United States Department of Agriculture

Hwy 46 Project

Final Environmental Impact Statement

Forest Service Willamette National Forest Detroit Ranger District March 2018
In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations 

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

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

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

Hwy 46 Project

Willamette National Forest Service

Marion County, Oregon

Lead Agency: USDA Forest Service

Responsible Official: GRADY MCMAHAN

District Ranger

Detroit Ranger District

Willamette National Forest

44125 N. Santiam Hwy SE

Detroit, OR 97342

503-854-4200

For Information Contact: LYN MEDLEY

NEPA Planner

44125 N. Santiam Hwy SE

Detroit, OR 97342

503-854-4228

Website: http://www.fs.usda.gov/project/?project=47109

Abstract: This Final Environmental Impact Statement (FEIS) contains the Detroit Ranger District’s 

proposal to improve stand growth, diversity and structure; move stand structure from an overabundance 

of mid seral stands to increase both early and late seral stand structure within the watershed; reduce 

hazardous fuels; restore sugar pine and encourage sugar pine regeneration; treat powerline visuals; restore 

riparian and meadow habitats; restore hydrologic processes in the Short Lake area; and provide a 

sustainable yield of timber for commercial products to local and regional economies. The proposed 

project is located approximately 6 miles northeast of the town of Detroit, Oregon, in Marion County. 

Three alternatives were analyzed in this FEIS; a no action alternative (Alternative 1) and two action 

alternatives (Alternative 2 and 3). Alternative 2 proposes 4,060 acres of treatment (including skips), 

Alternative 3 proposes 3,075 acres of treatment (including skips). Alternative 2 is the Forest Service 

preferred alternative.
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Reader’s Guide

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

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

This Draft Environmental Impact Statement discloses the direct, indirect, and cumulative environmental 

impacts that would result from the proposed actions and alternatives. The document is organized as 

outlined below:

• Summary

• Chapter 1. Purpose and Need: This chapter describes the scope and objectives of the proposal as 

well as defines why the proposal is being made at this location and at this time. 

• Chapter 2. This section describes the alternative methods for achieving the project’s purpose. 

Alternatives are designed to meet the project’s purpose and need and to address one or more 

significant issues related to the proposed actions. This chapter also includes mitigation measures 

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

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

environment that would be affected by the proposed actions as well as the environmental 

consequences of implementing the alternatives. The analysis is organized by resource area.

• Chapter 4. List of Preparers: This section lists the names, together with their qualifications 

(expertise, experience, professional disciplines), of the persons who were primarily responsible 

for preparing the environmental impact statement. 

• Chapter 5. List of Agencies, Organizations, and persons to whom copies of the statement are sent

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

in the draft environmental impact statement.

• References

• Glossary

• Index

Additional documentation, including more detailed analysis of project area resources, can be found in the 

project planning record located at the Detroit Ranger District Office on the Willamette National Forest.
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List of Acronyms

ACS..................Aquatic Conservation Strategy

ACSO...............Aquatic Conservation Strategy Objectives

ARP..................Aggregate Recovery Percentage

B.A...................Biological Assessment

B/C Ratio .........Benefit / Cost Ratio

B.E. ..................Biological Evaluation

BLM.................Bureau Of land Management

BPA..................Bonneville Power Administration

BMP.................Best Management Practices

B.O...................Biological Opinion

CFR..................Code of Federal Regulations

CHU.................Critical Habitat Unit

CVS..................Current Vegetation Survey

dB.....................Decibel

dbh ...................Diameter Breast Height (4.5 feet above ground)

DDE .................Dietary Digestible Energy

DEIS.................Draft Environmental Impact Statement

DEQ .................Department of Environmental Quality

DTR .................Dominant Tree Release

EFH..................Essential Fish Habitat

EIS ...................Environmental Impact Statement

ESA..................Endangered Species Act

FEIS .................Final Environmental Impact Statement

FM....................Fuel Model

FR.....................Fire Regime

FRCC ...............Fire Regime Condition Class

FS.....................Forest Service

FSH ..................Forest Service Handbook

FSM .................Forest Service Manual

FSVeg...............Forest Service Vegetation database

GIS...................Geographic Information System

GPS ..................Global Positioning System

HE....................Habitat Effectiveness

IRA...................Inventoried Roadless Area

LAA .................Likely to Adversely Affect
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LFH..................Listed Fish Habitat

LRMP...............Land and Resource Management Plan

LSR..................Late Successional Reserve

MA...................Management Allocation

MBF.................Thousand Board Feet

MIS ..................Management Indicator Species

MMBF .............Million Board Feet

MVUM.............Motor Vehicle Use Map

NEPA ...............National Environmental Policy Act

NF ....................National Forest 

NFF ..................National Forest Fund

NHPA...............National Historic Preservation Act

NLAA ..............Not Likely to Adversely Affect

NMFS...............National Marine Fisheries Service

NPV .................Net Present Value

NRHP...............National Register of Historic Places

NRIS ................Natural Resource Information System

NRT..................National Recreation Trail

NSO .................Northern Spotted Owl

NWFP ..............Northwest Forest Plan

ODF .................Oregon Department of Forestry

OFRI ................Oregon Forest Resources Institute

OHV.................Off-Highway Vehicle

ORV .................Outstanding Remarkable Values

PGE..................Pacific Gas and Electric

PNW.................Pacific Northwest

Q100.................100 Year Flood Flows

RA32................Recovery Action 32

RIS ...................Road Investment Strategy

ROD.................Record of Decision

ROS..................Recreation Opportunity Spectrum

SDI...................Stand Density Index

SDI max ...........Maximum Stand Density Index

SHPO ...............State Historic Preservation Officer

SIA...................Special Interest Area

TMDL..............Total Maximum Daily Load

Tpa ...................Trees per acre
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USDA...............United States Department of Agriculture

USDI................United States Department of Interior

USFWS ............United States Fish and Wildlife Service

VMS.................Visual Management System

VQO.................Visual Quality Standard

WEPP...............Watershed Erosion Prediction Project model

WMU ...............Wildlife Management Unit

WUI Wildland-Urban Interface
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Summary ...................................................................................................................................... 1

Chapter 1 - Purpose and Need ............................................................................................. 13

1.1 Introduction...............................................................................................................................................13

1.2 Purpose and Need for Action.................................................................................................................16

1.3 Proposed Action ......................................................................................................................................20

1.4 Forest Plan and Management Direction ..............................................................................................23

1.6 Tribal Consultation ..................................................................................................................................28

1.7 Public Involvement Efforts......................................................................................................................28

1.8 Consultation with other Agencies..........................................................................................................30

1.9 Issues Derived from Public Comments................................................................................................30

1.10 Decision Framework ...............................................................................................................................31

Chapter 2 - Alternatives.......................................................................................................... 32

2.1 Alternative 1 – No Action........................................................................................................................32

2.2 Alternative 2 – Preferred Alternative.....................................................................................................32

2.3 Alternative 3 – No Harvest in Fire Regenerated Stands....................................................................37

2.4 Alternatives Considered but Eliminated ...............................................................................................42

2.5 Comparison of Alternatives....................................................................................................................42

2.6 Project Design Elements Common to Alternatives 2 and 3 ..............................................................47

2.7 Mitigation and Enhancement Common to Alternatives 2 and 3 .......................................................62

2.8 Monitoring Common to Alternatives 2 and 3 .......................................................................................63

Chapter 3 - Affected Environment and Environmental Consequences .................... 65

3.1 Forest Vegetation ....................................................................................................................................68

3.2 Fire and Fuels ..........................................................................................................................................88

3.3 Soils...........................................................................................................................................................97

3.4 Hydrology................................................................................................................................................109

3.5 Fisheries .................................................................................................................................................144

3.6 Wildlife.....................................................................................................................................................158

3.7 Botany and Invasive Plants..................................................................................................................200

3.8 Transportation........................................................................................................................................216

3.9 Heritage ..................................................................................................................................................221

3.10 Scenic Quality ........................................................................................................................................226

3.11 Recreation ..............................................................................................................................................240

3.13 Wilderness..............................................................................................................................................252

3.14 Inventoried Roadless Areas (IRA) ......................................................................................................261

3.15 Noise .......................................................................................................................................................264

3.16 Economics ..............................................................................................................................................269

3.17 Climate Change.....................................................................................................................................273

3.18 Unavoidable Adverse Impacts.............................................................................................................274

3.19 Irreversible and Irretrievable Commitments of Resources ..............................................................274

3.20 Short-Term Effects versus Long-Term Productivity .........................................................................275

Chapter 4 – List of Preparers.............................................................................................. 276

Chapter 5 – List of Agencies, Governments, Organizations, and Individuals Given 

Notice of Availability ............................................................................................................. 279

Appendix A – Proposed Treatment Descriptions for the Action Alternatives .......281

Appendix B – Detailed List of Project Activities by Unit for the Proposed Action

..................................................................................................................................................... 286
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Appendix C – Compliance with Laws, Regulations and Executive Orders............ 291

Appendix D – Past, Present and Reasonably Foreseeable Future Actions Relevant 

to the Cumulative Effects Analysis................................................................................... 297

Appendix E - An Evaluation of Activities Authorized by the Hwy 46 Project FEIS

for Consistency with the Aquatic Conservation Strategy........................................... 299

Appendix F – DecAID Analysis........................................................................................... 312

Effects of fires of 2017 on snag densities in the Breitenbush River watershed....................................................320

Appendix G – Riparian Reserve Treatment Detail......................................................... 328

Appendix H – Road Status and Anticipated Road Work Activities .......................... 338

Appendix I – Unit Restriction Table .................................................................................. 366

Appendix J – Response to Comments on the Draft Environmental Impact 

Statement (DEIS).................................................................................................................... 374

Appendix K – Changes from Draft to Final Hwy 46 Project Environmental Impact 

Statement................................................................................................................................. 425

References............................................................................................................................... 428

Glossary ................................................................................................................................... 441

Index.......................................................................................................................................... 447

List of Tables

Table 1 Comparison of the Alternatives........................................................................................................................4

Table 2 Summary of Direct Effects on Resources for Alternative 2 and Alternative 3 ..................................................5

Table 3 Preferred Action Treatments and Connected Actions...........................................................................21

Table 4 Land Management Areas in Project Area and Proposed Treatment Acres (Alternative 2).............26

Table 5 Summary of Proposed Treatments and Connected Actions - Alternative 2 ...................................................32

Table 6 Summary of Forest Age Classes and Treatment Acres - Alternative 2............................................................35

Table 7 Summary of Proposed Treatments and Connected Actions - Alternative 3 ...................................................37

Table 8 Summary of Forest Age Classes and Treatment Acres - Alternative 3............................................................40

Table 9 Comparison of Alternatives ............................................................................................................................42

Table 10 Riparian Reserve Acres Proposed for Treatment..........................................................................................44

Table 11 Proposed Wildlife and DTR Gaps Within Outer Riparian Reserves for Alternatives 2 and 3 ........................45

Table 12 Proposed Streamside Treatments for Alternatives 2 and 3..........................................................................46

Table 13 Design Elements Common to Alternatives 2 and 3.......................................................................................47

Table 14 Snag and Down Wood Recommendations Common to Alternatives 2 and 3 ..............................................62

Table 15 Survey and Manage Species Buffer Recommendations Common to Alternatives 2 and 3 ..........................62

Table 16 Special Habitat Buffer Mitigation Recommendations Common to Alternatives 2 and 3 .............................62

Table 17 Historic Seral Stage Distribution Breitenbush Watershed ............................................................................69

Table 18 Current Seral Stage Distribution Breitenbush Watershed ............................................................................70

Table 19 Stand Replacing Disturbance ........................................................................................................................71
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Table 20 Alternative 2 and 3 Units by Category ..........................................................................................................72

Table 21 Stand Range of Conditions............................................................................................................................72

Table 22 Comparison of Alternatives ..........................................................................................................................85

Table 23 Comparison of Fuels Treatments by Alternative ..........................................................................................96

Table 24 Management Indicators for Assessing Effects to Soils................................................................................101

Table 25 Post Fire Management Indicators...............................................................................................................102

Table 26 Aggregate Recovery Percentages Threshold of Concern............................................................................112

Table 27 Vegetation Class of Riparian Reserves within the Project Area..................................................................117

Table 28 Road Densities by Sub-watershed ..............................................................................................................122

Table 29 Aggregate Recovery Percentages by Sub-watershed .................................................................................125

Table 31 Approximate Culvert Replacements in Perennial and Intermittent Streams by Alternative......................140

Table 32 Comparison of GRAIP-lite Modeled Road Sediment Delivery by Alternative .............................................141

Table 33 Fish Species of the Breitenbush Watershed ...............................................................................................146

Table 34 Woody Material Counts for Some Streams in the Project Area .................................................................151

Table 35 Wildlife Management Indicator Species for the Willamette National Forest.............................................176

Table 36 Potential Population Levels in Planning Subdrainages (base year 2016)....................................................179

Table 37 Snag Levels by Alternative ..........................................................................................................................179

Table 38 Down Wood levels by Alternative..............................................................................................................181

Table 39 Estimated Snag Population Potential for the Westside Lowland Conifer Hardwood and Montane Mixed 

Conifer Wildlife Habitat Types in the Breitenbush River Watershed and in the Willamette National Forest..182

Table 40 Elk Forage Classes Relative to DDE Values..................................................................................................184

Table 41 Elk Forage Class Distribution 1993 and 2013, Willamette National Forest ................................................185

Table 42 Changes in Elk Forage Distributions 1993 to 2012, Willamette National Forest ........................................185

Table 43 Elk Forage Class Distribution in 1993 and 2012 and for Alt 2 and 3 in the Hwy 46 Project........................186

Table 44 Changes in Elk Forage Class Distributions from 1993 to 2012 in the Hwy 46 Project Analysis Area ..........187

Table 45 Comparison of MVUM Open Road Density to Forest Plan Elk Road Density Standards and Guideline by Big 

Game Emphasis Area in the Hwy 46 Project Analysis Area ..............................................................................187

Table 46 Changes in Elk Forage Class Distributions in the Hwy 46 Project Analysis Area Due to Alternative 2........194

Table 47 Changes in Elk Forage Class Distributions Due to Alternative 3 .................................................................195

Table 48 Percent of Watershed within Project Area .................................................................................................206

Table 49 Special Habitats in the Hwy 46 Project Area...............................................................................................211

Table 50 Acres Affected by Weeds (in Acres)............................................................................................................215

Table 51 Key Forest Roads.........................................................................................................................................217

Table 52 Road Realignments .....................................................................................................................................220

Table 53 VMS/SMS Objectives and Proposed Treatments........................................................................................230

Table 54 Viewshed Thresholds..................................................................................................................................232

Table 55 Management Areas and ROS Allocations....................................................................................................242

Table 56 Hwy 46 Project Area ROS Allocation Summary and Desired Conditions ....................................................242

Table 57 Noise in dB of Different Logging Systems at Indicated Distances...............................................................256

Table 58 Acres potentially affected by helicopter noise ...........................................................................................258

Table 59 Noise Produced by Various Logging Equipment .........................................................................................265

Table 60 Noise Attenuation at Increasing Distances.................................................................................................266

Table 61 Units with Potential Noise Impacts.............................................................................................................268
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Table 62 North Santiam Canyon Employment ..........................................................................................................270

Table 63 Estimated Economic Alternatives ...............................................................................................................272

Table 64 Road Status within Hwy 46 Planning Area ................................................................................................339

List of Figures

Figure 1 Project Vicinity Map.......................................................................................................................................14

Figure 2 Hwy 46 Project Area ......................................................................................................................................15

Figure 3 6th Field Watersheds within the Project Area...............................................................................................15

Figure 4 Willamette Forest Plan Management Areas in the Hwy 46 Project Area......................................................24

Figure 5 Northwest Forest Plan Management Areas in the Hwy 46 Project Area.......................................................25

Figure 6 Map of Alternative 2......................................................................................................................................36

Figure 7 Map of Alternative 3......................................................................................................................................41

Figure 8 Location of 2017 Fires within Project area ....................................................................................................67

Figure 9 Project Area and Breitenbush 5th Field Watershed ......................................................................................69

Figure 10 Stand Age Distribution in the Hwy 46 Project Area.....................................................................................71

Figure 11 Douglas-fir plantations. Left: Stem exclusion stage in unit 47. Right: Competing crowns in Unit 140........73

Figure 12 Douglas-fir/hemlock Stands. Stem exclusion stage on the left. Stand re-initiation stage on the right.......73

Figure 13 Left: Unit 50 Douglas-fir/hemlock. Right: Unit 97 Douglas-fir/noble fir. ...................................................74

Figure 14 Examples of a Douglas-fir plantation from the 1920s that was never thinned ..........................................75

Figure 15 Left: Example of recent thinning in an 80-90 year old fire regenerated stand. Right: Example of recent 

thinning in a 40-50 year old plantation ..............................................................................................................76

Figure 16 Western hemlock growing into the mid-story approximately 30 years after thinning. ..............................77

Figure 17 Graphic representation of thinning with skips and DTR gaps......................................................................78

Figure 18 Google Earth image of recently created dominant tree release (DTR) gaps in a thinned stand .................78

Figure 19 Left: Sugar pine competing with other conifers in Unit 83. Right: Previously treated sugar pine stand 

within the project area. ......................................................................................................................................81

Figure 20 Left: Meadow portion of Unit 73. Right: Encroached meadow in Unit 32a. ...............................................82

Figure 21 Stream in Unit 430 in need of hardwood restoration. ................................................................................83

Figure 22 Examples of very low intensity ground fire in units 95 (left) and 83 (right) with little mortality expected.87

Figure 23 Example of low intensity fire initial effects in unit 13 with mixed species..................................................87

Figure 24 Left: Example of isolated crown mortality in low severity burn in unit 12. Right: Mixed severity burn in 

the Little Devils fire. No Hwy 46 units are visible in the Little Devils photo. ......................................................87

Figure 25 Fire Regime Classification Hwy 46 Planning Area........................................................................................90

Figure 26 Within and around the Breitenbush and Devils Creek summer homes areas of dense vegetation exist 

that may contribute to increased fire intensity making protection of structure in a wildfire difficult. .............91

Figure 27 Areas that have received hazardous fuel treatments such as this can help reduce fire intensity and 

provide for a safer environment to suppress wildfires and provide structure protection.................................91

Figure 28 Fuel Model 5 Figure 29 Fuel Model 8 ..................................................................................................92

Figure 30 Fuel Model 10 Figure 31 Fuel Model 12 ..............................................................................................92

Figure 32 Post-harvest underburning will create a mosaic of burned and unburned areas throughout stands........94

Figure 33 Underburns will be timed to ensure adequate duff and down wood retention .........................................95

Figure 34 Vegetation classification of the Breitenbush Watershed using high resolution satellite imagery 

(Worldview) and eCognition software..............................................................................................................115
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Figure 35 Vegetation classification within the Riparian Reserves of the project area and sub-watersheds using highresolution satellite imagery (Worldview) and eCognition software.................................................................116

Figure 36 Example of overstocked, conifer dominant stand lacking structural and species diversity within Riparian 

Reserves (Unit 520)...........................................................................................................................................118

Figure 37 Recent Short Creek debris flow, about mid-way up. Photo by J. Sheahan Alonso, 5/27/2016.................121

Figure 38 Source Distance Curves for Study Area (Benda and Bigelow 2014) ..........................................................130

Figure 39 From Burton et al (2016) Effect of wood volume recruitment to small channels by width of no-harvest 

buffer................................................................................................................................................................131

Figure 40 Sensitive and Survey and Manage Species documented within the project area.....................................202

Figure 41 Special Habitats .........................................................................................................................................212

Figure 42 Weed infestations......................................................................................................................................214

Figure 43 Hwy 46 Visual Quality Objectives for Alternative 2 ...................................................................................228

Figure 44 Hwy 46 Visual Quality Objectives for Alternative 3 ...................................................................................229

Figure 45 Fox Creek Group Site. Current conditions, ................................................................................................233

Figure 46 Fox Creek Group Site. Photoshop simulation of thinning..........................................................................234

Figure 47 Breitenbush View of Devils Ridge from Footbridge, left. View from Breitenbush Middle Pool, right. .....234

Figure 48 View from Gold Butte Lookout 9-27-16.....................................................................................................236

Figure 49 GoogleEarth view from Gold Butte facing SE towards project area..........................................................237

Figure 50 Photoshop simulation of proposed treatments in Alternative 2 from Gold Butte....................................237

Figure 51 Photoshop simulation of 1/2 acre gaps and thinning in units 28 and 30 in Alternative 2.........................238

Figure 52 Conditions of Powerline Corridor..............................................................................................................238

Figure 53: Unit 69 visual enhancement treatment....................................................................................................239

Figure 54 Recreation Uses in Hwy 46 Project area....................................................................................................241

Figure 55 Viewshed from Firecamp Lakes vicinity.....................................................................................................254

Figure 56 Viewshed from Triangulation Peak vicinity ...............................................................................................255

Figure 57 Area (in green) with expected impacts from helicopter operations .........................................................259

Figure 58 Map of Unit 520.........................................................................................................................................262

Figure 59 Unit 520 Current Conditions......................................................................................................................262

Figure 60 Hwy 46 Units Visibility from Breitenbush Resort and Conference Center ................................................268

Figure 61.DecAID analysis showing estimated current and historic downed wood for the Breitenbush River 

watershed in Westside Lowland Conifer-Hardwood Forest habitat (Acker 2015)...........................................313

Figure 62 DecAID analysis showing estimated current and historic large-diameter downed wood for the 

Breitenbush River watershed in Westside Lowland Conifer-Hardwood Forest habitat (Acker 2015)313

Figure 63. DecAID analysis showing estimated current and historic downed wood for the Breitenbush River 

watershed in Montane Mixed Conifer habitat (Acker 2015)............................................................................314

Figure 64. DecAID analysis showing estimated current and historic snags for the Breitenbush River watershed in 

Westside Lowland Conifer-Hardwood Forest habitat (Acker 2015).................................................................315

Figure 65. DecAID analysis showing estimated current and historic large snags for the Breitenbush River watershed 

in Westside Lowland Conifer-Hardwood Forest habitat (Acker 2015).............................................................316

Figure 66. DecAID analysis showing estimated current and historic snags for the Breitenbush River watershed in 

Montane Mixed Conifer habitat (Acker 2015)..................................................................................................316

Figure 67. DecAID analysis showing estimated current and historic snags for the Breitenbush River watershed in 

Montane Mixed Conifer habitat (Acker 2015)..................................................................................................317
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Summary

The Detroit Ranger District is proposing to improve stand growth, diversity and structure; move stand 

structure from an overabundance of mid-seral stands to increase both early and late seral stand structure 

within the watershed; reduce hazardous fuels; restore sugar pine and encourage sugar pine 

regeneration; treat powerline visuals; restore riparian, understory and meadow habitats; and restore 

hydrologic processes in the Short Lake area. This project would also provide a sustainable yield of 

timber for commercial products to local and regional economies. Treatments would occur on about 

4,060 acres on the Willamette National Forest. 

Purpose and Need

Improve Stand Growth, Diversity and Structure and Move Stand Structure 

from an Overabundance of Mid-seral Stands

The proposed project is needed to improve stand conditions, diversity, density, and structure in the project 

area, providing benefits to vegetation, wildlife, and overall health of the forest.

Increase Stand Health and Vigor: All of the stands in which overstory management is proposed have a 

high continuous overstory canopy cover, most averaging 80% or more. The trees are competing for 

sunlight, water, and nutrients causing reduced tree growth and vigor as well as limiting understory 

vegetation. The understory is mostly limited to shrubs with few small trees scattered throughout resulting 

in single-storied stands in the plantations. The fire regenerated stands are similar to the plantations in that 

there is high competition between the overstory trees and suppression in the regeneration.

The proposed project would help improve stand conditions, diversity, density and structure with thinning, 

gaps, and dominant tree release. Thinning the overstocked stands would make more growing space and 

resources available to the remaining trees, resulting in decreased tree stress and development towards 

larger diameter stands. Stand vigor would also be increased as released trees develop into larger trees 

sooner, accelerating the development of some late successional characteristics. Tree species, age, and 

structure diversity would be maintained or enhanced.

Plantations are generally characterized by dense monocultures of Douglas-fir. Competition is high with 

mortality occurring in many of the stands. Crown ratios are small, leading to reduced diameter growth. 

Although fairly well established on some of the northerly slopes, regeneration is suppressed by the 

overstory and growing slowly. Fire regenerated stands are older than the plantations in this project, and 

tend to have larger trees. Species composition in the overstory varies for pure Douglas-fir to mixed 

Douglas-fir with noble fir, western white pine, western hemlock, western redcedar, pacific silver fir, and 

sugar pine. Understory regeneration is variable and is predominantly western hemlock with western 

redcedar, grand fir, pacific yew, and mountain hemlock at the higher elevations. These stands are similar 

to the plantations in that there is high competition between the overstory trees and suppression in the 

regeneration.

Increase the Amount of Early Seral Habitat: Age class diversity in forest stands is important as some 

species of animals and plants depend on younger stages of forests for their feeding, nesting, and breeding 

requirements. Early seral habitat (defined as less than 20 years old) is of key importance to an estimated 

156 species of wildlife in the central Oregon Cascades (O’Neil et al 2001). 
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With the cessation of clear-cut logging twenty years ago and continued fire suppression, early seral 

habitat has been substantially reduced within the project area. Prior to the fires of 2017, the powerline 

corridor contained most of the early seral habitat in the project area, encompassing less than 1% of the 

acreage in the project area. It is estimated that 521 acres (1.6%) of early seral habitat was created in the 

project area as a result of the 2017 fires. Historically, the Breitenbush watershed maintained about 9% 

early seral due to wildfire (USDA 1996, 2014). Patches of early seral habitat contribute to landscape 

heterogeneity and provide habitat for large herbivores, song birds, cavity nesters, and pollinators.

Increase the Amount of Late Seral Habitat: Age class diversity in forest stands is important as some 

species of animals and plants depend on older stages of forest development for their feeding, nesting, 

breeding and cover requirements such as flying squirrels, spotted owls, and many lichens and mosses. 

Historically, the Breitenbush watershed maintained about 60% of closed canopy late seral stands. 

Currently, the watershed has about 48% closed canopy late seral stands. There is currently a need to 

enhance, create, and maintain stands of trees in the Breitenbush watershed with late seral characteristics.

Late-Successional Reserves (LSR) are to be managed to protect and enhance conditions of latesuccessional and old-growth forest ecosystems. Silviculture treatments are to benefit the creation and 

maintenance of late-successional forest conditions and are subject to review by the Regional Ecosystem 

Office (REO). In the Hwy 46 Project, there are 38 units that are either completely within or have a portion 

within the LSR, totaling 1,018 acres. Of this, 35 units encompassing 808 acres are prescribed for 

commercial thinning. These stands are previously managed, densely stocked plantations, less than 80 

years old.

Increase the Potential for Riparian Reserves to Function as Late Successional Habitat: Treatment of 

stands in Riparian Reserves would maintain adequate shade and accelerate the ability of Riparian 

Reserves to provide adequate root strength and bank stability, sediment filtration and nutrient cycling, 

large wood supply to waterbodies and floodplains, organic matter input, and habitat for ripariandependent wildlife.

Strategically Reduce Hazardous Fuels

The project area surrounds both the Breitenbush Hot Springs Retreat and Conference Center and the 

Breitenbush and Devils Creek summer home tracts. These areas have been identified as communities at 

risk in the Marion County Community Wildfire Protection Plan. Much of the area that surrounds the 

structures within these communities is dense older forest with heavy fuel loadings and narrow road access 

that could inhibit fire suppression activities in the event of a wildfire.

During 2017, fire suppression work was done within the Breitenbush and Devils Creek summer home 

tracks to improve defensible space, however due to the amount of fuel loading and narrow access and 

egress the structures were classified as “prep and leave” and determined to be non-defensible. Additional 

fuels reduction work may make these structures easier and safer to defend in the event of another wildfire 

threatening this community.

Restore Sugar Pine

The primary range of sugar pine extends from northern Mexico, through the Sierra Nevada, Northern 

California, and Southern Oregon. The very northern extent of its range is in the Hwy 46 project area. 

Sugar pines are moderately shade tolerant, particularly when they are young, needing some protection 

from the sun as they establish. As they get older their tolerance for competition decreases, and other 

species can out-compete them if lower intensity disturbances, primarily wildfire, do not thin stand 
Hwy 46 Project Final EIS

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densities. Fire suppression in the watershed has limited natural sugar pine regeneration, and the 

population has declined over time.

Treat Powerline Visuals

The Hwy 46 project area encompasses the Breitenbush viewshed corridor. This viewshed is an important 

scenic asset as it surrounds the Breitenbush Hot Springs Retreat and Conference Center and includes 

travel corridors that are considered sensitive to scenic quality. A powerline corridor bisects the watershed 

and the straight lines of the powerline corridor do not appear natural on the landscape. 

Restore Riparian and Understory Habitats, Meadows and Hydrologic 

Processes

The previously managed stands in the Hwy 46 Project Area were harvested and replanted using direction 

that pre-dates the Willamette Land and Resource Management Plan (1990) and prior to the Northwest 

Forest Plan (1994). As a result, the majority of these forest stands were set on a management-induced 

trajectory that has led to artificially dense, conifer-dominated stands, with tree densities above the range 

of natural variability expected in this area, suppressing shrub and forb diversity in the understory. 

Analysis found that 4.6% of the Riparian Reserves in the Hwy 46 project area had a deciduous and 

deciduous/shrub component. Deciduous leaves have a higher nutritional quality than coniferous needles

with regard to contributions to the aquatic food web. 

With the exclusion of fire, meadow habitat within the project area has been declining. A high elevation 

meadow has been encroached upon by conifers, resulting in a decline in plant diversity, pollinator habitat, 

and wildlife forage.

The current alignment of FS road 46-059 has disrupted the hydrology of the Short Lake Area. This road 

accesses Short Lake, a popular destination for dispersed recreation camping, as well as fishing, birding, 

boating and wildlife viewing. Rerouting the road would reduce sediment delivery to streams in the project 

area, improve water quality, and reduce road maintenance.

Provide Forest Products to the Local Economy

The proposed project is needed to ensure the Willamette National Forest continues to supply a reliable 

supply of timber products as directed by the laws and guidance and in doing so contributes to the stability 

of local, regional, and national economies and achieves the annual Probable Sale Quantity (PSQ) target 

for the Forest.

Alternatives

Three alternatives were analyzed in this FEIS; a no action alternative (Alternative 1) and two action 

alternatives (Alternative 2 and 3). The alternatives vary by the amount of treatment (Table 1). Alternative 

2 is the proposed action and preferred alternative.
Hwy 46 Project Final EIS

4

Table 1 Comparison of the Alternatives

Proposed Activity Unit of 

Measure Alternative 1 Alternative 2 Alternative 3

Timber Harvest Treatments

Thinning outside Riparian Reserves Acres 0 1785.45 1343.95

Thinning in Riparian Reserves Acres 0 703 528

Quality Early Seral Creation Acres 0 43 14

Sugar Pine Shelterwood Acres 0 92 9

Gaps Acres 0 47.8 28.8

Dominant Tree Release Acres 0 72.75 61.25

Skips Acres 0 910 689

Meadow Restoration Acres 0 8 0

Total Acres 0 3662 2674

Estimated Volume MMBF 0 ~40 ~24

Non-commercial treatments

Understory Habitat Enhancements Acres 0 155 155

Streamside treatments Acres 0 20 20

Hazardous Fuels Treatment Acres 0 229 193

Total Acres 0 398 368

Post-Harvest Fuels Treatments1 in Timber Harvest Units

Pile and Burn (mechanical and/or hand 

treatments )2 Acres 0 886 799

Post-Harvest Underburn 3 Acres 0 1102 586

Connected Actions

Harvest System

Helicopter Acres 0 317 56

Skyline Acres 0 1510 1163

Ground Acres 0 926 766

Transportation

Temporary Roads Reconstruction Miles 0 4.01 3.3

Temporary Roads Construction Miles 0 5.11 3

Road Maintenance/Haul Route Miles 0 108 98

Road Realignment Miles 0 1 1

Road Decommissioning Miles 0 8.88 8.88

Road Storage Miles 0 4.07 4.07
Hwy 46 Project Final EIS

5

Proposed Activity Unit of 

Measure Alternative 1 Alternative 2 Alternative 3

Rock Pit Management Each 0 10 10

Post-Harvest Planting

Early Seral Planting Acres 0 43 14

Shelterwood Planting Acres 0 92 9

Gap Planting Acres 0 47.8 28.8

Dominant Tree Release Planting Acres 0 Up to 72.75 Up to 61.25

Key Issues

Fire regenerated stands harvested Acres 0 767 0

1: Post-harvest fuels treatments methods may change depending on feasibility and funding. Post-harvest fuels treatments would occur in timber harvest units; 

therefore the acreage of post-harvest fuels treatments are not included in the total acres of treated units.

2: Mechanical treatment may include: grapple piling in slash concentrations, yarding tops attached, mastication, or any other mechanical device). 

3: These acres are possible underburn acres due to dbh and location, not all acreage may be underburned. Acreage not underburned may have other post-harvest 

fuels treatments assigned before implementation.

Summary of Environmental Consequences

Table 2 Summary of Direct Effects on Resources for Alternative 2 and Alternative 3

Resource Alternative 1 Alternative 2 Alternative 3

Forest and Stand 

Structure

High stocking density and 

canopy covers would 

continue to restrict 

regeneration and slow tree 

growth. Sugar pine presence 

would decline on the 

landscape as would early 

seral habitat.

3519 acres would be treated 

by thinning, skips, and gap 

creation. Inter-tree 

competition within the 

thinned portions of the 

stands would be reduced.

This would increase vigor, 

allowing the remaining trees 

to grow in diameter at a 

faster rate than without 

thinning. Shade tolerant tree 

species such as western 

hemlock and western 

redcedar would be released 

to grow further into the mid 

and overstory. Skips, clumps, 

and the creation of dominant 

tree release gaps would add 

to the structural 

heterogeneity of the stands 

as well as increase species 

diversity. One to three acre 

wildlife gaps would increase 

the amount of grass-forb 

stage habitat within the 

project area.

2651 acres would be treated 

by thinning, skips, and gap 

creation. Inter-tree 

competition within the 

thinned portions of the 

stands would be reduced. 

This would increase vigor, 

allowing the remaining trees 

to grow in diameter at a 

faster rate than without 

thinning. Shade tolerant tree 

species such as western 

hemlock and western 

redcedar would be released 

to grow further into the mid 

and overstory. Skips, clumps, 

and the creation of dominant 

tree release gaps would add 

to the structural 

heterogeneity of the stands 

as well as increase species 

diversity. One to three acre 

wildlife gaps would increase 

the amount of grass-forb 

stage habitat within the 

project area.
Hwy 46 Project Final EIS

6

Resource Alternative 1 Alternative 2 Alternative 3

Sugar Pine Sugar pine on the landscape 

would continue to decline.

92 acres of sugar pine

habitat would be restored 

The existing sugar pine 

population would benefit from 

reduced competition was well 

as the establishment of a 

new rust resistant cohort, 

ensuring the continued 

presence of the species.

9 acres of sugar pine habitat 

would be restored. The 

opportunity to restore sugar 

pine habitat on 83 acres 

would be missed.

Early seral habitat

No acres of quality early 

seral habitat would be 

created, the amount of grassforb stage in the project area 

would decline.

43 acres of quality early seral 

habitat would be created, 

increasing the amount of 

grass-forb stage habitat 

within the project area. A 

wide variety of species would 

benefit, including deer, elk, 

songbirds, and numerous 

pollinators.

14 acres of quality early seral 

habitat would be created, 

benefitting several wildlife 

species.

Late Successional 

Reserves

Stands within the Late 

Successional Reserve would 

continue to develop at the 

current rate.

Structural and species 

diversity would be increased 

on 808 acres, resulting in 

these stands attaining late 

seral characteristics sooner 

than if left untreated.

Structural and species 

diversity would be increased 

on 808 acres, resulting in 

these stands attaining late 

seral characteristics sooner 

than if left untreated.

Meadow restoration

Conifers would continue to 

encroach upon the high 

elevation meadow.

8 acres of conifers would be 

removed from the high 

elevation meadow, promoting 

both wet site plants and early 

seral obligate species.

Conifers would continue to 

encroach upon the high 

elevation meadow.

Fire and Fuels

Effects of fire suppression 

and past management 

activities would continue. 

Lack of fire disturbance 

would prevent the creation of 

new early seral conditions 

and inhibit the establishment 

of new sugar pine. Fuels

would continue to 

accumulate in the 

Breitenbush Summer Homes 

and Hot Springs Resort area.

Hazardous fuels on 193

acres in the Breitenbush WUI 

would be reduced. Timber 

harvest slash would follow 

Forest Plan standards and 

guidelines FW-212 and FW252 guidance. Returning fire 

would increase stand 

diversity and structure.

Hazardous fuels on 193

acres in Breitenbush WUI

would be reduced. Timber 

harvest slash would follow 

Forest Plan standards and 

guidelines FW-212 and FW252 guidance. Returning fire 

would increase stand 

diversity and structure.

Soil Productivity No effect

Nutrient availability and 

compaction would remain 

within the limits outlined in 

the standard and guidelines 

of the forest plan.

Nutrient availability and 

compaction would remain 

within the limits outlined in 

the standard and guidelines 

of the forest plan.

Water Quality and 

Quantity No effect

Water quality would be 

protected. Treatment of 

riparian vegetation would 

meet TMDL requirements for 

temperature and sediment. 

No increased flood flows are 

anticipated due to this 

project.

Water quality would be 

protected. Treatment of 

riparian vegetation would 

meet TMDL requirements for 

temperature and sediment. 

No increased flood flows are 

anticipated due to this 

project.
Hwy 46 Project Final EIS

7

Resource Alternative 1 Alternative 2 Alternative 3

Upper Willamette 

River 

ChinookSalmon 

(Evolutionarily 

Significant Unit-ESU) 

No effect May affect, not likely to 

adversely affect

May affect, not likely to 

adversely affect

Upper Willamette 

River Chinook 

Salmon 

(Critical Habitat)

No effect No effect No effect

Upper Willamette 

River 

ChinookSalmon 

(Essential Habitat)

No effect No effect No effect

Caddisflies -

Rhyacophila 

chandleri, 

Rhyacophila leechi, 

Namamyia plutonis

(R6 Sensitive)

No effect Beneficial effect Beneficial effect

Northern Spotted 

Owl (ESA Threatened 

and Management 

Indicator Species)

No effect

May affect and is likely to 

adversely affect spotted owls 

by habitat modification. May 

affect and is not likely to 

adversely affect spotted owls 

by disturbance.

May affect and is likely to 

adversely affect spotted owls 

by habitat modification. May 

affect and is not likely to 

adversely affect spotted owls 

by disturbance.

American Peregrine 

Falcon (R6 Sensitive 

and Management 

Indicator Species) 

No impact No impact No impact

Harlequin Duck (R6 

Sensitive) No impact

No impact. All project 

activities with potential to 

impact harlequin ducks are 

restricted from March 15 to 

July 15 to avoid disturbance 

to nesting harlequin ducks.

No impact. All project 

activities with potential to 

impact harlequin ducks are 

restricted from March 15 to 

July 15 to avoid disturbance 

to nesting harlequin ducks.
Hwy 46 Project Final EIS

8

Resource Alternative 1 Alternative 2 Alternative 3

Fisher 

(Proposed 

Threatened) 

No effect

Unlikely to occur in the 

project area and not 

expected to be affected by 

proposed activities.

Unlikely to occur in the 

project area and not 

expected to be affected by 

proposed activities.

Fringed Myotis and 

Townsend’s Bigeared Bat (R6 

Sensitive)

No impact

May be affected if trees 

which have potential to be 

used for nursery colonies are 

felled as hazards during 

harvest operations 

Subsequent snag creation 

may offset this impact.

May be affected if trees 

which have potential to be 

used for nursery colonies are 

felled as hazards during 

harvest operations 

Subsequent snag creation 

may offset this impact.

Johnson’s Hairstreak 

(R6 Sensitive) No impact Minimal effect Minimal effect

Western Bumble Bee No impact Beneficial effect, due to 

meadow restoration No effect

Crater Lake Tightcoil 

(R6 Sensitive and 

Survey and Manage 

Species) 

No impact No effect No effect

Oregon Megomphix 

(Survey and Manage 

Species) 

No impact No effect No effect
Hwy 46 Project Final EIS

9

Resource Alternative 1 Alternative 2 Alternative 3

Red Tree Vole 

(Survey and Manage 

Species) 

No impact No effect No effect

Great Gray Owl 

(Survey and Manage 

Species) 

No impact No effect No effect

Cavity Excavators 

(Management 

Indicator Species) 

No impact

Snag abundance may initially 

decline on 3515 acres, then

increase with post-harvest 

mitigation and enhancement.

Snag abundance may initially 

decline on 2652 acres, then

increase with post-harvest 

mitigation and enhancement.

Elk and Deer 

(Management 

Indicator Species)

No impact

About 1,747 acres of poor 

quality foraging areas would 

be converted to low-marginal 

(1,575 acres), high-marginal 

(164 acres) or good (8 acres) 

foraging habitat.

About 1,179 acres of poor 

quality foraging areas would 

be converted to low-marginal 

(1,096 acres) or highmarginal (83 acres) foraging 

habitat.

Pileated Woodpecker 

(Management 

Indicator Species) 

No impact No effect No Effect
Hwy 46 Project Final EIS

10

Resource Alternative 1 Alternative 2 Alternative 3

Marten

(Management 

Indicator Species

No impact

About 4.5% to 12.5% of the 

habitat in three potential 

marten home ranges would 

be degraded. This level of 

impact is not expected to 

result in a loss of functional 

home ranges for marten, but 

shifting of use within 

territories and minor changes 

to the size of the territory to 

compensate for the impacts 

on the habitat would likely 

occur. Understory habitat 

enhancement in older stands 

may slightly benefit marten 

habitat in two potential home 

ranges.

About 4.5% to 7.9% of the 

habitat in two potential 

marten home ranges would 

be degraded. This level of 

impact is not expected to 

result in a loss of functional 

home ranges for marten, but 

shifting of use within 

territories and minor changes 

to the size of the territory to 

compensate for the impacts 

on the habitat would likely 

occur. Understory habitat 

enhancement in older stands 

may slightly benefit marten 

habitat in two potential home 

ranges.

Bald Eagle 

(Management 

Indicator Species 

No impact No effect No effect

Sensitive Botanical 

Species No effect

No direct or indirect effect on 

sensitive vascular plants, 

lichens or bryophytes. 

However, since single year 

surveys were deemed 

infeasible for fungi, there 

could be effects to these 

species.

No direct or indirect effect on 

sensitive vascular plants, 

lichens or bryophytes. 

However, since single year 

surveys were deemed 

infeasible for fungi, there 

could be effects to these 

species.

Survey and Manage

Botanical Species No effect

Direct effects may include 

compaction and loss of host 

trees in timber harvest 

treatment areas

Direct effects may include 

compaction and loss of host 

trees in timber harvest 

treatment areas

Special Habitats No effect

Restoration of high elevation 

meadow habitat. All other 

special habitats will be 

protected by buffers or 

avoidance.

No effect due to buffers and 

avoidance

Invasive Plants No effect

A 9% increase in habitat for 

invasive plant species are 

expected. Project design 

features would be used to 

mitigate some increases in 

populations of invasive plants 

due to ground disturbance; 

weed increases will be 

minimized to the extent 

possible. 

A 6% increase in habitat for 

invasive plant species are 

expected. Project design 

features would be used to 

mitigate some increases in 

populations of invasive plants 

due to ground disturbance; 

weed increases will be 

minimized to the extent 

possible.

Roads

Continued decline in road 

conditions on the 108 miles 

of roads associated with the 

project.

Would improve declining 

road conditions on an 

estimated 108 miles of road.

8.88 miles of road would be 

decommissioned.4.07 miles 

of road would be closed or 

stored. The Short Lake road 

Would improve declining 

road conditions on an 

estimated 98 miles of road.

8.88 miles of road would be 

decommissioned.4.07 miles 

of road would be closed or 

stored. The Short Lake road 
Hwy 46 Project Final EIS

11

Resource Alternative 1 Alternative 2 Alternative 3

would be realigned, restoring 

hydrologic processes and 

decreasing road generated 

sediment deliver to streams 

in the project area. 

would be realigned, restoring 

hydrologic processes and 

decreasing road generated 

sediment deliver to streams 

in the project area.

Heritage No effect Not likely to affect Not likely to affect

Scenic Quality No effect

The proposed actions would 

provide benefits to visuals 

along the powerline corridor 

and would enhance the view 

of Mt. Jefferson from the 

West Cascades National 

Scenic Byway. The proposed 

actions would not have any 

long term adverse effects to 

visually sensitive 

management areas, and 

proposed treatments would 

be consistent with standards 

and guidelines set by the 

Forest Plan.

The proposed actions would 

provide benefits to visuals 

along the powerline corridor 

and would enhance the view 

of Mt. Jefferson from the 

West Cascades National 

Scenic Byway. The proposed 

actions would not have any 

long term adverse effects to 

visually sensitive 

management areas, and 

proposed treatments would 

be consistent with standards 

and guidelines set by the 

Forest Plan.

Recreation No effect

Temporary adverse effects 

due to trail closures, 

increased noise and dust and 

log truck traffic during 

harvest activity. Benefits of 

timber harvest activity would 

include improved access to 

dispersed recreation areas 

due to road maintenance, 

improved scenery from 

secondary forest roads and 

an enlarged and improved 

trailhead parking area at the 

South Breitenbush Trail.

Temporary adverse effects 

due to trail closures, 

increased noise and dust and 

log truck traffic during 

harvest activity. Benefits of 

timber harvest activity would 

include improved access to 

dispersed recreation areas 

due to road maintenance, 

improved scenery from 

secondary forest roads and 

an enlarged and improved 

trailhead parking area at the 

South Breitenbush Trail.

Eligible Wild and 

Scenic Rivers

There will be no impact to the 

free flowing status or the 

ORVs of each river and their 

eligibility for inclusion in the 

national Wild and Scenic 

River system will be 

maintained.

The actions proposed will not 

affect the eligibility of either 

the Breitenbush River or 

South Fork Breitenbush 

River for inclusion in the 

national Wild and Scenic 

River System. 

The actions proposed will not 

affect the eligibility of either 

the Breitenbush River or 

South Fork Breitenbush 

River for inclusion in the 

national Wild and Scenic 

River System.

Wilderness No effect

Temporary adverse effects to 

wilderness character due to 

increased noise during 

harvest activity.

Temporary adverse effects to 

wilderness character due to 

increased noise during 

harvest activity.

Inventoried Roadless 

Area (IRA) No effect

Approximately 14 acres 

would be thinned. Roadless 

characteristics would 

continue to be met in the 

IRA.

Approximately 14 acres 

would be thinned. Roadless 

characteristics would 

continue to be met in the 

IRA.
Hwy 46 Project Final EIS

12

Resource Alternative 1 Alternative 2 Alternative 3

Air Quality No effect

Impacts on air quality from 

smoke emissions would not 

exceed state mandated 

policy.

Impacts on air quality from 

smoke emissions would not 

exceed state mandated 

policy.

Economics

No contribution to local 

economy, forest sector jobs, 

or the National Forest Fund 

(NFF) would result. If not 

replaced by another project, 

Alternative 1 could contribute 

to a continued decline in 

forestry and milling related 

jobs.

Approximately 40 million 

board feet of timber would be 

contributed to local economy, 

forest sector jobs, and county 

governments via timber 

revenue and the National 

Forest Fund (NFF) would 

result. Jobs associated with 

timber harvest and 

production would contribute 

to the local economy with 

direct and indirect jobs and 

increased tax revenue to the 

government from those jobs. 

Approximately 24 million 

board feet of timber would be 

contributed to local economy, 

forest sector jobs, and county 

governments via timber 

revenue and the National 

Forest Fund (NFF) would 

result. Jobs associated with 

timber harvest and 

production would contribute 

to the local economy with 

direct and indirect jobs and 

increased tax revenue to the 

government from those jobs. 
Hwy 46 Project FEIS Chapter 1 – Purpose and Need

13

Chapter 1 - Purpose and Need 

1.1 Introduction

The Detroit Ranger District is proposing to improve stand growth, diversity and structure; move stand 

structure from an overabundance of mid-seral stands to increase both early and late seral stand structure 

within the watershed; reduce hazardous fuels; restore sugar pine and encourage sugar pine regeneration; 

treat powerline visuals; restore riparian and meadow habitats; and restore hydrologic processes in the 

Short Lake area. This project would also provide a sustainable yield of timber for commercial products to 

local and regional economies. Treatments would occur on about 4,060 acres on the Willamette National 

Forest. 

The Hwy 46 project area is approximately 31,295 acres, located in the Breitenbush Watershed. Forest 

Road 46 (Hwy 46), the Breitenbush River and a powerline bisect the project area. The Hwy 46 project 

area is located approximately 6 miles northeast of the town of Detroit, Oregon, in Marion County. The 

legal description of the area is T 9 S, R 6 E, sections 1, 11 – 15, 21 – 28, 35 and 36, T 9 S, R 7 E, sections 

3 – 36, T 9 S, R 8 E, sections 7, 18, 19, 30 and 31, T 10 S, R7 E, sections 1 – 6 and 8 – 12, T 10 S, R 8 E, 

section 6.

Within the project area trees are competing for sunlight, water and nutrients causing reduced tree growth 

and vigor. There is an oversupply of mid-seral stands, moving the seral distribution away from historic 

levels and limiting stand structure and species diversity across the landscape. This is the northern most 

extent of sugar pine, and past management and the exclusion of fire on the landscape has threatened this 

population of sugar pine. The Breitenbush Resort and Conference Center is located within the project 

area, and the watershed is popular with recreationists. 

31,136 acres in the project area are managed by the Willamette National Forest with the remaining 159 

acres belonging to private land holders. The project area is composed mostly of a Douglas-fir and western 

hemlock overstory, with an understory shrub component of vine maple, salal, dwarf Oregon grape, sword 

fern and Pacific rhododendron. Historically, large scale disturbances have been from infrequent, high 

intensity fires. Approximately 40% of the stands within the project area were initiated between 1600 and 

1800. Another round of fires burned portions of the landscape around the turn of the twentieth century, 

particularly in the northern part of the project area, with approximately 21% of the area in this age class. 

Although commercial logging started in the watershed shortly after that, it did not ramp up until the 1960s 

with even-aged management. Since the mid-1990s, there has been virtually no stand replacing 

disturbance. During the summer of 2017 three large fires burned within the project area. These fires were 

typical of the western cascades mixed severity fire regime and had a range of effects on the landscape, 

burning at total of 2,921 acres within the project area.

The project area is popular for recreation activities including: camping, hiking, hunting, fishing, 

bicycling, picnicking, target shooting, berry picking, viewing scenery, and driving for pleasure. Portions 

of the West Cascades National Scenic Byway and Cascading Rivers Scenic Bikeway are within the 

project area. The forested slopes along the Breitenbush River form an important scenic backdrop for the 

byway and river corridor. Several campgrounds along Forest Road 46 provide access opportunities to 

explore the area, enjoy a picnic or go for a short hike on a developed trail. Trailheads along the eastern 

project boundary provide entry to the Mt. Jefferson Wilderness. There are four special use permits for 

utilities within the project area as well as 71 recreation residences (summer homes).
Hwy 46 Project FEIS Chapter 1 – Purpose and Need

14

Figure 1 Project Vicinity Map
Hwy 46 Project FEIS Chapter 1 – Purpose and Need

15

Figure 2 Hwy 46 Project Area

Figure 3 6th Field Watersheds within the Project Area
Hwy 46 Project FEIS Chapter 1 – Purpose and Need

16

1.2 Purpose and Need for Action

The purpose of this project is to (1) improve stand growth, diversity and structure and move stand 

structure from an overabundance of mid-seral stands to increase early and late seral stand structure in the 

watershed, and to diversify wildlife habitat in the watershed; (2) strategically reduce hazardous fuels; (3) 

restore sugar pine stands to encourage sugar pine regeneration; (4) treat powerline visuals; (5) restore 

riparian habitats, meadows, and hydrologic processes in the project area; and (6) provide forest products 

to the local economy.

Improve Stand Growth, Diversity and Structure and Move Stand Structure 

from an Overabundance of Mid-seral Stands

The proposed project is needed to improve stand conditions, diversity, density, and structure in the project 

area, providing benefits to vegetation, wildlife, and overall health of the forest.

Increase Stand Health and Vigor

Why Consider Taking Action: All of the stands in which overstory management is proposed have a high 

continuous overstory canopy cover, most averaging 80% or more. The trees are competing for sunlight, 

water, and nutrients causing reduced tree growth and vigor as well as limiting understory vegetation. The 

understory is mostly limited to shrubs with few small trees scattered throughout resulting in single-storied 

stands in the plantations. The fire regenerated stands are similar to the plantations in that there is high 

competition between the overstory trees and suppression in the regeneration.

The proposed project would help improve stand conditions, diversity, density and structure with thinning, 

gaps, and dominant tree release. Thinning the overstocked stands would make more growing space and 

resources available to the remaining trees, resulting in decreased tree stress and development towards 

larger diameter stands. Stand vigor would also be increased as released trees develop into larger trees 

sooner, accelerating the development of some late successional characteristics. Tree species, age, and 

structural diversity would be maintained or enhanced. 

The Stand Density Index (SDI), which is a qualitative measure of tree competition within a stand, ranges 

from 143 to 522 and averages 322 for all stands being considered for treatment in the Hwy 46 project 

area. In Douglas-fir, the maximum SDI (SDImax) is 595 (Reineke 1933). As a stand reaches an SDI of 

about 149, or approximately 25% of SDImax, trees within the stand start to compete with each other. As 

SDI increases to around 357, or 60% SDImax, trees reach a point at which they start dying due to 

competition, or self-thinning (Long, 1985).

Existing Condition: Plantations are generally characterized by dense monocultures of Douglas-fir. 

Competition is high with mortality occurring in many of the stands. Crown ratios are small, leading to 

reduced diameter growth. Although fairly well established on some of the northerly slopes, regeneration is 

suppressed by the overstory and growing slowly. Fire regenerated stands are older than the plantations in 

this project, and tend to have larger trees. Species composition in the overstory varies for pure Douglas-fir 

to mixed Douglas-fir with noble fir, western white pine, western hemlock, western redcedar, pacific silver 

fir, and sugar pine. Understory regeneration is variable and is predominantly western hemlock with 

western redcedar, grand fir, pacific yew, and mountain hemlock at the higher elevations. These stands are 

similar to the plantations in that there is high competition between the overstory trees and suppression in 

the regeneration.

Desired Condition: The desired future condition is to have healthy, vigorous stands which are diverse in 

species as well as in vertical and horizontal structure. 
Hwy 46 Project FEIS Chapter 1 – Purpose and Need

17

Increase the Amount of Early Seral Habitat

Why Consider Taking Action: Age class diversity in forest stands is important as some species of animals 

and plants depend on younger stages of forests for their feeding, nesting, and breeding requirements. 

Early seral habitat (defined as less than 20 years old) is of key importance to an estimated 156 species of 

wildlife in the central Oregon Cascades (O’Neil et al 2001). 

With the cessation of clear-cut logging twenty years ago and continued fire suppression, early seral 

habitat has been substantially reduced within the project area. Prior to the fires of 2017, the powerline 

corridor contained most of the early seral habitat in the project area, encompassing less than 1% of the 

acreage in the project area. It is estimated that 521 acres (1.6%) of early seral habitat was created in the 

project area as a result of the 2017 fires. Historically, the Breitenbush watershed maintained about 9% 

early seral due to wildfire (USDA 1996, 2014). Patches of early seral habitat contribute to landscape 

heterogeneity and provide habitat for large herbivores, song birds, cavity nesters, and pollinators.

There is a need to enhance, create, and maintain diverse quality and structurally rich early seral habitat to 

support wildlife species that have been documented to depend on early seral habitat, such as elk, blacktailed deer, rufous hummingbirds, olive-sided flycatchers, and a large number of butterfly and moth 

species. 

Existing Condition: Less than 4% of the project area is early seral habitat (defined as less than 20 years 

old).

Desired Condition: Historically the Breitenbush Watershed maintained about 9% early seral due to 

wildfire (USDA 1996, 2014). The desired condition would be to increase quality early seral habitat in the 

project area closer to historic levels.

Increase the Amount of Late Seral Habitat

Why Consider Taking Action: Age class diversity in forest stands is important as some species of animals 

and plants depend on older stages of forest development for their feeding, nesting, breeding and cover 

requirements such as flying squirrels, spotted owls, and many lichens and mosses. 

Historically, the Breitenbush watershed maintained about 60% of closed canopy late seral stands. 

Currently, the watershed has about 48% closed canopy late seral stands. There is currently a need to 

enhance, create, and maintain stands of trees in the Breitenbush watershed with late seral characteristics. 

Late-Successional Reserves (LSR) are to be managed to protect and enhance conditions of latesuccessional and old-growth forest ecosystems. Silviculture treatments are to benefit the creation and 

maintenance of late-successional forest conditions and are subject to review by the Regional Ecosystem 

Office (REO). In the Hwy 46 Project, there are 38 units that are either completely within or have a portion 

within the LSR, totaling 1,018 acres. Of this, 35 units encompassing 808 acres are prescribed for 

commercial thinning. These stands are previously managed, densely stocked plantations, less than 80 

years old. 

Existing Condition: Approximately 48% of the project area is in closed canopy late seral stands. 

Desired Condition: Historically, approximately 60% of the project area was in closed canopy late seral 

stands. The desired condition would be to move the late seral habitat closer to historical levels.

Increase the Potential for Riparian Reserves to Function as Late Successional Habitat

Why Consider Taking Action: Treatment of stands in Riparian Reserves would accelerate the ability of 

Riparian Reserves to provide adequate stream shade, root strength and bank stability, sediment filtration 

and nutrient cycling, large wood supply to waterbodies and floodplains, organic matter input, and habitat 
Hwy 46 Project FEIS Chapter 1 – Purpose and Need

18

for riparian-dependent wildlife.

Existing Condition: Portions of Riparian Reserves within project area units consist of dense, overstocked, 

conifer-dominant stands with very little structural and species diversity and understory development. This 

lack of complexity and diversity is outside the natural range of variability and may be limiting nutrient 

cycling, deciduous organic matter input to waterbodies, and habitat for riparian-dependent wildlife.

Desired Condition: Maintain conditions in currently functioning portions of Riparian Reserves. In 

overstocked, conifer-dominant portions lacking structural and species diversity, attain Aquatic 

Conservation Strategy Objectives (Appendix E). 

Strategically Reduce Hazardous Fuels

Why Consider Taking Action: The project area surrounds both the Breitenbush Hot Springs Resort and the 

Breitenbush and Devils Creek summer home tracts. These areas have been identified as communities at 

risk in the Marion County Community Wildfire Protection Plan. Much of the area that surrounds the 

structures within these communities is dense older forest with heavy fuel loadings and narrow road access 

that could inhibit fire suppression activities in the event of a wildfire.

Existing Condition Fire suppression over the past century has resulted in increased fuel loading 

throughout forest ecosystems. In 2014 51 acres of mastication work was completed within the

Breitenbush Hot Springs, and between 2006 and 2012 50 acres of fuels reduction was completed by the 

US Forest Service within the summer home tracts. While this work has improved defensible space 

conditions and access for fire suppression resources there is still a substantial risk from wildfire within 

these communities.

During 2017, fire suppression work was done within the Breitenbush and Devils Creek summer home 

tracks to improve defensible space, however due to the amount of fuel loading and narrow access and 

egress the structures were classified as “prep and leave” and determined to be non-defensible. Additional 

fuels reduction work may make these structures easier and safer to defend in the event of another wildfire 

threatening this community.

