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Appendix D – Past, Present and Reasonably 

Foreseeable Future Actions Relevant to the 

Cumulative Effects Analysis

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.”

The cumulative effects analysis in this document is also consistent with Forest Service National 

Environmental Policy Act (NEPA) Regulations (36 CFR 220.4(f)) (July 24, 2008), which state, in part:

CEQ regulations do not require the consideration of the individual effects of all past actions to 

determine the present effects of past actions. Once the agency has identified those present effects 

of past actions that warrant consideration, the agency assesses the extent that the effects of the 

proposal for agency action or its alternatives will add to, modify, or mitigate those effects. The 

final analysis documents an agency assessment of the cumulative effects of the actions considered 

(including past, present, and reasonable foreseeable future actions) on the affected environment. 

With respect to past actions, during the scoping process and subsequent preparation of the 

analysis, the agency must determine what information regarding past actions is useful and relevant 

to the required analysis of cumulative effects. Cataloging past actions and specific information 

about the direct and indirect effects of their design and implementation could in some contexts be 

useful to predict the cumulative effects of the proposal. The CEQ regulations, however, do not 

require agencies to catalogue or exhaustively list and analyze all individual past actions. Simply 

because information about past actions may be available or obtained with reasonable effort does 

not mean that it is relevant and necessary to inform decision making. (40 CFR 1508.7)

The table below provides a summary of past, present, and reasonably foreseeable future actions that 

overlap in time and space with the Hwy 46 project and could contribute cumulative effects to the 

resources in the project area. 

Action Agency Description Resources Affected

Past Actions

Wildfires 2017 USFS

Scorpion Fire – 695 acres burned within 

project area.

Little Devil Fire – 2,161 acres burned within 

project area.

Whitewater Fire – 65 acres of the 11,493 

acre fire burned within the project area.

Vegetation, Soil, Water, 

Wildlife, Botany, 

Recreation and Scenic

Hazardous Fuels

Reduction

Breitenbush 

Hot Springs 

Resort and 

Conference 

Center

Mastication of hazardous fuels

Completed 2014

Approximately 51 acres

Vegetation, Soil, Water, 

Wildlife, Fisheries, Roads 

and Access 

Management, Invasive 

Plants
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Action Agency Description Resources Affected

Past Actions

Hazardous Fuels

Reduction USFS

Reduction of hazardous fuels in the 

summer home tracts

Completed 2006 - 2012

Approximately 50 acres

Vegetation, Soil, Water, 

Wildlife, Fisheries, Roads 

and Access 

Management, Invasive 

Plants

Present Actions (ongoing)

Powerline PGE and 

Bonneville Powerline runs through the project area

Vegetation, Soil, Water, 

Wildlife, Fisheries, 

Roads, Invasive Plants, 

Scenery, Recreation

Fire Repair USFS Repair of resource damage resulting from 

fire suppression activities 

Roads, Invasive Plants, 

Cultural, Recreation

Reasonably Foreseeable)

North Fork 

Breitenbush 

Restoration

USFS

Large wood enhancement along 

approximately 5 miles of the North Fork 

Breitenbush River, Respect-the-River 

treatments to dispersed campsites, road 

storage and decommissioning. Planned 

implementation 2019-2022.

Vegetation, Soil, Water, 

Wildlife, Fisheries, 

Roads, Invasive Plants, 

Scenery, Recreation

Legacy Roads Storm 

Damage Risk 

Reduction

USFS

Drainage improvements on Devils Creek 

Road and additional roads in the 

Breitenbush Watershed to reduce road 

sediment delivery to streams. Locations 

and miles to be determined Summer 2017.

Soil, Water, Fisheries, 

Roads

Roadside Hazardous 

Tree Removal USFS

Removal of roadside hazard trees resulting 

from the Little Devil Fire. Planned 

implementation 2018.

Vegetation, Wildlife