke for 

the short-term exposures typically experienced by firefighters and the public. Studies indicate 

that 90 percent of smoke particles emitted during wildland burning are particles that measure less 

than ten microns in size (PM10), and about 90 percent of these are less than 2.5 microns in size 

(PM2.5). Hydrocarbons and nitrogen oxides from large wildfires contribute to increased ozone 

formation (which causes injury to plants) under certain conditions (Ahuja 2006). 

There are two general strategies to managing wildfire smoke: (1) emission reduction and (2) 

emission redistribution. All pollutants except nitrous oxide are negatively correlated with 

combustion efficiency, so actions that reduce one pollutant result in the reduction of all. 

Emission redistribution techniques may effectively keep smoke impacts away from sensitive 

areas, but does little to reduce the amount of emissions produced. But optimal use of reduction 

techniques can reduce emissions by approximately 20 to 25 percent, assuming all other factors 

(vegetation types, acres, etc.) were held constant and land management goals were still met. 

Emission reduction techniques can include reducing the area burned, reducing fuel loading, 

reducing fuel production, reducing fuel consumption, and scheduling burning before new fuel 

appears and increasing combustion efficiency (Ahuja 2006). These reduction techniques, which 

can include prescribed fire, mechanical harvesting (which includes road work, cutting, and 

hauling of material) and vegetation management treatments (mastication and mechanical piling) 

can produce emissions that can affect human health and visibility.

The purpose and need of the Sugar Pine Adaptive Management Project is to reduce the intensity 

and spread of wildland fires and reduce stand densities to improve forest health. This report 

analyzes the direct, indirect and cumulative effects to Air Quality and visibility from the 

alternatives proposed to meet this purpose and need as well determines the General Conformity of 

these actions to the Clean Air Act.

Regulatory Framework

The Sierra National Forest Land and Resource Management Plan states that ―Forest activities will 

be managed so air quality is compatible with federal, state and local laws, including a program 

that achieves the Clean Air Act responsibilities‖ (SNF LRMP 1992, pg. 4-2). The SNF LRMP 

has Standards and Guidelines for Air Quality (SNF LRMP 1992, pgs. 4-25) that includes the 

following:
Chapter 3: Affected Environment and Environmental Consequences

162 Sierra National Forest

 Avoid cumulative impacts to air quality by coordinating prescribed burning activities 

within the Forest, with burning activities conducted by others (SNF LRMP 1992 S&G # 

216)

 Mitigate fugitive dust impacts on air quality by including dust abatement as a 

requirement for construction activities that have potential to generate dust (SNF LRMP 

1992 S&G # 217).

 Avoid prolonged effects from prescribed burning activities on air quality by burning only 

on Air Quality Control Board (AQCB) approved burn days when satisfactory wind 

dispersion conditions prevail (SNF LRMP 1992 S&G # 218).

 Participate with AQCB to qualitatively define air quality control regulations and 

guidelines and effects of air quality on the Forest, from sources outside the Forest (SNF 

LRMP 1992 S&G # 219).

 Obtain appropriate permits prior to conducting prescribed burning activities (SNF LRMP 

1992 S&G # 220).

 Incorporate air quality management considerations into fire management (SNF LRMP 

1992 S&G # 230).

Federal Clean Air Act

The federal Clean Air Act (CAA), enacted in 1963 and amended several times thereafter 

(including the 1990 amendments), establishes the framework for modern, national air pollution 

control. The CAA directs the Environmental Protection Agency (EPA) to establish National 

Ambient Air Quality Standards (NAAQS) for six pollutants: Ozone (O3), Carbon Monoxide 

(CO), lead (Pb), Nitrogen Dioxide (NO2), particulate matter (PM10 and PM2.5), and Sulfur Dioxide 

(SO2). The standards are divided into primary and secondary standards. Primary standards are 

designed to protect human health, including the health of ―sensitive‖ populations such as 

asthmatics, children, and the elderly, within an adequate margin of safety. Secondary standards 

are designed to protect public welfare, including protection against decreased visibility and 

damage to animals, crops, vegetation, and buildings.

Areas that do not meet the NAAQS are called nonattainment areas (Error! Reference source not 

found.32). For nonattainment areas, the CAA requires states to develop and adopt State

Implementation Plans (SIPs), which are strategies approved by the EPA that demonstrate how the 

federal standards will be achieved. Failing to submit a plan or secure approval could lead to 

denial of federal funding and/or permits for improvements such as highway construction and 

sewage treatment plants. In California, the EPA has delegated authority to prepare SIPs to the 

California Air Resource Board (CARB), which in turn, has delegated that authority to individual 

air districts. In cases where the SIP is submitted by the state, but fails to demonstrate achievement 

of the standards, the EPA is directed to prepare a federal implementation plan.

Federal Conformity Requirements

The CAAA require that all projects receiving federal funds must conform to the appropriate SIP. 

Federal actions are subject to either the Transportation Conformity Rule (40 CFR 51[T]), which 

applies to federal highway or transit projects, or the General Conformity Rule (40 CFR 51[W]), 

which applies to all other federal actions. Because the Sugar Pine Adaptive Management Project 

is not a federal highway or transit project, it is subject to the General Conformity Rule.
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Sierra National Forest – Chapter 3 163

General Conformity Rule Requirements

The purpose of the General Conformity Rule is to ensure that federal actions conform to 

applicable SIPs so that they do not interfere with strategies employed to attain the National 

Ambient Air Quality Standards (NAAQS). The rule applies to federal actions in areas designated 

as nonattainment, or in some cases maintenance, for any of the six criteria pollutants. The rule 

applies to all federal actions except:

 Programs specifically included in a transportation plan or program that is found to 

conform under the federal transportation conformity rule.

 Projects with associated emissions below specified de minimus threshold levels.

 Certain other projects that are exempt or presumed to conform.

A general conformity determination would be required if a proposed federal action‘s total direct 

and indirect emissions fail to meet one of these two conditions:

 Emissions for each affected pollutant for which the region is classified as a maintenance 

or nonattainment area for the NAAQS are below the de minimus levels indicated in Table 

1.

 Emissions for each affected pollutant for which the region is classified as a maintenance 

or nonattainment area for the NAAQS are regionally insignificant (total emissions are 

less than 10% of the area‘s total emissions inventory for that pollutant).

If either of these conditions is met, the requirements for general conformity do not apply because 

the proposed action is presumed to conform to the applicable SIP for each affected pollutant. As a 

result, no further analysis or determination would be required. If neither of these conditions is

met, a general conformity determination must be performed to demonstrate that total direct and 

indirect emissions for each affected pollutant for which the region is classified as a maintenance 

or nonattainment area for the national standards would conform to the applicable SIP.

The Sugar Pine Adaptive Management Project is within two different air basins, the San Joaquin 

(Madera County) and Mountain Counties Air Basins (Mariposa County). Madera County 

(SJVAPCD) Federal attainment status is currently serious for 1997 8-hour ozone standard, but a 

reclassification to ―extreme‖ was proposed by EPA on August 19, 2009 which is expected to be 

finalized at the end of 2009; in attainment (maintenance) for PM10; and non-attainment for PM2.5. 

Mariposa County Federal attainment status for Criteria Pollutants is in non-attainment (Former 

Subpart 1) for 8-hour ozone and is unclassified for each of the other criteria pollutants. The two 

air basins are considered in attainment for all other criteria pollutants.

The EPA, for determining conformity, has developed de minimus levels for each of the criteria 

pollutants based on an air basins attainment status for each pollutant. The table below shows 

these de minimus level thresholds and are bolded based on air basin status. 
Chapter 3: Affected Environment and Environmental Consequences

164 Sierra National Forest

Table 36. Federal de minimus Threshold Levels for Criteria Pollutants based on Air 

Basin attainment status. 

Pollutant Area Type Tons/Year

Ozone (NOx or VOC)

Extreme nonattainment (SJV Air Basin) 10

Other O3 Nonattainment Area Outside an O3 

Transport Region (Mountain Counties) 100

Carbon monoxide, SO2 

and NO2 All nonattainment & maintenance 100

PM-10

Serious nonattainment 70

Moderate nonattainment and maintenance (SJV Air 

Basin) 100

Lead (Pb) All nonattainment & maintenance 25

Note: Federal de minimus threshold levels in bold type are those where status is non-attainment or maintenance.

California Clean Air Act

Responsibility for achieving California‘s air quality standards, which are more stringent than 

federal standards, is placed on the Air Resource Board (ARB) and local air districts, and is to be 

achieved through district-level air quality management plans that are incorporated into the State 

Implementation Plan (SIP). In California, the EPA has delegated authority to prepare SIPs to the 

ARB, which in turn has delegated that authority to individual air districts.

The CCAA requires designation of attainment and nonattainment areas with respect to state 

ambient air quality standards. The CCAA also requires that local and regional air districts 

expeditiously adopt and prepare an air quality attainment plan if the district violates state air 

quality standards for CO, SO2, NO2, or ozone. These air quality attainment plans are specifically 

designed to attain these standards and must be designed to achieve an annual 5% reduction in 

district-wide emissions of each nonattainment pollutant or its precursors. Where an air district is 

unable to achieve a 5% annual reduction in district-wide emissions of each nonattainment 

pollutant or its precursors, the adoption of ―all feasible measures‖ on an expeditious schedule is 

acceptable as an alternative strategy (Health and Safety Code Section 40914(b)(2)). No locally 

prepared attainment plans are required for areas that violate the state PM10 standards, but the 

ARB is currently addressing PM10 attainment issues.

The CCAA requires that the state air quality standards be met as expeditiously as is practicable 

but, unlike the federal CAA, the CCAA does not set precise attainment deadlines. Instead, the 

CCAA establishes increasingly stringent standards for areas that will require more time to 

achieve the standards.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 165

Based on 2006 California ARB designation, Madera County is in non-attainment for PM10, PM2.5

and for ozone for State Air Quality standards. Mariposa County is in non-attainment for ozone 

for State Air Quality standards. For all other criteria pollutants, both counties are either 

unclassified or considered in attainment for State Air Quality Standards.

Local Air Districts

Local districts are given the responsibility to develop programs and plans for achieving both 

Federal and State air quality standards and are given the authority to implement control measures 

to reduce emissions of each nonattainment pollutants or its precursors. This is implemented

through the use of Rules and Regulations. 

Smoke Management

In accordance with the California Code of Regulations, Title 17, all persons or entities subject to 

subchapter 2 Smoke Management Guidelines for Agricultural and Prescribed Burning shall 

comply with the requirements therein and those requirements adopted by applicable districts in 

local smoke management regulations. Such persons or entities proposing to conduct prescribed 

burning must submit a smoke management plan to the air district of jurisdiction and: 1) receive a 

permit to burn, 2) receive authorization to burn on a given day, and 3) maintain communication 

with the local air district and report on the status of the burn until it is concluded.

San Joaquin Valley Air Pollution Control District

As agreed upon by San Joaquin Valley Air District staff and the Southern Sierra Interagency 

Smoke Management Group, all land managers planning to implement prescribed fire treatments 

will follow the Unified Guidelines and Procedures for Smoke Management, which includes the 

submission of a required Prescribed Fire Burn Plan and Smoke Management Summary. These 

are reviewed by district personnel and are conditionally approved. Burners are required to 

register prescribed burns prior to the fall burn season and authorization to burn is required prior to 

ignition based on air quality conditions and forecasts. For Prescribed Understory burning, seven 

days prior to ignition a Prescribed Fire Ignition Advisory form must be completed and submitted 

to district meteorology and compliance staff to begin receiving forecast for burn day potential. 

Participation on daily smoke management conference calls for burn project coordination is also 

required on a daily basis prior to and during implementation. On the day of ignition, final 

approval must be received from the compliance officer at the district. Pile burning approval is 

received through the calling the Hazard Reduction Burning phone number on a daily basis. A 

burn fee is applied to the total blackened acres accomplished on a yearly basis. These conditions 

are enforced through Air District Rules and Regulations (Rule 4103, Rule 4106).

Mountain Counties Air Pollution Control District

A Smoke Management Plan (SMP) is required for all prescribed burns, upon review and 

approval a burn permit will be issued with a fee for issuance. For Prescribed Understory burning, 

seven days prior to ignition a Controlled Burn form (CB-3) must be completed and submitted to 

the district compliance staff and to California Air Resources‘ Meteorology to begin receiving 

forecast for burn day potential. Participation on daily smoke management conference calls for 

burn project coordination is also required on a daily basis prior to and during implementation. 

On the day of ignition, final approval must be received from the compliance officer at the district. 

Pile burning approval is received through the Prescribed Fire Information Reporting System 

website on a daily basis. 
Chapter 3: Affected Environment and Environmental Consequences

166 Sierra National Forest

Prevention of Significant Deterioration

The Prevention of Significant Deterioration (PSD) provisions of the CAA require measures to 

―preserve, protect and enhance the air quality in national parks, national wilderness areas, 

national monuments, national seashores, and other areas of special national or regional natural, 

recreation, scenic or historic value.‖ The most stringent requirements for air quality apply to 

those established as Class I areas. These include international parks, national wilderness areas 

greater than 5,000 acres, national memorial parks greater than 5,000 acres, and national parks 

greater than 5,000 acres, and national parks greater than 6,000 acres established prior to August 7, 

1977.

There are no Class I airsheds within the project area. However, there are Class I airsheds nearby 

that must be considered and protected. These airsheds are listed in the Table below.

Table 37. Class I airsheds near the Sugar Pine Adaptive Management Project area.

Class I Airshed Proximity to Project Area

Yosemite National Park Southern Park boundary approximately 2 miles 

North of project area.

Ansel Adams Wilderness Area Western wilderness boundary approximately 

10 miles East of project boundary.

Visibility Protection

Visibility is an air-quality related value that is protected in all federal Class I areas. Since 1984, 

states have been required to protect the visibility in national parks and wilderness areas, as 

mandated by the 1977 Clean Air Act Amendments. The 1977 amendments established a national 

goal for the ―prevention of any future and the remedying of any existing impairment of visibility 

in mandatory Class I federal areas which impairment results from manmade pollution.‖ The 

regulations specifically require states to consider strategies for reducing visibility impairment 

from prescribed burning.

Methodology for Analysis 

For each alternative proposed for the Sugar Pine Adaptive Management Project, associated 

emissions are calculated. This is used to determine if any alternatives total direct and indirect 

emissions fail to be (1) below Federal de minimus thresholds, in this case thresholds for ozone 

(precursors NOx and VOC) and PM-10, or (2) considered regionally insignificant (less than 10% 

of the area‘s total emissions inventory for that particular pollutant). If any alternative‘s estimated 

emissions do not meet either of these conditions, a General Conformity Determination must be 

performed to ascertain how the proposed action would conform to the applicable SIP. 

Emissions Modeling-Smoke 

Four pieces of information are needed to calculate potential emissions produced from either 

wildfire or prescribed fire; acres burned, fuel loading, fuel type and type of burning (pile, 

understory or wildfire) that can determine the amount of fuel consumed. The actions proposed by 

each alternative are used to estimate these as well as information within the Fire/Fuels ReportSugar Pine Adaptive Management Project. Associated emissions for criteria pollutants are 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 167

derived utilizing an emissions spreadsheet developed and approved for prescribed fire emission

reporting purposes. This form was developed and built by the Interagency Smoke Management 

Group and San Joaquin Valley APCD staff from emission formulas from publications (EPA, AP42).

Emissions Modeling- Road Work; Mechanical Treatments

Information needed to calculate associated emissions produced by vehicular traffic from road 

work and mechanical treatments included in Alternatives 2, 3, and 4 (thinning operations, 

mastication and dozer piling) are; type of equipment and the number of hours this equipment is 

expected to run. The actions proposed by each are used to estimate these. Equipment hours are 

based on average production rates from similar projects. Equipment typically used for this type 

of work include heavy duty diesel-powered vehicles (tractor-trailers [log trucks/chip vans], 

wheeled skidders and loaders, track type dozers/masticators, road graders and potentially a 

stationary chipper), and smaller gasoline powered engines such as chainsaws. Emission factors 

for criteria pollutants are from ―A Desk Reference for NEPA Air Quality Analysis‖ (CH2Hill 

1995) and converted to total tons of pollutant.

Fugitive Dust Emissions

The Forest Service routinely requires timber sale operators to abate dust during use of the forest 

development roads. This is required for several reasons among which are: retaining road surface 

fines which help keep the larger supporting aggregate together; reduce dust visibility traffic 

hazards; reduce environmental dust plumes; and minimize loose fine material accumulations 

which can create muddy, road rutting conditions. (Lowe, 1994)

Fugitive (visible) dust emissions (VDE) by general vehicle movement are calculated at 10 pounds 

per day for 5 vehicles per day on unpaved roads. This figure is reduced to 3.63 pounds per day

per mile of VDE after dust abatement. This is accomplished through watering of roads or other 

dust abatement measures which are incorporated into the project design. Dust abatement is 

required for roads below 3000 feet in elevation in the San Joaquin Valley Air Basin. The Sugar 

Pine Adaptive Management Project is above 3,000 feet in elevation and is exempt from 

Regulation VIII, Rule 8011 General Requirements (www.valleyair.org), though dust abatements 

is still required by the Forest Service.

Because of this exemption and the use of abatement measures when they are not a requirement, 

specific calculations for fugitive dust emissions are not used in the analysis of potential emissions 

from this project, but are considered part of the direct, indirect and cumulative effects. 

Affected Environment

The Sugar Pine Adaptive Management Project is within two air basins that are regulated by two 

air districts: San Joaquin Valley Air Pollution Control District (Madera County) and Mountain 

Counties (Mariposa County). Each are responsible for implementing and regulating sources that 

degrade air quality and are responsible for meeting Federal and State air quality standards. The 

California Air Resources Board has oversight authority to monitor performance of district 

programs. 

The affected environment in this analysis includes areas that would or could experience 

degradation as a result of the actions proposed. Though Mariposa County (within Mountain 
Chapter 3: Affected Environment and Environmental Consequences

168 Sierra National Forest

Counties Air Basin) is considered in nonattainment for both federal and state standards for ozone, 

Madera County (within San Joaquin Valley Air Basin) is considered in nonattainment for state 

PM10, PM2.5 and ozone standards. The air basin is in federal attainment (maintenance level) for 

PM10, but is in federal nonattainment for PM2.5 and is expecting a reclassification from serious to 

extreme nonattainment for 8-hour ozone. San Joaquin Valley Air Basin versus Mountain 

Counties (Mariposa County) is considered the air basin downwind from the Sugar Pine Adaptive 

Management Project and is the air basin direct, indirect and cumulative impact analysis is focused 

on.

Air quality in the San Joaquin Valley air basin is among the poorest in the State. With the hot, 

dry summers, the San Joaquin Air Basin, in 2008, experienced 127 days above the federal 

standard for 8-hour ozone and 150 days above the state standard. Madera County, by itself, was 

above the federal 8-hour ozone standard 24 days and 46 days above the state standard 

(www.arb.gov ; Trends Summary). For PM10 in 2008, the estimated days over the federal 

standard was five, with 182 days estimated over the state standard. For PM2.5 in 2008, the annual 

average days over the federal standard were 24, with 21 days over the state standard 

(www.arb.gov ; Trends Summary).

Typically vegetation management activities such as thinning operations, road 

maintenance/reconstruction, mastication and dozer piling of natural and activity generate fuels 

take place during the summer months when equipment can reach treatment units and when there 

is less potential for wet soil conditions. During summer and fall months, poor ventilation occurs 

with relatively stable air masses over the area. Ozone concentrations can reach peak levels when 

strong sunshine and temperatures are above 95 ° F and accompany periods of poor ventilation. 

Although ozone is not released directly into the atmosphere, it is produced by chemical reactions 

involving VOCs and NOx. The meteorological conditions favorable to significant ozone 

formation occur only during the summer months.

Typically prescribed fire activities are planned for the fall, winter and spring months. These 

months of the year provide cooler, moister conditions and the greatest potential for unstable air 

masses to occur with storm system passage. Approval for prescribed burning operations by the 

Air Pollution Control District are typically based on atmospheric conditions where instability will 

allow for better ventilation into the upper atmosphere and transport winds that will carry smoke 

away from sensitive receptors. Because smoke from prescribed burns can last anywhere from a 

few hours to several days after ignition is completed, there is a potential for weather patterns to 

change from unstable to stable over the course of project implementation. This could ―cap‖ 

ventilation into the upper atmosphere and allow smoke to settle into sensitive areas. This can also 

occur during night time hours, as diurnal wind patterns produce light down slope winds with the 

majority of sensitive receptors down slope from the project area. When planning the use of 

prescribed fire, managers will evaluate with the Air Pollution Control District the size (acres) of

units planned and length of time smoke production is expected to be the greatest. This in 

conjunction with meteorological condition forecasts will be used to minimize the potential of this 

occurring.

In conjunction with the typical period when prescribed burn implementation occurs, is an 

increased use of wood burning stoves and hazard reduction burning by local residences in the 

area. There are restrictions in place on the valley floor (residences below 3000 feet in elevation) 

to limit the use of wood burning stoves during poor dispersion days, but because older residences 

above 3000 feet in elevation typically only have wood burning stoves as their sole source of heat, 

there are little restrictions above 3000 feet elevation. Hazard reduction burning is regulated by a 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 169

permitting process as well as burning only on ―affirmative‖ burn days when meteorological 

conditions are adequate for good dispersion and dilution of pollutants. These affirmative burn 

days are fairly sporadic and can lead to high numbers of residences burning on the same day, 

especially during weekends. The San Joaquin Valley APCD has created an educational program 

for the public on how to burn ―cleaner‖ and presented some of the Best Available Control 

Measures for Hazard Reduction burning activities.

State Highway 41, which borders the west boundary of the Sugar Pine Adaptive Management 

project, is the southernmost route into Yosemite National Park. Vehicular traffic increases during 

the summer months with visitors travelling into the park, but is also used to access Badger Ski 

Area in the park during the winter months. 

Sensitive receptors are population centers such as towns and villages, campgrounds, trails, 

hospitals, nursing homes, schools, roads, airports, mandatory Class I Federal areas, nonattainment 

areas, etc. where smoke and air pollutants can adversely affect public health, safety and welfare. 

Sensitive receptors that were identified and considered within 100 kilometers (10 miles) of the 

project area are listed in the table below.

Table 38. Sensitive receptors identified within 10 miles of the Sugar Pine Adaptive 

Management Project.

Sensitive Receptor 

Type

Location

Towns, Communities Sugar Pine, Fish Camp, Yosemite Mountain Ranch, Oakhurst, Wawona, 

Ahwahnee, Nipinnawassee, Cedar Brook, Bass Lake, Ponderosa Basin, 

Worman Mill

Recreation Areas Miami Motorcycle Trails, Westfall Day Use, Lewis Creek Natural Scenic 

Trail, Goat Meadow Winter Sports Area, Yosemite Sugar Pine Railroad, 

Yosemite Pack Station, Bass Lake 

Campgrounds Nelder Grove, Big/Little Sandy, Kelty Meadow, Fresno Dome, 

Summerdale, Summit, Soquel, Greys Mtn., Bass Lake C.G.s

FS Work 

Center/Ranger 

Station

Westfall, Batterson, Oakhurst Visitor Information Center

Roads State Highway 41, Forest Service and County Roads

Class I Federal areas See Table 2 for Class I areas

Other Private lands within and adjacent to the project area

Desired Condition 

The desired condition for Air Quality and Visibility in the Sugar Pine Adaptive Management 

Project is to meet the purpose and need for the Sugar Pine Adaptive Management Project while 

accomplishing the Sierra National Forest Land and Resource Management Plan goal to manage 

Forest activities so air quality is compatible with federal, state and local laws, including a

program that achieves the Clean Air Act responsibilities.
Chapter 3: Affected Environment and Environmental Consequences

170 Sierra National Forest

Environmental Consequences 

Mitigation and Monitoring 

Mitigation Techniques-Best Available Control Measures

The most effective means of controlling wildfire emissions is to prevent the occurrence of 

wildfires. A frequently used technique for reducing wildfire occurrence is "prescribed" or 

"hazard reduction" burning. This type of managed burn involves combustion of dead-and-down 

woody debris, litter and some underbrush to prevent fuel buildup under controlled conditions, 

thus reducing the danger of a wildfire. Properly executed, controlled burning is expected to 

produce fewer total emissions than wildfire. The reasons for this include: (1) prescribed fires 

typically burn fewer acres than wildfires, (2) prescribed fires are managed under weather 

conditions that present a small risk of crowning (i.e., burning through the crowns), and (3) 

prescribed fires are set under carefully controlled conditions of high fuel moisture contents, which 

reduces the total consumption of large woody material and duff. (CHM2HILL, 1995).

General: 

Specific mitigation techniques to reduce fire emissions include fuel loading reduction and fuel 

consumption reduction, techniques for optimizing flaming combustion, and avoidance techniques. 

Seasonal burning effectively combines these mitigation measures. Late fall, winter and spring 

burning results in reduced fuel consumption and emissions due to higher fuel moistures. 

Generally unstable atmospheric conditions during these seasons can lead to better smoke 

dispersion. Winter burning can result in less visibility impairment when conducted under 

conditions of natural impairment such as clouds and fog.

Commonly used reduction techniques include: improved utilization, burning of unit after harvest 

but before new live fuels appear, burning in the springtime prior to "green-up", burning 

concentrations of fuel rather than the entire area, burning when 1,000 hour fuels moistures are 

high, and burning when the duff is wet (during winter or spring).