Desired Condition: Reduced horizontal and vertical continuity of fuels in and around the Breitenbush 

Wildland-Urban Interface to decrease potential impacts and risks to people, structures, and resources in 

the event of a wildfire. 

Restore Sugar Pine

Why Consider Taking Action: The primary range of sugar pine extends from northern Mexico, through the 

Sierra Nevada, Northern California, and Southern Oregon. The very northern extent of its range is in the 

Hwy 46 project area. Sugar pines are moderately shade tolerant, particularly when they are young, 

needing some protection from the sun as they establish. As they get older their tolerance for competition 

decreases, and other species can out-compete them if lower intensity disturbances, primarily wildfire, do 

not thin stand densities.

Existing Condition: Fire suppression over the last 100 years, extensive logging, and the introduction of 

white pine blister rust at the turn of the 20th century have reduced the population across its range (Waring 

and Angell, 2011). Most of the sugar pine found in the project area are lone big trees surrounded by dense 

Douglas-fir stands. One area of naturally regenerating sugar pine was found during project 

reconnaissance. The presence of these trees means that sugar pine has been part of this landscape for a 

long time and now appears to be losing its place in the ecosystem due to lack of disturbance allowing it to 

regenerate.
Hwy 46 Project FEIS Chapter 1 – Purpose and Need

19

Desired Condition: Sugar pine will be restored closer to historic levels on the landscape with continued 

regeneration.

Treat Powerline Visuals

Why Consider Taking Action: The Hwy 46 project area encompasses the Breitenbush viewshed corridor. 

This viewshed is an important scenic asset as it surrounds the Breitenbush Hot Springs Retreat and 

Conference Center and includes travel corridors that are considered sensitive to scenic quality. A 

powerline corridor bisects the watershed and the straight lines of the powerline corridor do not appear 

natural on the landscape.

Existing Condition: The project area is a high priority viewshed, with the powerline corridor bisecting 

the project area. The straight lines of the corridor are not natural looking.

Desired Condition: The existing straight line along the powerline corridor will be softened and a more 

natural appearing landscape will be created.

Restore Riparian Habitats, Meadows and Hydrologic Processes

Why Consider Taking Action: The previously managed stands in the Hwy 46 Project Area were harvested 

and replanted using direction that pre-dates the Willamette Land and Resource Management Plan (1990) 

and prior to the Northwest Forest Plan (1994). As a result, the majority of these forest stands were set on a 

management-induced trajectory that has led to artificially dense, conifer-dominated stands, with tree 

densities above the range of natural variability expected in this area, suppressing shrub and forb diversity 

in the understory. Analysis found that 4.6% of the Riparian Reserves in the Hwy 46 project area had a 

deciduous and deciduous/shrub component. Deciduous leaves have a higher nutritional quality than 

coniferous needles with regard to contributions to the aquatic food web. 

With the exclusion of fire, meadow habitat within the project area has been declining. A high elevation 

meadow has been encroached upon by conifers, resulting in a decline in plant diversity, pollinator habitat, 

and wildlife forage.

The current alignment of FS road 46-059 has disrupted the hydrology of the Short Lake Area. This road 

accesses Short Lake, a popular destination for dispersed recreation camping, as well as fishing, birding, 

boating and wildlife viewing. Rerouting the road would reduce sediment delivery to streams in the project 

area, improve water quality, and reduce road maintenance.

Existing Condition: The project area is deficient in hardwoods along streams. Past silvicultural practices 

harvested timber to the edge of many streams and planted Douglas-fir along the streamside. Foliage from 

hardwoods provide nutrients for macro-invertebrates which provide food for fish downstream. 

A high elevation meadow has been encroached upon by conifers since the last severe fire around the turn 

of the twentieth century. Historic aerial photos and field surveys indicate that this meadow once contained 

much more moisture and meadow vegetation, which is now being shaded out.

The current alignment of FS road 46-059 has disrupted the natural hydrology in the Short Lake area, 

allowing road generated sediment to enter the streams.

Desired Condition: Increase the shrub and deciduous component adjacent to streams. Restore the high 

elevation meadow to original standards by increasing hydrology, increasing solar exposure and enhancing 

the ability for native species to re-establish. Reduce the amount of road generated sediment entering 
Hwy 46 Project FEIS Chapter 1 – Purpose and Need

20

streams in the area adjacent to FS road 46-059 (the Short Lake Road) by realigning the road to a more 

stable terrain.

Provide Forest Products to the Local Economy

Why Consider Taking Action: The proposed project is needed to ensure the Willamette National Forest 

continues to supply a reliable supply of timber products as directed by the laws and guidance below and 

in doing so contributes to the stability of local, regional, and national economies and contributes to the 

annual Probable Sale Quantity (PSQ) target for the Forest.

Several laws direct and allow the Forest Service to provide the sustainable harvest of trees from the 

Nation’s forests including Multiple-Use Sustained-Yield Act of 1960 and the National Forest 

Management Act of 1976. One of the strategic goals of the Forest Service is to provide and sustain 

benefits to the people of the United States and the world as a whole. To accomplish this goal, one of the 

objectives is to provide a reliable supply of forest products over time consistent with achieving the desired 

conditions on National Forest System (NFS) lands and to maintain or create processing capacity and 

infrastructure in local communities. (USDA Strategic Plan FY 2014-2018 ). Additionally, the Willamette 

National Forest Land and Resource Management Plan as amended by the Northwest Forest Plan, includes 

goals to produce an optimum and sustainable yield of timber that helps maintain the stability of local and 

regional economies, and contribute valuable resources to the national economy on a predictable and longterm basis.

Probable Sale Quantity (PSQ) is an estimate of probable harvest levels that could be maintained on a 

forest annually (Northwest Forest Plan 1994). PSQs represent neither minimum levels that must be met 

nor maximum levels that cannot be exceeded. Rather, PSQs represent the best assessment of the average 

annual amount of timber harvest that could occur on a forest without decline, over the long term, if the 

schedule of harvests and regeneration are followed (Northwest Forest Plan 1994). PSQ can vary and 

change over time depending on acres available for harvest, expected acre yields and Forest direction.

Existing Condition: The current PSQ annual target for the Willamette National Forest is 111 million board 

feet (MMBF) as amended by the Approval of PSQ Estimates for Northwest Forest Plan Forests (1998).

Desired Condition: Through implementation of the proposed action, the Detroit Ranger District would 

contribute approximately 40 MMBF to the Willamette National Forest PSQ target and to the local 

economy.

1.3 Proposed Action

Proposed Action

The proposed action would treat approximately 4,060 acres in the project area. Harvest treatments 

proposed include thinning, dominant tree release, gap creation, early seral creation, shelterwood harvest, 

meadow restoration and skips. Non-commercial treatments include understory enhancements, riparian 

treatments, and hazardous fuels treatments. A detailed description of proposed treatments and project 

activities is located in Appendix A.

As stated in Section 1.2, the purpose and need for action includes: 

1. improve stand growth, diversity and structure, and move stand structure from an overabundance 

of mid-seral stands to increase early and late seral stand structure in the watershed, and to 

diversify wildlife habitat in the watershed;
Hwy 46 Project FEIS Chapter 1 – Purpose and Need

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2. strategically reduce hazardous fuels;

3. restore sugar pine stands to encourage sugar pine regeneration;

4. treat powerline visuals;

5. restore riparian habitats, meadows, and hydrologic processes in the project area; and 

6. provide forest products to the local economy 

Table 3 illustrates the preferred action proposed treatments, connected actions, and the purpose and need

they address. 

Table 3 Preferred Action Treatments and Connected Actions

Proposed Activity Unit of 

Measure

Preferred

Action Purpose – Need Addressed

Timber Harvest Treatments

Thinning outside Riparian Reserves Acres 1785.45 1,3,4,5,6

Thinning in Riparian Reserves Acres 703 1,3,4,5,6

Quality Early Seral Habitat Creation Acres 43 1,6

Sugar Pine Shelterwood Acres 92 1,2,3,6

Gaps Acres 47.8 1,3,4,6 

Dominant Tree Release Acres 72.75 1,3,5,6 

Skips Acres 910 1,5

Meadow Restoration Acres 8 1,5,6

Total Acres 3662 -

Estimated Volume MMBF ~40

Non-Commercial Treatments

Understory Habitat Enhancements Acres 155 1,2,5

Streamside Treatments (fall and leave) Acres 20 1,5

Hazardous Fuels Treatment (WUI) Acres 223 2

Total Non-Commercial Treatment Acres 398

Post-Harvest Fuels Treatments1 in Timber Harvest Units

Pile and Burn (mechanical and/or hand 

treatments )2 Acres 886 2

Post-Harvest Underburn3 Acres 1102 2

Connected Actions

Harvest System
Hwy 46 Project FEIS Chapter 1 – Purpose and Need

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Proposed Activity Unit of 

Measure

Preferred

Action Purpose – Need Addressed

Helicopter Acres 317 6

Skyline Acres 1510 6

Ground Acres 926 6

Transportation

Temporary Road Reconstruction Miles 4.01 6

Temporary Road Construction Miles 5.11 6

Road Maintenance/Haul Route Miles 108 6

Road Realignment Miles 1 5, 6

Road Storage Miles 4.07 5

Road Decommissioning Miles 8.88 5

Rock Pit Management Each 10 6

Post-Harvest Planting

Early Seral Planting Acres 43 1

Shelterwood Planting Acres 92 1, 3

Gap Planting Acres 47.8 1, 3

Dominant Tree Release Planting Acres Up to 72.75 1, 3

Key Issues

Fire regenerated stands harvested Acres 767 1, 3, 5, 6

Other 

Subsoiling: Subsoiling would occur in harvest units where needed to keep compaction below Forest Standards and 

Guidelines for high compaction levels Subsoiling would also occur on skid roads located in regeneration 

harvest units and gaps. 

Temporary Road Decommissioning: All temporary roads used in project activities would be decommissioned 

upon completion of activities or connected activities. 

Scarifying Temporary Roads: Soils may be scarified to aid in vegetation establishment. 

Down Wood and Snag: At least 240 lineal feet per acre of decay class I and II material greater than 20” diameter 

and 20 feet in length would be retained within the regeneration harvest units. Where the preferred size of 

material is not available, 240 lineal feet per acre of the next largest trees proposed to be harvested would be 

left. On average 4 snags (or live trees for snag creation) per acre would also be left in the regeneration harvest 

units. 

1

: Post-harvest fuels treatments methods may change depending on feasibility and funding. Post-harvest fuels treatments would 

occur in timber harvest units; therefore the acreage of post-harvest fuels treatments are not included in the total acres of treated 

units.
Hwy 46 Project FEIS Chapter 1 – Purpose and Need

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2

: Mechanical treatment may include: grapple piling in slash concentrations, yarding tops attached, mastication, or any other 

mechanical device). 

3

: These acres are possible underburn acres due to dbh and location, not all acreage may be underburned. Acreage not 

underburned may have other post-harvest fuels treatments assigned before implementation. 

1.4 Forest Plan and Management Direction

This final Environmental Impact Statement (FEIS) is tiered to the following EISs and plans, which are 

incorporated by reference:

The Willamette National Forest Land and Resource Management Plan Environmental Impact Statement, 

as amended (USDA Forest Service 1990; referred to as the “Forest Plan”)

The Northwest Forest Plan and Record of Decision and Standards and Guidelines for Management of 

Habitat for Late-Successional and Old-Growth Related Species with the Range of the Northern

Spotted Owl (USDA Forest Service and USDI Bureau of Land Management 1994a; referred to as the 

“Northwest Forest Plan”)

The Forest Plan as amended by the 2001 Record of Decision and Standards and Guidelines for 

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

and Guidelines (USDA Forest Service and USDI Bureau of Land Management 2001)

The Environmental Impact Statement and Record of Decision for Preventing and Managing Invasive 

Plants (USDA Forest Service 2005)

The Willamette National Forest Road Investment Strategy, Travel Analysis Report (TAR) (USDA Forest 

Service 2015)

The Forest Plan “guides all natural resource management activities and establishes management standards 

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

resource production and management, and the availability and suitability of lands for resources 

management” (Forest Plan, I-1). The Forest Plan provides management direction through the designation 

of specific management areas and standards and guidelines specific to these designations. 

The Forest Plan was amended by the Northwest Forest Plan (1994), which established additional 

management areas, standards, and guidelines associated with Matrix, Riparian Reserves, Adaptive 

Management Areas, and Late-Successional Reserves. When there is overlap of management areas, the 

more restrictive standards and guidelines apply (Northwest Forest Plan 1994a p. A-6). Figure 4 and 5 

illustrate the Forest Plan and Northwest Forest Plan management areas. Table 4 displays Forest Plan 

management areas, Northwest Forest Plan land management areas and proposed action unit acres for the 

proposed action.
Hwy 46 Project FEIS Chapter 1 – Purpose and Need

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Figure 4 Willamette Forest Plan Management Areas in the Hwy 46 Project Area
Hwy 46 Project FEIS Chapter 1 – Purpose and Need

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Figure 5 Northwest Forest Plan Management Areas in the Hwy 46 Project Area
Hwy 46 Project FEIS Chapter 1 – Purpose and Need

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Table 4 Land Management Areas in Project Area and Proposed Treatment Acres (Alternative 2)

Forest Plan

Management Areas (MA)

Northwest Forest Plan

Management Areas (MA)

Acres in 

Project 

Area

Proposed Action Acres

Timber 

Harvest

Non 

Commercial Total

Special Interest Areas (5A) 182 0 0 0 

Old Growth Groves (7) Late Successional Reserve 

(16A) 422 0 0 0

Wildlife Habitat – Pileated 

Woodpecker (9B) <1 0 0 0

Wildlife Habitat – Marten (9C) 168 0 0 0

Dispersed Recreation –

Lakeside Setting (10F) 130 101 0 10

Scenic Modification 

Middleground (11A) Matrix (14) 5353 1150 8 1158

Scenic Modification 

Middleground (11A)

Late Successional Reserve 

(16A)) 215 22 0 22

Scenic Modification 

Middleground (11A)

100-acre Late Successional 

Reserve (16B) 193 0 0 0

Scenic Partial Retention 

Middleground (11C) Matrix (14) 2385 299 0 299

Scenic Partial Retention 

Middleground (11C) Late Successional Reserve (16A) 2790 192 5 197

Scenic Partial Retention 

Middleground (11C)

100-acre Late Successional 

Reserve (16B) 137 0 0 0

Scenic Retention Middleground 

(11D) Late Successional Reserve (16A) 97 0 0 0

Scenic Retention Foreground 

(11F) Matrix (14) 1259 188 52 240

Scenic Retention Foreground 

(11F) Late Successional Reserve (16A) 1872 126 448 174

Developed Recreation – FS Site 

(12A) 45 0 3 3

Developed Recreation – Special 

Use Permits (12B) 7 0 5 5

Developed Recreation – Special 

Use Permits (12B) Late Successional Reserve (16A) 105 0 93 93

Special Use Permit Areas (13A) 335 59 0 59

Special Use Permit Areas (13A) Late Successional Reserve (16A) 65 27 0 27

Administrative Use Site (13B) Late Successional Reserve (16A) 6 0 0 0

General Forest (14A) Matrix (14) 6323 1070 140 1210

General Forest (14A) Late Successional Reserve (16A) 8965 519 44 563
Hwy 46 Project FEIS Chapter 1 – Purpose and Need

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Forest Plan

Management Areas (MA)

Northwest Forest Plan

Management Areas (MA)

Acres in 

Project 

Area

Proposed Action Acres

Timber 

Harvest

Non 

Commercial Total

General Forest (14A) 100-acre Late Successional 

Reserve (16B) 82 0 0 0

Eligible Wild and Scenic Rivers

(6B/6C) 5288 372 132 504

Riparian Areas (15) Riparian Reserves (15) 13502 761 53 814

Critical Habitat 24552 2692 305 2997

Private Land 

(not a management allocation) 159 0 0 0

Total Land Allocations1 31295 3662 398 4,060

1

: Does not include Eligible Wild and Scenic Rivers, Riparian Reserves or Critical Habitat which overlay other allocations.

The following management direction is relevant to management allocations with proposed treatments in 

the project area:

Forest Plan

Scenic – Modification Middleground (11A) areas have an objective to create and maintain desired visual 

characteristics of the forest landscape through time and space. Visually sensitive landscapes would be 

managed for a modest level of scenic quality. This area may also be managed for other resource goals 

including maintenance of wildlife habitats, recreation opportunities, watershed protection, and timber 

production.

Scenic-Partial Retention Middleground (11C) areas have the objective to create and maintain desired 

visual characteristics of the forest landscape through time and space. Visually sensitive landscapes would 

be managed for a moderate level of scenic quality. This area would also be managed for other resource 

goals including timber production, recreation opportunities, watershed protection, and maintenance of 

wildlife habitats.

Scenic-Partial Retention Foreground (11D) areas have an objective to create and maintain desired visual 

characteristics of the forest landscape through time and space. Visually sensitive landscapes would be 

managed for a moderate level of scenic quality. This area may also be managed for other resource goals 

including maintenance of wildlife habitats, recreation opportunities, watershed protection, and timber 

production.

Scenic-Retention Foreground (11F) areas have the objective to create and maintain desired visual 

characteristics of the forest landscape through time and space. Visually sensitive landscapes would be 

managed for a high visual quality. This area may also be managed for other resource goals including 

maintenance of wildlife habitats, recreation opportunities, watershed protection, and timber production.
Hwy 46 Project FEIS Chapter 1 – Purpose and Need

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Developed Recreation Sites (12A) areas have an objective to provide a safe, healthful, aesthetic, nonurban 

atmosphere for the pursuit of natural resource based recreation, and to provide facilities and 

improvements, consistent with resource protection needs and anticipated user demand.

Developed Recreation Special Use Permits (12B) areas have an objective to provide a safe, healthful, 

aesthetic, nonurban atmosphere for the pursuit of natural resource based recreation, and to provide 

facilities and improvements, consistent with resource protection needs and anticipated user demand.

Special Use Permits (13A) areas have an objective to provide safe and efficient sites for permitted 

facilities and improvements to promote public welfare in an environmentally sound manner.

General Forest (14 A) consists of areas outside of other Land Management Allocation categories where 

most of the timber treatments occur to produce an optimum and sustainable yield of timber production 

that is compatible with multiple use objectives.

Eligible Wild and Scenic Rivers (6B/6C) areas have an objective to maintain or enhance the largely 

undeveloped character of the shoreline while maintaining and improving the quality of water entering the 

river. These areas are managed to provide opportunities for a wide range of river oriented recreation 

activities and to maintain or enhance scenic quality. Management will comply with standards for 

Recreation or Scenic rivers as specified in FSH 1909.12. 

Northwest Forest Plan

General Forest-Matrix Lands (14A) consists of areas outside of other Northwest Forest Plan land 

allocation categories where intensive timber management takes place and most of the timber treatments 

occur to produce an optimum and sustainable yield of timber production that is compatible with multiple 

use objectives.

Riparian Reserves (MA 15) are areas where the conservation of aquatic and riparian-dependent, terrestrial 

resources receives primary emphasis. In these areas all streams, wetlands, ponds, lakes, and unstable or 

potentially unstable areas are included and managed for the purpose of protecting the health of the aquatic 

system and its dependent species. 

Late Successional Reserves (MA 16A) are managed to protect and enhance conditions of late-successional 

and old-growth forest ecosystems. The purpose of silvicultural treatments is to benefit the creation and 

maintenance of late-successional forest conditions.

1.6 Tribal Consultation 

Tribal consultation for the Hwy 46 project began in 2011 during the early planning stages of the project 

and included field visits with tribal representatives. On July 15, 2011 the Grand Ronde and Warm Springs 

Tribes participated in a field visit to the project area. Representatives from both tribes have also 

participated in collaborative meetings. The Siletz Tribes consulted independently with field visits and 

meetings. The Detroit Ranger District consulted with the Klamath Tribes, the Confederated Tribes of 

Grand Ronde, the Confederated Tribes of Siletz Indians and the Confederated Tribes of Warm Springs. A 

consultation package and invitation to comment was sent to the Tribes listed above on January 28, 2016. 

No comments were received. 

1.7 Public Involvement Efforts

Public involvement efforts during the development of the FEIS included collaborative meetings, scoping 

letters, field trips, meetings with interested parties and landowners, and publication of the project in the 
Hwy 46 Project FEIS Chapter 1 – Purpose and Need

29

Willamette National Forest Schedule of Proposed Actions and Willamette National Forest website. Below 

is a timeline illustrating public involvement efforts for the Hwy 46 project:

• July 15, 2011: Tribal input field trip into the Hwy 46 planning area.

• July 29, 2011: Breitenbush Community input field trip into the Hwy 46 planning area.

• August 3, 2011: Timber industry input field trip into the Hwy 46 planning area.

• August 15, 2011: Environmental Advocate input field trip into the Hwy 46 planning 

area.

• November 17, 2011: Breitenbush Collaborative begins meeting

• July 1, 2015: Project published in the Willamette National Forest Schedule of Proposed 

Actions

• March 9, 2016: Notice of Intent (NOI) to prepare an EIS published in the Federal 

Register

• March 9, 2016: Scoping letter and background information mailed to members of the 

public, organizations, and state/federal agencies that have expressed interest in receiving 

information on District projects

• May 25, 2016: Public field trip to view and discuss Hwy 46 project at Detroit, Oregon

• October 20, 2017: Notice of Availability (NOA) and initiation of 45-day comment period 

for Draft Environmental Impact Statement (DEIS) published in the Federal Register

• October 20, 2017: Notice of Availability (NOA) and initiation of 45-day comment period 

for DEIS published in the Statesman Journal

Members of the public, organizations, and state and federal agencies were invited to provide comments 

and concerns about the Hwy 46 project during the public scoping comment period from March 10th 

through April 25, 2016. Scoping comments received varied from those that wanted more clarification on 

proposed activities to specific suggestions for project implementation. Scoping comments were used to 

help develop planning issues, alternatives, and effects analysis for the DEIS.

Members of the publics, organization, and state and federal agencies were invited to provide comment on 

the DEIS during the 45-day comment period from October 20th through December 4th, 2017. Twenty two 

letters were received from members of the public, federal officials, public interest organizations, and 

private businesses. Comments received varied from general statements of support or opposition to 

requests for additional analysis. Comments on the DEIS and the corresponding responses are located in 

Appendix I (FEIS). A complete record of all letters, including names and addresses of individuals, 

agencies, and organizations that submitted a letter during the 45-day comment period, is available online 

in the Hwy 46 EIS Public Reading Room at https://cara.ecosystemmanagement.org/Public//ReadingRoom?Project=47109

All correspondence and comments are available in the Project Record at the Detroit Ranger District 

office. 
Hwy 46 Project FEIS Chapter 1 – Purpose and Need

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1.8 Consultation with other Agencies

United States Fish and Wildlife Service (USFWS) and National Marine 

Fisheries Service (NMFS)

Upper Willamette River Chinook Salmon

This analysis found that the Hwy 46 Project “may affect, not likely to adversely affect” Upper Willamette 

spring Chinook salmon. This is due to the potential for “take” as defined in the ESA. Take is prohibited 

by the ESA unless it is authorized by the “fisheries” agencies (National Marine Fisheries Service for 

salmon). In order for the Forest Service to obtain authorization we must conduct consultation with the fish 

agencies under Section 7 of the ESA. Consultation is anticipated to be completed by May 2018. 

Northern Spotted Owl

The Biological Assessment for Willamette Planning Province of Oregon for FY 2018 LAA Projects 

within the Willamette National Forest with a Potential to Modify Habitat and/or Disrupt Northern Spotted 

Owls of LAA Projects with the Potential to Modify the Habitat and/or Disrupt Northern Spotted Owls –

Willamette Planning Province – FY 2016/17 was used to determine effects. A biological assessment was 

submitted August 1, 2017 and a biological opinion was signed August 31, 2017 which includes the Hwy 

46 project. This project would need to be completed prior to a final decision notice being signed for this 

project. The determination expected to be made in the Biological Assessment for the Hwy 46 project, 

which would be completed and concurrence received from the USFWS prior to the final decision notice is 

signed, is this project may affect and is not likely to adversely affect spotted owls by disturbance.

Oregon State Historic Preservation Office

The 1995 Programmatic Agreement (PA) among the USDA Forest Service PNW, the Advisory Council on 

Historic Preservation, and the Oregon State Historic Preservation Officer (SHPO) Regarding Cultural 

Resource Management in the State of Oregon by the USDA Forest Service, (amended in 2004), provides 

a process by which the Forest Heritage Specialist may certify that the Forest has complied with Section 

106 of NHPA for the project. In accordance with this PA, an appropriate inventory was conducted during 

the summers of 2013, 2014, 2015 and 2016. All known cultural sites in the Area of Potential Effect 

(project area) were protected by avoidance, resulting in a determination of “No Historic Properties 

Affected” on December 28, 2016. Documentation was provided by SHPO and copies have been retained 

in the Forest and District Heritage files.

1.9 Issues Derived from Public Comments

A standardized content analysis process was conducted to analyze the letters received during the public 

scoping comment period. Content analysis was designed to extract comments from each letter received, 

evaluate similar comments from different letters, and identify topics or issues of concern. During content 

analysis, the Interdisciplinary Team (IDT), with involvement and approval from the Responsible Official, 

identified issues and separated them into three categories: “key” issues, “other” issues, and “out of scope”

issues.

Key Issues

Key issues represent an unresolved conflict associated with potential environmental effects of the 

proposed action that cannot be resolved simply with mitigation or design features. Key issues are used to 

formulate alternatives and focus the analysis of environmental effects. 
Hwy 46 Project FEIS Chapter 1 – Purpose and Need

31

During the public scoping process, two key issues were identified from comments and questions: 

Key Issue #1: Log truck traffic on the roads into and around the Breitenbush community poses a 

public safety concern. Issue includes public safety (Breitenbush community, bikeway, scenic 

byway, motorcyclists, etc.), and associated dust and noise associated with logging.

Key Issue #2: Harvest treatments should not occur in fire regenerated stands 

In response to Key Issue #1, concern for public safety issues associated with log truck traffic near the 

Breitenbush community, the haul route has been redesigned to require hauling as much as possible over 

FS road 2231 to Highway 22. Units located in the southern part of the planning area that are accessed by 

FS road 2231 will be hauled southeast over Boulder Ridge and down to Highway 22 just west of Idanha. 

This haul route is for both Alternative 2 and Alternative 3.

In response to Key Issue #2, Alternative 3 was developed, which eliminates harvest in fire regenerated

stands. Hazardous fuel and understory treatments would still occur in fire-regenerated stands.

Though two issues are listed above, only one measure of change will be used to compare the alternatives: 

Key Issue Measurement: Acres of fire-regenerated stands harvested

Other Issues and Out of Scope Issues

Other issues are minor issues that do not result in development of alternatives or focus the analysis of 

environmental effects. In most cases, the IDT is able to address these issues by refining the design of a 

project (i.e. dropping a unit from the project) or applying a design feature (i.e. requiring buffers around 

streams). 

Out of Scope issues are those identified as being “out of scope” of this environmental analysis. These 

issues include those that are not or cannot be addressed or solved in this project-level analysis; issues

already decided by law, regulation, or other higher level decisions; issues irrelevant to the decision being 

made; and/or issues that are conjectural or not supported by scientific evidence.

1.10 Decision Framework

The responsible official for this proposal is the District Ranger of the Detroit Ranger District on the 

Willamette National Forest. The District Ranger will review the proposed action, alternatives, and the 

environmental consequences in order to make the following decisions:

• Whether to implement the proposed action or another alternative;

• What specific design features are needed;

• What specific project monitoring requirements are needed to ensure design features are 

implemented and effective; and 

• What if any modifications would be made to the proposed action.

The decision will be based on: 

• How well the selected alternative achieves the project purpose and need; and

• How well the selected alternative responds to analysis issues. 
Hwy 46 Project FEIS Chapter 2 – Alternatives

32

Chapter 2 - Alternatives

This chapter describes and compares the alternatives considered for the Hwy 46 project. It includes a 

description and map of each alternative considered. This chapter also presents the alternatives in comparative 

form, defining the differences between each alternative in order to provide a clear basis for choice by the 

decision maker.

Three alternatives have been analyzed for this project: Alternative 1 - No-Action; Alternative 2 - Proposed 

Action and Alternative 3 - No Harvest in Fire Regenerated Stands.

2.1 Alternative 1 – No Action

Alternative 1- No-Action assesses the current management situation of the affected environment as well as 

the future conditions should an action not be implemented. The No-Action alternative should not be confused 

with a baseline. Whereas a baseline is essentially a description of the affected environment at a fixed point in 

time, the No-Action alternative considers what effects would occur to forest ecosystems and resources in the 

project area if no action is taken.

The purpose and need of the proposed action would not be met under Alternative 1, as no timber harvest or 

fuels treatments would be implemented.

2.2 Alternative 2 – Preferred Alternative

Alternative 2 is the preferred alternative and was developed to fully meet the purpose and need for this 

project. Alternative 2 proposes to treat approximately 4,060 acres in the project area (Figure 6). Harvest 

treatments proposed include thinning, gap creation, dominant tree release, quality early seral creation, sugar 

pine shelterwood harvest, meadow restoration and skips. Harvest treatments would yield approximately 40 

million board feet of timber. Post-harvest fuels treatments would include pile and burn and post-harvest 

underburn. Non-commercial treatments include understory enhancements, riparian treatments, and hazardous 

fuels treatments. Approximately 9.2 miles of temporary road construction and reconstruction would occur 

and approximately 108 miles of existing road would be maintained under Alternative 2. The Short Lake

reroute would connect FS Rd 040 to FS Rd 045 by using Rd 059 (as signed in the field) with a new 

construction of a short section to be approximately 1000 feet in length. Road 059 (as signed in the field) is an 

existing road that is located on a broad flat ridge. Approximately 1 mile of road realignment will occur, 

including the Short Lake road realignment and 0.3 miles of realignment on FS road 2231 to accommodate 

hauling over the Boulder Ridge road to Highway 22.

Table 5 includes a summary of treatments and connected actions proposed under Alternative 2. A detailed 

description of proposed treatments and project activities is included in Appendix A. A detailed list of 

individual unit treatments is listed in Appendix B. 

Table 5 Summary of Proposed Treatments and Connected Actions - Alternative 2

Proposed Activity Unit of 

Measure Alternative 2 Purpose – Need Addressed

Timber Harvest Treatments

Thinning outside Riparian Reserves Acres 1785.45 1,3,4,5,6

Thinning in Riparian Reserves (outside of no 

treatment buffers) Acres 703 1,3,4, 5,6
Hwy 46 Project FEIS Chapter 2 – Alternatives

33

Proposed Activity Unit of 

Measure Alternative 2 Purpose – Need Addressed

Quality Early Seral Creation Acres 43 1,6

Sugar Pine Shelterwood Acres 92 1,2,3,6

Gaps Acres 47.8 1,3,4,6 

Dominant Tree Release Acres 72.75 1,3,5,6 

Skips Acres 910 1,5

Meadow Restoration Acres 8 1,5,6

Total Acres 3662 -

Estimated Volume MMBF ~40

Non-Commercial Treatments

Understory Habitat Enhancements Acres 155 1,2,5

Streamside Treatments (fall and leave) Acres 20 1, 5

Hazardous Fuels Treatment Acres 223 2

Total Non-Commercial Treatments Acres 398

Post-Harvest Fuels Treatments1 in Timber Harvest Units

Pile and Burn (mechanical and/or hand 

treatments )2 Acres 886 2

Post-Harvest Underburn3 Acres 1102 2

Connected Actions

Harvest System

Helicopter Acres 317 6

Skyline Acres 1510 6

Ground Acres 926 6

Transportation

Temporary Roads Reconstruction Miles 4.01 6

Temporary Roads Construction Miles 5.11 6

Road Maintenance/Haul Route Miles 108 6

Road Realignment Miles 1 5, 6

Road Storage Miles 4.07 5

Road Decommissioning Miles 8.88 5

Rock Pit Management Each 10 6
Hwy 46 Project FEIS Chapter 2 – Alternatives

34

Proposed Activity Unit of 

Measure Alternative 2 Purpose – Need Addressed

Post-Harvest Planting

Early Seral Planting Acres 43 1

Shelterwood Planting Acres 92 1,3

Gap Planting Acres 47.8 1,3

Dominant Tree Release Planting Acres Up to 72.25 1,3

Other 

Subsoiling: Subsoiling would occur in harvest units where needed to keep compaction below Forest Standards and 

Guidelines for high compaction levels Subsoiling would also occur on skid roads located in regeneration 

harvest units and gaps. 

Temporary Road Decommissioning: All temporary roads used in project activities would be decommissioned 

upon completion of activities or connected activities. 

Scarifying Temporary Roads: Soils may be scarified to aid in vegetation establishment. 

Down Wood and Snag: At least 240 lineal feet per acre of decay class I and II material greater than 20” diameter 

and 20 feet in length would be retained within the regeneration harvest units. Where the preferred size of 

material is not available, 240 lineal feet per acre of the next largest trees proposed to be harvested would be 

left. On average 4 snags (or live trees for snag creation) per acre would also be left in the regeneration harvest 

units. 

1

: Post-harvest fuels treatments methods may change depending on feasibility and funding. Post-harvest fuels treatments would occur in 

timber harvest units; therefore the acreage of post-harvest fuels treatments are not included in the total acres of treated units. 2

: Mechanical treatment may include: grapple piling in slash concentrations, yarding tops attached, mastication, or any other mechanical 

device). 3

: These acres are possible underburn acres due to dbh and location, not all acreage may be underburned. Acreage not underburned 

may have other post-harvest fuels treatments assigned before implementation. 

Harvest treatments would occur in stands ranging from 26-145 years old. Non-commercial understory habitat 

and hazardous fuels treatments would occur in stands ranging from 20-450 years old. Table 6 provides a 

summary of forest age classes and treatment acres for Alternative 2.
Hwy 46 Project FEIS Chapter 2 – Alternatives

35

Table 6 Summary of Forest Age Classes and Treatment Acres - Alternative 2

<80 years old 80-120 years old >120 years old

Acres of Harvest Units 

(including skips)

2621 773 266

Acres Proposed for 

Harvest 1966 608 210

Non-Commercial 

Treatment Acres

(including skips)

94 8 284
Hwy 46 Project FEIS Chapter 2 – Alternatives

36

Figure 6 Map of Alternative 2
Hwy 46 Project FEIS Chapter 2 – Alternatives

37

2.3 Alternative 3 – No Harvest in Fire Regenerated Stands

During the public scoping process, two key issues were identified from comments and questions: 

Key Issue #1: Log truck traffic on the roads into and around the Breitenbush community poses a 

public safety concern. Issue includes public safety (Breitenbush community, bikeway, scenic byway, 

motorcyclists, etc.), and associated dust and noise associated with logging.

Key Issue #2: Harvest treatments should be restricted to plantations, no harvest in stands over 80 or 

in fire regenerated stands. 

In response to Key Issue #2, Alternative 3 was developed, which commercially harvests in plantations only, 

eliminating harvest in fire-regenerated stands. Therefore, measuring acres of fire-regenerated stands treated 

will encompass the stands over 80 years of age. Understory habitat treatments and hazardous fuels (WUI) 

treatments would still occur in fire-regenerated stands and stands over 80 years of age.

Alternative 3 proposes to treat approximately 3,022 acres in the project area (Figure 7). Harvest treatments 

proposed include thinning, gap creation, dominant tree release, quality early seral creation, sugar pine

shelterwood harvest, and skips. Harvest treatments would yield approximately 24 million board feet of 

timber. Post-harvest fuels treatments would include pile and burn and post-harvest underburn. Noncommercial treatments include understory enhancements, riparian treatments, and hazardous fuels 

treatments. Approximately 6.3 miles of temporary road construction and reconstruction would occur and 

approximately 98 miles of existing road would be maintained under Alternative 3. Approximately 1 mile of 

road realignment will occur, including 0.3 miles of realignment on FS road 2231 to accommodate hauling 

over the Boulder Ridge road to Highway 22. Road decommissioning and road storage miles remain the same.

Because harvest would occur in plantations only under Alternative 3, proposed acres for harvest treatment

decrease by 988 acres from Alternative 2, with harvest acres decreasing by 767 acres. Alternative 3 proposes 

19 fewer acres of gap creation; 11.5 fewer acres of dominant tree release; 616.5 fewer acres of thinning; 221

fewer acres of skips; and 29 fewer acres of regeneration harvest than Alternative 2. Alternative 3 would 

reduce acres of sugar pine restoration to 9 acres. There would be no meadow restoration in Alternative 3. 

Post-harvest fuels treatments would include pile and burn and post-harvest underburn. Non-commercial 

treatments include understory enhancements, riparian treatments, and hazardous fuels treatments.

Table 7 includes a summary of treatments and connected actions proposed under Alternative 3. A detailed 

comparison of Alternative 2 and Alternative 3 is available in Section 2.4 – Comparison of Alternatives. 

Table 7 Summary of Proposed Treatments and Connected Actions - Alternative 3

Proposed Activity Unit of 

Measure Alternative 3 Purpose – Need Addressed

Timber Harvest Treatments

Thinning outside Riparian Reserves Acres 1343.95 1,3,4,5,6

Thinning in Riparian Reserves Acres 528 1,3,4, 5,6

Quality Early Seral Creation Acres 14 1,6

Sugar Pine Shelterwood Acres 9 1,2,3,6

Gaps Acres 28.8 1,3,4,6 

Dominant Tree Release Acres 61.25 1,3,5,6 
Hwy 46 Project FEIS Chapter 2 – Alternatives

38

Proposed Activity Unit of 

Measure Alternative 3 Purpose – Need Addressed

Skips Acres 689 1,5

Meadow Restoration Acres 0

Total Acres 2674 -

Estimated Volume MMBF ~24

Non-Commercial Treatments

Understory Habitat Enhancements Acres 155 1,2,5

Streamside Treatments (fall and leave) Acres 20 1,5

Hazardous Fuels Treatment Acres 193 2

Total Non-Commercial Treatment Acres 368

Post-Harvest Fuels Treatments1 in Timber Harvest Units

Pile and Burn (mechanical and/or hand 

treatments )2 Acres 799 2

Post-Harvest Underburn3 Acres 586 2

Connected Actions

Harvest System

Helicopter Acres 56 6

Skyline Acres 1163 6

Ground Acres 766 6

Transportation

Temporary Roads Reconstruction Miles 3.3 -6

Temporary Roads Construction Miles 3.0 6

Road Maintenance/Haul Route Miles 98 -6

Road Realignment Miles 1 5, 6

Road Decommissioning Miles 4.07 5

Road Storage Miles 8.88 5

Rock Pit Management Each 10 6

Post-Harvest Planting

Early Seral Planting Acres 14 1

Shelterwood Planting Acres 9 1,3

Gap Planting Acres 28.8 1,3
Hwy 46 Project FEIS Chapter 2 – Alternatives

39

Proposed Activity Unit of 

Measure Alternative 3 Purpose – Need Addressed

Dominant Tree Release Planting Acres Up to 61.25 1,3

Key Issues

Fire Regenerated Stands Harvested Acres 0

Other 

Subsoiling: Subsoiling would occur in harvest units where needed to keep compaction below Forest Standards and 

Guidelines for high compaction levels Subsoiling would also occur on skid roads located in regeneration

harvest units and gaps. 

Temporary Road Decommissioning: All temporary roads used in project activities would be decommissioned 

upon completion of activities or connected activities.

Scarifying Temporary Roads: Soils may be scarified to aid in vegetation establishment. 

Down Wood and Snag: At least 240 lineal feet per acre of decay class I and II material greater than 20” diameter 

and 20 feet in length would be retained within the regeneration harvest units. Where the preferred size of 

material is not available, 240 lineal feet per acre of the next largest trees proposed to be harvested would be 

left. On average 4 snags (or live trees for snag creation) per acre would also be left in the regeneration harvest 

units. 

1

: Post-harvest fuels treatments methods may change depending on feasibility and funding. Post-harvest fuels treatments would occur in 

timber harvest units; therefore the acreage of post-harvest fuels treatments are not included in the total acres of treated units. 2

: Mechanical treatment may include: grapple piling in slash concentrations, yarding tops attached, mastication, or any other mechanical 

device). 3

: These acres are possible underburn acres due to dbh and location, not all acreage may be underburned. Acreage not underburned 

may have other post-harvest fuels treatments assigned before implementation. 

Harvest treatments would occur in stands ranging from 26-56 years old. No harvest would occur in stands 

over 57 years old. Non-commercial understory habitat and hazardous fuels treatments would occur in stands 

ranging from 20-450 years old. Table 8 provides a summary of forest age classes and treatment acres for 

Alternative 3.
Hwy 46 Project FEIS Chapter 2 – Alternatives

40

Table 8 Summary of Forest Age Classes and Treatment Acres - Alternative 3

<57 years old 57-120 years old >120 years old

Acres of Harvest Units 

(including skips)

2621 0 0

Acres Proposed for 

Harvest 1966 0 0

Non-Commercial 

Treatment Acres

(including skips)

94 0 308
Hwy 46 Project FEIS Chapter 2 – Alternatives

41

Figure 7 Map of Alternative 3
Hwy 46 Project FEIS Chapter 2 – Alternatives

42

2.4 Alternatives Considered but Eliminated

Alternative that Utilized FS Road 46 as Only Haul Route to Highway 22

The original proposed action included hauling all timber down FS Road 46 to Highway 22. This alternative 

would increase heavy equipment and log truck traffic in the vicinity of Breitenbush Resort and Conference 

Center. Due to public safety and noise concerns during logging and hauling operations, this haul route was 

modified to reduce traffic from operations in the vicinity of private land holdings in the project area, and the 

original haul route not analyzed.

Alternative with More Early Seral Habitat Creation 

In order to meet the purpose and need of moving the watershed seral distribution towards historic levels, 

more acres were considered for early seral habitat creation during planning and project design. The IDT 

developed guidelines for quality early seral habitat creation, and considered slope, exposure, plant 

association and location (limited vehicle access and not in the late successional reserve). If the acres did not 

meet the guidelines, the stand was dropped or thinning prescribed, and those acres were not analyzed for 

early seral creation.

Alternative with No Early Seral Habitat Creation

During public scoping, comments were received asking us to consider an alternative with no early seral 

creation. Because this alternative would not meet the purpose and need of moving the watershed seral 

distribution towards historic levels, it was not further analyzed.

2.5 Comparison of Alternatives

Table 9 summarizes and compares treatments and connected actions that would occur under each alternative. 

Table 9 Comparison of Alternatives

Proposed Activity Unit of 

Measure Alternative 1 Alternative 2 Alternative 3

Timber Harvest Treatments

Thinning outside Riparian Reserves Acres 0 1785.45 1343.95

Thinning in Riparian Reserves Acres 0 703 528

Quality Early Seral Creation Acres 0 43 14

Sugar Pine Shelterwood Acres 0 92 9

Gaps Acres 0 47.8 28.8

Dominant Tree Release Acres 0 72.75 61.25

Skips Acres 0 910 689

Meadow Restoration Acres 0 8 0

Total Acres 0 3662 2674

Estimated Volume MMBF 0 ~40 ~24
Hwy 46 Project FEIS Chapter 2 – Alternatives

43

Proposed Activity Unit of 

Measure Alternative 1 Alternative 2 Alternative 3

Non-commercial treatments

Understory Habitat Enhancements Acres 0 155 155

Streamside treatments Acres 0 20 20

Hazardous Fuels Treatment Acres 0 223 193

Total Acres 0 398 368

Post-Harvest Fuels Treatments1 in Timber Harvest Units

Pile and Burn (mechanical and/or hand 

treatments )2 Acres 0 886 799

Post-Harvest Underburn 3 Acres 0 1102 586

Connected Actions

Harvest System

Helicopter Acres 0 317 56

Skyline Acres 0 1510 1163

Ground Acres 0 926 766

Transportation

Temporary Roads Reconstruction Miles 0 4.01 3.3

Temporary Roads Construction Miles 0 5.11 3

Road Maintenance/Haul Route Miles 0 108 98

Road Realignment Miles 0 1 1

Road Decommissioning Miles 0 8.88 8.88

Road Storage Miles 0 4.07 4.07

Rock Pit Management Each 0 10 10

Post-Harvest Planting

Early Seral Planting Acres 0 43 14

Shelterwood Planting Acres 0 92 9

Gap Planting Acres 0 47.8 28.8

Dominant Tree Release Planting Acres 0 Up to 72.75 Up to 61.25

Key Issues

Fire regenerated stands harvested Acres 0 767 0

1

: Post-harvest fuels treatments methods may change depending on feasibility and funding. Post-harvest fuels treatments would occur 

in timber harvest units; therefore the acreage of post-harvest fuels treatments are not included in the total acres of treated units. 2

: Mechanical treatment may include: grapple piling in slash concentrations, yarding tops attached, mastication, or any other mechanical 

device). 3

: These acres are possible underburn acres due to dbh and location, not all acreage may be underburned. Acreage not underburned 

may have other post-harvest fuels treatments assigned before implementation. 
Hwy 46 Project FEIS Chapter 2 – Alternatives

44

Comparison of Treatments Proposed in Riparian Reserves for Alternative 2 

and 3

The treatments proposed in Riparian Reserves for Alternative 2 and 3 are described and displayed below in 

Tables 11 and 12. All units were surveyed by fisheries, hydrology, wildlife, and botany specialists. Each unit 

was gridded to capture streams, springs, wetlands and other waterbodies that may not be mapped on the GIS 

layer. Based on stream and riparian characteristics, a recommendation was made for no-treatment buffers and 

other potential treatments (e.g., down wood creation) for each waterbody.

Alternatives 2 and 3 propose both active and passive management of Riparian Reserves: thinning, gap 

creation, down wood augmentation, and no treatment (table 10). Within Riparian Reserves, stand-specific 

treatments were prescribed by the Silviculturist in consultation with the District Hydrologist and Fish 

Biologist and are listed in the Design Elements in Table 13. Stand treatments promote variable density within 

and among stands, including Riparian Reserves, by leaving skips, varying thinning intensities, and 

introducing gaps in selected stands (see the Vegetation Report). Within Riparian Reserves, no-treatment 

buffers protect stream shade, bank stability, large wood recruitment and other riparian processes; outside of 

the buffers, treatment in Riparian Reserves are designed to meet or accelerate meeting ACS objectives. Unit 

design elements developed by the interdisciplinary team directed the management action and the protection 

needed to accomplish resource goals. 

Table 10 Riparian Reserve Acres Proposed for Treatment

Activity Riparian Reserve Acres Proposed for Treatment

Alternative 

1

Alternative 2 Alternative 

3

Total Total Over 80 Total

Timber Harvest Treatments 0 708 190 528

Thinning 0 703 187 528

Sugar Pine Restoration 0 0 0 0

Quality Early Seral 0 0 0 0

Meadow Restoration 0 3 3 0

DTR Gaps (1/4-1/2 acre) 0 2 0 0

Non-commercial Treatments 0 73 3 73

Understory Habitat Enhancement 0 4 1 4

Hazardous Fuels Reduction 0 49 2 49

Streamside Treatment 0 20 0 20

Total Treatment 0 781 193 601

No Treatment N/A 677 208 474

Total Riparian Reserves in proposed units N/A 1,458 401 1,075

Total Riparian Reserves in Project Area 13,502

Percent of Riparian Reserve Commercially 

Thinned

0 5.2 1.4 3.9

Percent of Riparian Reserve Treated 0 5.8 1.4 4.4

Total Riparian Reserves in Watershed 27,925

Percent of Riparian Reserve Commercially 

Thinned

0 2.5 0.7 1.9

Percent of Riparian Reserve Treated 0 2.8 0.7 2.1
Hwy 46 Project FEIS Chapter 2 – Alternatives

45

In order to add additional structural complexity, vegetative diversity, and habitat diversity to stands, some of 

the Riparian Reserve stands proposed for thinning also have small gap creation, totaling approximately 2 

acres. These small 1⁄4 acre gaps would increase stand diversity and productivity, enhancing terrestrial habitats 

which are also a component of the ACS objectives (see Wildlife Section and Appendix E). These gaps are 

planned primarily out of the Riparian Reserves but may have portions extending into the outer Riparian 

Reserve beyond the secondary shade zone. Table 11 shows a list of these proposed units. 

Table 11 Proposed Wildlife and DTR Gaps Within Outer Riparian Reserves for Alternatives 2 and 3

Unit

DTR Gaps in Unit Approximate Gap 

Acres in Riparian 

Reserve

Number 

of Gaps Gap Size

320 6 1⁄4 acre 0.3

350 2 1⁄4 acre 0.4

380 4 1⁄4 acre 0.7

400 3 1⁄4 acre 0.3

520 6 1⁄4 acre 0.4

Total 21 1⁄4 acre 2.1

Several streams were identified during field surveys to have a shortage of large woody material within the 

channel or floodplain, lack of riparian diversity, and/or opportunity for hardwood release. Selected streams 

for treatment were chosen for their vegetation characteristics at the stream catchment scale and at the sitespecific scale. The large majority of riparian stands along the entire length of the streams in units 6, 100, 190, 

430, and 520 are dense plantations lacking structural and species diversity. In these five young plantation 

units, fall and leave treatment would occur in approximately 20 to 75% of the units’ no-harvest buffers along 

approximately 3.2 miles of streams to reduce densities, open the canopies, increase growth and vigor of 

remaining trees, and add medium to large wood to forest floor and stream channels (Table 12). These 

treatments will occur with consideration to protecting or enhancing future shade trees and large wood that 

have potential to contribute to conditions in-stream in the long term.
Hwy 46 Project FEIS Chapter 2 – Alternatives

46

Table 12 Proposed Streamside Treatments for Alternatives 2 and 3

Unit Stream Treatment Description Estimated 

Acres

Class 2 

Stream Miles

Class 3-4 

Stream Miles

6 Fox Creek

Fall and leave to 70 TPA density patches 

along the lower Fox Creek downstream 

of tributary confluence.

2.6 0.25 -

100 Leone Creek 

and tributaries

Fall and leave to 70-90 TPA density 

along the entire north side and patchy 

thinning with small gaps on south side of 

the southwest stream channel. Also fall 

and leave along parts of Leone Creek and 

east tributary to Leone in north part of 

units. Tip trees into streams.

7.6 - 1.0

190 Hill Creek

Lightly fall and leave in small hardwood 

release gaps within the 60 foot no-harvest 

buffer treat along Hill Creek.

2.3 0.4 -

430

Class IV 

tributary to 

North Fork 

Breitenbush 

River

Fall and leave trees into stream channel 

as source wood for the North Fork 

Breitenbush River downstream within 50 

feet of the channel to 90 TPA. 

2.2 - 0.2

520

Unnamed 

Class 3 and 4 

streams

Fall and leave to 70-90 TPA within 60 

foot no-harvest buffer on all streams, 

with 3-4 small hardwood release gaps

along the class 3 streams. 

5.5 - 0.8 (class 3)

0.5 (class 4)

Total Estimated Streamside Treatment 20 0.65 2.5
Hwy 46 Project FEIS Chapter 2 – Alternatives

47

2.6 Project Design Elements Common to Alternatives 2 and 3

The design features in Table 13 were developed to reduce the environmental effects of the proposed activities and ensure project activities are 

implemented to comply with standards and guidelines, goals, objectives, conservation strategies and Best Management Practices. 

Table 13 Design Elements Common to Alternatives 2 and 3

Table 13: Design Elements for Action Alternative

Unit # Reason Design Feature Dates

Haul Route

70, 71, 72, 73, 

74, 75, 76, 77, 

78, 100, 110, 

120, 130, 140, 

160, 180, 190, 

200, 220, 240, 

250, 260, 280, 

290, 300, 310, 

320, 340, 350, 

360, 370, 380, 

390, 400

Respond to Key Issue

#1 – Public Safety. 

Reduce the amount of 

log truck traffic in the 

vicinity of the 

Breitenbush Resort 

and Conference 

Center

• Timber will be hauled over the 2231 road to Highway 22 and not down Highway 46.

Silviculture

All Protect legacy trees • Legacy trees should be retained and included in the thinning spacing. If legacy trees are determined to be a 

safety hazard or need to be felled for operational purposes, they shall be felled and left in place. Legacy 

trees are defined as trees left from the previous stands that are typically larger than the remaining trees. In 

this project area legacy trees are defined as all trees >30 inches dbh. 

All Prevent noxious weed 

spread • Keep the edge of gaps and DTRs at least 200 feet from drivable roads and 100 feet from each other.

2001), 2201), 

240-260, 280-

540

LSR assesment 

guidelines • Individual trees exceeding 20 inches dbh shall not be harvested except for the purpose of creating 

openings, providing other habitat structure such as down logs, elimination of a hazard from a standing 

danger tree, or cutting yarding corridors. Where trees larger than 20 inches dbh are cut, they will be left in 

place to contribute toward coarse woody debris.

1) for portion of unit in LSR only.

2001), 2201), 

240-260, 280-

540

LSR assesment 

guidelines • Leave at least 10% of the unit area in un-thinned patches and between 3 and 10% of the unit area in 

dominant tree gaps no larger than 1⁄4 acre each.

All where 

planting occurs

Meet stocking 

requirements identified • Plant to stocking level and species composition identified in the silvicultural prescription.
Hwy 46 Project FEIS Chapter 2 – Alternatives

48

Table 13: Design Elements for Action Alternative

Unit # Reason Design Feature Dates

in National Forest 

Management Act

Fuels

All For Soil Productivity 

(Duff retention and 

ground cover 

standards)

• Retain existing duff percentages in accordance with Forest Plan Standard and Guidelines, See integrated 

prescriptions for unit specifics. Duff retention will be monitored as part of any activity that may affect the soil 

resource, such as spot or pile burning, or broadcast burning.

• Where chipping operations are planned, depth of chips should not exceed 3 inches and should not exceed 

40% ground cover of an area for any given acre. Chipping equipment traffic would be maintained within 

existing roads, trails footprints, or similar areas to minimize compaction.

170, 210, 270 Minimize visual 

impacts of hazardous 

fuels treatments

• Fuels treatments occurring in or adjacent to the Breitenbush and Devils Creek summer homes or 

Breitenbush Resort will require representatives from the district recreation staff, the district archeologist, the 

Breitenbush Summer Home Association, and the Breitenbush Hot Springs Resort to be consulted in the 

design phase of the fuels treatment projects in or adjacent to these areas.

• Additionally, within these units the following elements will be incorporated into treatment specifications:

o All work would be done with hand treatments only, no mechanical treatments would be used

o Areas of shrubs and trees would be retained in “skips” to provide vegetation buffers where 

needed

o Burning would be minimized to the greatest extent possible

7, 11, 80, 150 Reduce impacts to 

recreating public • No fuels treatments will occur in or adjacent to Breitenbush Campground, Cleator Bend Group Camp, Fox 

Creek Group Camp while campgrounds are open in fee status.

April 15 –

September 30

13, 24, 83 Protect threatened, 

endangered, sensitive 

and survey and 

manage plant species

• No burning in buffers prescribed for survey and manage Pseudocyphellaria rainierensis, Chalciporus 

piperatus and Rhizopogon truncatus

All Protect key riparian 

features and integrity • Underburning in Riparian Reserves will occur only during low intensity burning conditions. Ignition will not 

occur in Riparian Reserves but fire will be allowed to back into Riparian Reserve areas. Hand line 

construction in Riparian Reserves must be coordinated with Hydrologist/Fish Biologist if deemed 

necessary. Wet line construction is preferred.

12, 17, 18, 24, 

27, 32, 32a, 33, 

35, 47, 73, 84, 

93, 95, 96, 270, 

430, 450

To avoid disruption of 

nesting spotted owls • Under burning, fuel treatments and slash burning is prohibited. (no spring burning) March 1 – July 

15
Hwy 46 Project FEIS Chapter 2 – Alternatives

49

Table 13: Design Elements for Action Alternative

Unit # Reason Design Feature Dates

270 To avoid disruption of 

nesting spotted owls • All activities including chainsaw use and burning in the east half of stand is prohibited March 1 –

September 30

Wilderness

560

Mitigate sound impacts 

from non-commercial 

units

• Restrict activities to recreation off-season

• Accomplish treatment with non-motorized equipment

• Expedite activities to affect only 1 year

Operate from 

October 15th 

through June 

15th

Noise

All Reduce noise 

disturbance from 

harvest operations

• No harvest operations during weekends including Memorial Day, 4th of July or Labor Day 

Memorial Day 

through Labor 

Day

24, 32, 32a Reduce noise 

disturbance from 

helicopter operations

• Restrict helicopter yarding to off season time period for the Breitenbush Hot Springs Resort. This restriction 

does not apply to other logging activities. 

• No helicopter operations prior to 8 am.

• Encourage the design and location of flight paths to landings that travel away from the Breitenbush Hot 

Springs Resort in order to minimize sound impacts from helicopter logging.

No operations 

from Memorial 

Day to Labor 

Day

27, 28, 30, 42, 

200, 240.

Reduce noise 

disturbance from 

skyline operations

• Restrict logging season to off season time period for the Breitenbush Hot Springs Resort. No skyline 

operations 

from Memorial 

Day through 

Labor Day

Recreation

All Reduce impacts to 

recreating public • Road Management Objectives for traffic to FS Roads 46, 4685, 4696, and 2231, requires weekend and 

holiday haul restrictions between Memorial and Labor Day Weekends. No hauling on Memorial, 4th of July, 

and Labor Day holidays. Notify Public Affairs Office to coordinate public information updates (temporary 

road closures, delays) with two weeks prior notice.

Memorial Day 

to Labor Day

All Reduce impacts to 

recreating public • No weekend helicopter operations Memorial Day through Labor Day weekends Friday 6 pm through 

Monday 8 am. No helicopter operations on Memorial, 4th of July, and Labor Day holidays. 

Memorial Day 

to Labor Day

7, 11, 80, 44, 

150, 170, 210, 

270

Reduce impacts to 

recreating public • No weekend operations from Memorial Day through Labor Day on Friday 6 pm through Sunday. No harvest 

activity on Memorial Day, 4th of July, and Labor Day holidays.

Memorial Day 

to Labor Day

7, 11, 80, 44, 

150, 170, 210, 

270

Reduce impacts to 

recreating public • No operations within a 1⁄4 mile of developed recreation sites, recreation residences, and private resort areas 

between the hours of 10 pm and 8 am to help minimize noise disturbance.
Hwy 46 Project FEIS Chapter 2 – Alternatives

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Table 13: Design Elements for Action Alternative

Unit # Reason Design Feature Dates

All Reduce impacts to 

dispersed site creation 

and expansion

• Prevent off road travel and dispersed site creation. Place natural obstacles such as down wood and rock in 

a natural arrangement to prevent creation of new dispersed sites where they don’t presently exist. Bury 

boulders 1/3 of the way in the ground where possible.

All Reduce impacts to 

dispersed site creation 

and expansion

• Rehabilitate all landings to prevent site from becoming a new dispersed site. Place natural obstacles such 

as down wood and rock in a natural arrangement to prevent creation of new dispersed sites where they 

don’t presently exist. Bury boulders 1/3 of the way in the ground where possible.

All Reduce impacts to 

dispersed site creation 

and expansion

• In units where proposed landings are currently dispersed sites, rehabilitation of sites will be necessary to 

restore site to desired condition for continued use as a dispersed site or return to a naturalized state. 

Consultation with a recreation specialist will be required in the design phase for units in or adjacent to these 

areas. Rehabilitation may include: Placing natural obstacles such as down wood and rock in a natural 

arrangement to prevent expansion of dispersed sites. Burying boulders 1/3 of the way in the ground where 

possible.

All Reduce impacts to 

dispersed site creation 

and expansion

• Purchaser will close temporary roads to traffic and rehabilitate to prevent new off road recreation use. 

Subsoil road surface of temporary roads to prevent new road creation. Place natural obstacles such as 

down wood and rock in a natural arrangement to prevent creation of new dispersed sites where they don’t 

presently exist. Bury boulders 1/3 of the way in the ground where possible.

All Reduce impacts to 

recreating public • No operations on opening weekends of Cascade elk/deer rifle seasons; restriction is limited to the opening 

weekend of each hunt.

510 Reduce impacts to 

recreating public • All logging debris to be completely cleaned up by piling a minimum of 100 feet from existing trailheads. 

Burning of logging debris piles acceptable if trailhead is accessible and public safety is accounted for. Keep 

the trailhead open for use. Keep trail #3366 open Friday-Sunday when logging Unit 510. Notify 

PAO/recreation staff to coordinate public information updates (temporary road and trail closures, delays) 

with two weeks prior notice.

All Reduce impacts to 

recreating public • Commercial hauling on a road open to all vehicles (mixed used, levels 2-5 road), must use a warning sign 

indicating “Trucks” or “Log Haul”, in order to prevent OHV use on roads beyond those signs. Notify Public 

Affairs Office to coordinate public information updates (temporary road closures, delays) with two weeks 

prior notice.

All year

70, 71, 72, 73, 

74, 75, 76, 77, 

78, 100, 110, 

120, 130, 140, 

180, 190, 200, 

220, 240, 250, 

260, 280, 290, 

300, 310, 320, 

330, 340, 350, 

360, 370, 380, 

390, 400

Reduce impacts to 

recreating public • Snow plowing of Road 2231 to haul over Boulder Ridge during the winter is allowed. Attempt to minimize 

the number of seasons impacted by plowing to reduce recreational impacts to the McCoy Motorized Use 

Area.
Hwy 46 Project FEIS Chapter 2 – Alternatives

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Table 13: Design Elements for Action Alternative

Unit # Reason Design Feature Dates

All Reduce impacts to 

recreating public • Inform public of mixed use road closures, due to harvest activity, on Forest Service websites, two weeks 

prior to harvest activity. Notify Public Affairs Office to coordinate public information updates (temporary road 

closures, delays) with two weeks prior notice.

All Reduce impacts to 

recreating public • Post an advance notice of future harvest activity and mixed use road closures, two weeks prior to harvest 

activity at Forest Service designated OHV staging areas. Notify Public Affairs Office to coordinate public 

information updates (temporary road closures, delays) with two weeks prior notice.

Scenic Quality and Eligible Wild and Scenic Rivers

7, 32, 510 Minimize visual 

impacts • A 50 ft. horizontal no-harvest buffer will be maintained on either side of trail segments of Mansfield, Crag, 

South Breitenbush, and South Breitenbush Gorge trails that would overlap with proposed treatment units 

and surrounding tent campsites in the Fox Creek group campground. Markings to delineate this buffer 

would be faced away from the trail. Slash piles and all boundary markers within 100 ft. of trail or trailhead 

would be removed. A recreation specialist and/or landscape architect would be consulted during layout and 

prior to implementation.

6, 16, 18, 21, 

22, 23, 27, 28, 

30, 32, 35, 47, 

69, 180, 200

Minimize visual 

impacts • Gaps would be designed to mimic natural openings (no long, straight edges or sharp angles), and where 

possible, placed adjacent to natural features such as meadows or rock outcrops. Placement of gaps would 

vary so that they wouldn’t be adjacent to one another, linear, or in a grid-like pattern. Gaps, other than 

visual enhancement gaps, would be placed at least 100 ft. from trails.

2, 47, 69 Minimize visual 

impacts • Placement of gaps would be done after consultation with recreation staff and/or landscape architect.

2, 3, 6, 7, 11, 

13, 28, 30, 44, 

80, 150, 170, 

210, 270, 410, 

460, 470, 480, 

490, 510, 520

Minimize visual 

impacts • Stumps to be flush cut to 4” on the high side on all portions of the unit within 100’ of system roads inside the 

1/2 mile Eligible Wild and Scenic River corridor. This activity will occur post sale. 

31, 42, 45, 46, 

64, 69

Minimize visual 

impacts • Stumps to be cut to 4” on the high side within 100’ of system roads. This activity will occur post sale.

• All trees marked within 100 feet of a system road will be marked on the side away from the road. All slash 

piles will be chunked.

2, 3, 6, 7, 11, 

13, 28, 30, 31, 

42, 44, 45, 46, 

64, 69, 80, 150, 

170, 210, 270, 

410, 430, 460, 

470, 480, 490, 

510, 520; all 

portions within 

1⁄4 mile of Wild & 

Minimize visual 

impacts and protect 

values in the Wild and 

Scenic corridor

• Following harvest activities visible landings will be shaped to blend with the landscape and ground cover to 

be reestablished. Preferred slash disposal methods include chip/disperse, chip/remove, truckload remove, 

hand pile/burn.
Hwy 46 Project FEIS Chapter 2 – Alternatives

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Table 13: Design Elements for Action Alternative

Unit # Reason Design Feature Dates

Scenic River 

corridor

Wildlife

55, 57, 58, 60-

64, 89, 92, 420, 

430

Protect peregrine 

falcons from 

disturbance impacts

• All harvest and fuel treatment related activities are restricted January 15 –

July 31

Scorpion, 

Mansfield and 

Switchback

Protect nesting 

peregrine falcons • Rock pit blasting is restricted, crushing is not restricted. January 15 –

July 31

32 & 32a Protect nesting 

peregrine falcons • Helicopter yarding restriction January 15 –

July 31

170, 210 & 270 To avoid disturbance 

to foraging and nesting 

harlequin ducks

• Seasonally restrict all project related activities within 200’ of the Breitenbush River and Devils creek March 15 –

July 15

13 Protect nesting osprey • Restriction of all activities March 1 – July 

31

32, 32a To avoid disruption of 

spotted owl nesting • All harvest related activities including road building, hauling, plowing, chainsaw use, yarding, loading trucks, 

etc. are prohibited

March 1 – July 

15

5 (North and 

East of the 4698 

road, 16a 

(eastern one 

acre), 24, 25, 

26, 27 (western 

2 acres), 35, 64, 

73, 75, 140, 180

To avoid disruption of 

nesting spotted owls • Chainsaw and heavy equipment use are prohibited March 1 – July 

15

12, 24, 32, 32a, 

93, 95, 96, 300, 

310

Prevent disruption of 

spotted owl nesting • Helicopter yarding is prohibited March 1 – July 

15

Scorpion, Unit 

74, Lower 

Skunk, Skunk, 

Dead Lily, 

Switchback, 

Prevent disruption of 

nesting spotted owls • Rock source blasting is prohibited March 1 – July 

15
Hwy 46 Project FEIS Chapter 2 – Alternatives

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Table 13: Design Elements for Action Alternative

Unit # Reason Design Feature Dates

Unit 220 and 

Fox Creek pits

32 Protect spotted owls • Avoid placement of a three acre gap in the Northeastern edge of unit

Botany

24, 83 Protection of 

threatened, 

endangered, sensitive 

and survey and 

manage plant species

• Buffer Pseudocyphellaria rainierensis 100 feet to maintain habitat and microclimate for species persistence. 

Botanist will help with layout to maximize protection of the population.

13, 24 Protection of 

threatened, 

endangered, sensitive 

and survey and 

manage plant species

• Buffer Chalciporus piperatus 100 feet to maintain habitat and microclimate for species persistence. Botanist 

will help with layout to maximize protection of the fruiting body.

83 Protection of 

threatened, 

endangered, sensitive 

and survey and 

manage plant species

• Buffer Rhizopogon truncatus by 50 feet. Botanist will help with layout to maximize protection of the fruiting 

body.

1, 2, 6, 13, 26, 

27, 28, 30, 31, 

44, 45, 62, 64, 

83, 270

Protection of sensitive 

and survey and 

manage plant species

• Avoid surface disturbance to known populations of Peltigera pacifica and Sparassis crispa during harvest 

operations if possible. Botanist will help with layout to provide adequate site management.

44, 62, 64 and 

370 

Control of noxious 

weeds • Pre-Treat knapweed sites along the roads to the project area and sites within units to ensure weed seed 

will not be spread by project activities.

3, 6, 7, 11, 13, 

14, 17, 19, 23, 

25, 26, 27, 28, 

30, 31, 32, 33, 

34, 35, 38, 39, 

40, 42, 45,46, 

47, 48, 50, 51, 

52, 54, 55, 56, 

57, 58, 59, 60, 

61, 62, 63, 64, 

69, 73, 80, 81, 

Control of noxious 

weeds • Contain existing well established weed populations. This includes monitoring and treatment of weedcontaining special habitats, gaps and roads after the timber sale for 5 years 
Hwy 46 Project FEIS Chapter 2 – Alternatives

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Table 13: Design Elements for Action Alternative

Unit # Reason Design Feature Dates

87, 93, 100, 

150, 210, 250, 

260, 450

All Control of noxious 

weeds • Clean all equipment used off roads in project work to avoid bringing seed into the project area. Equipment 

should work in non-weed infested areas first (USFS will provide map).

All Control of noxious 

weeds • Obtain gravel and fill for road construction and reconstruction from a weed-free rock source.

All Prevent weed 

infestation • Seed (with genetically local grasses and shrubs) and mulch all heavily disturbed areas such as landings 

and closed roads with native species.

6, 16, 18, 21-24, 

27, 28, 35, 47, 

69, 180, 190

Control of noxious 

weeds • Seed all exposed mineral soil in gaps with native local forage species to out compete weeds.

5, 19, 21, 22, 

23, 34, 35, 45, 

47, 52, 55, 64, 

69, 73, 74, 75, 

83, 94, 100, 

130, 140, 160, 

170, 190, 200, 

220, 250, 270, 

280, 300, 320, 

410, 440

Maintain wetland 

microclimate • Protect wetland habitats with a 100 foot buffer.

21, 22, 35, 47, 

69, 190

To avoid weed 

encroachment into the 

unique areas.

• Place gaps 200 feet from wetland special habitats

48, 53 Maintain microclimate • Protect mesic meadows with a 100 foot buffer

3, 19, 33, 38, 

42, 51, 54, 83, 

86, 170,180, 

290, 300, 530

Maintain microclimate • Avoid direct impacts to dry special habitats such as rock gardens, dry meadows and talus slopes. Use 

directional felling away from habitats and no road building or skidding through habitats.

110, 490, 510 Maintain microclimate • Protect wetland habitats with a 60 foot buffer

45, 52, 64, 200, 

340

Maintain microclimate • Protect sedge meadows with a 50 foot buffer

220, 270 Maintain microclimate • Protect wetlands and skunk cabbage swamp with a 30 foot buffer
Hwy 46 Project FEIS Chapter 2 – Alternatives

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Table 13: Design Elements for Action Alternative

Unit # Reason Design Feature Dates

All units 

containing 

Special habitats

Protect special 

habitats • Avoiding placement of equipment, landings, skyline corridors, and designated skid roads through special 

habitats including running cables across rocky outcrops.

All Protect special 

habitats • Special habitats discovered during layout will be brought forward for a field review by the IDT. Additional 

buffers may be implemented to protect the resource.

Road 

Decommission 

activities

Protection of 

threatened, 

endangered, sensitive 

and survey and 

manage plant species

• Roads will be surveyed for special status species prior to any ground-disturbing activities.

Road 

Decommission 

activities

Control and prevention 

of noxious weeds • Use clean equipment for any ground disturbing activities such as subsoiling.

• Roads that will be decommissioned or closed with ground disturbing activities will be seeded with native 

grass seed where mineral soil is exposed.

• Monitor decommissioned roads for invasive plants following ground disturbing activities.

Roads

45, 46, 62, 64, 

69, 410, 420, 

430, 440, 450, 

460, 470, 480, 

490, 510, 520, 

530, 540

Minimize erosion and 

sedimentation • Haul routes are not suitable for wet weather haul. Wet weather haul is restricted on 4600012, 014, 016, 

024, 026, 097; 4688099; and the entire 4685 road system.

All Minimize erosion and 

sedimentation • All disturbed sites related to reconstruction and or maintenance such as waste area sites and culvert 

replacements will require erosion control methods

All Minimize erosion and 

sedimentation • Newly installed culverts will meet 100 year flow (Q100) on perennial streams.

All • All work done to or on a road will be consistent with the Road Management Objective for that road

All • Right of Way Authorizations and/or Land Use Agreements with the State of Oregon required to provide 

legal access will be obtained prior to harvest activities.

Soils and Aquatics (Fish and Hydrology) 

All harvest units Protect and enhance 

riparian features • A minimum no harvest riparian buffer of 100 feet on all fish bearing streams.

• A minimum no harvest riparian buffer of 60 feet on both sides of perennial, Class III streams are prescribed 

to minimize sediment delivery to streams and reduce the potential for temperature increases. 
Hwy 46 Project FEIS Chapter 2 – Alternatives

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Table 13: Design Elements for Action Alternative

Unit # Reason Design Feature Dates

• A minimum no harvest riparian buffer of 30 feet on both sides of the intermittent, Class IV streams are

prescribed to minimize sediment delivery to streams. 

• Apply Riparian treatments as prescribed in Appendix G: Riparian Reserves Treatment Detail 

• Buffers are measured out from the trees growing nearest to the stream not from the edge of the water or 

stream bed.

• Actions to be taken during project implementation on unstable (instability) areas surveyed and mapped 

within riparian reserves on units 25, 40, 42, and 53 are prescribed in the Appendix G: Riparian Reserve 

Treatment Detail. The soils scientist is available for assistance during layout.

6, 100, 190, 

430, 520, 32a

Protect and enhance 

riparian features • In streamside treatment and meadow restoration units, no commercial harvest is allowed within the 

minimum 30-60 foot buffers specified above. Trees cut within the no-harvest buffer for restoration purposes 

will be directionally felled and left on site and in the stream channel.

All harvest units Reduce compaction

directly adjacent to 

stream channels

• Ground based equipment is prohibited within 60 feet from all streams.

• Skid roads should be at least 60 feet from the no harvest buffer for all streams (fish-bearing to intermittent), 

except at designated stream crossings. These widths are required unless a change is approved by the 

district hydrologist or district fish biologist.

All harvest units Reduce soil 

compaction and 

displacement

• Soil conditions should be monitored during wet weather season and high precipitation events. The soil 

scientist will be available for consultation if re-routing or restrictions become necessary.

• Site evaluation is recommended during wet weather or high precipitation events using the following: 

a. Operations will be suspended before precipitation results in off-site movement of sediment into drainage 

courses and any trenching, or rutting is detected. 

b. Soil factors such as: 

i. Saturation/high soil moisture levels (ideal operations occurs under dry soils);

ii. Exposure and high levels of standing water/high water table (for example water pooling, etc.)

iii. Potential existence of surface or subsurface sensitive soils (such as clay, clay loam or others applicable 

soil textures).

iv. Existing soil disturbance (expose soils levels)

v. Type of proposed logging system, etc.

Wet weather 

or high 

precipitation 

season

5, 24, 44, 62, 

64, 110, 220, 

470 and 520

Protect water quality 

and reduce damage to 

stream channel

• The number of stream crossings shall be minimized (no greater than 16 total in the project area).

• All stream crossings should be placed perpendicular to stream channels and swales 

• All stream crossings for ground based equipment and new temporary roads will be approved in advance by 

the District Hydrologist (or Fish Biologist). 

• Intermittent and ephemeral stream crossings will require temporary placement of bunk logs and slash to 

minimize damage to channel bed and banks.

• Stream crossing activities (skidding) will be restricted to dry season, when there is no flow or greatly 

reduced flow.
Hwy 46 Project FEIS Chapter 2 – Alternatives

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Table 13: Design Elements for Action Alternative

Unit # Reason Design Feature Dates

62, 64 Protect water quality 

and reduce damage to 

stream channel

• Perennial stream crossings will require temporary culverts and hydrologist approval on design and location 

for crossing equipment to minimize damage to the stream channel and sediment input to the streams.

• Construction and removal of all perennial stream crossings for temporary roads will be restricted to dry 

season, when stream flow is reduced.

All harvest units Protect water quality 

and reduce damage to 

stream channel

• Temporary roads in Riparian Reserves will be minimized: Wherever possible, temporary roads would be 

located on ridge tops, gentle slopes, or would utilize locations previously disturbed by historic logging. 

• Temporary roads that must be located within the Riparian Reserves will be placed well outside of the 

primary shade zone (approximately 60 to 80 feet on each side of streams) and cross perpendicular to the 

stream where necessary.

• All temporary roads in Riparian Reserves will be decommissioned after treatment activities are completed 

following BMP’s and additional design elements.

• Landings will be located outside of Riparian Reserves wherever possible. The number and acreage of 

landings in Riparian Reserve will be minimized by:

a. Restricting landings to existing roadbeds wherever possible 

b. Locating landings an absolute minimum of 100 feet away from any streams

c. Allowing no more than 15 total new landings within Project Area Riparian Reserves. 

• All new landings in Riparian Reserves will be decommissioned after treatment activities are completed 

following BMP’s and additional design elements.

All harvest units Protect water quality 

and reduce damage to 

stream channel

• Pre-bunched log piles should be at least 60 feet from ephemeral swales and all stream channels. Any 

crossings with feller-bunchers should be perpendicular to ephemeral swales and channels.

All harvest units 

and associated 

access.

Minimize erosion and 

sedimentation • Construction or maintenance of roads will not be done when soils are saturated or run-off occurs. A stable 

fill would be constructed across all streams when crossed by new temporary roads.

• Unclassified or temporary roads used outside the standard operating season should generally be rocked, 

snow covered, or frozen to reduce the potential for erosion, unless other mitigating or extenuating 

circumstances are present.

• The reopening of temporary or unclassified roads should occur in the dry season (May through October) to 

avoid surface erosion from exposed soil. Open roads should be storm proofed if they have to sit through 

extended periods of wet weather. Wet weather management will be followed upon consultation with Forest 

Service personnel.

Winter/wet 

season

All harvest units 

and associated 

access

Minimize erosion and 

sedimentation • All non-paved roads used for wet weather haul will have at least 4 inches of aggregate material, with 

minimum size determined by road slope and proximity to streams.
Hwy 46 Project FEIS Chapter 2 – Alternatives

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Table 13: Design Elements for Action Alternative

Unit # Reason Design Feature Dates

All harvest units 

and associated 

access.

Minimize erosion and 

sedimentation • Native surfaced roads are restricted from hauling when soils are saturated or run-off occurs.

All harvest units 

and associated 

access

Minimize erosion and 

sedimentation • Wet weather haul is only permitted on roads pre-designated for wet weather haul. 

• On all wet weather haul routes, additional cross-drains leading off onto the forest floor will be constructed 

within 100 feet above stream crossings to minimize direct delivery of road sediments to streams.

• Wet weather haul will be monitored by the Timber Sale Administrator, with input from Engineers, Fisheries 

Biologist, Soil Scientist, and/or Hydrologist. When necessary, haul may be suspended during rainfall to 

prevent off-site movement of sediment into stream courses.

• Haul may also occur when the road surface is either covered with a relatively continuous snow pack of at 

least 2”or is frozen, and forecasts indicate that rapid warming and thawing is not likely.

• Dust abatement of road surfaces would be used if roads become excessively dusty during the summer. 

Pump chance locations must be approved by hydrologist or fish biologist. Pump chance locations on fish 

bearing stream must include fish screens or bypass on intakes.

Winter/wet 

season

All harvest units Ensure sufficient water 

flow in streams • Water sources used by project operations will be reconstructed or maintained as necessary to protect 

stream bank stability, riparian vegetation, and water quality. Water used for fire treatments and dust 

abatement will be drafted from various water sources outside of Listed Fish Habitat. At all drafting locations, 

90% of stream flow will be maintained to reduce risk to aquatic species and water quality and pump intakes 

will be screened to prevent aquatic organism entrapment.

All harvest units 

and associated 

access

Minimize erosion and 

sedimentation • Culvert replacements will be done during periods of no/reduced-flow for streams (intermittent and 

perennial) and during the instream work season (June 1st – August 31st).

• Culvert replacements on perennial or live streams will require additional erosion control measures, 

including flow bypass (drop channels) and channel dewatering.

June 1 –

August 31 

work window

All harvest units Reduce off-site 

movement of sediment 

into drainage courses. 

To decrease soil 

displacement and 

compaction.

• Ground based equipment operations over snow/frozen soil may occur in the following conditions:

o 0 inches of frozen soil−Need at least 18 inches of settled (packed) snow 

o 4 inches of frozen soil−Need at least 9 inches of settled (packed) snow 

o 6 inches of frozen soil−No snow cover necessary

If necessary, pre-pack snow on designated routes before work commences. 

• Over snow operations will be suspended or re-routed if thawing, soil exposure or uneven snow pack 

occurs.

All skyline 

harvest units

Minimize impacts to 

stream channels • Skyline yarding is not allowed through the buffers on Class 1 streams. Require full or one-end suspension 

when yarding in the remaining (outer) portion of the Riparian Reserve.
Hwy 46 Project FEIS Chapter 2 – Alternatives

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Table 13: Design Elements for Action Alternative

Unit # Reason Design Feature Dates

• Full suspension a minimum of 60 feet from the stream channel edge would be required when yarding over 

Class 2 and Class 3 (perennial) streams. Require full or one-end suspension when yarding in the remaining 

(outer) portion of the Riparian Reserve.

• Full suspension a minimum of 30 feet from the stream channel edge would be required when yarding over 

Class 4 intermittent streams. Full suspension limits will be extended to match no-harvest or no equipment 

buffers where they are set due to concerns regarding stability. Require full or one-end suspension when 

yarding in the remaining (outer) portion of the Riparian Reserve.

All harvest units Minimize impacts to 

stream channels. • Where cable yarding requires corridors through a riparian area, corridors will be laid out to minimize the 

number of trees cut. Trees located within no-harvest buffers that must be cut to facilitate yarding corridors 

will be felled towards the channel (if feasible) and left on site.

All harvest units Provide adequate 

drainage and avoid 

unnecessary soil 

disturbance

• All skid trails and landings should be water-barred to provide adequate drainage. Water bar location shall 

occur where local terrain facilitates effective drainage of the skid trail or landing while avoiding unnecessary 

soil disturbance. An example would be to construct water bars every 100 feet on slopes less than 15%, and 

every 50 feet on slopes greater than 15%. Water bars should be keyed-in to the cut bank and have a clear 

outlet on the downhill side. In lieu of water bars, where available in concentrations, slash can be scattered 

on corridors, skid trails and landings.

All harvest units Minimize compaction

and disturbance levels 

and for soil productivity 

(ground cover and 

nutrient loss 

maintenance); during 

project implementation

• Ground based equipment should generally operate in the dry season, May through October, unless 

otherwise restricted by other resource concerns or waived by Forest Service personnel, based on site 

specific conditions (mentioned above) and the objective to reduce soil disturbance as stated in previous 

design features. 

• Existing skid and haul roads should be used before new skid road locations are approved. They should not 

usually exceed 15 feet in width, and the objective is to maintain a 10 to 12 foot width throughout the length. 

• Where practical the skidder, cat, shovel or forwarder should travel on slash Skid roads will generally be 100 

to 200 feet apart with conventional line pulling operations, and 40 to 60 feet apart with processor / forwarder 

operations.

• Ground based equipment is limited to slopes less than 30%. Ground based equipment may be allowed on 

slopes greater than 30% but less than 40% in a few selected instances where it is determined that yarding 

on these steeper slopes is more beneficial to the various resources than implementing some other logging 

system. Determining factors will include a site specific evaluation in the field by Forest Service personnel, 

the operational period and current (and expected) weather conditions, and the ability of the operator / 

contractor to implement the work successfully and safely.

• Partial or one end suspension is required on skyline units, except at tail trees and landings. Given the 

irregular topography in some units, sections of ground lead may occur along some skyline roads. Generally 

this is acceptable, but approval usually requires a site specific, on-the-ground review of the area by Forest 

Service personnel.

• Where operable, harvested trees should be topped and limbed in the units in order to provide small limbs 

and needles for nutrient recycling (upon fuels, timber specialist and soil scientist consultation).

• Avoid disturbance to the existing large down woody debris concentrations created by the initial entry in the 

managed stands as much as practical.
Hwy 46 Project FEIS Chapter 2 – Alternatives

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Table 13: Design Elements for Action Alternative

Unit # Reason Design Feature Dates

380 To protect shallow 

groundwater and 

subsurface streams

• Several streams go subsurface mid-way down the unit, indicating shallow groundwater. Restrict equipment 

use in lower part of unit. Consult with hydrologist during layout of skyline corridors.

All harvest units 

and associated 

access. 

Reestablish hydrologic 

and geologic 

processes

• All temporary roads will be made hydrologically stable and decommissioned after completion of project 

activities. Decommissioning of temporary roads may include: blocking the entrance, removal of culverts, 

out-sloping the road surface, pulling back displaced material onto the road way, installation of water bars, 

re-vegetation of the road prism, and/or the sub soiling of compacted surfaces when necessary.

Road 

Decommission 

activities

• Soil scientist will be consulted for assessment of instability risks and to develop an effective instability 

restoration plan for all roads being decommissioned.

All harvest units Protect key riparian 

features and integrity • All existing down wood will be retained within Riparian Reserves to maintain aquatic objectives

Rock Pits Reduce erosion and 

sedimentation, protect 

water quality

• Any expansion beyond existing boundaries or reclamation of rock pits will require development of a Pit Plan 

and analysis.

70, 140, 190 and 

250

Reduce compaction

levels and improve 

overall productivity.

• Mitigation subsoiling to a depth of 18 to 24 inches is required by the Purchaser / Logger, who would subsoil 

primary skid roads, landings or temporary haul roads used in the logging operations.

8, 9, 10, 17, 23, 

31, 35, 56, 57, 

58, 59, 61, 63, 

70, 73, 74, 78, 

140A, 150, 180, 

220, 450 and 520

the highest 

priorities are 

Units 35, 63, 73, 

180 and 520

Reduce compaction

levels and improve 

overall productivity.

• Enhancement subsoiling to decompact the soil surface to a minimum depth of 20 inches to a maximum of 

24 inches at the completion of logging activities (Purchaser end of operation or post sale) on old skid roads 

and landings from this or previous entries. 

• Subsoiling should be done using the munching or roughening technique (excavator and attachments). 

Mulching, seeding and slashing (re-applying the stored slash) the area upon decompaction is strongly 

recommended to improved infiltration and soil productivity within the disturbed area.

1, 2, 3, 5, 7, 12, 

13, 14, 20, 25, 

27, 29, 32, 34, 

38, 40, 42, 49, 

50, 52, 53, 61, 

65, 66, 68, 69, 

72, 79, 82, 83, 

86, 87, 88, 93, 

94, 95, 96, 97, 

290, 300, 310, 

320, 330, 350, 

Protect soil resources • No prebunching allowed.
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Table 13: Design Elements for Action Alternative

Unit # Reason Design Feature Dates

380, 390, 400, 

480, 490, 530, 

Cultural

All Protect cultural 

resources • There are 14 cultural sites (06180400008, 06180400011, 06180400114, 06180400224, 06180400317, 

06180400328, 06180400441, 06180400586, 06180401056, 06180401059, 06180401103, 06180401105, 

06180401122, 06180401130) within the Hwy 46 Project that are considered eligible or potentially eligible 

for inclusion in the National Register of Historic Places (NRHP) and must be protected from project 

activities or evaluated to determine eligibility to the NRHP. Presale, Timber Sale Administrator and Fire 

Management must work closely with the Archaeologist to insure these sites are protected for the full term of 

the Timber Sale Contract. The Zone Archaeologist will layout the protection buffer.

All Protect cultural 

resources • Changes to the current unit configurations and/or the addition of any new units, will require consultation 

with the Zone Archaeologist in order to protect the known and unknown heritage resources.

All Protect cultural 

resources • Project activities planned outside of the area as defined in the heritage resource inventory schema must be 

coordinated with the district archaeologist prior to initiation. This includes the establishment of additional 

harvest landings, helicopter landings, guy-line equipment anchors, slash burning and the removal of 

roadside danger trees. New road construction (including temporary roads) should avoid ridgetops.

All Protect cultural 

resources • Post-harvest subsoiling of any skid or spur road located in high probability ground for the occurrence of 

cultural resource must be coordinated with the zone Archaeologist. This could require a cultural resource 

survey prior to subsoiling.

All Protect cultural 

resources • Although no other surface or subsurface evidence of cultural resources was found in the proposed project 

area, the possibility remains that more prehistoric or historic cultural resources are present and could be 

exposed/uncovered during project activities. If cultural resources are encountered during the course of this 

project, earth-disturbing activities in the vicinity of the find should be suspended, in accordance with federal 

regulations, and the zone archaeologist notified to evaluate the discovery and recommend subsequent 

courses of action. Therefore, contract provision BT6.24 must be included in all project prospecti and 

contracts. The contract provision outlines the procedures to follow in the event heritage resources are 

discovered during the life of the timber sale.
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2.7 Mitigation and Enhancement Common to Alternatives 2 and 3

Table 14 Snag and Down Wood Recommendations Common to Alternatives 2 and 3

Unit Acres Snag 

creation

Trees left for 

future snag 

creation

Down wood 

creation

Total leave 

trees for snags

and down wood

6 3 5 5 9 19

14 13 20 23 39 82

16 3 5 5 9 19

17 16 24 29 48 101

18 2 3 4 6 13

21 3 5 5 9 19

22 3 5 5 9 19

23 3 5 5 9 19

24 1.5 3 3 5 11

28 3 5 5 9 19

32 3 5 5 9 19

35 6 9 11 18 38

47 7 11 13 21 45

59 4 6 8 12 26

63 12 18 22 36 76

180 6 9 11 18 38

200 3 5 5 9 19

Snags would be created after harvest and slash treatment in gaps and early seral habitat treatments areas at 

the rate of 1.5 per acre in units 6, 23, 35, 47, 59, 63, 180 and 200. Techniques may include topping, 

girdling and/or inoculation. 

Down wood would be created after harvest and slash treatment in gaps over 1 acre and early seral habitat

treatment areas at the rate of 3 trees felled per acre of the largest available in units 6, 14, 16-18, 21- 24, 

28, 32, 35, 47, 59, 63, 180 and 200. The minimum amount to be left is 240 lineal feet/acre.

Table 15 Survey and Manage Species Buffer Recommendations Common to Alternatives 2 and 3

Units Sensitive Species Buffer Distance

24, 83 Pseudocyphellaria rainierensis 100 ft.

13, 24 Chalciporus piperatus 100 ft.

83 Rhizopogon truncatus 50 ft.

Table 16 Special Habitat Buffer Mitigation Recommendations Common to Alternatives 2 and 3
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Units Special Habitat Buffer Distance*

220, 270 wetlands and skunk cabbage 

swamp

30 ft.

5,19,21,22,23, 34, 35,45,47,52, 

55,64,69,73,74,75,83,94,100, 110,130, 

140,160,170, 190,200,220, 250, 270, 

280, 300,320, 410, 440,490,510

wetland 100 ft.

110, 490 wetland 60 ft.

48, 53 mesic meadow 100 ft.

45,52,64,200, 340 sedge meadow 50 ft.

No-disturbance buffer distance is based on Special Habitat Management Guide. Buffers would be expanded if Aquatic Resource 

Specialists deems them insufficient to maintain hydrologic function.

2.8 Monitoring Common to Alternatives 2 and 3

Operations: Contract administrators would monitor treatments during implementation to ensure 

contractors are in compliance with their contract. Contract elements monitored would include harvest 

specifications, bole damage to residual trees, down wood and snag retention, skid trail spacing and use of 

designated skid trails. 

Fuels Treatments: Santiam River Zone fire and fuels personnel would monitor fuel loading prior to and 

post application of fuels treatments. Fuels treatment results would offer data to use in the future.

Road Management: Detroit Ranger district engineering personnel would monitor road management 

through contract administration and routine road maintenance inspections.

National Aquatic Best Management Practice Monitoring: The National Best Management Practices 

Program provides a standard set of core best management practices and consistent documentation of the 

use and effectiveness of the practices. Post-implementation best management practices monitoring may 

include review of aquatic management zones, erosion prevention and control measures, cable and ground 

based yarding operation effects, and site treatment.

Forest Plan Implementation Monitoring: The Forest Supervisor’s Staff performs annual project 

monitoring at each Ranger District and compiles the results in the yearly Forest Monitoring Report. 

Implementation of treatments from this project would be subject to Forest Plan Implementation 

monitoring. Other implementation monitoring elements may include temporary road decommissioning, 

snag and large down wood abundance, and any seeding or planting of vegetation.

Reforestation: Ensure stand is sufficiently stocked within five years. Forest Service Manual directs us to 

conduct first and third year stocking surveys to determine if the site can be certified.

Dead Wood Habitat Monitoring: Detroit Ranger District wildlife personnel would monitor snag and 

large down wood habitat levels in units prior to wildlife tree and down wood enhancement activities and 

after prescribed burning, if applicable. This would determine existing habitat levels and compare those 

with the amounts needed for mitigation and enhancement activities. Monitoring may also be conducted 

after underburning to evaluate the level of tree mortality and snag creation from fire. 
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Invasives Monitoring: Detroit Ranger District botany personnel will monitor spread of existing weed 

populations in timber sale units and along roads leading into the project area for 5 years post-treatment. 

Populations of invasives will be treated as they are detected.
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Chapter 3 - Affected Environment and Environmental 

Consequences

This section of the FEIS considers the environmental consequences of implementation of the various 

alternatives. The following discussion of effects follows CEQ guidance for scope (40 CFR 1508.25(c)) by 

categorizing the effects as direct, indirect, and cumulative. The focus is on cause and consequences. For 

this analysis, in general, direct and indirect effects have been discussed in the context that most readers 

are accustomed to: those consequences which are caused by the action and either occur at the same time 

and place, or are later in time or farther removed in distance but are still reasonably foreseeable (40 CFR 

1508.8). Cumulative effects are discussed where there is an effect to the environment which results from 

the incremental effect of the action when added to other past, present, or reasonably foreseeable future 

actions (40 CFR 1508.7). Effects from the 2017 fires are discussed where there is an effect to the 

environment from the fires.

The analysis of direct, indirect, and cumulative effects on each resource includes defined analysis area 

boundaries, as well as the length of time effects are expected to last. These are specific to each resource 

and therefore may vary in physical and temporal scale.

Interdisciplinary Team

The interdisciplinary team (IDT) includes Forest specialists for each discipline (Chapter 4, for team 

members and their qualifications). Specialists on the IDT prepared technical reports to address the 

affected environment and expected environmental consequences of the proposed action and alternatives 

of the Hwy 46 project. All reports are maintained in the project file, located at the Detroit Ranger District 

in Detroit, Oregon. In some cases, this chapter provides a summary of the report and may only reference 

technical data upon which conclusions were based. When deemed appropriate, those parts of specialist 

reports that are not included in this FEIS are incorporated by reference (40 CFR 1502.41).

Role of Science

Science information improves the ability to estimate consequences and risks of decision alternatives. The 

effects of each alternative are predicted based on science literature and the professional experience of the 

IDT specialists. The conclusions of the IDT specialists are based on the best available science and current 

understanding. Relevant and available scientific information is incorporated by reference and a complete 

bibliography is included at the end of this FEIS. Referenced material is a consideration of the best 

available science.

Cumulative Effects

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 
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final analysis documents an agency assessment of the cumulative effects 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)

Appendix D provides a summary of past, present, and reasonably foreseeable activities in the project area 

that could contribute potential cumulative effects to the environment along with the Hwy 46 project.

2017 Fires

During the summer of 2017 three large fires burned within the project area effecting several units. These 

fires were typical of the western cascades mixed severity fire regime and had a range of effects on the 

landscape. 

The 695 acre Scorpion Fire had the largest effect on units within the project area, burning through most of 

units 13, 16, and 83 as well as parts of units 12, 25, 95, and 96. While this fire was generally moderate in 

intensity with the fire primarily underburning through stands and consuming ground fuels and patches of 

shrubs and small trees, it did include some areas of high mortality that created openings in the canopy and 

early seral habitat conditions. It is anticipated that additional mortality may occur over the next year or 

two in trees that were damaged or overly stressed from the fire. 

The Little Devils Fire burned 2,161 acres within the planning area and was also a mixed severity fire, 

underburning in places but also creating some areas of high mortality that will provide future early seral 

habitat. Although this fire primarily burned adjacent to units planned for timber management activities, 

approximately 3 acres of unit 360 was effected by the fire. 

The Whitewater Fire burned 11,493 acres but only 65 acres burned within the project area. No units were 

affected by this fire.

To assess the immediate impacts to these units, ground reconnaissance was conducted by the District 

Silviculturist in the fall of 2017, as soon as fire behavior abated enough to permit entry into the area. 

Satellite data was later collected and processed with RAVG software to assess fire severity through 

spectral analysis of the ground and canopy vegetation mortality. Combining field observations and RAVG 

data, the Silviculturist projected that areas identified as “moderate” and “high” severity have or will result 

in early seral habitat based on the extent of tree mortality. These higher mortality areas total 521 acres 

within the project area. Other areas identified as “unchanged” or “low” severity will also have some 

mortality, but it will likely be confined to smaller understory trees or small pockets of overstory less than 

an acre in size.
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Figure 8 Location of 2017 Fires within Project area
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3.1 Forest Vegetation

3.1.1 Summary of Effects Analysis

Alternative 1, the no action alternative, would have no direct effect. Indirectly, high stand stocking density 

and canopy covers would continue to restrict regeneration and slow tree growth. Sugar pine presence 

would decline on the landscape as would early seral habitat.

The implementation of Alternative 2 would reduce inter-tree competition within the thinned portions of 

the stand. This would increase vigor, allowing the remaining trees to grow in diameter at a faster rate than 

without thinning. Tree crowns would grow to become larger in diameter and deeper in height. Vegetation 

and advanced regeneration on the forest floor would also benefit. Shrubs such as vine maple, 

rhododendron, and big huckleberry would increase in density and height. Shade tolerant tree species such 

as western hemlock and western redcedar would be released to grow further into the mid and overstory. 

Skips, clumps, and the creation of dominant tree release gaps would add to the structural heterogeneity of 

the stands as well as increase species diversity. Quality early seral units along with one to three acre 

wildlife gaps would increase the amount of grass-forb stage habitat within the project area. A wide variety 

of species would benefit, including deer, elk, songbirds, and numerous pollinators. The existing sugar 

pine population in the project area would benefit from reduced competition was well as the establishment 

of a new rust resistant cohort, ensuring the continued presence of the species. Two meadows would be 

restored or enhanced, promoting both wet site plants and early seral obligate species. Wood products 

made available to local mills would amount to approximately 40 million board feet of volume. This 

would provide or sustain logging and mill jobs in the North Santiam canyon as well as support local 

businesses in Detroit.

Alternative 3 would be similar to Alternative 2 in the plantations, but older fire regenerated stands would 

not be treated. This would reduce the commercial thinning acres by approximately 25%, reduce early 

seral habitat acres by approximately 65%, reduce sugar pine treatment acres by approximately 90%, and 

reduce timber volume supplied to the local economy by approximately 40%.

3.1.2 Scale of Analysis

The scale used to evaluate direct, indirect and cumulative effects on forest vegetation associated with the 

Hwy 46 project is the project area. The project area consists of 31,295 acres within the Breitenbush 5th 

field watershed. By using the project area, it is possible to evaluate potential impacts in an area large 

enough to encompass other disturbances, both human and natural, and it is a logical analysis area to 

assess stand conditions based on plant associations.

3.1.3 Affected Environment

Location

The Hwy 46 project area is located approximately 6 miles northeast of the town of Detroit, Oregon, in 

Marion County. The legal description of the area is T 9 S, R 6 E, sections 1, 11 – 15, 21 – 28, 35 and 36, 

T 9 S, R 7 E, sections 3 – 36, T 9 S, R 8 E, sections 7, 18, 19, 30 and 31, T 10 S, R7 E, sections 1 – 6 and 

8 – 12, T 10 S, R 8 E, section 6.
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Figure 9 Project Area and Breitenbush 5th Field Watershed

Landscape Conditions – Breitenbush Watershed

The project area is within the 69,461 acre North Fork Breitenbush River fifth field watershed. Of this, 

61,428 acres (88%) are on the Detroit Ranger District. The District portion of the Breitenbush Watershed 

has 14,872 acres (24%) LSR, and 10,872 acres (18%) Wilderness.

The Breitenbush Watershed Analysis indicates that the historical distribution of seral stages (preEuropean) were as follows:

Table 17 Historic Seral Stage Distribution Breitenbush Watershed

Seral Stage Percentage of area.

Early, post-disturbance 9.0%

Mid-seral, closed canopy 17.0%

Mid-seral, open canopy 5.2%

Late seral, open canopy 8.4%

Late seral, closed canopy 60.4%

Total 100.0%
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Analysis by Lisa Helmig (Forest Silviculturist,Willamette N.F.), and Jane Kertis (Ecologist, Willamette 

N.F.) in 2013, indicated that the seral stages in the Breitenbush Watershed were distributed as follows :

Table 18 Current Seral Stage Distribution Breitenbush Watershed

Seral Stage Percentage of area.

Early, post-disturbance 4%

Mid-seral, closed canopy 29%

Mid-seral, open canopy 8%

Late seral, open canopy 11%

Late seral, closed canopy 48%

Total 100%

Data from GNN. Combined potential veg group, qmd of tallest 25 trees and canopy cover into coarse seral stages.

Landscape Conditions – Hwy 46 Project Area

Stand replacing disturbance has been at work in this area for thousands of years. Historically, large scale 

disturbances have been from infrequent, high intensity fires. Stand ages from the Vegetation Events 

Geographic Information System (VEGIS) GIS layer indicate that fires burned large portions of the 31,295 

acre project area between 1600 and 1800. Approximately 40% of the stands within the project area were 

initiated during this time. Another round of fires burned portions of the landscape around the turn of the 

twentieth century, particularly in the northern part of the project area, with approximately 21% of the area 

in this age class. Although commercial logging started in the watershed shortly after that, it did not ramp 

up until the 1960s with even-aged management. Since the mid-1990s, there has been virtually no stand 

replacing disturbance. In 2017, while the draft of this document was being finalized and published, the 

Willamette National Forest experienced its worst fire season in decades with over 70,000 acres burned. 

The Detroit Ranger District had over 14,000 acres burn at various intensities during the season, 

2,921acres of which was within the Hwy 46 Project Area. It is estimated that 521 acres of early seral 

habitat was created. See 2017 Fire Effects later in this section for more details.
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Figure 10 Stand Age Distribution in the Hwy 46 Project Area

Table 19 Stand Replacing Disturbance

Time Period Primary Disturbance Acres % of Project

Prior 1600 Fire 1,914 6%

1600-1800 Fire 12,436 40%

1800-1916 Fire 6,700 21%

1917-1959 Fire/Timber harvest 790 3%

1960-1996 Timber harvest 9,392 30%

1997- present Timber harvest 20 < 0.1%

No data 43

Totals 31,295 100

Stand Conditions

The stands proposed for management with this project fall under three general categories: plantations, fire 

regenerated Douglas-fir/hemlock stands, and fire regenerated Douglas-fir/noble fir stands. Plantations are 

the result of past clear-cut harvesting, broadcast burning, planting of Douglas-fir, fertilizing, pre-
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commercial thinning, and sometimes pruning. Fire regenerated Douglas-fir/hemlock stands are the result 

of intense wildfires in the late 1800s which seeded in naturally. Fire regenerated Douglas-fir/noble fir 

stands are high elevation and variable in age.

Table 20 Alternative 2 and 3 Units by Category

Category Unit Numbers Total Acres

Plantation 1-3, 5-7, 11, 19, 20, 23, 26, 30, 33-35, 38, 42, 44-49, 51-53, 55-64, 69-78, 

80, 100-140a, 160, 180-200, 220, 240-490, 510-540, 560, 570

2,690

Fire regenerated 12, 13, 14, 16, 17, 18, 21, 22, 24, 27, 28, 29, 31, 32, 32a, 39, 40, 41, 50, 54, 

81-84, 87, 89, 92, 94-97, 150, 210

1,347

Table 21 Stand Range of Conditions

Category Stand Age Overstory avg. 

diameter

Overstory trees 

per acre

Overstory 

canopy cover

Plantations 20 - 56 9.5 - 18.2” 105 - 397 60 - 95%

Fire regenerated 93 - 145 12.1 - 27.2” 86 - 293 40 - 95%

Plantations are generally characterized by dense monocultures of Douglas-fir. On southern aspects these 

plantations have very little understory regeneration and varying amounts of vegetation. Some of the more 

northerly aspects tend to have more naturally occurring regeneration underneath them, composed 

primarily of western hemlock with smaller amounts of western redcedar, grand fir, and pacific yew. 

Competition is high with mortality occurring in many of the stands. Crown ratios are small, leading to 

reduced diameter growth. Although fairly well established on some of the northerly slopes, regeneration 

is suppressed by the overstory and growing slowly.

Fire regenerated stands are older than the plantations in this project, and tend to have larger trees. Species 

composition in the overstory varies for pure Douglas-fir to mixed Douglas-fir with noble fir, western 

white pine, western hemlock, western redcedar, pacific silver fir, and sugar pine. A few of these stands 

have relic older trees scattered within them that are remnants from before the fire that regenerated the 

stand. Understory regeneration is variable and is predominantly western hemlock with western redcedar, 

grand fir, pacific yew, and mountain hemlock at the higher elevations. These stands are similar to the 

plantations in that there is high competition between the overstory trees and suppression in the 

regeneration.

All of the plantation stands are considered to be in the stem exclusion stage (Oliver and Larson, 1990). 

Stem exclusion stands have a dense overstory canopy cover that blocks out light to the forest floor and 

limits understory development. All of the stands in which overstory management is proposed have a high 

continuous overstory canopy cover, most averaging 80% or more. The trees are competing for sunlight, 

water, and nutrients causing reduced tree growth and vigor as well as limiting understory vegetation. The 

understory is mostly limited to shrubs with few small trees scattered throughout resulting in single-storied 

stands.
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Examples of plantations

Figure 11 Douglas-fir plantations. Left: Stem exclusion stage in unit 47. Right: Competing crowns in Unit 140.

Most of the fire regenerated stands are also in the stem exclusion stage with several beginning to 

transition into the understory re-initiation stage (Oliver and Larson, 1990) due to previous commercial 

thinning. The latter is characterized by dense overstory canopies with an understory of climax seedlings 

and saplings, predominantly composed of western hemlock with smaller amounts of western redcedar and 

occasional grand fir and pacific yew.

Examples of fire regenerated stands

Figure 12 Douglas-fir/hemlock Stands. Stem exclusion stage on the left. Stand re-initiation stage on the right.
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Figure 13 Left: Unit 50 Douglas-fir/hemlock. Right: Unit 97 Douglas-fir/noble fir. 

3.1.4 Environmental Consequences

Direct and Indirect Effects

Alternative 1 - No Action

Direct Effects 

There are no direct effects of choosing the no action alternative.

Indirect Effects 

The high stand densities that currently exist in these stands mean that there is strong competition between 

trees for light, water, and nutrients. Canopy closure restricts light to the forest floor, inhibiting the 

development of vegetation in the understory. Tree seedlings that may initially establish are out-competed 

and would either stagnate or die (Chan et al 2006). Without a developing understory, most of the stand 

structure is restricted to the even-aged overstory trees which have little variation in size and species 

composition. Diameter growth of most of the trees would be inhibited by inter-tree competition as well. 

As the development of large trees is delayed, so would the development of large snags. Although some 

trees would succumb to competition as density continues to increase, it would generally be the smaller 

suppressed trees that die. High stocking density and canopy covers would continue to restrict regeneration 

of shade intolerant species such as Douglas-fir and sugar pine. As older sugar pine die, their presence in 

the project area would be reduced without young trees to replace them. With continued fire suppression, 

the current shortage of early seral habitat for wildlife species would continue to decline. Suitable foraging 

habitat for large game animals as well as habitat for many bird species and pollinators would continue to 

decrease (Hanely 1984; Kie et al 2003; Betts 2010; Ellis and Betts 2011).

Eventually small gaps would form in the overstory as trees die from competition, wind throw, or other 

disturbance. Advanced regeneration of more shade tolerant species, such as western hemlock, would take 

advantage of these openings and begin growing into the overstory. Gradually structural and species 

diversity would increase in the stand (Franklin et al 2002; Oliver & Larson 1996). Left to natural process, 
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an uneven-aged structure would eventually arise if no further stand level disturbance occurs, but it would 

take many decades or centuries to develop. Figure 13 are examples of a stand (adjacent to, but not within 

the Hwy 46 Project) that was planted circa 1921 and never commercially thinned afterwards. There is 

very little structural and species diversity in this stand and growth rates are slow due to the intense intertree competition. This is a good example of what similar plantations would look like if not treated.

Figure 14 Examples of a Douglas-fir plantation from the 1920s that was never thinned

Alternative 2 

Commercial Thinning

Alternative 2 is proposing to commercially thin 2,549 acres. The silvicultural prescriptions are designed 

to reduce tree density and inter-tree competition which would result in:

• Maintenance or improvement of stand health and vigor.

• Acceleration of large diameter tree development due to enhanced growth.

• Increased structural and species diversity by allowing advanced regeneration to release into the 

mid and overstory.

• Increased shrub and herbaceous growth developing more understory complexity.

• Providing timber products to the local economy.

Most of the commercial thinning would be implemented using various Designation by Description (DxD) 

prescriptions. With this method, trees are designated as cut trees if they are within a given spacing of trees 

larger in diameter. For example, in a 15 foot DxD prescription, all smaller trees within 15 feet of the 

largest trees would be cut, leaving the largest trees spaced between 15 to 30 feet apart. This is essentially 

a “thin from below”, favoring the largest and most vigorous trees in the stand. Desired residual trees per 

acre as well as average diameter are used to calculate the spacing. Maximum diameter cut limits and 

species retention can be identified in the prescription to protect relic old trees or minor species 

components.

A variety of thinning intensities are prescribed in this project. These intensities are generally based on 

average tree diameter and stocking levels. Heavier thinnings of 40-60 residual trees per acre (tpa) are 

prescribed for stands with larger trees, as these trees need more space to grow than smaller ones. Most of 

the plantations are of similar age and structure and are prescribed thinnings to 70-90 tpa. A few of the 
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youngest plantations would receive a thinning ranging from 80-110 residual tpa to allow the trees room to 

grow without lowering the canopy cover below 40%.

Thinning to 40-100 tpa is prescribed to provide a wide range of canopy covers within the stands while 

still maximizing areas of stand and individual tree growth. This treatment is prescribed for Unit 28 which 

already has some species and structural diversity and would be applied with individual tree marking to 

ensure diversity retention and to allow for clumpiness desired for this stand. 

Figure 15 Left: Example of recent thinning in an 80-90 year old fire regenerated stand. Right: Example of 

recent thinning in a 40-50 year old plantation

Direct and Indirect Effects 

An immediate direct effect of thinning is reduced overstory canopy cover. Thinning reduces tree densities 

and opens up the canopy throughout the stand. This allows additional light to the forest floor thereby 

promoting understory vegetation development and natural tree regeneration, which can lead to multiple 

canopy layers and more structurally complex stands (Bailey and Tappeiner, 1998; Bailey et al, 1998; 

Harrington et al, 2005; Chan et al, 2006; Ares et al, 2009; Davis and Puettman, 2009). Figure 15 shows 

examples of stands that have been recently thinned. Canopies are receiving more light which allows the 

trees to allocate more resources to growth. Vegetation in the understory is also beginning to respond to 

the increase in light.

A short-term adverse impact to understory vegetation and below ground fungi would be the mechanical 

damage from logging (Courtney et al 2004). These short-term adverse effects would be expected to 

recover within a few years post-harvest as regrowth of herbs and shrubs occur. This effect would be 

reduced by minimizing additional soil impacts with the use of designated skid trails with ground–based 

yarding systems and log-suspension capabilities of skyline and helicopter yarding systems.

Indirect effects would include increased tree diameter growth, increased understory growth, and 

attainment of an uneven-aged structure in a shorter time frame (Ares 2009; Baily et al 1998; Chan 2006; 

Baily and Tappeiner 1998). Reductions in stand density would reduce inter-tree competition, allowing 

individual trees to use more sunlight, water, and nutrients. As trees grow in height, they would be able 

increase the relative size of their crowns resulting in increased tree diameter (Oliver and Larson, 1996). 

Increased light availability to understory trees would increase their height growth, allowing them to move 
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into the mid canopy and overstory. In many situations these trees are of a different, more shade-tolerant 

species than the overstory. Releasing them to grow would increase the species diversity in the upper 

levels of the crowns as well as the vertical structure of the stand. 

An additional effect is providing wood products to the local economy. This would create or maintain 

logging and mill jobs as well as help support local businesses in Detroit during harvesting operations.

Figure 16 Western hemlock growing into the mid-story approximately 30 years after thinning.

Skips, Clumps, and Dominant Tree Release (DTR) Gaps

No-treatment areas, called skips, are proposed within the stands to promote complexity by providing 

variable density within and among stands. Skips can be areas left untreated due to 1) resource 

considerations such as protection buffers adjacent to streams and special habitat areas, 2) logistical 

considerations such as logging feasibility, 3) areas not in need of thinning or 4) leaving untreated areas 

embedded within a stand to promote complexity. This combination of treatment and no treatment would 

result in skips within the stands to promote variable density both at the stand scale and across the 

landscape. Alternative 2 proposes to leave 910 acres of skips within the commercially treated portions of 

the project.

Clumps are groups of 2 to 5 trees immediately adjacent to each other that would be left in units in Late 

Successional Reserve (LSR). These groups of trees scattered throughout the thinned portion of the stand 

would increase both spatial heterogeneity and structural diversity as the stand grows. Alternative 2 

proposes to leave a total of 117 clumps within plantations in the LSR.

Dominant tree release gaps (DTR) are also proposed as a tool to promote complexity by providing 

variable density within stands, allowing for maximum tree growth, increased crown depth and expansion, 

enhanced species growth into the mid and overstory, as well as allowing for understory development. 

One or more dominant trees are left and all other trees within a radius of these tree(s) are removed, 

creating either a 1⁄4 acre gap or a 1⁄2 acre gap around the tree(s). If desirable advanced regeneration is 

present in the opening, it would be released by the treatment and grow into the overstory at a faster rate. If 

no advanced regeneration is present, the appropriate species would be planted. Generally for this project, 

1⁄4 acre DTRs would be created on northerly slopes where climax species such as western hemlock and 
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western redcedar are present (planted if not present); while 1⁄2 acre gaps would be created on southerly 

slopes and planted with seral species such as sugar pine, western white pine, or incense cedar. Climax 

species may be planted in the shady (southern) portions of these gaps as well. Stand selection for DTR 

placement is based on a variety of factors including plant association, stand structure, and land allocation.

Alternative 2 proposes to create approximately 250 DTRs for a total of about 74 acres.

 Figure 17 Graphic representation of thinning with skips and DTR gaps

 Figure 18 Google Earth image of recently created dominant tree release (DTR) gaps in a thinned stand

Direct and Indirect Effects 

The immediate effects of these treatments to the stand would be increased horizontal structural diversity, 

as well as increased light to the forest floor. An increase in wood products would also result. In the longer 

term, dominant trees that are released would become more open grown, larger in diameter, and more 

likely to develop larger limbs lower to the ground. Trees along the edge of the gaps would also increase in 

size more rapidly with the increased sunlight and reduced competition. Species diversity would increase 
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as existing and planted trees grew into the mid-story as well as understory vegetation developed in the 

openings (Ares 2009; Baily et al 1998; Chan 2006; Baily and Tappeiner 1998).

Quality Early Seral Habitat

Early seral habitat results from significant stand disturbance that removes most of the tree canopy cover. 

In this stage of succession, abundant light is available for hardwood vegetation growth such as shrubs and 

trees as well as other plants such as grasses and forbs. The primary creators of early seral in the West 

Cascades are fire, wind, insects, and logging. Natural disturbance typically leaves a legacy structure in the 

form of snags and down wood, which is important to many forms of wildlife including cavity nesters, 

rodents, and amphibians. Quality early seral habitat, also known as complex early seral habitat, has legacy 

structure. Historic practices of clear-cut logging and burning remove most of this structure, reducing the 

value of the resulting early seral to some wildlife, plant, and insect species.

With the cessation of clear-cut logging in the watershed twenty years ago and continued fire suppression, 

early seral habitat has been substantially reduced within the project area. Prior to the 2017 wildfires, the 

powerline corridor contained most of the early seral habitat, encompassing less than 1% of the acreage in 

the project area. It is estimated that the fires this past year have created an additional 1.6% in areas that 

burned hot enough to kill the majority of the trees. Historically, the Breitenbush watershed maintained 

about 9% early seral due to wildfire (USDA 1996, 2014).

Alternative 2 includes four units for early seral habitat creation (Units 14, 17, 59, and 63). These units 

were the only stands within the project area meeting all of the characteristics identified by the wildlife 

biologist for big game forage. These characteristics include:

• Gentle slopes, generally southerly in aspect

• Suitable plant association types favoring vine maple

• Avoiding plant associations that favor rhododendron or beargrass

• Limited vehicle access

• Not in Late Succession Reserve

The proposed regeneration harvesting would meet all Green Tree Retention guidelines outlined within the 

Northwest Forest Plan providing a minimum of 15% of each unit uncut in a combination of skips and 

scattered trees (USDA, 1994; REIC, 1996a; REIC, 1996b). An average of 7 to 8 tpa of live larger trees 

would be left for snag recruitment and down woody material in the harvested portions of the stands. Units 

14 and 17 are mature stands and would provide the largest potential snags for quality early seral habitat. 

All four units would be broadcast burned, planted at 150-200 tpa with seral species, and seeded with 

native grass species for big game forage. One foot square scalps to mineral soil would be created at the 

time of planting around each planted seedling to reduce competition from surrounding vegetation and 

increase survival. Some snags may also be created from the residual trees. 

Wildlife Gaps

Gaps one to three acres in size are proposed to be located in twelve units (Units 6, 16, 18, 21, 22, 23, 28, 

32, 35, 47, 180, and 200) for a total of up to 45 acres under Alternative 2. These gaps would contribute to 

the quality early seral habitat as described in Quality Early Seral Habitat above as well as adding species 

and structural complexity at both the stand and landscape level. Seven to eight trees per acre of residual 

trees would be left in each gap to increase stand diversity and for future snag and down woody 
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recruitment. Gaps would be broadcast burned where practical and all would be planted with seral conifers 

at 150 to 200 trees per acre. 

Direct and Indirect Effects 

Both the Quality Early Seral and Wildlife Gap creation would substantially reduce canopy cover in the 

areas treated. More light would be available to the remaining trees around the edge of the treatment area

as well as to the forest floor. This would result in an increase in hardwood, shrub, and forb development, 

as well as increased flowering and fruit production. Planted seral species would have adequate light to 

grow. Residual trees and trees on the perimeter of the openings would be released from competition for 

decades, resulting in larger diameters and deeper crowns. Numerous wildlife species would benefit from 

the vegetative response, including deer, elk, song birds, cavity nesters, humming birds, and other early 

seral dependent species.

Sugar Pine Restoration

The primary range of sugar pine extends from northern Mexico, through the Sierra Nevada, Northern 

California, and Southern Oregon. The very northern extent of its range is in the Hwy 46 project area. 