Techniques to optimize flaming combustion include: burning of piled fuels rather than broadcast 

burning, reducing the amount of dirt in piles, and rapid ignition to create a high intensity fire.

Avoidance techniques include: burning on cloudy days when the plume and residual smoke 

cannot be seen, during periods of atmospheric instability for better smoke dispersal, and during 

periods of low visitor use.

As part of the Prescribed Fire Burn Plan documentation, these techniques are utilized to reduce 

the potential impacts of emissions produced by prescribed fire implementation. Some, such as 

improved wood utilization (biomass operations) and piling of remaining fuels are incorporated in 

the design of this project and its Alternatives. In completing the Smoke Management Plan, as 

part of the burn plan, managers must record the techniques and mitigations that will be utilized to 

reduce potential emissions as well as the desired meteorological conditions that will provide 

adequate dispersion of smoke away from sensitive receptors. During past prescribed fires 

implemented within the vicinity of the Sugar Pine Adaptive Management Project techniques such 

as limiting the number of acres burned per day, size of burn units, burning during periods of 

instability, limiting time of active ignition, pile burning vs. broadcast burning, mastication vs. 

burning as a means to reduce vertical fuel loading and thinning operations were employed to 

reduce impacts to sensitive receptors listed in Table 34 and were successful in mitigating impacts 

to sensitive receptors in the area. These mitigations and techniques will be utilized, as needed, 

for prescribed fire activities. 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 171

Firefighter Safety

Techniques employed to minimize impacts to the general public are also employed to minimize 

the impacts from pollutants inhaled by the firefighters implementing prescribed fire. Prior to the 

implementation of prescribed fires, all personnel must review the Job Hazard Analysis prepared 

for the project that is to be implemented. This Job Hazard Analysis list the potential hazards 

associated with the task at hand and provide mitigation measures that will be utilized. To 

minimize the effects caused by smoke inhalation, continuous monitoring of firefighters in areas 

where heavy concentrations of smoke are and ―rotating‖ individuals in and out of these areas as 

well as adjusting scheduled burning to allow for ―breaks‖ between burns are some of the ways 

used to accomplish this. 

Monitoring Techniques

As part of prescribed fire implementation, burn bosses are to make observations on a regular basis 

of the smoke conditions that are being created by implementation. These include the travel 

direction and dispersion quality of smoke such as smoke settling into smoke sensitive areas and

continued or potential for visibility degradation especially across main travel routes. When 

possible, lighting techniques and/or burn operations are changed to minimize the continuance of 

these impacts.

As part of the Prescribed Fire Burn Plan, the public will be informed of planned prescribed fire 

implementation via local newspaper, media (radio/TV) and/or in some cases personal 

communications. At the minimum, the news release will include planned dates, length of time 

prescribed fire smoke maybe in the area, location of the burn and contact numbers for 

information.

Alternative 1 – No Action

Direct, Indirect and Cumulative Effects

No direct effects from management actions to air quality or visibility would occur under this 

alternative since no treatments would be completed outside of that which is already permitted or 

authorized.

Indirect and cumulative effects include the potential for unplanned ignitions and uncontrolled 

wildfires to occur in the area. The resultant smoke caused by these would have large amounts of 

emissions released and could potentially be of long duration. Values measured such as PM10 and 

visibility range used to determine the Health-Protective Value would be in the ranges assumed to 

be Unhealthy. Values associated with this rating are PM10 ranging from 176 to 300 μg/m3 and 

visibility of 1.24 to 2 miles (considered moderate smoke conditions). This would be considered 

the lower of the Health-Protective Values a wildfire would produce, if it occurred in the area. It

is anticipated that for short periods of time the values may rise to the levels considered Very 

Unhealthy or perhaps Hazardous. The Statewide Emission Inventory in 2002 reported emissions 

(tons/day, annual average) from wildfires (Ahjua 2006) and is demonstrated in the table below.
Chapter 3: Affected Environment and Environmental Consequences

172 Sierra National Forest

Table 39. Statewide Emission Inventory 2002 for Natural Sources-Wildfire

Emissions Total 

Organic 

Gases

Reactive 

Organic 

Gases

Carbon 

Monoxide

Nitrogen 

Oxides

Sulfur 

Oxides 

PM10

Natural Sources: 

Wildfire

6,522 3,046 17,474 3,441 302 2,418

The high summer temperatures and light wind speeds that occur during the summer months, 

places a cap on valley air with no means for cleansing itself by dispersion or transport. Because of 

the poor air quality associated with the San Joaquin Valley Air Basin it does not take large 

amounts of additional emissions to degrade air quality into unhealthy ranges especially in the 

summer and fall months, where storm systems are less likely to occur and disperse smog and 

emissions. Emissions from a wildfire could potentially have long lasting impacts beyond the 

initial burning period because of this. Uncontrolled wildfires are clearly responsible for the most 

widespread, prolonged, and severe periods of air quality degradation (Sugihara, N. 2006). For 

comparison purposes with the Alternatives presented to reduce the intensity and spread of 

wildfire, if the acres within the Sugar Pine Adaptive Management Project were affected by an 

uncontrolled wildfire during the typical fire season conditions the emissions produced from that 

wildfire would be as demonstrated in Table 40.

Table 40. Potential emissions if a wildfire were to burn within the entire Sugar Pine 

Adaptive Management Project boundary.

Emissions:

Fuel 

Type 

Total 

Acres

Fuel 

Loading 

(Tons/ 

acre)

Total 

tons

Tons 

PM10

Tons 

PM2.5

Tons 

Nox

Tons 

SO2

Tons 

VOC

Tons 

CO

Forest 5400.00 20 108000 1323.0 1188 189.0 5.40 783.0 12582.0

Common to Alternatives 2, 3, and 4

Treatments are proposed to reduce surface, ladder fuels and some aerial fuels to meet the purpose 

and need of reducing the intensity and spread of wildland fires as well as reduce stand densities. 

This is to occur, if these alternatives were chosen, through the use of mechanical methods 

(thinning from below, mastication and biomass operations) as well as management ignited fire in 

the form of prescribed fires such as pile burning, understory burning and/or broadcast burning. 

Prescribed fire would be applied to the project area for three purposes: (1) as a final ―cleaning‖ 

after vegetation management treatments to further reduce 1, 10 and 100 hours fuels (those fuels 

that have the greatest influence on fire spread); (2) to maintain the lower levels of the 1, 10, and 

100 hours fuels; (3) to reintroduce the fire element back into a fire dependent ecosystem.

The Sugar Pine Adaptive Management Project is one of two projects being studied by University 

of California through what is called the Sierra Nevada Adaptive Management Project (SNAMP). 

With this, management actions from the selected alternative will need to be completed within two 

years after beginning implementation to conform to timelines set by this study. This includes 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 173

harvesting operations and post harvest operations (reduction of surface fuel loadings, where 

needed), if Alternative 2, 3 or 4 were selected. To meet this timeframe, the type of treatments 

proposed within the action alternatives (Alternatives 2, 3 and 4) are proposed to reduce ladder 

fuels and reduce the amount of surface fuel treatments needed (referred to as post activity 

treatments). This is proposed to be completed with the use of biomass operations, where 4 to 10 

inch diameter conifers would be removed from the treatment areas to meet the fire/fuels 

objectives, rather than utilizing hand cutting, piling and burning as would typically be used to 

meet fire/fuels objectives.

Emissions from smoke produced by prescribed fire implementation are estimated using the 

number of acres to be burned, the surface fuel loading of the area being burned and the amount of 

consumption. With the use of biomass operations in Alternative 2, 3 and 4 it is estimated 35 to 

40 percent of the treatment area acres where treatments are actually occurring (approximately 250 

to 350 acres) would need to have some form of post activity treatment to reduce surface fuel 

loading to meet fire/fuels objectives. This would be accomplished through spot dozer piling and 

burning. The treatment of these fuels would need to be completed within the two year 

implementation timeline. 

Within the treatment areas and based on the criteria provided in the Fire/Fuels Design Criteria 

Common to all Alternatives, it is estimated that an additional 10 to 25 percent of the total 

treatment area acres (approximately 290 to 730 acres) could have prescribed fire used for 

maintenance treatment of surface fuels. There is a total of 215 acres that is proposed to utilize 

prescribed fire as the primary treatment type (RX treatment areas). Treatments involving the 

application of prescribed fire over a broad area and needing to have specific conditions prior to 

ignition, such as the case with these types of burns, these treatments do not have the constraint of 

needing to be completed within the two year implementation period. It is estimated that, as 

conditions permit, these types of prescribed fires could take up to 10 years to fully implement and 

would be used, as needed, to maintain surface fuel loadings at or below 10 to 20 tons/acre.

Dependent on where and how prescribed fire treatments are being utilized, the fuel loading can 

range from 4 to 34 tons per acre and be in the form of machine or hand created piles and/or in 

concentrations across a broad area such as the case in understory burning. On average the fuel 

loading for an area requiring prescribed fire as a primary treatment, maintenance and/or post 

activity treatment would be 20 tons/acre. 

The main focus of prescribed fire implementation is to reduce surface fuel loadings that 

contribute to fire behavior rates of spread and flame length the greatest. These are the 1, 10 and 

100 hour time lag categories (mainly needles, twigs and branches less than 3 inches in diameter). 

Prescribed fire burn plans set objectives for what percent consumption of these fuels are to be 

accomplished by the implementation of the prescribed fire. For pile burning, burn plan objectives 

typically set the objective at 75 to 80 percent consumption. Pile burning is conducted when the 

fuels have had a period of time to dry and are no longer green. For understory burning, burn plan 

objectives typically set the objectives at 60 to 70 percent consumption (or reduction) of these 

fuels, though this would not be across the entire burn area. A typical understory burn is 

implemented to create a ―mosaic‖ burn pattern, leaving patches of unburned areas amongst 

burned areas.
Chapter 3: Affected Environment and Environmental Consequences

174 Sierra National Forest

Alternative 2 – Proposed Action

Alternative 2 proposes a higher intensity of treatments to meet both fire/fuels objectives and 

forest health objectives. With this it is estimated that Alternative 2 would have more acres 

requiring post activity treatments to be accomplished. As stated above, common to all action 

alternatives, all thinning and post activity treatments need to be completed to meet SNAMP study 

timeframes to collect post treatment data. This would include the completion of prescribed 

burning of both dozer and hand piles created. Because thinning and piling operations need to be 

completed before pile burning can occur, it is estimated it will take 2 years to complete the 

prescribed pile burning which by itself will limit the number of acres per year that can be 

accomplished. The table below estimates the emission potential for the highest total acres of pile 

burning anticipated from Alternative 2 and the estimated emission potential per year for the 

highest total acres of pile burning. 

Table 41. Total tons of emissions for estimated Prescribed Pile Burning and Prescribed Pile 

Burning estimated per year.

Emissions:*

Fuel 

Type 

Estimated 

Total 

Acres

Fuel 

Loading 

(Tons/ 

acre)

Total

tons

Tons 

PM10

Tons 

PM2.5

Tons 

Nox

Tons 

SO2

Tons 

VOC

Tons 

CO

Pile_Slash 350.00 20 7000 27.30 25.55 18.20 0.04 22.05 231.00

Estimated 

Per Year 

Acres

Pile_Slash 175.00 20 3500 13.65 12.78 9.10 0.02 11.03 115.50

*Note: Pile_Slash would be pile burning emissions. PM10 =Particulate matter 10 microns in size; PM2.5 = Particulate 

matter 2.5 microns in size; Nox = Nitrogen Oxide (considered a precursor to ozone); SO2 =Sulfur Dioxides; VOC = Volatile 

Organic Compounds (considered a precursor to ozone). 

It is anticipated that understory burning would be very limited within the project area until after 

the SNAMP study post treatment data is gathered (estimated at an additional 2 years after 

implementation is completed). These treatments are to be used to maintain surface fuel loadings 

(0-3‖ in diameter fuels) between 10 to 20 tons/acre or lower. These prescribed fire treatments 

would be accomplished after thinning and post activity pile burning treatments were 

accomplished. Emissions created by this type of prescribed burning is typically higher than pile 

burning and is why some form of pretreatment of fuels (thinning, biomass and/or mastication) is 

typically completed prior to understory (broadcast) burning. This reduces the amount of fuel 

being burned (tons/acre). The table below estimates the emission potential for the highest total 

acres of understory burning anticipated from Alternative 2 and the estimated potential emissions 

per year for the understory burning.

Because of variable weather conditions during the late fall, winter and spring months when 

prescribed burning would be implemented, not every day would be considered an affirmative 

burn day. It is estimated that out of the seven months (November to May) when prescribed 

burning would be implemented there would be a total of 150 days (65% of the total 210 days) 

available to burn per year. This would be decreased further since prescribed burning typically 

does not occur on weekends, when residences are usually at their cabins or houses. This would 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 175

leave 100 days available for prescribed fire implementation per year or 200 days for 

implementation of prescribed burning in Alternative 2. 

Table 42. Total tons of emissions for estimated Prescribed Understory burning and 

Prescribed Understory burning estimated per year.

Emissions:*

Fuel 

Type 

Estimated 

Total 

Acres

Fuel 

Loading 

(Tons/ 

acre)

Total

tons

Tons

PM10

Tons 

PM2.5

Tons 

Nox

Tons 

SO2

Tons 

VOC

Tons

CO

Forest 945.00 15 14175 173.64 155.93 24.81 0.71 102.77 1651.39

Estimated 

Per Year 

Acres

Forest 100.00 15 1500 18.38 16.50 2.63 0.08 10.88 174.75

*Note: Forest would be understory burning emissions. PM10 =Particulate matter 10 microns in size; PM2.5 = Particulate 

matter 2.5 microns in size; Nox = Nitrogen Oxide (considered a precursor to ozone); SO2 =Sulfur Dioxides; VOC = Volatile 

Organic Compounds (considered a precursor to ozone). 

Table 43. California Air Resources Board 2008 Estimated Annual Average Daily Emissions 

for Forest Management-Burning and Disposal for the San Joaquin Valley Air Basin and 

annual average for the estimated 200 days of prescribed burning in Alternative 2. 

Emissions*

(Tons/day)

TOG ROG CO NOx SOx PM

Forest 

ManagementBurning (Daily 

ave.)

2.97 1.69 27.03 0.83 0.26 2.85

Forest 

ManagementBurning (200 

days)

594 338 5406 166 52 570

*TOG= Total Organic Gases; ROG = Reactive Organic Gas (equivalent to VOC=Volatile Organic Compounds); CO= Carbon 

Monoxide; NOx= Nitrogen Oxide; SOx= Sulfur Oxide; PM= Particulate matter.

When comparing the estimated total emissions for the implementation of the prescribed burning 

in Alternative 2 with the annual average emissions in the San Joaquin Valley Air Basin for Forest 

Management-Burning and Disposal expanded to 200 days, Alternative 2 would contribute 35% of 

CO, 26% of NOx, 1% of SOx, and 40% of PM or less of that emitted. When compared to the 

average annual emission in the San Joaquin Air Basin for all Managed Burning emissions, 

Alternative 2‘s prescribed burning emissions would be 5% or less for all pollutants of that 

emitted. 
Chapter 3: Affected Environment and Environmental Consequences

176 Sierra National Forest

Emissions from mechanical treatments/Road maintenance-reconstruction activities

Equipment hours are based on average production rates from similar projects. Most of the 

material will be thinned by track type tractor and skidded (wheeled tractor/loader). Dependent on 

contractor, biomass chipping may or may not occur on the landing. Material may be removed in 

whole form to utilization facility. Piling and mastication of activity created slash and brush will 

be with a track type tractor. For this analysis all emissions are based upon use of wheeled 

skidders and loaders, heavy duty diesel powered highway truck and track type dozer or dozer 

with mastication head. Road maintenance and reconstruction activities utilize motor graders. 

Commercial logging within the project area under Alternative 2 is estimated to produce 4200 

m.b.f. (thousand board feet) and 3941 bone dry ton volume of biomass material. A typical size 

load for a logging truck is 5 m.b.f. per log truck and 320 bone dry ton volume for chip vans. 

The nearest sawmill to the Sugar Pine Adaptive Management Project is Sierra Forest Products in 

Terra Bella, CA. It is 134 miles one way to this mill and is estimated to take a loaded log truck 3 

hours to drive one way to the mill. The same haul distance and time to facility is used for biomass 

material, but the delivery of this material may be shorter or longer dependant on where the 

material is actually taken. 

Because of Limited Operating Periods for wildlife species and contractual clauses that prevent 

work during wet weather, mechanical treatments usually occur during the months of June through 

October, but can be shortened. Excluding weekends this would be a total of 130 days of 

operations per year.

Table 44. Total tons of emissions for mechanical treatments and road maintenancereconstruction activities for the completion of operations in Alternative 2.

Type of 

Equipment

Total 

Number 

of Hours

PM Exhaust 

Hydrocarbons NOx CO SOx

Wheeled 

Tractor 1344 0.09 0.13 0.85 2.48 0.06

Wheeled 

Loader 378 0.01 0.02 0.16 0.04 0.01

Heavy Duty 

Diesel 

Powered 

Truck

7404 0.95 0.71 15.42 6.64 1.68

Track Type 

Tractor 14,000 0.78 0.85 8.82 2.42 0.96

Motor grader 77 0.00 0.00 0.03 0.01 0.00

Misc. 

(Chipper) if 

used on 

landing

90 0.01 0.01 0.08 0.03 0.01

Total for 

Entire 

Project

23292 1.84 1.71 25.36 11.62 2.72
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 177

As with the post activity treatments for prescribed burning, all mechanical treatments (thinning, 

mastication, biomass operations, road work and dozer piling) would need to be completed within 

the two year SNAMP study timeline. It is anticipated this would not be completed in the first 

year of implementation, but over the two year period, having the emissions spread over a two 

year period, thus the potential emissions would be half in one year and half in the next year.

Direct and Indirect Effects

Of the management actions proposed in Alternative 2, prescribed burning (smoke generated 

pollutants) has the greatest potential for direct effects. The degree and potential for sensitive 

receptors (listed in Table 38) to be directly affected by smoke is dependent on distance and 

direction of smoke travel at the time prescribed fire is being implemented. This would also be 

true with local visibility and potential for smoke to move into the Class I airsheds (listed in Table 

37) and cause obscured visibility within them. With the mitigation and monitoring techniques 

listed in the above section as well as following air district Rules and Regulations associated with 

pre, during and post prescribed burn implementation as well as open communications between the 

air district and managers, these direct effects would be of short duration (confined to the period of 

time for ignition and residual burn down) and generally small in scale (confined by the number of 

acres burned in that period of time). These are two factors that are typically utilized by managers 

and air district compliance staff to minimize duration and scale of impacts.

Additional management actions proposed in Alternative 2 would create dust (PM) and vehicle 

emissions. Dust abatement by watering roads, while not required above 3,000 feet elevation, 

would reduce PM air pollution that could affect identified sensitive receptors. The closest mill 

for the products offered is in Terra Bella, California, and 134 miles from the project area. The 

most likely haul route would include Madera, Fresno and Kings Counties, all within the San 

Joaquin Air Basin. The table below shows 2008 estimated annual average emissions from all onroad motor vehicles and heavy duty diesel vehicles for San Joaquin Air Basin derived from tables 

produced by the California Air Resources Board (www.arb.gov).

Table 45. California Air Resources Board 2008 Estimated Annual Average Daily Emissions 

for On-Road Motor Vehicles for the San Joaquin Valley Air Basin.

Emissions 

(Tons/day)

TOG ROG CO NOx SOx PM

On-road 

Motor 

Vehicles

87.0 79.2 705.6 330.0 0.7 14.6

*TOG= Total Organic Gases; ROG = Reactive Organic Gas; CO= Carbon Monoxide; NOx= Nitrogen Oxide; SOx= Sulfur Oxide; 

PM= Particulate matter.
Chapter 3: Affected Environment and Environmental Consequences

178 Sierra National Forest

Table 46. California Air Resources Board 2008 Estimated Annual Average Daily Emissions 

of Heavy Duty Diesel Trucks for the San Joaquin Valley Air Basin and annual average for 

the estimated 260 days of mechanical operations in Alternative 2 .

Emissions*

(Tons/day)

TOG ROG CO NOx SOx PM

Heavy duty 

diesel trucks 

(Daily ave.)

19.58 17.20 70.32 236.75 0.22 10.10

Heavy duty 

diesel trucks 

(260 days)

5090.8 4472 18283.2 61555 57.2 2626

*TOG= Total Organic Gases; ROG = Reactive Organic Gas; CO= Carbon Monoxide; NOx= Nitrogen Oxide; SOx= Sulfur Oxide; 

PM= Particulate matter.

When comparing the estimated total emissions for the implementation of the mechanical 

treatments in Alternative 2 with the annual average emissions in the San Joaquin Valley Air 

Basin for heavy duty diesel trucks expanded to the estimated 260 days of operations, Alternative 

2 would contribute 0.06% of CO, 0.04% of NOx, 4.8% of SOx, and .07% of PM or less of that 

emitted. 

When compared to the total emissions that would be produced if a wildfire were to burn through 

the Sugar Pine Project area, Alternative 2 would reduce emissions by 85%. 

Cumulative Effects 

Annual trends in ozone and PM air pollution are decreasing largely due to State regulations for 

vehicle emissions. This is expected to continue as technology and regulations to reduce 

emissions are implemented. In addition, mechanical treatments (harvesting) contribution to air 

pollution in particular appears to be on a downward trend likely due to decreased logging activity. 

The incremental effects of Alternative 2 when added to past, present and foreseeable future 

activities, are not likely to influence this trend of reduced logging associated emissions.

From past implementation of prescribed burning on the Bass Lake Ranger District and in 

particular prescribed burns within the vicinity of the Sugar Pine Adaptive Management Project, 

mitigations limiting the number of acres burned per day, burning during optimal transport wind 

directions/speeds, higher mixing heights and the quantity of other prescribed fires being 

conducted are considered prior to air district final approval to reduce potential impacts to 

sensitive receptors. This has been extended into limiting the number of days burning can occur, 

and requiring all active ignitions to end by late afternoon to reduce smoke production at night 

time and to limiting the number of consecutive days burning can occur to reduce the amount of 

emissions produced at any one time. Close communication with the Air Pollution Control 

District compliance staff before and during implementation and monitoring smoke conditions will 

aid in determining if there are impacts on sensitive receptors and Class I airsheds in the area are 

beginning and additional mitigations are required. 

Cumulative effects can be caused by outside influences not associated with the project itself. 

Because of the rural surroundings, many residences utilize wood burning stoves as their main 

source of home heating. Hazard reduction burning is also permitted in rural communities in 

Madera and Mariposa counties. This can lead to cumulative impacts if prescribed fire is 

conducted on what is considered a marginal dispersal day when added to wood stove smoke and 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 179

increased numbers of hazard reduction burns within the communities in or surrounding the 

project area.

Alternative 3

Direct, Indirect and Cumulative Effects

Alternative 3 would not alter the number of acres where ladder and surface fuels are to be 

reduced through treatments, but would alter the amount of post treatment surface fuels (lower 

tons/acre) in treatment area T4 and T3. This reduced amount of post treatment is created by not 

conducting stand density treatments (mid level canopy thinning) in these treatment areas. It is 

anticipated this would not create a significant difference in the estimated emissions calculated for 

Alternative 2. Thus the direct, indirect and cumulative effects would remain similar to those 

under Alternative 2.

Alternative 4

Direct, Indirect and Cumulative Effects

Alternative 4 would not alter the number of acres where ladder and surface fuels are to be 

reduced through treatments, but would potentially have lower amounts of post activity surface 

fuels (tons/acre). As in Alternative 2, prescribed burning would be utilized to reduce surface fuel 

loading as either an initial treatment (understory/broadcast) or as a post activity treatment (pile 

burning). Biomass operations, mastication, road reconstruction/maintenance, but not commercial 

thinning operations would continue to be implemented with Alternative 4. With no commercial 

thinning operations, emissions from mechanical treatments would be reduced significantly from 

Alternative 2 and 3, and would have the potential of reducing the amount of acres in which pile 

burning would be needed reducing the amount of emissions from prescribed burning. Understory 

burning in some areas may no longer be possible because of the potential effects the combination 

of fire and overcrowded trees could have on residual stands reducing the amount emissions from 

prescribed burning further. Thus the direct, indirect and cumulative effects of Alternative 4, 

would be the similar to Alternatives 2 and 3, but would be to a lesser degree. 