Sugar pine are moderately shade tolerant, particularly when they are young, needing some protection 

from the sun as they establish. As they get older their tolerance for competition decreases, and other 

species can out-compete them if lower intensity disturbances, primarily wildfire, do not thin stand 

densities. These wildfires not only help prolong the existence of the established sugar pine, they are also 

essential for their regeneration (Sugihara and McBride, 1992) (Garza, 1995). Fire suppression over the 

last 100 years, extensive logging, and the introduction of white pine blister rust at the turn of the 20th

century have reduced the population across its range (Waring and Angell, 2011). Most of the sugar pine 

found in the project area are lone big trees surrounded by dense Douglas-fir stands. One area of fire 

regenerating sugar pine was found during project reconnaissance. The presence of these trees means that 

sugar pine has been part of this landscape for a long time and now appears to be losing its place in the 

ecosystem due to lack of disturbance allowing it to regenerate.

Proposed treatments aim to both protect and reinvigorate existing sugar pine as well as re-establishing it 

in areas suitable to its prolonged existence. Prescriptions would include shelterwood with reserve cuts, 

broadcast burning, planting of rust resistant stock, and pre-commercial regeneration release. Ten units 

have been selected for this treatment which include: 6, 12, 33, 39, 40, 83, and 93-96. Only portions of 

each unit would receive the shelterwood cut, the rest of the area would be commercially thinned. A total 

of approximately 94 acres would be treated to restore sugar pine. Prescribed burning would reduce 

logging slash and prepare the site for planting. Large sugar pine would have the slash pulled back from 

their base to help protect them during burning. Sugar pine would also be planted in other units in gaps

created for early seral or in DTRs created for species diversity along with other seral species. One foot 

square scalps to mineral soil would be created at the time of planting to reduce immediate vegetative 

competition to the tree seedlings.

Direct and Indirect Effects 

Shelterwood prescriptions would leave approximately 20-30 trees per acre of existing sugar pine and 

other large diameter trees such as Douglas-fir. The direct effects of the shelterwood cuts would be a 

decrease in canopy cover with a corresponding increase in sunlight reaching the forest floor. Air 

movement through the stand would increase and could cause some less windfirm trees to blowdown in 

high wind events. Most of the trees left would be relics and the more dominant trees in the stand and 

should be resistant to most wind events, however some smaller trees may be left as well to meet the 
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prescription and these trees may not be as windfirm. Planted trees would create a new cohort of sugar 

pine, incense cedar, and western white pine. Douglas-fir would likely seed in as well from the reserve 

trees, as would some sugar pine. Sugar pine would have an increased presence on the landscape for the 

next several decades or centuries when compared to the no action alternative.

Figure 19 Left: Sugar pine competing with other conifers in Unit 83. Right: Previously treated sugar pine

stand within the project area.

Understory Habitat Enhancement

These treatments include enhancement of understory vegetation and meadow restoration. The principle 

objective of these treatments is to increase sunlight to the forest floor to enhance or restore desirable 

vegetation other than trees. Units 54, 82, 89, 92, and 560 would thin conifers less than 7 inches dbh to 

reduce shading of ground vegetation. No commercial harvest of conifers is proposed for these units. Total 

treatment is approximately204 acres.

Unit 32a is a high elevation meadow that has been encroached by conifers since the last severe fire there 

around the turn of the twentieth century. Historic aerial photos and field surveys indicate that this 

meadow once contained much more moisture and meadow vegetation, which is now being shaded out. 

The proposed treatment is to cut and remove most of the conifers within the boundaries of the historic 

meadow, leaving 3-5 tpa of larger live trees and retaining any relic conifers from before the fire. 

The northwest portion of unit 73 is a dry meadow being encroached by Douglas-fir. 

Enhancement would involve falling and leaving the encroaching trees on approximately 6 acres.
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Figure 20 Left: Meadow portion of Unit 73. Right: Encroached meadow in Unit 32a.

Direct and Indirect Effects

The direct effects of the proposed treatments would be increased light reaching the forest floor. Indirectly, 

existing vegetation would grow and new vegetation adapted to more sunlight would become established. 

Flowering and fruit production would increase, benefiting a wide variety of pollinating species (Neill and 

Puettmann 2013). In unit 32a, the reduction in water uptake by the trees currently there should help to 

restore moisture to portions of the meadow as well as reduce shade, allowing meadow plants to reestablish. Benefits described for early seral habitat would also apply for the meadow enhancement units.

Riparian Treatments

The project area is deficient in hardwoods along streams. Foliage from hardwoods provide nutrients for 

macro-invertebrates which provide food for fish down steam. Past silvicultural practices harvested timber 

to the edge of many streams and planted Douglas-fir along the streamside. Thinning the Douglas-fir 

would allow more sunlight to hit the ground, encouraging hardwoods such as red alder and vine maple to 

re-establish along the stream banks. Several reaches within five different plantation units have been 

identified for treatment. Units 6, 100, 190, 430, and 520 would have conifers thinned to the stream bank 

for some the portions of streams. In addition, small gaps (less than 1⁄4 acre in size) would be created within 

these treatment areas in locations where it would be the most beneficial to hardwood release. Total acres 

of these gaps would not exceed 4 acres. All portions within the no-harvest buffers would be felled and 

left. Thinning intensities would match the prescription for the rest of the unit. A total of approximately 20 

acres of riparian treatment is proposed.

Direct and Indirect Effects 

As with other similar treatments described in this project, immediate effects would include reduced 

canopy cover over the stream areas increasing sunlight reaching the stream and forest floor. This would 

result in an increase in growth, in both height and abundance, of any existing hardwoods such as vine 

maple or red alder. Residual trees left would increase their rate of diameter growth and crowns would 

increase in size and depth. In the long run, these treatments would result in larger trees growing along the 

stream sooner than if there is no treatment. This would eventually lead to larger snags and increased down 

woody material to the stream as well.
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Figure 21 Stream in Unit 430 in need of hardwood restoration.

Visual Enhancement Gaps

To enhance scenic views, three gaps have been proposed in this project. Units 27 and 30 would each have 

a 1⁄2 acre “scallop” along the powerline corridor with residual overstory to soften the view of the straight 

line of the corridor. A few trees would be left in the scallops to help “soften” the visual contrast between 

the timber and the corridor. Unit 69 would have a 1/3 acre gap below road 46 to increase the view of Mt. 

Jefferson from the summit pull-out. All trees in this gap would be cut.

Direct and Indirect Effects 

For units 27 and 30, the immediate effect would be the reduction in trees per acre and canopy cover in the 

areas treated. As with other gaps described in this project, residual tree growth would increase and forest 

floor vegetation would respond as well. Scotch broom, an invasive species, is present in the powerline 

corridor and there is risk of it spreading into the gaps.

Fuels Treatments

Several stands adjacent to the Breitenbush Resort property and summer home area have been identified as 

needing understory fuels treatments to reduce the risk of wildfire. Units include 170, 210, and 270. 

Proposed treatments include thinning conifers less than 7 inches dbh to a 15 foot spacing, pruning, 

brushing, chipping, hand piling, and pile burning. 

Direct and Indirect Effects 

Initially there would be a reduction in the number of small trees and some rhododendron and vine maple 

in portions of the units. Overstory canopy cover would not be affected. Both western hemlock and the 

shrubs cut would re-establish after a few years.
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Late Successional Reserve (LSR) 

Late-Successional Reserves are to be managed to protect and enhance conditions of late-successional and

old-growth forest ecosystems. Silviculture treatments are to benefit the creation and maintenance of latesuccessional forest conditions and are subject to review by the Regional Ecosystem Office (REO). 

Exemption criteria from REO review for commercial thinning were established in 1996 (REIC 1996a and 

1996b) and projects that fully meet these criteria do not require a project review.

In the Hwy 46 Project, there are 38 units that are either completely within or have a portion within the 

LSR, totaling 1,018 acres. Of this, 35 units encompassing 808 acres are prescribed for commercial 

thinning. These prescriptions meet the exemption criteria set by the REO by meeting the following 

requirements 

• The purpose of the proposed treatment is to accelerate the rate of development of latesuccessional conditions and reduce the risk of large-scale disturbance.

• Timber volume production is only incidental.

• The proposed stand for commercial thinning is less than 80 years old, overstocked, and not 

structurally complex.

• A proposed treatment is an intermediate treatment resulting in 10% or more of the stands’ acreage 

in unthinned patches and 3-10% in small openings (1/4-acre).

• Trees >20 inches dbh shall not be cut except for the purpose of creating openings, providing other 

habitat structure, elimination of a hazard, or cutting yarding corridors.

• Snag objectives are included by designing prescriptions that include developing large trees for 

potential future snag recruitment, retaining agents of mortality or damage, retention of snags, and 

leaving skips to allow currently competition mortality processes to naturally continue.

In addition, clumps of 2-5 trees would be left within the thinned portion of the units, as described earlier 

in this section.

Direct and Indirect Effects 

The effects would be reduced canopy cover and increased sunlight to the forest floor, leading to increased 

vegetative response, increased tree growth, increased horizontal structural diversity, and increased species 

diversity in forbs, shrubs, and trees. These treatments would result in these stands attaining late seral 

characteristics decades sooner than if left untreated.

Alternative 3 

The primary difference between Alternative 2 and 3 is the elimination of any treatments in fire 

regenerated stands. This would affect the number of acres treated for commercial thinning, quality early 

seral habitat, DTRs, and sugar pine restoration. It would also have an effect on the amount of wood 

provided to the local market. See Table 22 for a summary.
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Table 22 Comparison of Alternatives

Activity Acres treated 

Alternative 1

Acres Treated 

Alternative 2

Acres Treated 

Alternative 3

Commercial Thinning 0 2,488.45 1,871.95

Dominant Tree Release 0 72.25 61.25

Quality Early Seral Habitat 0 43 14

Wildlife Gaps 0 46.5 28

Sugar Pine Restoration 0 92 9

Understory Habitat Enhancement 0 155 155

Riparian Treatments 0 20 20

Visual Enhancement Gaps 0 1.3 0.8

Fuels Treatments 0 229 193

Timber Volume (Million Board feet) 0 40 24

Direct and Indirect Effects 

The direct effects of implementing Alternative 3 compared to Alternative 2 is 640.5 (25%) less acres of 

commercial thinning, 13 (18%) less acres of DTRs, 29 (64%) less acres of quality early seral habitat, 17 

(38%) less acres of wildlife gaps, 85 (90%) less acres of sugar pine restoration, 0.5 less acres of visual 

enhancement gaps, and 13 (38%) million less board feet of timber products. The trees within the older 

stands not treated would continue to experience high competition. The crown level would continue to rise 

and regeneration within the stands would grow slowly or stagnate. As disturbance creates holes in the 

canopy, structural diversity would increase slowly as western hemlock or other species grow into the 

gaps, although this would most likely happen on a much longer time scale when compared to Alternative 

2.

Cumulative Effects 

Alternative 1 – No Action

With implementation of Alternative 1, no cumulative effects to forest stand and structure would occur as 

the effects of Alternative 1 do not overlap in space and time with effects from any past, present or 

reasonably foreseeable future actions.

Alternative 2 and 3

Effects on forest stand structure from Alternatives 2 and 3 overlap in time a space with the 294 acres of 

powerline corridor traversing the project area that is maintained in an early seral condition by the 

Bonneville and PGE power companies and approximately 521 acres of recent high tree mortality due to 

the 2017 wildfires which will result in early seral habitat as the vegetation begins to recover. Ninety one

acres of early seral creation in Alternative 2 and 43 acres from Alternative 3 would contribute to early 

seral habitat for the next 20 years, until a young forest is re-established in units treated.

2017 Fire Effects

As mentioned earlier in this section, an unusually active fire season this past year has impacted the 

vegetation within the Breitenbush watershed and the project area. Two fires, Scorpion and Little Devil, 

have virtually all of their perimeters within the Hwy 46 project area, totaling 2,921 acres. The Scorpion 
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fire affected several planned units for this project. To assess the immediate impacts to these units, ground 

reconnaissance was conducted by the District Silviculturist in the fall of 2017, as soon as fire behavior

abated enough to permit entry into the area. Satellite data was later collected and processed with RAVG 

software to assess fire severity through spectral analysis of the ground and canopy vegetation mortality. 

Combining field observations and RAVG data, the Silviculturist projected that areas identified as 

“moderate” and “high” severity have or will result in early seral habitat based on the extent of tree 

mortality. These higher mortality areas total 521 acres within the project area. Other areas identified as 

“unchanged” or “low” severity will also have some mortality, but it will likely be confined to smaller 

understory trees or small pockets of overstory less than an acre in size.

Direct and Indirect Effects 

The Scorpion fire burned in units 12, 13, 16, 25, 83, 95, and 96. Generally, this was a low intensity 

ground fire with isolated pockets of torching and limited crown fire. Trees with thinner bark are more 

susceptible to ground fire, which can kill the cambium layer, effectively girdling the tree. Young, small 

diameter trees of most species in this area have thin bark and can be susceptible to ground fire. More 

shade tolerant climax species, such as western hemlock and western redcedar, tend to have thinner bark 

even as they grow larger, and are less likely to survive a ground fire than seral species, such as Douglasfir and sugar pine. Trees killed by ground fire may not die right away, as with trees that experience crown 

damage. In some cases, trees weakened by partial ground scorching can become susceptible to bark 

beetles several years after the fire, particularly if insect populations increase as a result of widespread tree 

stress created by the fire. Stands with a higher component of smaller diameter and thin bark species will 

likely have high mortality in those trees. This was observed in portions of units 13 and 16, and 83. Other 

areas where the forest is dominated by Douglas-fir of larger diameters will likely experience very little 

mortality. This was evident in units 25, 95, 96, and portions of units 12, 16, and 83. There are also some 

isolated pockets of crown fire noticed in units 12, 13, 16, and 83. The highest intensity pocket affecting a 

unit is in unit 13 in an area that previously had diverse crown structure and species diversity. This part of 

the unit was originally going to be “skipped” at layout and not treated, however, the presence of ladder 

fuels likely contributed to higher fire intensity.

Since the fire effects are variable throughout the units impacted by the fire and actual mortality may not 

be evident for a year or more, decisions on how future timber sales from this project will be affected will 

be made at the time of layout. Areas that no longer need treatment will be dropped from impacted units 

unless a viable salvage opportunity exists.
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Examples of Fire Effects

Figure 22 Examples of very low intensity ground fire in units 95 (left) and 83 (right) with little mortality 

expected.

Figure 23 Example of low intensity fire initial effects in unit 13 with mixed species.

Left: Live crowns show no impact immediately after the fire. Right: Large Douglas-fir in the right of the photo 

will likely survive, western hemlock to the left will certainly not. 

Figure 24 Left: Example of isolated crown mortality in low severity burn in unit 12. Right: Mixed severity burn 

in the Little Devils fire. No Hwy 46 units are visible in the Little Devils photo.
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3.2 Fire and Fuels

3.2.1 Summary of Effects Analysis

Proposed actions for Alternative 2 and 3 would reduce fuel loadings following timber harvest, improve 

fire suppression capabilities, reduce risk from wildfire to public and private lands and structures, and 

introduce fire as an ecological function to portions of the landscape. Treatment of activity generated fuels 

would be accomplished through a variety of techniques including piling, chipping, mastication, and 

prescribed burning to meet Forest Plan standards and guidelines for post-harvest fuel loadings. Fire 

suppression capabilities would be enhanced and risk from wildfire reduced through reduction of fuel 

densities in strategic areas such as roads corridors and areas adjacent to structures and private lands, 

lookout maintenance, and decreased fire intensity in stands following post-harvest fuel treatments. 

Alternative 2 includes 1113 acres of underburning and 897 acres of pile burning, and Alternative 3 

incudes 655 acres of underburning and 805 acres of pile burning. Both Alternative 2 and 3 include 223

acres of hazardous fuels treatments. Immediately following timber harvest activities an increase in 

potential fire intensity will exist in units until fuels treatments are completed. 

3.2.2 Scale of Analysis

Landscape level and project wide data was used to analyze the historic role of fire and its effects across 

the project area. Stand specific data was used in the fuels treatment recommendations for individual units. 

3.2.3 Affected Environment

Fire on the Landscape

Within the Hwy 46 planning area naturally occurring lightning fires were one of the primary agents of 

disturbance prior to Euro American settlement. Before the beginning of fire suppression and large scale 

timber harvest activities, fires of variable size and intensity created a mosaic of forest types and age 

classes that affected wildlife habitat, stand dynamics, soil properties, and watershed hydrology. Some 

amount of fire on the landscape had also been introduced by the Native American communities within the 

greater geographic area, but these events are thought to be focused primarily in the valley bottoms to the 

west, outside of the planning area. Small specific sites may have been burned to maintain or enhance 

berry production and camas fields but the extent of this burning is not fully understood (Morrison and 

Swanson 1990).

Fire Regime and Frequency

A fire regime describes the pattern, frequency, and intensity of the wildfires that prevail in an area. While 

the traditional model of Douglas-fir/western hemlock forests has emphasized high severity fire as the 

primary disturbance agent, recent studies are beginning to suggest that lower severity non-stand replacing 

fires may have also played a role in successional pathways (Tepley 2013). These non-stand replacing fires 

foster the development of multi-cohort stands where shade-intolerant and shade-tolerant species both 

form distinct age cohorts. The impacts of fire varied greatly across this region and helped to shape the 

historic structural diversity that resulted in a variety of age classes and seral types. 

Fire frequency is a general term referring to the reoccurrence of fire in an area over a given time. The idea 

of a fire frequency or return cycle as a regular occurrence is not as predictable in the Western Cascades 

and the Hwy 46 planning area as it is in drier forest types, and can range anywhere from 95 to 145 years 

between events (Agee 1993). Within the East Humbug and Scorpion Creek drainages Garza (1995) 

observes a mean fire frequency index of 142 years but also found evidence of surface fires at return 

intervals of less than 25 years. The highly variable nature of fire frequency and intensity in the western 
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Cascades creates a mixture of both stand replacing and non-stand replacing fires that leads to multiple 

developmental pathways and variations in stand structure. 

Between 1970 and 2016 there were 198 recorded fires in the planning area, with 39% attributed to 

lightning and 61% human-caused. Of these fires 83% were suppressed at 0.1 acres or less, with four fires 

reaching more than 10 acres and one fire over 100 acres that was reported with a final size of 335 acres. 

During the summer of 2017 three large fires burned within the project area effecting several units. These 

fires were typical of the western cascades mixed severity fire regime and had a range of effects on the 

landscape. 

The 695 acre Scorpion Fire had the largest effect on units within the project area, burning through most of 

units 13, 16, and 83 as well as parts of units 12, 25, 95, and 96. While this fire was generally moderate in 

intensity with the fire primarily underburning through stands and consuming ground fuels and patches of 

shrubs and small trees, it did include some areas of high mortality that created openings in the canopy and 

early seral habitat conditions. It is anticipated that additional mortality may occur over the next year or 

two in trees that were damaged or overly stressed from the fire. 

The Little Devils Fire burned 2,161 acres within the planning area and was also a mixed severity fire, 

underburning in places but also creating some areas of high mortality that will provide future early seral 

habitat. Although this fire primarily burned adjacent to units planned for timber management activities, 

approximately 3 acres of unit 360 was effected by the fire. 

The Whitewater Fire burned 11,493 acres but only 65 acres burned within the project area. No units were 

affected by this fire.

The Hwy 46 planning area is a mixture of fire regimes and includes the following:

• Fire Regime II: 0 to 35 year fire return interval; high severity (over 75% mortality)

• Fire Regime III: < 35 to 150 year fire return interval; mixed severity (25-75% mortality)

• Fire Regime IV: < 35 to 150 year fire return interval; high severity (over 75% mortality)

• Fire Regime V: 150+ year fire return interval; high severity (over 75% mortality)
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Figure 25 Fire Regime Classification Hwy 46 Planning Area

Fire Effects on Sugar Pine

The Hwy 46 planning area is at the northern most range of sugar pine. As an early seral shade intolerant 

species regeneration of sugar pine without disturbance is not possible. Sugar pine seedlings prefer mineral 

soil seedbeds for germination and mature trees are classified as intermediate in fire tolerance with a thick 

fire-resistant bark and open canopy that retards aerial fire spread. Frequent burning reduces site 

productivity over time which favors sugar pine as it has been observed to grow faster on lower 

productivity sites than Douglas fir, whereas Douglas fir can outgrow sugar pine on higher productivity 

sites. Low to moderate severity surface fires would also reduce understory development which can create 

competition for resources. During a drought in the mid-1980s many older sugar pine were killed by bark 

beetles that tend to attack weaker trees under stress for resources. 

Garza (1995) shows a wide variance in the fire frequency index throughout the East Humbug and 

Scorpion Creek drainages ranging from 48 to 469 years. He also found that sites with sugar pine in this 

area have a shorter fire frequency index (116 years) than sites without sugar pine (156 years). 

The 2017 Scorpion Fire burned through several stands that contained sugar pine and had a variety of 

effects. Some large older trees were killed by the fire, however throughout most of the burned area the 

fire burned along the ground only, leaving the larger tress mostly unaffected. Some pockets of younger 

sugar pine that were identified as opportunities to thin and release appear to have suffered high mortality

rates, however canopy openings created by the fire should also provide ideal habitat for future sugar pine 

regeneration.
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Wildland-Urban Interface

The project area surrounds both the Breitenbush Hot Springs Resort and the Breitenbush and Devils 

Creek summer home tracts. These areas have been identified as communities at risk in the Marion County 

Community Wildfire Protection Plan. Much of the area that surrounds the structures within these 

communities is dense older forest with heavy fuel loadings and narrow road access that could inhibit fire 

suppression activities in the event of a wildfire. In 2014, 51 acres of mastication work was completed 

within the Breitenbush Hot Springs Resort and Conference Center, and between 2006 and 2012 50 acres 

of fuels reduction was completed by the US Forest Service within the summer home tracts. While this 

work has improved defensible space conditions and access for fire suppression resources there is still a 

substantial risk from wildfire within these communities.

Figure 26 Within and around the Breitenbush and Devils Creek summer homes areas of dense vegetation 

exist that may contribute to increased fire intensity making protection of structure in a wildfire difficult.

Figure 27 Areas that have received hazardous fuel treatments such as this can help reduce fire intensity and 

provide for a safer environment to suppress wildfires and provide structure protection.
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Fuel Profile and Fire Behavior

The following are summaries of expected fire behavior and fuel profile conditions of stands within the 

planning area (NWCG 1982). 

Fuel Model 5 (Young Plantations): These stands are comprised of shrubs or young conifers with little to 

no dead wood where fire often carries through surface and ground fuels. Fires occurring in these stands 

are often of low intensity due to the light surface fuel loading. However, under severe weather conditions 

such as high wind events or times of the year when foliar fuel moisture is low these stands can see an 

increase in fire intensity. Plantations that have been recently thinned fall into a separate category due to 

their heavier fuel loadings. 

Figure 28 Fuel Model 5 Figure 29 Fuel Model 8

Fuel Model 8 (Mature Plantations and Fire Regenerated Natural Stands): These are stands with 

closed canopies of short needle conifers where surface fuels are primarily needles and small 

accumulations of twigs and branches. Some limited areas of heavy fuel accumulation may be present but 

do not substantially effect fire behavior. Most fires are slow burning ground fires although under severe 

weather conditions such as high wind events or periods low humidity and high temperatures these fuels 

may pose a hazard and transition from a surface fire to a crown fire. 

Fuel Model 10 (Older Natural Stands): These are older stands with multiple canopy layers and greater 

quantities of large down dead material. During periods of elevated fire danger this fuel type is more likely 

to result in higher fire intensities and has a greater probability of individual and group tree torching. 

Figure 30 Fuel Model 10 Figure 31 Fuel Model 12

Fuel Models 11, 12 (Stands Post Commercial Harvest): Following timber harvest stands will see an 

increase in the amount of fuel distributed on the forest floor. These elevated fuel loadings will create 
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potential for increased fire intensity until fuels reduction activities take place or sufficient time elapses for 

fuels to break down and decompose (approximately 5 to 15 years). 

3.2.4 Environmental Consequences

Direct and Indirect Effects

Alternative 1 - No Action

Under Alternative 1 the effects of fire suppression and past management activities would continue. Lack 

of fire disturbance would prevent the creation of new early seral conditions and inhibit the establishment 

of new sugar pine. Existing open areas and meadows would continue to fill in with conifers and mid-seral

closed canopy conditions will continue to dominate the landscape. Plantations would remain at their 

current stocking levels and short-term impacts to fire danger would be avoided as no resulting slash 

would be created during harvest operations. Over time however these stands will begin to self-thin either 

through competition for resources, insect damage, disease, or a combination of environmental factors. 

Fuel loadings and fire danger would increase as a result of this self-thinning, similar to that following 

commercial harvest, but without any mitigating fuels treatments. Without release from dense stocking 

levels tree vigor would decline and average tree diameter and bark thickness growth would stagnate 

leaving dense stands of small diameter trees susceptible to fire damage in the event of a wildfire. Fuels

would continue to accumulate in the Breitenbush Summer Homes and Hot Springs Resort area and those 

communities would remain at a risk to wildfire. 

Alternative 2 

Post-harvest Fuels Treatments

Following timber harvests there will be an increase in potential wildfire behavior. The greatest risk from 

fire will come in the first five years following harvest while needles and small twigs remain attached to 

branches and limbs. Depending upon the amount and distribution of fuels following harvest, fires will be 

fairly active with high intensities, particularly in areas of heavy thinning and gaps where direct sunlight is 

able to reach the forest floor. 

Fuel reduction treatments such as piling and burning of limbs and branches, chipping, or prescribed 

underburning can mitigate the effects of commercial harvests and reduce long term wildfire risk and 

intensity. Fuels treatments will generally be completed within 1 to 2 years following harvest and reduce 

total fuel loading to within or below standards set by the Willamette Forest Management Plan Standards 

and Guidelines FW-212 and 252. 

While stands will see a short term increased risk from fire post-harvest, over the long term the individual 

trees will become more fire resistant as increased growth rates will create larger diameter thicker barked 

trees that will be able to withstand higher temperatures for longer durations in the event of a wildfire. 

All Underburns

Each underburn will have an individual Prescribed Fire Plan developed with specific prescription 

parameters. Prescribed burning will be conducted when threat of fire escaping from the defined unit 

boundaries is low and smoke management forecast are favorable. Some units will be seasonally restricted 

from burning activities to avoid impacts to wildlife during critical breeding periods. Units that are 

prescribed underburning may require fireline dug down to mineral soil around the perimeter of the burn 

unit.
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Post-Harvest Underburning

Underburning following timber harvest would take place on approximately 1113 acres and is intended to 

achieve a variety of resource objectives. The primary objective is the treatment of activity generated slash 

created by timber harvest to bring fuel loading within or below standards established by the Willamette 

Forest and Management Plan to reduce threat from wildfire. Underburning is the most effective way to 

mitigate post-harvest fuel loading and breaks up fuel continuity across the landscape by treating entire 

units. These burns target the consumption of the smaller diameter fuels, the primary drivers of fire 

behavior. Once this size class of fuels are consumed future fires within these stands would lack sufficient 

fuel loading to burn with much intensity and would be easily controlled. Some material such as downed 

logs, duff, and some small pockets of live and dead fuels will remain after any underburns but would 

generally not affect the ability of firefighters to safely and effectively suppress any future fires within 

these stands. 

Secondary objectives for underburns include a variety of natural resource benefits including promotion of 

early seral species, improvement of big game forage, and creation of new snags. Acceptable mortality 

resulting from prescribed fire in overstory trees would be 0-10%, and burns would be timed to minimize 

consumption of duff and large woody debris. While fire would naturally occur at a larger scale throughout 

the planning area and have a greater degree of variability in terms of its intensity and severity, prescribed 

underburning allows for a controlled replication of the natural fire disturbance process while minimizing 

threats to public safety and private property. 

Figure 32 Post-harvest underburning will create a mosaic of burned and unburned areas throughout stands
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Figure 33 Underburns will be timed to ensure adequate duff and down wood retention

Sugar Pine Underburning (only in Alternative 2)

Underburning in stands identified as sugar pine habitat improvement areas will have the same objectives 

and effects as post-harvest underburning with different mortality objectives. In these units mortality in 

mature sugar pine will be kept as close to zero as possible. Removal or redistribution of fuels at the base 

of sugar pines may be needed to reduce fire behavior within proximity to trees. Other conifer species 

within these stands will have a higher mortality range of 5-15% to create pockets of snags and canopy 

gaps for establishment of new sugar pine habitat. No mortality created by prescribed burning would be 

salvaged.

Hand or Machine Piling and Burning

Piling and burning of harvest created slash would take place on approximately 897 acres. Pile burning 

would mitigate most post-harvest fuel loading but would not provide the same replication of the natural 

fire disturbance process as prescribed underburning. Piling will be focused on concentrations of postharvest slash to reduce overall fuel loading and decrease fire hazard, but some amount of material would 

be left to decompose on site and break down over time. In areas where these concentrations remain some 

elevated resistance to fire control will exist until the material fully breaks down, approximately 5-15 years 

after harvest. Burning would generally take place in the fall when fire season has been declared over and 

there is little chance of fire spreading outside of the created piles. 

Hazardous Fuels Treatments

Hazardous fuels treatments would take place on up to 223 acres around the Breitenbush Hot Springs 

Resort and Conference Center and within the Breitenbush and Devils Creek recreation residence areas. 

The units proposed for this project are intended to serve as an area where hazardous fuels treatments 

could take place as a collaborative effort between the Breitenbush Hot Springs Resort and Conference 

Center, summer home owners, and the Forest Service. Not all acres may be treated depending upon the 

need and desires of all partners involved in the project. 
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Hazardous fuels treatments include non-commercial thinning and pruning of trees less than 7 inches in 

diameter and treating the resulting fuels through burning or chipping. The purpose of these treatments is 

to reduce the intensity of any wildfires that may impact these communities in the future through the 

establishment of defensible space, or the distance between vegetation and structures. Adequate defensible 

space aids in the protection of structures from wildfire and provides a safer environment for firefighters to 

operate in. Hazardous fuel treatments are also intended to reduce fuel loadings along the road systems in 

and around these communities. This will allow for the safe ingress and egress of firefighting resources 

and the public throughout these communities during a fire and increase the ability to effectively utilize 

road systems as fire control lines. Reducing hazardous fuels and improving defensible space around 

structures will increases both firefighter safety and the probability of success in protecting these 

communities. 

To mitigate any potential visuals concerns resulting from work within the hazardous fuels units adjacent 

to the Breitenbush community and summer homes, the following mitigations and design elements will be 

implemented:

• All work will be done with hand treatments only, no mechanical treatments will be used

• Areas of shrubs and trees will be retained in “skips” to provide vegetation buffers where needed 

• Burning will be minimized to the greatest extent possible

Unit 570

Unit 570 is a 24 acre unit on the north slope of Gale Hill. The location serves as a fire lookout point for 

the Breitenbush watershed during lighting storms and provides a vantage point for locations that are not 

visible from the districts primary fire lookout at Coffin Mountain. This project proposes to selectively 

thin and clear pre-commercial conifer trees (less than 7 inches dbh) to maintain visibility from this 

vantage point into the Breitenbush watershed. 

Table 23 Comparison of Fuels Treatments by Alternative

Treatment Unit of Measure Alt. 1 Alt. 2 Alt. 3

Post-Harvest Fuels Treatments (1)

Hand Piling Acres 0 26 54

Mechanical Treatments (2) Acres 0 805 745

Post-Harvest Underburn Acres 0 1102 586

WUI Treatments

Hazardous Fuels Treatment 

(not including skips) Acres 0 169 169

Total Fuels Treatment Acres 0 2137 1554

(1): Post-harvest fuels treatments methods may change depending on feasibility and funding.

(2): Mechanical treatment may include: grapple piling in slash concentrations, mastication, or any other mechanical 

device). 

Alternative 3 

Alternative 3 would treat 583 less acres of activity generated fuels due to the reduction in harvest acres 

and no burning would take place in stands containing sugar pine. The hazardous fuels treatments around 

the Breitenbush Hot Springs Resort and summer homes area would still be implemented as well as the 

lookout point maintenance at Gale Hill. 
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Cumulative Effects 

Alternative 1

No cumulative effects would take place as no post-harvest fuels treatments or hazardous fuels projects 

would take place. 

Alternative 2 and 3

Effects to fire and fuels from actions proposed in the Hwy 46 project (Alternative 2 and 3) overlap in time 

and space with effects from the following actions:

• Breitenbush Hot Springs Fuels Reduction: In 2014 51 acres of mastication work was 

completed within the Breitenbush Hot Springs Resort. Maintenance of this work or the 

completion of additional of work in the future would overlap in time and space with the 169 acres 

of hazardous fuels reduction treatments proposed in the Hwy 46 project and would provide 

additional protection from risk of wildfire. 

• Breitenbush and Devils Creek Summer Homes Fuels Reduction Project: Between 2006 and 

2012 approximately 50 acres of hazardous fuels reduction was completed by the US Forest 

Service within the summer home tracts. These areas would be maintained or improved upon 

during the implementation of the 169 acres of hazardous fuels work in Alternatives 2 and 3 to 

provide protection to structures from wildfire. 

• Scorpion Fire: The Scorpion Fire Burned 695 acres within the project area in the summer of 

2017. Units 12, 13, 16, 25, 83, 95, and 96 were affected by the fire, with either portions or the 

majority of these units having fire burned through them. Effects to stands from the fire are 

currently being evaluated and it is anticipated that additional mortality may develop over the next 

year or two as a result of damage and stress to trees as a result of the fire. While some mature 

sugar pine within units that were planned for thinning and release may have suffered mortality, it 

is believed that most of the sugar pine in these stands have survived. Additionally, canopy gaps

created by the fire should provide areas for both natural sugar pine regeneration or potential areas 

for sugar pine planting sites. 

• Little Devils Fire: This fire burned 2,162 acres within the project area. While the fire burned 

within close proximity to several units, only 3 acres proposed for treatments were affected by the 

fire. 

• Whitewater Fire: This fire burned approximately 65 acres within the project area. None of the 

acres effected by this fire are proposed for treatments. 

3.3 Soils

3.3.1 Summary of Effects Analysis

Potential short-term impacts to the soil and geology resource from management and harvest activity, as 

discussed in the Willamette National Forest Final Environmental Impact Statement (FEIS 1990), include 

displacement, compaction, nutrient loss, and instability. In most situations, preventing soil impacts is the 

most effective and feasible way of ensuring long-term soil productivity.

As part of the vegetation management activities, all action alternatives have the same basic effects and the 

same soil protection measures, as described on a unit by unit basis. 

Anticipated effects to the soils resource will be below and within the Willamette National Forest 

Standards and Guidelines. The soils design features were designed to maintain long term soil productivity, 
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provide erosion control, and to meet or exceed the requirements consistent with the standards and 

guidelines of the Willamette National Forest's Land and Resource Management Plan (1990) and Oregon 

State Department of Environmental Quality guidelines. 

With a proper project implementation and use of the design features, no adverse effects to soil resources 

are expected.

Post-fire effects from the Scorpion, Little Devil, and Whitewater incidents depend on the level of soil 

burn severity, fire vegetation intensity and time of project implementation. With a dominant unburned, 

very low and low soil burn severities within the fire affected area, in addition to a high supply of woody 

and duff material from delay tree mortality any exposed mineral soils, should not be higher than 30% 

after project implementation. Consequently, erosion, soil productivity loss would be minimized with the 

addition of design criteria’s such as slash cover, duff retention, subsoiling, etc.

3.3.2 Scale of Analysis

For the soil resource the scale of analysis for both direct / indirect effects and cumulative effects is almost 

always the “unit”, i.e. the stand polygon or activity area proposed for silvicultural treatment. The unit of 

measure for evaluating those effects is generally considered the percent of the “unit” affected (by field 

reconnaissance of potential harvest units and surrounding areas for this planned project). The summing of 

acres for various units, such as the total acres of skyline logging in a given alternative, is not an 

evaluation criterion for soils impacts. Impacts are evaluated on a unit-by-unit basis, and are generally the 

same in any given unit for all action alternatives, unless otherwise noted. 

Evaluating impacts and their potential significance between or among alternatives requires a discussion of 

the duration and intensity of those impacts. The following definitions apply to impacts in this section. 

Duration 

Short-term: The effects last for a few weeks to one or two years; 

Intermediate: The effects last from one or two years to about a decade:

Long-term: The effects last from about 10 years or longer.

Intensity

Low, negligible, little or no, minimal, minor: The impacts are essentially zero, at the lowest levels of 

detection, or very slight but still noticeable.

Moderate, reasonable: The impacts are readily apparent, but meet standards and guides.

Excessive, substantive, major, critical: The impact is moderately severe and likely approaches the upper 

limits of standards and guides. 

Significant, unacceptable: The impacts are severe, and likely exceed standards and guides or do not 

meet Best Management Practices. 

Post-fire soil resources effects are assessed by mapping the post-fire Soil Burn Severity. This assessment 

is followed as part of the Burn Area Emergency Assessment (BAER) protocols. A Soil Burn Severity map 

was conducted during the month of October, using definitions in the “Field Guide for Mapping Soil Burn 

Severity.” (Parsons, et.al. 2010). Soil burn severity is determined using factors such as depth, soil color, 

ash soil color and character, live fuels consumption extent, root and plant condition, litter and duff 

consumed, loss of soil structure, development of water repellency, and soil crusting. Soil Burn Severity is 

classified as high, moderate, low, and very low or unburned.
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Some Aerial reconnaissance (photos and video) was done a week before ground base field 

reconnaissance. These photos were used to correlates soil burn severity within areas not reachable and 

following the “Field Guide for Mapping Soil Burn Severity.” 

The duration and intensity of fire effects to soil resources fall under the same categories as stated above 

and relate directionally to the type of soil burn severity class map within the analyzed area. 

3.3.3 Affected Environment

The Breitenbush watershed is located above Detroit Reservoir and has a total area of about 69,400 acres, 

almost all of which is located on the Willamette National Forest. This project area contains both High 

Cascade and Western Cascade physiographic provinces. The dividing line runs approximately south and 

northeast from the area of the confluence of the North and South Forks. 

Most of the proposed units in this project area are located within the Western Cascades physiographic 

region, on strata that were once called the Little Butte Sequence. Much of this area has been remapped by 

Walker and Duncan (1989) as “Tu”. The project area lies at the eastern boundary of their mapping area 

and also extends east beyond it. “Tu” includes undivided Miocene and Oligocene tuffaceous sedimentary 

rocks, basalt flows, tuffs and breccias form the foundation for most West Cascade drainages (Walker and 

Duncan, 1989) in this area. The strata often consist of a heterogeneous assemblage of continental, largely 

volcanogenic deposits of basalt and basaltic andesite, including flows and breccias, complexly 

interstratified with epiclastic and volcanoclastic deposits of basaltic to rhyodacitic composition. They also 

include extensive rhyodacitic to andesitic ash-flow and air-fall tuffs, abundant lapilli tuff and tuff breccia, 

andesitic to dacitic mudflow (lahar) deposits, massive to bedded, fine to coarse grained, tuffaceous 

sedimentary rocks, and volcanic conglomerates. Radiometric potassium/argon dates on parts of this 

formation are mostly 32 to 17 million years old (Walker and Duncan, 1989). 

Overlying these older formations, the higher elevation main ridges are capped with flows and flow 

breccias of olivine andesite, basaltic andesite, and some basalt. These rocks, the “Tba” of Walker and 

Duncan (1989) have previously been designated as the Sardine Formation by some authors (Peck, et al, 

1964). These flow deposits lie in an unconformable position on the older Tertiary deposits and erupted 

mostly from widespread, northwest trending dikes and dike swarms and related plugs and lava cones. 

Their potassium-argon age dates range from about 17 to 10 million years ago or Middle to late Miocene 

(Walker and Duncan, 1989). 

Overlying these upland volcanic deposits are even younger, ridge capping basalt flows, the “Tb” of 

Walker and Duncan (1989). A few proposed units appear to be located on these strata. Some volcanic 

flows of this unit are lithologically similar to flow rocks of the High Cascade volcanic sequence and some 

are more like flows that were previously mapped as part of the Sardine Formation. Potassium – argon 

ages of rocks of this unit range in age from about 10 to 4 million years (Walker and Duncan, 1989).

The High Cascades portion on the eastern side of the project area contains the youngest volcanic rocks of 

the Cascade range, mostly Pliocene or Pleistocene in age. Some of the oldest lava flows of the High 

Cascades appear to have covered the youngest Western Cascade strata. Since then, most volcanic events 

have generally been confined to the High Cascades proper (Hammond, et al, 1980). Most of the High 

Cascade volcanic eruptions, which form the broad base of the High Cascade platform, contain basalt 

flows, flow breccias, and pyroclastic deposits. They represent the early part of the volcanic eruptions, and 

their ages range from about four to one million years. The youngest and most recent deposits are 

generally less than one million years in age and include intra-canyon flows, low shield volcano out 
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pouring, and the more pronounced stratacone deposits, like those on Mount Jefferson or Three Fingered 

Jack (Walker and Ducan, 1989) (Hammond, P. E., et al, 1980). 

In the last several million years, all these rock formations have been extensively modified by stream 

erosion, mountain glaciation and slope instability (Ricker, 1982). The surface expression of these rock 

formations has been extensively altered by erosion since late Pliocene time, especially with Pleistocene to 

Holocene glacial activity and large scale slope instability. The upper Breitenbush drainage was likely 

heavily affected by the large ice cap glaciers that covered the High Cascade platform with sheets of ice 

hundreds of feet thick. During numerous glacial periods, large valley glaciers surged away from the 

Cascade crest and traveled west down the main drainage. The drainages of the High Cascades are 

typically U-shaped, glaciated valleys with flat valley bottoms and steep rocky valley walls that abruptly 

transition to rolling uplands at the higher elevations. More recent late Pleistocene glaciations were likely 

much smaller, and localized valley glaciers carved smaller cirques on the north aspects of these same 

stream uplands. 

The rocks and strata of some of the older Tertiary volcanic deposits (usually the “Tu” strata) sometimes 

weather to form deep colluvial and residual soils that can give rise to unstable soils. Stabilized slump / 

earth flow features, such as sag ponds, bench and scarp topography, and disrupted drainages are common 

in many parts of this project area. It seems likely that slump / earthflow instability has been a significant 

factor in slope development and stream channel morphology for the last several thousand years, certainly 

since the end of the Pleistocene. However, large scale slope instability from slump / earthflow complexes 

and debris chutes has been relatively inactive in the last 500 to 1000 years or more, except in some 

localized areas. 

This complex relatively recent geologic history has produced a myriad of diverse landforms and soils. In 

general soils on these side slopes have been stable and productive for at least several hundreds of years. 

Soils formed either directly on the underlying volcanic bedrock, on the more limited glacial deposits, or 

on jumbled combinations of the two in the slump complexes. Both types have similar size gradations that 

range from silt loams to gravelly or cobbly, sandy loams. Depth to bedrock is highly variable and can 

range from a few feet to many times that amount. The various land types are generally well drained where 

permeability is rapid in the surface soils, and rapid to moderate in the subsoil. Because of high infiltration 

rates, overland flow is generally uncommon. In the proposed units, side slopes range from near zero to 

about 80%, but are generally less than 60%. Offsite erosion is generally not a concern because of the 

extensive vegetative ground cover and the gentle to moderate side slopes. 

Stand ages in this project area are somewhat variable and indicate natural or human caused impacts. 

There is some evidence that under burning happened in older stands when stand replacement fires 

occurred in nearby areas. Other areas were not burnt or under burnt in the extensive stand replacement 

fires that traveled through much of the District approximately 150 to 500 years ago. It is likely that 

aboriginal or natural fires were common along the ridge lines in this project area prior to settlement by 

Europeans. As a result, natural accumulations of down woody debris are highly variable across many 

areas.

The Scorpion, Little Devil, and Whitewater fires occurred during the summer of 2017 and burned 

approximately 9% of the proposed project area. This is 2 % within Scorpion, 7% within Little Devil and 

0.2 % within Whitewater fire.

Scorpion fire effects occur mostly in 7 proposed units (12, 13, 16, 25, 83, 95, 96) for a total of 230 acres. 

Dominant soil burn severity within those areas was very low/unburned (75%) follow by low soil burn 

severity conditions (25%). 
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The Little Devil fire burned around 3 acres of a proposed unit but overall stay southwest from the 870 

roads (Devils Creek Road) not impacting additional proposed units. The dominant soil burn severity 

within the 3 acres is very low or unburned. Adjacent burned areas to proposed units exhibit a mosaic of 

low soil, very low and unburned soil burn severity.

The small project area burned as part of the Whitewater fire exhibit a mosaic of unburned, very low, low 

and small patches of moderate (ridges) soil burn severity. No units were affected due to the Whitewater 

fire incident.

Ground field reconnaissance of the fires and soil burn severity shows that overall the vegetation fire 

intensity (canopy) was higher (moderate vegetation intensity) with some small patches of high vegetation 

intensity than the soil burn severity. Another factor that precluded the reduction of high, moderate areas 

was the level of rock outcrops, colluvial and ridge sections. These areas show a higher intensity in 

vegetation but with none or shallow soil profiles resulting in minimal soil post-fire effect.

Ground cover removal in fire areas was low to moderate due to the high shrub, canopy density and woody 

debris component in the ecosystem. Duff litter was still mostly intact with a depth of 1⁄2 inches to an inch 

with very low/unburned and low soil burn severity areas. Field values mentioned show that nutrient loss 

was low to moderate on the ground surface with a short-term recovery.

Base on the remote sensing post-fire vegetation analysis RAVG, (Rapid Assessment of Vegetation 

Condition after Wildfire); basal area mortality within the burned units fall mostly under no basal area 

mortality or lower than 10 % area mortality. These values represent mostly a low ground cover and 

surface organic removal. There are site-specific patches of moderate ground cover and surface organic 

removal (around 25% basal area mortality). In low severity soils, a delay of mortality is expected mostly 

in small root system patches depending on terrain and soil depth loss resulting in site-specific hazard tree 

potential.

62% of the burned units within the Scorpion fire show a high to very high erosion hazard rating. A 

moderate to high erosion hazard rating occurs in the Little Devil fire areas located northeast from the 

proposed project units. Soils in the small project area affected by the Whitewater fire exhibit a high to 

very high erosion hazard rating.

3.3.4 Environmental Consequences 

Direct and Indirect Effects

The major short-term effects to soil productivity from harvest activity, as discussed in the Willamette 

National Forest Final Environmental Impact Statement (FEIS 1990), include management indicators of 

displacement, compaction, nutrient loss, and instability (Table 24). The total area of cumulative 

detrimental soil conditions should not exceed 20% of the total acreage within the activity area, including 

roads and landings.

Table 24 Management Indicators for Assessing Effects to Soils

Issue Management Indicator Justification

Displacement

50% of topsoil or humus enriched soil horizons are 

removed from an area of 100 square feet that is at least 

5 feet in width

FW-081 
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Issue Management Indicator Justification

Compaction

Increase in soil bulk density by at least 15% and/or a 

reduction in macropore space of 50% over the 

undisturbed soil

FW-081

Nutrient Loss Insufficient duff retention or large woody material to 

ensure adequate nutrient cycling FW-085

Instability Increase in size, intensity or number of slope failures FW-086 

The main post-fire short-term effects to soil and geology resources due to fire effects depend on the soil 

burn severity and the erosion (site movement) levels within the next year after a fire. Erosion and 

evidence of surface soil loss at 5 to 10 years (long-term) would depend on the revegetation stages and 

ground cover generation within affected areas.

Table 25 Post Fire Management Indicators

Issue Management Indicator Justification

Severely 

Burned Areas / 

Detrimental 

Burning

Soils are considered to be severely burned 

when the top layer of mineral soil has been 

significantly changed in color, usually to red, 

and the next 1⁄2 inch blackened from organic 

matter charring by heat conducted through 

the top layer.

FW-081/ Region 6 – Soil Quality 

Standards 

Soil Erosion

Detrimental 

Surface 

Erosion

To minimize off-site movement of soil, 

management activities shall be planned to 

retain the soil duff and litter using the 

following limits:

• Mineral soil exposed on soils

classed as low to moderate surface 

erosion hazard should not exceed 

40%

• Mineral soil exposed on soils

classed as high surface erosion 

hazard should not exceed 30%.

• Mineral soil exposed on soils

classed as very high surface 

erosion hazard should not exceed 

15%.

Evidence of surface soil loss in areas 

greater than 100 square feet including rills, 

gullies, and/or water quality degradations 

from sediment or nutrient enrichment.

FW-084 

Region 6 – Soil Quality 

Standards

Alternative 1 – No Action

Stands will continue to develop. Many of the stands proposed for treatment currently have little 

understory vegetation because of the lack of sunlight to the forest floor. Intermediate and suppressed trees 
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would slowly be removed from the stand through mortality and decay. In areas of heavy stocking, stands 

would stagnate. Blow down and snow down would continue to increase fuel loading in the short to 

intermediate term. Global climate change could alter the capacity of some stands to continue to carry the 

current density of trees in a healthy manner. 

In general, plant diversity would diminish as well as soil biota because of the lack of sunlight. In areas 

already compacted or disturbed, the soil building process will continue to return the soil to near preharvest conditions in the longer term. Short-term to intermediate term impacts from harvest, such as soil 

disturbance, dust (or mud), slash accumulation and disposal, and longer term impacts such as compaction

and nutrient loss would not occur. 

Slope instability is a geologic process that is currently active in parts of this project area and can 

potentially affect some proposed units. Most potentially actively unstable or potentially highly unstable 

soils were deleted from the units in the action alternatives. Consequently, in the short or intermediate 

term, no effects to slope instability are anticipated whether the units are managed or not. Stand density is 

such that little change in stability is anticipated in the short to intermediate term. In the long term, loss of 

stand integrity with disease, storm or fire might cause an increase in slope failure.

Under current conditions, the fire effects depending on the soil burn severity class are:

• Low - The ground surface, including any exposed mineral soil, may appear (lightly charred), and 

the canopy and understory vegetation will likely appear “green.”

• Very low or Unburned - Little to no burn expected within these areas. Canopy and ground litter 

completely intact. Little to no vegetative mortality expected.

Consequently, under a no-action alternative, within current burned areas sudden revegetation (understory) 

would proliferate in the first year as is showing similar diversity effects to prescribed burn activities. The 

recovery of patches of moderately burned areas is expected to increase from 3 to 5 years.

Based on estimated post-fire soil erosion values (ERMIT model, 2006), a low-risk erosion potential was 

determined considering the amount of unburned/very low and low burn severity fire and the high degree 

of regeneration and recuperation within the fire areas. In addition felling of trees, branches, snags, etc., is 

expected to occur within burned areas to a higher content that under normal conditions, resulting in a 

large woody and ground cover accumulation acting and reduction burned erosion potential, potentially 

increasing fire fuel loading within the next three years. 

Alternative 2 and 3

Effects between both action alternatives would be the same except for acreage harvested. The major 

short-term impacts to soil productivity from harvest activity include displacement, compaction, nutrient 

loss, and instability. Forest-wide (FW) Standards and Guidelines (FW–081), state that the total area of 

cumulative detrimental soil conditions should not exceed 20% of the total acreage within the activity area, 

including roads and landings. Anticipated direct effects to the soils resource would be within Willamette 

National Forest Standards and Guidelines. In most situations, preventing soil impacts is the most effective 

and feasible way of reducing cumulative effects and ensuring long-term soil productivity. All 

prescriptions or design features discussed are designed to meet or exceed the requirements outlined in the 

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

(USDA, 2012).. 

Displacement: Little physical evidence can be found in any unit to indicate displacement from previous 

management activity has been a problem. Stand, shrub and brush growth, as well as duff accumulation 

over the decades, have provided an effective ground cover. To adequately protect the soil resource, the 
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primary yarding objective for all units will be either ground based systems with predesignated skid roads 

and directional falling as appropriate, or skyline yarding with one end suspension, except at tail trees and 

landings. All ground based yarding activities will be adhere to contract clauses (as stated in soil report) 

and/or line pulling and directional falling would be implemented; in all cases, existing skid or haul roads 

will be utilized before any additional new skid or forwarder roads are developed. Skyline operations in 

thinning units with small wood and intermediate supports usually impacts less than 1% of the unit area. 

Most of the units with steeper ground had little or no existing disturbance levels. Disturbance from 

yarding will be well within the Regional and Forest standards, and significant adverse impacts are not 

anticipated. With appropriate suspension during logging, soil disturbance is minimal and off site erosion 

is essentially non-existent. During harvest, the retention of stream adjacent trees and the requirement of 

full suspension yarding over or away from stream courses will minimize or eliminate off-site erosion. 

Some units (or portions thereof) may be helicopter yarded to minimize development of the transportation 

system that would be needed for more conventional logging systems. In this project, helicopter yarding is 

not needed for increased soil protection.

Compaction: The primary previous impact to the soil resource from management is compaction, the 

effects of which can remain apparent for decades. Evidence of compaction from previous entry is still 

present. Field reconnaissance of the proposed units shows some level of existing compaction, primarily 

within the existing plantations. .The field investigation indicated that units 70, 140, 190 and 250 exceeded 

the Willamette National Forest FW-081 Standard of 20% of an activity area impacted by compaction. In 

unit 360, the area above the road on the ridge had higher compaction, but the bulk of the unit was skyline 

with very little existing compaction. The remaining units were sufficiently within the standard. Although 

standards and guides would be imposed for the units, it is possible that some ground based units may 

approach or exceed the 20% standard at the completion of yarding, grapple piling, and pile burning. 

Consequently, three actions are recommended in order to bring the units into compliance with the current 

standards by reducing overall compaction below the 20% level. These actions are: 1) As mitigation in 

Units 70, 140, 190, and 250 all primary landings, temporary haul or principal skid roads utilized by the 

purchaser / logger would be subsoiled (to a depth of 18 to 24 inches) at the completion of logging 

activities; 2) In addition, some subsoiling of landings and primary haul or skid roads is a proposed 

enhancement in many ground based units to insure that cumulative levels remain well below the 20% 

standard; and 3) Some post-sale enhancement subsoiling is recommended for areas not utilized by the 

Purchaser or included within the sold units. Potential units include 8, 9, 10, 17, 23, 31, 35, 56, 57, 58, 59, 

61, 63, 70, 73, 74, 78, 140A, 150, 180, 220, 450 and 520 or portions of other units where both skyline and 

ground based systems may be employed. Of these, the highest priority are units 35, 63, 73, 180 and 520. 

With the use of designated skid roads, the reuse of the existing skid road system, and the subsoiling of 

landings and primary skid roads, compaction is not anticipated to exceed the 20% value in any unit, it 

should generally be below the 15% level (or much lower), except unit 190, where compaction levels will 

be reduced from pre-thinning levels, but the 20% objective may or may not be achieved. Based on 

previous experience, this effort should be successful. 

Skyline operations in thinning units with small wood and intermediate supports usually impacts less than 

1% of the unit area. Skyline yarding with one end suspension is proposed for parts or all of many units. 

Most of these units had low existing compaction levels at generally less than 5%, at least in the areas of 

steeper side slopes. Skyline landings are primarily planned at old existing landings, road turnouts, and 

road junctions. Little new spur road would be required. Effects from existing compaction and skyline 

yarding are not anticipated for any individual unit.

The use of temporary truck roads considerably reduces the amount of compaction for most units by 

reducing both the number of trips across the ground and shortening the skidding distance. The use of the 
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existing road system in the area and the potential to create new temporary roads on the relatively flat 

ground in order to reduce soil compaction, is recommended. Given that, temporary roads should be 

subsoiled at the completion of harvest activities. Subsoiling may be curtailed in some areas in order to 

reduce the amount of root pruning of leave trees, to avoid excessive amounts of exposed soil, or to avoid 

stumps or large rocks. 

Nutrient Loss: Potential nutrient loss is primarily controlled by duff retention standards. Duff retention is 

the amount of duff thickness remaining after management activities are completed. Duff retention 

objectives would be specified for each unit to maintain nutrient cycling. Duff retention values range on 

the low end from 10-30% to as much as 60 to 80% on sensitive slopes. Monitoring and field 

reconnaissance in recent years has shown that the duff retention percentages for under burns in partial 

cuts, thinning, or fuels reduction within unmanaged stands, which maintain an intact live root mat and 

live canopy cover over most of the unit, could be lower and still achieve adequate soil protection. 

For all action alternatives, within the managed plantations, slash would be scattered in the units, piled and 

burned, or perhaps broadcast or under burned. Piling may occur by hand or with a grapple machine. 

Grapple piling occurs with a grapple not with a dozer brush rake. Grapple piling requires one pass of the 

machine across the landscape, and the machine works while sitting on slash. Extensive monitoring of 

grapple machine piling operations indicates that little or no additional compaction or displacement occurs, 

when properly implemented. In many cases only a few acres of any particular unit are hand piled or 

machine piled. 

Burning the piled slash may develop sufficient heat to affect the underlying soil. However, the hotter 

portions of pile burning involve a very small part of the acreage in any unit, usually less than 1% of the 

area. Also pile burning is usually done in the fall or winter months when duff and soil moistures are 

higher, and this helps reduce the downward heat effects to the soil. Pile burning is considered a minor 

effect and not cumulative because of the limited overall acreage involved. 

Another aspect of long term nutrient availability and ectomycorrhizal formation is the amount of larger 

woody material retained on site. Management activities would be planned to maintain enough large 

woody debris (dead and down) to provide for a healthy forest ecosystem and ensure adequate nutrient 

cycling (FW-085). At this time, site specific needs would be considered commensurate with wildlife 

objectives as outlined in FW-212a and FW-213a (as amended). Concentrations of larger down logs that 

were produced with the initial harvest should be left undisturbed as much as possible. With the retention 

of adequate duff and woody debris, potential adverse impacts to long-term soil productivity are not 

anticipated. 

Instability: The Breitenbush drainage is generally considered a moderately stable to very stable. Based on 

field reconnaissance, 14 units (or portions thereof) could have instability concerns, units 5, 6, 12, 25, 38, 

42, 53, 60, 77, 84, 93, 95, 100 and 290. Unit 37, which also has instability concerns was dropped. The 

removal of trees with harvest from these units could in the short to intermediate term, reduce 

evapotranspiration as compared to the current condition. This could result in slight increases in the ground 

water level, which might affect slope instability down slope. However, this is not considered a critical 

concern for three reasons: 1) these changes are anticipated to be within levels that are similar to natural 

rainfall amounts at two to ten year storm events. The potential intermediate impacts from thinning and a 

reduction in stem density will be quickly ameliorated by the increased growth on the leave trees; 2) if no 

action occurs, suppression will result in the stands loosing trees or growth with a similar loss in 

evapotranspiration; and 3) monitoring of commercial thinning harvest implemented on potentially highly 

unstable or actively unstable terrain has shown good release and not exacerbated slope instability. 
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Field review of previously thinned units in the past several years on both stable and unstable land types 

has shown no increase in either slope instability or erosion in either uplands or riparian reserves. Thinning 

within those units with potentially highly unstable or actively unstable terrain will not immediately 

promote greater slope stability. However, thinning will create healthier stands with bigger trees that have 

larger crowns and more roots. Those areas with shallow, debris chute type soil failures where rooting 

depth plays a part in slope stability, will see improvements within a few years as crowns begin to respond 

to the increased sun light. Larger trees create more roots and tend to increase slope stability, and if failures 

do occur, they provide larger wood for down slope riparian areas. For those units with slump / earthflows, 

failure depths are below the rooting zone. However, evapotranspiration will maintain or increase with 

bigger trees, and that will reduce pore water pressure in the longer term. With thinning, these stands will 

return to current levels of water usage within a few years, and this rate will be maintained or increased for 

decades into the future as the stand matures, crowns expand, and root mats enlarge and deepen.

A total of 47 acres of instability areas within some riparian reserves were assessed and mapped during the 

summer of 2017. These are located in units 25, 40, 42, 53 and 92. Based on the level and type of 

instability potential actions within these areas could be avoidance (area deleted from unit during layout) 

or increasing the no harvesting buffer zone. Specific prescriptions and action to be taken are stated in 

Appendix G: Riparian Reserve Treatment Detail.

Transportation system to access units and suitable landing sites for ground based, skyline or helicopter 

yarding systems may require temporary roads, opening old logging roads constructed many decades ago, 

or by using new temporary roads. Temporary roads are located on gentle stable side slopes, with common 

material. Little or no full bench construction is required, and if needed, end haul of excess excavation will 

be transport to a suitable waste area. Use of these old logging roads will allow for drainage structure 

improvements and fill stabilization. Some specific geotechnical works were conducted within 3 units of 

the project. The geotechnical work consisted in site assessment for some hauling road extension, 

construction and waste site conditions on units 97, 140, 490.

Post-Fire Effects:

Based on Forest Standards, burned areas did not reached a severe (high) detrimental level therefore there 

are not currently detrimental burning effects within the project area and recovery of the area is expected 

within the next 5 years. Consequently, under alternatives 2, and 3 soil resources impacts would depend 

on:

• The timing (years after fire) of project implementation.

• The level of natural recovery achieve within the burned areas. 

• The level of tree mortality or delay mortality resulting in reducing or dropping acres and areas 

for vegetation management. 

Following soil erosion indicators (measures) and above factors, the potential limitations or impacts to 

burned areas under harvesting activities are:

• Project implementation after 1 year of recovery: 

o Erosion and runoff potential would maintained a high potential within slopes greater than 

30% , in addition nutrient cycling would be set back under groundbased disturbance. This 

due to the removal of the under recovery ground cover, large woody debris, direct 

increase in the amount of bare soil and specific soil physical properties such as water 

repellency.

o Erosion and runoff potential in areas lower than 30% should be moderate due to the 

dominant unburned, very low soil burn severity levels in which ground litter is intact and 
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were nutrient cycling have a higher natural recovery due to the quick intake from soil 

surface nutrients. 

o Skyline corridors should produce a minimal erosion and runoff impact within harvesting 

areas by following proposed designs as mention above.

• Project Implementation after 3 to 5 years.

o With unburned, very low, and low soil burn severity then the soil infiltration, woody 

debris (fine, large) and duff layer would increase (high supply of litter) due to tree 

mortality delay. The understory recovery (revegetation) would increase close to pre-fire 

conditions. Therefore, erosion and runoff impacts are expected to be moderate. 

o Nutrient loss would increase within bare soil areas by breaking the recover organic layer. 

With this reduction, the soil productivity loss would be an impact on disturbed areas. 

Addition of slash material, tops, etc. within disturbed areas, would be a post-project 

supply to the organic layer improving and mitigating soil productivity loss, erosion and 

runoff potential.

Exposed mineral soils, in both conditions should not be higher than 30% after project implementation due 

to the dominant low soil burn severity, a high supply of woody and duff material and by following duff 

retention, slash cover and subsoiling design criteria’s.

Road Investment Strategy Analysis:

An opportunity to conduct road decommissioning in the area of Short Lake prompted the need to tie FS 

Rd 040 into FS Rd 045 by using Rd 059 (as signed in the field) and a short section of new construction of 

approximately 1000 feet in length. This new construction is the Short Lake reroute mentioned in Table 

64. Road 059 (as signed in the field) is an existing road that is located on a broad flat ridge. The new 

connection route drops from the end of the ridge to the west in two broad switchbacks. This new section 

is located on side slopes that range from 0 to about 20%. Grades are favorable at 5 to around 12%. Soil 

depths are greater than 10 feet so the entire route is located in common material. No drainages, seeps, or 

wet soil areas are evident along this route. Most of the length of proposed new route essentially follows 

existing old skid / haul road, and most of the route is located in an existing plantation. The new Short 

Lake Reroute as stated in the Road Investment Strategy Analysis (Table 64) would result in 1 to 1.3 miles 

of road decommission within the lake area.

Unsuited areas, such as cliffs, rock outcrops, critical rocky areas, or wetlands and dry meadows were 

mapped as part of the field reconnaissance. Skyline corridors running through unsuited areas within a unit 

are acceptable to access suited portions of the unit. Trees in the unsuited area that need to be cut to 

maintain the integrity or safety of the skyline corridor will be left for down woody debris (following 

Forest Plan recommendations). Partial suspension is the logging requirement over rocky areas, full 

suspension is required over wetlands, dry meadows and riparian sites.

Further analysis of the Willamette Road Investment Strategy within the proposed project area recommend 

a total of 4 miles (2% of the project road system) of road storage, these are roads to be closed and stored 

for resource protection (such as drainage, soils displacement, etc.). There are 8.88 miles of recommended 

road decommission (4 % of the project road system), which are roads assign for complete obliteration or 

depending on the area a mixed adaptive area stabilization and restoration.

Soil and geology resources risks or limitation levels within road system were analyzed based on the 

following indicators:

• Erosion - road profile and soil component erosion potential
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• Adjacent instability - the existence of historic, current mass movement, potential type of mass 

movement (instability) and potential of activation.

• Runoff Potential - overland flow potential base on native and soil physical properties

52% of the recommended new road closures and 64% of currently closed segments exhibits moderate to 

high soil and geology resources risks. A long-term beneficial impact is expected by closing these 

segments to permanent traffic (using berms or other temporary closures). Natural revegetation and 

stability regeneration would occur and improved soil and geology resources limitations in an intermediate 

to long-term duration. Additional erosion and instability mitigation would occur as part of the 

improvements and maintenance of less than 1 to 10% of segments to be used for hauling during the 

project implementation.

71% of the road segments recommended for decommissioning exhibits a moderate to high soil and 

geology resources risks. Road decommissions activities such as road stabilization, subsoiling, fill 

removal, etc. could result in a short-term increase in erosion and sedimentation to be minimized by 

implementing erosion control practices during and after decommissioning activities. The 

decommissioning of these segments is beneficial by reducing road density, increase productivity by 

providing ground cover, increase infiltration potential (drainage), increase natural revegetation and 

provide entrance to quantify mass movement risk and design the appropriate restoration to reduce that 

risk and potential sediment movement.

69% of the roads within the project areas are recommended to remain open. Some site-specific erosion, 

runoff impact could occur requiring erosion control practices and stability techniques; adhering to forest 

service standards, maintenance standards, monitoring and soil/geology mitigations (such as wet weather 

management, dry versus wet weather haul, erosion control practices) a minimal impact is expected.

Cumulative Effects

The impacts are evaluated on a unit-by-unit basis, and are generally the same in any given unit for all 

action alternatives, unless otherwise noted. The primary previous impact to the soil resource from 

management was compaction, the effects of which can remain apparent for decades. Potential cumulative 

effects from displacement, nutrient loss, and instability with previous management were not observed in 

the field reconnaissance. Existing compaction levels have been documented and discussed for the various 

units. The soils design elements are designed to limit the amount of additional compaction, and the 

subsoiling is intended to reduce compaction where levels would exceed standards and guides. It is 

possible that some ground based units may approach or exceed the 20% standard at the completion of 

yarding, grapple piling, and pile burning. Specifically, 70, 140, 190 and 250 have subsoiling as a 

mitigation to insure compaction is reduced to more acceptable levels. In addition, for most ground based 

units, some purchaser subsoiling is recommended as enhancement to lower compaction amounts further. 

The objective is to remain below the 20% cumulative level, maintain long-term soil productivity, and 

provide a level of erosion control that is consistent with State guidelines. 

Prescriptions for soil protection and watershed considerations take into account past and predicted future 

land management activities. No single unit measure of long-term soil productivity is widely used. 

Information on the survival and growth of planted seedlings may indicate short-term changes in site 

productivity. However, the relationship of short-term changes to long-term productivity is not fully 

understood. Experience indicates that the potential impacts on soils are best evaluated on a site-specific, 

project-by-project basis. The major soils concerns—compaction, nutrient loss, displacement and 

instability—are most effectively reviewed for short- and long-term effects at the project level. With 

proper project implementation, unacceptable cumulative effects on soils are not anticipated from the 

action alternatives. Soil protection measures and best management practices as defined in this report 
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would preclude the need for additional cumulative effects analysis. Deviations from the standards and 

guidelines would trigger further cumulative effects review, and no deviations are planned.

With the dominant unburned, very low and low soil burn severities within the fire affected area, in 

addition to a high supply of woody and duff material from delay tree mortality any exposed mineral soils, 

should not be higher than 30% after project implementation. Consequently, erosion, soil productivity loss 

would be minimized with the addition of design criteria such as slash cover, duff retention, etc. Same 

impacts, conditions, and mitigations are expected in roadside hazard foreseeable actions. 

The Burn Area Assessment determined a series of post-fire treatments such as storm patrol, and stormproofing activities. These activities consist of cleaning culverts, increasing ditch and catchment basin 

capacity where they exist to handle post-fire flows, sediment, and debris between or during storms. These 

foreseeable actions would monitor, improved, and reduced erosion, sedimentation, and runoff conditions 

within the fire affected areas. Erosion control practices, road closures, storm management practices, 

ground cover improvements are expected as part of fire rehabilitation activities.

Road decommissioning would occur when funds are available but temporary closures would provide a 

short-term resource protections, in addition, some of these roads are already closed, and to some level 

stabilized.

3.4 Hydrology

3.4.1 Summary of Effects Analysis

Alternative 1 would retain stands and roads in current condition with no changes to peak flow responses 

and negligible to immeasurable changes to surface flows and water storage. Lack of road maintenance 

would continue to pose risks of stream channel diversion. Variably thinning stands and creating local 

disturbances under Alternatives 2 and 3 would alter the hydrology on the site scale, but due to the design 

elements that avoid or limit impacts and a less than 3% reduction in the ARP level on the subwatershed 

scale, effects would be minor to immeasurable. Under Alternative 2, local disturbances would include 16 

ground-based crossings on intermittent streams and 2 temporary road crossings and culvert upgrades. 

Alternative 3 would treat less acreage, have one less ground-based stream crossing disturbance, and less 

road miles maintained. Negligible to minor effects to runoff from underburning stands and pile burning 

treatments are anticipated, due to the low intensity and low acreage, respectively, of affected ground. 

Conifer encroachment would continue to transition the meadow in Unit 32a towards a forested condition 

under Alternatives 1 and 3, whereas under Alternative 2, meadow restoration would improve hydrology 

for wet meadow vegetation species, pollinators and wildlife. 

Desired riparian conditions, with high species and structural diversity and large dead and down wood

would continue to slowly develop over time as natural disturbances take place. Alternatives 2 and 3 

propose to treat 781 and 601 acres of Riparian Reserve, respectively, to improve stand conditions towards 

meeting ACS objectives by reducing stand densities, to increase light to the forest floor, improve stand 

vigor and increase stand diversity. Primary shade to streams would be protected, with slight reductions to 

the secondary shade zones and maintenance of stream temperatures. Action alternatives would protect 

approximately 90% or more of the recruitment zones for large wood where Riparian Reserves are treated, 

with attributable reductions in wood recruitment to streams experienced in the short-to intermediate-term. 

Alternative 1 would protect large wood recruitment the greatest in the short to –intermediate term, but 

would be delayed in its ability to generate larger wood, responsible for forming and maintaining stream 

channels. Proposed streamside treatments in the action alternatives would restore hardwood riparian plant 

communities and add large wood to streams, benefitting riparian conditions along 3.2 miles of tributaries. 
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Effects to riparian conditions would be similar for both action alternatives, with the exception that 184 

less thinning acres would affected under Alternative 3. Alternative 2 offers the greatest opportunity to 

improve ACSO’s in Riparian Reserves on the watershed scale.

Stream shade and temperature would be maintained with no effects under Alternative 1. Under the action 

alternatives, stream shade would be reduced slightly but minimized with cutting of trees at 15-16 

individual stream crossings and thinning in the secondary shade zone. Canopy closure of at least 50% 

would be retained in the secondary shade zone and thinning would be excluded from the primary shade 

zones by a minimum of 60-100 foot no treatment buffers. Treatments would have no measurable effects to 

stream temperature.

Rates of road related sediment yield are estimated to remain relatively unchanged under Alternative 1, 

with existing road erosion problems that result in sedimentation to streams unaddressed. Forty-one and 36 

stream crossing culverts that are currently in poor condition or undersized would be replaced or upgraded 

in Alternatives 2 and 3, respectively, yielding approximately 62 and 54 cubic yards of sediment, 

respectively, during replacement, but stabilizing 10,250 and 9,000 cubic yards of sediment from longterm risk of potential culvert failure. New temporary road construction (5.1 mi), road realignments (0.3), 

road storage and decommissioning (4 mi) and the Short Lake Reroute (0.4 mi) decrease road generated 

sediment delivery to streams in the project area by 12 cubic yards annually. Fewer miles of new 

temporary roads and existing spurs constructed and re-opened, haul routes, and road 

maintenance/reconstruction would produce slightly less sediment yield to streams than Alternative 2. 

Alternative 3 would treat approximately 614 acres within Riparian Reserves, and all other treatments 

would be the same as Alternative 2. Effects on riparian conditions would be similar to Alternative 2. With 

fewer acres thinned than Alternative 2, dense riparian reserves untreated would be more prone to wildfire, 

disease, and infestation, and no benefits of meadow restoration.

This section is summarized from the Hwy 46 Hydrology Report, which is incorporated by reference and 

available in the project record at the Detroit Ranger District Office.

3.4.2 Analysis Methods

The hydrologist analyzed stream temperature data from 10 sites, including long-term monitoring sites and 

additional project specific sites since 2006. Level II stream surveys were completed on major streams in 

the project area between 2002 and 2014 and included detailed measures of stream morphology, 

streamflow, streambed substrates, large wood counts and riparian characteristics. This data was used in 

conjunction with unit-level riparian reconnaissance to assess the need for treatment to improve riparian 

conditions.

Fisheries, hydrology, wildlife, botany, and silviculture specialists surveyed all potential units in the 

project area. Seasonal aquatics technicians surveyed the units and streams during the 2014 and 2015 

summer seasons, walking through each of the proposed units and surrounding areas, recording any 

streams and wet areas that were encountered with a handheld GPS unit. Aquatics technicians also 

inventoried culverts and surveyed road conditions throughout the project area. Aquatics staff (hydrologist 

and fisheries biologists) visited the majority of the riparian units. In these units with primarily class 2 and 

3 streams, aquatics staff assessed Riparian Reserves to determine if ACSO’s were being met, and 

documented treatment and buffer needs. Photos of stands, GIS information and field data were utilized in 

discussion and development of site-specific prescriptions with the interdisciplinary team.

Existing data from the Willamette National Forest Geographic Information System (GIS) database was 

queried to provide stream density, road density, stand condition (age), riparian connectivity, special 

habitat locations, types of aquatic habitats, and fish distribution. . Aquatic specialists gathered data on 
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current and historic watershed condition from the Breitenbush Watershed Analysis and through GIS 

analysis of a USFS vegetation database (FSVeg) and high-resolution satellite imagery (WorldView2). 

Aggregate Recovery Percentage (ARP) was utilized to analyze effects of thinning on peak flow and 

standard observations of past activities within the watershed considered when determining effects to 

hydrology, stream channel, water quality and riparian conditions. 

Using existing road layers and proposed road changes, the hydrologist used the GRAIP-lite model of the 

GIS-based NetMap toolset to generate road-related sediment delivery (Benda et al 2007) estimates by 

alternative. Inputs to the model include slope derived from a 10-meter digital elevation model, NHD 

streams layer, roads (operational maintenance levels and surface type), and base rate of annual road 

erosion. Compared with the WEPP model, commonly used for road-sediment generation estimates,

GRAIP-lite tool provides more realistic estimates of sediment delivery. The GRAIP-lite model is also 

limited, however, in that it cannot be adjusted to reflect the effects of hauling traffic and comparisons 

between alternatives are more restricted to differences in miles of new or re-opened road, 

decommissioning or realignment of roads and any changes to maintenance level or surface type. The IDT 

used the 2014 Willamette Road Investment Strategy as a starting point to review road status changes in 

the planning area. Road segments that were modeled as having high aquatic risk and were not needed for 

future timber use (accessing plantations) were considered highest priority for decommissioning. Where 

future access was needed but not in the near-term, these high-risk roads and others were recommended for 

closure with additional monitoring and hydrologic stabilization. 

Changes to the affected environment and cumulative effects from the 2017 wildfires were analyzed using 

the 2500-8 Burned-Area Report (USFS, 2017). Modifications to the proposed project were considered for 

all treatment types in the areas affected by the fires and the suppression activities.

Alternative treatments were analyzed for their effects on hydrology, stream channels, water quality, and 

riparian conditions at various scales to assess both positive and negative effects and to predict progress 

towards desired future conditions. Analysis by aquatic specialists used a combination of field 

reconnaissance, GIS-based analysis, past management records, and professional judgment to evaluate and 

compare effects of the proposed actions at the local site, the 6th field sub-watershed and 5th field 

watershed scales.

3.4.3 Affected Environment

Watershed Hydrology

Landscape

The Breitenbush Watershed is a fifth field watershed under the 1994 Northwest Forest Plan Aquatic 

Conservation Strategy. The Breitenbush River is tributary to the North Santiam River, which joins with 

the South Santiam River near the confluence with the Willamette River, within the Columbia River Basin. 

The project area encompasses three sub-watersheds within the Breitenbush Watershed. The majority 

(63%, 19,743 acres) of the project area is in the sixth field Upper Breitenbush River sub-watershed. The 

South Fork Breitenbush River and North Fork Breitenbush sub-watersheds respectively make up 19% 

(5,994 acres) and 17% (5,204 acres) of the project area. Less than one percent of the project area includes 

small portions of the Humbug Creek, Lower Breitenbush and Cub Creek sub-watersheds.

The Breitenbush River flows westward from the center of the project area from the confluence of its 

North and South Forks in the eastern Marion County. Major tributaries of the Breitenbush include East 

Humbug, Fox, Scorpion, Short and Mansfield Creeks entering from the north and Leone, Hill, Devils and 

Skunk Creeks from the south. The drainages that form this portion of the watershed are typical, low to 
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moderate elevation, dendritic, stream systems. Many stream channels have been altered by both glacial 

and earthflow activity. These areas often contain a complex drainage pattern that parallels earthflows and 

fault lines. The Breitenbush River follows a fault line that is a conduit for the hot, hydrothermal waters of 

the Breitenbush Hot Springs at the upper end of the river below the North and South forks.

Stream Flow/Disturbance History

The hydrology of the Breitenbush Watershed is similar to other typical watersheds within the Western 

Cascades. The hydrology is dominated by rain inputs and snow/glacial melt from Mt. Jefferson and the 

High Cascades. Flows in the winter through spring generally average between 800 and 900 cubic feet per 

second (cfs) and begin to decline as snowpack and snowmelt diminish in June. Mean annual discharge for

the Breitenbush River is 621 cfs.

Peak flows are predominately generated by rain-on-snow events in the transient snow zone, which occur

between 1,200 and 4,900 feet elevation (Harr, 1981; Jones and Grant, 1996). Rain-on-snow events are 

considered the primary effect on peak flows. The transient snow zone covers approximately 88.6% of the 

Hwy 46 project area. Peak flows occur between October and May. While there is significant variability 

year to year in magnitude of peak flow, there are no noticeable trends of annual peak flows during this 

long period of record. The 2017 Scorpion and Little Devil wildfires are estimated to have increased peak 

flow rates minimally by 1.1 to 1.2 times (See Hydrology Report, Attachment A, available on the project 

webpage and in the project file at the Detroit Ranger District office).

With an average Aggregate Recovery now estimated over 90% and well over the threshold of concern of 

74%, the area’s sub-watersheds are moving into a vegetative condition that buffers the effect of snow 

accumulation. Snow accumulates in thinned areas in lesser amounts and therefore does not pose the same 

risk to rain-on-snow events. Regeneration harvest units (15-20 years old) still exist within the project

area, allowing accumulation of snow, but these plantations are growing at a rate expecting full recovery 

within 15 years. Currently, hydrology is responding well within its natural range with the existing 

vegetation components of the project area. This area includes the following sub-watersheds with 

corresponding thresholds of concern for Aggregate Recovery Percentage (ARP) within the Breitenbush 

Watershed:

Table 26 Aggregate Recovery Percentages Threshold of Concern

Subwatershed Subwatershed Acres Threshold of Concern % 

(midpoint ARP*)

Current Condition 

(2017*)

Upper Breitenbush 20,395 70-75 92.28

North Fork Breitenbush 16,254** 75 93.82

South Fork Breitenbush 13,082 73 95.47

* Midpoint ARP was originally calculated for subdrainages as part of the 1990 Willamette National Forest Plan. Under the 

subdrainage classification, the Upper Breitenbush split as the “Middle Breitenbush” and “Devil’s Creek” subdrainages. The 

average midpoint ARP was calculated from the subdrainages that fall within each subwatershed.

**While the total area of the North Fork Breitenbush subwatershed is 16,254 acres, only 10,935 acres are actually within 

Forest Service boundaries and have an available existing vegetation layer. The percent of watershed was calculated using the 

10,935 acres for which data was available.

Stream Channels

From the first order stream channels in the headwaters to the fifth order Breitenbush River, stream 

channels within the project area exhibit a dendritic pattern. Rosgen type A, B and C channels are present 

within the proposed project area. Type A channels are characterized by high gradient, transport channels 
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on valley walls and contain larger, volcanic substrates, whereas Type C channels occur in lower gradient, 

meandering sections of the Breitenbush River on alluvial and colluvial substrates. 

Type B channels are present in higher order channels such as Breitenbush River and Devils Creek that 

flow over cobble and small boulder substrates. Sediments typically move through these channels 

alternating between flow transport in higher gradients and deposition in lower gradients and by receding 

flows where channel obstructions, such as boulders and large wood, dissipate flow energies. Channel bar 

mobilization, stream bank erosion, and debris torrent activity from the steeper terrains feed streams with 

structure and sediment. The majority of the fine sediment is transported out of the system and into the 

Detroit Reservoir. Intense precipitation is episodic in nature, and often generates peak flows that are a 

major disturbance mechanism for stream channels and associated riparian areas in the project area. 

Stream channels in headwater streams are predominantly intermittent due to the lack of water and 

sediment storage. 

Level II stream surveys conducted in 2002-2014 found that in-stream large wood in the Breitenbush River 

was below pre-management levels and also low for all the surveyed tributaries (Byars, Devils, Humbug, 

East Humbug, Hill, Leone, Mansfield, Bummer, Horsetail and Short Creeks, and the North and South 

forks of the Breitenbush River). Large wood in streams is slowly improving through natural recruitment 

of fallen large conifers from unmanaged riparian areas, large wood restoration projects, riparian stand fall 

and leave projects and development of large wood adjacent to the channels. Over the last 20 years the 

riparian condition and channels are gradually recovering needed complexity due to natural processes, 

changed land management techniques, and an improved understanding of the importance of channel 

complexity. 

Forest Service aquatics technicians completed field surveys and GPS-mapped a total of 60.2 miles of 

stream channels in and around each treatment unit within the planning area. The field surveys and 

corresponding GIS work assure more accurate placement of buffers and Riparian Reserve prescriptions. 

Recorded and updated in the project GIS database are the following types of channels in context with 

treatment units in the Hwy 46 planning area:

• Class I and II– Public drinking water source or fish-bearing, perennial: 43.4 miles, 13%

• Class III - Perennial, non-fish bearing: 58.7 miles, 17.9%

• Class IV - Intermittent, ephemeral: 227.1 miles, 69.0%

Riparian Conditions

Approximately 43% of the entire project area (13,502 acres) is designated as Riparian Reserves. Present 

day riparian conditions are shaped by natural and human disturbances, including flooding, mass wasting, 

timber harvest, fire, and construction of railroads, powerlines and roads. 

There have been numerous large fires documented in the watershed back to 1900 including the largest of 

these, Firecamp Lakes Fire which burned 2,000 acres in 1914. The Humbug, Fox and Scorpion drainages 

have the most active fire history in the watershed (Garza, 1995). Depending on their size and intensity, 

these fires were disturbance mechanisms that contributed to the current riparian conditions, from diverse 

complex riparian areas that burned less severely, if at all, and dense monocultures in the stem-exclusion 

stage, naturally derived from high intensity stand replacing fires. Additional very recent fires during 

summer 2017 encompassed 1,783 acres in the Hwy 46 project area with 1,017 acres of those having a low 

to moderate soil burn severity and the remaining 764 acres in unburned condition. Within these 

perimeters, 1,275 acres were in Riparian Reserves within the Hwy 46 project area, again which were 

predominately unburned or low severity. Only an estimated 10 acres of Riparian Reserve were rated as 

moderate soil burn severity. 
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Past distrubances of fire and intensive timber harvest set today’s Riparian Reserves on a trajectory with 

high-density conifer-dominated stands. Riparian areas are dominated by Douglas fir with minor amounts 

of other conifers. Depending primarily on elevation and aspect, other conifers include western hemlock, 

western red cedar, noble fir, pacific silver fir, and grand fir. These riparian area include scattered areas of 

red alder and big leaf maple. Except for the lower reaches of the Breitenbush River which were logged by 

railroad, the larger streams in the watershed were largely excluded from regeneration harvests and remain 

in a more natural condition (Breitenbush Watershed Analysis, 1996). 

Within the project area, early-seral and late-seral vegetation is currently at the lower end of the natural 

range of variability (Breitenbush Watershed Analysis 1996). In late-seral stands, shrubs and herbs are reinitiated as conifers die and create gaps in the canopy. A recent study of riparian plant communities in 

northwest Oregon (McCain 2005) provides data on “relatively unmanaged” conditions. The study 

describes riparian and upland plant communities based on geomorphic features (e.g. in-channel, cobble 

bars, terraces, floodplain, etc.). On the “steep banks/terraces” and “high terraces/major floodplain” 

features common to streams in the project area, deciduous trees had typical percent cover values of 15 to 

64%. Valley cross-sections (300-foot riparian transects) on 3rd and 4th order “relatively unmanaged” 

streams in the west Cascades had a hardwood basal area of 7 to16 square feet/acre and hardwoods were 

present throughout the 300-foot transect. This study suggests that in “relatively unmanaged” riparian plant 

communities, there is typically a hardwood, shrub, and herb component. These deciduous and herbaceous 

species provide many benefits to riparian and aquatic ecosystems, including better food resources and 

higher productivity for aquatic invertebrates compared to conifer-dominated systems (Wipli et al 2007); 

increased nitrogen fixation, organic matter cycling, and soil fertility (Compton et al. 2003); and wildlife 

benefits. 

With a lack of both early- and late-seral vegetation classes that have a large deciduous and herbaceous 

component, it follows that these species are underrepresented on the current landscape. This is further 

supported by analysis of existing vegetation using high resolution satellite imagery. Aquatic specialists 

completed an analysis of the Breitenbush Watershed and project area Riparian Reserves using a GISbased WorldView2 Satellite Imagery and eCognition software analysis of the Breitenbush Watershed 

(Figures 34-35). WorldView2 imagery highlights areas of high chlorophyll production, which helps 

distinguish between deciduous and coniferous vegetation. Based on results of this analysis, approximately 

88% of Riparian Reserves in the Breitenbush watershed are conifer-dominant and 2% are deciduousdominant (trees and shrubs). Approximately 2% are mixed conifer and deciduous, and 8% are non-forest 

(Figure 34). 
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Figure 34 Vegetation classification of the Breitenbush Watershed using high resolution satellite imagery (Worldview) and eCognition software. 
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Within the scale of the Hwy 46 project area (Figure 35), approximately 91% of Riparian Reserves are 

conifer-dominant and less than 2% are deciduous-dominant (trees and shrubs) (Table 27). Approximately 

2.6% are mixed conifer and deciduous, which occur primarily in late-seral stands along the Breitenbush 

River. The results of this landscape-scale analysis reveal a very low abundance of deciduous species and 

are corroborated by surveys at the stand scale, where dense conifers dominate Riparian Reserves and 

there is often a lack of understory development and species diversity. Some portions of Riparian Reserves 

in previously unmanaged areas within the project area have higher structural and species diversity and are 

providing adequate stream shade, root strength and bank stability, sediment filtration and nutrient cycling, 

large wood supply to waterbodies and floodplains, organic matter input to waterbodies, and habitat for 

riparian-dependent wildlife. These riparian areas are found to be achieving ACS objective or are on close 

trajectory to doing so. These riparian areas serve as a reference of desired future condition, guiding 

development of riparian prescriptions.

Figure 35 Vegetation classification within the Riparian Reserves of the project area and sub-watersheds 

using high-resolution satellite imagery (Worldview) and eCognition software. 
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Table 27 Vegetation Class of Riparian Reserves within the Project Area

Vegetation Class Acreage in 

Project Area

Percent of 

Project Area

Acreage in 

Riparian Reserve

Percent of 

Riparian Reserve

Conifer 28,659 92% 12,268 91%

Mixed 534 1.7% 350 2.6%

Deciduous 348 1.1% 230 1.7%

Deciduous-Shrub 101 0.32% 43 0.3%

Other 1,586 5.1% 578 4.3%

Water 55 0.2% 34 0.2%

Of 1,458 acres of Riparian Reserve within the proposed (Alternative 2) units, 996 acres (68% have been 

harvested in the past, and are considered plantations. Approximately 462 acres (31%) are considered fire 

regenerated and have not been managed, though most of these are in similar condition to past 

regeneration harvested Riparian Reserves due to stand replacing fires around the turn of the century. 

Riparian stands proposed for commercial thinning treatment are a combination of plantations created after 

clear-cut harvesting and natural fire regenerated areas. All of the plantation stands and most of the older 

fire regenerated stands are considered to be in the stem exclusion structural stage. Riparian stands to be 

treated are considered to be in the stem-exclusion stage.

Relative tree densities and structural stages of stands are considered to be outside the range of natural 

variability. Stands are densely stocked and relatively young, averaging 68 years old (ranging from 26 to 

145 years old). Stand densities in the proposed units range from 75 to 397 TPA (trees per acre), averaging 

198. In contrast, research in the Coast Range and Western Cascades by Tappeiner et al (1997) and Poage 

and Tappeiner (2002) indicates that existing old growth stands developed with natural stand densities of 

40 to 60 conifers per acre. Pollock et al (2005) found that “riparian stands often develop in a much more 

open structure, such that stem exclusion is much less common and understory vegetation usually is 

present throughout the development of a forest.” Stem exclusion stands have dense crowns that block out 

light to the forest floor and limit understory species and structure development (Oliver and Larson, 1990). 

The trees are competing for sunlight, water, and nutrients causing reduced tree growth and vigor as well 

as limiting understory vegetation. Suppressed understories are mostly limited to shrubs and herbs with a 

few small trees scattered throughout. The existing lack of complexity and diversity may be limiting 

nutrient cycling, deciduous organic matter input to waterbodies, and habitat for riparian-dependent 

wildlife. 
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Figure 36 Example of overstocked, conifer dominant stand lacking structural and species diversity within 

Riparian Reserves (Unit 520). 

Aquatics specialists observed limited amounts of downed wood in Riparian Reserves that were field 

visited on the ground, however on the watershed scale, the amount of course woody downed debris is still 

within the range of natural variability. The DECAID Analysis (Appendix F) found that natural 

accumulations of down woody debris fall within the range of natural variability in the Breitenbush 

Watershed. Stand ages in parts of this project area indicate that fires were very prevalent in the last 70 to 

130 years; these fires were natural, human caused or management-induced. Older plantations with lower 

utilization standards retained considerable large down woody debris. Younger plantations, with 

commercially higher utilization standards, removed much of this type of woody material. The most recent 

plantations, which had down woody debris objectives, again began to accumulate larger material within 

riparian areas. 

In addition to streamside areas, riparian areas also include lakes and wetlands. Short Lake and Leone 

Lake are the only named lakes in the proposed project area. Both lakes have their origins as sag ponds 

created from depressions related to slump activity, Short Lake is managed as special use area for 

recreation, aesthetics and ecological values. The project area also contains three other small lake/ponds 

and numerous wetlands, including swamps, meadows, seeps and springs, which are mapped as Special 

Habitats (SHABs). Wetland areas are generally small in size and scattered throughout the project area. 

Most were created either by glacial or slump action. These naturally-formed features add to the 

complexity and value of groundwater systems.

In general, riparian conditions appear to be partially functioning and on a slow trend toward recovery for 

this Western Cascade environment. While riparian conditions are generally recovering into the natural 

range of variability from past management activities, riparian stands selected for treatment are low in 

structural and species diversity, limited in large wood and would benefit from restorative treatment.
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Water Quality: 

Water quality is generally high and of high value, in part due to hyporheic flow, for most of the streams 

associated within the project area. Stream banks and floodplains are generally well vegetated and stable. 

Surface waters mix with groundwater in the inter-gravel flow (hyporheic zone). Water quality parameters 

monitored in the project area have been found to fall within the natural range of variability for West 

Cascade streams. Sediment and water quality conditions are recovering from past timber harvest 

activities, though naturally occurring landslides and debris flows in unstable areas of the watershed are 

chronic sediment sources to some streams and downstream waters. Geothermal areas provide unique 

hydrology to a few locations in the valley bottoms along the Breitenbush River. Hot and highly 

mineralized water surfaces as seeps or springs these areas. 

The Oregon Department of Environmental Quality currently lists portions of the Breitenbush River and 

South Fork Breitenbush River as water quality impaired (303(d) listed). These segments were submitted 

in 2010 by DEQ to the Environmental Protection Agency (EPA) and approved. At this writing, no TMDL 

has been approved by EPA for these listings, so they are considered Category 5: 303(d), TMDL needed. It 

is anticipated that the lists may change during the NEPA and implementation timelines of this project, due 

to ongoing legal disputes. The Breitenbush River from the mouth to river mile 12.2, and the South Fork 

Breitenbush River, from its mouth to river mile 1.6 are listed for Biological Criteria. The Biological 

Criteria listing indicates that the waters are not of sufficient quality to support aquatic species without 

detrimental changes in the resident biological communities. This assessment is based on a single benthic 

macroinvertebrate sample collected in 1999 in the reach not having a representative number of taxa 

present as compared to a regional reference condition. The South Fork of the Breitenbush River, from 

mouth to river mile 9.4 is listed for sedimentation, based on a single sample collected in 1999.

The Breitenbush is a domestic water supply, considered to be of high quality and value to the Breitenbush 

Community and City of Detroit, downstream of the project area. Wells also supply water to the Humbug, 

Cleator Bend and Breitenbush Campgrounds up river from these municipalities. The City of Salem uses 

the North Santiam River below Detroit Dam as its primary public water drinking water supply. The 

Breitenbush River is a major tributary of the North Santiam River contributing to Salem’s municipal 

water supply. 

Stream Shade and Temperature

Past harvest near stream channels increased solar radiation inputs and caused subsequent increases in 

thermal loading of streams. Past harvest has affected approximately 67% of the Riparian Reserve network 

within the project area. Past harvest practices involved removal of all vegetation. Increased water 

temperature resulted until such time that shade recovered with regrowth on the site. Today, much of the 

streamside shade in the previously harvested units of this project area is currently functioning in early to 

mid-seral vegetation conditions. Many of these areas are now light limited due to closed canopies and 

primary production in steams may be limited by light exclusion. 

Existing condition for temperature in the project area varies widely, attributable to differences in 

geomorphology, stream channel orientation, and position in the landscape. Stream temperature data were 

collected at 10 locations in the project area during the summer months (June through September). The 

data were collected for a minimum of two seasons with a maximum of 10 seasons. A summary of the data 

for the Breitenbush Watershed is provided in the hydrology report. Changes in the range of maximum 

temperatures from one water year to the next are attributable to inter-annual differences in precipitation 

and stream flows. Region-wide low winter snowpack and spring rains in the 2015 water year led to low 

stream flows and subsequent increased stream temperatures, for many streams. The annual timing of the 

maximum temperature occurred between July and August in all instances. This suggests that any past 
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management impacted only the increased value for maximum temperature and has not affected interannual variability or annual timing of peak temperatures.

No streams in the Breitenbush Watershed and Hwy 46 project area are currently have been listed as a 

“303d” water quality limited water body for stream temperature. However, the Willamette National Forest 

does still follow the guidance of the Willamette TMDL Water Quality Restoration Plan (2008) and 

Northwest Forest Plan Temperature TMDL Implementation Strategies (2012) to protect stream shade and 

improve stream temperatures in the Willamette Basin. 

Sedimentation

Existing sources of sedimentation in streams include hillslope erosion, mass wasting, and road-related 

erosion. The stability of hillslopes and stream channel banks are closely tied to the water quality of the 

project area. The majority of the geologic terrain and soils within the Hwy 46 proposed treatment units 

are not inherently prone to extensive erosion due to high infiltration limiting overland flow unless 

disturbed as discussed in the Soils Specialist Report (located in the project file). Past timber harvest 

methods resulted in compaction levels varying from 12 to 16% for most of the units of harvested with 

ground based logging systems. However, four units exceeded the 20% maximum allowed by the Forest 

Standards and Guidelines (Soils Specialist Report). With increasing levels of compaction, there is an 

increased risk of surface erosion due to greater overland flow and less infiltration.

Unstable land types were considered when designing the boundaries of the treatment units and buffers. 

Stream channels generally transport mobilized sediments into the Detroit Reservoir where the majority 

settles out. However, fine clay particles can persist as turbid waters in the Breitenbush River. Intensive 

studies in the late 1990s on suspended sediment and turbidity in the Breitenbush River were conducted by 

the US Geological Survey, the Forest Service, the Pacific Northwest Research Station, State University 

researchers and Washington D.C.’s General Accounting Office. The joint effort found hydrated clays 

(smectite) originating from the toes of earthflows and older and weathered Miocene and Oligocene period 

basalt and andesitic lithologies in the East Humbug, Short, and Mansfield Creeks to be the main source of 

sediment and turbidity (Uhrich & Bragg 2003). During larger flood events, these suspended sediments 

can persist in the river past Detroit Dam down to the Pacific Ocean. 

The 2016 water year in particular was marked by a noticeable increase in turbidity in Short Creek and 

Cultus Creek, both contributing the Breitenbush River and further downstream. Field reconnaissance by 

the Soils Scientist confirmed the re-activation of the Short Creek slump and a subsequent massive debris 

flow that will continue to contribute fine sediments downstream in future years. The numerous slope 

failures in this area of Short Creek recently and over the last 150 years are deemed naturally occurring, as 

no active land management has occurred in that area (Shank, 2013). Additionally in early 2016, another 

new slide occurred in the watershed contributing considerable turbidity to Breitenbush River. Field 

reconnaissance by the Soils Scientist also found the turbidity source of landslide activity in the upper 

Cultus Creek drainage, encompassing about 5 acres of hillslope. Analysis of past aerial photos indicated 

that this area had a history of instability and timber harvest (Shank, 2016). Both of these recent slides are 

anticipated to deliver sediment downstream and contribute to turbidity over the next decade or more. 
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Figure 37 Recent Short Creek debris flow, about mid-way up. Photo by J. Sheahan Alonso, 5/27/2016

The 2017 Fires increased sediment erosion rates by 1.7-3.8 percent in the burned area perimeters. Postfire analysis of sediment delivery potential to streams was conducted based on ratings of Soil Burn 

Severity. Areas of Moderate to High SBS and steep slopes increase the potential for overland flow and 

delivery of sediments into streams within Riparian Reserves, however with less than 10 acres across the 

three fires burning in Riparian Reserves at a severity of moderate or higher, there is minimal potential 

increase in overland delivery of sediments to streams in the Project Area. There is a slightly increased 

hazard of debris flows in the Little Devil fire perimeter (See Attachment A: Hwy 46 Detailed Post-Fire 

Hydrology Analysis, available on the project webpage and in the project file at the Detroit Ranger District 

office). 

Road-stream crossings can also provide direct contact with the channel and direct pathways for sediment 

movement to stream channels. Road crossing failures and streams running down earthflows or slumps 

cause pulses of sediment that move downstream and eventually reach mainstem channels and the Detroit 

Reservoir. Poorly designed placement of roads historically and limited maintenance of a few roads, has 

led to road-related sediment delivery due to inadequate drainage spacing or blocked culverts and 

subsequent concentration of runoff and road surface erosion. Road maintenance reduces the risk 

associated with these crossings by cleaning the inlets and preventing crossing failures. Road maintenance 

is a high priority for management located in the East Humbug, Short, Mansfield and Devils Creek 

drainages.

Since implementation of the Forest Plan in 1990, road maintenance activities have worked to eliminate 

many of these unstable fill situations. Even so, roads continue to be a large source of human-caused 

sedimentation in the project area. A few old roads still carry water during winter storm events essentially 

extending the stream system and occasionally diverting flow from natural stream channels. Additional 

impacts to streams within the project area include failing culverts and displacement from steep road 

headwalls. Road densities over 3.5 miles of road per square mile are considered “Not Properly 

Functioning” (FEMAT 1993). Sub-watershed road densities in the project area range from 1.70 to 5.15 

miles per square mile. The Lower Breitenbush River Sub-watershed exceeds the threshold for properly 

functioning, but only 1% of the sub-watershed is within the Hwy 46 Project Area.
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Table 28 Road Densities by Sub-watershed

Sub-watershed Acres Square 

Miles

Percent of Subwatershed in Planning 

Area

Road Density 

(mi/mi2)

Upper Breitenbush River 20,395 31.87 96% 3.42

South Fork Breitenbush River 13,082 20.44 32% 1.35

North Fork Breitenbush River 16,255 25.40 46% 1.70

Lower Breitenbush River 9,203 14.38 1% 5.15

The GRAIP-lite tool in the NetMap roads GIS toolset was also used to analyze road sediment production 

and delivery to streams. Estimated sediment from the GRAIP-lite model for existing roads in the Hwy 46 

project area and haul roads extending out of the project area is approximately 95 cubic yards of sediment 

delivered to streams per year. In comparison, the 1999-2000 USGS study of turbidity and suspended 

sediment estimated an annual load of 20,100 tons for Breitenbush River (Uhrich & Bragg, 2003). ). The 

2017 Fires, are estimated to have increased overall road-related sediment delivery to streams in the 

project area by 6 tons/year for the first 2-5 years following the fire. The wildfire suppression activities 

involved re-opening and blading some previously closed roads, with some drainage and sediment delivery 

concerns. (See Attachment A: Hwy 46 Detailed Post-Fire Hydrology Analysis, available on the project 

webpage and in the project file at the Detroit Ranger District office).

3.4.4 Environmental Consequences

Unless otherwise noted, the geographic scale used to assess direct, indirect and cumulative effects for 

aquatic resources includes the project activity units, the project area and the Upper Breitenbush, South 

Fork Breitenbush and North Fork Breitenbush sub-watersheds. 

Direct and Indirect Effects

Stream Flows/Disturbance

Alternative 1 – No Action 

Implementation of the no action alternative would maintain managed timber stands that do not have a live 

crown ratio (percent of the tree with limbs) sufficient to reach full potential across the landscape, 

including riparian areas. The stands would experience reduced growth rates due to competition as 

transpiration rates decrease due to loss of canopy crown diameters. This could result in potential increase 

in summer flows due to the decline in the stands ability to utilize available water. There is a higher 

likelihood of reduced tree health, which limits the ability of tree crowns to intercept and hold snow 

increasing the risk for tree damage and breakage by snow load accumulation. Infiltration rates would also 

be affected by the loss of canopy and the drip that occurs from snow interception. Reduced canopies are 

more exposed to latent heat transfer and rapid snow loss, which reduces the contact time the water stored

in the snow, has with the soil (Harr, 1981). However, changes in surface flows would be very small and 

immeasurable. With ARP values projected to remain well above Midpoint, Alternative 1, No Action, 

would result in no changes to existing peak flows based on vegetation removal. However, lack of density 

reduction and fuel treatments of overstocked stands would retain an increased risk of high severity 

wildfire or disease outbreaks. High severity wildfire or disease outbreaks on the watershed level would 

have the potential to increase peak flows in the 3 to 5 year period following the event.
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The meadow in Unit 32a would not be treated for restoration. Lack of treatment would result in continued 

growth of existing trees and encroachment of younger conifers. Subsequent reduction in available light 

from shading and water from increased evapotranspiration to herbaceous meadow species would further 

the loss of the meadow habitat. Over time in the absence of treatment or natural disturbance, the meadow 

would successionally advance to a forested condition all together.

The no action alternative would maintain the effects of past artificial disturbance mechanisms, road 

crossings, and associated ground disturbances. Several miles of roads are in poor condition and funnel 

water to stream crossings or into alternative drainages. Road maintenance activities that prevent the road 

prisms from becoming sediment sources would largely be deferred. Without maintenance, road drainage 

facilities such as culverts would continue to degrade the natural hydrology near road systems within the 

project area. At the fifth field watershed scale, hydrological effects are anticipated to remain within the 

existing natural range of variability.

Alternative 2 

Under Alternative 2, thinning stands would change the hydrology by reducing competition for light, 

water, and nutrients in the thinned stands. There would be increased snow accumulation on the thinned 

acres, roads and landings. A short-term (5 to 10 years) increase in discharge during the wet and the dry 

periods would occur as a result of thinning. Increased snow accumulation (wet period) would create small 

increases in peak flows (Jones, and Grant, 2001), and reduced canopy (dry periods) would reduce 

transpiration rates which could account for small increases in summer flows. These potential changes in 

discharge and peak flow are not likely to create detrimental effects and would likely be immeasurable due 

to the limited spatial extent and type of thinning treatment (Pike and Scherer 2003). 

Early seral habitat creation, gaps, shelterwood cut, and meadow restoration activities have greater 

reductions in canopy closure than thinning. Effects of canopy closure reduction include: reduced 

interception and transpiration, increased snow accumulation, runoff associated with rain-on-snow and 

water storage, and increased availability of water and nutrients for remaining trees and other vegetation.

Under Alternative 2, meadow restoration in Unit 32a would remove encroaching conifers to enhance 

habitat for wet meadow vegetation species, pollinators and wildlife. Approximately 3 to 5 trees per acre 

would be retained, along with the largest relic trees. Opening of the canopy would reduce canopy 

interception of precipitation, retain snowpack longer into the spring, and reduce evapotranspiration from 

shallow groundwater, leading to increased storage and duration of available shallow groundwater to 

support meadow vegetation. The resulting hydrology of the meadow is anticipated to be characteristic of 

seasonally saturated herbaceous slope wetland with increased saturation of soils from precipitation and 

snowmelt and decreased transpiration loss. A small intermittent stream channel near the middle bottom of 

the unit would correspondingly also experience longer duration stream flow, though it would still remain 

intermittent. Channel stability of the intermittent stream is not expected to change as portions of the 

stream where the channel becomes incised are buffered from tree removal and runoff is anticipated to be 

muted by increased storage. 

Understory Habitat Enhancement treatment in units 54, 82, 89, 92, and 560 would thin conifers less than 

7 inches dbh to reduce shading of ground vegetation. Felling will be done by hand, no material would be 

removed from site, and there will be no overstory removal. Therefore, no hydrological effects are 

anticipated from this treatment. 

Instability, displacement, compaction, and nutrient loss are the main soils and geology impacts with 

potential to affect hydrology in the project area. Hydrology effects from these vary with the most 
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important being the movement of water through subsurface and surface zones. Any change in the 

characteristics of these zones could influence the rate and ability of the water to enter the shallow water 

table. Use of design elements during implementation would either avoid or minimize effects to soil to 

keep them below thresholds established in the Forest Plan, in this case, less than 20% of a treatment area. 

Correspondingly, subsequent effects on hydrology would be localized and not readily apparent when 

scaled to the watershed area. 

To prevent subsurface flow from surfacing in swales by ground based thinning and piling activities, prebunched log piles would be staged at least 50 feet away from ephemeral swales and channels. Any 

crossings with ground based equipment would be perpendicular to stream channels and swales as 

designated. Under Alternative 2, 16 ground based crossings of have been identified to facilitate removal 

of wood from treated areas. These crossings would cross small intermittent streams, no perennial streams 

would be skidded across. Temporary placement of bunk logs and slash will be utilized to facilitate 

skidding of logs without doing damage to stream banks and channel bottoms. This work will be done in 

the dry season when there is no or reduced flow in these channels and all logs and slash will be removed 

from channels prior to the next wet season. From the intermittent crossing locations, there may be a small 

flush of fine sediment (1/2 cubic yard or less) during the first winter flow after treatments have occurred, 

but due to the amounts of slash following harvest, the effect would be localized with downstream 

sediment movement staying under 100 feet from each crossing. 

Skid trails, landings, yarding corridors and roads serve as compacted surfaces, locally reducing soil water 

infiltration and increasing surface runoff and downslope erosion potential. As the Soils report specifies, 

new road construction and re-opening of temporary spur roads would marginally increase road densities 

in the short-term. This would be a slightly greater increase for Alternative 2. Decommissioning an 

additional 8.88 miles of road in this project would reduce sub-watershed densities by 0.21 miles per 

square mile in the Upper Breitenbush River Subwatershed and 0.07 miles per square mile in the North 

Fork Breitenbush Subwatershed. Additionally, 4.07 miles of currently open roads would be closed, yet 

retained on the system for future use. Roads to be closed that have high aquatic risk for stream channel 

diversion potential or stream crossing failure would be hydrologically stabilized with waterbars and 

pulled culverts as needed.

Following harvest, most commercially thinned units will be underburned to treat slash and reduce fuel 

loading. Fire intensities will vary with fuel loading within the units, but could reach high intensities. Loss 

of vegetation, in addition to timber harvest can decrease precipitation interception and increase runoff. 

With acceptable mortality in overstory trees of 0-10% from, overstory canopy closure could be reduced 

slightly more than just reductions from the thinning treatment alone. In the sugar pine treatment stands 

where a more open canopy is part of the objective, overstory mortality could be higher (5-15%). 

Understory and ground cover vegetation will be reduced immediately but will grow back quickly in the 

near-term. With duff retention standards in place, underburning will have minor effects to soils. A 

mosaic-like effect of reduced understory vegetation and duff on the forest floor is anticipated. Ignition of 

the underburns would take place outside of Riparian Reserves, providing some buffer of undisturbed 

ground cover between the burned areas and the streams. In considering the negligible to minor effects of 

underburning to canopy closure, understory cover, and soils condition, is not likely that changes to 

hydrological processes of interception and runoff would be measurable nor would they create detrimental 

effects (Pike and Scherer 2003). Effects to runoff would be similar for hazardous fuels reduction 

treatment. No effects to runoff are anticipated from pile burning treatments due to the low acreage of 

affected ground.
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Stream flow changes anticipated are well within the variation of normal flows and should not generate a 

condition that the channel has not responded to through time. Short-term changes may be evident in the 

time of peak and the duration of flow throughout the year due to changes in transpiration rates and routing 

of flows. These changes are short lived until such time that the stand closes canopy and utilizes the 

available water for the site. These changes would be more likely in drainages with more intensive 

treatments, such as in Unit 32a where the goal is to restore meadow hydrology. Such short-term changes 

in localized drainages are still minor and not anticipated on a subwatershed scale. With the area’s 

recovery percentage currently well above the threshold and minor reductions in post-treatment ARP 

values, no altered peak flow changes are anticipated from the implementation of the proposed actions. 

Current vegetative conditions in the North Fork Breitenbush and South Fork Breitenbushall three 

subwatersheds exceed 15 points above the Aggregate Recovery Percentage (ARP) midpoint threshold. 

Exceeding the ARP threshold by 10 points means that sub-watershed canopies are considered fully 

recovered and that cumulative effects are not anticipated for rain-on-snow events, or for the overall 

hydrology of the sub-watershed. With site-specific prescriptions, it is not anticipated that these actions or 

any reasonably foreseeable future action would create an adverse downstream effect.

Table 29 Aggregate Recovery Percentages by Sub-watershed

Subwatershed

Subwatershed 

Acres

Average* Threshold of 

Concern % 

(midpoint ARP)

Alt 1 

(No Action) Alt 2 Alt 3

Upper Breitenbush 20,395 74.3 92.28 88.19 89.32

North Fork Breitenbush 16,254 75 93.82 90.61 90.61

South Fork Breitenbush 13,082 73 95.47 94.75 94.75

* Midpoint ARP was originally calculated for subdrainages as part of the 1990 Willamette National Forest Plan. Under 

the subdrainage classification, the Upper Breitenbush split as the “Middle Breitenbush” and “Devil’s Creek” subdrainages. 

The average midpoint ARP was calculated from the subdrainages that fall within each subwatershed.

**While the total area of the North Fork Breitenbush subwatershed is 16,254 acres, only 10,935 acres are actually within 

Forest Service boundaries and have an available existing vegetation layer. The percent of watershed was calculated using 

the 10,935 acres for which data was available.

In conclusion, variably thinning stands and local disturbances by proposed project activities are 

anticipated to cause small scale, minor changes well within the natural range of hydrological variability. 

Due to the design elements that avoid or limit impacts, implementing this project is expected to produce 

little, if any effect to the hydrology of the project area under Alternative 2. 
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Alternative 3 

Compared to Alternative 2, Alternative 3 treats almost 500 fewer acres, does not commercially thin in fire 

regenerated stands, and does not restore the meadow in Unit 32a. Alternative 3 has less ground 

compaction and disturbance from reduced harvest acreage and a slightly lower road density during 

implementation than Alternative 2. Post-implementation road densities would be the same for Alternative 

2 and 3, which are lower than Alternative 1 due to decommissioning of 8.88 miles of road. ARP 

percentages would be equal to Alternative 2 for the South Fork Breitenbush and North Fork Breitenbush 

sub-watersheds, and within 1.2% for the Upper Breitenbush sub-watershed. Given similar or less impacts 

as compared to Alternative 2 and use of the same design elements, the effects of Alternative 3 are 

similarly expected to produce little, if any effects to the hydrology of the project area.

Riparian Conditions

Alternative 1 – No Action 

Under the no action alternative, riparian conditions would develop the characteristics of structure, 

openings and down wood naturally over time (decades) and would maintain a higher overstory canopy 

cover than the action alternatives in the near term. A higher canopy cover prohibits sunlight to penetrate 

lower canopy levels and the forest floor. It suppresses the vigor and growth of individual large trees, 

vegetation development in the understory and future recruitment of structural wood in stream channels. 

Reduced vigor occurs due to the increased competition and damage that may occur from snow or insects. 

Higher canopies naturally break open over the long term (>100 years) when lower canopy development is 

anticipated to recover. 

Future recruitment of large trees in stream channels is an integral component of riparian diversity, quality 

aquatic habitat and structural integrity. Current rates of large wood recruitment, provided mostly by stem 

mortality (from competition, disease, wind and snow downed trees) and bank erosion, would be 

maintained. Alternative 1 would provide a slightly higher rate of in-stream wood recruitment compared to 

the action alternatives. The no action alternative would protect 100% of the wood recruitment zones. In 

some streams, recruitment trees are of sufficient size to meet ACS Objectives (Appendix E), but in other 

streams with small diameter riparian stands the aquatic benefit is limited, namely through the reduced 

ability to store sediment and organic matter and contribute to habitat forming processes (e.g. scour). 

Though small wood has some value, particularly in the smaller headwater reaches, the longevity of 

recruited small diameter trees is short-lived, as they break down through abrasion and decomposition 

more rapidly compared to large trees. Small diameter trees are also more likely to be transported out of 

the system. In-stream wood abundance is low for most streams in the project area and is largely due to 

past management, historic flooding, and the lack of large enough sized wood to remain stable in channels. 

It is anticipated that the no action alternative would have little effect on the long-term objective to create 

stand diversity and shade due to the natural growth and the resiliency of the stands to respond to change. 

However, the rate of change would be slower for stand diversity and complexity development within the 

short term (<100 years). Desired riparian conditions – high species and structural diversity with large 

dead and down wood – would slowly develop over time (several decades) and depend solely on natural 

thinning events (stem exclusion mortality and disturbance). Without management to increase the 

abundance of deciduous and herbaceous vegetation in dense, conifer-dominant stands, ecosystem 

productivity would remain at relatively low levels. Accelerated restoration of riparian stands that 

currently don not meet ACS Objectives would not be accomplished.
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In addition, the currently dense riparian stands would be at greater risk to high severity fire, insect 

infestation, and disease – all carried more efficiently through overstocked stands. Although these are 

natural disturbance processes that contribute to forest habitat and diversity, a large disturbance event, or 

one of high severity, has the potential to reduce vegetation, large woody material, and stream shade across 

large areas of Riparian Reserves. Research conducted in the Pacific Northwest has shown that while fire 

severity may be lower along perennial streams due to relatively cool and moist conditions, fire severity 

along intermittent streams can be similar to adjacent upland areas (Tollefson 2004). In fact, under some 

circumstances, riparian areas can become corridors of increased fire spread (Pettit 2007).

Alternative 2 

The Northwest Forest Plan (NWFP) prohibits timber harvest in Riparian Reserves except as needed to 

control stocking, reestablish and manage stands, and acquire desired vegetation characteristics needed to 

attain ACS Objectives (NWFP Standards and Guides, TM-1(c)). Riparian reserves make up 

approximately 36% of the area within the proposed units (1,458 acres). Landscape and stream reach 

assessments, coupled with field reconnaissance, indicate that current conditions of the Riparian Reserves 

on the watershed scale are outside the natural range of variability, with many areas are not meeting 

desired vegetation characteristics needed to attain ACS Objectives. Of 1,458 acres of Riparian Reserve 

within the proposed units, 996 acres (68%) have been harvested in the past as plantations. Approximately 

462 acres are fire regenerated and have not been managed, though most of these are in similar condition 

to past regeneration harvested Riparian Reserves due to stand replacing fires around the turn of the 

century. Therefore, there is a need to manage parts of the Riparian Reserves to accelerate attainment of 

desired conditions. Other areas, however, are currently meeting desired vegetation characteristics and 

management is not necessary. In some cases, maintaining and/or restoring each one of the ACS 

Objectives can be a balancing act with trade-offs. For example, to meet the riparian vegetation objectives 

(“species composition and structural diversity of plant communities” and “habitat to support well 

distributed populations of native plant, invertebrate and vertebrate riparian dependent species”) in young, 

dense conifer stands, a common silvicultural tool is to remove overstory density to encourage understory 

growth and structural development. Removal of overstory density, however, could potentially lead to 

increased thermal loading or reduction of wood volume available for recruitment. Because of these tradeoffs, we carefully balance conflicting objectives based on watershed conditions and characteristics of each 

waterbody and adjacent riparian area. 

Alternative 2 proposes both active and passive management of Riparian Reserves: thinning, gap creation, 

down wood augmentation, and no treatment. Within Riparian Reserves, stand-specific treatments were 

prescribed by the Silviculturist in consultation with the District Hydrologist and Fish Biologist and are 

listed in the Design Elements in Chapter 2. Stand treatments promote variable density within and among 

stands, including Riparian Reserves, by leaving skips, varying thinning intensities, and introducing gaps

in selected stands (see the Silviculture Report). Within Riparian Reserves, no-treatment buffers protect 

stream shade, bank stability, large wood recruitment and other riparian processes; outside of the buffers, 

treatments in Riparian Reserves are designed to meet or accelerate meeting ACS objectives. Unit design 

elements developed by the interdisciplinary team directed the management action and the protection 

needed to accomplish resource goals.

Within Riparian Reserves, stand treatments under Alternative 2 would be consistent with the Aquatic 

Conservation Strategy by increasing structural and biological diversity and developing large conifers. 

Across the landscape, including Riparian Reserves within the Late-Successional Reserve, stands would be 

on an accelerated trajectory for developing late-successional conditions by developing multiple canopy 

layers and larger trees. Improvement in stand health would also reduce the likelihood of catastrophic fire 
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that could remove entire portions of the landscape and negatively affect watershed stability and its ability 

to provide high water quality and fish habitat. Appendix E discusses how Aquatic Conservation Strategy 

Objectives will be met with the project. Following are descriptions of the types of treatments proposed 

and the considerations for analysis with each.