Compliance with the Forest Plan and Other Regulatory Direction 

To move towards the desired condition for air quality and visibility set by the Sierra National 

Forest Land and Resource Management Plan goal to manage Forest activities so air quality is 

compatible with federal, state and local laws, including a program that achieves the Clean Air Act 

responsibilities, the Sugar Pine Adaptive Management Project‘s alternatives must meet the 

General Conformity Rule of the Clean Air Act. If the alternatives do not meet the General 

Conformity Rule (below de minimus levels or 10% or less of the total regional emissions), then a 

General Conformity Determination must be completed where the following must be 

demonstrated: 

§51.853

 (g)The Federal agency must meet the criteria for establishing activities that are presumed to 

conform by fulfilling the requirements set forth in either paragraph (g)(1) or (g)(2) of this 

section:
Chapter 3: Affected Environment and Environmental Consequences

180 Sierra National Forest

(1) The Federal agency must clearly demonstrate using methods consistent with this rule 

that the total of direct and indirect emissions from the type of activities which would be 

presumed to conform would not:

(i) Cause or contribute to any new violation of any standard in any area:

(ii) Interfere with provisions in the applicable SIP for maintenance of any 

standard;

(iii) Increase the frequency or severity of any existing violation of any standard 

in any area; or

(iv) Delay timely attainment of any standard or any required interim emission 

reductions or other milestones in any area including, where applicable, emission 

levels specified in the applicable SIP for purposes of:

(A) A demonstration of further progress

(B) A demonstration of attainment; or

(C) A maintenance plan; or

(2) the Federal agency must provide documentation that the total of direct and indirect 

emissions from such future actions would be below the emissions rates for a conformity 

determination that are established in paragraph (b) of this section, based, for example, 

on similar actions taken over recent years. (SJVAPCD, Rule 9110, 2003).

Alternative 2 proposed the greatest amount of management actions that have the potential to 

produce emissions. In completing the conformity analysis this alternative‘s estimated emissions 

are used with the assumption that if a determination is made that it conforms, then Alternatives 3 

and 4 would as well since these alternatives reduce the amount of management actions, 

prescribed burning and thinning operations, occurring.

Presented in the above analysis, estimated total direct and indirect emissions for the Sugar Pine 

Adaptive Management Project management actions will be above de minimus levels for NOx, 

VOC, but not for PM10 when considered on that produced on a yearly basis for project activities. 

When compared to the annual average daily emissions in the San Joaquin Valley Air Basin 

(Regional area) the estimated total project emissions are less than 10% of that emitted. 

California‘s Smoke Management Program (California Code of Regulations, Title 17) along with 

the Rules and Regulations applied to prescribed burning by the San Joaquin Valley Air Pollution 

Control District (Rules 4103, 4106) as well as the Unified Guidelines and Procedures for Smoke 

Management are used by land management agencies to minimize impacts on sensitive receptors 

and to reduce PSD in Class I airsheds. The coordination efforts put forth between land 

management agencies and the San Joaquin Air Pollution Control District staff when prescribed 

burning is being implemented includes bi-annual meetings, daily conference calls, following 

reporting procedures and beginning to utilize the Air Resource Board‘s Prescribed Fire 

Implementation Reporting System (PFIRS). With the implementation of the mitigation measures 

and monitoring techniques that have been utilized in during past actions similar to these, further 

minimization of impacts from management actions can and have been accomplished.

In conclusion, the incremental effects of smoke, dust and emissions created by the proposed 

actions in Alternative 2, 3 and 4 when added to the past, present and foreseeable future activities 

are not expected to: 1) cause or contribute to any new violation of any standard in any area; 2) 

increase the frequency or severity of any existing violation of any standard in any area; or 3) 

delay timely attainment of any standard or any required interim emission reductions or other 

milestones in any area. (CAA Sec 176 (c) (1)) as further defined by San Joaquin Valley APCD 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 181

Rule 9110-General Conformity, §51.853 and is expected to conform to the State Implementation 

Plan for the associated criteria pollutants of NOx, VOC, PM10 and PM2.5. This determination 

would be in compliance with the Sierra National Forest Land and Resource Management Plan‘s 

goals as well as meet the Standards and Guidelines written for air quality and visibility.

Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 183

Engineering / Transportation __________________

The direct, indirect and cumulative effects to the transportation resource are summarized from the 

Engineering Report for the Sugar Pine Adaptive Management Project (Hosford, A. 2008).

Affected Environment

The transportation system (roads) within the project area provides needed access for public use of 

the National Forest and access to private lands. Most roads receive low traffic volume, but are 

considered important by their users for dispersed recreation experiences of many types. 

Maintenance level 1 and 2 roads are generally open to legal OHV use. These roads also provide 

needed access for Forest Service administrative uses including fire suppression, fuels reduction, 

recreation administration, timber harvest, reforestation, and assessment of biological resources.

Reduced funding and road maintenance activities associated with timber harvest have limited 

opportunities to maintain the road system to proper standards. It is estimated that 80% of the road 

system within the Sugar Pine Adaptive Management Project area fails to meet current road 

maintenance standards. 

The existing transportation system for the Sugar Pine Adaptive Management Project consists of 

approximately 39.5 miles of National Forest Transportation System (NFTS) roads. Madera 

County maintains 1.5 miles of roadway. Mariposa County maintains 0.1 miles of roadway. The 

transportation system for the analysis area is nearly complete. Small areas may be identified 

during project planning where minor amounts of new permanent road and temporary road 

construction are needed. 

There are 33.4 miles of NFTS native and aggregate surfaced roads and approximately 6.1 miles 

of paved roadway. These native surfaced roads are not suited for wet weather use due to erosive 

soils and lack of armoring. 

Most system roads are in poor condition and are experiencing erosion problems due to lack of 

proper road maintenance, wet weather use, and erosive soils. Many of the local roads have 

received little to no maintenance over the years and will require heavy maintenance and/or 

reconstruction to eliminate resource damage and meet acceptable standards established in the 

Forest Service Handbook 7709.58.

Alternative 1 – No Action

Direct, Indirect and Cumulative Effects

Under the No Action alternative, no project activities would take place. Existing road 

maintenance and reconstruction needed to eliminate resource damage and support equipment 

access would not take place. There would be no road reconstruction activities on local roads and 

no new road construction would be needed. The transportation system for the area would 

continue to receive only minimal, if any maintenance with continued potential for loss of 

infrastructure investment from erosion, wet weather use and brush encroachment. 
Chapter 3: Affected Environment and Environmental Consequences

184 Sierra National Forest

Alternative 2 – Proposed Action

Direct, Indirect and Cumulative Effects

The highest priority for Bass Lake Ranger District road management will continue to be safety 

for the traveling public and employees and improvement and restoration of roads with resource or 

access needs. Road maintenance and reconstruction will be required for identified roads that do 

not meet acceptable standards for the proposed service level and transportation system. This work 

may include installation of culverts, rolling dips, water bars; and aggregate surfacing where soil

erosion is evident; riprap at outlets of culverts, dips and water bars when needed; and minor 

clearing and widening to a 12-foot road width for equipment access. NFTS roads used for this 

project will be kept open for public use during sale and post sale activities. Existing landings, skid 

trails, and temporary roads will be used for timber access, when available. 

The Sugar Pine Adaptive Management project is proposing to perform road maintenance and/or 

road reconstruction activities on all or portions of roads 5S06, 5S17, 5S17X, 5S18, 5S22Y, 

5S22YA, 5S79, 5S79A, 6S07, 6S10, 6S47Y, 6S90 and 6S90D. These roads will require a final 

field review prior to project activities to determine complete road reconstruction and/or road 

maintenance needs. 

The logging systems plan has identified approximately 0.2 miles of new road construction and 

approximately 0.5 miles of temporary road construction for unit access. After project completion, 

the new road will remain open to allow access to Yosemite Trails Pack Station facilities; 

however, all temporary roads will be closed. These roads will require a final field review prior to 

project activities to determine complete road construction design needs. 

There are 26 recorded archeological and historical sites within the Sugar Pine Adaptive 

Management Project area. A preliminary map review of the location of recorded sites and 

specified roads shows four road/site conflicts. These road/site conflicts are of minimal concern 

because of the limited impact of the continued use of the roads, the limited significance of the 

sites, or the conflicts are easily mitigated. 

There is one section of existing forest road 6S90 that was built on previously constructed Madera 

Sugar Pine Railroad grade. Road 6S90 is scheduled for reconstruction including widening three 

curves to allow chip van truck access. This will not further affect the historical integrity of the 

grade.

There are four sites where proposed maintenance or reconstruction of the roads running through 

them may cause an impact that could be mitigated. The roads that have the most serious road/site 

conflicts are 5S18, 5S22Y, 5S22YA, and 5S79 which are scheduled for reconstruction.

Planned new road construction, temporary road construction, road reconstruction and road 

maintenance activities for the Sugar Pine Adaptive Management Project will be reviewed by the 

District Archeologist to develop mitigation requirements for archeological or road site conflicts 

prior to work activities. 

This relatively low traffic volume road system has received less maintenance in recent years. 

These roads, mostly maintenance level 2, comprise most of the miles of the road system. Many of 

them are brushing in and washing out. The results are negative effects on access and 

environmental resources and loss of the infrastructure investment.

The greatest surface erosion problems occur in highly erodible terrain where existing drainages 

structures have become non functional due to lack of adequate road maintenance activities and/or 

wet weather use. Road 6S90 was identified as a native surfaced road located in High Erosion risk 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 185

soils including the Holland family. Road maintenance and or reconstruction treatments would be 

considered to reduce the possible adverse effects to water quality and wildlife habitat.

Existing road densities, in general, are acceptable from a wildlife perspective. However, any 

system roads or unclassified roads not needed should be decommissioned to enhance wildlife 

habitat and reduce road densities to a more desired level.

Alternative 3

Direct, Indirect and Cumulative Effects

The effects of this alternative would be similar to Alternative 2, since there would be no change 

in types of activities occurring and utilizing the project area transportation system.

Alternative 4

Direct, Indirect and Cumulative Effects

The effects of this alternative would be similar to Alternative 2, since there would be no change 

in types of activities occurring and utilizing the project area transportation system.
Chapter 3: Affected Environment and Environmental Consequences

186 Sierra National Forest

Economics _________________________________

The analysis of the economics associated with the alternatives is summarized from the Economics 

Report for the Sugar Pine Adaptive Management Project (Ballard, K. 2010).

The Sugar Pine Adaptive Management Project area was selected for treatment based on analysis 

within the Fresno River Landscape Analysis Plan. Hazardous fuel reduction and stand density 

management is important here due to the proximity of the project area to several communities 

along the State Highway 41 corridor. The inclusion of research from the Sierra Nevada Adaptive 

Management Project (SNAMP) added a timeline requirement to the project that would result in 

expediting the proposed treatments. Considering the timeline requirement and the current 

depressed lumber market, the district recognized that the project would cost more money than it 

could generate from the forest products removed. The depressed lumber market is the result of 

reduced housing starts and the consequences of the current global recession. Additional 

appropriated dollars would need to be requested to complete any of the action alternatives.

The treatments prescribed were developed with regard to those activities necessary to reduce the 

intensity and spread of wildfire and reduce stand density, not to provide positive economic 

returns or provide products to local mills or biomass consumption plants. Treatments need to be 

done now to prevent a situation similar to that which occurred on the San Bernardino National 

Forest, where thousands of acres of trees died from insect mortality due to over-stocked 

conditions. An economic analysis is required to comply with NEPA guidelines and can generally 

be helpful in selecting an alternative by showing comparative costs and\or revenues between 

alternatives. However, economics will not be a deciding factor for selecting any action 

alternative for the Sugar Pine Adaptive Management Project. Instead, alternative selection will 

be based on the alternative that best accomplishes the purpose and need of the project. This 

economic analysis, at a minimum, will give the public an approximate comparison of costs 

between alternatives.

The economic analysis for the Sugar Pine Project is simply a comparison of product value after 

delivery to processing centers for all action alternatives, which involves estimating stump to truck 

costs (the cost of cutting and moving thinned material to a central landing) and the cost to 

transport both sawtimber and biomass to processing centers. The cost of environmental 

documentation (project planning) is a constant for all alternatives, including the No-Action 

Alternative, and is not included in the economic analysis. As is displayed in Table 48, all action 

alternatives would require appropriated dollars to complete the work. Alternative 2 would require 

the most appropriated dollars, while Alternative 3 would require the least amount of appropriated 

dollars to complete.

Associated with all action alternatives are several other treatments. Mastication, hand thinning 

and hand piling, dozer piling, understory burning, and pile burning would occur within the project 

area. These treatments generally occur after commercial harvest and biomass treatments. The 

cost of these other treatments is constant between each action alternative (the acres by treatment 

type is the same between all action alternatives). Table 47 displays the type of treatment and its 

associated cost per acre.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 187

Table 47. Other Treatments Cost – All Action Alternatives

Treatment Cost per Acre

Mastication $480 - $540

Hand Thin/Hand Pile $1,100

Tractor Pile $280

Pile Burning $70

Understory Burning $90 - $150

Whenever you have a project that puts people to work and provides a product to the free market, 

there are societal benefits derived. Woods workers, truck drivers, and mill workers are directly 

employed and the taxes they pay benefit both Federal and State Government. Yield taxes are 

collected from Purchasers upon cutting sawtimber and are paid to the State. Processed materials 

from mills eventually reach retail stores and provide jobs for retail workers and income and sales 

tax to Federal and State Government. These societal benefits are a by-product of the prescribed 

treatments designed to meet the purpose and need of this project. When greater amounts of forest 

products are removed from a project, more societal benefits are realized. Alternative 2 would 

provide the greatest societal benefits. The No Action alternative would provide no societal 

benefits.
Chapter 3: Affected Environment and Environmental Consequences

188 Sierra National Forest

Table 48. Sugar Pine Adaptive Management Project Appraisal Cost Summary

Sawtimber

Alt 2 Alt 3 Alt 4

Sawlog CCF Volume 8383.8 6683.3 1497.9

Sawlog MBF Volume 4200.1 3378.2 690.9

Sawlog Pond Value ($/CCF 

Average) $ 127.38 $ 128.11 $ 116.60 

Total Sawlog Pond Value $ 1,067,928 $ 856,198 $ 174,655 

Sawlog Haul Cost $ 508,728 $ 405,544 $ 103,876 

Sawlog Stump to Truck Cost $ 708,429 $ 581,182 $ 292,680 

Road Maintenance Cost $ 53,479 $ 44,742 $ 12,053 

Specified Road Construction Cost $ 120,000 $ 120,000 $ 120,000 

Specified Road Reconstruction Cost $ 88,387 $ 88,387 $ 88,387 

Road Surface Replacement Deposit $ 19,141 $ 13,968 $ 3,145 

Erosion Control Cost $ 18,497 $ 18,497 $ 18,497 

PAL Cost $ 53,572 $ 42,706 $ 9,571 

Total Sawlog Costs $ 1,570,233 $ 1,315,026 $ 648,209 

Present Net Value* $ (502,304) $ (458,829) $ (473,554)

Biomass

Alt 2 Alt 3 Alt 4

Biomass CCF Volume 1394.6 1145.2 406.9

Biomass Green Ton Volume 7883.3 6428.8 1852.0

Biomass Dry Bone Ton Volume 3941.7 3214.4 926.0

Biomass Delivered Value ($/BDT) $ 21 $ 21 $ 21

Total Biomass Delivered Value $ 82,775 $ 67,502 $ 19,446 

Biomass Haul Cost $ 100,985 $ 82,353 $ 23,724 

Biomass Stump to Truck Cost $ 60,409 $ 60,409 $ 60,409 

Chipper and Operator Cost $ 11,568 $ 11,562 $ 11,520 

Total Biomass Costs $ 172,962 $ 154,324 $ 95,653 

Present Net Value* $ (90,187) $ (86,822) $ (76,207)

Total Project Value

Alt 2 Alt 3 Alt 4

Present Net Value* $ (592,492) $ (545,650) $ (549,761)

*December 2009
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 189

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).

Maintenance and enhancement of long-term productivity is accomplished through restoration 

treatments that reduce basal area and number of stems (stand density) in over crowed stands. 

Stands that exist presently are no longer sustainable or resilient to changing environmental 

conditions that can and are occurring now and into the future. Drought induced stress, insect or 

disease attacks and wildfire all can have detrimental effects on the forest of today. Short-term 

activities described in the action alternatives are intended to lead to the enhancement of long-term 

productivity by beginning to restore forest conditions that resilient to disturbances.

Actions described in Chapter 1 lead to enhancement of long-term productivity, especially:

 The need to increase the proportion of large trees across a landscape,

 The need to increase the proportion of fire resistant species such as pines,

 The need to reduce wildfire intensity and spread across the landscape, and

 The need to reduce stand density.

Unavoidable Adverse Effects__________________

No unavoidable adverse effects would occur in the project area.

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. 

Approximately 0.7 miles of new and temporary road construction is proposed for the Sugar Pine 

Project. Road construction results in removal of surface soils and subsoil and complete loss of 

soil productivity within the road prism. 

The 0.7 miles of road is approximately 1.2 acres of ground with total loss of soil productivity. 

The direct effect of this new road construction is irreversible and irretrievable. Erosion on newly 

constructed roads is usually higher immediately after the road is constructed. There is potential 

that accelerated erosion could occur off the road prism and reduce soil productivity off site and 

after the road is constructed. Applicable soil and water conservation Best Management Practices 

(BMP) will be implemented, including erosion control measures, such as water bars, straw 

mulching of fills and fertilization of soils to re-vegetate the bare soils. Road reconstruction and 

road maintenance operate within the road prism and have little effect to the soil resource. 
Chapter 3: Affected Environment and Environmental Consequences

190 Sierra National Forest

However, there can be a positive effect to the soil resource outside of the road prism from road 

reconstruction by restoring proper drainage features of the road. Restoration of drainage features 

will result in less surface erosion and soil loss that leads to loss in soil productivity.

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.‖ The proposed action and alternatives must comply with the 

following regulation.

Principle Environmental Laws 

The following laws contain requirements for protection of the environment that apply to the 

proposed action and alternatives.

Endangered Species Act 

The Forest Service is directed to comply with this Act and does so through Biological 

Assessments and Evaluations that are used to analyze the effects of the proposed alternatives. 

These assessments and evaluations make determinations on Federally-listed endangered, 

threatened, candidate and proposed species and their habitat. The analysis was conducted in part 

to determine whether formal consultation or conference is required with the United States 

Department of the Interior, Fish and Wildlife Service (USDI-FWS), pursuant to this act.

The Sugar Pine Adaptive Management Project, through the inclusion of design criteria 

established for all action alternatives for species covered under this Act as well as the completion 

of Biological Assessments and Evaluations for Botanical, Aquatic and Terrestrial species, is in 

compliance with this act. 

Clean Water Act

The Sugar Pine Adaptive Management Project would comply with this Act by adoption of Best 

Management Practices and other design criteria established for all action alternatives as detailed 

in Chapter 2. 

Clean Air Act

Under the General Conformity Rule the Sugar Pine Adaptive Management Project has been 

determined to comply with this Act and the California State Implementation Plan through the 

implementation of treatments following Best Available Control Measures (BACMs) for 

prescribed burning as well as Rules and Regulations established by the San Joaquin Valley Air 

Pollution Control District and Mountain Counties Air Pollution Control District as required under 

section 190 of this Act, as amended in 1990. 

National Historic Preservation Act (NHPA)

The USDA Forest Service is directed to identify, evaluate, treat, protect, and manage historic 

properties by several laws. However, the National Historic Preservation Act of 1966, as amended 

(16 U.S.C. 470 et seq.) (NHPA) provides comprehensive direction to Federal agencies about their 

historic preservation responsibilities. 

Section 106 of the NHPA and the ACHP implementing regulations, Protection of Historic 

Properties (36 CFR Part 800), require that Federal agencies take into account the effect of their 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 191

undertakings on historic properties, and that agencies provide the ACHP with an opportunity to 

comment on those undertakings. Programmatic agreements (36 CFR 800.14(b)) provide 

alternative procedures for complying with 36 CFR 800. Pacific Southwest Region 5, USDA 

Forest Service has such an agreement: Programmatic Agreement among the U.S.D.A. Forest 

Service, Pacific Southwest Region, California State historic Preservation Officer, and Advisory 

Council on Historic Preservation Regarding The Identification, Evaluation and Treatment of 

Historic Properties Managed by the National Forest of the Sierra Nevada, California (Sierran 

PA). This agreement provides specific standards for conducting cultural resources inventory, 

evaluation, and management, including Forest Heritage Program requirements, identification 

standards, standard procedures for protecting cultural resources, reporting and public 

participation.

Cultural resource design criteria are established for all action alternatives and are based on 

stipulations within the Sierran PA. All alternatives would be in compliance with historic 

preservation law, policy and regulation, as this project meets the stipulations of the Sierran PA.

National Forest Management Act

The National Forest Management Act (16 U.S.C. 1604) and the Multiple-Use Sustained-Yield 

Act of 1960 (16 U.S.C. 528–531) gives direction to National Forests to develop National Forest 

Land and Resource Management Plans that (A) insure consideration of the economic and 

environmental aspects of various systems of renewable resource management, including the 

related systems of silviculture and protection of forest resources, to provide for outdoor recreation 

(including wilderness), range, timber, watershed, wildlife, and fish; (B) provide for diversity of 

plant and animal communities based on the suitability and capability of the specific land area in 

order to meet overall multiple-use objectives, and for steps to be taken to preserve the diversity of 

tree species. As set forth by these Acts, the Sierra National Forest Land and Resource 

Management Plan, as amended by the Sierra Nevada Forest Plan Amendment (SNFPA) in 2004, 

set specific standards and guidelines which are to be followed during project level planning and 

implementation.

By the inclusion of design criteria as part of all action alternatives to minimize or eliminate 

significant environmental effects from proposed management actions as well as the inclusion of 

standards and guidelines from the Sierra National Forest LRMP and SNFPA ROD (USDA-FS 

2004b) used to design this project, this project would comply with this act.

Soil Productivity 

Soil resource management is achieved by maintaining soil productivity using Regional Soil 

Quality Standard and Guidelines and management direction provided in the LRMP (USDA-FS

1992). The Geology/Soils section, starting on page 39 in Chapter 3, analyzes the existing soil 

productivity and effects of alternatives on soil productivity. 

Management Indicator Species (MIS)

The bioregional scale monitoring strategy for the Sierra NF MIS is found in the Sierra Nevada 

Forests Management Indicator Species Amendment (SNF MIS Amendment) Record of Decision 

(ROD) of 2007. Bioregional scale habitat monitoring is identified for all twelve of the terrestrial 

MIS. In addition, bioregional scale population monitoring, in the form of distribution population 

monitoring, is identified for all of the terrestrial MIS except for the greater sage-grouse. For 

aquatic macroinvertebrates, the bioregional scale monitoring identified is Index of Biological 

Integrity and Habitat. The current bioregional status and trend of populations and/or habitat for 
Chapter 3: Affected Environment and Environmental Consequences

192 Sierra National Forest

each of the MIS is discussed in the Sierra Nevada Forests Bioregional Management Indicator 

Species (SNF Bioregional MIS) Report (USDA-FS 2008).

Other Standards and Guidelines, especially those dealing with Water 

Quality

Best Management Practices will be applied to all action alternatives and are listed in Appendix 

B of this document. Design criteria listed in Chapter 2 incorporate additional protection measures 

to minimize and/or eliminate impacts to water quality. 

Executive Orders 

The following executive orders provide direction to Federal agencies that apply to the proposed 

action and alternatives:

Indian Sacred Sites, Executive Order 13007 of May 24, 1996, applies to the proposed action 

alternatives because of historic and prehistoric uses known in the area. This is specifically 

addressed in Chapter 3 under Heritage Resources and Tribal Relations. All project alternatives 

comply with this order.

Protection and Enhancement of the Cultural Environment, Executive Order 11593 of May 

13, 1971, directs Federal agencies to inventory cultural resources under their jurisdiction, to 

nominate to the National Register of Historic Places all Federally owned properties that meet the 

criteria, to use due caution until the inventory and nomination processes are completed, and to 

assure that Federal plans and programs contribute to preservation and enhancement of nonFederally owned properties. 

Cultural resource design criteria are established for all action alternatives and are based on 

stipulations within the Sierran PA. All alternatives would be in compliance with historic 

preservation law, policy and regulation, as this project meets the stipulations of the Sierran PA.

Invasive Species, Executive Order 13112 of February 3, 1999, applies to the proposed action 

alternatives. A risk of introducing invasive species does exist. Measures need to be in place to 

prevent the spread of these species. The proposed action alternatives comply by providing 

measures to prevent the introduction and spread of invasive species.

Recreational Fisheries, Executive Order 12962 of June 6, 1995, applies to the proposed action 

alternatives. Action alternatives comply with this order by implementing Best Management 

Practices and other design criteria and correcting existing resource problems. These design 

criteria are detailed in Chapter 2 and the list of specific Best Management Practices associated 

with this project are included in Appendix B of this document. 

Migratory Birds, Executive Order 13186 of January 10, 2001. Under the National Forest 

Management Act (NFMA), the Forest Service is directed to ―provide for diversity of plant and 

animal communities based on the suitability and capability of the specific land area in order to 

meet overall multiple-use objectives (P.L. 94-588, Sec 6 (g) (3) (B)).‖ The January 2000 USDA 

Forest Service (FS) Landbird Conservation Strategic Plan, followed by Executive Order 13186 in 

2001, in addition to the Partners in Flight (PIF) specific habitat Conservation Plans for birds and 

the January 2004 PIF North American Landbird Conservation Plan all reference goals and 

objectives for integrating bird conservation into forest management and planning.

In late 2008, a Memorandum of Understanding (MOU) between the USDA Forest Service 

and the U.S. Fish and Wildlife Service to Promote the Conservation of Migratory Birds was 

signed. The intent of the MOU is to strengthen migratory bird conservation through enhanced 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 193

collaboration and cooperation between the Forest Service and the Fish and Wildlife Service 

as well as other Federal, State, tribal and local governments. Within the National Forests, 

conservation of migratory birds focuses on providing a diversity of habitat conditions at 

multiple spatial scales and ensuring that bird conservation is addressed when planning for 

land management activities. 