Thinning in Riparian Reserves

Under Alternative 2, thinning treatments are proposed for Riparian Reserves to meet the objectives 

related to this project. Riparian Reserves represent 36% of the 4,046 acres of stands proposed for 

treatment under Alternative 2. Approximately 708 acres of the 1,458 acres of Riparian Reserves (49%) 

would be variably thinned to meet project objectives, representing 5.2% of the Riparian Reserves in the 

Project Area. Thinning intensities would match the prescription for the rest of the unit, and would retain 

canopy closure well above 50% in all stands. Where riparian areas are developing the needed 

characteristics naturally, no thinning was prescribed. Riparian Reserves that were found to be achieving 

or near achieving ACSO’s are fully buffered to the first site tree potential height (172 feet).

The body of literature on the effects of thinning on stream and forest ecosystems is quite extensive. The 

interdisciplinary team considered several key factors in determining where this type of treatment would 

be beneficial for the attainment of ACS objectives. In-stream wood recruitment, upland down woody 

material levels, stand structure, and species composition are described below. Stream temperature, 

sediment, riparian microclimate, and other factors are described in the sections below. Alternative 2 

would treat approximately 781 acres within Riparian Reserves. Appendix G details where treatments are 

proposed within Riparian Reserves and the vegetation objectives for each unit in Alternative 2 and 3.

Stand Structure and Species Composition

Based on a review of existing literature and stand development theory, Spies et al. (2013) found that the 

“greatest potential ecological benefits of thinning to accelerate the development of older forest structure 

(e.g. large trees, large dead trees, spatial structure and compositional heterogeneity, etc.) come in dense 

uniform plantations less than 80 years and especially less than 50 years old.” The benefits of thinning in 

stands over 80 years old are more variable. Stand conditions were reviewed for each waterbody and 

recommendations were based on multiple variables, not just age. These factors included tree height and 

diameter, stand density, species composition, and understory development.

Most stands where thinning would occur within Riparian Reserves are under 80 years old (73%), 

however, 187 acres of Riparian Reserves in stands aged over 80 years old would be thinned in Alternative 

2. Appendix G provides a detailed description of Riparian Reserve treatments by unit, including rationale 

for treatment, the no-harvest buffer widths, and stand age. Where thinning is proposed within Riparian 

Reserves, increases in abundance of understory vegetation, species diversity, stand structural diversity, 

and tree growth at a faster rate than background levels are expected. Some modeling has shown that 

young conifer stands, if left untreated, would follow a trajectory towards forest structure found in certain 

reference conditions (Pollock et al. 2012); Reference conditions were considered to have mature, latesuccessional conifer dominated stands with abundant large trees in the overstory, abundant large snags, 

and a well-developed understory of shade-tolerant trees. However, according to Harrington et al. (2005) 

thinning tends to increase shrub cover and greatly increase within-stand variability where shrub cover is 

absent before treatment. Riparian thinning can also promote the development of late successional forest 

attributes of value to many riparian and upland-associated species (Pabst et al. 2008, Harrington et al. 

2005). Based on recent research (Ruzicka et al, 2014), increased tree growth within no-treatment buffers 

adjacent to thinned stands has been shown to occur. In their study, trees responded to an apparent edge 

effect up to 15 m (49 feet) downslope of thinned areasand we it expect to have similar beneficial effects 
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within in no-treatment buffers. Because Alternative 2 has more thinning in Riparian Reserves than 

Alternative 3, 709 and 528 acres respectively the benefits in Alternative 2 would be greater.

In order to add additional structural complexity, vegetative diversity, and habitat diversity to stands, some 

of the Riparian Reserve stands proposed for thinning also have small gap creation, totaling approximately 

2 acres. These small 1⁄4 acre gaps would increase stand diversity and productivity, enhancing terrestrial 

habitats, which are also a component of the ACS objectives (see Wildlife Section and Appendix E). These 

gaps are planned primarily outside the Riparian Reserves but may have portions extending into the outer 

Riparian Reserve beyond the secondary shade zone. Table 10(Chapter 2, page 43) shows a list of these 

proposed units.

In-Stream Wood 

In-stream wood is important to the health of aquatic habitats, and many researchers have studied the areas 

along streams where wood recruitment typically occurs. Wood recruitment zones vary from as little as 8 

meters (26 feet) up to about 45 meters (148 feet) depending on various factors (Benda and Bigelow 2014, 

Spies et al. 2013). According to Benda and Bigelow (2014), wood source areas are highly variable, but 

are strongly correlated to tree height and the dominant wood recruitment process for each stream reach. 

They found that in managed forests of the Cascades Range, where bank erosion and tree mortality are the 

dominant wood recruitment processes, 90% of in-stream wood originated from within about 8 meters (26 

feet) of stream channels and the remaining 10% is supplied from a distance equivalent to one tree height. 

Figure 38 shows the source distance curves for wood in Benda and Bigelow (2014). In less managed and 

unmanaged forests, 90% of in-stream wood originated from about 13 meters (43 feet) of stream channels.
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Figure 38 Source Distance Curves for Study Area (Benda and Bigelow 2014)

Meleason et al. (2003) used the simulation model OSU STREAMWOOD to evaluate the potential effects 

of different riparian thinning scenarios on wood recruitment to streams over time. In one scenario, they 

modeled the contribution of wood from forest plantations (up to 120 years old in a Douglas-fir – western 

hemlock forest), beyond no-harvest buffers of varying widths. The results suggest that no-harvest buffers 

greater than 10 meters (33 feet) from the stream channel contributed minimal amounts of wood volume to 

streams. In a similar study that modeled effects of no-harvest buffers of 10 meters, as well as effects of 

single and double entry thinnings with no stream buffer and tree-tipping at various rates, Benda et al 

(2015) found that a 10-meter buffer maintained 93% of the in-stream wood in comparison to no 

treatment. This percentage increased and eventually was nullified by tipping up to 12% directly into the 

streams.

Burton et al (2016) evaluated the effects of buffer width from repeated forest thinning treatments on wood 

loading in small headwater streams of previously managed stands. The streams with the smallest buffers 

of 6 meters had the greatest volumes of large woody debris recruited, as compared with the streams that 

had 15 meters and 70 meters. The unexpected finding that smaller buffers led to more recruitment is 

thought to be due to reduced competition leading to increased growth of trees outside of the buffer, as 

well as increased growth of trees within the buffer due to increased side-lighting. Contributions of slash, 

tree tops, etc. from harvest operations may also account for some of this. Burton et al found that the 

majority of wood recruitment appears to come from within 15 meters of the stream channel, in addition to 

other sources upstream that are delivered by mass wasting events and re-distribution. Burton et al 
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suggests thoughtful consideration of applying silvicultural treatments within the first site tree potential of 

streams to increase large wood to channels and use of more proactive directional felling techniques to 

accelerate large wood recruitment.

Figure 39 From Burton et al (2016) Effect of wood volume recruitment to small channels by width of noharvest buffer

In all of the proposed riparian thinning stands, an area near the stream was designated as a no-harvest 

buffer to protect wood recruitment zone, channel stability and other riparian values. The overall goal for 

developing wood recruitment zones was to protect 90% of the trees that could potentially be recruited to 

the stream channel. This level of future wood input is thought to be sufficient to sustain physical 

complexity and stability required by the ACS Objectives while allowing for treatments to improve 

vegetation and accelerate the growth of future in-stream wood. This no-harvest buffer ranges in width 

depending on specific conditions in each unit (i.e. site stability, width and gradient of stream, vegetation 

characteristics, etc.) and by stream type (i.e. seasonally flowing streams, perennial non-fish bearing 

streams, and fish bearing streams). Because all perennial waterbodies (Class 1, 2, and 3) have 60-foot 

minimum shade protection buffers, the wood recruitment zones will also be protected. Based on the 

research findings, a primary wood recruitment zone of 30 feet from each side of narrow (typically the 

intermittent class 4) stream channels was defined for young, dense stands within the project area, where 

bank erosion and tree mortality are the dominant wood recruitment processes and average tree heights 

range from 56 to 114 feet. No harvest buffers ranging from 30 feet to 172 feet. Along the wider perennial 

and fish bearing streams where average tree heights ranged from 70 feet to 114 feet, no-treatment buffers 

range from 60 feet to 344 feet depending on riparian area conditions.

Given that research has shown that the greatest amount of wood supply comes from 100 feet on either 

side of perennial stream channels, thinning beyond 60-foot no-treatment buffer (in the secondary shade 
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zone) has some potential to affect large wood supply. Under Alternative 2, future wood recruitment 

would be affected by thinning within secondary shade zone. Thinning within 30 to 60 feet of intermittent 

streams would protect 90% of the wood recruitment zone. Thinning outside these buffers has the potential 

to reduce some intermediate-sized wood recruitment into stream channels. Loss would create an 

intermediate term, 10 to 30 year, period that intermediate wood would not be recruited into the channel 

through the natural thinning of the stand. However, due to the height of the trees being thinned (56 to 114 

feet), there is a < 5% chance that wood of an appreciable size removed by thinning from outer Riparian 

Reserves would fall and reach the channel, and most wood supply would still be coming from notreatment buffers and skips as well as existing sources of large wood within the unmanaged portions of 

the project area.

Terrestrial Down Wood 

In addition to in-stream wood, numerous studies have been conducted that address both the specific roles 

of down wood in ecosystem as well as its ecological function for wildlife and aquatic species. However, it 

is less easy to quantify the exact levels of down wood expected to have occur in the upland portions of 

Riparian Reserves assuming there were no human impact to the forest since these are subject to many 

variants. Only two management rotations in Douglas-fir stands have been estimated to reduce the 

abundance of dead wood by 90% compared to levels in natural old-growth systems (Rose et. al.). It 

should be noted that stands go through a “U” shaped pattern of down wood development naturally; and 

depending on stand age, a fluctuation of LWM is expected. With thinning prescriptions targeting densities 

of 40-100 TPA, these are still greater than natural stand densities of 40-60 TPA. Therefore, down wood 

resulting from continued stand development is expected to be higher in these stands than typically found 

in naturally regenerated stands. Thinning will reduce the biomass and number of stems available for wood 

recruitment from physical and suppression caused mortality (Luz and Halpern 2006) in the short to 

intermediate term. 

Across the project area, current levels of down wood are within estimated historical ranges (see Appendix 

F: DECAID Analysis for more information). As the Breitenbush Watershed is currently within the range 

of natural variability for downed wood and the proposed thinning in Riparian Reserves only represents 

2.5 percent of the entirety of Riparian Reserves in the Breitenbush, short to intermediate term reductions 

to terrestrial wood recruitment are anticipated within in the unit but these are minor on the watershed 

scale. On the contrary, “fall and leave only” treatments in Riparian Reserves would have additional 

benefits to increase upland course down woody debris in the Riparian Reserves, this type of approach 

would be difficult to balance resulting fuel loading from downed trees with enough falling to achieve 

desired diversity objectives. The watershed is currently within the range of natural variability for downed 

wood, so it was not targeted as a needed restorative treatment activity for Riparian Reserves in this project 

area. This minor reduction in upland downed wood in Riparian Reserves is considered a tradeoff towards 

improving vegetative species and structural diversity in Riparian Reserves (ACS Objectives viii and ix), 

the latter of which is currently not within the natural range of variability and in greater need of restorative 

treatment on a watershed scale. 

No Treatment in Riparian Reserve

Included in Alternative 2, some stands will be left in their current relatively intact condition. The 677

acres of no-treatment portions of the Riparian Reserves were selected where ACSO’s are being achieved, 

are on a close trajectory towards being achieved, or added protection of existing habitats would be 

needed. These no-treatment areas are either partial buffers within the Reserves or full Riparian Reserves. 

The Riparian Reserves in these units and several others show existing stand and vegetation diversity, 
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sensitive habitat, soil stability issues, temperature sensitivity, or existing quality aquatic habitat so no 

thinning was recommended within the Riparian Reserves. Information on proposed silvicultural 

treatments in Riparian Reserves, or non-treatment, can be found in Appendix G.

Streamside Treatments

Several streams were identified during field surveys to have a shortage of large woody material within the 

channel or floodplain, lack of riparian diversity, and/or opportunity for hardwood release. Selected 

streams for treatment were chosen for their vegetation characteristics at the subwatershed scale and at the 

site-specific scale. The large majority of riparian stands along the entire length of the streams in units 6, 

100, 190, 430, and 520 are dense plantations lacking structural and species diversity. In these five young 

plantation units, fall and leave treatment would occur in approximately 20 to 75% of the units’ no-harvest 

buffers along approximately 3.2 miles of streams to reduce densities, open the canopies, increase growth 

and vigor of remaining trees, and add medium to large wood to forest floor and stream channels (Table 

12, page 48). Due to the evidence of historic debris flows through Unit 430, this unit was identified 

specifically as having a high potential for large wood recruitment via an intermittent stream channel 

downstream less than 1⁄4 mile to the North Fork Breitenbush River. This very dense monoculture stand has 

evidence of historical debris flows, with a high potential to serve as source of large wood downstream. 

Stream habitat in the North Fork Breitenbush River is largely lacking in large wood and this passive 

treatment would contribute to its restoration. Treatment would entail falling and leaving individual trees 

scattered along the riparian area or small groups of trees. The integration of directionally falling trees into 

the stream along with no-harvest buffers in thinned units increases the recruitment of large wood instream 

on the site scale (Benda et al, 2015) but due to the conservative number of miles proposed for streamside 

treatment, this is negligible on the watershed scale.

Approximately 4 acres of small near-stream gaps are proposed within units 100, 190, and 520 (Table 12

in chapter 2, page 48). There are several objectives for these treatments including increased light 

availability for primary productivity and increased deciduous vegetation for allochthonous material 

(decomposition of organic matter imported from outside the stream). Historic timber harvest and dense 

conifer revegetation in the project area have resulted in a lack of deciduous vegetation along many 

streams. Homogenous conifer stands near streams such as these have been shown to impact the food 

supply and thus the lifecycle of macro-invertebrates (Hoover 2011). In converse, mature and old-growth 

stands exhibit a mixture of heterotrophic (shaded) and autotrophic (lighted) habitats within stream reaches 

(Stovall 2009, Warren 2013).

Research and field surveys indicate that near-stream gaps may be appropriate in certain situations: 

• drainages with dense conifer canopy (i.e. plantations) where stream productivity may be 

relatively low

• lower gradient reaches (<10%) that have higher potential to retain and process organic inputs

• streams tightly coupled to biological hotspots 

• streams with low sensitivity to thermal loading and erosion

• riparian areas within plant associations that should have a hardwood/deciduous component

Small near-stream gaps would increase light availability to streams by 20 to 30% to increase primary 

productivity and increase the hardwood component in order to begin to emulate old-growth 

characteristics. Canopy gaps have been shown to play a major role in providing light to streams within 

old growth stands and is significantly higher in those reaches than within younger (~60 years old) closed 

canopy stands (Warren 2013). Some removal of trees out of the gaps may be required in order to allow 

regeneration of early serial species. However, these trees would be left in the Riparian Reserves for large 
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woody material. Monitoring will be an integral component of this project. All of the proposed near-stream 

gaps are within young plantations <60 years old. 

Other Treatments

Prescribed Fire

Within some of the commercial thinning units and all of the hazardous fuels reduction units, the 

introduction of low severity fire into patches of Riparian Reserves is anticipated. Fire would not be 

ignited in any Riparian Reserves, but would be allowed to back into the Reserves. The fire would then

burn in a mosaic pattern rather than requiring a fire line around the Reserves which would potentially 

result in erosion. At low burn severities, large wood would not be removed from the Reserves. In 

addition, with local differences in soil moisture and relative humidity, the pattern of burning in the 

Riparian Reserves is expected to resemble a patchwork mosaic of unburned and lightly burned sites. In 

the unburned portions, the existing understory vegetation, including conifers, would be retained. In lightly 

burned areas, understory conifers would experience some mortality, but fire adapted species such as 

willow and other hardwood shrubs would re-sprout and, in some instances, be stimulated into increased 

growth in response to the disturbance. The net result would be increased plant species and stand structural 

diversity, with a closer resemblance to historic stand condition than non-thinned plantations. Somewhere 

in the range of 5 to 105 acres of Riparian Reserve in commercial thinning units and 49 acres in hazardous 

fuels treatment units could be affected under Alternative 2. This range of affected acreage is based on the 

design criteria of fire only being allowed to back into the Riparian Reserves and an estimated 5-25% of 

those Riparian Reserve acres being impacted. The 25% represents a likely maximum and the “worst-case 

scenario”. 

Roads and Landings

Proposed road decommissioning would remove 4.2 miles of roads no longer needed from Riparian 

Reserves. These decommissioned roads would be restored to more natural riparian conditions with level 

of decommissioning treatment (passive to high degree of treatment) to be determined for each individual 

road segment. 

Wherever possible, temporary roads would be located on ridge tops, gentle slopes, or would utilize 

locations previously disturbed by historic logging. Those segments located within the Riparian Reserves

would be located well outside of the primary shade zone (approximately 60 to 80 feet) and cross 

perpendicular to the stream where necessary. Two temporary road stream crossings are proposed on class 

3 perennial streams (Units 62 and 64). Crossing locations would be approved by hydrology/fisheries staff 

during layout and would have temporary culverts installed and removed following harvest.

Operations will minimize the number of landings in Riparian Reserves will be minimized by restricting 

landings to existing roadbeds wherever possible and locating them a minimum of 100 feet away from any 

streams. Up to 15 new landings in Riparian Reserves could be located off the existing road prism in 

addition to the estimated 137 that would be on existing disturbed ground. The maximum effect of new 

disturbance from temporary roads and landings in Riparian Reserves is approximately 6 acres. Sixteen

ground based skid trail stream crossings are proposed to access portions of units. Impacts to large wood 

are expected to be similar to those of thinning treatments. Typical rates of re-vegetation start occurring 

within 2 decades from natural regeneration if the disturbed area is not replanted. All temporary roads and 

landings in Riparian Reserves would be decommissioned after treatment activities are completed 

following BMP’s and additional design elements, including removal of any temporary crossings, subsoilng the approaches and spreading slash over sub-soiled areas. 
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Rock Pits

Under Alternative 2, nearby rock sources are needed for use to upgrade roads to hauling standards. Of the 

nine pits that are proposed to be used for material, only one (Lower Skunk) is located within the Riparian 

Reserve. Any expansion, additional development, or reclamation of Lower Skunk Pit would occur outside 

of the Riparian Reserve and be assessed in a separate analysis with development of a Pit Plan.

Alternative 3 

Alternative 3 proposes, to treat 601 acres of Riparian Reserve. Effects to riparian conditions would be 

similar to Alternative 2 with the exception that 184 less acres would be treated. No Riparian Reserves that 

have stand ages greater than 80 years old would be treated, including meadow restoration in Unit 32a, 

leaving these reserves remaining in current condition and on a slower trajectory towards achieving 

ACSO’s. Alternative 3 offers a greater opportunity to improve ACSO’s in Riparian Reserves on the 

watershed scale than Alternative 1, but less opportunity than Alternative 2. 

Thinning in Riparian Reserves

Approximately 528 acres of Riparian Reserve would be thinned under Alternative 3, with thinning in 

plantations only (no thinning in fire-regenerated stands). Approximately 180 less acres of Riparian 

Reserve treatment would occur under Alternative 3. The effects of thinning in Riparian Reserves would 

be similar to Alternative 2, though with less acres affected. The effects of not thinning the additional 175

acres of Riparian Reserve would represent a 0.7% difference on the watershed scale.

No Treatment in Riparian Reserve

As with Alternative 2, Alternative 3 proposes to leave 480 acres of fire regenerated stands untreated given 

that ACSOs are either being achieved or are on a trajectory towards being achieved, or additional 

protection of existing habitats was needed with similar effects as discussed for Alternative 2. 

Streamside Treatments

Under Alternative 3, streamside treatments would remain the same as Alternative 2 and have similar 

effects. 

Other Treatments

Prescribed Fire

Post-harvest underburning treatment would occur in 516 fewer acres across units and 50 fewer Riparian 

Reserve acres under Alternative 3. The number of acres of Riparian Reserve affected by Hazardous Fuels

Reduction treatments would remain the same. Effects would be similar as Alternative 2 with slightly less 

acres treated. 

Temporary Roads

Alternative 3 would have about 1.2 miles of temporary roads and up to 15 new landings off-the-existingroad-prism in Riparian Reserves. Distrubance from temporary roads and new landings would amount to 

approximately 5.5 acres of disturbance, slightly less than Alternative 2. The number of temporary 

crossings for ground based skidding and hauling would be the same as Alternative 2. Design elements for 

landings and temporary roads would be the same for both alternatives. 

Rock Pits
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Use of rock pits and subsequent effects to Riparian Reserves are the same as Alternative 2.

Stream Shade and Temperature

Alternative 1 – No Action 

Activities that affect stream-shading vegetation would not occur, and direct, indirect, or cumulative 

effects of this alternative on stream temperature are not anticipated. Water temperatures in streams in the 

project area would continue to recover toward more natural levels as riparian vegetation that was 

disturbed or removed by management activities prior to implementation of the Northwest Forest Plan regrows and re-establishes streamside shade. No indirect effects on stream temperatures due to 

implementation of this alternative are anticipated. 

However, with the increased risk of high severity wildfire, which is carried more easily through dense 

stands, this may affect water quality in the future. The corresponding loss of vegetation and duff may 

affect temperatures and microclimates around the edges of the streams and wetlands. Most of the streams 

and seasonal wet meadows go dry during the summer when temperatures are typically an issue. So 

increased stream temperature at the current vegetation conditions or after a high-severity fire is not 

expected in most of the class 4 streams in the project area. Microclimates, however, would be affected 

after a high-severity fire.

Alternative 2 

The system of Riparian Reserves under the ACS provides zones around streams, wetlands, and water 

bodies that contribute to protecting or restoring the physical, chemical, and biological integrity of these 

waters, which is the major goal of the Clean Water Act. For all action alternatives, treatments within 

riparian areas have been designed to comply with the “Northwest Forest Plan Temperature TMDL 

Implementation Strategies – Evaluation of the adequacy of the Northwest Forest Plan Riparian Reserves 

to achieve and maintain stream temperature water quality standards” (TMDL 2012). 

The Strategies outline how stream shade can be protected to prevent solar radiation from heating streams, 

providing calculations for determining the effective stream shading based on tree height, bank/hill slope, 

aspect and location. At a minimum, the Strategies prescribe no-thin buffers to protect stream shade within 

the primary shade zone, the riparian area adjacent to perennial stream channels that provides stream shade 

for the period of greatest solar loading. The secondary shade zone, which provides shade in the morning 

and afternoon, and also located within the first site potential tree may have some thinning allowed up to 

50% canopy closure that does not result in any loss of stream shading. For an even-aged site with 60-100 

foot tall trees, the approximate primary shade zone ranges from 50-60 feet depending on and increasing 

with slope. This varies with stream width, aspect, and location. To comply with the stream temperature 

standards, no-harvest buffers were developed to eliminate management effects. These buffers were 

developed based in part by calculating the width of primary and secondary shade zones. 

Research has shown that in many cases significant changes in stream temperature are not observed with 

partial no-harvest buffers within the Riparian Reserve width (Levno and Rothacher 1967, Brown and 

Krygier 1970, Swift and Messer 1971, Macdonald et al. 2003). In several cases, buffer distances less than 

one site potential tree have been shown to protect water temperature. Typically the primary shade zone is 

half of the site potential tree height. Gomi et al. (2006) reported maximum daily temperatures in 

headwater streams did not increase significantly when 30- and 90-foot buffers were applied.

Intermittent (Class 4) streams are dry during the portion of the year when elevated temperatures occur and 

therefore temperature is not as significant an issue. However, no-harvest buffers of 30 feet which were 
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designed for other resource objectives would provide substantial shade regardless. Much of the streaminfluenced microclimate would also be preserved since the gradients are strongest within the first 20-30 

feet (Anderson 2007) and a portion of the canopy cover throughout the rest of the Riparian Reserve would 

be maintained. In all of the units with proposed thinning in Riparian Reserves, conifer densities are high 

and would benefit from thinning. 

No-harvest buffers on Class 3 streams have varying widths developed in part to accelerate species and 

structural diversity while protecting effective shade. All of the Class 3 streams within the proposed 

harvest units have a minimum 60-foot no-harvest buffer to retain effective stream shade and terrestrial 

microclimates (Anderson 2007). It should be noted that “no-harvest” and “no-treatment” differ, whereas 

in a “no-harvest” buffer, trees may not be commercially cut and milled, but may be cut and felled for 

other purposes – such as for streamside restoration treatment where specified and stream 

crossings/equipment access. A “no-treatment” buffer would not have any trees cut or any other active 

management treatment within the buffered area and includes no-harvest buffers. The majority of 

perennial streams (Class 1 and 2) are protected with a minimum of a 100-foot no-harvest buffer to retain 

effective stream shade. Where thermal loading, soil stability, desired stand characteristics, etc. are 

present; no-harvest buffers are wider to meet ACS obje)ctives. Within the no-harvest buffer of units with 

streamside treatment (Units 6, 100, 190, 430, and 520) up to 20 acres would have fall and leave thinning

and small gaps within the primary shade zone. The current canopy cover for the proposed streamside 

treatment units is 80-90%. Gaps would be placed and thinning treatments heavier on the north and east 

sides of the channels where solar radiation is less.

The meadow restoration in Unit 32a would occur under this alternative, however the Class 4 stream 

associated with the meadow is currently dry by early summer. Any increased duration of streamflow 

associated with the treatment, decreased evapotranspiration, and increased groundwater storage would be 

minimal and not affect downstream water temperatures.

Small openings in old growth stands are common; and localized warming as a result of the proposed gaps

are expected to result in similar conditions remaining within the range of natural variability (Warren 

2013). Most studies relevant to shade recovery after clear-cut and other “heavy” harvests predict 

substantial return to pre-harvest levels within 5 to 7 years of treatment (Brown 1970; Feller 1981; Harr 

1988). These recovery predictions assume the rapid return of bankside understory vegetation, because 

canopy shade provided by second-growth forests will require 10 to 20 years (Beschta 1987, Johnson 

2000). Canopy openings in these gaps would likewise be transitory and revegetate quickly. In addition to 

protection for excessive thermal loading, the proposed gaps are in streams flowing through locations 

where hyporheic exchange can provide additional offsets to warming.

There are sixteen proposed temporary stream crossings as part of Alternative 2 for ground-based 

equipment to skid logs across to landings. All of these would cross intermittent Class 4 streams (Units 5, 

24, 44, 62, 64, 110, 220, 470, and 520); No perennial streams would be used for ground-based crossings. 

Class 4 streams are dry during the summer when water temperature is typically a concern. Historic skid 

roads will be used where possible. This would allow for already compacted areas to be re-used then 

properly sub-soiled and re-vegetated in order to reduce overall compaction levels. Based on 

implementation of the design features outlined in Chapter 2, which reduce the acres of disturbance due to 

temporary roads and skid trails as well as field observations during project reconnaissance; a minimal 

direct effect is anticipated at a localized level within a few feet downstream of the temporary road 

crossings. No landings would be located in the primary shade zone of streams (approximately 60 -80 

feet), though up to 15 new landings encompassing approximately 5 acres total would potentially be 

located in the secondary shade zones a minimum of 100 feet from the stream channel. 
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Additionally two perennial stream crossings are proposed in Units 62 and 64 for temporary roads used to 

haul logs from landings. At the perennial stream crossings, the width of the clearing needed to establish 

the crossings would not create a detrimental change in temperature or shade because the primary and 

secondary shade zones of the adjacent riparian area would retain sufficient canopy closure to these narrow 

streams to provide shade. A few short segments of other temporary roads would enter the outer portion of 

Riparian Reserves but not cross any streams.

Due to protection of primary and secondary shade zones, water temperatures of streams within the project 

area would continue to recover toward more natural levels as riparian vegetation re-grows and reestablishes streamside shade. Additionally, many of the treatment units are over-stocked plantations with 

small diameter riparian trees. Thinning within the secondary shade zone would increase growth of the 

remaining trees. These treatments would increase the shrub and understory vegetation, which would 

increase effective shading as well. Small incremental increases in the rate of recovery as a result of 

implementing Alternative 2 are anticipated to improve conditions over the long term.

Based on implementation of the design elements outlined in Chapter 2 as well as field observations 

during project reconnaissance; a minimal direct effect is anticipated at a small/localized level only within 

a few feet downstream of the temporary road crossings. No long-term indirect increases of stream 

temperature are anticipated within the project area as a result of these alternatives. Incremental increases 

or a decrease in the rate of recovery as a result of implementation of either action alternative is not 

anticipated.

Additionally, thinning of dense stands and managing fuel loading helps reduce the risk of high severity 

wildfire. This in turn reduces the risk of impacts to stream shade, temperature, and microclimate.
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Alternative 3

Alternative 3 would have less acres of thinning than Alternative 2, these acres are all outside the primary 

shade zone and would not have any effect on stream shade and temperature. The meadow restoration in 

Unit 32a would not occur under this alternative, however the Class 4 stream associated with the meadow 

is currently dry by early summer. This would not change in this alternative. Overall, the effects to stream 

shade and temperature are similar to Alternative 2.

Sedimentation and Roads

Alternative 1 – No Action 

Rates of road related sediment yield are estimated to remain relatively unchanged under Alternative 1 (No 

Action). Alternative 1 would not correct existing road erosion problems that result in chronic 

sedimentation to streams. Landscape delivery of fine sediment, as modified by the road and streamcrossing network, would remain as it is and subject only to scheduled maintenance. Without timber 

harvest related road maintenance, the existing budgetary trend would result in only the main roads being 

maintained. Culverts that are not maintained could plug and cause washouts. The resulting sediment 

plumes could be detrimental to fish and amphibians. Over several decades, these road issues would 

stabilize as the disturbed areas re-vegetate. However, no project-related storage or decommissioning 

would occur. Tables 30 and 31 on the following pages provides a comparison of road related sediment 

delivery to streams between all Alternatives.

Alternative 2 

Project activities with potential to affect water quality by increasing sediment delivery to streams are road 

construction, reconstruction and maintenance, timber haul and log skidding. Road construction can create 

sediment during pioneering, excavating and development of road prism and placement of crossings. 

Timber haul can affect sediment delivery when done during wet conditions on non-paved surfaces. Log 

skidding can create compacted surfaces that create pathways for sediment laden water. 

Best Management Practices will be utilized and project design elements are prescribed for each of the 

following activities to prevent or mitigate these effects. 

• No-harvest buffers and equipment exclusion buffers are designated to reduce delivery of 

sediments generated from harvest practices upslope.

• Trails for log skidding will be designated to prevent flow paths to streams and minimize 

compaction.

• Road work will be done in the dry season. 

• Wet weather haul will be restricted to roads that are structurally sufficient and pre-identified in 

this project analysis.

• Wet weather haul will occur only during conditions that support proper road use. 

• All non-paved roads used for wet weather haul will be rocked with at least 4 inches of aggregate 

material, with minimum size determined by road slope and proximity to streams.

• On all wet weather haul routes, additional cross-drains leading off onto the forest floor will be 

constructed approximately 100 – 200 feet above stream crossings within 1000 feet of Listed Fish 

Habitat to minimize direct delivery of road sediments to streams.

Road work associated with the Hwy 46 Project would also include replacement of a number of culverts 

that are currently in poor condition or inadequately sized to pass 100-year flood flows (Q100). These 

culverts currently pose an elevated risk of fill failure. Discussions with engineering personnel indicated 
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that an average fill volume is around 250 cubic yards. This material is at risk of entering the streams and 

potentially generating debris torrents if the existing culverts fail. However, replacement would require instream work in these locations. Work will be done during non-flow periods for intermittent streams, and 

engineering practices such as sediment barriers and flow bypass would minimize impacts on perennial 

streams. Flows in perennial streams are expected to be less than 1.0 cubic feet per second when work 

occurs. Localized effects would occur during the replacement of the culverts and the stream crossings 

after the first flow and for a limited length downstream. It is not possible to do this work without some 

sediment delivery, and accurate estimates are not predictable. Depending on weather behavior and other 

variable factors, sediment yields should fall between 0.5 and 1.5 cubic yards per installation.

Under Alternative 2, approximately 41 stream crossing culverts on planned haul routes that are in poor 

condition or currently undersized would be replaced or upgraded. Table 30 provides a summary of these 

replacements and the potential amount of fill material that would have a reduced risk of entering streams. 

It also estimates the amount of sediment produced from the culvert replacements. The maximum estimate 

of sediment yields from the culvert replacements would be approximately 62 and 54 cubic yards for 

Alternative 2 and 3, respectively. In comparison, the estimated volume of fill stabilized is 10,250 cubic 

yards for Alternative 2. Alternative 2 would reduce the long-term potential for runoff effects and culvert 

failures that may affect Riparian Reserves or water quality to the greatest extent.

Table 30 Approximate Culvert Replacements in Perennial and Intermittent Streams by Alternative

Alternative Stream Type

Number of Culverts 

Installed/Replaced/

Removed

Cubic Yards of 

Fill Stabilized

Sediment Yields from 

Culvert Replacements 

(Cubic Yards)

Alternative 1 None 0 0 0

Alternative 2

Perennial 27 6250 13.5 - 41.5

Intermittent 14 3500 7-21

Total 41 10,250 20.5 - 61.5

Alternative 3

Perennial 22 5,500 11 - 33

Intermittent 14 3,500 7 - 21

Total 36 9,000 18 - 54

As part of road storage and decommissioning, a number of culverts on perennial and intermittent streams 

would be removed along with the fill material to stabilize the stream crossings. Based on GIS review, it is 

estimated that up to 7 perennial and 32 intermittent stream crossings would be stabilized with the 

proposed decommissioning activities and up to 17 intermittent stream crossings with the proposed road 

storage. The culvert removals would stabilize approximately 14,000 cubic yards of material. While work 

would be done during no to low-flow stream conditions during the in-water-work period and other BMP’s 

would be followed, 28-84 cubic yards could be delivered to streams during decommissioning activities. 

An analysis of estimated sediment delivery from roads in the project area was completed using the 

GRAIP-lite toolset in the NetMap Tools GIS model. The analysis was conducted for each alternative by 

applying changes in addition of temporary roads, decommissioning of roads, and changes to surface type 

and road maintenance levels associated with the action alternatives (Table 31). Despite construction of 

new temporaty roads, improvements to haul routes (drainage and rocking) would decrease road generated 

sediment delivery to streams in the project area by 12 cubic yards annually when the project is 

implemented. It should be noted this does not account for the amount of haul or distinguish between wet 

or dry weather hauling. The new road construction and reconstructed roads will be graded and up to 
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current standards. In addition to the 29.9 miles of paved roads that would be utilized for wet weather haul, 

up to 77.6 miles of non-paved roads could be used for wet weather haul; non-paved roads that are used for 

wet weather haul would meetbe wet weather design specifications, including rocking with four inches of 

surface rock. Temporary roads used for wet weather haul will also be rocked, though exactly which roads 

these would be is unknown. As a worst-case scenario, they were all considered native surface in the 

model input. Wet weather haul will not be permitted on native surface roads. Combined with the road 

improvements, the construction and subsequent decommissioning of temporary roads, the additional 

activities of road realignments (0.3), road decommissioning (8.7 mi) and the Short Lake Reroute (0.4 mi), 

would further reduce road sediment delivery by another 14 cubic yards annually.

Table 31 Comparison of GRAIP-lite Modeled Road Sediment Delivery by Alternative

Alternative Description Cubic yards of sediment 

delivered/year

Alternative 1 all existing roads in Hwy 46 + haul routes 95

Alternative 2

Alt 2 Implementation Total 83

Alt 2 Post sale/posts decommissioning Total 69

Alt 2 Total 78

Alternative 3

Alt 3 Implementation Total 78

Alt 3 Post sale/posts decommissioning Total 74

Alt 3 Total 70

Hauling during wet weather conditions would likely lead to road sediment erosion and fine sediment 

delivery to streams, however, installation of additional cross-drains approximately above stream crossings 

and rocking the road surface will improve road drainage and minimize sediment delivery to stream 

channels. Additional cross-drains nor sediment delivery associated with wet versus dry weather hauling 

based on amount of hauling traffic are not accounted for in this model. No effects are anticipated during 

dry weather construction, haul and removal when Best Management Practices are used during all 

operations. 

Nearby rock sources are needed for use to upgrade and maintain roads to hauling standards and minimize 

fine sediment delivery to streams. Nine pits are proposed to be used for material but are generally located 

well away from streams. The current limits of lower Skunk Pit is located within 100 feet of Skunk Creek, 

a perennial class 3 stream. Extraction of material from this pit could lead to fine sediment delivery to 

Skunk Creek, but would be minimized by following BMP’s. Any expansion, additional development, or 

reclamation of Lower Skunk Pit would occur outside of the Riparian Reserve and be assessed in a 

separate analysis with development of a Pit Plan. 

Alternative 3 

Thirty-six stream crossing culverts that are currently in poor condition or undersized would be replaced or 

upgraded (Table 30). The maximum estimate of sediment yields from the culvert replacements would be 

less than Alternative 2 by approximately 7.5 cubic yards less (54 cubic yards total). However, five 

culverts that are in need of replacement would not be replaced, with approximately 1,250 cubic yards of 

fill not stabilized in this Alternative. Road decommissioning and storage effects would be the same as 

Alternative 2. Alternative 3 would reduce the long-term potential for runoff effects and culvert failures 

that may affect riparian conditions or water quality but to a lesser extent than Alternative 2. 
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Fewer miles of new temporary roads and existing spurs would be constructed and re-opened than 

Alternative 2. There would also be fewer miles of haul routes, and subsequently wet weather haul miles, 

maintenance/reconstruction, and culvert upgrades than Alternative 2. There would be no difference in 

number of roads decommissioned or stored, realignments and re-routes, or rock pit use than Alternative 2. 

Slightly less road-generated sediment would be produced and delivered to streams with Alternative 3 

during project implementation (Table 31). However in the mid-to longer term there would be a higher risk 

of culvert failure and fill release with Alternative 3, because less miles of road would be brought up to 

standards and fewer culverts upgraded to proper sizing and condition.

Cumulative Effects

The cumulative effects of the proposed project plus the projects listed in the Past, Present, and 

Reasonably Foreseeable Actions Relevant to the Cumulative Effects Analysis (Appendix D) are 

considered at the local and 6th field subwatershed scale. Effects of a cumulative nature are those effects 

which independently do not pose a risk to water quality yet, when added together may have some 

measurable effect on hydrology, riparian conditions or water quality. All recent and planned timber 

harvest, riparian habitat complexity development, and road improvement and decommissioning projects 

were and will be designed with similar protection measures, design features, and Best Management 

Practices that minimize effects to water quality and aquatic resources. 

Alternative 1

Cumulative effects of Alternative 1 would range from no measurable effect to beneficial effects on 

hydrology, stream channels, water quality, and riparian conditions for approximately 25 years. At that 

time, stand conditions and large wood recruitment levels could change and would begin to show delayed 

effects on hydrology, stream channels and water quality. Riparian stand diversity, understory 

development, and large wood (>36 inch diameter) recruitment in stream channels would be delayed from 

recovering to desired future conditions. Implementation of the CMLG road drainage improvement project 

and the North Fork Breitenbush Restoration in the next 5 years would provide some potential 

improvements to stream flows and water quality; however, an ongoing and longer term lack of road 

maintenance may cause road drainage structures to fail raising risks to water quality and stream channel 

routing. Ongoing concerns with road sediment delivery from non FS-system roads in the powerline 

corridor are anticipated to continue as well as continued fine sediment delivery to the Breitenbush River 

from the Short Creek slide debris flow. As a result of the recent 2017 wildfires, which burned a combined 

2759 acres in the South Fork Breitenbush Subwatershed and 891 acres in the Upper Breitenbush 

Subwatershed were generally of low soil burn severity and fire intensity. The low severity coupled with 

the low percentage of subwatershed acreage will slightly increase peak flow responses (1.2 times and 1.1 

times increase for the South Fork Breitenbush and Scorpion Creeks, respectively). An increase in 

sediment erosion and delivery to streams is anticipated in the first 2-5 years post-fire. Post-fire BAER and 

suppression repair treatments include storm-proofing roads that are threatened from increased runoff and 

erosion will minimize the potential fire-related impacts in the Breitenbush Watershed. Timber harvest, 

fire, geology/soils, and social influences on these parameters are anticipated to remain unchanged from 

the current condition and potential positive effects to the riparian conditions in the diversity and health of 

the ecosystem would be delayed.
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Cumulative Effects for Alternatives 2 and 3

Stream Flows/Disturbance

Breitenbush Hot Springs Resort is the only privately held land in the project area. Although its lands are 

managed primarily for recreation, impacts to streams may occur with infrastructure in the stream channel 

and floodplains for drinking water and hydropower generation. The powerline corridor represents a vast 

swath of federally owned land that is primarily managed by BPA and PGE. Vegetation growth is 

managed in this corridor to suppress interference with powerlines. A vast network of non-system roads 

are used to access towers and lines. Numerous stream crossings are associated with these roads, with 

instances where stream channels have been created or diverted. These effects are anticipated to continue. 

The planning subwatersheds are well recovered from an ARP standpoint and cumulative effects for peak 

flows are not anticipated, even coupled with the minor increases resulting from the 2017 Wildfires. It is 

not anticipated that implementing either action alternative with their accompanying design elements 

would create an adverse downstream hydrologic effect relating to peak flows. With the protection buffers 

and restrictions placed on activities adjacent to wet areas and streams it is not anticipated that cumulative 

effects would be associated with the hydrology of the groundwater dependent areas found within the area.

Additive ground-disturbing activities of the proposed action alternatives are not anticipated to impact 

stream channel conditions through time with the proposed mitigations and Best Management Practices. 

Planned restoration of the North Fork Breitenbush River with placement of large wood structures along 

approximately 5 miles will have a long-term benefit to stream channels on the subwatershed scale. The 

effects of these individual actions have a cumulative minor effect on the local site scale in the near-term 

and negligible to beneficial effect on stream channels/disturbance on the sub-watershed scale in the longterm.

Riparian Conditions

Within the 2017 wildfire perimeters, 1,275 acres were in Riparian Reserves within the Breitenbush 

Watershed. These were predominately unburned or low severity. Only an estimated 10 acres of Riparian 

Reserve were rated as moderate soil burn severity. The powerline corridor crosses approximately 35 

streams in the project area and is maintained in early seral vegetation condition to suppress powerline 

interference. Riparian areas in this corridor will continue to be managed for early seral condition and 

continue to have a negative effect on the site scale, but this is and will continue to be minor on the 

subwatershed scale. In contrast, thinning Riparian Reserves would maintain and improve overstocked 

forest conditions to meet ACS objectives, and streamside treatments of the proposed action to increase 

structural and species complexity and diversity would have positive effects at the site scale but little 

discernable cumulative effects at the subwatershed scale due to the limited scale of treatments. Minor 

losses wood recruitment within riparian areas in the near-term from thinning outside of no-treatment

buffers as part of the proposed action, will be offset for the intermediate to long-term through the 

accelerated development of larger wood to be recruited in the long term. Each of the projects listed in 

Appendix D were analyzed for effects to riparian conditions and were found to have negligible effect, 

minor effect or beneficial effect.

Stream Shade and Temperature

Though some riparian areas burned in the 2017 Wildfires, very little burned at fire intensities high enough 

to result in tree mortality and subsequent loss of canopy cover and stream shading. Stream temperatures 

are not expected to increase as a result of the fires. The powerline corridor would continue to be managed 

in early seral condition, maintaining numerous small segments of minimal shade within in the corridor 
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area. The proposed action would have minor to negligible impacts to shade in the near-term due to use of 

no-treatment buffers that protect existing shade, leading to no detrimental cumulative effects at the subwatershed scale. Along with the other recent, ongoing, and likely foreseeable future actions, stream shade 

would be maintained in the short-term and be maintained or increase slightly in the long-term as tree

canopies respond to reduced densities and increased vigor in riparian areas.

Sedimentation and Roads

There is an increased potential of sediment delivery to the South Fork Breitenbush and its tributaries to do 

increased soil erosion, debris flow probability and road interception of runoff. The post-fire suppression 

rehab work and planned drainage improvements on the 2231870 road system will help offset these 

impacts prior to implementation of the Hwy 46 project. Short-term effects of the proposed action 

alternatives on sediment would be associated with designated crossings, road maintenance and road 

reconstruction, and would be short lived and localized, gone after the first storm event that provides 

sufficient flow. By utilizing BMPs during winter haul, this activity will also be managed to prevent 

detrimental sedimentation that could cumulatively affect water quality when haul routes cross multiple 

streams. However, the long-term beneficial effects of fixing and maintaining roads outweigh the short 

term negative impacts as part of the with the proposed action and the reasonably foreseeable CMLG 

Legacy roads project may slightly improve water quality in the long term by improving road drainage and 

reducing road surface erosion and sediment delivery to streams. Well-maintained roads efficiently drain 

runoff through properly sized culverts and protect fills from becoming saturated and catastrophically 

failing. The 8.88 miles of planned road decommissioning and road closure with hydrologic stabilization 

in areas of higher aquatic risk will further reduce road-related sediment delivery in the long-term. Within 

the powerline corridor, non-FS powerline access roads that do not currently adhere to best management 

practices along with a high density of road-stream crossings, would continue to have minor impacts on 

sedimentation on the site and negligible on the subwatershed scales. In reviewing the reasonably 

foreseeable future projects found within the project record it is anticipated that the proposed action along 

with these foreseeable future actions would have negligible to beneficial minor effects in the near to longterm; and would not generate any adverse cumulative effects on sedimentation.

3.5 Fisheries

3.5.1 Summary of Effects Analysis

This analysis found that the Hwy 46 Project “may affect, not likely to adversely affect” Upper Willamette 

spring Chinook salmon. This is due to the potential for “take” as defined in the ESA. Take is prohibited 

by the ESA unless it is authorized by the “fisheries” agencies (National Marine Fisheries Service for 

salmon). In order for the Forest Service to obtain authorization we must conduct consultation with the fish 

agencies under Section 7 of the ESA. Consultation is anticipated to be completed by May 2018.

Breitenbush River is habitat for spring Chinook salmon and there is the potential to harass, or harm, as a 

result of the hauling activities. The Forest Service is required to complete consultation before the Record 

of Decision can be signed for this FEIS. The Forest Service would be required to follow all terms and 

conditions provided by the fish agencies in their Biological Opinions.

Essential fish habitat (EFH) under the Magnuson-Stevens Fishery Conservation and Management Act is 

designated in all areas except above impassible dams (Detroit and Big Cliff Dams), and natural migration 

barriers. The Magnuson-Stevens Fishery Conservation and Management Act reauthorization in 1996 

established a new requirement for essential fish habitat that requires Federal agencies to consult with the 

National Marine Fisheries Service on activities that may adversely affect essential fish habitat. Essential 
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145

fish habitat for the Pacific coast salmon fishery means those waters and substrate necessary for salmon 

production needed to support a long-term sustainable salmon fishery and salmon contributions to a 

healthy ecosystem. 

The Breitenbush River above Detroit Dam was not considered EFH but since reauthorization of the 

Magnuson-Stevens Fishery Conservation and Management act the USACE has constructed an adult fish 

collection facility and is actively transporting Chinook salmon above the dam. Therefore, we consider the 

Breitenbush River upstream of Detroit Dam to be EFH. This project would not adversely affect EFH 

because of the no cut buffers we established along ESA fish bearing streams, project design elements, and 

the implementation of Best Management Practices (BMPs).

The most common salmonid sport fish for which there is habitat on the Detroit Ranger District are spring 

Chinook salmon, rainbow trout, and coastal cutthroat trout. 

The Hwy 46 project will have a neutral effect on LWD at the 5th field watershed scale. Improvements in 

road condition with implementation of Alternative 2 or 3 will decrease sediment inputs. Riparian structure

and composition will improve. There will be no change to Dissolved Oxygen, Chemical Nutrients, 

Physical Barriers, Substrate Composition, Pool Frequency and Quality, Off Channel habitat, Refugia, 

Streambank Composition, or Flood plain Connectivity with the implementation of any of the alternatives 

at the 5th field watershed scale.

The Hwy 46 Project would maintain habitat conditions for aquatic management indicator species in the 

project area. Therefore, the Hwy 46 Project would not contribute to a negative trend in viability on the 

Willamette National Forest for these management indicator fish species.

The biological evaluation found that the Hwy 46 Project may have beneficial impacts to listed caddisflies. 

This is due to an improvement in the type of organic matter they consume. That is, a small increase of 

deciduous leaves due to the small gaps that would be created near streams where we do not expect 

significant increases in stream temperatures.

Both action alternatives would have similar effects on fish and aquatic insects. No cut buffers were 

established to provide sources of woody material, and thinning would improve structural and vegetative 

diversity in the monoculture stands of Douglas-fir in riparian reserves. Gaps in certain plantations would 

allow more sunlight to reach the stream and increase primary productivity. Eventually hardwoods will 

colonize these gaps and provide a higher quality of nutritional organic matter to the stream community. 

These gaps would not be large enough to significantly affect stream temperatures. Fall and leave 

treatments would provide an immediate source of large woody material to two fish bearing streams that 

are lacking that habitat element.

3.5.2 Scale of Analysis

The Fisheries section includes a description of the fisheries resource in the project area and assessment of 

implementation of three project alternatives. This assessment builds on the soil and hydrology analysis of 

physical parameters and their effects to soil stability and compaction, water quality, beneficial uses of 

water, and riparian resources. The fisheries discussion further examines effects on water quality, habitat 

and biological parameters on MIS fish including spring Chinook salmon and trout. Please refer to the 

hydrology report for project overview.

Regulatory Framework

• Detroit and Big Cliff Reservoirs are managed by the Army Corps of Engineers
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• 1990 Willamette National Forest Land and Resource Management Plan Specific direction IV-3, 

IV-4 as well as 28 separate S&Gs) 

• Oregon Dept. of Environmental Quality Memorandum of Understanding (Water Quality Best 

Management Practices 1998)

• Clean Water Act PL92-500 as amended in 1977 and 1982 (sections 208, 209, 303, 305, 319)

• Oregon Administrative Rules (Chapter 341, Division 41) identifies beneficial uses

• 1994 Northwest Forest Plan Aquatic Conservation Strategy, Tier II watershed, and amends S&Gs

• Breitenbush Watershed Analysis update February 2014.

• 1993 Forest Ecosystem Management Assessment Team Report (FEMAT)

• Federal Water Pollution Control Acts of 1970, 1965, 1956, 1948 and 1972 Amendment of (PL92-

500)

• Best Management Practices last published in April 2012 by USFS.

• 2005 Northwest Forest Plan Temperature TMDL Implementation Strategies

• Endangered Species Act (ESA) of 1973

• Magnuson-Stevens Fishery Conservation and Management Act Reauthorization

• Wild and Scenic Rivers Act

3.5.3 Affected Environment

The Hwy 46 project is distributed along the Northern and Southern portions of the Breitenbush River 

watershed, upstream of the Humbug campground. Primary streams within the project area include the 

Breitenbush River, South Fork Breitenbush River, North Fork Breitenbush River, East Humbug Creek, 

Devils Creek, Scorpion Creek, Cultus Creek, Leone Creek, Hill Creek, Mansfield Creek, Short Creek, 

Skunk Creek, and Roaring Creek. There are two small lakes included in the project are, Leone lake (6.5 

acres), and Short Lake (2.3 acres). There are also numerous non-fish bearing streams located in the 

project area. 

A variety of fish species can be found in the Breitenbush watershed.

Table 32 Fish Species of the Breitenbush Watershed

Common Name Scientific Name

spring Chinook salmon* Oncorhynchus tshawytscha

coastal cutthroat trout* Oncorhynchus clarki

rainbow trout* Oncorhynchus mykiss

mountain whitefish* Prosopium williamsoni

longnose dace Rhinichthys cataractae

speckled dace* Rhinichthys osculus

redside shiner* Richardsonius balteatus

sculpin species* Cottus spp.

brook trout* Salvelinus fontinalis

*Confirmed sighting
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Management Indicator Species 

The Willamette Forest Plan recognizes anadromous and resident salmonids as economically important 

species and designates them as management indicator species for riparian habitat and water quality. 

Salmonids are good indicators because they are predators in the stream ecosystem. This means that they 

are not only affected by the physical conditions of their habitat but also by the metabolic energy pathways 

in the watershed from primary production to decomposition. 

Coastal cutthroat trout are ubiquitous in the project area. They can be found in small tributaries, in the 

Breitenbush River, North Fork Breitenbush River and in Short and Leone Lake. Rainbow trout tend to be 

seen primarily in the Breitenbush River downstream of Breitenbush Campground. This is due primarily to 

Oregon Department of Fish and Wildlife stocking activities of rainbow trout which ends at Breitenbush 

campground. Previous timber management in riparian areas has affected aquatic habitat quality by 

altering the quantity, size and recruitment source of large woody material, which can affect substrate 

storage, habitat composition (e.g. pools, riffles, off channel habitat) and water temperature.

The combination of habitat condition, and ODFW stocking of non-native rainbow trout is believed to 

suppress native cutthroat trout abundance in the project area through competition with non-native species. 

ESA Listed Species 

Spring Chinook salmon migration, spawning and rearing occur in the mainstem Breitenbush and North 

Fork Breitenbush Rivers within the project area. This species is listed as Threatened under the 

Endangered Species Act. 

Low gradient reaches of the mainstem Breitenbush and North Fork Breitenbush in the project area are 

used as spawning habitat by spring Chinook salmon. Spawning in these reaches occurs in September and 

October, with fry emergence about 3 months later. 

High water quality in the form of cold water temperature and high habitat quality remaining in the upper 

sub-basin provides the largest remaining core area for spring Chinook salmon reproduction and rearing in 

the basin. The project area portion of the sub-basin historically provided greater quantity and quality 

habitat with a greater level of channel complexity and off-channel area. Previous management activities 

such as stream cleaning, reduced large wood recruitment potential, and modified flow, sediment and wood 

routing regimes (as modified by dams and roads), have diminished salmon production in the project area. 

Spring Chinook salmon and winter steelhead originally spawned in the North Santiam sub-basin 

(including the Breitenbush River). The habitat was blocked by Detroit Dam in 1953 and these 

anadromous species were extirpated from the watershed. Since 2000, ODFW has trapped and hauled adult 

spring Chinook salmon around the dams to the Breitenbush River and the Upper North Santiam River to 

naturally spawn. The USACE (United States Army corps of Engineers) and the Oregon Department of 

Fish and Wildlife (ODFW) have a goal of moving up to 3000 adult spring Chinook salmon upstream of 

the dam each year. 

This trap and haul effort has changed management in the Watershed in a couple of ways. First, it has 

increased the number of Class 1 anadromous streams in the Watershed. It is assumed that the historically 

occupied habitat in the Breitenbush River is currently being utilized by both adult and juvenile spring 

Chinook salmon. Second, the National Marine Fisheries Service (NMFS) recently completed their final 

listing determinations for 16 Evolutionary Significant Units (ESUs) of West Coast Salmon (70 FR 37160; 

effective August 29, 2005). The Upper Willamette River Chinook salmon ESU is considered to be 

threatened under the Endangered Species Act (ESA), confirming their earlier determination (64 FR 
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14308; effective May 24, 1999). The Upper Willamette River Chinook ESU includes all naturally 

spawned populations of spring-run Chinook salmon in the Clackamas River and in the Willamette River, 

and its tributaries, above Willamette Falls, Oregon. Detroit Dam is the upper limit of critical habitat for 

listed Chinook salmon. The Magnuson-Stevens Fishery Conservation and Management Act lead to the 

designation of Essential Fish Habitat (EFH) for commercially harvested fish, which includes Chinook 

salmon on the Willamette National Forest. The National Marine Fisheries Service (NMFS) designation of 

EFH did not include any streams above Big Cliff dam.

Future actions include the trapping and hauling of Upper Willamette Steelhead and the possible 

reintroduction of Bull Trout. 

Bull trout where once present in the Breitenbush River but no documented record of bull trout exists since 

the early 1970s and they are considered extirpated from the watershed. The High Cascades portion on the 

eastern side of the project area contains the youngest volcanic rocks of the Cascade range, mostly 

Pliocene or Pleistocene in age. Some of the oldest lava flows of the High Cascades appear to have 

covered the youngest Western Cascade strata. Since then, most volcanic events have generally been 

confined to the High Cascades proper (Hammond, et al, 1980). Most of the High Cascade volcanic 

eruptions, which form the broad base of the High Cascade platform, contain basalt flows, flow breccias, 

and pyroclastic deposits. They represent the early part of the volcanic eruptions, and their ages range from 

about four to one million years. The youngest and most recent deposits are generally less than one million 

years in age and include intra-canyon flows, low shield volcano out pouring, and the more pronounced 

stratacone deposits, like those on Mount Jefferson or Three Fingered Jack (Walker and Ducan, 1989) 

(Hammond, P. E., et al, 1980). 

Aquatic Insects

Three aquatic insects found on the Regional Forester’s sensitive species list (SSL) have been documented 

on the Willamette National Forest. These aquatic insects are all caddisflies and little is known about them. 

In fact, the common name for all of these caddisflies is “A Caddisfly.” A short summary of the 

distribution and known habitat associations is provided below. For a more detailed discussion on these 

species, see the Fisheries Biological Evaluation.

Rhyacophila chandleri: In Oregon, this species is documented on Willamette, Deschutes, and Umpqua 

National Forests. It is documented on the Willamette National Forest as a rare insect on the H.J. Andrews 

Experimental Forest. The entire Rhyacophila genus, whose name is derived from the Greek roots rhyaco 

(stream or torrent) and philia (fondness), is confined to running water. In the Cascade Mountains of 

Oregon, this species is associated with very cold, larger spring-fed streams (USDA Forest Service and 

USDI Bureau of Land Management 2012). Elevations of known populations range from around 1219 to 

1700 m (4000 to 5600 ft.) in Oregon. The larval behavior and diet of R. chandleri is not known, but 

probably similar to others in the Rhyacophila verrula-group. While most Rhyacophila larvae are obligate 

predators, feeding on aquatic invertebrates, members of the verrula-group are unique in having 

phytophagous diets (i.e. feeding on plant material) consisting largely of filamentous algae, diatoms, 

detritus, bryophytes, liverworts, and/or other non-animal material (USDA Forest Service and USDI 

Bureau of Land Management 2011 and 2012).

Rhyacophila leechi: In Oregon, R. leechi is documented to occur on the Willamette National Forest and 

on Bureau of Land Management land in the Medford District. Adults have been collected from springs 

and cold, spring-fed streams. This species appears to require colder water temperatures than the common 

and more widely distributed Rhyacophila verrula, and is likely confined to smaller, headwater streams 

and springs (USDA Forest Service and USDI Bureau of Land Management 2011). Oregon sites range in 
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elevation from 440 to 980 m (1444 to 3210 ft.). The larval behavior and diet of R. leechi is not known, but 

probably similar to others in the Rhyacophila verrula-group. 

Namamyia plutonis: This species of caddisfly occur in the Coast and Cascade Ranges of Oregon and 

California (USDA Forest Service and USDI Bureau of Land Management 2010). Populations tend to be 

extremely localized and are patchily distributed. Currently, fewer than 30 locations are known to contain 

this caddisfly, which occurs in low numbers. Namamyia plutonis can be found associated with small 

streams in densely forested old growth or mature forests, but the majority of the documented occurrences 

are between 30 and 50 years old. Most species of trichopterans have very specific preferences regarding 

water temperature, flow, oxygen levels and substrate characteristics.

Sampling for aquatic organisms (macroinvertebrates) has not taken place in the Breitenbush Watershed, 

however samples were taken on Horn Creek, tributary to the North Santiam River in 2012 and 2013. 

Samples were taken and members of the genus Rhyacophila were found but none of the species found on 

the sensitive species list (SSL) was documented in those efforts. No members of the genus Namamyia

were found in any of these samples.

Despite not finding the species on the SSL the Breitenbush Watershed provide the type of habitat that 

Rhyacophila requires for survival (i.e. large spring-fed rivers) so we treat that habitat as potentially 

occupied. Namamyia plutonis tend to be found associated with small streams in densely forested old 

growth or mature forest watersheds (USDA Forest Service and USDI Bureau of Land Management 2010). 

We did not sample this type of habitat but it does exist in the project area. 

In-stream Habitat 

The condition of many in-stream habitat elements contributes to overall aquatic habitat quality. These 

elements include, but are not limited to:

Stream Temperature Large Woody Material

Dissolved Oxygen/Turbidity Pool Frequency and Quality

Chemicals/Nutrients Off-Channel Habitat

Riparian Structural and Species Diversity Refugia

Physical Barriers Streambank Condition

Substrate Composition Floodplain Connectivity

Stream temperature for most streams in the watershed is functioning properly and shade continues to 

recover from historic timber harvest. Dissolved oxygen is high, turbidity and fine sediment delivery is 

relatively low (see exception for Short and Cultus Creeks in Hydrology and soils report), and there is no 

indication of chemical contamination. The overall lack of deciduous and herbaceous vegetation may be 

impacting stream ecosystems by limiting productivity. Due to the relatively low carbon:nitrogen ratio, 

deciduous litterfall is much more readily usable and nutritious to the aquatic foodweb than is conifer 

litterfall. 

Physical barriers exist below the project area in the form of Detroit and Big cliff Dams. In the project area 

barriers, in the form of impassible or variable pass stream/road culverts, exist in several locations. Most of 

the barrier culverts exist on small cutthroat inhabited streams. As funding becomes available these barrier 

culverts are being replaced with AOP (aquatic organism passage) designed crossings. There are four 

barrier culverts on medium sized streams (Mansfield, Short (2), and Devils creek). Cost estimates for 
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these four crossings is at least $500k+ each. With current funding levels it is unlikely that any of these 

four crossings will be replaced soon.

In-stream large wood frequency in the Breitenbush River and many tributaries is considered to be below 

historic levels and not properly functioning, mostly due to the decrease in size of recruited wood and 

previous management actions that removed large wood from the main river systems. The lack of large 

wood impacts pool frequency and quality, off-channel habitat, refugia, and floodplain connectivity which 

are all not functioning properly. Streambank condition is good throughout the watershed due to root 

strength associated with high vegetative growth. In general, the habitat elements that contribute to quality 

fish habitat are in a somewhat impaired condition, primarily due to the removal of large woody material. 

These conditions need to improve in order to maintain and increase native fish populations in the 

watershed. For a detailed discussion of the project area on each of the elements listed above see the 

Fisheries Biological Assessment located in the project file.

Planning efforts are currently underway to significantly increase the large wood component in the 

Breitenbush River and its tributaries.

T
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able 33 Woody Material Counts for Some Streams in the Project Area

Stream Reach Wood/Mile

Small/Medium/Large

Wood/Mile

Medium/Large Only

Short Creek (2013) 1 27 23

2 18 11

S. Fk Breitenbush River 

(2009)

1 28 9

2 90 26

Mansfield Creek (2013) 1 No Data No Data

2 19 4

Hill Creek (2014) 1 46 27

2 52 14

Leone Creek (2014) 1 52 14

2 36 23

3 22 6

Devils Creek (2014) 1 16 7

2 27 10

3 35 17

N. Fk Breitenbush River 

(2009)

1 27 4

2 36 9

3 28 9

4 90 25

Small – are at least 12 inches in diameter at 25 feet from the large end.

Medium – are 24 inches to 36 inches in diameter at 50 feet from the large end.

Large – are greater than 36 inches in diameter at 50 feet from the large end.

Riparian

More information and description of the existing condition for riparian reserves can be found in the 

hydrology and soils sections of this FEIS. In the project area riparian reserves can be found in variety of 

conditions from young stands of dense Douglas-fir monocultures (i.e. plantations) to mature and old 

growth stands with a greater diversity in tree species and light availability to the stream ecosystem. Given 

the size of the project area, riparian reserves are found along a variety of water bodies including seasonal 

flowing streams, perennial flowing non-fish bearing streams, fish bearing tributaries and a river (the 

Breitenbush), small ponds, a large “sag pond” (Short Lake), and Leone Lake.

Recent forest research in the Coast Range and Western Cascades indicates that existing old growth stands 

developed with natural stand densities of 40 to 60 conifers per acre (Tappeiner et al, 1997; Poage & 

Tappeiner 2002). There is one plantation in the project area that has 397 trees per acre. Post-harvest 

thinning densities in riparian reserves would range from a residual approximately 70 trees per acre to 

approximately 90 trees per acre with the average stand having approximately 84 trees per acre. All 

riparian reserves where thinning is proposed would have a no cut buffer, except for units 6, 100, 190, 430, 

and 520 (see Appendix B for specific information on all units) and thinning would maintain 40% canopy 

cover in the rest of the reserve. 
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On site assessment of riparian reserves found that nineteen of the proposed unit’s riparian reserves have a 

good mix of hardwoods in the stand so no treatment was recommended in those areas. These stands 

appear to be on their way to achieving Aquatic Conservation Strategy objectives without any need of 

silvicultural activities. 

Some riparian reserves in units did not have a good mix of hardwoods in the stand so silvicultural 

treatment is recommended in those areas. These stands are dense, dark plantations of almost pure 

Douglas-fir with either very few hardwoods in the riparian reserve or none at all and very little sunlight 

reaching the forest floor or the stream channels. These conditions were verified using satellite imagery 

and on the ground field investigations. In some cases thinning is recommended and in a few stands noncommercial “near stream gaps” are proposed. In these quarter acre gaps all trees would be felled and left 

on site. These sites would be monitored to ensure that hardwood trees colonized the site. We expect that 

within 6 to 10 years there would be a stand of hardwood trees on the site. If needed, we would plant 

hardwoods (i.e. vine maple, big leaf maple, and red alder). Units where near stream treatments are 

recommended are: 6, 100, 190, 430, and 520. These stands range in age from 40 to 48 years old. 

Preliminary data collection at H.J. Andrews Experimental Forest in 2013 support the fundamental idea 

that historically, light regimes in these headwater ecosystems were highly variable with areas of low light 

where canopies cover the stream and areas of high light associated with canopy gaps. The McKenzie 

Ranger District worked with Oregon State University researchers to collect observational information on 

gaps on a tributary to McCrae Creek. This creek is comparable in size to the streams on which we are 

proposing streamside treatments. Results from this and other streams in the region showed that there are 

more gaps in the old growth reach and greater light availability to the stream channel compared to the 

plantation. In their assessments of juvenile trout growth through the summer, they observed greater 

growth rates in young-of-year cutthroat in the old growth reach as compared to the plantation reach.

On several streams we propose to fall and leave trees in the channel. Table 12, Chapter 2, page 48

summarizes proposed treatments.

Leone, Fox and Hill Creeks are tributaries to the Breitenbush River and are inhabited by coastal cutthroat 

trout. All three are relatively small streams and relatively steep (5-8% gradient and steeper). Two 

unnamed tributaries that run through units 430 and 520 respectively, are class three stream channels 

(perennial, non-fish). In unit 520 the riparian area is a monoculture of Douglas fir with virtually no 

understory. This tributary drains to the South Fork Breitenbush. The second unnamed tributary running 

through unit 430 is very steep (>15 %) and shows evidence of episodic debris flows. This tributary drains 

into the North Fork Breitenbush. Treatment of riparian stands in this unit have two goals. The first is to 

increase the diversity of the riparian stand. The second goal is to fall trees into this debris prone channel 

for future LWD deposition in the North Fork Breitenbush River. 

Pool frequency and quality, off-channel habitat, refugia, streambank condition, and floodplain 

connectivity for most streams in the project area are currently classified as not properly functioning. This 

is due primarily to past management actions that removed wood from streams and past management 

actions that failed to leave intact riparian buffers.

3.3.4 Environmental Consequences 

Direct and Indirect Effects

The management activities proposed have the potential to affect the habitat elements listed above, 

particularly stream temperature, water quality and quantity, riparian structural and species diversity, and 
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large woody material which creates pools, off-channel habitat, refugia, and floodplain connectivity. 

Because salmonids and caddisflies depend on the functioning of these habitat elements, the effects to 

habitat elements and how they may impact biota are analyzed. 

Alternative 1 – No Action

Alternative 1 would result in little or no change to the habitat elements listed above. Landscape delivery 

of fine sediment, as modified by the road and stream crossing network, would remain as it is and subject 

only to scheduled maintenance. The No-Action alternative would leave deteriorating roads and culverts 

untreated, yielding fine sediment similar to current levels. The current levels would remain within the 

range of conditions necessary to sustain native aquatic biota, but not optimally so. Periodic stream 

crossing failures may occur at undersized and outdated culverts, potentially delivering large pulses of fine 

sediment to fish bearing reaches. Culvert failures may induce stresses on resident fish populations, but not 

at magnitudes that would be expected to extirpate local populations. Depending on proximity to listed fish 

habitat, particularly spawning habitat, culvert failures could result in take of listed fish. High sediment 

loads may also impact sensitive caddisfly populations and other native biota.

Current rates of large wood recruitment, provided mostly by stem mortality (from competition, disease, 

wind and snow downed trees) and bank erosion, would be maintained. Alternative 1 would provide a 

slightly higher rate of natural in-stream wood recruitment compared to the action alternatives. Where the 

action alternatives protect about 90% of the wood recruitment zones, the No-Action alternative would 

protect 100%. In some streams, recruitment trees are of sufficient size to meet ACS Objectives (Appendix 

E), but in other streams with small diameter riparian stands the aquatic benefit is limited, namely through 

the reduced ability to store sediment and organic matter and contribute to habitat forming processes (e.g. 

scour). Though small wood has some value, particularly in the smaller headwater reaches, the longevity 

of recruited small diameter trees is short-lived, as they break down through abrasion and decomposition 

more rapidly compared to large trees. Small diameter trees are also more likely to be transported out of 

the system. In-stream wood abundance is low for most streams in the project area and is largely due to the 

lack of large enough wood to remain stable in channels. Implementing the No-Action alternative would 

maintain slower tree growth rates than the action alternatives.

The No-Action alternative would not benefit from thinning to enhance vegetation. Desired riparian 

conditions – high species and structural diversity with large dead and down wood – would slowly develop 

over time (several decades) and depend solely on natural thinning events (stem exclusion mortality and 

disturbance). Without management to increase the abundance of deciduous and herbaceous vegetation in 

dense, conifer-dominant stands, ecosystem productivity would remain at relatively lower levels. Active 

restoration of riparian stands that currently do not meet ACS Objectives would not occur. In addition, the 

currently dense riparian stands would be at greater risk to high severity fire, insect infestation, and disease 

– all carried more efficiently through overstocked stands.

Alternatives 2 and 3

The Riparian Reserve management strategy was specifically designed to accelerate complex forest 

structure while protecting and enhancing the habitat elements important to aquatic biota. No-harvest and 

no-treatment buffers on streams were established to minimize effects to aquatic species and their habitat. 

Treated stands account for less than 6.0 % of all the Riparian acres in the project area and the volume loss 

of small and medium wood would be immeasurable at the 6th field scale. Any trees, or parts of trees 

felled in protection buffers as part of harvest operations would be left on site. There would be no yarding 

of trees out of the protection buffers. These residual trees left in treated units near streams and untreated 

stands in the affected watersheds would leave a supply of whole trees as well as small and medium wood 

available for short-term and long-term recruitment to the stream network. Thinning inside designated 

riparian reserve units would lead to an increase in understory development, increased plant diversity and 
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trend towards stand characteristics that resemble old growth forests. This prescription would maintain 

ACSO (Aquatic Conservation Strategy Objectives).

Retention of the larger trees in the riparian units allows for additional potential recruitment, outside of the 

protection buffers, of future LWD to stream channels in headwater stream areas. This increases the wood 

component and fish habitat is improved as this wood is transported into lower fish bearing reaches. Wood 

that does not hold in streams inside the project area would be transported to larger streams and potentially 

to Detroit Lake. Wood that reached the lake would provide minimal habitat for spring Chinook salmon

habitat in Detroit Lake and none in the lower North Santiam River because wood that makes its way to 

the reservoir is blocked by the dam and removed for boater safety. Historically, wood that was transported 

from slopes in the project area to the North Santiam River would contribute to fish habitat throughout the 

North Santiam and Willamette Rivers.

Project design features in Chapter 2, Table 13 were incorporated into all activities to similarly protect 

aquatic resources. Due to these project design features, protection measures, and enhancement treatments, 

Alternatives 2 and 3 would result in short-term “negligible”, “discountable”, or “insignificant” (official 

terms used in the Fisheries Biological Assessment) negative effects as well as beneficial effects to the 

habitat elements listed above. For a detailed discussion of how the project actions affect each habitat 

element, see the Fisheries Biological Assessment located in the project file. 

Thinning outside the primary shade zone and limiting thinning in the secondary shade zone of perennial 

streams would protect stream shade and temperature within the project area. See the Stream Shade and 

Temperature Section for details. 

Based on hydrologic analysis, changes in flow regimes, including peak flows, are not anticipated from 

proposed activities. Aggregate Recovery Percentage (ARP) levels, which are used to calculate the 

potential increase of peak flows, are maintained above recommended values for all alternatives in the 

affected sub-watersheds even immediately after implementation when the potential for adverse impacts to 

vegetation would be greatest.

Sediment delivery is expected to increase during project implementation while culverts are being installed 

and replaced and road maintenance is occurring. There could be a short term (immediately after the first 

rain of the season) turbidity effect but juvenile and adult salmonids appear to be little affected by 

ephemerally high concentrations of suspended sediments that occur during most storms and episodes of 

snow melt (Bjornn and Reiser 1991). Once the project is complete, sediment production rates return to 

slightly less than pre-project conditions. Either Alternative 2 or 3 would reduce the potential for runoff 

effects and culvert failures that may affect Riparian Reserves or water quality. See the Sedimentation 

Section for details. Soil disturbance is likely to occur when trees are felled and yarded with ground based

or cable logging systems. Much of this erosion would be localized and is not expected to enter stream 

channels. Sediment that is transported to stream channels is expected to be minor because the majority of 

sediment would be trapped within the no-harvest buffers before it reaches the streams. Haul related 

sediment generation and transportation via ditch lines will be disconnected from stream systems by 

locating cross drains in areas where sediment can infiltrate through the forest floor prior to stream 

crossings. The project was designed to minimize the amount of sediment that may enter a stream channel 

and be transported to fish habitat. Distance of timber harvest activity to fish habitat, the presence of a 

glacial terrace to facilitate sediment deposition, and in most cases, absence of surface connection between 

harvest activity and fish habitat further reduces risk of fine sediment transport. All live stream crossings 

will have new cross drains installed within 100-200 feet of crossing to disconnect road drainage from live 

streams. These crossings will be located, with input from the hydrologist, fish biologist, and road engineer 

to minimize any potential surface connection to waterways. All of the units on the South side of the 

Breitenbush River (with the exception of unit 80) will have haul out the Boulder Ridge road. This road is 
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paved for 6.7 miles down to HWY 22 in the North Santiam Watershed. Haul along gravel surfaced roads 

is planned for only one unit (unit 80) adjacent to ESA listed fish habitat. There may be increased 

sedimentation to suspended sediment and substrate at the site-scale (culvert Stream crossings), but the 

probability of sediment reaching and affecting fish habitat is discountable due to distance and volume of 

inputs.

Thinning outside of the primary wood recruitment zone was designed to retain the majority of potential 

wood (>90%) while achieving desired vegetation characteristics that support productive aquatic 

communities. The action alternatives may have a slightly lower rate of in-stream wood recruitment than 

the No-Action alternative, but the benefits to vegetation diversity and accelerated tree growth would be 

greater. The major wood recruitment process on the Breitenbush River and its tributaries is stream 

adjacent recruitment. A 2011 research paper determined that 90% of all LWD inputs to stream channels 

originated within 60 feet (N.T. Johnston, 2011). There are no commercial thinning activities in the action 

alternatives within 172 feet of ESA-listed fish habitat and 20 units adjacent to other fish-bearing streams 

with Management Indicator Species (MIS). Of those 20 units, 17 have a minimum 100 foot no-cut/entry 

buffer. The remaining three units would have fall and leave into the stream channel to improve riparian 

stand diversity (see discussion on riparian units). The probability that thinning in Riparian Reserves

would adversely affect water quality, habitat complexity, sediment storage capacity or floodplain 

processes in fish–bearing streams is very low. These potential effects on ESA-listed fish, MIS, and 

sensitive caddisflies are not expected to be measureable for the following reasons:

• Of the streams that do have surface connection to ESA-listed fish habitat, approximately half of 

them are intercepted by roads. If debris makes it past those roads, the flat glacial terrace acts as a 

depositional area and stores most of the debris before reaching listed fish habitat. 

• Three units adjacent to fish-bearing streams with MIS (Units 6, 100, and 190) will have 

management occurring in the primary wood recruitment zones. Proposed management actions in 

these units involve falling and leaving thinned trees in the stream channel. 

• Hazardous fuels treatment units are located adjacent to the Breitenbush River, but no treatment is 

planned to occur within the steam influence zone (0-172 feet). Fire would be allowed to back into 

riparian zones but is not anticipated to have significant, or measurable impacts (see hydrology 

report). Therefore, there would be no impacts to ESA-listed fish or MIS or their habitat from 

these activities. 

• Conditions in currently functioning portions of Riparian Reserves would be maintained. In 

overstocked, conifer-dominant portions lacking structural and species diversity, thinning would

occur in upland units with tributary streams to ESA-listed fish habitat and along units with MIS. 

The desired benefit of thinning in Riparian Reserves is to improve stand structure, vegetation 

diversity, and accelerate development of large diameter trees to acquire desired vegetation 

characteristics needed to attain Aquatic Conservation Strategy Objectives (Appendix E). 

Management of these stands would accelerate the ability of Riparian Reserves to provide 

adequate stream shade, root strength and bank stability, sediment filtration and nutrient cycling, 

large wood supply to waterbodies and floodplains, organic matter input, and habitat for ripariandependent wildlife. As this landscape rarely transports the products of disturbance, recruited 

material has little opportunity to migrate to ESA-listed fish habitat. Improvements in riparian 

stand diversity are expected to be of greatest benefit to MIS, primarily cutthroat trout.

Cumulative Effects

Alternative 1 – No Action

Alternative 1 would perpetuate the effects of dense forested stands in previously harvested areas. Most of 

these areas have little to no hardwood vegetation in the riparian reserve. These areas are delivering large 

amounts of Douglas-fir needle cast to the streams. Douglas-fir needles are not as nutritionally available to 
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the stream community as are hardwood leaves. The hardwood analysis we conducted for all the riparian 

reserves in the Breitenbush River project area found that 2.0% of the area was hardwood or hardwood 

shrub. Roads would receive periodic maintenance depending on funding. Stream crossings will continue 

to degrade over time with an increase potential for stream crossing failure. These crossing failures may 

adversely impact ESA fish spawning areas, depending on location and magnitude. 

Alternatives 2 and 3

Cumulative effects for fish and aquatic insects are analyzed at the site scale and at the watershed scale 

(i.e. Breitenbush River watershed). Some effects are short term (1-10 years) and others are long term (50-

100 years).

All recent and planned timber harvest and hazardous fuels reduction projects were and would be designed 

with similar protection measures, design features, and Best Management Practices that minimize effects 

to water quality and aquatic resources. Each of the past projects listed in Appendix D were analyzed for 

effects to riparian condition and were found to have no effect, negligible effect, or beneficial effect. The 

negligible or beneficial effects combined with the minor impacts expected from the Hwy 46 project 

would not measurably contribute to impaired riparian conditions.

Road work associated with the proposed action will result in reduced sediment inputs to streams and 

MIS/ESA impacts over the short term (0-5years) and long term (10+ years). Timber haul (dry season and 

wet season) does have the potential to impact MIS and ESA species and their habitats. See the Biological 

assessment located in the project file for a more detailed description of impacts associated with hauling 

activities. 

Portland General Electric and Bonneville Power transmission line corridor runs through the project area 

and crosses approximately 35 streams in the project area. This corridor is maintained in an early-seral 

condition, reducing shade and potential wood recruitment. This minor amount of affected area combined 

with the minor impacts expected from the Hwy 46 project would not measurably contribute to increased 

impaired riparian conditions.

Compliance with the Forest Plan and Other Regulatory Direction

Aquatic Conservation Strategy

See Appendix E for a discussion on compliance with the Aquatic Conservation Strategy objectives and 

Standards and Guidelines.
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Endangered Species Act

Upper Willamette River spring Chinook salmon are listed as threatened on the Endangered Species list. 

This species occurs in the Breitenbush River. The fisheries biological evaluation is where we analyze 

effects to listed fish species. This analysis found that the Hwy 46 Project “may affect, not likely to 

adversely affect” Upper Willamette spring Chinook salmon. In order for the Forest Service to obtain 

authorization we must conduct consultation with the fish agencies under Section 7 of the ESA.

The Forest Service is required to complete consultation before the Record of Decision can be signed for 

this FEIS. The Forest Service would be required to follow all terms and conditions provided by the fish 

agencies in their Biological Opinions.

Magnuson-Stevens Fishery Conservation and Management Act

Essential fish habitat under the Magnuson-Stevens Fishery Conservation and Management Act is 

designated in all areas except above impassible dams (Big Cliff and Detroit Dams), and natural migration 

barriers. The Magnuson-Stevens Fishery Conservation and Management Act reauthorization in 1996 

established a new requirement for essential fish habitat that requires Federal agencies to consult with the 

National Marine Fisheries Service on activities that may adversely affect essential fish habitat. Essential 

fish habitat for the Pacific coast salmon fishery means those waters and substrate necessary for salmon 

production needed to support a long-term sustainable salmon fishery and salmon contributions to a 

healthy ecosystem. The species designated in the Breitenbush River is spring Chinook salmon.

Technically the Breitenbush River upstream Big Cliff and Detroit Dams is not considered EFH but since 

reauthorization of the act the USACE has constructed an adult fish collection facility and is actively 

transporting Chinook salmon above the dam. Therefore, we treat the Breitenbush upstream of Detroit 

Dam as EFH. This project would not adversely affect EFH because of the no cut buffers we established 

along EFH fish bearing streams, project design elements, and the implementation of Best Management 

Practices (BMPs).

Management Indicator Species 

The Willamette Forest Plan recognized anadromous and resident salmonids as economically important 

species and designated them as management indicator species for riparian habitat and water quality. 

Salmonid fish are good indicators because they are predators in the stream ecosystem. This means that 

they are not only affected by the physical conditions of their habitat but also by the metabolic energy 

pathways in the watershed from primary production to decomposition. The most common salmonid sport 

fish for which we have habitat on the Detroit Ranger District are spring Chinook salmon, rainbow trout, 

and coastal cutthroat trout. 

Management Indicator Fish Viability Statement: The Hwy 46 Project would maintain habitat conditions 

for aquatic management indicator species in the project area. Therefore, the Hwy 46 Project would not 

contribute to a negative trend in viability on the Willamette National Forest for these management 

indicator fish species.

Sensitive Species (Caddisflies)

The biological evaluation found that the Hwy 46 Project may have beneficial impacts to listed caddisflies. 

This is due to an improvement in the type of organic matter they consume. That is, a small increase of 

deciduous leaves due to the small gaps that would be created near streams where we do not expect 

significant increases in stream temperatures 
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3.6 Wildlife

3.6.1 Summary of Effects Analysis

Prior to the 2017 forest fires Alternative 2 would increase early seral habitat in the planning area to 1.46% 

or 460 acres. Alternative 3 would increase early seral habitat to 1.29% or 405 acres. With the 2017 forest 

fires there was an increase in early seral habitat. There are two measures of early seral habitat. Crown 

mortality was measured by satellite data for a total of 16 acres in the scorpion fire and 68 acres in the 

short devils fire. Another measure was of which combined ground fire intensity and canopy mortality 

which was used to predict future mortality which found 521 total acres which are predicted to become 

early seral habitat. 

Based on crown mortality alternative 2 would increase early seral habitat in the planning area to 1.75% or 

544 acres. Alternative 3 would increase early seral habitat to 1.57% or 489 acres. 

Based on ground fire intensity and canopy mortality it is predicted that in the future alternative 2 would 

increase early seral habitat in the planning area to 3.15% or 981 acres. Alternative 3 would increase early 

seral habitat to 2.97% or 926 acres. 

Spotted owls are protected from nesting disruption by seasonal restrictions on proposed activities near 

nest patches. Proposed hazardous fuels treatments in nest patches would be dropped from consideration. 

Suitable and dispersal habitat is proposed to be removed by the project activities where meadow 

restoration, wildlife gaps, sugar pine restoration, dominant tree release, quality early seral and one road 

relocation are would occur. Alternative 2 would remove an estimated 131 acres of suitable habitat and 96 

acres of dispersal habitat. Alternative 3 would remove an estimated 5 acres of suitable habitat and 32 

acres of dispersal habitat.

Forest Service Regionally Sensitive species are known to exist in the planning area and where located 

during surveys are protected by seasonal restrictions on project activities. With seasonal restrictions no 

impacts are expected to occur to regionally sensitive species.

Survey and Manage Species were not located in proposed project activity areas so direct impacts to these 

species is not expected to occur. 

Bald eagle and osprey surveys were conducted with one osprey nest located. Seasonal operating 

restrictions would protect the osprey nest from disturbance impacts. The nest tree is outside proposed

project treatment areas and would not be impacted.

Management indicator species were analyzed with species dependent on early seral habitat identified as 

limited by lack of habitat. Early seral habitat is proposed to be increased by the proposed project where 

meadow restoration, wildlife gaps, sugar pine restoration, dominant tree release, quality early seral units 

would occur.

3.6.2 Affected Environment – Early Seral Habitat for Wildlife

Age class diversity in forest stands is important as some species of animals and plants depend on younger 

stages of forests for their feeding, nesting, and breeding requirements, whereas other species thrive in 

middle age or old forests. Early seral habitat (defined as less than 20 years old for this wildlife analysis) is 

of key importance to an estimated 156 species of wildlife in the central Oregon Cascades. 
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Historically, early seral habitat in the project area was created from stand-replacing fires and regeneration 

harvest. Changes in forest management on Federal lands in the past 30 years, including fire suppression 

and reduced regeneration harvest have resulted in fewer acres of early seral habitat creation. Additionally, 

fire suppression and reduced regeneration harvest have resulted in a much higher proportion of dense, 

closed canopy stands. Consequently, there is less structurally rich and diverse quality early seral habitat in 

the project area than in the past. Currently, early seral habitat within the Hwy 46 project area is limited to 

powerline corridors, recent stand replacing fires and a few small naturally occurring meadows. 

The Hwy 46 project area occurs in eleven planning subdrainages: Humbug, Fox, Scorpion, Short, 

Mansfield, North Fork Breitenbush, Roaring, South Fork Breitenbush, Devils, Hill, Leone-Cultus and 

Cliffs. Within these watersheds, approximately 31,136 acres of land are managed by the Forest Service. 

One private quarter section of approximately 159 acres is managed by Breitenbush Hot Springs Resort 

and Conference Center. Within the 31,136 acres an estimated 361 acres or 1.15% of the planning area is 

early seral habitat prior to the 2017 wildfires. The estimate is based on existing natural meadows of 20 

acres, powerline of 311 acres and timber harvest less than 20 years of 30 acres. Historically about 9% of 

the watershed was estimated to be in early seral habitat on the average. See the Forest Vegetation Section 

for a more detailed analysis of the existing and historical conditions. With the 2017 forest fires there was 

an increase in early seral habitat. There are two measures of early seral habitat. Crown mortality was 

measured by satellite data for a total of 16 acres in the scorpion fire and 68 acres in the short devils fire. 

Another measure was of which combined ground fire intensity and canopy mortality which was used to 

predict future mortality which found 521 total acres which are predicted to become early seral habitat.

3.6.3 Environmental Consequences – Early Seral Habitat for Wildlife

Direct and Indirect Effects

Alternative 1 – No Action

With implementation of Alternative 1, the amount of early seral habitat in the Hwy 46 project area would 

remain around 2.83% of the area with the powerline corridor expected to remain in early seral condition 

indefinitely. Meadows are expected to be overgrown in approximately 30 years. The timber harvest areas 

are expected to become forested habitat and lose early seral characteristics in approximately 10 years.

Alternative 2

With implementation of Alternative 2, the amount of diverse early seral habitat in the Hwy 46 project area 

would increase to approximately 3.15%. Early seral habitat would be created by gaps, early seral creation 

and meadow restoration treatments. The total acres of early seral created by treatments is 99 acres. Of the 

total analysis area of 31,295 acres, treatments on approximately 99 acres represents 0.31% of the total 

area. The increase in early seral habitat is expected to be maintained for approximately 30 years when the 

treated areas will transition into forested habitat.

Alternative 3

With implementation of Alternative 3, the amount of diverse early seral habitat in the Hwy 46 project area 

would increase to approximately 2.97%. Early seral habitat would be created by gaps and early seral 

creation. The total acres of early seral created by treatments is approximately 44 acres. Of the total 

analysis area of 31,295 acres, treatments on 44 acres represents 0.14% of the total area. The increase in 

early seral habitat is expected to be maintained for approximately 30 years when the treated areas will 

transition into forested habitat.
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Cumulative Effects

Alternatives 1, 2 and 3

There are no additional effects as there are no other projects occurring in the analysis area. 

3.6.4 Affected Environment – Northern Spotted Owl (Federally Threatened 

Species)

The northern spotted owl is a federally threatened species under the Endangered Species Act (ESA) that 

uses forest habitat in the project area. The effects of the various proposed actions for the Hwy 46 project 

would be addressed by the Willamette National Forest (2017) and evaluated by the U. S. Fish and 

Wildlife Service (USFWS) in the 2017 Biological Opinion (B.O.)(USFWS reference 01EOFWOO-2017-

F-0555, signed on August 31, 2017). This B.O. would fulfill the Forest Service’s legal requirement with 

respect to Section 7 of ESA for the Hwy 46 project. A summary of the effects of the alternatives on the 

northern spotted owl is provided in this section. 

Consultation on the northern spotted owl was based on current survey information provided by the Detroit 

Ranger District from surveys completed in 2014-2016 plus historic nest sites. A team of consultation 

advisory biologists reviewed the proposed project and provided guidance on where surveys were needed. 

Surveys were conducted to minimize the potential of adverse effects to activity centers either by 

disruption of nesting or reduction in habitat to below minimum threshold levels. All activities which were 

planned to occur within spotted owl nest patches were dropped from further consideration. A total of 

twenty eight current and historic owl sites were consulted on and occur within 1.2 miles of the proposed 

activities.

Interspecies Competition: The barred owl occurs throughout the Willamette National Forest, including the 

Hwy 46 project area. Competition with barred owls has been found to be an important threat to northern 

spotted owls (USFWS 2011). In western Oregon, both species prefer forests older than 120 years of age. 

The larger and more aggressive barred owls can displace spotted owls where they establish territories 

(Wiens 2012). Wiens (2012) has recommended retaining conifer forests older than 120 years of age as a 

method to reduce interspecific competition between the owl species. Where barred owls occur, he has 

found that spotted owl survival significantly declines as the percent of forests >120 years of age in the 

general home range drops below 35%. 

Guiding documents for northern spotted owl analysis include:

• The Land and Resource Management Plan, Willamette National Forest, as amended, 1990; 

• The Record of Decision, for amendments to Forest Service and Bureau of Land Management 

Planning Documents Within the Range of the Northern Spotted Owl, U.S. Department Of 

Agriculture, Forest Service and U.S. Department of the Interior, Bureau of Land Management, 

April 13, 1994; and

• Revised Recovery Plan for the Northern Spotted Owl, June 28, 2011.

• The Biological Assessment for Willamette Planning Province of Oregon for FY 2018 LAA 

Projects within the Willamette National Forest with a Potential to Modify Habitat and/or Disrupt 

Northern Spotted Owls of LAA Projects with the Potential to Modify the Habitat and/or Disrupt 

Northern Spotted Owls – Willamette Planning Province – FY 2016/17 was used to determine 

effects. A biological assessment was submitted August 1, 2017 and a biological opinion was 

signed August 31, 2017 which includes the HWY46 project. 
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• The Biological Opinion 01EOFWOO-2017-F-0555 fulfilled the Endangered Species Act 

requirements for consultation with the U.S. Fish and Wildlife Service on project effects to 

northern spotted owls.

Spotted Owl Recovery Plan (Revised June 28, 2011)

This project is in compliance with the 2011 Revised Recovery Plan actions 6 and 32. Objectives for Hwy 

46 include 1) Increase stand health and vigor. 2) Increase structural and species diversity across the 

landscape, including plant communities in riparian areas. 3) Reduce fuels to provide for public and 

firefighter safety in the event of a large-scale disturbance.

“Recovery Action 6: In moist forests managed for spotted owl habitat, land managers should implement 

silvicultural techniques in plantations, overstocked stands and modified younger stands to accelerate the 

development of structural complexity and biological diversity that will benefit spotted owl recovery.”

“Recovery Action 32: Because spotted owl recovery requires well distributed, older and more structurally 

complex multi-layered conifer forests on Federal and non-federal lands across its range, land managers 

should work with the Service as described below to maintain and restore such habitat while allowing for 

other threats, such as fire and insects, to be addressed by restoration management actions. These highquality spotted owl habitat stands are characterized as having large diameter trees, high amounts of 

canopy cover, and decadence components such as broken-topped live trees, mistletoe, cavities, large 

snags, and fallen trees.”

Existing Condition

Prior to 2017 forest fires there were 16,024 acres (53%) of suitable spotted owl habitat currently in the 

planning area. Dispersal habitat of 7993 acres (26%) and 6433 acres (21%) that is non-habitat for spotted 

owls. Based on 2017 forest fire satellite analysis the acres of spotted owl habitat has been reduced. After 

forest fire effects there are an estimated 15741 acres (50.6%) of suitable spotted owl habitat 7901 acres 

(25.4%) of dispersal habitat and 6433 acres (21%) that is non-habitat for spotted owls. Total acres of land 

analyzed in the planning area are 31,081 acres which for analysis is reduced by areas that are not capable 

of functioning as habitat in the future such as cliffs, talus, roads, lakes, rivers and private land were 

estimated. The estimated acres deducted included 159 acres of private land owned by Breitenbush Hot 

Springs, 311 acres of powerline corridor, 70 acres of cliffs and talus, 30 acres of river and 60 acres of 

roads. Total acres deducted from non-habitat acres is 630. Total acres capable of growing owl habitat is 

30,451 acres.

Harvest during the 1960-1996 time period occurred on approximately 33% of the landscape and these 

areas are now in mid-seral habitat condition. Matrix land would develop suitable habitat in riparian 

reserves which is expected to remain intact for long periods of time. Non-riparian matrix land is expected 

to cycle through periods of no habitat and dispersal habitat as timber harvest occurs. LSR areas are 

expected to continue increasing in age and stand diversity with no scheduled timber harvest as the 

objective of LSR is to provide mature forests. CHU areas are designated for the recovery of NSO and

guidelines related to this designation would increase suitable owl habitat over time. As LSR and CHU 

have similar objectives they are both expected to increase in number of acres of suitable NSO habitat over 

time and maintain large contiguous areas of habitat.

Twenty one known Spotted Owl activity centers are located in the planning area. These activity centers 

were identified during surveys in 2014, 2015 and 2016. All of the activity centers have proposed project 

activities occurring within their home ranges. Seven activity centers outside the planning area have home 
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ranges (a circle 1.2 miles in diameter around the activity center) that overlap proposed activities. A total 

of twenty eight activity centers within 1.2 miles of proposed activities were analyzed.

Challenges to spotted owl conservation exist range-wide, including potential threats from wildfires, 

barred owl competition, great horned owl predation, West Nile virus and sudden oak death. Range-wide 

disturbances on the landscape from wildfires and wind storms have affected spotted owl habitat rangewide.

Effects of habitat modification on individual northern spotted owl sites are assessed at three spatial scales: 

the home range, core area, and nest patch.

Home Range – A home range in the Oregon Cascades Province is a 1.2 mile radius circle (2,955 acres) 

centered on an activity center (i.e. nest site). It is used by northern spotted owls to obtain cover and food, 

and for reproduction and rearing of young. Home ranges of multiple northern spotted owl pairs may 

overlap with habitat shared between adjacent resident northern spotted owl pairs and dispersing northern 

spotted owls. These areas are important for the survival and productivity as northern spotted owls are 

non-migratory.

Core Area – Within the home range, the core area (500 acres) is a 0.5 mile radius circle centered on the 

activity center, representing the area most heavily used during the nesting season (USDI USFWS et al. 

2008). The core area is defended by territorial northern spotted owls and generally does not overlap the 

core areas of other northern spotted owl pairs.

Nest Patch – Within the core area, the nest patch (70 acres) is defined as a 300 meter radius circle around 

the activity center (USDI USFWS et al. 2008). The two key elements of habitat within a nest patch are: 

(1) canopy closure of dominant, co-dominant, and intermediate conifer and hardwood trees and (2) the 

amount of down wood (USDI USFWS et al. 2008). Modification of habitat within this area is considered 

likely to affect the reproductive success of nesting northern spotted owls and is used in determination of 

incidental take (USDI USFWS et al. 2008). There are no proposed units that overlap nest patches.

The U.S. Fish and Wildlife Service (USFWS) have determined viability thresholds of 50% suitable 

habitat in the core area and 40% suitable habitat in the home range, respectively. Suitable habitat levels 

below these thresholds are thought to compromise the reproductive success of owls (USDI USFWS et al. 

2008). Owls may successfully fledge young when suitable habitat drops below these percentages, but the 

likelihood of this decreases as suitable habitat declines.
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3.6.5 Environmental Consequences – Northern Spotted Owl (Federally 

Threatened Species)

Direct and Indirect Effects 

Alternative 1 – No Action

Alternative 1 would maintain stands on their current successional trajectory and would likely delay 

attainment of multi-story canopy layers and larger diameter trees, snags, and down wood needed for late 

successional habitat compared to stands thinned under the proposed action alternatives. Due to current 

closed canopy conditions reducing sunlight to the ground understory development would be delayed for 

approximately 100 years in untreated stands. The development of suitable owl habitat would occur more 

slowly in Alternative 1 than in the action alternatives.

Alternative 2 

Effects of Habitat Modification: Approximately 2056 acres of dispersal and 833 acres of suitable habitat 

would be thinned and remain habitat after thinning. Thinning would open the canopy allowing sunlight to 

reach the forest floor and allow for the development of an understory. Gaps would be created in 

commercial thinning units with approximately 28 acres of dispersal removed and 20 acres of gaps in 

suitable removed. Where habitat is removed it will take approximately 30 years for dispersal habitat to 

regrow and 80 years for foraging habitat to regrow. Dominant tree release would degrade but not remove 

approximately 10 acres of suitable and 60 acres of dispersal habitat. Sugar pine shelterwood harvest 

would remove approximately 80 acres of suitable and 10 acres of dispersal habitat. Early seral would 

remove approximately 35 acres of suitable and 19 acres of dispersal habitat. Road relocation would 

remove approximately 2 acres of foraging habitat. Hazardous fuel treatment would occur on 

approximately 167 acres of suitable and 28 acres of dispersal habitat which would remain habitat. 

Understory habitat enhancement would occur on approximately 30 acres of suitable (foraging) and 108 

acres of dispersal habitat which would remain habitat. In alternative 2 approximately 131 acres of suitable 

habitat and 96 acres of dispersal habitat would be removed. Where habitat is removed it will take 

approximately 30 years for dispersal habitat to regrow and 80 years for foraging habitat to regrow.

Effects of Habitat Modification on Critical Habitat: Of the proposed treatments approximately 1625 of 

2056 acres of dispersal and 829 of 833 acres of suitable habitat would be thinned and remain habitat after 

thinning in Northern Spotted Owl Critical Habitat (CHU). Gaps would be created in commercial thinning 

units with approximately 28 acres of dispersal removed and 20 acres in suitable removed in CHU. Where 

habitat is removed it will take approximately 30 years for dispersal habitat to regrow and 80 years for 

foraging habitat to regrow. Dominant tree release would degrade but not remove approximately 10 acres 

of suitable and 51 acres of dispersal in CHU. Sugar pine shelterwood harvest would remove 

approximately 75 acres of suitable and 3 acres of dispersal habitat in CHU. Early seral and meadow 

restoration would remove approximately 29 acres of suitable habitat and 17 acres of dispersal habitat. 

Road relocation would remove approximately 2 acres of foraging habitat. Hazardous fuel treatment would 

occur on approximately 167 acres of suitable and 28 acres of dispersal habitat which would remain habitat 

in CHU. Understory habitat enhancement would occur on approximately 30 acres of suitable (foraging) 

and 80 acres of dispersal habitat which would remain habitat. These treatments are designed to improve 

stands by encouraging growth of an understory and increasing structural diversity within the stands.

Effects of Habitat Modification on Late Successional Reserve: Of the proposed treatments 

approximately 656 acres of dispersal and 3 acres of suitable habitat would be thinned and remain habitat 

after thinning in Late Successional Reserve (LSR). Currently these stands are single storied and lack 

complexity. Gaps in commercial thinning units would remove approximately 3 acres of dispersal habitat 
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for approximately.40 years. Dominant tree release would degrade but not remove any suitable habitat and 

approximately 2 acres of dispersal in LSR. Sugar pine shelterwood harvest would not remove suitable or 

dispersal habitat in LSR. Hazardous fuel treatment would occur on approximately 108 acres of suitable 

and 28 acres of dispersal habitat which would remain habitat in LSR. Understory habitat enhancement

would occur on approximately 28 acres of dispersal habitat which would remain dispersal habitat, no 

suitable habitat would be affected. LSR quality is expected to be improved by adding structure, increasing 

overall stand diameter and encouraging growth of an understory.

A few remnant older trees may be present in some planned thinning units and these trees are protected 

from cutting unless identified as hazard trees, which may be felled for operational purposes, and left in 

place. All legacy trees from the previous stand (>) 30 inches dbh) should not be cut in thinning units. In 

LSR the maximum diameter limit is 20 inches dbh.

Alternative 3

Effects of Habitat Modification: Approximately 1957 acres of dispersal and 247 acres of suitable habitat 

would be thinned and remain habitat after thinning. Thinning would open the canopy allowing sunlight to 

reach the forest floor and allow for the development of an understory. Gaps would be created in 

commercial thinning units with approximately 28 acres of dispersal removed and 3 acres of suitable 

removed. Where habitat is removed it will take approximately 30 years for dispersal habitat to regrow and 

80 years for foraging habitat to regrow. Dominant tree release would degrade but not remove 

approximately 1 acre of suitable and approximately 60 acres of dispersal habitat. Sugar pine shelterwood 

harvest would remove no acres of suitable and approximately 5 acres of dispersal habitat. Early seral 

would remove no acres of suitable habitat and approximately 19 acres of dispersal habitat. Road 

relocation would remove approximately 2 acres of foraging habitat. Hazardous fuel treatment would 

occur on approximately 167 acres of suitable and 28 acres of dispersal habitat which would remain 

habitat. Understory habitat enhancement would occur on approximately 30 acres of suitable (foraging) 

and 108 acres of dispersal habitat which would remain habitat. In alternative 3 approximately 5 acres of 

suitable habitat and 33 acres of dispersal habitat would be removed. Where habitat is removed it will take 

approximately 30 years for dispersal habitat to regrow and 80 years for foraging habitat to regrow.

Effects of Habitat Modification on Critical Habitat: Of the proposed treatments approximately 1594 of 

1957 acres of dispersal and 112 of 247 acres of suitable habitat would be thinned and remain habitat after 

thinning in CHU. Gaps would be created in commercial thinning units with approximately 28 acres of 

dispersal removed and 3 acres of suitable removed in CHU. Where habitat is removed it will take 

approximately 30 years for dispersal habitat to regrow and 80 years for foraging habitat to regrow. 

Dominant tree release would remove but not degrade no acres of suitable and approximately 45 acres of 

dispersal in CHU. Sugar pine shelterwood harvest would remove no acres of suitable and approximately 2 

acres of dispersal habitat in CHU. Early seral would remove no acres of suitable habitat and 

approximately 19 acres of dispersal habitat. Road relocation would remove approximately 2 acres of 

foraging habitat in CHU. Hazardous fuel treatment would occur on approximately 167 acres of suitable 

and 28 acres of dispersal habitat which would remain habitat in CHU. Understory habitat enhancement

would occur on approximately 30 acres of suitable (foraging) and 80 acres of dispersal habitat which 

would remain habitat. These treatments are designed to improve stands by encouraging growth of an 

understory and increasing structural diversity within the stands.

Effects of Habitat Modification on Late Successional Reserve: Of the proposed treatments 

approximately 656 of 1957 acres of dispersal and 3 of 247 acres of suitable habitat would be thinned and 

remain habitat after thinning in Late Successional Reserve (LSR). Gaps would be created in commercial 

thinning units with approximately 3 acres of dispersal removed, there are no gaps in suitable habitat in 

LSR. Where habitat is removed it will take approximately 30 years for dispersal habitat to regrow and 80 
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years for foraging habitat to regrow. Dominant tree release would not remove any acres of suitable, but 

would degrade approximately 32 acres of dispersal in LSR. Sugar pine shelterwood harvest would not 

remove suitable or dispersal habitat in LSR. Hazardous fuel treatment would occur on approximately 108 

acres of suitable and 28 acres of dispersal habitat which would remain habitat in LSR. Understory habitat 

enhancement would not occur on suitable (foraging) but would occur on approximately 28 acres of 

dispersal habitat which would remain dispersal habitat. LSR quality is expected to be improved by adding 

structure, increasing overall stand diameter and encouraging growth of an understory.

A few remnant older trees may be present in some planned thinning units and these trees are protected 

from cutting unless identified as hazard trees, which may be felled for operational purposes, and left in 

place. Most thinning units have no remnant trees or snags.

Variable density thinning adds diversity to the stands which also benefits owls by providing more diverse 

habitats for prey species.

For more detailed analysis at a province level refer to the biological assessment and biological opinion

referenced in this document. 

Spotted Owl Recovery Plan (Revised June 28, 2011)

Alternatives 2 and 3 are in compliance with the 2011 revised recovery plan actions 6 and 32. Treatments 

in RA32 are limited to hazardous fuel reduction adjacent to the Breitenbush community. Harm is not 

expected to occur to any nesting spotted owls as activity centers have been located by surveys and 

seasonal prohibitions on activities would be implemented. Owl home ranges would not have acres 

reduced by proposed treatments to below minimum viability levels. 

Effects of Disturbance from Project Activities

This project complies with protection measures which would avoid any actions which would result in a 

May Affect and Likely to Adversely Affect from disturbance determination. All MA-LAA disturbance 

activities are prohibited in the Hwy 46 project. Only MA-NLAA or NE disturbance activities are planned 

to occur in the project. This project proposes activities which are within the disruption distance of known 

spotted owl activity centers. Activities within the disruption distance of activity centers are prohibited 

from occurring during the critical nesting period to protect nesting owls. This project does propose 

activities which are within the disturbance distance of eighteen spotted owl activity centers. The 

determination made in the Biological Assessment for the Hwy 46 project is may affect and is not likely to 

adversely affect spotted owls by disturbance.

The proposed action includes all processes needed to plan, evaluate, survey, prepare and complete 

activities including, but not limited to, falling, bucking, helicopter yarding, hauling, road reconstruction; 

and the interdependent actions of rock source operations, post-harvest burning, fuel reduction treatments 

and post-harvest project generated firewood sales. Rock pit operations may require blasting, rock 

crushing, and operation of heavy equipment.

There are no other projects occurring in the planning area which occur within the disruption distance of 

known spotted owl activity centers.

Cumulative Effects 

Alternative 1 – No Action

Alternative 1 would have no direct effects on spotted owl habitat, so there are no cumulative effects to be 

considered.
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Alternatives 2 and 3

No projects on federal land are anticipated which would remove more suitable habitat or reduce the 

amount of dispersal habitat in the planning area.

The habitat and pre-field review section and existing conditions section for NSO considers all impacts to 

habitat to date. 2017 forest fire effects were integrated into the existing condition discussion. Effects from 

fire suppression activities were insignificant. 

Ongoing road maintenance is expected to continue to fall hazard trees adjacent to roads which would 

continue to reduce the quality of suitable spotted owl habitat in the planning area. Personal use firewood 

cutting is expected to continue near roadways and is expected to maintain reduced amounts of downed 

wood and thus lower the quality of suitable habitat adjacent to road corridors.

Dispersal habitat is well connected with suitable habitat in the planning area. Foreseeable actions in 

conjunction with the effects of implementing Alternative 2 and 3 are not expected to compromise the 

functionality on any NSO home ranges or create barriers to dispersal across the project area. Analysis of 

effects to NSO home ranges as a result of the 2017 forest fires confirmed that the functionality of home 

ranges was not compromised by the effects of the fires.

Determination

Habitat

The Biological Assessment for Willamette Planning Province of Oregon for FY 2018 LAA Projects 

within the Willamette National Forest with a Potential to Modify Habitat and/or Disrupt Northern Spotted 

Owls was used to determine effects. A biological assessment was submitted to the USFWS on August 1, 

2018 and biological opinion 01EOFW00-2017-F-0555 was signed by the USFWS on August 31, 2017.

Disturbance

There are no project activities within the disruption distances of known spotted owl activity centers which 

are proposed to occur during the critical nesting period. Activities would occur during the disturbance 

period and within a distance which could cause disturbance effect to eighteen known spotted owl activity 

centers. 

3.6.6 Affected Environment – Proposed Threatened and Forest Service 

Sensitive Wildlife

Sensitive species are designated by the Regional Forester as species which have population viability 

concerns evidenced by: 1) Significant current or predicted downward trends in population numbers or 

density or 2) Significant current or predicted downward trends in habitat capability that will reduce a 

species existing distribution. All actions are taken to ensure that management activities do not jeopardize 

the continued existence of sensitive species or result in an adverse modification of their essential habitat 

(FSM 2670.3, Region-6 ID 2670-92-1, 1/91). Effects of the alternatives on Forest Service sensitive 

species are considered in a project Wildlife Biological Evaluation (BE). This environmental impact 

statement tiers to the analysis in the BE. One threatened, and thirteen sensitive species have habitat or 

potential suitable habitat in the project area and were analyzed in detail in the project BE. One of these 

species, the Crater Lake tightcoil snail, is on both the “Sensitive” species list and the “Survey and 

Manage” species list.
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Regulatory Framework

Update of the Regional Forester Special Status Species List, July 21, 2015, provides the list of sensitive 

species addressed in this analysis.

Analysis Methods 

A Biological Evaluation was prepared for this project as part of the wildlife specialist report, and is 

available in the project file located at the Detroit Ranger District office. This EIS tiers to that analysis and 

the findings are summarized in the Environmental Consequences of this section. 

Existing Condition

Habitat is present in the planning area which could be occupied by the following sensitive species: 

American peregrine falcon, northern bald eagle, North American wolverine, harlequin duck, fringed 

Myotis, fisher, Townsend’s big-eared bat, Johnson’s hairstreak, Crater Lake tightcoil snail and western 

bumble bee. Detailed information on these sensitive species can be found in the Hwy 46 biological 

evaluation for wildlife.

Bald eagles are protected by the Bald and Golden Eagle Protection Act which prohibits disruptions to the 

bald eagle to the point of harm. Bald eagle populations have been increasing on the Detroit Ranger 

District and as new territories are established shifts in bald eagle use patterns may occur. Periodic 

monitoring of nesting sites provides information, such as alternative nest locations, needed to protect 

these areas.

Species Analyzed in Biological Evaluation

American Peregrine Falcon

Preferred nesting sites for peregrines are sheer cliffs 75 feet or more in height having horizontal ledges or 

small caves. Foraging is associated with a variety of open and forested habitats, however it is most closely 

associated with riparian settings. One known and two potential nest sites occur in the analysis area. 

Numerous potential nest sites and occupied territories occur on the Willamette National Forest. 

Northern Bald Eagle

Bald eagles use scattered old-growth conifer trees in proximity to open water near rivers, lakes, and 

reservoirs with plentiful prey. Feed primarily on fish, but will also eat waterfowl and carrion. On the 

Detroit Ranger District they currently nest at Detroit Reservoir and Marion Lake. Foraging habitat is 

available primarily on the Breitenbush River in the analysis area. 

Harlequin Duck

During nesting (April-June) adults require fast-flowing water with midstream loafing sites nearby, dense 

shrub or timber/shrub mosaic vegetation on the bank, and an absence of human disturbance. Nest on 

ground under the shelter of vegetation, rocks, or large woody debris in close proximity to water. Broods 

prefer low gradient streams with adequate macro-invertebrate abundance. Breeding and foraging known 

to occur along the Little North Fork of the Santiam River, Humbug Creek, North Fork of the Santiam 

River, Breitenbush River, Marion Creek, Devils Creek and Blowout Creek on the Detroit Ranger District. 

The Breitenbush River, Devils Creek and Humbug Creek occur in the planning area.

North American Wolverine (Proposed Threatened)

Found primarily in wilderness or remote country where human activity is limited. High elevation areas 

appear to be preferred in summer, which may effectively separate wolverines and intensive human 
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disturbance in most areas. In winter wolverines may move to lower elevations that are snowbound and/or 

have very limited human activity. They are capable of foraging widely (30-40 km) on a daily basis, and 

do not significantly use young, dense stands of timber or clear-cuts. The majority of activity occurs in 

large expanses of scattered mature timber, with some use of ecotonal areas such as small timber pockets, 

and rocky, broken areas of timbered benches. Heavy use of openings in areas with good winter 

populations of big game is a principal source of carrion which makes up much of the wolverine's diet. 

They also feed on marmots, snowshoe hares, various rodents, insects, insect larvae, eggs, and berries. 

Historical sightings on the Detroit Ranger District have occurred over a wide range of habitat types and 

locations. Sightings have not been reported in approximately 15 years with the last report south of the 

project area near Marion Forks. The wolverine is proposed threatened by the USFWS. A study was 

conducted during 2 field seasons (approximately Oct-May 2012-2014 in the Willamette and Deschutes 

National Forests in the Mt. Jefferson and Mt. Washington Wilderness areas with no wolverines detected.

Sierra Nevada Red Fox

Sierra Nevada red fox is known to occur on Detroit Ranger District near Santiam Pass. This species 

occurs at high elevations near the crest of the Cascade Mountains. In California they live in open conifer 

woodlands and mountain meadows near tree line. This species is not expected to occur in the project area 

as habitat for this species is not present.

Fisher

Considered a riparian associate but found in a wide variety of densely forested habitats at low to midelevations. Data suggests they do better in areas with minimized fragmentation of old growth, secondgrowth, and riparian area and in areas with abundant down and standing woody material important. No 

sightings of fishers have been recorded on the Detroit Ranger District. A survey was conducted by the 

USFWS during the winter of 2015-2016 to determine presence of fishers in the Northern Cascades of 

Oregon. Camera data was collected from survey sites during the summer of 2016 with analysis ongoing. 

This survey is part of a potential reintroduction of fisher proposal from the USFWS.

Fringed Myotis Bat

Occurs in Oregon, however, habitat use is poorly documented. Three captured in 1971 were associated 

with young coniferous forest. They are known to use caves, mines, rock crevices, and buildings as both 

day and night roosts. Little is known about habits in winter. Diet of moths, leafhoppers, lacewings, daddylonglegs, crickets, flies, true bugs, and spiders. Occurrence has been documented on Detroit Ranger 

District. (Pat Ormsbee, Willamette N.F.)

Townsend’s Big-Eared Bat

Found throughout Oregon where suitable roosting habitat occurs. Forage preference is mostly moth 

species. Literature reviews indicate it is highly susceptible to disturbance by humans. Roosts range from 

caves, cliff-faces, large trees, mines to houses. Townsend’s big-eared bats have been documented on the 

Detroit Ranger District.

Johnson’s Hairstreak Butterfly

Habitat is conifer forests with dwarf mistletoe. It is thought to fly high in the canopy where dwarf 

mistletoe grows so is rarely seen from the ground. As mistletoe grows mostly on larger trees mature forest 

are generally associated with this species. The species ranges from central California to British Columbia.

Three sightings have been reported on the Detroit R.D., however, none were in the planning area. Where 

mature forests are present in the planning area Johnson’s hairstreak butterflies are likely to occur.
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Western Bumble Bee

A generalist pollinator species with a wide range in Western North America. Populations and range are 

decreasing. Populations of the western bumble bee in central California, Oregon Washington and southern 

British Columbia have mostly disappeared. (USFS fact sheet, 

http://www.fs.fed.us/r6/sfpnw/issssp/species-index/fauna-invertebrates.shtml). Surveys on the Detroit 

Ranger district were conducted in 2015 and 2016 in the project area. No western bumble bees were 

located in the project area.

Crater Lake Tightcoil Snail

This species is associated with areas within 10 meters of perennial wetlands and riparian areas (Duncan et 

al. 2003).

3.6.7 Environmental Consequences - Proposed Threatened and Forest 

Service Sensitive Wildlife

Direct and Indirect Effects

Alternative 1 – No Action 

There would be no direct effects to any sensitive species in the no action alternative. Without meadow 

restoration projects habitat for western bumble bees would continue to slowly diminish.

Direct and Indirect Effects

Alternatives 2 and 3

The effects of Alternative 2 on sensitive species are summarized from the project biological evaluation.

American peregrine falcon nesting habitat (cliffs) would not be impacted by proposed activities. 

Treatments proposed in the primary nest zone of high potential site, Cliffs Creek, would thin habitat in 

units 70 and 71. Foraging habitat in units 70 and 71 would become more open with better access to prey 

species. All proposed treatments with potential to disturb nesting falcons at the known site would be 

restricted January 15 to July 31. Two high potential sites may be impacted by project activities if 

peregrine pairs occupy a site. Sale contracts contain C-clauses to protect raptors if new pairs are located 

during project implementation.

Harlequin duck habitat is expected to be disturbed and remain functional where project activities are 

occurring within 200 feet of the Breitenbush River and Devils Creek. All project activities with potential 

to impact nesting harlequin ducks are restricted from March 15 to July 15 to avoid disturbance.

The bald eagle is not expected to be impacted by the proposed alternatives. No bald eagles were located 

during surveys of the planning area.

Wolverine and fisher are both unlikely to occur in the project area and are not expected to be affected by 

proposed activities.

Fringed Myotis and Townsend’s big-eared bat may be impacted if trees which have potential to be used 

for nursery colonies are felled as hazards during harvest operations. Potential habitat for nursery colonies 

may exist but have not been located within the project boundaries. Old-growth trees would be retained in 

harvest units, unless they are determined to be safety hazards. Stands with legacy trees and old-growth 

stands occur throughout the planning area and adjacent to proposed harvest units. These stands are 
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expected to continue providing roosting and nursery habitat so viability of these bat species is expected to 

be maintained.

Johnson’s hairstreak butterfly has been documented on the Detroit Ranger District but has not been 

documented in the project area. This species is associated with coniferous forests that have dwarf 

mistletoe. Potential impacts may occur if old-growth tree habitat, which has potential to also contain 

dwarf mistletoe, is felled as hazard trees during harvest operations. Any loss of individual old-growth 

trees in harvest units would have an inconsequential impact on overall habitat availability as suitable 

individual trees and patches of old growth trees are located in adjacent stands. Alternative 2 would have a 

minimal impact on Johnson’s hairstreak viability in the planning area.