The Sierra National Forest is proposing to manage lands on the Bass Lake Ranger District that are 

located in the Fresno River and South Fork Merced fifth field watersheds. Proposed management 

is intended to implement direction contained within the Sierra National Forest Land and Resource 

Management Plan (LRMP, USDA-FS 1992) as amended by the SNFPA ROD (USDA-FS 

2004b). Opportunities to promote conservation of migratory birds and their habitats in the project 

area were considered during development and design of the Sugar Pine Adaptive Management 

Project (MOU Section C: items 1 and 11 and Section D: items 1 and 3). 

Within this project area special considerations have been given to maintaining higher levels of 

biodiversity through actions such as delineating Old Forest Linkages (OFLs) surrounding 

perennial streams (see EIS and BE/BA for a description of OFLs). Higher levels of biodiversity 

have also been planned for by marking retention groups of large diameter trees. Two-hundred and 

eighty (280) such tree groups were identified in the main project area, and an additional 74 were 

identified in the hydrology study area. These tree groups are composed of a cluster of 3 or more 

trees, 30-inch dbh or greater, with touching crowns, and will benefit those species which utilize 

dense groupings of large trees. Another project design measure which will maintain biodiversity 

is the identification of retention areas around large oaks within treatment units. Two to three large 

oaks per acre were identified and marked with paint. These oaks will retain a zone of no activity 

measuring 35 feet, or dripline circumference around the oak (whichever is greater). The 

delineation of OFLs, retention of large tree groups, and oak no treatment zones will ensure a 

heterogeneous post treatment landscape resulting in the continued accessibility of both hiding 

cover and prey availability within these areas of biodiversity. 

Likely impacts to habitats and select migratory bird populations resulting from the Sugar Pine 

Adaptive Management project have been assessed in detail within the project MIS report and 

impacts to select TES birds and their habitats have been analyzed in the project BA and/or BE. 

The project will not adversely impact migratory landbird species or their associated habitats.

Potential impacts to migratory species would be minimized through the adherence of LRMP 

Standards and Guidelines as well as Design Criteria common to All Action Alternatives (pages 

16-26). These define the retention levels for snags/down woody debris, activities occurring 

within riparian management areas which include SMZs, OFLs, how to minimize ground 

disturbance and maintenance of canopy cover. The project is designed to improve habitat 

conditions through the acceleration of late-successional habitat characteristics, while still 

maintaining current functional habitat. Specific project design criteria include: canopy cover will 

be maintained at 50 to 60% or greater where available; ground disturbance will be limited to 

those guidelines with the LRMP as amended; vegetation species diversity and composition will 

be maintained; management activities will be limited in designated riparian management areas; 

and retention of snags and downed logs would be retained at levels defined in the Design Criteria 

Common to All Action Alternatives. All riparian management areas within the project have been 

identified and buffers established. In addition, no operations will occur during the wet weather 

season. 

Floodplain Management, Executive Order 11988 of May 24, 1977, does not apply because of 

exclusions and buffers that are in place through design criteria for the action alternatives and are 

found in detail in Chapter 2.
Chapter 3: Affected Environment and Environmental Consequences

194 Sierra National Forest

Protection of Wetlands, Executive Order 11990 of May 24, 1977, does not apply because of 

exclusions and buffers that are in place through design criteria for the action alternatives and are 

found in detail in Chapter 2.

Environmental Justice, Executive Order 12898 of February 11, 1994, applies to the proposed

action alternatives. Compliance has been attempted by making this document understandable and 

accessible.

Use of Off-Road Vehicles, Executive Order 11644, February 8, 1972, does not apply to this 

proposal. No off road use is being proposed nor existing use changed in this document.

Special Area Designations

The selected alternative will need to comply with laws, regulations and policies that pertain to the 

following special areas.

Research Natural Areas

No research natural areas are located in the project area. This project would comply with 

applicable laws, regulations and policies for research natural areas.

Inventoried Roadless Areas

No Inventoried Roadless Areas are located in the project area. This project would comply with 

applicable laws, regulations and policies for Inventoried Roadless Areas.

Wilderness Areas

No Congressionally-designated wilderness areas are located in the project area. This project 

would comply with applicable laws, regulations and policies for wilderness areas.

Wild and Scenic Rivers

No Congressionally-designated wild and scenic rivers occur in the project planning area.

Municipal Watersheds (FSM 2540)

No municipal watersheds occur in the project planning area.

Other Required Disclosures

NEPA at 40 CFR 1502.25(a) directs ―to the fullest extent possible, agencies shall prepare draft 

environmental impact statements concurrently with and integrated with...other environmental 

review laws and executive orders.‖

Species surveys, review of recent literature, and professional judgment have been incorporated 

into determinations of possible effects on species. Surveys provide information on species 

presence and habitat on a local scale. An element of uncertainty exists for effects on species with 

distributions beyond the project or Sierra N.F. boundaries. The Pacific fisher and Yosemite toad 

are Forest Service sensitive species that have also been designated by the U.S. Fish and Wildlife 

Service as candidate species for listing under the Endangered Species Act. A candidate species is 

determined by the U.S. Fish and Wildlife Service through a 12-month finding as warranted for 

listing. The listing process is precluded by other priorities. The Sierra N.F. requested and received 

technical advice from the U.S. Fish and Wildlife Service to address uncertainty related to these 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Chapter 3 195

candidate species. Their advice is integrated extensively throughout the Terrestrial and Aquatic 

Species sections of Chapter 3 as well as in the design criteria for all action alternatives. 

Sierra National Forest – Chapter 4 197

Chapter 4. Consultation and Coordination

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 document:

ID Team Members

Mark Lemon/Burt Stalter, District Fuels Officer; Fire/Fuels Analysis; ID Team Leader

David Smith, District Silviculturist; Vegetation/Silvicultural Analysis; Core Team Member

Anae Otto, Acting District Wildlife Biologist; Biological Assessment/Biological Evaluation for 

Terrestrial Wildlife (2010); Management Indicator Species Analysis; ID Team Member

Greg Schroer, Forest Wildlife Biologist; Biological Assessment/Biological Evaluation for 

Terrestrial Wildlife (2010)

Kevin Williams, District Wildlife Biologist-Terrestrial; Biological Assessment/Biological 

Evaluation for Terrestrial Wildlife; Core ID Team Member

Keith Ballard, District Timber Management Officer; Data Collection/Analysis; Core Team 

Member

Denise Tolmie, Forest Fuels Officer; Writer/Editor; Core Team Member

Phillip Strand, Fisheries Biologist; Aquatics-Riparian Analysis; ID Team Member

Keith A. Stone, Hydrologist; Hydrology Analysis; ID Team Member

Joanna Clines, Forest Botanist; Botanical Biological Assessment/Biological Evaluation/Noxious 

Weed/Invasive Species Analysis; ID Team Member

Marie Mogge/Constance Popelish, District Archeologist; Archeology Analysis; ID Team 

Member

Andy Hosford, District Engineer; Transportation Analysis; ID Team Member

Alan Gallegos, Province Geologist; Cumulative Watershed Effects Analysis/Soils Analysis; ID 

Team Member

Karen Nooney, District Lands/Special Uses; Special Uses Analysis; ID Team Member

Federal, State, and Local Agencies

Although no formal or informal consultation was required for this project, personnel 

communications with Federal, State and Local Agencies including, but not limited to; U.S. Fish 

and Wildlife Service, California Department Fish and Game, The Resources Agency (CalFire), 

University of California Academics and other Memorandum of Understanding Signatory 

Agencies occurred throughout the planning stages of this project as part of the Sierra Nevada 

Adaptive Management Project.

Tribes

North Fork Mono Rancheria; Picayune Rancheria of the Chukchansi Indians; Mariposa Indian 

Council; Mono Nation; California Indian Basketweavers Association.
Chapter 4: Consultation and Coordination

198 Sierra National Forest

Others

Sierra Nevada Adaptive Management Project-Integration Team; Science Team-Sierra Nevada 

Adaptive Management Project.

Distribution of the Environmental Impact 

Statement _________________________________

This draft 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, Federally-recognized tribes, State and local governments, and organizations: 

Advisory Panel on Historic Preservation, USDA-Animal and Plant Health Inspection Service, 

USDA-Natural Resources Conservation Service, USDA-National Agricultural Library, 

National Oceanic and Atmospheric Administration, National Marine Fisheries Service, South 

Pacific Division-US Army Engineer, Region 9-Environmental Protection Agency, US 

Department of the Interior, US Coast Guard, Western Pacific Region-Federal Aviation 

Administration, US Department of Energy, Federal Highway Administration, U.S. Fish and 

Wildlife Service, California Department of Fish and Game, North Fork Mono Rancheria, 

Picayune Rancheria of the Chukchansi Indians, Mariposa Indian Council, Mono Nation, 

Madera and Mariposa County Board of Supervisors, San Joaquin Valley Air Pollution 

Control District, local Chapter of Society of American Foresters, Eastern Madera Fire Safe 

Council, Mariposa Fire Safe Council, Coarsegold Resource Conservation District, Sierra 

Forest Legacy, National Chapter and Tehipite Chapter-Sierra Club, John Muir Project, 

California Indian Basketweavers Association, Sugar Pine Yosemite Railroad, Yosemite Trails 

Pack Station and Tenaya Lodge.
Sierra National Forest – Glossary 199

Glossary

Adaptive Management: A type of natural resource management that implies making decisions 

as part of an on-going process. Monitoring the results of actions provides information that may 

indicate the need to change a course of action. Scientific findings and the needs of society may 

also indicate the need to adapt resource management to new information.

Air Shed/Air Basin: A geographical area that shares the same air mass due to topography, 

meteorology, and climate.

Analysis Area: A collection of land area, not necessarily contiguous, sufficiently similar in 

character that they can be treated as if they were identical.

Aspect: A position facing a particular direction, usually expressed as a compass direction in 

degrees or cardinal directions.

Bark Beetle: A member of the family Scolytidae (Coleoptera). Adults and larvae tunnel in the 

cambial region (either in the bark only or in the bark and xylem) of living, dying and recently 

dead or felled trees and utilize these areas for food and shelter.

Basal Area: The area of the cross section of a tree trunk near its base, usually 41⁄2 feet above the 

ground. Basal area is a way to measure how much of a site is occupied by trees. The term basal 

area is often used to describe the collective basal area of trees per acre.

Baseline: Starting point for analysis of environmental consequences. A baseline may be 

conditions at a point in time or collected over a specified period of years.

Best Management Practices (BMPs): Practices determined to be the most effective and 

practicable means of controlling pollutants at levels compatible with environmental quality goals. 

BMPs were conceptualized in the 1972 FUS Federal Water Pollution Control Act. BMPs as 

defined in the USDA Forest Service Soil and Water Conservation Handbook.

Biomass thin: Used in this document to describe the cutting of vegetation (conifers) that may or 

may not have a market value, but are removed from site after cutting. For this document this is 

considered a conifer approximately 4-10 inches in diameter.

Breast Height (as referred to as dbh): A standard height from ground level, generally 4.5 feet 

for recording diameter, circumference or basal area of a tree. 

Broadcast Burn: A type of prescribed fire allowed to burn over a designated area within defined 

boundaries to achieve land management objectives.

Buffer: A land area designated to block or absorb unwanted impacts to the area inside the buffer.

Bulk Density: The weight per unit volume of a measured material. Bulk density of plants is 

measured at a specified moisture tension.

California Wildlife Habitat Relationship System (CWHR): A wildlife information and 

predictive system for mammals, reptiles, and amphibians. This system is considered a state-ofthe-art information system for California‘s wildlife. The system provides the most widely used 

habitat relationship models for California‘s terrestrial vertebrate species. CWHR is operated and 

maintained by the California Department of Fish and Game, in cooperation with the California 

Interagency Wildlife Task Group (CIWTG).

Canopy: Foliar cover in the forest stand consisting of one or several layers.

Chaparral: Dense growth of mostly small-leaved evergreen shrubs. Found in the foothills of 

California.
Glossary

200 Sierra National Forest

Classified Roads: Roads wholly or partially within or adjacent to National Forest System lands 

that are determined to be needed for motor vehicle access including State roads, County roads, 

privately owned roads, National Forest Transportation System roads, and roads authorized by the 

Forest Service that are intended for long-term use.

Clump: An isolated, generally dense, group of trees.

Codominant: Tree species in a forest that are about equally numerous and exert the greatest 

influence.

Cohort: A group of trees developing after a single disturbance, commonly consisting of trees of 

similar age. A considerable range of tree ages of seedling or sprout origin and trees that predate 

the disturbance can be included.

Commercial thin: Used in this document to describe the cutting and removal from site of 

vegetation (conifers) that typically has a market value. For this document this is considered a 

conifer over approximately 10 inches in diameter.

Corridor: Elements of the landscape that connect similar areas. Streamside vegetation may 

create a corridor of willows and hardwoods between meadows where wildlife feed.

Cover: Any feature that conceals wildlife or fish. Cover may be dead or live vegetation, boulders, 

or undercut streambanks. Animals use cover to rest, feed, and escape from predators.

Crown: The upper part of a tree that carries the main branch system and foliage.

Crown Closure: The point at which the vertical projections of a crown‘s perimeter within a 

canopy touches.

Crown Density: The amount and compactness of foliage for trees or shrubs.

Cumulative Effects: Combined effects resulting from sequential actions on a given area.

Den Tree: A tree that contains a weather tight cavity for wildlife.

Defensible fuels profile(s), Defensible Fuel Profile Zone(s), DFPZ(s): The term DFPZ is being 

used in this document to describe the geographic location associated with an area of proposed 

vegetation treatment, not an area where treatment intensity would change. DFPZs, as proposed in 

this project, are designed and associated with main transportation corridors, on National Forest 

System lands, that lead into and out of designated Wildland Urban Intermix (WUI). They are not 

designed to stop an oncoming wildfire by themselves, but rather to moderate fire behavior to 

provide a safe location to facilitate fire suppression efforts and provide safer escape routes to 

those in and around the community they are associated with.

Diameter Class: Intervals into which a range of diameters of tree stems or logs may be divided 

for classification or use.

Disturbance: A force that results in changes in the structure and composition through natural 

events such as wind, fire, flood, avalanche, or mortality caused by insect or disease outbreaks or 

human events (e.g. timber harvest).

Duff: Organic material covering the forest floor (includes fresh litter from plants and older, well 

developed humus).

Ecosystem: An arrangement of living and non-living things and the forces that move among 

them. Living things include plants and animals. Non-living parts of ecosystems may be rocks and 

minerals. Weather and wildfire are two of the forces that act within the ecosystems.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Glossary 201

Elevation: Vertical distance of measure displayed in feet above sea level.

Endangered Species: A plant or animal that is in danger of extinction throughout all or a 

significant portion of its range. Endangered species are identified by the Secretary of the Interior 

in accordance with the Endangered Species Act of 1973.

Endemic Species: Plants or animals that occur naturally in a certain region and whose 

distribution is relatively limited to a particular locality.

Environmental Effects: Includes ecological (such as the effects on natural resources and on the 

components, structures, and functioning of affected ecosystems), aesthetic, historic, cultural, 

economic, social, or health whether direct (which are caused by action and occur at the same time 

and place), indirect (which are caused by the action and are later in time or farther removed in 

distance, but are still reasonably foreseeable), or cumulative (results from the incremental impact 

of the action when added to other past, present or reasonably foreseeable future actions). 

Environmental Impact Statement (EIS): A document prepared by a Federal agency in which 

anticipated environmental effects of a planned course of action or development are evaluated. 

Federal statute (Section 102 of the National Environmental Policy Act of 1969) requires that such 

statements be prepared. An impact statement includes: (1) the environmental impact of the 

proposed action, (2) any adverse impacts which cannot be avoided by the action, (3) alternatives 

courses of actions, (4) relationships between local short-term use of the human environment and 

the maintenance and enhancement of long-term productivity, and (5) a description of the 

irreversible and irretrievable commitment of resources which would occur if the action were 

accomplished.

Ephemeral Stream: A stream or portion of a stream that flows only in direct response to 

precipitation, receiving little or no water from springs and no long continued supply from snow or 

other sources and whose channel is at all times above the water table.

Erosion: The wearing away of land surface by rain, running water, wind, ice, gravity, or other 

natural agents including gravitational creep and tillage.

Feasibility: Capability and suitability for specific use. 

Fire Behavior: The over-arching means by which to describe how an ignited fire reacts to the 

influences of fuels, topography and weather when combined together. Typical terms used when 

describing fire behavior include rate of spread (how fast a fire travels over a given distance in a 

given period of time); flame height (as measured in feet from ground through middle of flame); 

intensity (BTUs given off from flaming front); fire type (surface vs. crown) to name a few. 

Computer based models are used to predict fire behavior for given environmental and fuel 

conditions.

Flow: The movement of a stream of water or other mobile substances from place to place. The 

movement of water and the moving water itself. The volume of water passing a given point per 

unit of time.

Forage: All browse and non-woody plants that are eaten by wildlife.

Forb: A grouping or category of herbaceous plants which are not included in grass, shrub or tree

groupings, generally smaller flowering plants. Forbs contain little or no woody material.

Forest: An ecosystem characterized by a more or less dense and extensive tree cover, often 

consisting of stands of varying in characteristics such as species composition, structure, age class, 

and associated processes. Commonly includes meadows, streams, fish and wildlife.
Glossary

202 Sierra National Forest

Forest Health: The perceived condition of a forest derived from concerns about such factors as 

its age, structure, composition, function and vigor, presence of unusual levels of insects or 

disease, and resilience to disturbance. Individual and cultural viewpoints, land management 

objectives, spatial and temporal scales, the relative health of the stands that make up the forest, 

and the appearance of the forest at a point which influences the perception and interpretation of 

forest health.

Forest Plan: Also referred to as a Land and Resource Management Plan (LRMP). A signed 

document that is the source of management direction for an individual National Forest that 

specifies activity and output levels for a period of 10-15 years. Management direction in the 

Forest Plan is based on issues identified at the time of Plan development.

Forestry: The profession embracing the science, art and practice of creating, managing, using 

and conserving forests and associated resources for human benefit and in a sustainable manner to 

meet desired goals, needs and values.

Forest Type: A category of forest usually defined by its vegetation, particularly its dominant 

vegetation as based on percentage cover of trees.

Fragmentation: The process by which a landscape is broken into small islands of forest within a 

mosaic of other forms of land use or ownership.

Frequency: 1. biometrics: the number of occurrences of a given type of event of the number of 

members of a population falling into a specified class; 2. ecology: the number of individuals in a 

community. 

Fuelbreak: A strip or block of land on which the native vegetation has been or is modified so 

that fires burning into it can be more readily suppressed. Usually strategically build in 

conjunction with a roadway (for access) and along ridgelines. Terms like shaded fuelbreak is used 

to differentiate the amount or type of vegetation that is removed or reduced to create the 

fuelbreak. In this project, a previously created shaded fuelbreak (a fuelbreak where canopy is 

spaced for openings, but still has an overstory and surface fuels are reduced) is proposed to have 

vegetation treatments completed to maintain the fuelbreak. 

Geographic Information System (GIS): A system of computer maps with corresponding sitespecific information that can be electronically combined to provide reports and maps.

Habitat: The place where an animal, plant or population normally lives and develops.

Habitat capability: The ability of a land area or plant community to support a given species of 

wildlife.

Headcuts: Land erosion at the head of a stream, creek, or river.

Headwater: The source of a stream. The upper tributaries of a drainage basin.

Herb: A non-woody, vascular plant.

Herbaceous: A class of vegetation dominated by no-woody plants known as herbs.

Horizon (soil): A layer of soil approximately parallel to the land surface and differing from 

adjacent genetically related layers in physical, chemical and biological properties or 

characteristics such as color, structure, texture, consistency, kinds and number of organisms 

present, degree of acidity or alkalinity.

Indigenous: Native to a specified area or region.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Glossary 203

Indirect Effects: Effects that are caused by an action and occur at a later time, or at another 

location, yet are reasonably foreseeable in the future.

Insect: A member of the class Insecta characterized by a body segmented into three distinct 

regions (head, thorax, abdomen), by a head with one pair of antennae, by a thorax with three 

segments each with a pair of legs, and usually one or two pairs of thoracic wings.

Intensity: The amount of heat (energy) given off with an unit area. 

Interdisciplinary Team (IDT): A group of specialists assembled to solve a problem or perform a 

task.

Invasive Plants: Plant species that are introduced into an area in which they did not evolve and 

in which they usually have few or no natural enemies to limit their reproduction and spread. 

These species can cause environmental harm by significantly changing ecosystem composition, 

structure, or processes and can cause economic harm or harm to human health.

Ladder fuels or fuel ladders: Arrangement of vegetation (trees, brush, etc.) that provides 

vertical continuity from the forest floor to the crowns of overstory trees. Example would be 

similar to steps on a ladder.

Land and Resource Management Plan (LRMP): See Forest Plan.

Landscape: A large land area composed of interacting ecosystems that are repeated due to 

factors such as geology, soils, climate and human impacts. Landscapes are often used for coarse 

grain analysis.

Maintenance: The work of keeping something in proper condition or standard.

Masticate or Mastication: Means by which vegetation is mechanically ―mowed‖ into small 

pieces and changed from a vertical to horizontal arrangement.

Management Indicator Species (MIS): Animals or plants identified in Forest Land and 

Resource Management Plans (LRMPs or forest plans) developed under the 1982 Planning Rule, 

that are selected because their population changes are thought to indicate the effects of Forest 

Service management activities.

Mechanical Methods: Utilization of machinery such as bulldozers and skidders for tractor 

logging; helicopter logging, skyline cable logging, mechanical harvesters and 

shredders/masticators.

Merchantable: Having the size, quality and condition suitable for marketing under a given 

economic condition.

Mitigation: Actions taken to avoid, minimize or rectify the impact of a land management 

activity.

Model: A representation of reality used to describe, analyze or understand a particular concept. A 

model may be a relatively simple qualitative description of a system or organization or a highly 

abstract set of mathematical equations. A model has limits to its effectiveness and is used as one 

of several tools to analyze a problem.

Mortality: Trees dying from natural causes, usually by size class in relation to sequential 

inventories or subsequent to incidents such as storms, wildfire or insect and disease epidemics.

Mosaic: A pattern of vegetation in which two or more kinds of communities are interspersed in 

patches, such as clumps of shrubs with grassland between.
Glossary

204 Sierra National Forest

National Environmental Policy Act (NEPA): Congress passed in 1969 to encourage productive 

and enjoyable harmony between people and their environment. One of the major tenets of NEPA 

is its emphasis on public disclosure of possible environmental effects of any major action on 

public lands. Section 102 of NEPA requires a statement of possible environmental effects to be 

released to the public and other agencies for review and comment.

Native Species: Indigenous species normally found as part of a particular ecosystem.

Natural Fuel: Term used to describe vegetation, live or dead, in a given area that is not 

associated with being created by management activities. It is usually described in terms of natural 

fuel accumulations or build-up from naturally falling leaves, branches and/or logs from fallen 

snags. 

Notice of Intent (NOI): A notice printed in the Federal Register announcing that an 

Environmental Impact Statement will be prepared. The NOI must describe the proposed action 

and possible alternatives, describe the proposed agency scoping process and provide a contact 

person for further information.

Noxious Weeds (Plants): An undesirable, non-native plant that is difficult to control and is on 

either the California Department of Food and Agriculture Noxious Weed list or the California 

Invasive Plant Council Inventory of invasive plants in California. 

Old-growth (forest): Old forests often containing several canopy layers, variety in tree sizes and 

species; and standing and dead woody materials.

Old Forest Linkage(s) [OFL]: OFL‘s consist of buffers measuring 300 feet total on either side 

of perennial streams and are designed to provide habitat connectivity for various species, 

primarily Pacific fisher. Within these buffers, there are designated zones (measured by distance 

from stream) where certain management activities are or are not allowed to occur. Design criteria 

common to all action alternatives are listed for each of these zones. 

Patch: An area of homogeneous vegetation, in structure and composition.

Pathogen: A parasitic organism directly capable of causing disease.

Perennial Stream: A stream that has running water on a year-round basis under normal climatic 

conditions.

Pre-commercial thin: Used in this document to describe the cutting of vegetation (conifers) that 

does not typically have a market value and not removed from site after cutting. For this document 

this is considered a conifer approximately 1-10 inches in diameter.

Prescribed burning (fire): With a given range environmental condition (air temperature, fuel 

moisture, windspeed and direction, etc.) and approved plan, a fire that is management ignited to 

meet specific resource management objectives. This can include dozer/hand pile; understory and 

broadcast burning.

Rate of Spread: The relative speed with which a fire increases in size usually expressed in chains 

(66 feet) per hour.

Record of Decision (ROD): An official document in which a deciding official states the chosen 

activity (alternative) that will be implemented from a prepared EIS.

Reforestation: The restocking of an area with forest trees, by either natural or artificial means, 

such as planting.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Glossary 205

Regeneration: The renewal of a tree crop by either natural or artificial means. The term is also 

used to refer to the young crop itself.

Residual: A tree or snag remaining after an intermediate partial cutting of a stand.

Resilience: The ability of an ecosystem to maintain diversity, integrity and ecological processes 

following a disturbance.

Resistance: The ability of a community to avoid alteration of its present state by a disturbance. 

The ability of plants to avoid, suppress, prevent, overcome, or tolerate insect or pathogen attack.

Responsible Official: The Federal employee who has the delegated authority to make and 

implement a decision on a proposed action. 

Riparian Area: The area along a watercourse or around a lake or pond.

Riparian Ecosystem: The ecosystems around or next to water areas that support unique 

vegetation and animal communities as a result of the influence of water.

Riparian Conservation Areas (RCAs): These are land allocations that are managed to maintain 

or restore the structure and function of aquatic, riparian and meadow ecosystems. The intent of 

management direction for RCAs is to (1) preserve, enhance, and restore habitat for riparian-and 

aquatic-dependent species; (2) ensure that water quality is maintained or restored; (3) enhance 

habitat conservation for species associated with the transition zone between upslope and riparian 

areas; and (4) provide greater connectivity within the watershed.

Riparian Management Area(s) (RMAs): 

Risk: The relative probability of any of several alternative outcomes as determined or estimated 

by a decision maker when the outcome of an event or series of events is not known.

Road Maintenance: The ongoing upkeep of a road necessary to retain or restore the road to the 

approved road management objectives.

Road Reconstruction: Activities that result in road realignment or road improvement.

Sample: A part of a population selected and examined as a representative of the whole.

Salvage: As used in this document, it the removal of dead, dying, damaged, or deteriorating trees 

to primarily put the wood to use before it becomes worthless.

Sediment (sedimentation): Solid materials, both mineral and organic, in suspension or 

transported by water, gravity, ice or air; may be moved and deposited away from their original 

position and eventually will settle to the bottom.

Sensitive Species: Plant or animal species which are susceptible to habitat changes or impacts 

from activities. The official designation is made by the USDA Forest Service at the Regional 

level and is not part of the designation of threatened or Endangered Species made by the U.S. 

Fish and Wildlife Service.

Severity: A measurement in the degree of effect on a given element by a causal agent. 

Shade tolerant: When used to describe a conifer, the tree prefers to grow in the shade.

Silvicultural System: The cultivation of forest; the result is a forest of a distinct form. 

Silvicultural systems are classified according to harvest and regeneration methods and the type of 

forest that results.
Glossary

206 Sierra National Forest

Silviculture: The art and science that promotes the growth of single trees and the forest as a 

biological unit.

Simulation: An operations research technique that represents physical, natural, social and 

economic systems by models in order to study the factors affecting the system and to aid decision 

making.

Site: The area in which a plant or a stand grows, considered in terms of its environment, 

particularly as this determines the type and quality of the vegetation the area can carry.

Site Preparation: Removing unwanted vegetation, slash, roots and stones from a site before 

reforestation. Naturally occurring wildfire, as well as prescribed fire can prepare a site for natural 

regeneration.

Skid Road (skid trail): A road access cut through the woods for skidding of logs.

Skidder: A self-propelled machine (cable, clam-bunk or grapple) used for dragging trees or logs.

Skidding: Hauling logs by sliding, not on wheels, from stump to a collection point.

Slash: Residue left on the ground after timber cutting or left after a storm, fire or other event. 

Slash includes unused logs, uprooted stumps, broken or uprooted stems, branches, bark, etc.

Snag: A standing dead tree. Snags are important as habitat for a variety of wildlife species and 

their prey.

Soil Compaction: Reduction of soil volume. The weight of heavy equipment, for example, on 

soils can compact the soil and thereby change it in some ways, such as in its ability to absorb 

water.

Species: The main category of taxonomic classification into which genera are subdivided, 

comprising a group of similar interbreeding, individuals sharing a common morphology, 

physiology and reproductive process.

Stand: A group of trees that occupies a specific area and is similar in species, age, and condition.

Stand density: A quantitative measure of stocking expressed either absolutely in terms of 

number of trees, basal area, or volume per unit area or relative to some standard condition. A 

measure of the degree of crowding of trees within stocked areas commonly expressed by various 

growing space ratios.

Stand Structure: The physical and temporal distribution of plants in a stand. Silviculture the 

horizontal and vertical distribution of components of a forest stand including the height, diameter, 

crown layers and stems of trees, shrubs, herbaceous understory, snags and down woody material.

Standards and Guidelines: Direction outlined in the Forest Land and Resource Management 

Plan (LRMP) for specific aspects of project planning and analysis.

Stocking: An indication of growing-space occupancy relative to a pre-established standard.

Strategically Placed Landscape Area Treatments (SPLATs): As defined in the SNFPA ROD 

(USDA-FS 2004b), SPLAT is a wildland fire modification strategy (created from research 

conducted by Dr. Mark Finney [1999]) by which a fire is forced to go around areas where fuels

have been reduced or otherwise modified. The treated areas function as ―speedbumps‖ on the 

landscape to slow the spread and reduce the intensity of oncoming fires and thereby reduce 

damage to both treated and untreated areas. In this project, SPLATs were used as initial 

treatment areas during project development and were brought forward from the Fresno River 

Landscape Analysis. The term SPLAT is being used in this document to describe a specific area 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Glossary 207

proposed for vegetation treatment, not an area where treatment intensity would change. SNAMP 

will be modeling fire behavior pre and post treatment based on the SPLAT strategy presented in 

the SNFPA ROD (USDA-FS 2004b) and the efficacy of how this theory has been interpreted and 

in where the SPLATs have been designated in this project. 

Streamside Management Zones (SMZs): Management Zones established to protect and 

maintain water quality, site productivity, channel stability, wildlife habitat, and riparian

vegetation.

Structure: Sizes, shapes and/or ages of the plants and animals in an area.

Surface Fuels: Vegetation, either dead or alive, that is on the surface, which includes dead 

branches, blowdown timber, leaves, and low vegetation, as contrasted with crown fuels.

Thinning from below: A silvicultural technique by which cutting is done in an immature stand 

of trees to accelerate growth of the remaining trees or to improve the form of the remaining trees. 

From below describes the incremental cutting of trees based on its position in the stand. First 

starting with suppressed, then intermediates, then co-dominates to reach a desired or prescribed 

basal area for the stand.

Threatened Species: Plant or animal species likely to become endangered throughout all or part 

of their range in the foreseeable future. Designated by the U.S. Fish and Wildlife Service under 

the Endangered Species Act of 1973.

Understory: The trees and woody shrubs growing beneath the overstory in a stand of trees.

Viability: The ability of a population of a plant or animal species to persist for some specified 

time into the future. Viable populations are populations that are regarded as having the estimated 

numbers and distribution of reproductive individuals to ensure that its continued existence is well 

distributed in a given area.

Watershed: The entire region drained by a waterway (or into a lake or reservoir). More 

specifically, a watershed is an area of land above a given point on a stream that contributes water 

to the streamflow at the point.

Weed: A valueless, troublesome or noxious plant often exotic, growing wild especially on 

growing profusely. A plant growing where it is not wanted.

Wildfire: Any wildland fire that is not a prescribed fire.

Wildland: Land other than that dedicated for other uses such as agriculture, urban, mining or 

parks.

Wildland Urban Intermix (WUI): The line, area, or zone where structures and other human 

development meet or intermingle with undeveloped wildland or vegetative fuels. WUI has three 

zones associated with it and these zones have standards and guidelines associated with them. The 

urban core, as defined in the USDA-FS 2004 FSEIS, is an area whereby the next zones are 

designated from. The defense zone is the area nearest the urban core and in this project is defined 

as the area 1⁄4 mile distance from the outer edge of the entire urban core. The threat zone is the 

next designated zone and in this project is defined as the area 1 1/4 mile distance from the outer 

edge of the defense zone. The total distance of the Defense and Threat Zone is 1 1⁄2 miles. The 

USDA-FS 2004, FSEIS mapped these areas based on 1990 Census data and were not redefined 

for this project. 

Wildfire Intensity: Describes the buildup of heat within a fire, both in amount and in rate of 

transmission-a function of heat release. Usually described as low, moderate or high intensity fires.
Glossary

208 Sierra National Forest

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the role of Best Management Practices in minimizing sediment redistribution and loss in 

forests after harvesting. Forest Ecology and Management 170:217-232.

Weatherspoon, C. P., 1996. Sierra Nevada Ecosystem Project; Chapter 44, Fire-Silviculture 

Relationships in Sierra Forests, pp. 1167-1175.

Wilkerson, E., Hagan, D., Siegel, D., Whitman, A. 2006. The effectiveness of different buffer 

widths for protecting headwater stream temperature in Maine. Forest Science 52(3) 2006 

pp. 221-231.

Winget, R., Mangum, F. 1979. Biotic condition index; integrated biological, physical and 

chemical stream parameters for management. U.S. Forest Service Intermountain Region, 

U.S. Department of Agriculture, Odgen.
Sierra National Forest – Index 219

Index

aquatic ... 13, 15, 16, 23, 24, 25, 43, 46, 80, 

81, 85, 86, 87, 89, 90, 91, 94, 95, 98, 99,

102, 125, 127, 128, 130, 132, 152, 191, 

205, 209, 211, 212, 214, 224, 226, 227, 

228, 230, 231

California spotted owl........ vii, 2, 5, 7, 108

conifer .. ix, 3, 4, 12, 13, 14, 15, 19, 26, 41, 

43, 44, 61, 91, 97, 112, 113, 114, 115, 

118, 119, 120, 121, 133, 136, 137, 138, 

139, 142, 145, 147, 148, 150, 199, 200, 

204, 205, 210, 235, 255

crowns... 96, 108, 139, 140, 142, 143, 144, 

147, 148, 152, 153, 154, 157, 193, 203

cultural resources. 36, 37, 38, 39, 191, 192

desired conditions ... 1, 4, 19, 57, 135, 145, 

149, 158, 232

disease .iii, viii, 60, 87, 110, 113, 114, 115, 

117, 119, 135, 138, 142, 159, 160, 189, 

200, 202, 203, 204

ecosystem.. vii, 1, 106, 118, 152, 157, 158, 

201, 203, 204, 205, 212

endangered .. 25, 41, 43, 45, 81, 82, 86, 89, 

99, 102, 190, 207

fuels....iii, 1, 3, 4, 5, 13, 14, 16, 19, 24, 27, 

34, 44, 45, 48, 55, 57, 58, 60, 85, 89, 90,

91, 93, 94, 95, 97, 98, 101, 102, 104, 

105, 110, 113, 115, 123, 128, 130, 132, 

139, 141, 142, 143, 145, 147, 148, 149, 

150, 151, 152, 153, 154, 155, 156, 157, 

158, 159, 160, 172, 183, 200, 201, 203, 

206, 207, 212, 216, 223, 228, 230, 233, 

236

Management Indicator Species... 7, 80, 81, 

82, 85, 91, 105, 106, 107, 191, 197, 203,

217

MIS ... 82, 85, 89, 91, 92, 95, 99, 102, 105, 

106, 107, 108, 109, 112, 114, 118, 120, 

121, 191, 193, 203, 217

Pacific fisher ... vii, 2, 7, 26, 101, 104, 159, 

194

plants..... 16, 37, 41, 42, 43, 44, 45, 46, 47, 

199, 200, 201, 202, 203, 204, 205, 206, 

207

prescribed burning iii, ix, x, 12, 19, 47, 61, 

91, 111, 113, 116, 117, 138, 158, 190, 

200

riparian .. 18, 19, 23, 24, 43, 44, 45, 46, 81, 

85, 86, 87, 89, 93, 94, 95, 96, 97, 98, 

101, 104, 123, 125, 127, 193, 205, 207, 

209, 211, 212, 214, 223, 227, 230, 231, 

232

sensitive. 16, 17, 19, 25, 41, 42, 43, 45, 46, 

47, 49, 51, 81, 82, 89, 95, 99, 102, 127, 

128, 145, 157, 194, 214, 223, 224, 225, 

227, 228, 230

soil... 17, 43, 44, 45, 46, 48, 49, 50, 51, 52, 

54, 55, 56, 57, 58, 94, 95, 96, 104, 125, 

127, 133, 134, 140, 141, 142, 152, 153, 

184, 189, 191, 202, 206, 224, 225, 226, 

227, 229, 231, 232, 233

SPLATs............................................ 12, 91

stand density.... 3, 27, 89, 96, 97, 101, 104, 

116, 117, 136, 137, 138, 139, 142, 145, 

189, 255

thinning .... ix, 4, 12, 13, 17, 25, 27, 33, 47, 

56, 57, 59, 61, 85, 88, 89, 90, 91, 92, 93,

94, 95, 96, 97, 100, 101, 103, 104, 109, 

116, 117, 124, 126, 128, 129, 130, 131, 

132, 133, 135, 136, 137, 138, 139, 140, 

141, 142, 143, 144, 149, 154, 155, 157, 

235

threatened.... 25, 41, 43, 45, 81, 82, 89, 99, 

102, 190, 205

wildfires .....iii, 3, 4, 12, 39, 110, 113, 115, 

116, 117, 119, 145, 152, 171, 172, 232, 

255

WUI..... 1, 3, 5, 7, 12, 14, 19, 27, 138, 148, 

149, 158, 207

Sierra National Forest – Appendix A – Map Package 221

Appendices

Appendix A – Map Package for Sugar Pine 

Adaptive Management Project_________________

Provided as a separate document with Final Environmental Impact Statement.

Sierra National Forest – Appendix B – Best Management Practices 223

Appendix B – Best Management Practices 

Associated with Sugar Pine Adaptive Management 

Project ____________________________________

BMP Name, Objective, and 

Direction

Application to the Sugar Pine Project

BMP 1-1 Timber Sale Planning 

Process: To incorporate water 

quality and hydrologic 

considerations into the timber 

sale planning process.

Implemented through the Riparian Conservation Objectives/Forest 

Plan Consistency report, specification of operational BMPs, 

Environmental Analysis including interdisciplinary team office and 

field discussions, and incorporation of water quality protection 

measures in the Timber Sale Contract for the KRP EIS.

BMP 1-4 Use of Sale Area 

Maps (SAM) and/or Project 

Maps for Designating Water 

Quality Protection Needs: To 

ensure recognition and protection 

of areas related to water quality 

protection delineated on a SAM 

or project map. 

The sale administrator and purchaser will review these areas on the 

ground prior to commencement of ground disturbing activities. 

Examples of water quality protection features that will be 

designated on the project map include:

a. Location of streamcourses and riparian zones to be protected, 

including the width of the protection zone for each area.

b. Wetlands (meadows, lakes, springs, etc.) and other sensitive

areas (such as shallow soils) to be protected. 

c. Boundaries of harvest units, specified roads and roads where 

hauling activities are prohibited or restricted, areas of different 

skidding and/or yarding methods, including post-harvest fuels

treatments, and water sources available for purchaser use.

BMP 1-5 Limiting the 

Operating Period of Timber 

Sale Activities: To ensure that 

the purchasers conduct their 

operations, including erosion 

control work, road maintenance, 

and so forth, in a timely manner, 

within the time frame specified in 

the Timber Sale Contract.

The purchaser contract operation period will be limited to contractspecified periods when adverse environmental effects are not likely. 

The Sale Administrator will close down operations due to rainy 

periods, high water, or other adverse operating conditions in order 

to protect resources.

BMP 1-8 Streamside 

Management Zone 

Designation: 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. 

Streamside management zones (SMZs ) have been supplemented 

with RMAs and RCAs (USDA-FS 2004b) as described in Appendix 

E and the Aquatics design measures. 

Within SMZs, the constraints defined in Sierra Supplement No. 1 

(USDA Forest Service, 1989) apply. This includes no self-propelled 

ground based equipment, a minimum groundcover of 50%, and 

shade canopy may not be modified in a way that affects stream 

temperature. 

Modifications to these guidelines are possible where site-specific 

needs exist if the action is reviewed by a hydrologist or fisheries 

biologist.
Appendices

224 Sierra National Forest

BMP Name, Objective, and 

Direction

Application to the Sugar Pine Project

BMP 1-9 Determining Tractor 

Loggable Ground: To minimize 

erosion and sedimentation 

resulting from ground 

disturbance of tractor logging 

systems. 

Limit ground skidding and machine piling with tractors to slopes 

less than 35%. Endlining can be used to remove logs from steeper 

slopes. Ground disturbance on areas of shallow soils, notably soils 

adjacent and abutting to rock outcrops, will be avoided. 

BMP 1-10 Tractor Skidding 

Design: By designing skidding 

patterns to best fit the terrain, the 

volume, velocity, concentration, 

and direction of runoff water can 

be controlled in a manner that 

will minimize erosion and 

sedimentation.

The sale administrator and purchaser will designate all skid trails 

prior to ground disturbing activities. If uncertainty arises regarding 

potential resource impacts of skid trail location, consult with an 

earth science specialist (i.e., hydrologist, aquatic biologist, or soil

scientist). 

BMP 1-11 Suspended Log 

Yarding in Timber harvesting:

To protect the soil mantle from 

excessive disturbance; to 

maintain the integrity of the SMZ 

or other sensitive watershed area; 

to control erosion on cable 

corridors.

Helicopter yarding has not been specified on steep slopes in this 

project.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Appendix B – Best Management Practices 225

BMP Name, Objective, and 

Direction

Application to the Sugar Pine Project

BMP 1-12 Log Landing 

Location: To locate new 

landings in such a way as to 

avoid watershed impacts and 

associated water quality 

degradation 

The following criteria are to be used by the Sale Administrator 

when evaluating landings:

a. The cleared or excavated size of landings will not exceed that 

needed for safe and efficient skidding and loading operations. 

Trees considered dangerous will be removed around landings to 

meet the safety requirements of OSHA.

b. Selected landing locations will involve the least amount of 

excavation and fill possible. Landings must be located outside 

of SMZs.

c. Locate landings near ridges away from headwater swales in 

areas that will allow skidding without crossing stream channels, 

violating SMZs, or causing direct deposit of soil and debris to a 

stream. 

d. Locate landings where the least number of skid roads will be 

required, and sidecast can be stabilized without entering 

drainages or affecting other sensitive areas. Keep the number of 

skid trails entering a landing to a minimum.

e. Position landings such that the skid road approach will be nearly 

level as feasible, to promote safety and to protect soil from 

erosion.

f. Avoid excessive fills associated with landings constructed on 

old landslide benches. 

g. Construct stable landing fills or improve existing landings by 

using appropriate compaction and drainage specifications. 

In some cases, using an existing landing located within an RCA or 

CAR is preferable to constructing a new landing outside of it. These 

situations will be reviewed on a site-by-site basis by an earth 

science specialist (aquatics, hydrology, geology, or soils). 

BMP 1-13 Erosion Prevention 

and Control Measures during 

Timber Sale Operations: To 

ensure that the purchasers‘ 

operations will be conducted 

reasonably to minimize soil

erosion.

Timber purchaser responsibilities for erosion control will be set 

forth in the Timber Sale Contract. Equipment will not be operated 

when ground conditions are such that excessive damage will result. 

The kinds and intensity of control work required of the purchaser 

will be adjusted by the sale administrator to ground and weather 

conditions with emphasis on controlling overland runoff, erosion, 

and sedimentation. 

Erosion control work required by the contract will be kept current. 

At certain times of the year this means daily, if precipitation is 

likely or weekly when precipitation is predicted for the weekend. 

Erosion prevention measures must be applied no later than October 

1 and immediately upon completion of activity begun after 

November 1. 

If the purchaser fails to perform seasonal erosion control work prior 

to any seasonal period of precipitation or runoff, the Forest Service 

may temporarily assume responsibility, complete the work, and use 

any unencumbered deposits as payment for the work.
Appendices

226 Sierra National Forest

BMP Name, Objective, and 

Direction

Application to the Sugar Pine Project

BMP 1-16 Log Landing 

Erosion Protection and 

Control: To reduce the impacts 

of erosion and subsequent 

sedimentation associated with log 

landings by use of mitigating 

measures. 

Landings will be properly cross-ditched, ripped (if soils are 

compacted), re-contoured (as necessary), and mulched after use and 

before the winter precipitation period, whichever comes first. 

Excess material not needed for erosion control can be piled and 

burned. Upon completion of the project, consult with the 

hydrologist or soil scientist to determine the need for additional soil 

protection measures.

BMP 1-17 Erosion Control of 

Skid Trails: To protect water 

quality by minimizing erosion 

and sedimentation derived from 

skid trails. 

Erosion control measures will be installed on all skid trails, tractor 

roads, and temporary roads. Erosion control measures include, but 

are not limited to, cross ditches (water bars), organic mulch, and 

ripping. 

Cross ditches will be spaced according to the guidelines below, 

maintained in a functioning condition, and placed in locations 

where drainage would naturally occur (i.e., swales). The level of 

maintenance will be contingent upon existing or predicted weather 

patterns as determined by the Sale Administer (see BMP 1-13).

Minimum Cross Drain Spacing

% Slope Maximum Spacing

0 - 15 125 feet

15 - 35 45 feet

BMP 1-18 Meadow Protection 

during Timber Harvesting: To 

avoid damage to the ground 

cover, soil, and hydrologic 

function of meadows.

Mechanical equipment is not permitted in meadows unless 

specifically authorized by an aquatic biologist and hydrologist.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Appendix B – Best Management Practices 227

BMP Name, Objective, and 

Direction

Application to the Sugar Pine Project

BMP 1-19 Streamcourse and 

Aquatic Protection: The 

objectives of this BMP are:

1) To conduct management 

actions within these areas in a 

manner that maintains or 

improves riparian and aquatic

values. 

2) To provide unobstructed 

passage of stormflows. 

3) To control sediment and other 

pollutants entering 

streamcourses.

4) To restore the natural course 

of any stream as soon as 

practicable, where diversion of 

the stream has resulted from 

timber management activities. 

a. The location and method of crossings on Class IV and V 

streams must be agreed to by the sale administrator (SA) prior 

to construction. 

b. Stream crossings on Class I – III streams must be approved by 

the hydrologist and aquatic biologist. 

c. Damage to stream banks and channels will be repaired to the 

extent practicable. 

d. All sale-generated debris will be removed from streamcourses, 

unless otherwise agreed to by the SA, and in an agreed upon 

manner that will cause the least disturbance. 

e. Felled trees will not be pulled across perennial or intermittent 

stream channels without prior approval by the hydrologist or 

aquatic biologist. 

f. Methods for protecting water quality while utilizing tractor skid 

trail design in stream course areas where harvest is approved 

include: (1) end lining, (2) falling to the lead, and (3) utilizing 

specialized equipment with low ground pressure such as feller 

buncher harvester. 

g. Water bars or other erosion control structures will be located so 

as to disperse concentrated flows and filter out suspended 

sediments prior to entry into streamcourse. 

h. Material from temporary road construction and skid trail 

streamcourse crossings will be removed and streambanks 

restored to the extent practicable. 

i. Special slash treatment site preparation activities will be 

prescribed in sensitive areas to facilitate slash disposal without 

use of mechanized equipment. 

j. Project-related bare soil areas (e.g. skid trails, landings, 

temporary roads, etc.) will be covered with existing native 

vegetation mulch, organic debris, or certified weed free straw to 

at least 50%, well distributed cover, and cross-ditched per BMP 

1-17 requirements.

BMP 1-20 Erosion Control 

Structure Maintenance: To 

ensure that constructed erosion 

control structures are stabilized 

and working

During the period of the timber sale contract, the purchaser will 

provide maintenance of soil erosion control structures contracted by 

the purchaser until they become stabilized, but not more than one 

year after their construction. If the purchaser fails to do seasonal 

maintenance work, the Forest Service may assume the 

responsibility and charge the purchaser accordingly. The Forest 

Service sale administrator is responsible for ensuring erosion 

control maintenance work is completed.
Appendices

228 Sierra National Forest

BMP Name, Objective, and 

Direction

Application to the Sugar Pine Project

BMP 1-21 Acceptance of 

Timber Sale Erosion Control 

Measures before Sale Closure:

To ensure the adequacy of 

required erosion control work on 

timber sales. 

The sale administrator must inspect erosion control measures to 

ensure their adequacy prior to accepting closure on the unit and/or 

sale. 

The effectiveness of erosion control measures will be evaluated 

using BMPEP protocols (see Monitoring Plan) after the sale area 

has been through one or more wet seasons. This evaluation is to 

ensure that erosion control treatments are in good repair and 

functioning as designed before releasing the purchaser from 

contract responsibility. 

The purchaser is responsible for repairing erosion control 

treatments that fail to meet criteria in the Timber Sale Contract, as 

determined by the Sale Administer, for up to one year past closure 

of the sale. 

BMP 1-22 Slash Treatment in 

Sensitive Areas: To maintain or 

improve water quality by 

protecting sensitive areas from 

degradation which would likely 

result from using mechanized 

equipment for slash disposal. 

All burn piles made with mechanical equipment must be located 

outside of the SMZ.

Hand piles will be kept at least 20 feet away from all streams, 

meadows, springs, seeps, and other sensitive aquatic areas. 

In Alternative 3, special mechanized fuels treatment has been 

specified in sub-watersheds with cumulative watershed effects 

concerns in order to minimize ground disturbance.

BMP 2-1 General guidelines for 

the Location and Design of 

Roads: To locate and design 

roads with minimal resource 

damage. 

The following considerations are incorporated into the planning 

process of road location and design. These measures are 

preventative, apply to all transportation activities, and indirectly 

protect water quality:

a. Transportation facilities will be developed and operated to best 

meet the resource management objectives with the least adverse 

effect on environmental values. 

b. The location, design, and construction of roads will include the 

use of the IDT. 

c. Sensitive areas such as wetlands, inner gorges, and unstable 

ground will be avoided to the extent practicable.

d. Stream crossings will be designed to provide the most cost 

efficient drainage facility consistent with resource protection, 

facility needs, and legal obligations. 

BMP 2-2 Erosion Control Plan:

To mitigate and control erosion 

through effective planning prior 

to initiation of construction. 

Any new construction would be subject to erosion control measures 

as per an IDT approved plan that may include but not be limited to 

waterbar installation, sediment fencing, culvert installation and 

armoring, placement of straw waddles, approved straw cover and/or 

slash and any other method necessary to mitigate erosion and 

sediment routing in the project subwatershed(s).
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Appendix B – Best Management Practices 229

BMP Name, Objective, and 

Direction

Application to the Sugar Pine Project

BMP 2-3 Timing of 

Construction Activities: To 

minimize erosion by conducting 

operations during minimal runoff 

periods and when soils are dry 

and less prone to compaction. 

Ground-disturbing activities will occur when soils are dry. In some 

cases soils may never dry sufficiently. Ground-disturbing work that 

occurs off of existing roads will occur during the dry season and 

will reduce ground disturbance as much as possible.

BMP 2-5 Road Slope 

Stabilization Construction 

Practices: To reduce 

sedimentation by minimizing 

erosion from road slopes and 

slope failure along roads.

An adequate soils and geologic investigation will be conducted 

when finalizing new road construction designs for: correct cut and 

fill steepness based on the angle of repose for the type of material; 

methods to handle surface runoff; and necessary compaction 

standards and surfacing needs.

BMP 2-7 Control of Road 

Drainage: To minimize the 

erosive effects of water 

concentrated on roads, to 

disperse runoff from road 

surfaces, to lessen sediment yield 

from roaded areas, and to 

minimize erosion of the road 

prism. 

Newly constructed or reconstructed roads will be designed to 

reduce hydrologic connectivity and soil erosion wherever feasible. 

The sale administrator or other Forest Service representative will 

ensure that roads are adequately maintained during project 

implementation to ensure that road drainage features function as 

designed.

BMP 2-8 Constraints Related 

to Pioneer Road Construction:

To minimize sediment 

production and mass wasting 

from pioneer road construction. 

a. Roads will be constructed within the planned roadway limits 

unless otherwise specified or approved by the ER or COR.

b. Pioneer roads will be located to prevent undercutting of the 

designated final cut slope, avoid deposition of materials outside 

the designated roadway limits, and accommodate drainage with 

temporary culverts or log crossings. 

c. Erosion control work will be completed prior to the rainy season 

and in accordance with the contract.

d. Crossing sites on live streams will be dewatered during 

construction with diversion devices (see BMP 2-15). 

BMP 2-9 Timely Erosion 

Control Measures on 

Incomplete Roads and Stream 

Crossing Projects: To minimize 

erosion and sedimentation from 

disturbed ground on incomplete 

projects. 

Erosion control must be completed before the rainy season (usually 

October in the KRP project area). Preventative measures for timely 

erosion control include:

a. Removal of temporary culverts, culvert plugs, diversion dams, 

or elevated stream crossings.

b. Installation of temporary culverts, side drains, flumes, cross 

drains, diversion ditches, energy dissipaters, dips, sediment 

basins, berms, debris racks, or other facilities needed to control 

erosion. 

c. Removal of debris, obstructions, and spoil material from 

channels and floodplains. 

d. Planting vegetation, mulching, and/or covering exposed 

surfaces with jute mates or other protective material.
Appendices

230 Sierra National Forest

BMP Name, Objective, and 

Direction

Application to the Sugar Pine Project

BMP 2-10 Construction of 

Stable Embankments: To 

construct embankments with 

materials and methods which 

minimize the possibility of 

failure and subsequent water 

quality degradation. 

Roadways will be designed and constructed as stable and durable 

earthwork structures with adequate strength to support the 

treadway, shoulders, subgrade and road traffic loads.

BMP 2-11 Control of Sidecast 

Material During Construction 

and Maintenance: To minimize 

sediment production originating 

from sidecast material during 

road construction or 

maintenance.

Sidecasting is not permitted within SMZs. 

Waste areas must be located where excess material can be deposited 

and stabilized.

BMP 2-12 Servicing and 

refueling equipment: 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. 

Storage of hazardous materials (including fuels) and servicing and 

refueling of equipment will be conducted at pre-designated 

locations outside of RCAs and CARs. If fueling and/or storage of 

hazardous materials are needed within RCAs or CARs, those sites 

must be reviewed and approved by the District Hydrologist or 

Aquatic Biologist. Additional protection measures, such as 

containment devices, may be necessary. 

BMP 2-13 Control of 

Construction and Maintenance 

Activities Adjacent to SMZs:

To protect water quality by 

controlling construction and 

maintenance actions within and 

adjacent to SMZs so that SMZ 

functions are not impaired. 

Construction and maintenance fills, sidecast, and end-hauled 

materials will be kept out of SMZs except at designated crossing 

sites to minimize the effect to the aquatic environment. 

BMP 2-14 Controlling InChannel Excavation: To 

minimize stream channel 

disturbances and related sediment 

production.

There will be no in-channel or streambank excavation during any 

phase of project activities unless authorized by the district 

hydrologist or aquatic biologist.

BMP 2-16 Stream Crossings on 

Temporary Roads and Skid 

Trails: 

Mechanical equipment crossing of perennial and intermittent 

(generally class I – III) streams is not permitted unless approved by 

the district hydrologist or aquatic biologist. Ephemeral streams 

(stream class IV and V) may be crossed at designated locations as 

agreed upon by the sale administrator and purchaser. Designate skid 

trails to avoid stream crossings and SMZs wherever possible. 

Designated crossings must be as perpendicular to the channel as 

possible and avoid sensitive soils and riparian vegetation damage. 

Stream banks must be repaired upon completion of the project.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Appendix B – Best Management Practices 231

BMP Name, Objective, and 

Direction

Application to the Sugar Pine Project

BMP 2-19 Disposal of Right-ofWay and Roadside Debris: To 

ensure that organic debris 

generated during road 

construction is kept out of 

streams so that channels and 

downstream facilities are not 

obstructed. 

If slash generated by road work is disposed of within SMZs, it will 

be piled and burned or chipped. Material may also be removed from 

the SMZ for disposal.

BMP 2-21 Water Source 

Development Consistent with 

Water Quality Protection: To 

supply water for roads and fire 

protection while maintaining 

existing water quality.

Water drafting will not occur in streams when the base discharge is 

less than 1.5 cfs, and will not draft more than 50% of the ambient 

discharge over 1.5 cfs. New drafting sites shall be approved by the 

District Hydrologist or Fisheries/Aquatic Biologist and located to 

minimize sediment and maintain riparian resources, channel 

condition, meadow integrity, and aquatic species viability and 

habitat. Approaches will be as near perpendicular to the stream as 

possible and will be gravel surfaced or otherwise stabilized. 

If water-drafting is required, pumps with low entry velocity and 

suction strainers with screens less than 2 mm in size (1/8 in.) will 

be used.

BMP 2-22 Maintenance of 

Roads: To maintain roads in a 

manner that provides for water 

quality protection by minimizing 

rutting, failures, sidecasting, and 

blockage of drainage facilities, 

all of which can cause erosion, 

sedimentation, and deteriorating 

watershed conditions.

Roads needed for project activities will be brought to current 

engineering standards of alignment, drainage, and grade before use, 

and will be maintained through the life of the project. Roads will be 

inspected at least annually to determine what work, if any, is 

needed to keep ditches, culverts, and other drainage facilities 

functional and the road stable. 

BMP 2-23 Road Surface 

Treatment to Prevent Loss of 

Materials: 

Surface stabilization will be considered where grades exceed 12% 

or road is within riparian conservation areas.

BMP 2-24 Traffic Control 

During Wet Periods: To reduce 

road surface disturbance and the 

rutting of roads, and to minimize 

sediment washing from disturbed 

road surfaces.

On roads not designated for all weather or winter haul, heavy 

equipment operations will be limited until the period after the soil

has dried in the top 12 inches in the spring.

BMP 2-26 Obliteration or 

Decommissioning of Roads: To 

reduce sediment generated from 

temporary roads, unneeded 

system and non-system roads by 

obliterating or decommissioning 

them at the completion of the 

intended use.

Temporary roads will be obliterated after serving their intended 

purpose for this project. This includes: (1) road effectively 

barricaded; (2) road effectively drained by measures such as recontouring or outsloping to return surface to near natural hydrologic 

function; (3) a well distributed mulch or organic cover provides at 

least 50% cover, or road surface is revegetated using local native 

species; (4) sideslopes are reshaped and stabilized to match the 

natural contour (as necessary); and (5) stream crossings are 

removed and natural channel geometry is restored. 

If non-local mulch is used (such as straw), it must be approved by 

the Forest Service as weed free. 
Appendices

232 Sierra National Forest

BMP Name, Objective, and 

Direction

Application to the Sugar Pine Project

BMP 5-8 Pesticide Application 

According to Label Directions 

and Applicable Legal 

Requirements: To avoid water 

contamination by complying with 

all label instructions and 

restrictions for use. 

This BMP requires glyphosate applicators to strictly adhere to 

pesticide label instructions. There is no pesticide application 

proposed in the Sugar Pine Adaptive Management Project.

BMP 5-11 Cleaning and 

Disposal of Pesticide 

Containers and Equipment: To 

prevent water contamination 

resulting from cleaning or 

disposal of pesticide containers. 

The cleaning and disposal of glyphosate containers will be done in 

accordance with Federal, State, and local laws, regulations and 

directives. There is no pesticide application proposed in the Sugar 

Pine Adaptive Management Project.

BMP 5-12 Streamside Wet 

Area Protection During 

Pesticide Spraying: To 

minimize the risk of pesticide 

inadvertently entering waters, or 

unintentionally altering the 

riparian area, SMZ, or wetland. 

When spraying glyphosate, an untreated strip of land and vegetation 

will be left alongside surface waters, wetlands, riparian areas, or 

SMZ. Strip widths established by the IDT are 5 feet for dry 

channels and 25 feet for flowing channels (see Herbicide Use 

design criteria). There is no pesticide application proposed in the 

Sugar Pine Adaptive Management Project.

BMP 6-1 Fire and Fuel 

Management Activities: 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. 

The project action alternatives are designed to achieve the desired 

conditions of BMP 6-1. 

BMP 6-2 Consideration of 

Water Quality in Formulating 

Fire Prescriptions: To provide 

for water quality protection while 

achieving the management 

objectives through the use of 

prescribed fire. 

Prescribed burning is planned at the minimum intensity and severity 

necessary to achieve management objectives, and each Burn Plan 

will incorporate all relevant design measures from this EIS. 

BMP 6-3 Protection of Water 

Quality from Prescribed fire 

Effects: To maintain soil

productivity, minimize erosion, 

and minimize ash, sediment, 

nutrients, and debris from 

entering water bodies.

Fires will be allowed to back into riparian vegetation, but direct 

lighting within riparian vegetation will not occur. 

All fire lines within RCAs and CARs will be water barred per BMP 

1-17 spacing requirements. Fire lines within RCA (i.e., 150 ft., 

seasonal streams, and 300 ft. perennial streams, springs, and 

meadows) will be designed and constructed to reduce sediment 

entry into channels. Fire lines in RCAs will cross perpendicular to 

streams and follow the natural landscape contour as much as 

possible. Firelines within the SMZ will be hand cut. Waterbars will 

be placed on either side of each stream crossing to prevent or 

reduce sediment entry into streams. 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Appendix B – Best Management Practices 233

BMP Name, Objective, and 

Direction

Application to the Sugar Pine Project

BMP 6-5 Repair or 

Stabilization of Fire 

Suppression Related 

Watershed Damage: To 

stabilize all areas that have had 

their erosion potential 

significantly increased, or their 

drainage pattern altered by 

suppression related activities.

In the event of a wildfire, protection of resources would be 

evaluated under the Burned Area Emergency Response, assessment 

and treatment Implementation protocol.

BMP 6-6 Emergency 

Rehabilitation of Watersheds 

Following Wildfires: To 

minimize as far as practicable: 1.) 

loss of soil and onsite 

productivity; 2.) overland flow, 

channel obstruction and 

instability; 3.) threats to life and 

property both on-site and off-site

In the event of a wildfire, protection of resources would be 

evaluated under the Burned Area Emergency Response, assessment 

and treatment Implementation protocol.. 

BMP 7-3 Protection of 

Wetlands: To avoid adverse 

water quality impacts associated 

with destruction, disturbance, or 

modification of wetlands.

Ground disturbing activities will not occur in wetlands or meadows. 

BMP 7-4 Oil and Hazardous 

Substance Spill Contingency 

Plan and Spill Prevention 

Containment and 

Countermeasure (SPCC) Plan:

To prevent contamination of 

water from accidental spills.

A spill contingency plan and spill prevention and countermeasure 

plan (SPCC) must be prepared if hazardous materials (including 

fuels and oils) stored on the Sierra National Forest exceed 1320 

gallons, or if a single container exceeds 660 gallons.

The plan will at a minimum include: the types and amounts of 

hazardous materials located in the project area, pre-project 

identified locations for hazardous materials storage and 

fueling/maintenance activities (must be located outside of RCA and 

CAR unless prior approval by District Hydrologist or Aquatic 

Biologist is obtained), methods for containment of hazardous 

materials and contents of on-site emergency spill kit, and a 

contingency plan (including contact names with phone numbers) to 

implement in the event of a spill. 

The SPCC plan must be approved by the Forest Service prior to 

project implementation.

Sierra National Forest – Appendix C – Data Tables 235

Appendix C – Data Tables for Sugar Pine Adaptive 

Management Project _________________________

Sugar Pine Plot Data Summary Table

Existing and Proposed Action Conditions

The Sugar Pine plot data summary table displays plot data collected within the proposed 

treatment areas displayed on the Sugar Pine EIS map (Map 1). Variable plots were taken using a 

30 Basal Area Factor prism. Trees less than 4 inches dbh were not sampled (4 inches was the 

smallest diameter being considered for biomass treatments). Due to the wide variability of 

vegetation present within these proposed treatment areas and the project as a whole, plots 

representing similar stand conditions were grouped together by proposed treatment area. It would 

be misleading to display an average for the project area. The column labeled ―No. Plots‖ displays 

the number of plots within each grouping. Although plots were taken within specific potential 

treatment areas, similar stand conditions may be present in other areas as well. Plot conditions 

varied widely from a basal area low of 90 ft2to 510 ft2per acre. Plot data recorded variations in 

trees 4 inches dbh and larger per acre from 15 to over 1000. In some plots no small trees were 

captured in the sample while in others hundreds per acre were. Several plots represent ―groupings 

of conifers with increased BA retention (20 to 30-inch dbh)‖ similar to those retained in the Cedar 

Valley project area. 

The term ―light‖ which accompanies a number of the proposed treatment areas refers to those 

areas/plots where the basal area present is generally light and would result in minimal removal of 

trees 10 inches dbh and larger. Although an area may be designated as ―light‖ due to lighter basal 

areas present, there may still be a need to treat heavily stocked pockets of smaller diameter trees 

(less than 4 inches dbh) that may not have been sampled during the sampling process.

The majority of the Sugar Pine project area was heavily railroad logged between 1918 and 1924. 

Logs were processed at the mill at Sugar Pine. The 1944 aerial photos provide a graphic display 

of the extent of that activity. In some areas scattered older trees were left following logging. The 

vast majority of conifers present today were seedlings and saplings present in the understory that 

survived the logging entry. Except for the 40 year old pine plantation adjacent to Road 6S07, a 

small pine plantation along Road 5S79, and a couple of others in the Big Sandy area, stands 

proposed for treatment average 90 to 110 years of age. Overall average site quality sampled is a 

Dunning 1. 

Plot data indicates that the majority of the stands within the area surrounding Sugar Pine are a 

pine type that is quite heavy to the more shade tolerant, but fire prone, incense cedar. In this area, 

mixed conifer stands where white fir is a significant component, are found in only a few 

locations, predominantly near cooler, more moist, draws. White fir stands mixed with red fir and 

pines comprise a large proportion of the stands in the smaller subwatershed being studied near 

Big Sandy as a part of the hydrology portion of the project. Crown Closures present were taken 

from the data sheets with a reduction made for crown overlap. Suppressed trees were not included 

as part of the existing crown closure.

The plot data and summaries shown provide insight into the variability of the vegetation present 

within the proposed treatment areas. During collection of the plot data, trees that might be 

selected for removal under the proposed thinning prescription for that species composition were 

noted. From that data, potential leave and cut basal area, leave and cut tree sizes and numbers and 
Appendices

236 Sierra National Forest

existing and post harvest crown closures were determined. On a number of plots, for various 

reasons, leave basal area exceeds targets for that species composition.

Legend for Sugar Pine Plot Data Summary Tables

Location

Number Corresponds to the Treatment Area Number on Project Map

(MC) represents an area that is considered a Mixed Conifer dominated stand

(plt) represents a pine plantation

(WF) represents an area that is considered a White Fir dominated stand

Remainder are considered pine dominated stands 

Species Composition

PP – Ponderosa Pine

SP – Sugar Pine

WF – White Fir

RF – Red Fir

IC – Incense Cedar

OK – Oak

Crown Closure

Given in percent (reduced for crown overlap). CWHR relationship for crown closure designation.

P: 25-39%

M: 40-59%

D: 60% +

Desired leave Basal Area for comparison

Pine dominated stands = 150-180 ft2per acre

Mixed Conifer (MC) dominated stands = 210 ft2per acre

White Fir (WF) dominated stands = 240 ft2per acre 

For Alternative 3 and 4 a surrogate of 10 inches dbh was used to display the changes that would 

occur based on only removing ladder fuels for each alternative. It is anticipated that some trees 

larger than 10 inches dbh that contribute to fuel ladders will be removed. Since these will be 

either intermediate or suppressed trees, overall crown closures following treatment will not 

change.

Age

Calculated from one sampled tree per plot. The majority of the conifers within the proposed 

treatment area are 90-110 years old. 

Mean Diameter (Dia)

Calculated from trees within plots
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Appendix C- Data Tables 237

Table 49. Sugar Pine Plot Data Summary, Existing and Proposed Action (Alternative 2) Conditions Location

Species Composition

Age

Site

Trees 5-inch dbh and larger Basal Area 5 inches 

and larger Crown Closure

Mean Dia

No Plots

PP SP WF RF IC OK

Total

Cut 5-10

Cut 11-20Cut 21-29

Leave

Total

Cut 5-20

Cut 21-29

Leave

Before After

3 light 86 0 0 0 14 0 90 1 102 0 38 0 64 210 30 0 180 64 (D) 64 (D) 19 1

3 34 3 14 0 38 10 84 1 111 0 37 14 60 290 60 40 190 89 (D) 66 (D) 22 3

4 light 37 3 11 0 47 3 112 1 109

B

25 0 0 84 142

B

7 0 135 42 (M) 42 (M) 15 8

4 34 6 0 0 47 13 98 1 216 74 73 12 57 320 100 30 190 97 (D) 83 (D) 16 3

4 Oak 8 0 0 0 31 62 87 1 66 0 0 0 66 130 0 0 130 88 (D) 88 (D) 12 3

5 light 73 9 18 0 0 0 86 1 62 0 0 0 62 165 0 0 165 39 (P) 39 (P) 22 2

6 62 8 15 0 15 0 134 1 73 0 0 0 73 195 0 0 195 56 (M) 56 (M) 22 2

6 MC 5 18 45 0 32 0 126 1 199 28 77 9 85 330 75 30 225 77 (D) 60 (D) 17 2

7 light 19 0 0 0 81 0 129 1 99A

0 30 6 63 225

A

30 15 180 52 (M) 45 (M) 12 2

7 38 0 0 0 62 0 94 1 251 98 86 19 48 420 150 60 210 100 (D) 70 (D) 17 3

8 MC 6 6 47 0 42 0 107 1 117

A

12 47 5 53 270

A

52 15 203 57 (M) 48 (M) 21 4

8 46 17 0 0 25 13 120 1 231 124 38 16 53 360 105 45 210 100 (D) 78 (D) 16 2

8 light 33 17 0 0 50 0 107 1 101 0 0 0 101 180 0 0 180 53 (M) 53 (M) 18 1

10 74 5 0 0 21 0 120 1 136 0 65 3 66 285 75 15 195 88 (D) 60 (D) 20 2

10 

light

25 4 14 0 50 7 100 1 240 90 5 0 145 210 30 0 180 68 (D) 61 (D) 12 4
Appendices

238 Sierra National Forest Location

Species Composition

Age

Site

Trees 5-inch dbh and larger Basal Area 5 inches 

and larger Crown Closure

Mean Dia

No Plots

PP SP WF RF IC OK

Total

Cut 5-10

Cut 11-20Cut 21-29

Leave

Total

Cut 5-20

Cut 21-29

Leave

Before After

12 0 50 10 0 40 0 65 1 71 0 0 27 44 300 0 90 210 59 (M) 52 (M) 28 1

14 MC 0 31 50 0 19 0 115 1 116 0 32 32 52 480 30 120 330 92 (D) 73 (D) 28 1

23 MC 31 0 63 0 6 0 83 1 112 0 14 48 50 480 30 150 300 100 (D) 70 (D) 28 1

30 plt 100 0 0 0 0 0 43 1 149 0 67 0 82 240 90 0 150 90 (D) 60 (D) 17 1

33 WF 0 5 50 45 0 0 113 1 138 37 46 5 50 320 65 15 240 53 (M) 45 (M) 20 6

34 

light 

WF

0 0 80 20 0 0 100 1 69 0 0 0 69 240 0 0 240 45 (M) 45 (M) 25 2

A

Plus 172 4-inch dbh trees/acre (15 ft2) to be removed (not included in totals)

B

Plus 86 4-inch dbh trees/acre (7.5 ft2) to be removed (not included in totals)
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Appendix C- Data Tables 239

Table 50. Sugar Pine Plot Data Summary, Existing and Alternative 3 Location

Species Composition

Age

Site

Trees 5-inch dbh and larger Basal Area 5 inches 

and larger Crown Closure

Mean Dia

No Plots

PP SP WF RF IC OK

Total

Cut 5-10

Cut 11-20Cut 21-29

Leave

Total

Cut 5-20

Cut 21-29

Leave

Before After

3 light 86 0 0 0 14 0 90 1 102 0 38 0 64 210 30 0 180 64 (D) 64 (D) 19 1

3 34 3 14 0 38 10 84 1 111 0 37 14 60 290 60 40 190 89 (D) 66 (D) 22 3

4 light 37 3 11 0 47 3 112 1 109

B

25 0 0 84 142

B

7 0 135 42 (M) 42 (M) 15 8

4 34 6 0 0 47 13 98 1 216 74 0 0 142 320 10 0 310 97 (D) 97 (D) 16 3

4 Oak 8 0 0 0 31 62 87 1 66 0 0 0 66 130 0 0 130 88 (D) 88 (D) 12 3

5 light 73 9 18 0 0 0 86 1 62 0 0 0 62 165 0 0 165 39 (P) 39 (P) 22 2

6 62 8 15 0 15 0 134 1 73 0 0 0 73 195 0 0 195 56 (M) 56 (M) 22 2

6 MC 5 18 45 0 32 0 126 1 199 28 77 9 85 330 75 30 225 77 (D) 60 (D) 17 2

7 light 19 0 0 0 81 0 129 1 99A

0 30 6 63 225

A

30 15 180 52 (M) 45 (M) 12 2

7 38 0 0 0 62 0 94 1 251 98 86 19 48 420 150 60 210 100 (D) 70 (D) 17 3

8 MC 6 6 47 0 42 0 107 1 117

A

12 47 5 53 270

A

52 15 203 57 (M) 48 (M) 21 4

8 46 17 0 0 25 13 120 1 231 124 38 16 53 360 105 45 210 100 (D) 78 (D) 16 2

8 light 33 17 0 0 50 0 107 1 101 0 0 0 101 180 0 0 180 53 (M) 53 (M) 18 1

10 74 5 0 0 21 0 120 1 136 0 65 3 66 285 75 15 195 88 (D) 60 (D) 20 2

10 

light

25 4 14 0 50 7 100 1 240 90 5 0 145 210 30 0 180 68 (D) 61 (D) 12 4
Appendices

240 Sierra National Forest Location

Species Composition

Age

Site

Trees 5-inch dbh and larger Basal Area 5 inches 

and larger Crown Closure

Mean Dia

No Plots

PP SP WF RF IC OK

Total

Cut 5-10

Cut 11-20Cut 21-29

Leave

Total

Cut 5-20

Cut 21-29

Leave

Before After

12 0 50 10 0 40 0 65 1 71 0 0 27 44 300 0 90 210 59 (M) 52 (M) 28 1

14 MC 0 31 50 0 19 0 115 1 116 0 32 32 52 480 30 120 330 92 (D) 73 (D) 28 1

23 MC 31 0 63 0 6 0 83 1 112 0 14 48 50 480 30 150 300 100 (D) 70 (D) 28 1

30 plt 100 0 0 0 0 0 43 1 149 0 67 0 82 240 90 0 150 90 (D) 60 (D) 17 1

33 WF 0 5 50 45 0 0 113 1 138 37 46 5 50 320 65 15 240 53 (M) 45 (M) 20 6

34 

light 

WF

0 0 80 20 0 0 100 1 69 0 0 0 69 240 0 0 240 45 (M) 45 (M) 25 2

A

Plus 172 4-inch dbh trees/acre (15 ft2) to be removed (not included in totals)

B

Plus 86 4-inch dbh trees/acre (7.5 ft2) to be removed (not included in totals)

A small portion of Treatment Area 3 would only have fuel ladders removed under this alternative (effects not displayed in table).
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Appendix C- Data Tables 241

Table 51. Sugar Pine Plot Data Summary, Existing and Alternative 4 Location

Species Composition

Age

Site

Trees 5-inch dbh and larger Basal Area 5 inches 

and larger Crown Closure

Mean Dia

No Plots

PP SP WF RF IC OK

Total

Cut 5-10

Cut 11-20Cut 21-29

Leave

Total

Cut 5-20

Cut 21-29

Leave

Before After

3 light 86 0 0 0 14 0 90 1 102 0 0 0 102 210 0 0 21 64 (D) 64 (D) 19 1

3 34 3 14 0 38 10 84 1 111 0 0 0 111 290 0 0 20 89 (D) 89D) 22 3

4 light 37 3 11 0 47 3 112 1 109

B

25 0 0 84 142

B

7 0 135 42 (M) 42 (M) 15 8

4 34 6 0 0 47 13 98 1 216 74 0 0 142 320 10 0 310 97 (D) 97 (D) 16 3

4 Oak 8 0 0 0 31 62 87 1 66 0 0 0 66 130 0 0 130 88 (D) 88 (D) 12 3

5 light 73 9 18 0 0 0 86 1 62 0 0 0 62 165 0 0 165 39 (P) 39 (P) 22 2

6 62 8 15 0 15 0 134 1 73 0 0 0 73 195 0 0 195 56 (M) 56 (M) 22 2

6 MC 5 18 45 0 32 0 126 1 199 28 0 0 171 330 15 0 315 77 (D) 77 (D) 17 2

7 light 19 0 0 0 81 0 129 1 99A

0 0 0 99 225

A

0 0 225 52 (M) 52 (M) 12 2

7 38 0 0 0 62 0 94 1 251 98 0 0 153 420 40 0 380 100 (D) 100 (D) 17 3

8 MC 6 6 47 0 42 0 107 1 117

A

12 0 0 105 270

A

8 0 262 57 (M) 57 (M) 21 4

8 46 17 0 0 25 13 120 1 231 124 0 0 107 360 45 0 315 100 (D) 100 (D) 16 2

8 light 33 17 0 0 50 0 107 1 101 0 0 0 101 180 0 0 180 53 (M) 53 (M) 18 1

10 74 5 0 0 21 0 120 1 136 0 0 0 136 285 0 0 285 88 (D) 88 (D) 20 2

10 

light

25 4 14 0 50 7 100 1 240 90 0 0 150 210 23 0 187 68 (D) 68 (D) 12 4
Appendices

242 Sierra National Forest Location

Species Composition

Age

Site

Trees 5-inch dbh and larger Basal Area 5 inches 

and larger Crown Closure

Mean Dia

No Plots

PP SP WF RF IC OK

Total

Cut 5-10

Cut 11-20Cut 21-29

Leave

Total

Cut 5-20

Cut 21-29

Leave

Before After

12 0 50 10 0 40 0 65 1 71 0 0 0 71 300 0 0 300 59 (M) 59 (M) 28 1

14 MC 0 31 50 0 19 0 115 1 116 0 0 0 116 480 0 0 480 92 (D) 92 (D) 28 1

23 MC 31 0 63 0 6 0 83 1 112 0 0 0 112 480 0 0 480 100 (D) 100 (D) 28 1

30 plt 100 0 0 0 0 0 43 1 149 0 0 0 149 240 0 0 240 90 (D) 90 (D) 17 1

33 WF 0 5 50 45 0 0 113 1 138 37 0 0 101 320 5 0 315 53 (M) 53 (M) 20 6

34 

light 

WF

0 0 80 20 0 0 100 1 69 0 0 0 69 240 0 0 240 45 (M) 45 (M) 25 2

A

Plus 172 4-inch dbh trees/acre (15 ft2) to be removed (not included in totals)

B

Plus 86 4-inch dbh trees/acre (7.5 ft2) to be removed (not included in totals)
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Appendix C- Data Tables 243

Sugar Pine California Wildlife Habitat Relationship Mapping and Acres

CWHR Mapped Polygons vs. CWHR Table of Acres: Polygons on the CWHR map (Map 7) shows the generalized location of 

CWHR vegetation types found in the project area based on Geographic Information System vegetation mapping. Due to the high 

degree of variability in stand structure within the project area and the existence of aggregations within stands, further refinement of 

the CWHR vegetation typing was conducted through aerial photo interpretation and field verification by the District 

Silviculturist/Wildlife Biologist to develop CWHR Table of acres (See next pages-Table 52 & 53). This refinement may show 

increases or decreases in total acreage amounts from what is displayed in the map polygons for particular CWHR types.

Legend for CWHR Map and Table:

All CWHR size classes and canopy closures are included unless otherwise specified. 

D.B.H. = Diameter at breast height (consider 4.5 feet from the ground).

Tree size classes:

1 Seedling (<1" dbh)

2 Sapling (1"-5.9" dbh)

3 Pole (6"-10.9" dbh)

4 Small tree (11"-23.9" dbh)

5 Medium/Large tree (>24" dbh)

6 Multi-layered Tree [In Ponderosa Pine and Sierra Mixed Conifer] 

(From Mayer and Laudenslayer, 1988) 

Canopy Closure classifications:

S = Sparse Cover (10-24% canopy closure)

P = Open cover (25-39% canopy closure)

M= Moderate cover (40-59% canopy closure)

D = Dense cover (60-100% canopy closure)
Appendices

244 Sierra National Forest

California Wildlife Habitat Relationships (CWHR) 

Table 52. Sugar Pine CWHR Data, Main Project Area; Present Compared to Proposed Action (Alternative 2)

CWHR

Total Project 

Acres

Treatment 

Analysis 

Area Acres

Acres Before Treatments Acres After Treatments Total Project 

Acres After 

Tractor Mastication Treatments 1 Rx2 Tractor Mastication1 Rx2

MCH 6 1 0 0 0 0 0 0 6

MCP 38 24 0 19 0 0 19 0 38

MRI 1 0 0 0 0 0 0 0 1

MHW3M 5 1 0 0 0 0 0 0 5

MHW3D 27 15 0 0 0 0 0 0 27

MHW4M 81 15 3 7 0 3 7 0 81

MHW4D 26 17 1 14 0 1 14 0 26

MHC4P 23 23 13 5 0 13 5 0 23

MHC4M 62 50 15 26 0 15 26 2 64

MHC4D 605 325 115 66 31 115 66 29 603

MHC5D 21 4 0 4 0 0 4 0 21

PGS 3 3 0 3 0 0 3 0 3

PPN3P 6 6 1 5 0 1 5 0 6

PPN3M 16 14 5 8 1 42 8 1 53

PPN3D 186 186 167 19 0 130 19 0 149

PPN4S 8 6 0 0 0 0 0 0 8

PPN4P 56 40 40 0 0 40 0 0 56

PPN4M 312 261 136 93 0 136 93 1 313

PPN4D 1429 762 314 210 11 314 210 10 1428
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Appendix C- Data Tables 245

CWHR

Total Project 

Acres

Treatment 

Analysis 

Area Acres

Acres Before Treatments Acres After Treatments Total Project 

Acres After 

Tractor Mastication Treatments 1 Rx2 Tractor Mastication1 Rx2

PPN5M 88 80 22 56 0 22 56 0 88

PPN5D 17 7 5 0 0 5 0 0 17

SMC3S 5 5 0 0 5 0 0 5 5

SMC3M 16 16 9 2 0 12 2 0 19

SMC3D 35 21 7 14 0 4 14 0 32

SMC4S 4 4 0 0 4 0 0 4 4

SMC4P 54 36 8 21 7 8 21 7 54

SMC4M 149 120 12 55 50 12 55 55 154

SMC4D 1016 410 98 132 71 98 132 66 1011

SMC5M 8 0 0 0 0 0 0 0 8

SMC5D 30 6 0 4 2 0 4 2 30

WFR4D 9 7 1 0 6 1 0 6 9

Total 4342 2465 972 763 188 972 763 188 4342

1Note: Acres Before and After Treatment for Mastication and Rx are gross acres

2Approximately only 65% of mastication acreage will be treated. Rx burning acreage % may be substantially less than shown
Appendices

246 Sierra National Forest

Table 53. Sugar Pine CWHR Data, Hydrology Study Area; Present Compared to Proposed Action (Alternative 2)

CWHR

Total Project 

Acres

Treatment 

Analysis 

Area Acres

Acres Before Treatments Acres After Treatments Total Project 

Acres After 

Tractor Mastication Rx Tractor Mastication Rx Treatments

MCP 27 2 0 0 2 0 0 2 27

BAR 16 2 0 0 0 0 0 0 16

JPN2S 34 32 0 32 0 0 32 0 34

JPN3P 24 24 6 16 0 6 16 0 24

JPN3M 45 45 39 6 0 44 6 0 50

JPN3D 5 5 5 0 0 0 0 0 0

SMC3S 7 3 2 0 0 2 0 0 7

SMC3P 33 2 0 0 0 0 0 0 33

SMC3M 8 6 3 0 0 3 0 0 8

SMC3D 7 0 0 0 0 0 0 0 7

SMC4S 14 14 1 1 4 1 1 4 14

SMC4P 23 12 8 1 1 8 1 1 23

SMC4M 78 65 36 6 8 36 6 8 78

SMC4D 26 11 7 0 0 7 0 0 26

SMC5S 4 4 4 0 0 4 0 0 4

SMC5M 65 65 48 3 3 48 3 3 65

SMC5D 109 63 57 0 0 57 0 0 109

RFR4S 5 5 5 0 0 5 0 0 5

RFR4P 33 33 10 23 0 10 23 0 33

RFR4M 22 16 9 2 5 9 2 5 22
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Appendix C- Data Tables 247

CWHR

Total Project 

Acres

Treatment 

Analysis 

Area Acres

Acres Before Treatments Acres After Treatments Total Project 

Acres After 

Tractor Mastication Rx Tractor Mastication Rx Treatments

RFR4D 9 3 0 3 0 0 3 0 9

RFR5M 23 20 14 1 0 14 1 0 23

RFR5D 51 19 13 0 0 13 0 0 51

WTM 14 0 0 0 0 0 0 0 14

Total 682 451 267 94 23 267 94 23 682
Appendices

248 Sierra National Forest

Appendix D- Response to Comments

A Draft Environmental Impact Statement and supporting environmental analyses (resource 

specialist reports/Biological Assessments/Biological Evaluations) for the Sugar Pine Adaptive 

Management Project were provided to the public (complete list on page 196) for comment during 

the 30-day comment period. The following individuals, agencies and organizations provided 

timely comments during the 30-day comment period:

 Kirby D. Molen for Sierra Forest Products (SFP)

 Sierra Pacific Industry (SPI)

 Tom Eliason for Conservation Committee, Sierra Club-Tehipite Chapter 

(TESCTC)

 American Forest Resource Council (AFRC)

 Richard E. Kangas, Sierra Club-Tehipite Chapter (RKSCTC)

 United States Environmental Protection Agency-Region IX (USEPA)

 Sierra Forest Legacy/Sierra Club Environmental Law Program (SFCSC)

 The John Muir Project of Earth Island Institute (JMP)

The following were received after the 30-day comment period, but were considered and responses 

to their comments are presented below.

 California Forestry Association (CFA)

 United States Department of Interior (USDI)

The comments received are herein identified as being a ―Substantive Comment‖. To meet the 

definition of being a ―Substantive Comment‖, the comment must meet the following: (1) be 

within the scope of the proposed action; (2) be specific to the proposed action; (3) have a direct 

relationship to the proposed action; and (4) include supporting reasons for the Responsible 

Official to consider.

Economics Related Comments:

1. DEIS does not address at all the economic impact of the various alternatives. What will 

the cost of implementation of various alternatives be to the forest? Given the budgetary 

constraints of the forest, do differences exist in the likelihood of implementation of the 

various alternatives? This analysis would be beneficial to the decision maker in 

identifying the best alternative for this project and is a required by Section 102 (B) of the 

NEPA. (SPI) 

The Final Environmental Impact Statement on page 186 includes an economic analysis 

for the Sugar Pine Adaptive Management Project that is a comparison of product value 

after delivery to processing centers for all action alternatives. This includes an estimate 

of stump to truck costs (the cost of cutting and moving thinned material to a central 

landing) and the cost to transport both sawtimber and biomass to processing centers. 

With the current depressed lumber market, the district recognized that this project would 

cost more money than it could generate from the forest products removed. As shown in 

the analysis, a request for additional appropriated dollars would need to occur to 

implement any of the action alternatives. With this in mind, consideration for the ―cost‖ 

of implementing any of the three action alternatives is presented to the decision maker, 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Appendix D- Response to Comments 249

but is not the main criteria used in determining which alternative best meets the purpose 

and need of the project.

2. Appraisal Cost Summary (Table 42) in the DEIS, should be updated to reflect current 

lumber prices and discuss the fact that the current lumber market is at an extremely 

depressed level. Economic recovery, potential rise in wholesale lumber prices would 

make Alternative 2 the greatest positive value. (AFRC)

As stated in the response to Comment #1, the FEIS for the Sugar Pine Adaptive 

Management Project (known as the Sugar Pine Project) includes an Economics analysis 

of the action alternatives. Table 48, Sugar Pine Project Appraisal Summary has been 

updated to include prices from December 2009 and total for the Present Net Value. 

3. Add a discussion of social and economic effects of the alternatives and their impact on 

the human environment. (AFRC)

As stated in the response to Comment #1 in this Section, the FEIS for the Sugar Pine 

Project includes a brief discussion on the potential social and economic effects of the 

alternatives. Although these are presented to the Responsible Official, it is not the main 

criterion used in determining which alternative best meets the purpose and need of the 

project.

Forest Health Related Comments:

1. Based on PSW-GTR-220 (North et al 2009), how do the principles apply to the plot data 

summary, Table 37, page 223? Explanation needed or rationale for the trees removed, 

based on Table 37, page 223. (TESCTC) 

Tables 37-39 in the DEIS (Tables 49-51 in FEIS) are a summary of plot data collected for 

stands within the treatment areas of the Sugar Pine Project. Although these tables, by 

Alternative, are from plot data taken in the project area, they are used to display the 

variability in stand conditions that are within the project area. More focused on the 

conifers that would be removed under each alternative than those that would remain in 

the stands is a product of the plot data that was collected. There is no information 

provided about the trees that are over 30 inches or less than 30 inches in diameter that are 

remaining in the stands, simply the number and basal area of trees remaining. Also not 

represented in these tables, is the spatial arrangement of the trees remaining. When used 

in conjunction with FEIS Tables 52-53, the California Wildlife Habitat Relationship 

changes for Alternative 2, which evaluates the changes to wildlife habitat based on 

treatments proposed in Alternative 2, the description of Design Criteria Common to All 

Action Alternatives and the purpose and need for the project, several of the ―principles‖ 

provided in the PSW-GTR-220 (North et al 2009) were used in the development and 

design of the treatments in the alternatives. 

 
Appendices

250 Sierra National Forest

2. On p. 117, para. 2, you say, “Wide swings in climatic conditions over the past 30 

years....” What you mean is wide swings in weather. Climate is determined by 

considering weather over 30 consecutive years. (RKSCTC)

In this particular sentence, it should state wide swings in weather, not climate. Although 

the conditions stated in this paragraph such as drought and rising temperatures are 

considered to be due to climate changes. The word ―climatic‖ has been corrected to 

―weather‖.

3. The paragraph starting at the bottom of p. 121 and ending on p. 122 says “studies have 

shown” and gives much tree physiology information, but no references are cited. 

Scientific citations are needed to establish a base of “sound science” required by the 

National Forest Management Act. (RKSCTC)

This has been corrected in the FEIS to reflect the source of these citations. These 

citations have come from one scientific document that summarizes the results from 

several other studies and is referenced as Fetting, C. J.; Et. Al. 2007. ―The effectiveness 

of vegetation management practices for prevention and control of bark beetle infestations 

in coniferous forest of the western and southern United States.‖; Forest Ecology and 

Management. 238: (pages 24-53). 

4. On p. 123 for Alternative 2 (as well as for Alternative 3 on p. 126 and Alternative 4 on p. 

127), you quote Smith (1962) in the following manner: “...removal of only intermediate 

and suppressed trees results in „little more than the salvage of trees which will inevitably 

die.” The problem is that the term intermediate as used here can be confused with the 

way that North, et al. (2009) use the term “intermediate”. For North, et al. (2009) who 

do not cite Smith (1962),“intermediate trees”, those 20 to 30 inches dbh, are to be 

protected. For Smith (1962) “intermediate trees” could to be removed as salvage 

material. Also, the term “salvage” is not defined in the Sugar Pine DEIS. You need to 

rewrite to clarify what you mean and intend in this regard. In the Sugar Pine Project 

area intermediate-sized trees as defined by North, et al. (2009) are the largest trees and 

should be the leave trees. In Smith (1962) it seems the “intermediate trees” are not the 

larger trees. Again, please clarify. (RKSCTC)

It is true that the meaning of the word ―intermediate‖ does have two different meanings. 

The FEIS has further explained or clarified the use of the word ―intermediate‖. In the 

FEIS, Forest Vegetation/Silviculture section, the term ―intermediate‖ is used to describe a 

trees position in the canopy in relationship to other trees in the stand. When describing 

how a particular tree is positioned in the canopy of a stand of trees the terms referenced 

are: suppressed, intermediate, co-dominant and dominant, in order of lowest to highest 

position in the canopy of the stand. In PSW-GTR-220 (North, et.al. 2009) uses the term 

intermediate in reference to the of size (diameter at breast height [dbh]) of a tree, in 

PSW-GTR-220 the term intermediate is referencing trees 20 to 30 inches dbh. The term 

salvage has also been defined in the Glossary. 

5. On pp.123-124, for Alternative 2 (applies as well as for Alternative 3 on p. 126) you say 

“Where choices exist, more fire resistant pines would be favored over fir and incenses 

cedar as leave trees. In most areas, stand composition following treatment will consist of 

a greater percentage of more fire and drought resistant ponderosa and sugar pine as 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Appendix D- Response to Comments 251

recommended in the North paper (2009). Although existing stand composition averages 

about 40 percent pine and sugar pine, 39 percent incense cedar, 15 percent white fir, and 

6 percent oaks, it is estimated that 75 percent of the trees to be removed will be incense 

cedar, 10 percent will be white fir and 15 percent will be ponderosa and sugar pine. 

Thirty (30) inch harvest tree diameter limitations dictated by the SNFPA ROD 2004 will, 

in many areas, result in basal area retention levels in excess of proposed residual basal 

areas. In some cases in pockets of larger trees, no trees will be harvested. In these types 

of thinnings, the smaller size of the product to be removed makes harvest operations 

much more expensive than those where larger trees are removed.” You are beating 

around the bush. Why is it a choice to cut any trees in the 20-inch to 30-inch dbh size 

range. North, et al. (2009, p. 24) state that clear reasons for removal of any intermediate 

sized trees greater than 16 inches should be explained for projects just like this Sugar 

Pine project. The implication is that removal of those intermediate sized trees is not 

good for the forest. North, et al., (2009) then list several reasons such intermediate sized 

trees might be harvested. What are your reasons for choosing to log trees greater than

16 inches? You need to clearly state your reasons in order to follow North, et al. (2009). 

Such reasons should be directly related in your Purpose and Need. This is not clear. 

NEPA requires that your plan be clear. Tucking this suggestion away in a paragraph on 

p. 124 certainly is not making your intent clearly known. (RKSCTC)

As stated as part of the purpose and need for this project is ―the need for conifer stands to 

be resilient to attack from insects, diseases, drought conditions and/or wildfire. The 

reason for this need is conifer stands are well above normal stocking levels (stand 

densities) resulting in a decline in growth, health and resiliency, thus increasing a stands 

potential for higher rates of mortality‖. The FEIS goes on to state that part of what is 

considered the Forest Health purpose is to increase the health, growth and vigor of the 

stands to increase resiliency to these types of potential disturbance agents. In order to 

perpetuate this increased health, growth and vigor to increase resiliency, stands that are 

currently overstocked, based on site capacity, (the amount of vegetation the ground can 

sustain) need to have the trees thinned to provide more growing space for the trees left (in 

this case the larger sized trees remain in the stand, since thinning is accomplished by 

―thinning from below‖) and to reduce inter-tree competition for sunlight, nutrients and 

water as presented in the Forest Vegetation/Silviculture Section of the FEIS. Because of 

the high variability of the stands within the Sugar Pine Project area, this includes the need 

to remove trees > 20‖ in diameter, where conditions exist present the need to do this to 

meet the forest health objectives of the project. If the focus was reversed to what is 

expected to remain in the stands after the implementation of any of the action 

alternatives, by looking at the California Wildlife Habitat Relationship changes (FEIS 

Tables 52-53) and the analysis within the Terrestrial Wildlife Section of the FEIS, stands 

will continue to meet habitat conditions for sensitive species like Pacific fisher and 

California spotted owl. Based on designing the treatments, as proposed in all the action 

alternatives, using Design Criteria Common to All Action alternatives, this project 

incorporates the basic summary findings in PSW-GTR-220 (North et.al 2009).

6. On p. 124 in the last sentence of para. 2, you state, “Thinning is an effective technique 

for creating stands that more closely represent those present prior to railroad and other 

extensive logging and the exclusion of fires during the 20th Century.” This will work only 

if the larger trees are NOT removed. The forest prior to that logging contained many 

very large boles. Your intent is to remove now-existing trees up to 30 inches dbh. All 
Appendices

252 Sierra National Forest

those larger trees (above 16 inches as stated by North et al., 2009) should be left to make 

the forest even closer to what the pre-logging forest was. To help the forest look more 

like what it was before fire exclusion, your plan should include and PROPOSE another 

alternative to use hand thinning of small trees followed by understory burning instead of 

logging larger trees. You need to show the true economics of your plan. The U.S. Forest 

Service has ALWAYS (ever since 1905) shown an annual loss of money on timber sales 

(Robert Wolf, personal communication) and (Char Miller, Pinchot biographer, in the 

DVD set The Greatest Good created for the Centennial of the U.S. Forest Service in 

2005, disk 3, history out takes, “Biltmore”). North et al. (2009) say that getting revenue 

to pay for fuel treatment or to provide merchantable wood to the local sawmill are 

reasons for the sale of larger trees. If that is your intent, you need to clearly say so. You 

also need to show an analysis to compare the economics (including costs into the future) 

of the various alternatives, including a hand thinning and understory burning alternative. 

If the hand thinning alternative is more economic in the long run, then that should be the 

chosen alternative. UNLESS your real need is to supply timber to the local sawmill, you 

need to show how timber sale revenue will provide greater economic benefit than other 

alternatives, including one for hand thinning and understory burning. If one of your real 

needs is to provide timber to the local sawmill, you must clearly say so. In this sense you 

need to follow the National Environmental Policy Act and the National Forest 

Management Act. (RKSCTC)

Please refer to the Response found under Comment #5 of the Forest Health Related 

Comments as well as the response found under Comments #1 and #2 of the Economics 

Related Comments.

7. Appendix D is very helpful to understand variability in the stands across the project area. 

Is it possible to give an indication of the extent of different stand data; how often such 

conditions occur across the landscape, it would improve the ability to assess the degree 

of change expected to habitat conditions. In field reviewing the project, infrequent 

observation of 20-30” trees marked, suggest that the more intensive harvest in T-7 (in the 

table) occurs infrequently, the tables do not provide information allowing us to evaluate 

this. (SFLSC)

It would be difficult to say with any confidence how often such conditions occur across 

the landscape, since this plot data was through variable plot sampling throughout the 

project area. This is why the FEIS also provides Map #7 in the Map Package to depict 

the current California Wildlife Habitat Relationship (CWHR) typing and Tables # 52 and 

#53 to depict the expected changes in these CWHR types based on Alternative 2, since 

Alternative 2 proposes the greater amount of these types of treatments. The Terrestrial 

Wildlife Section in the FEIS, shows the CWHR type changes expected from Alternatives 

#3 (page 78) and Alternative #4 (page 79). 

8. DEIS inadequate in its analysis of some the most basic impacts of the proposed project. 

a) Does not clearly divulge the upper diameter limit used in mechanical thin units; b) 

Appendix D divulges the canopy cover reduction occurring in each unit, but does not 

divulge the intensity of removal of mature trees (Appendix D groups all trees over 5” 

DBH together); c) DEIS implies that there is a problem with excess tree mortality, but 

does not divulge the current density of large snags (>15” DBH) in each unit. (JMP)
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Appendix D- Response to Comments 253

a) Now clearly stated in the Summary on page x of the FEIS is the upper diameter limit 

used in designing and planning the mechanical thin from below treatments as allowed by 

the SNFPA ROD (USDA-FS 2004). b) The tables being referred to and are in the FEIS as 

Tables # 49-51 in Appendix C, display the size of trees being removed by treatment area 

and are categorized by tree size groupings of 5-10‖ dbh, 11-20‖ dbh, and 21-29‖ dbh 

based on plot data summary. Next to this in the table is the basal area being removed of 

these same tree size groupings. Also included is the leave number of trees and the leave 

basal area, the canopy cover before and after treatment and the mean diameter of trees in 

the summarization of this plot data. c) In the Terrestrial Wildlife Section of the FEIS, on 

page 66, describes the current snag densities in the project area with a discussion of 

snags. 

9. Provide specific and detailed information (including maps) of the location of fisher 

detections and dens. (JMP)

The FEIS Terrestrial Wildlife Section beginning on page 62 summarizes the information 

about the Pacific fisher found in and around the Sugar Pine Project. The Terrestrial 

Wildlife Biological Assessment/Biological Evaluation found in the project record

includes additional detailed information about the location of fisher detections and dens. 

Map # 13 in the Map Package displays the designated Pacific fisher densite locations 

from the 2008/2009 SNAMP pre-treatment data. 

10. Inadequate analysis of adverse impacts on Fisher/Spotted Owl. Basic information on the 

impacts of particular thinning units for species is missing. (JMP)

The Terrestrial Wildlife Section of the FEIS summarizes the Terrestrial Wildlife 

Biological Assessment/Biological Evaluation (BA/BE) found in the project folder and 

includes a more thorough analysis of effects on species such as the Pacific Fisher and 

California spotted owls including an analysis of the CWHR habitat changes expected by 

Alternative. 

11. DEIS fails to explain why reducing the density of live mature trees and large snags would 

benefit the ecological forest health of the project area and the imperiled wildlife species 

that occupy it. (JMP)

As stated in the Design Criteria Common to All Action Alternatives (pages 19-20) 

Section of the FEIS, Retention of Snags, all snags unless considered a safety hazards will 

remain in the project area. The definition of a safety hazard is also provided. The 

purpose and need of this project includes the need to reduce stand densities to improve 

resiliency of the stands that are currently overstocked and are vulnerable to loss from 

insects, disease, drought conditions and/or wildfire. The Terrestrial Wildlife Section 

(pages 62-82), Forest Vegetation/Silviculture Section (pages 133-145) and the Fire/Fuels 

Section (pages 145-161) all present the purpose of reducing the density of live mature 

trees and the effects associated with carry out such actions. 
Appendices

254 Sierra National Forest

Fire/Fuels Related Comments:

1. Map #3 shows very large areas for SPLATS. Is there reliable data to support the efficacy 

of the SPLAT concept? (TESCTC)

The SPLAT theory as presented originally in the 2001 Sierra Forest Plan Amendment 

Record of Decision and brought forward into the 2004 Record of Decision, has been 

modeled as a viable concept, but there is very little actual documentation of SPLATs 

created across the landscape slowing down a wildfire and would support this theory. 

There are, however, several scientific papers that show the ability for fuels treatments 

(the treating ladder and surface fuels) in areas have reduced fire spread and intensity, 

which is the underlying focus of Dr. Finney‘s SPLAT theory, but on a landscape level. 

The Fire/Fuels section references some of these papers. As part of SNAMP, the fire and 

forest health portion of the study will be gathering data within and surrounding these 

mapped SPLATs in this project to provide pre and post data needed to model fire 

behavior before and after treatment to inform future management decisions about 

SPLATs and their efficacy. What was not included in Dr. Finney‘s theory was the 

second purpose of this project which is to improve the resiliency of stands within the 

project area. As stated in the FEIS, SPLATs, as defined in this document, are used in this 

document to describe a specific area proposed for vegetation treatment, not an area where 

treatment intensity would change.

2. In your Summary on p. v, SPLATS and “defensible fuel profiles” (I assume you mean 

DFPZs) are lumped together as though indistinguishable. However, your Glossary 

definitions make them different. (RKSCTC)

The FEIS provides a means by which to distinguish the terms SPLATs and Defensible 

Fuels Profile Zones. The FEIS Glossary definitions of these two terms have been refined 

to reflect how these terms are being used in this document. 

3. Locations of SPLATS are shown on Sugar Pine Map #3, but locations of DFPZs are not 

shown.(RKSCTC)

Map #3 in the Map Package of the FEIS has the locations of the DFPZs included on it.

4. In the extreme, SPLATS and DFPZs might be the same as clearcuts according to your 

Glossary definition. To what extent is the vegetation modified, and how is that 

modification to be maintained over time after the economic incentives of timber 

extraction? (RKSCTC)

The FEIS- Glossary definitions for SPLATs and DFPZs have been refined to reflect how 

these terms are used in the context of this document. Within those definitions, it is stated 

that these terms reference a specific geographical location of a treatment area and the 

treatment intensities will not change within these areas. 

5. Your Glossary definition for DFPZs includes the idea that SPLATS will enhance DFPZ 

effectiveness. That means SPLATS will be in the same areas as DFPZs. So is there 

really no difference between them? (RKSCTC)

The FEIS-Glossary definitions for SPLATs and DFPZs have been refined to reflect how 

these terms are used in the context of this document. 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Appendix D- Response to Comments 255

6. In Table 42 costs are given for biomass production, but no value is given for the biomass; 

whereas, a value of $1,477,390 is given as “Sawlog Pond Value”. It seems that biomass 

production will not return value. Your Purpose and Need includes nothing about 

biomass production. On pp. 10-18, your section “Design Criteria Common to All Action 

Alternatives” says nothing about biomass. It would be better to burn that small material 

on site so nutrients could remain in the forest. Please explain your rationale for 

production of biomass in this project. (RKSCTC)

The FEIS provides an explanation as to why biomass operations are being used to treat 

ladder fuels and thin the lower canopy first in the Summary (page x). In the Air Quality 

Section of the FEIS, beginning on page 161, also describes how the air basins the Sugar 

Pine Project is within are classified by the US Environmental Agency as in Extreme NonAttainment for the precursors to Ozone (NOx and VOC) and at a maintenance level for 

PM10. With these classifications, the use of prescribed fire is under strict regulations and 

is authorized on a project-by-project basis by the San Joaquin Valley Air Pollution 

Control District and/or the Mountain Counties Air Pollution Control District which, if 

deemed necessary to prevent smoke impacting smoke sensitive areas, can limit acres, 

burn days and time allowed for ignitions as an example.

7. Recent research provides evidence that seriously questions the very basis for thinning 

and its assumed effectiveness. Rhodes and Baker (2008) found that, based upon the fire 

rotation interval for high severity fire, and assuming an effectiveness period of 20 years 

for a mechanically-thinned area (i.e., before it would need to be treated again to 

maintain effectiveness from a fire/fuels perspective), the probability of a thinned area 

encountering a high severity fire patch during the 20-year effectiveness period (assuming 

for the sake of argument that the thinning actually does reduce fire severity during this 

period) is only about 3.3% in California‟s forests. It would be less than 2% if an 11-year 

thinning effectiveness period is assumed (Rhodes and Baker 2008). This means that, in 

order to have a 50% chance of having the thinned area reduce the severity of a fire patch 

that would have otherwise been high severity, the thinned area would have to be rethinned every 20 years for about 300 years (see Rhodes and Baker 2008). Please fully 

analyze the implications of this new data, and please also fully divulge whether you 

intend to re-thin this area over and over again every couple of decades or so for the next 

three centuries or so in order to have a reasonable probability of having the thinning 

area ACTUALLY prevent high severity fire from occurring in the thinned area. If so, 

please fully analyze the cumulative environmental impacts on wildlife, soils, and 

watersheds from such repeated mechanical activities on this site. If not, please divulge 

the fact that the probability that the thinned area will NOT encounter a high severity fire 

area is about 97% or greater, and that your thinning activities are extremely unlikely to 

be effective in any tangible or meaningful way for fuels/fire management. (JMP)

The purpose and need of the Sugar Pine Project is multi-faceted and utilizes an ecosystem 

approach that compares the current condition of key ecosystem components against 

desired conditions set by the SNFPA ROD (USDA-FS 2004b). The purposes for the 

project are: 1) to reduce the intensity and spread of wildfires across the landscape and 

near communities and 2) to reduce stand density, within the lower and mid-canopy 

layers of conifer stands, to such a level as to provide for increased stand resiliency, 

growth and vigor. Fire intensity is a measure of the energy (heat) released along a given 

unit. As used in the FEIS, the purpose of the project is to reduce the amount of heat 
Appendices

256 Sierra National Forest

intensity (the energy) given off by a fire (Agee J.K. 1993). In contrast, fire severity is the 

effect of fire on the various components that are part of the area where a fire burns (Agee, 

J.K. 1993). While Rhoades and Baker 2008, provides the probability for a high or high to 

moderate severity fire to encounter a fuels treatment area within its effectiveness period 

of 11 and 20 years is low, it does not speak fire intensity. Considered in the FEIS, under 

all resource areas are the direct, indirect and cumulative effects of the No Action 

Alternative, as well as the (3) action alternatives that were designed and planned to meet 

the purpose and need of this project. It is recognized within the FEIS, that there may be 

areas within the project boundary where ―maintenance‖ treatments are needed to extend 

the effectiveness of this reduction in fire intensity and spread. In this FEIS in the Design 

Criteria Common to All Action Alternatives, this maintenance would be completed 

utilizing prescribed fire. The areas were these maintenance treatments with prescribed 

fire would be considered are listed under the Fire/Fuels design criteria. To speculate 

beyond the life of this document (generally expected to be 10 years) is beyond the scope 

of this document.

Wildlife Related Comments:

1. As part of Appendix C (p. 214) “New Information” is provided from three publications 

regarding the Pacific fisher. While all of those are important reports, there are others of 

importance as well. I refer to: (1) Lutz, van Wagtendonk and Franklin (2009) 

“Twentieth-century decline of large-diameter trees in Yosemite National Park, 

California, USA” in which a decline in tree size is linked to a decline in forest fires; and 

(2) Hanson, Odion, Dellasalla, and Baker (2009) “Overestimation of Fire Risk in the 

Northern Spotted Owl Recovery Plan” which suggests intense fire may not be so 

damaging to habitat and that thinning may not be the best way to go. The National 

Forest Management Act requires the use of “sound science”. Further, it has been 

determined that “selective science” is to be avoided. So these additional sources and 

others as well also need to be considered. (RKSCTC)

First and foremost, Appendix C that was included in the DEIS, has been removed from 

the FEIS, with the incorporation of Design Criteria associated with terrestrial wildlife 

species that are based, in part, on reports and scientific study results such as the ones 

named above. As well, pre-treatment data collected within and surrounding the Sugar 

Pine Project by SNAMP scientist about Pacific fisher and findings from the Pacific 

Southwest Research Station in the Kings River area on the Sierra National Forest and 

Richard Truex‘s work on the Sequoia National Forest has provided ―real-time data‖ that 

has been used in the analysis. The Terrestrial Wildlife Biological Assessment/Biological 

Evaluation for the Sugar Pine Project has incorporated the use of several peer-reviewed 

science-based documents, including those with opposing views of the effects of 

management actions as proposed in the FEIS, in its analysis of the effects of the 

alternatives on species habitat and the species themselves and a listing of those 

documents that are cited are contained in the Literature Cited Section of this report 

(found in the Project Record).

2. As part of Appendix C (p. 215) Table 35. Landscape Level Habitat Maintenance and 

Improvement Principles and Implementation Approaches, there is a citation (PSW EMS). 

What is PSW EMS? (RKSCTC)
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Appendix D- Response to Comments 257

As mentioned in the response to Comment #1 of the Wildlife Related Comments, 

Appendix C that was included in the DEIS, has been removed from the FEIS. The PSW 

EMS referred to in that appendix stood for Pacific Southwest Ecosystem Management 

Study.

3. The term “Old Forest Linkage”, p. 14, is not defined there nor in the Glossary.

(RKSCTC)

The FEIS includes a definition of ―Old Forest Linkage‖ both in the Design Criteria 

Common to All Action Alternatives on page 21 and is included in the Glossary.

4. Hazard Trees and Snag Management: Several sections identified in DEIS where snag 

retention or removal are discussed as well as hazard tree and down log 

retention/recruitment. FEIS needs to more clearly state the intent and criteria for the 

removal of hazard trees/snags. (SFLSC)

In the FEIS, Design Criteria Common to All Action Alternatives on pages 19-20 and on 

page 26 clearly state the intent and criteria for the removal of trees deemed a danger 

(hazard) tree as well as describes down log retention/recruitment within the Sugar Pine 

Project. 

5. LOP for Fisher: How the LOP for fisher will be applied differs between the DEIS and 

BE. Needs to be resolved. Because minimizing direct disturbance to denning fisher is 

very important, ask that we follow for all action alternatives LOP as defined in the BE, 

i.e., apply the LOP to ALL suitable denning habitat in project area. (SFLSC)

In the FEI, Design Criteria Common to All Action Alternatives on page 21 applies a 

Limited Operating Period of March 1 to June 1 to all suitable Pacific fisher denning 

habitat within the Sugar Pine Project area. Design Criteria for Terrestrial Wildlife are 

incorporated directly from the Terrestrial Wildlife Biological Assessment/Biological 

Evaluation found in the project record.

6. Activities Allowed in the Den Buffer: Need to fix discrepancy between the BE and DEIS 

when discussing the level of activities allowed under each action alternative. (SFLSC)

The Terrestrial Wildlife Biological Assessment/Biological Evaluation (BA/BE) has been 

revised and updated for the FEIS. With this the FEIS and Terrestrial Wildlife BA/BE 

discrepancy has been corrected and clearer information about the activities allowed in 

designated densite buffers has been included in Chapter 2-Alternatives Considered in 

Detail starting on page 31. 

7. SMZs and OFLs: Uncertain of what activities are proposed within or near to streams. 

Need to get clear definitions of SMZ, RCA, RMA, OFL and what exactly can occur based 

on designation. Riparian Reserve term used (DEIS, page 91 and 156). How does this 

relate to the others. Overlap in the design criteria for OFLs and SMZs with respect to 

treatments allowed in each. (SFCSC)
Appendices

258 Sierra National Forest

In the FEIS, Design Criteria Common to All Action Alternatives (pages 16-26) there is 

are clearer definitions of all the terms listed in this comment as well as what exactly can 

occur in each area based on the particular designation. These terms can be located under 

the Terrestrial Wildlife and Aquatics Design Criteria. 

8. Information of Fisher Surveys: DEIS and BE does not mention recent information on 

fisher use in the project area. Need to include the information presented in letter on 

fisher and other information on specific use of the area by fisher and incorporate it into 

the analysis of effects of the project on Pacific fisher. (SFLSC)

The Terrestrial Wildlife Biological Assessment/Biological Evaluation (BA/BE), and 

summarized in the FEIS has been revised and updated for the FEIS. This has now been 

included in the BA/BE and is incorporated into the analysis of effects of the project on 

Pacific fisher. The complete BA/BE can be found in the project file.

9. Analysis of effects on Fisher are incomplete: Appears not all potential effects on fisher 

were discussed in the DEIS or BE. Potential effects were generalized and not related to 

ongoing fisher use of the area. Denning females in the area and potential disruption 

should be discussed. Existing condition for fisher habitat not sufficiently described. BE 

quantifies the potentially suitable habitat in the project area, but does not describe 

whether this is low, moderate, or high quality habitat. Quantification seems to rely on 

remote sensing and does not address important habitat elements such as large snags and 

down logs, and understory vegetation. (SFLSC)

The Terrestrial Wildlife Biological Assessment/Biological Evaluation (BA/BE), and 

summarized in the FEIS has been revised and updated for the FEIS. This revision and 

update expands the analysis of the potential effects on Pacific fisher. This has now been 

included in the BA/BE and is incorporated into the analysis of effects of the project on 

Pacific fisher. The complete BA/BE can be found in the project file.

10. Design criteria in DEIS do not seem to be the same as those in the BE. Analysis seems to 

be completed based on criteria in BE. These two need to be consistent with one another.

(SFLSC)

The Terrestrial Wildlife Biological Assessment/Biological Evaluation (BA/BE) has been 

revised and updated for the FEIS. With this the FEIS and Terrestrial Wildlife BA/BE 

discrepancy has been corrected.

11. Cumulative effects analysis does not define a specific analysis area or describe the effects 

of the past, present and reasonably foreseeable future projects. Existing condition of the 

cumulative effects analysis area is not presented. (SFLSC)

The Terrestrial Wildlife Biological Assessment/Biological Evaluation (BA/BE) has been 

revised and updated for the FEIS. The cumulative effects analysis defines the specific 

analysis area and describes the effects of past, present and foreseeable future project as 

well as the existing condition of the cumulative effects analysis area is present. This is 

summarized in the FEIS and in its entirety in the Terrestrial Wildlife BA/BE available in 

the project file.
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Appendix D- Response to Comments 259

12. Not clear how past activities have altered the habitat conditions important to fisher or the 

extent to which they had an effect on fisher habitat conditions. (SFLSC)

The Terrestrial Wildlife Biological Assessment/Biological Evaluation (BA/BE) has been 

revised and updated for the FEIS. It describes how past activities have altered the habitat 

conditions important to fisher and the extent to which they have had on Pacific fisher 

habitat conditions. This is summarized in the FEIS and in its entirety in the Terrestrial 

Wildlife BA/BE available in the project file.

13. Analysis should consider effects on habitat connectivity and fisher dispersal to the north 

and south and Sugar Pines importance to this. (SFLSC)

The Terrestrial Wildlife Biological Assessment/Biological Evaluation (BA/BE) has been 

revised and updated for the FEIS. The analysis considers the effects on habitat 

connectivity and fisher dispersal to the north and south and Sugar Pine Project‘s 

importance to this based on the incorporation of Design Criteria Common to All Action 

Alternatives that are associated with habitat connectivity (OFLs, untreated areas, Riparian 

Areas and control areas). This is summarized in the FEIS and in its entirety in the 

Terrestrial Wildlife BA/BE available in the project file.

14. Discussion and evaluation of (Forest Plan) amendment would benefit from an analysis of 

the potential conservation costs and benefits to fisher from undertaking the amendment 

versus the alternatives. More complete discussion about why the den buffer measure is 

not appropriate or effective and how the desired action better addresses conservation 

should be included in the analysis. (SFLSC)

The Terrestrial Wildlife Biological Assessment/Biological Evaluation (BA/BE) has been 

revised and updated for the FEIS. A complete analysis of the Forest Plan amendment is 

provided in the Terrestrial Wildlife BA/BE found in the project file and is summarized in 

the FEIS. The analysis is based on the incorporation of the Design Criteria Common to 

All Action Alternatives and the need to gain information from SNAMP surrounding the 

uncertainty of the ability to maintain adequate habitat qualities (which is what the Design 

Criteria attempt to accomplish as well as what the SNFPA ROD S&G #86) and still 

accomplish the purpose and need of the Sugar Pine Project. 

15. Information regarding current and future density of snags in each treatment area needs 

to be included as well as whether these numbers are adequate or not. Same for down 

logs. Both of the large size. (JMP)

This has been summarized in the Terrestrial Wildlife Section of the FEIS on pages 66-67.

Comments Related to Adding Additional Alternatives: 

1. Neither Alternative 2, the Proposed Action (p. 121) nor any of the other action 

alternatives (p.126, p. 127) include hand thinning of trees followed by understory 

burning as an economic method for increasing vigor of remaining trees and for fuels 

reduction. Please add that as one of the possible methods to be considered. (RKSCTC)
Appendices

260 Sierra National Forest

In the FEIS, Alternatives 2, 3, and 4 all include hand thinning of pre-commercial trees 

within treatment areas (see Chapter 2-Alternatives Considered in Detail) with piling and 

burning, where needed, after that treatment. In these alternatives, understory burning 

would be used as a primary treatment in treatment areas shown as RX on the treatment 

area Map #1 in the Map Package. In the Fire/Fuels Design Criteria Common to All 

Alternatives, understory burning would be considered as a maintenance treatment for 

areas described in this section. The FEIS describes the methodology used in developing 

and designing the treatment areas and the current condition of these treatment areas. In 

these alternatives, as well as the treatments within the alternatives, treatments are those 

that would meet the purpose and need of the project. As written in the FEIS, the 

development and design of the treatments in the alternatives takes into consideration the 

Standards and Guidelines associated with Southern Sierra Fisher Conservation Area, 

where mechanical treatments are preferred over prescribed fire. As written in the FEIS, 

alternatives need to take into consideration, if any of the action alternatives were selected, 

treatments analyzed in detail would need to be completed within the SNAMP two year 

implementation timeframe. To the extent possible, hand thinning and prescribed burning 

as a treatment was presented in each of the action alternatives considered in detail.

2. Need to analyze alternatives with 8 and 12-inch diameter limits wherein greater BA and 

SDI densities would be allowed. (JMP)

Though not specifically stated as such in the FEIS, Alternative #4 in effect would limit 

the treatments to those needed to meet fire/fuels objectives to reduce ladder and surface 

fuels. As stated in the both the Forest Vegetation/Silviculture and Fire/Fuels Sections of 

the FEIS, in designing treatments that meet fire/fuels objectives only, few trees above 10 

inches in diameter would be removed.

Roads and Watershed Related Comments:

1. Page 150, Road 6S90 high erosion risks soils with reconstruction/maintenance 

treatments...location of this road with respect to treatment units is not indicated, the 

potential maintenance and/or reconstruction treatments are not specified, and the 

impacts and success of measures to mitigate for these impacts are not accessed. 

(USEPA)

In the FEIS, Design Criteria Common to All Action Alternatives is an integral part of 

each alternative. They direct the design of treatment areas, the design of treatment types 

and/or are direction to follow during implementation. In listing these as part of all action 

alternatives, they are considered when analyzing the direct, indirect and cumulative 

effects of each alternative and are used to minimize potential environmental impacts of 

the management actions proposed by alternatives. There are design criteria focused on 

such actions (see FEIS pages 17 and 18) as well as the listing of Best Management 

Practices to be implemented in Appendix B. Past projects on the district have 

implemented and utilized these design criteria and Best Management Practices similar to 

those shown in the FEIS and have proven successful in minimizing impacts. 

2. Page 150, all temp roads will be closed and any roads not needed should be 

decommissioned. Document does not indicate whether road decommissioning will 

actually occur. Need to identify all roads that will be decommissioned and described 
Final Environmental Impact Statement Sugar Pine Adaptive Management Project

Sierra National Forest – Appendix D- Response to Comments 261

how the ranger district will ensure road closures effectively preclude off-highway vehicle 

activity and associated impacts. (USEPA)

In the FEIS, Design Criteria Common to All Action Alternatives specifies that all 

temporary roads required for unit access will be closed upon completion of use. It goes 

on to described the means by which this closer will be completed. Past projects on the 

district have implemented and utilized design criteria similar to this and have proven 

successful in minimizing impacts. Within the scope of this document, no roads were 

considered for decommissioning.

3. Map #12 should be revised to show ALL new roads and ALL temp roads proposed for 

this project. All roads on Map 12 should be labeled. (USEPA)

Map #12 in the Map Package for the FEIS has been revised to include ALL new and 

temporary roads and includes labels.

4. Page 110, identifies (2) streams in subwatershed 503.0010 which could be adversely 

affected by the proposed action. A road crossing one stream in unit T8 would potentially 

affect the stability of the channel, but the DEIS does not indicate how this will be avoided 

or mitigated. Unit T11 is adjacent to another stream that is currently in poor condition. 

While the DEIS states the project design criteria have been developed to protect this 

channel from further degradation, it does not specify these criteria. The FEIS should 

describe the measures that will be required to protect stability and improve watershed 

conditions in these areas of T8 and T11. (USEPA)

The DEIS and FEIS include design criteria as well as list the specific Best Management 

Practices (Appendix B) that will be utilized to avoid or mitigate potential negative effects 

to these streams. The specific design criteria for this minimizing this can be found under 

the Hydrology, Soils, Aquatics and Engineering section of the design criteria as well as 

the Best Management Practices in Appendix B specific to road construction and 

maintenance. Past projects on the district have implemented and utilized design criteria as 

well as Best Management Practices similar to this and have proven successful in 

minimizing impacts. 

Air Quality Related Comments:

1. Updating/corrections need to be made based on reclassification of the San Joaquin 

Valley Air basin. (USEPA)

The Air Quality Section of the FEIS has been updated to reflect the reclassification of the 

San Joaquin Valley Air basin.

2. Sensitive Areas for smoke should be identified and specify measures that would be 

required to minimize those impacts. FEIS should also describe how to reduce exposure 

of firefighters to adverse smoke constituents such as CO, aldehydes, and particulates 

while working RX fires. Recommend a commitment to specific measures to reduce smoke 

exposure to FF. (USEPA)

The Air Quality Section of the FEIS has been revised to include the items provided in this 

comment and can be found beginning on page 161. 
Appendices

262 Sierra National Forest

Forest Plan Amendment Related Comments:

1. Page 2, DEIS needs to be more concise in the proposed forest plan amendment such as 

on page 158-159. Need to cite authority to amend on a project specific basis. (SFLSC)

The FEIS in Chapter 2-Alternatives, Including the Proposed Action includes a more 

concise description including the evaluation of its significance. This can be found 

beginning on page 9, ―Relationship of Alternatives to Existing Management Plans‖ 

section of Chapter 2.