Western bumble bee historically present in the planning area and not located during surveys. Meadow 

restoration activities are expected to improve potential habitat which may be used in the future if this 

species recolonizes the planning area.

Crater Lake tightcoil snail is associated with perennially wet areas. Their habitats are unlikely to occur in 

proposed treatments units and no impacts to individuals are expected from proposed activities.

Determination

The proposed project may adversely impact individuals of proposed, threatened and forest service 

sensitive species, but is not likely to result in a loss of viability in the planning area or cause a trend to 

federally listing or a loss of species viability range wide.

Cumulative Effects

All Alternatives 

For sensitive species, the cumulative effects analysis area is the project area. On-going hazard tree 

removal along roads is expected to impact bats and their habitat. No cumulative impacts, in addition to 

the proposed alternatives, are expected to occur for peregrine falcon, bald eagle, harlequin duck, 

wolverine, fisher, Johnson’s hairstreak butterfly or western bumble bee. When considered together with 

other activities in the analysis area this project does add to other past, present and reasonably foreseeable 

activities to produce some cumulative effects to one sensitive species, but only to a small degree and 

cumulatively, it is not likely to result in a loss of viability in the planning area nor cause a trend to 

federally listing or a loss of viability range wide for these species.

3.6.8 Affected Environment – Survey and Manage Species

Survey and manage requirements originated in the “Northwest Forest Plan” also known as “The Record 

of Decision for Amendments to Forest Service and Bureau of Land Management Planning Documents 

Within the Range of the Northern Spotted Owl, Standards and Guidelines for Management of Habitat for 

Late-Successional and Old-Growth Forest Related Species Within the Range of the Northern Spotted 

Owl”, April 1994, p. C-4-6. The “survey and manage” standard and guideline will provide benefits to 

certain species of amphibians, mammals, bryophytes, mollusk, vascular plants, fungi, lichens, and 

arthropods. 

A record of decision and standards and guidelines for amendments to the survey and mange, protection 

buffer, and other mitigation measures standards and guidelines came out in January of 2001. Various 

supplements and modifications were made to these documents and a lawsuit resulted in a settlement 

agreement in 2011.
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Regulatory Framework

The 2011 Settlement Agreement in Litigation over the Survey and Manage Mitigation Measure in 

Conservation Northwest et al. v. Sherman et al., Case No 08-1067-JCC (W.D. Wash.) reset direction. The 

Court set aside the 2007 RODs, putting into effect the Record of Decision and Standards and Guidelines 

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

and Guidelines (USFS it al. 2001) (2001 ROD). Projects within the range of the northern spotted owl are 

subject to the Survey and Manage Standards and Guidelines in the 2001 ROD as modified by the 2011

Settlement Agreement.

This project is consistent with the January 2001 Record of Decision and Standards and Guidelines for 

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

Guidelines.

This project utilizes the December 2003 species list. This list incorporates species changes and removals 

made as a result of the 2001, 2002, and 2003 Annual Species Reviews with the exception of the red tree 

vole, Arborimus longicaudus. For the red tree vole, the Ninth Circuit Court of Appeals in KSWC et al. V. 

Boody et al., 468 F3d 549 (9th Cir. 2006) vacated the category change and removal of the red tree vole in 

a portion of its range, and returned the red tree vole to its status as existed in the January 2001 Record of 

Decision and Standards and Guidelines, which makes the species Category C throughout its range.

In addition, there are 12 species receiving special considerations as directed in the May 13, 2014 Regional 

Forester letter. We reviewed these species and conducted pre-disturbance surveys and manage known 

sites for Megomphix hemphilli. The other 11 species either do not have habitat in the project area or are 

covered in the botanical resources section of this EIS.

Exemption from Survey and Manage Pre-Disturbance Surveys

The Settlement Agreement acknowledges and maintains in force the stipulation in previous litigation 

which exempts four categories of projects. These exemptions removed pre-disturbance surveys and 

known site management from: 

1. Thinning in forest stands younger than 80 years of age; 

2. Culvert replacement/removal;

3. Riparian and stream improvement projects;

4. Hazardous fuel treatments applying prescribed fire for noncommercial projects. 

Proposed projects in the Hwy 46 project are partially within the parameters of the exemptions from predisturbance surveys. Hazardous fuel treatments are removing understory trees less than 7 inches dbh and 

machine piling, hand piling or chipping/mulching and underburning. Road closures are not impacting 

habitat and culvert removals are exempt from surveys.

Survey and Manage Pre-Disturbance Surveys

Activities which are not exempt from surveys include thinning harvest units over 80 years old which were 

surveyed to protocol for survey and manage species. Big game habitat enhancements in the form of large 

gaps are occurring in proposed thinning units within some stands over 80 years old. Some sugar pine

restoration, dominant tree release, early seral habitat creation and meadow restoration is occurring in 

stands over 80 years of age and were surveyed to protocol standards. No survey and manage species were 

located during surveys of suitable habitat.
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The Survey and Manage tracking form is located in the wildlife report in the project file at the Detroit 

Ranger District. Details of the project surveys and/or site management are described below. 

Oregon Megomphix

This snail occurs at low to moderate elevations, below the zone of seasonally persistent snow pack. 

Megomphix snails are most often found within the mat of decaying vegetation under sword ferns and bigleaf maple trees and near rotten logs. Most occupied sites are on well-shaded slopes and terraces, and 

many are near streams (Management Recommendations for Terrestrial Mollusk Species: Megomphix 

hemphilli, the Oregon Megomphix, Version 2.0, Applegarth 2000). Oregon Megomphix is in S&M 

Category “A” North of the south boundary of Linn County, this project is in Marion County, so surveys 

are required. There are no records of the Oregon Megomphix in the project area. Surveys to protocol

standards were conducted where activities are proposed which can disturb habitat below 3000’ elevation 

in stands over 80 years of age. No Oregon Megomphix were located during surveys. 

Red Tree Vole

The standards and guidelines to conduct red tree vole surveys and protect nest sites were developed, along 

with other habitat protection measures from the Northwest Forest Plan to provide a reasonable assurance 

of persistence of certain species, such as red tree vole, which were believed to be rare and uncommon 

across the range of the Northwest Forest Plan at the time it was developed. For vertebrate species, like 

voles, this persistence objective is consistent with the goals of providing for viable and well-distributed 

populations under the National Forest Management Act Regulations (Forest Service and BLM 2001:3-4; 

Forest Service and BLM 1994:43-47).

Pre-disturbance surveys for the red tree vole were conducted in 2014-2016 in all proposed Alternative 2 

stands over 80 years of age as required by the Red Tree Vole Survey Protocol Version 3.0 (Forest Service 

and BLM 2012). Trees were climbed where potential nests were located in units 7, 13 and 40. No red tree 

vole nests were found. A sample of an old red tree vole nest was dropped off by a member of the public at 

the Detroit Ranger District with UTM coordinates provided which place the sample collection point in 

proposed unit 94. Unit 94 is in CHU where all trees greater than 30 inches dbh are retained. The diameter 

of the sample tree is 48 inches and is a Douglas-fir. The person climbed several large trees around this 

tree but did not find additional nests. As the nest site was inactive it does not require site management or 

protection.

Great Gray Owl

Individual great gray owls can be found in a wide variety of habitat types. However, forests appear to be 

necessary for reproduction in North America (Habeck 1994, Duncan and Hayward 1994). Examples of 

forest types known to be suitable for great gray owls include: ponderosa pine (Pinus ponderosa), 

lodgepole pine (Pinus contorta), tamarack (Larix occidentalis), Douglas-fir (Pseudotsuga menziesii),

grand fir (Abies grandis), mixed conifer- hardwood, aspen (Populus tremuloidus), and other deciduous 

tree types. Platt and Goggins (1991) found great gray owl nests on the Willamette National Forest in 

mature and remnant old-growth Douglas-fir and mixed-conifer habitat. Most nests are located near natural 

meadows or manmade openings. Bryan and Forsman (1987) found nests in south central Oregon to be 

less than 980 feet (300m) from the nearest meadow opening. Platt and Goggins (1991) found nests within 

660 feet (200m) of a timber-harvest-created opening.

The required habitat characteristics of suitable great gray owl habitat include: (1) large diameter nest 

trees, (2) forest for roosting cover, and (3) proximity [within 600 feet] to openings that could be used as 

foraging areas (Survey Protocol for the Great Gray Owl within the range of the Northwest Forest Plan

v3.0, January 12, 2004). In some locations on the Willamette National Forest, shelterwood harvesting has 
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been found to be beneficial because it opens up closed forest canopy cover for foraging (Forest Service 

and Bureau of Land Management 2001). NRIS, the Forest Service web-based wildlife sighting database, 

currently shows no records of great gray owls in the project area. Two sightings were located in the 

database on the Detroit Ranger District and are south of the project area approximately 10 miles. 

Pre-disturbance survey(s) for Great Gray Owls are not required for the Hwy 46 project because the 

activities in Alternatives 2 and 3 do not have proximity to natural openings > 10 acres, and predisturbance surveys are not required in suitable nesting habitat adjacent to man-made openings at this 

time (pg. 14, Survey Protocol for the Great Gray Owl within the range of the Northwest Forest Plan v3.0, 

January 12, 2004).

Crater Lake Tightcoil Snail

Species may be found sparsely distributed throughout Oregon Cascades above 2000’ elevation associated 

with perennially wet environment in mature conifer forests and meadows among vegetation or under 

rocks and woody debris. Suitable locations within 10 meters of open water generally in areas under snow 

for extended periods during winter. One documented site occurs on the Willamette N.F. on Middle Fork 

R.D. A few occurrences have been documented on the Mt Hood, Deschutes, Umpqua, Winema, and 

Rogue River National Forests. No individuals have been documented on the Detroit R.D.

Pre-disturbance surveys were required for the Hwy 46 project as suitable habitat for Crater Lake tightcoil 

would be impacted by proposed project activities. No Crater Lake tightcoil snails were located during 

surveys of the project area.

3.6.9 Environmental Consequences – Survey and Manage Species

All Survey and Manage Species

Direct and Indirect and Cumulative Effects - All Alternatives

No Survey and Manage species were detected during surveys. Direct and indirect effects to potential red 

tree vole habitat would occur in action alternatives. Cumulative effects to red tree voles are expected to 

occur where road maintenance activities remove hazard trees which have potential to be suitable habitat.

3.6.10 Affected Environment – Raptors and Colonial Nesting Birds

Regulatory Framework

The Forest Plan directs projects on the forest to manage for raptors and colonial nesting birds. Active 

roost and nest sites (including rookeries) shall be protected. Timber harvest may be foregone in a primary 

zone extending up to 500 feet from the nest or roost site. Where activities of significant disturbance and 

duration are near active roost sites it may be necessary to establish a secondary Restricted Activity Zone 

outside the primary zone. This secondary zone could range up to 1,000 feet or more from the nest or roost 

site, depending on the individual situation. Timing or duration of operations may be restricted within the 

secondary zone.

Analysis Methods 

Raptor and colonial bird nest sites have been recorded in the analysis area as a result of past sightings. 

Field visits to the project area in 2014, 2015 and 2016 did locate active osprey nests. Surveys were not 

conducted within sale units for raptors.
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Existing Condition 

Bald eagle potential nesting habitat is present in the project area. No bald eagles were observed in the 

project area. Osprey nests have been documented in the analysis area within 1000 feet of proposed 

activities or in locations which would cause disturbance to nesting. Large trees which could be used by 

nesting raptors or colonial nesting birds such as Vaux’s swifts are present in the project area and it is 

likely some of these trees are used for nesting and roosting.

3.6.11 Environmental Consequences – Raptors and Colonial Nesting Birds

Direct and Indirect Effects

Alternative 1 – No Action 

Active roost and nest sites for raptors and colonial nesting birds would not be disturbed. Stands would 

continue in their current growth trajectory and trees would generally be smaller and provide less desirable 

nest sites compared to Alternatives 2 and 3. 

Direct and Indirect Effects

Alternative 2 and 3

The effect of the two action alternatives on raptors and colonial nesting birds are similar. Active roost and 

nest sites for ospreys have been identified in the project area within 1000 feet of proposed activities. 

Seasonal restriction on project activities would protect these nest sites from disturbance. One osprey nest 

was located adjacent to unit 13, a seasonal restriction on all activities from March 1 – July 31 would 

protect nesting birds. Nest trees are expected to remain after harvest as potential nest trees are located 

outside proposed harvest units. Potential nest trees with old growth characteristics within proposed units, 

if present, would be retained and available for future nesting use as they are protected from harvest. All 

other proposed activities are not expected to impact raptors and colonially nesting birds. If new nests are 

located in the future a seasonal restriction on activities which have the potential to disturb nesting birds is 

recommended and the nest tree is to be protected. The both alternatives as proposed comply with 

Willamette Forest Plan Standards and Guidelines.

Raptor detections are included in contract language for timber sales with recommended procedures when 

detected. Individual trees are protected under this contract clause and harvest activities are seasonally 

restricted during the nesting season. The timber sale administrator looks for potential raptor nests during

normal inspection activities. Raptors are not surveyed for as nest locations move yearly. During unit 

layout the cruisers and unit boundary layout crew also look for and report raptor nests when found.

Cumulative Effects

All Alternatives 

There are no additional projects occurring in the project area which would cause cumulative impacts to 

raptors and colonial nesting birds.

3.6.12 Affected Environmental – Management Indicator Species

The implementing regulations for the National Forest Management Act of 1976 (NFMA) require the 

Forest Service to plan the management of wildlife habitats to “maintain viable populations of existing 

native and desired non-native vertebrate species in the planning area.” Implementing regulations for 

NFMA further define viable population management. “In order to insure that viable populations will be 
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maintained, habitat must be provided to support at least a minimum number of reproductive individuals 

and that habitat must be well distributed so that individuals can interact with others in the planning area” 

(36CFR 219.19). To facilitate management of all these species, NFMA further requires each Forest to 

identify management indicator species (MIS) through the planning process and to establish objectives to 

maintain and improve the habitats of these indicator species. Management indicator species represent 

either featured species or ecological indicators. Featured species are threatened and endangered plant and 

animal species on federal lists, species that are hunted, fished, or trapped, species of special concern or 

interest, and species with special habitat needs that may be at risk due to planned management activities. 

Ecological indicator species were selected because their population and habitat changes indicate potential 

effects of management activities on other species dependent on selected habitat types or water quality.

The use of Management Indicator Species (MIS) in project planning was established by the 1982 National 

Forest Management Act planning regulations. Management Indicator Species are species whose response 

to land management activities can be used to predict the likely response of a wide range of species with 

similar habitat requirements. Through Region-wide coordination, each Forest identified the minimum 

habitat distribution and habitat characteristics needed to satisfy the life history needs of management 

indicator species. Management recommendations to ensure their viability were incorporated into the 

Willamette Forest Plan (USDA Forest Service, 1990). Management indicator species include spotted owl, 

bald eagle, deer, elk, peregrine falcon, cavity excavators, pileated woodpecker and marten (Table 35).

The Willamette Forest Plan (1990) provides dedicated areas of mature and old-growth tree habitat to 

ensure maintenance of viable populations of selected management indicator species that are surrogates for 

a diversity of species dependent on old-growth habitat. Old growth and mature conifer habitat provides 

feeding, resting, and breeding areas that are required by northern spotted owl, pileated woodpecker, and 

marten. These management indicator species represent wildlife associated with late seral stages of forest 

development. As ecological indicators, these wildlife species represent all species which may be affected 

by limited amounts, distribution, and quality of mature and old-growth coniferous forests. The Northwest 

Forest Plan (1994) amended the Willamette Forest Plan. Administratively withdrawn areas that were 

specified in Forest Plan to benefit martens, pileated woodpeckers, and other late successional species 

were returned to matrix unless local knowledge indicated other allocations and these standards and 

guidelines will not meet management objectives for those species. On the Detroit Ranger District some 

pileated woodpecker and marten habitat areas were retained. 

Viability of northern spotted owls is maintained by compliance with the 2011 Revised Spotted Owl 

Recovery Plan. Viability of peregrine falcons is maintained by compliance with Willamette Forest Plan

for protection of raptors and colonial nesting birds. Viability of bald eagles is maintained by compliance 

with the Bald and Golden Eagle Protection Act as modified at the time they were removed from the 

threatened and endangered species list and by Willamette Forest Plan protection of raptors and colonially 

nesting birds. Viability of big game is maintained by management of big game by Oregon Department of 

Fish and Wildlife under the Black-tailed Deer Management Plan (Nov. 14, 2008) and the Oregon’s Elk

Management Plan (February 2003). Oregon Department of Fish and Wildlife monitors populations yearly 

to determine management and harvest levels to maintain viable populations of big game. Cavity excavator 

populations and pileated woodpeckers are monitored in a variety of ways, as described in Appendix 2 of 

the DecAID analysis, and viability based on population trends is stable or increasing statewide. Marten 

are managed for viability by ODFW as furbearers, regulated by Oregon Furbearer Trapping and Hunting 

Regulations and analyzed yearly with the most recent Oregon Furbearer Program Report published in 

August 2011.
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The effects of the alternatives on northern spotted owl are addressed in a specific section for that species. 

The impacts of the alternatives on peregrine falcons and bald eagles are addressed in the section on Forest 

Service Sensitive Species.

Table 34 Wildlife Management Indicator Species for the Willamette National Forest

Indicator Species Indicator Habitat Reason Selected in 1990

cavity excavators1 dead and decaying trees ecological indicator, limited habitat

elk winter range commonly hunted

deer winter range commonly hunted

pileated woodpecker old growth and mature conifers ecological indicator, limited habitat

marten old growth and mature conifers ecological indicator, limited habitat

northern spotted owl2 old growth and mature conifers ecological indicator, limited habitat, 

proposed threatened species2

bald eagle3 old growth conifers near large 

bodies of water

federally threatened species3

peregrine falcon3 cliff nesting habitat near abundant 

prey

federally endangered species3

1

Forest Service (1990) identified the following species in this group: red-breasted nuthatch, northern flicker, hairy woodpecker, 

downy woodpecker, red-breasted sapsucker, Lewis woodpecker, black-backed woodpecker, and northern three-toed woodpecker.

2

Became a federally threatened species in June 26, 1990, as the Willamette NF Plan was being finalized.

3

Bald eagles and peregrine falcons were subsequently delisted and are now Forest Service Sensitive Species.
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Cavity Excavators, Pileated Woodpecker, and Deadwood Abundance

Cavity excavator MIS are used as an ecological indicator for the abundance of dead and decaying trees. 

Pileated woodpeckers are MIS that use snags, but also prefer old and mature forests and occur in the 

project area. Cavity excavator MIS species that occur or have potential habitat in the proposed Hwy 46

units are red-breasted nuthatch, northern flicker, hairy woodpecker, downy woodpecker, red-breasted 

sapsucker, Lewis woodpecker, black-backed woodpecker, and northern-three toed woodpecker.

Lewis woodpecker is a Forest Service sensitive species that does not breed on the Detroit Ranger District 

but regularly occurs along Cascade Mountain ridges in the fall (Marshall et al. 2003, NRIS_Wildlife 

database). This fall dispersal habitat in not thought to be limiting and the species is not expected to be 

present in the project BE. The Oregon Cascades-California and the Black Hills populations of blackbacked woodpeckers have been petitioned for listing under the Endangered Species Act (USFWS 2013). 

The black-backed woodpecker responds to large fires on the Willamette National Forest, especially fires 

near the Cascade Crest in montane mixed conifer forests. The project area has had no recent large fires 

and populations of this species are thought to not occur in the project area. 

None of the other cavity excavator MIS species are federally listed Endangered or Threatened Species, 

Forest Service Sensitive species, U. S. Fish and Wildlife Service Birds of Conservation Concern (USFWS 

2008), or species that are regionally identified as having current viability concerns. Population trends for 

the species from breeding bird surveys from 1996─2013 indicate stable populations in Oregon for hairy 

woodpecker, downy woodpecker, Lewis woodpecker, and black-backed woodpecker and increasing 

population trends for pileated woodpecker and red-breasted sapsucker (Sauer et al. 2014). Breeding bird 

survey trends are not available for the northern three-toed woodpecker. A decline in northern flicker and 

red-breasted nuthatch has been detected in Oregon from 1996-2013. Northern flicker is a common 

resident species that is ubiquitous to most forest habitats in Oregon. They are most abundant in open 

forest habitat and along forest edges with available large (31 inches dbh or greater) snags (Marshall et al. 

2003). The red-breasted nuthatch appears to be fairly common in Oregon and is somewhat flexible to use 

different forest types. This species is showing a slight population decline due to intensive forest 

management that reduces the amount of large diameter trees, snags, and structural diversity (Marshall et 

al. 2003). Despite a recent decline in numbers, both northern flickers and red-breasted nuthatches are well 

above population levels that would suggest a viability concern.

A collection of information, referred to as DecAID, has been developed by Region 6 to help projects 

identify the levels of snags and downed logs required to meet wildlife population needs (Forest Service, 

2012). At the landscape level, DecAID recommends providing dead wood at levels within the range of 

historic variability. 

Snags 

Analysis Methods 

Two analysis methods and scales were used to evaluate snags and down wood: 

1) A snag model tied to a forest geographic information system layer of vegetation types was used to 

calculate current conditions in planning subdrainages affected by the project and for determining 

compliance with Willamette Forest Plan and Northwest Forest Plan Standards and Guidelines. The scale 

of analysis for the Willamette Forest Plan snag model describes conditions at the planning subdrainage 

level and is more responsive to project level effects on snag habitat than a larger landscape assessment.
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2) DecAID, a web-based advisory tool was used to estimate historic and current snag and down wood

levels at a watershed level and reflects a larger landscape reference of snag habitat than the snag model. 

DecAID contains data showing wildlife use of dead wood and showing amounts and sizes of down wood 

across the current landscape in managed and unmanaged stands. Vegetation data can help determine the 

“natural range of variability” for dead wood, which can be used as a proxy for historic range of 

variability. This provides a method of comparing current and historic levels of snags and downed logs. By 

managing habitat within historic range of variability it is assumed that adequate habitat will be provided 

because species survived those levels of habitat in the past to be present today. The further current 

conditions deviate from the historic range of variability the less likely adequate habitat is being provided 

to sustain those species using the habitat. Historic range of variability does not replace the standards and 

guidelines for dead wood in the Willamette Forest Plan.

The DecAID model was re-run to reflect the effects of the 2017 forest fires in the Breitenbush watershed. 

The DecAID analysis re-run can be found in Appendix F.

Regulatory Framework – Snag Model

Because proposed activities can affect the amount and distribution of snags, the effects of the alternatives 

on snag abundance were evaluated. The Willamette Forest Plan (WFP) directs snag habitat to be managed 

at levels capable of providing for at least 40% or greater potential populations of cavity-nesting species 

(FW-122). To meet the minimum diameter and height requirements to count toward Willamette Forest 

Plan objectives, a snag shall be greater than 18 inches dbh or the largest size available within the stand 

being treated and 20 feet tall (FW-128 and FW-130). Snag habitat shall be provided and monitored at the 

subdrainage level to provide for at least 40% or greater potential populations (WFP 1990). The Willamette 

Forest Plan, as amended by the 1994 Northwest Forest Plan (Forest Service 1994) (p. C-42), states, “As a 

minimum, snags are to be retained within the harvest units at levels sufficient to support species of cavitynesting birds at 40% of potential population levels based on published guidelines and models.” (The 

Willamette Forest Plan required 20 % as a minimum in harvest units, the amendment increased this to 

40% in harvest units.) More recent science has invalidated the biological potential model concept (Rose et 

al. 2001). Until the Willamette Forest Plan is amended, the snag densities related to biological potential 

remain as minimum standards for snags. 

For the Hwy 46 project area, it is estimated that 1.51 large snags/acre would meet the 40% population 

potential addressed in the Willamette Forest Plan standard. A snag density model tied to a geographic 

information system layer of forest vegetation size classes was used to calculate the current condition for 

primary cavity excavator population potential. Because the Forest Plan standard applies only to Forest 

Service lands, only Forest Service lands within the planning area are considered in this assessment. Due 

to the forest vegetation layer not being updated in many years the Fox planning subdrainage was analyzed 

based on current condition from stand exams in proposed treatment areas and field verification of habitat 

conditions.

Existing Condition

The area analyzed for effects are in the Cliffs, Devils, Fox, Hill, Humbug, Leone-Cultus, Mansfield, 

North Fork Breitenbush, Roaring, Scorpion, Short, South Fork Breitenbush and Tunnel planning 

subdrainages. The 2017 forest fires occurred primarily in the Scorpion, South Fork Breitenbush and

Devils planning subdrainages. The effect of the fire on snag habitat is to alter snag levels where trees were 

killed to be far in excess of the 100% level. The forests producing snags were already producing snags at 

the 100% level. From a model perspective there is no change from the existing condition prior to the fire 

as the forest affected had snag levels at the 100% level before and after the fires. The change is in future 

natural snag recruitment which will be delayed. Without the fire the forests would continue producing 
Hwy 46 Project FEIS Chapter 3

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snags at the 100% level. With the fire, snag levels will drop when the trees killed by the fire fall down and 

levels are reduced to below the 100% level and green trees are not old enough to produce replacement 

snags. 

Table 35 Potential Population Levels in Planning Subdrainages (base year 2016)

Planning subdrainage Existing condition –

percent of subdrainage 

meeting 40% PPL

Time to reach 40% PPL 

– no action

Time to reach 40% PPL 

– Alternatives 2 and 3

Cliffs 59.6% Already meeting Already meeting

Devils 47.1% Already meeting Already meeting

Fox 65.7 Already meeting Already meeting

Hill 51.4% Already meeting Already meeting

Humbug 51.9% Already meeting Already meeting

Leone-Cultus 40.2% Already meeting Already meeting

Mansfield 49.2% Already meeting Already meeting

North Fork Breitenbush 46.1% Already meeting Already meeting

Roaring 66.0% Already meeting Already meeting

Scorpion 55.9% Already meeting Already meeting

Short 46.4% Already meeting Already meeting

South Fork Breitenbush 42.8% Already meeting Already meeting

Tunnel 49.4% Already meeting Already meeting

All thirteen planning subdrainages are currently meeting the 40% potential population level.

Table 36 Snag Levels by Alternative

Planning

subdrainages

Current 

Condition (Alt#1)

Alt#2 Alt#3

Cliffs 59.6% 59.0% 59.6%

Devils 47.1% 47.1% 47.1%

Fox 65.7 63.0% 65.2%

Hill 51.4% 51.1% 51.1%

Humbug 51.9% 51.9% 51.9%

Leone-Cultus 40.2% 40.2% 40.2%

Mansfield 49.2% 48.8% 48.9%

North Fork Breitenbush 46.1% 45.7% 45.8%

Roaring 66.0% 66.0% 66.0%

Scorpion 55.9% 52.4% 55.9%

Short 46.4% 44.2% 46.1%

South Fork Breitenbush 42.8% 42.8% 42.8%
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Planning

subdrainages

Current 

Condition (Alt#1)

Alt#2 Alt#3

Tunnel 49.4% 46.8% 49.4%

Willamette

Forest Plan S/Gs

>40% of Psub FW-125

Mitigation Requirements for Alternative 2

Snags at the rate of 1.5 per acre would be created after harvest and slash treatment in gaps and early seral 

habitat treatments areas in units 6, 14, 16-18, 21- 24, 28, 32, 35, 47, 59, 63, 180 and 200. After snags are 

created these units will meet Forest Plan Standards and guidelines for snag habitat.

Mitigation Requirements for Alternative 3

Snags at the rate of 1.5 per acre would be created after harvest and slash treatment in gaps and early seral 

habitat treatments areas in units 6, 23, 35, 47, 59, 63, 180 and 200. After snags are created these units will 

meet Forest Plan Standards and guidelines for snag habitat.

Down Wood 

Analysis Methods 

A Geographic Information System (GIS) analysis was performed to evaluate existing conditions.

Regulatory Framework

The 1994 Northwest Forest Plan amended forest plans within the range of the Northern Spotted Owl. It 

provided standards for leaving coarse woody debris in regeneration harvest units (p. C-40). Regeneration 

harvest is proposed as part of the project. On the Willamette National Forest leave 240 linear feet of logs 

per acres greater than or equal to 20 inches in diameter. Logs less than 20 feet in length cannot be credited 

toward this total. Decay class 1 and 2 logs can be counted towards these totals. Down logs should reflect 

the species mix of the original stand.
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Existing Condition

Table 37 Down Wood levels by Alternative

Planning

subdrainages

Current 

Condition (Alt#1)

Alt#2 Alt#3

Cliffs 67.0% 67.0% 67.0%

Devils 59.1% 59.1% 59.1%

Fox 74.8% 74.1% 74.7%

Hill 56.2% 56.2% 56.2%

Humbug 58.9% 58.9% 58.9%

Leone-Cultus 45.4% 45.4% 45.4%

Mansfield 55.5% 55.5% 55.5%

North Fork Breitenbush 50.7% 50.7% 50.7%

Roaring 71.9% 71.9% 71.9%

Scorpion 62.3% 62.3% 62.3%

Short 52.3% 52.3% 52.3%

South Fork Breitenbush 47.6% 47.6% 47.6%

Tunnel 57.8% 57.8% 57.8%

Willamette

Forest Plan S/Gs

>40% of Psub FW-125

Cavity Excavator Potential Population Analysis

Calculations indicate that, on the Willamette National Forest, there is a current snag population potential 

of about 54% in the Westside Lowland Conifer Hardwood (WLCH) habitat type and 56% in the Montane 

Mixed Conifer (MMC) habitat type. In the Breitenbush River watershed, the current snag population 

potential is estimated at about 50% in the Westside Lowland Conifer Hardwood habitat type and 46% in 

the Montane Mixed Conifer habitat type. The analysis suggests that the Hwy 46 project area is above the 

minimum snag population potential, but that snag abundance is lower than the average condition across 

the Forest.
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Table 38 Estimated Snag Population Potential for the Westside Lowland Conifer Hardwood and Montane 

Mixed Conifer Wildlife Habitat Types in the Breitenbush River Watershed and in the Willamette National 

Forest

Analysis Area Habitat Type Current Historic 

Breitenbush River Watershed WLCH 50% 77%

Willamette National Forest WLCH 54% 75%

Breitenbush River Watershed MMC 46% 74%

Willamette National Forest MMC 56% 74%

DecAID analysis suggests the current snag and down wood levels are below historic levels and above 

minimum levels for population viability. In addition to the model information two factors should be 

mentioned. 1) A large fire occurred north of the Breitenbush River and was concentrated in the Western 

part of the analysis area. There were areas to the east of this concentration that were also burned 

extending to the forest boundary. The year of origin of the trees growing in the burned area is 1893 which 

in 2017 makes these trees 124 years old. The burned area is approximately 5,000 acres. Model results will 

show the burned area to be low in snag and down wood levels when in reality these trees have grown 

larger and have become mature forests. 2) The Eagle Rock fire south of the Breitenbush River at the 

western edge of the planning area occurred in 1967. The Eagle Rock stands are close to having large 

enough trees for commercial thinning. During the planning process it was decided that this area would be 

deferred into the future. The model would show this area to be low in snags and down wood when in 

reality it is contributing to smaller diameter material and would soon begin producing larger snags and 

down wood.

Snags and down wood are prescribed where regeneration harvest is proposed to occur in early seral 

habitat creation and gaps over one acre. The number of snags and down wood are listed in the Forest Plan

Section of the Snags and Down Wood analysis. The number of trees needed to meet forest plan standards 

and guidelines for down wood and snags will be left in each area treated and would be converted to snags 

and down wood after harvest and slash treatment are completed. The silvicultural prescription for these 

treatment areas includes leave trees for snags and down wood. Specific units include 14, 17, 32a, 59, 63 

for quality early seral and meadow restoration, units 83, 84, 93, 94, 95, 96 for sugar pine restoration, units 

2, 6, 12, 16, 18, 21, 22, 23, 28, 32, 35, 39, 40, 47, 180 and 200 for gaps over 1 acre and sugar pine shelter 

woods.

Elk and Deer 

Elk and deer are Forest management indicator species because they are important big game hunting 

species in Oregon. The purpose and need elements of this project to increase early seral habitat and to 

enhance and restore meadows directly address elk and deer habitat needs. Public comments from Oregon

Hunters Association and the Rocky Mountain Elk Foundation supported restoring elk and deer 

populations and improving their foraging conditions especially by using treatments that reduced crown 

cover below 50%. Comments from Cascadia Wildlands asked that the role of private lands, especially 

those used for agriculture and forestry, in providing elk and deer habitat be considered.

The project area is in the state-designated Santiam Wildlife Management Unit (WMU) which is a large 

area that includes the Detroit Ranger District and much of the Sweet Home Ranger District on the 

Willamette National Forest, the Mt Hood National Forest west of the Cascade Crest, and large tracts of 
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private, State and Bureau of Land Management lands within and to the west of the National Forests. The 

estimated elk population in this WMU was about 4,000 in 1990 at the beginning of the Willamette Forest 

Plan, peaked at about 5,000 in 2002, and has since declined to about 3,000. Elk harvests and hunter 

success peaked in the late 1990s in this WMU and have declined since then. The current estimated elk 

population of about 3,000 for the Santiam WHU is well below the State Management Objective of 5,200. 

Also in the Santiam WMU, deer harvests have declined from about 3,400 in 1990 to 1,540 in 2010 while 

hunter success has declined from 21% to 11% during that time (USDA Forest Service 2011). Reduced 

forage quality and quantity due to the reduction in clear-cut logging on the Willamette National Forest are 

important factors in this decline of elk and deer. While private lands, which comprise 37% of the WMU 

(Oregon Department of Game Regulations-www.dfw.state.or.us), provide valuable big game habitat, the 

private forestry and agricultural lands cannot fully compensate for a reduction in habitat quality on the 

National Forest lands as evidenced by the decline in big game populations and harvests. Also the National 

Forest lands are especially important for providing the public with hunting opportunities that cannot be 

fully compensated for on private lands where access by the general public is more limited. 

An elk nutrition model has been developed that predicts Dietary Digestible Energy (DDE) on the 

Willamette National Forest (Rowland et al 2013) based on percent canopy cover (lower canopy cover, 

higher DDE), proportion of hardwoods (more hardwoods, higher DDE), and potential vegetation zone 

(silver fir/mountain hemlock forest types have higher DDE than western hemlock forests other factors 

being equal). Cook et al. (2004) found that increased summer forage quality (which DDE represents) 

improved elk reproduction and survival. An increase in summer and fall elk forage quality can directly 

increase calf weights prior to winter, overwinter calf survival, pregnancy rates, adult fall fat accumulation, 

and herd productivity (op cit.). The benefits of increased summer forage quality that have been 

demonstrated for elk are also expected for deer. 

Recently, as part of the Willamette Forest Monitoring Report for 2014-2015, changes in elk forage quality 

were evaluated across the Forest by running the elk nutritional model using Gradient Nearest Neighbor 

(GNN) data. GNN data are widely used by the Forest Service for large-scale mapping and habitat trend 

analysis, including for the 20-year Northwest Forest Plan Monitoring (e.g., Davis et al. 2015, 2016). The 

years 1993 and 2012 were used as “bookends” to compare changes in elk nutrition on the Forest and in 

the project area and reflect the year with available GNN data that is closest to Year 1990, the start of the 

Willamette Forest Plan, and the most recent year with available GNN data, respectively. 

The elk nutritional model (Rowland et al. 2013) divides elk forage into six classes ranging from poor to 

excellent (Table 40).
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Table 40 Elk Forage Classes Relative to DDE Values

DDE Class DDE values

Poor <2.40

Low-Marginal >-2.4 to <2.575

High-Marginal >-2.575 to <2.75

Low-Good >-2.75 to <2.825

High-Good >-2.825 to <2.90

Excellent >2.90

*DDE = dietary digestible energy (kcal/g)

DDE values are estimated from 2 sets of equations for dominant potential vegetation types that are 

applicable to the Willamette NF (Douglas-fir/Western hemlock-Springfield area and Pacific silver 

fir/Mountain hemlock), percent canopy cover, and proportion of hardwoods (Rowland et al. 2013). The 

values are very general in that they do not account for the different plant association within the potential 

vegetation type, but the model is useful in showing broad changes in nutritional forage values when 

calculated over large areas like a watershed or Forest. Within the Douglas-fir/western hemlock forest, the 

model predicts poor nutrition forage values at high canopy cover and low hardwood abundance (e.g., 

>60% cover and no hardwoods; >75% cover and >20% hardwoods). Using the Westside nutrition model, 

Douglas-fir/western hemlock forests never reach “good” nutritional quality (i.e., DDE >2.75 kcal/g), but 

can reach the “high-marginal” forage class at low canopy cover (e.g., <20% cover and no hardwoods; 

<30% cover and >20% hardwoods). 

The silver fir/mountain hemlock series is about a forage class higher than Douglas-fir/western hemlock 

under similar canopy cover and hardwood percentages. Dense stands lacking hardwoods are predicted to 

be marginal for elk nutrition. Good forage values occur in stands with moderate canopy and increasing 

hardwood abundance (e.g., <30% cover and no hardwoods; <50% cover and >20% hardwoods). Excellent 

forage nutrition is predicted to occur in open stands, typically early seral forests (e.g., 0% canopy cover 

with no hardwoods; <20% cover and 20% hardwoods).

The acres and percent of the Forest in each forage category is shown below for years 1993 and 2012 

(Table 41). During the period 1993 to 2012, there was a roughly 50,000 acre net increase in the amount of 

poor quality forage areas forest-wide and a decrease in all other elk forage categories (Table 42). 
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Table 39 Elk Forage Class Distribution 1993 and 2013, Willamette National Forest

Acres (%) by DDE Class

DDE Class 1993 2012

1 - Poor 487,940 (28.1%) 537,520 (31.0%)

2 - Low Marginal 883,000 (50.9%) 870,890 (50.2%)

3 - High Marginal 239,850 (13.8%) 218,370 (12.6%)

4 - Low Good 32,620 (1.9%) 22,650 (1.3%)

5 - High Good 25,690 (1.5%) 22,940 (1.3%)

6 - Excellent 65,620 (3.8%) 62,360 (3.6%)

Table 40 Changes in Elk Forage Distributions 1993 to 2012, Willamette National Forest

DDE Class Change in % of 

Forest

Relative % 

Change Change in Acres

1 - Poor 2.9 10.2 49,570

2 - Low Marginal -0.7 -1.4 -12,110

3 - High Marginal -1.2 -9.0 -21,480

4/5 - Good -0.8 -23.5 -13,880

6 - Excellent -0.2 -5.0 -3,265

About 28% of the Forest was estimated to be poor quality forage for elk in 1993. By 2012 this had 

increased to about 31% of the Forest. The Willamette Forest Plan divided the Forest into about 200 Big 

Game Emphasis Areas (BGEAs). The BGEAs total 1.79 million acres including private inholdings. 

Among BGEAs, 177 (88%) had an increase in poor quality forage areas, while 14 (7%) had a decrease. In 

1993, about 7.2% of the Forest was good or excellent forage. By 2012, this had declined to 6.2%, a 

decrease of about 17,100 acres. However, the average net decline is somewhat misleading because several 

wildfires created large areas of good to excellent forage, while the amount of higher quality forage 

declined across much of the rest of Forest. Fires include the B&B of 2003 at over 90K acres, Shadow 

Lake of 2011 at 10k, GS of 2007 at 7k, Puzzle Creek of 2006 at 6k and Lake George of 2006 at 5k acres. 

Overall, 157 BGEAs (78%) had a decline in acres of good to excellent forage, while 34 (17%) had an 

increase. Fifty percent above the 1993 forest-wide average was selected as a benchmark for areas with 

relatively large amounts of high-quality elk forage (i.e. BGEAS with >10.5% in good to excellent forage 

class). In 1993, 50 (25%) of the BGEAs, exceeded this threshold. By 2012, 19 (9.5%) BGEAs exceeded 

the threshold. In tracking the individual BGEAs, 40 of the original 50 in 1993 declined below the 

threshold level by 2012, while 9 BGEAS were added due to fires.
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Proposed treatment units occur in nine Big Game Emphasis Areas. However, in the McCoy BGEA, a 

couple acres of a proposed understory habitat enhancement treatment unit overlapped the edge of the 

BGEA. Moreover, the proposed understory habitat enhancement treatment would not affect overstory 

canopy cover or change the model-predicted forage quality in this unit. Because no predicted change 

would occur to the big game forage values in this BGEA, effects to the McCoy BGEA were not evaluated 

further. The remaining eight BGEAs where treatments were proposed were combined and used to 

evaluate the effects of the alternatives on big game habitat. The eight BGEAs total slightly more than 

57,000 acres of big game habitat and are referred to as the project analysis area for big game forage in the 

remainder of this section. The acres in each elk forage class in 1993 and 2012 are displayed in Table 42

for these BGEAs and the changes in DDE classes between 1993 and 2012 are shown in Table 43. About 

1.2% of these BGEAs are on non-Forest Service land.

Changes in elk forage quality from 1993 to 2012 in the project analysis area is generally in line with the 

trends forest-wide. There has been a relatively large decline in high-marginal, good and excellent forage 

areas and an increase in poor quality forage areas (Table 43). One small difference is that low marginal 

forage areas increased slightly (1.1% relative change) in the project analysis area compared to a slight 

decline (-1.4% relative change) forest wide. The decrease in big game forage quality in the project area is 

in line with the observed declines in deer and elk and the concerns about decreased hunting success 

expressed by members of the public.

Table 41 Elk Forage Class Distribution in 1993 and 2012 and for Alt 2 and 3 in the Hwy 46 Project

Acres (%) by DDE Class

DDE Class 1993 2012 Alt 2 Alt 3

1 - Poor

17,940

(31.3%)

20,740

(36.2%)

18,990

(33.2%)

19,560

(34.2%)

2 - Low Marginal

24,840

(43.4%)

25,120

(43.9%)

26,700

(46.6%)

26,220 

(45.8%)

3 - High Marginal 9,600 (16.8%) 7,950 (13.9%)

8,110

(14.2%)

8,030

(14.0%)

4 - Low Good 1,410 (2.5%) 1,050 (1.8%) 1,060 (1.8%) 1,050 (1.8%)

5 - High Good 840 (1.5%) 770 (1.3%) 770 (1.3%) 770 (1.3%)

6 - Excellent 2,620 (4.6%) 1,610 (2.8%) 1,610 (2.8%) 1,610 (2.8%)

The big game project analysis area is composed of 8 BGEAs which include Devils, 

Humbug, Leone-Curtis, North Fork Breitenbush, Roaring, South Fork Breitenbush, Short, 

and Slide.
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Table 42 Changes in Elk Forage Class Distributions from 1993 to 2012 in the Hwy 46 Project Analysis Area

DDE Class Change in % of 

Analysis Area

Relative % 

Change Change in Acres

1 - Poor 4.9 15.6 2,800

2 - Low Marginal 0.5 1.1 280

3 - High Marginal -2.9 -17.2 -1,650

4/5 - Good -0.7 -18.9 -420

6 - Excellent -1.8 -38.5 -1,010

Studies have shown that elk avoid open roads that receive regular motorized traffic (Rowland et al. 2004, 

2013). Standards and guidelines in the 1990 Willamette Forest Plan established road habitat effectiveness 

values for each Big Game Emphasis Area that directly translate into desired maximum open road 

densities for each BGEA. The desired maximum open road densities compared to the current open road 

density is shown in Table 45. All BGEAs in the project analysis area currently meet the desired open road 

density.

Table 45 Comparison of MVUM Open Road Density to Forest Plan Elk Road Density Standards and Guideline 

by Big Game Emphasis Area in the Hwy 46 Project Analysis Area

Big Game Emphasis Area Forest Plan Elk Emphasis 

Level

Forest Plan Desired** 

Maximum Open Road 

Density for Elk (road 

miles/sq. mile)

MVUM Open Road 

Density (road miles/sq. 

mile)

Devils Moderate < 2.9 1.4

Humbug Moderate < 2.9 1.7

Leone Curtis Moderate < 2.9 2.2

North Fork Breitenbush Moderate < 2.9 1.3

Roaring Moderate < 2.9 1.6

Short Moderate < 2.9 2.1

Slide Low < 4.8 2.6

South Fork Breitenbush Moderate < 2.9 0.5

*MVUM = Motor Vehicle Use Map which is the Forest Service record of roads on National Forest Lands 

designated for public vehicle use pursuant to 36 Code of Federal Regulations (CFR) 212.51. 

** Willamette Forest-wide Standards and Guidelines FW-151 and FW-153 establish minimum Habitat 

Effectiveness Values for open roads in Moderate and Low BGEAs. These road habitat effectiveness values 

directly translated into the maximum desired open road densities (Wisdom et al. 1986) shown in this table.

Because of the low amount of recent clear-cutting on the Forest and the lack of large-scale fires in the 

project analysis area, cover for elk and deer is abundant and not limiting the populations. After the 2017 
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forest fires there are approximately 521 acres of potential additional early seral habitat generated by fire 

in the watershed. The acres of additional early seral based on dead canopy are approximately 84 acres. 

Moreover, Cook et al. (1998) found that thermal cover did not enhance elk survival and reproduction and 

could not compensate for inadequate forage conditions.

Marten

Marten are members of the weasel family that prefer mature and old conifer-dominated forest habitat. 

They use cavities in snags and logs for denning, resting, and natal sites. Although the Willamette Forest 

Plan established marten habitat areas, designated as 9c management areas, at strategic locations across the 

entire forest (USDA Forest Service 1990), recent information suggests marten primarily occur in montane 

conifer forests above about 4,000 feet elevation (Aubry and Lewis 2003, NRIS_wildlife database). 

Camera set monitoring on the Willamette NF beginning in 2012 have detected marten at 91% of the 

stations above 4000 feet elevation (n = 37 stations) and 0% of the stations below that elevation (n = 33 

stations) (Willamette NF unpublished wildlife data, Supervisors Office). About 700,000 acres (39%) of 

the Willamette National Forest are above 4000’ elevation and considered marten habitat.

3.6.12 Environmental Consequences – Management Indicator Species 

Cavity Excavators, Pileated Woodpecker, and Deadwood Abundance

Snags 

Direct and Indirect Effects

Alternative 1 – No Action 

Existing levels of snags would be maintained. Untreated mature natural stands would continue to produce 

large diameter snags through natural processes. Younger stands would continue to produce small diameter 

snags through competition induced mortality. Generally competition induced mortality occurs in the 

smallest trees which average approximately one half the average stand diameter. The production of snags 

through natural mortality would be delayed in previously thinned stands as a result of reduced 

competition and would produce fewer snags than would be expected from unmanaged stands. Snag 

diameters and numbers would continue to increase over time due to tree growth and mortality. In the 

future there would continue to be losses of snags from hazard tree cutting adjacent to open roads. Trees in 

riparian reserves, CHU and LSR would continue to increase diameter over time and would provide snags 

from natural recruitment.

Alternative 2 

Private land in the analysis area is limited to approximately 159 acres in the Breitenbush Hot Springs 

area. As snags are a hazard in a high use recreation setting they are expected to be removed soon after 

trees die. Changes as a result of activities on private land in the Hwy 46 planning area would not alter 

snag levels as only National Forest System land is analyzed. Private land comprises approximately 0.5% 

of the planning subdrainages analyzed for Hwy 46.

Alternative 2 proposes approximately 2609 acres of commercial thinning which includes gaps and 

dominant tree release treatments. In stands proposed for commercial thinning, slowing of growth has 

occurred from overstocking. With thinning, the average diameter of the stand would be increased by 

removing the smaller trees and the remaining trees would grow faster. Thinning harvest units are not 
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expected to have trees large enough to provide snags of the diameter size needed to meet Forest Plan

standards and guidelines. Abundance of smaller snags would be initially reduced by harvest activities and 

a subsequent reduction in competition mortality in thinned units. Some small diameter snag loss would be 

offset by larger trees damaged during harvest and from exposure to wind and snow breakage due to 

thinning. 

Alternative 2 proposes approximately 195 acres of regeneration and other final removal harvest. 

Regeneration harvest and any final removal harvest requires Snags and Down Wood be created after 

harvest to meet forest plan standard and guideline levels. Meadow restoration considered a final removal 

and would have snags and down wood requirements. The silvicultural prescription for meadow 

restoration is to leave 3-5 trees per acre of the largest trees which may become snags after slash treatment. 

Dominant tree release treatments are limited in size from 1⁄4 - 1⁄2 acre and would not lower overall snag 

levels to below minimum levels to meet forest plan standards and guidelines. Fuel treatments propose 

thinning and removing trees under 7 inches dbh with under burning of the stands treated. Fuel treatments 

are occurring in mostly mature forest stands which would be expected to have snags and down wood 

present. Fuel treatments may reduce snag and down wood levels slightly but are not expected to reduce 

the affected stands to below levels needed to meet forest plan standards. Understory habitat enhancement

is cutting trees under 7 inches dbh and burning piles where needed is not be expected to reduce snags or 

down wood levels. The proposed road relocation is occurring in previously thinned stands with basically 

no snags so this activity is not expected to reduce snag levels.

Riparian reserve areas, Late Successional Reserves and Critical Habitat areas for Northern Spotted Owl

recovery would produce larger snag diameters for an indefinite period of time.

Commercial thinning of approximately 2550 acres in alternative 2 would reduce future natural 

recruitment by reducing competition induced mortality and delay snag recruitment. Snag levels would be 

lower in the thinned stands for approximately 30-60 years based on growth simulation (FVS) model runs. 

Changes to snags levels in the short term would increase diameter and abundance in regeneration and 

other final removal harvest on approximately 197 acres. The increase of snags in regeneration and other 

final removal harvest units would be due to mitigation measures where snags are created to meet forest 

plan standards and guidelines

Alternative 3 

Private land in the analysis area is limited to approximately 159 acres in the Breitenbush Hot Springs 

area. As snags are a hazard in a high use recreation setting they are expected to be removed soon after 

trees die. Changes as a result of activities on private land in the Hwy 46 planning area would not alter 

snag levels as only National Forest System land is analyzed. Private land comprises approximately 0.5%

of the planning subdrainages analyzed for Hwy 46.

Alternative 3 proposes approximately 1962 acres of commercial thinning which includes gaps and 

dominant tree release treatments. In stands proposed for commercial thinning, slowing of growth has 

occurred from overstocking. With thinning, the average diameter of the stand would be increased by 

removing the smaller trees and the remaining trees would grow faster. Thinning harvest units are not 

expected to have trees large enough to provide snags of the diameter size needed to meet Forest Plan

standards and guidelines. Abundance of smaller snags would be initially reduced by harvest activities and 

a subsequent reduction in competition mortality in thinned units. Some small diameter snag loss would be 

offset by larger trees damaged during harvest and from exposure to wind and snow breakage due to 

thinning.
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Regeneration harvest and any final removal harvest requires Snags and Down Wood be created after 

harvest to meet forest plan standard and guideline levels. Meadow restoration considered a final removal 

and would have snags and down wood requirements. The silvicultural prescription for meadow 

restoration is to leave 3-5 trees per acre of the largest trees which may become snags after slash treatment. 

Dominant tree release treatments are limited in size from 1⁄4 - 1⁄2 acre and would not lower overall snag 

levels to below minimum levels to meet forest plan standards and guidelines. Fuel treatments propose 

thinning and removing trees under 7 inches dbh with under burning of the stands treated. Fuel treatments 

are occurring in mostly mature forest stands which would be expected to have snags and down wood 

present. Fuel treatments may reduce snag and down wood levels slightly but are not expected to reduce 

the affected stands to below levels needed to meet forest plan standards. Understory habitat enhancement

is cutting trees under 7 inches dbh and burning piles where needed is not be expected to reduce snags or 

down wood levels. The proposed road relocation is occurring in previously thinned stands with basically 

no snags so this activity would not be expected to reduce snag levels.

Riparian reserve areas, Late Successional Reserves and Critical Habitat areas for Northern Spotted Owl

recovery would produce larger snag diameters for an indefinite period of time. 

Commercial thinning in alternative 3 would reduce future natural recruitment by reducing competition 

induced mortality and delay snag recruitment. Snag levels would be lower in the thinned stands for 

approximately 30-60 years based on growth simulation (FVS) model runs. Changes to snags levels in the 

short term would increase diameter and abundance in regeneration and other final removal harvest on 

approximately 54 acres. The increase of snags in regeneration and other final removal harvest units would 

be due to mitigation measures where snags are created to meet forest plan standards and guidelines.

Cumulative Effects

The area analyzed for cumulative effects was the Hwy 46 planning area.

Alternative 1

The trend of the analysis area is toward more and larger snags over time as the forests mature, particularly 

in the Late Successional Reserves, Riparian Reserves and Critical Habitat Areas for Northern Spotted 

Owl Recovery. Dead wood conditions are expected to improve and provide more and better habitat for 

dead wood species.

Routine hazard tree felling along roads would continue to reduce snag levels adjacent to roads where 

these activities occur.

Alternatives 2 and 3

Ongoing road maintenance and the associated falling of hazard trees is expected to continue along roads 

which are open for use. This ongoing activity when combined with alternatives 2 or 3 would not result in 

significant impacts to snag levels in the analysis area. The 2017 forest fires in the analysis area did not 

increase snag and down wood levels at the modeling level as the stands burned were already producing 

snags and down wood at the 100% potential population level. Approximately 251 acres will be producing 

snags and down wood at much higher levels from fire mortality which will not be reflected in model 

numbers. Additionally, low intensity fire areas are expected to produce slightly elevated snag and down 

wood levels from individual tree mortality. It is possible ground fire removed existing down wood which 

is expected to be replaced in the next few years by snags falling as their root systems rot. Fire suppression 

activities reduced snag levels adjacent to roads and fire breaks which would not be expected to alter stand 

snag levels as numbers are averaged across the entire stands.
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Down Wood 

Direct and Indirect Effects

Alternative 1 – No Action 

Existing levels of down wood would be maintained. Untreated natural late-successional stands would 

continue to produce large diameter down wood through natural processes. Stands which are younger than 

late successional condition would continue to produce small diameter down wood through competition 

induced mortality. The production of larger diameter down wood through natural mortality would be 

delayed in previously thinned stands as a result of reduced competition and would produce fewer down 

wood than would be expected from unmanaged stands. Down wood diameters and numbers would 

continue to increase over time due to tree growth. In the future there would continue to be losses of down 

wood from wood cutting adjacent to open roads. Riparian reserve area, CHU and LSR trees would 

continue to increase in diameter over time and would provide down wood from natural recruitment.

Alternative 2 

For proposed activities which would be considered regeneration harvest, meeting northwest forest plan 

requirements is required. For early seral habitat creation and gaps over 1 acre meeting down wood

requirements would be required. As part of the proposed regeneration harvest treatments burning slash is 

expected to remove most of the existing down wood which would be replaced by created down wood. 

These acres would have an increase in down wood in a larger size than current natural recruitment is 

providing. At a minimum 240 lineal feet of logs per acres greater than or equal to 20 inches in diameter, 

or largest available, would be provided.

In stands proposed for thinning on approximately 2550 acres, slowing of growth has occurred from 

overstocking and dominant trees are mostly less than 16 inches dbh. Generally competition induced 

mortality occurs in the smallest trees which average approximately one half the average stand diameter.

Commercial thinning as proposed under all action alternatives would result in an impact on down wood

levels within the units. Since thinning captures future mortality and can delay snag recruitment, it can also 

delay down wood recruitment. It is expected that down wood recruitment for the action alternatives would 

follow a similar path as described for the snags. Down wood levels would be lower in the thinned 

portions of stands and there would be a delay in natural recruitment due to reduced competition induced 

mortality. Alternative 2 would affect approximately 2520 acres, (8%) of the 31,135 acres of Forest 

Service land within the project planning area. 

Hazardous fuel treatment on 169 acres is expected to reduce the smallest diameter down wood component 

as this treatment consists of thinning live conifer trees less than 7 inches dbh. For the Northwest forest 

plan standard these trees do not meet minimum diameter requirements. Smaller diameter trees will be 

analyzed in the DecAID portion of the analysis which does include smaller dead wood. Underburning and 

slash treatment has potential to remove down wood. Slash treatment and underburning may also kill trees 

which would become down wood in the future. Fuel treatments are not expected to alter planning 

subdrainage down wood levels when averaged across the area. Not all down wood is expected to be 

removed by hazardous fuel reduction treatment.

Understory habitat enhancement on 155 acres has a similar treatment as hazardous fuel treatments without 

underburning of slash. Trees under 7 inches diameter are proposed to be cut to assist in the enhancement 

of understory shrubs. Some pile burning may occur which is not expected to remove a significant amount 

of down wood.
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During harvesting any legacy trees felled for safety reasons would be left on site providing large down 

wood. Removing snags which are along traveled roads is commonly done for public safety which reduces 

the number of snags which may become down wood.

Smaller down wood diameter levels would be initially reduced by harvest activities and the reduction of 

competition mortality. Trees would be damaged during harvest and from exposure to wind and snow 

breakage after thinning. Trees killed are expected to become down wood in an estimated 25 to 35 years.

Mitigation Requirements

Down wood would be created after harvest and slash treatment in gaps over 1 acre and early seral habitat

treatment areas at the rate of 3 trees felled per acre of the largest available in units 6, 14, 16-18, 21- 24, 

28, 32, 35, 47, 59, 63, 180 and 200. After down wood creation of 3 trees per acre these units will meet 

Forest Plan Standards and guidelines for dead wood. 

Alternative 3 

In stands proposed for thinning on approximately 1888 acres, slowing of growth has occurred from 

overstocking and dominant trees are mostly less than 16 inches dbh. Generally competition induced 

mortality occurs in the smallest trees which average approximately one half the average stand diameter.

Alternative 3 would affect 1888 acres, (6%) of the 31,135 acres of Forest Service land within the project 

planning area. 

Hazardous fuel treatment on 169 acres is expected to reduce the smallest diameter down wood component 

as this treatment consists of thinning live conifer trees less than 7 inches dbh. For the Northwest forest 

plan standard these trees do not meet minimum diameter requirements. Smaller diameter trees will be 

analyzed in the DecAID portion of the analysis which does include smaller dead wood. Underburning and 

slash treatment has potential to remove down wood. Slash treatment and underburning may also kill trees 

which would become down wood in the future. Fuel treatments are not expected to alter planning 

subdrainage down wood levels when averaged across the area. Not all down wood is expected to be 

removed by hazardous fuel reduction treatment.

Understory Habitat Enhancement on 155 acres has a similar treatment as hazardous fuel treatments 

without underburning of slash. Trees under 7 inches diameter are proposed to be cut to assist in the 

enhancement of understory shrubs. Some pile burning may occur which is not expected to remove a 

significant amount of down wood.

During harvesting any legacy trees felled for safety reasons would be left on site providing large down 

wood. Removing snags which are along traveled roads is commonly done for public safety which reduces 

the number of snags which may become down wood.

Smaller down wood diameter levels would be initially reduced by harvest activities and the reduction of 

competition mortality. Trees would be damaged during harvest and from exposure to wind and snow 

breakage after thinning. Trees killed are expected to become down wood in an estimated 25 to 35 years.

Sugar Pine restoration would occur on 4 acres in alternative 3.

Mitigation Requirements

Down wood would be created after harvest and slash treatment in gaps over 1 acre and early seral habitat

treatment areas at the rate of 3 trees per acre felled of the largest available in units 6, 23, 35, 47, 59, 63, 
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180 and 200. After down wood creation of 3 trees per acre these units will meet Forest Plan Standards and 

Guidelines for dead wood.

Cumulative Effects

Alternatives 2 and 3

Hazard tree removal along roads would continue to reduce down wood levels in areas where these 

activities occur. Firewood cutting along roadways open to the public reduces down wood levels adjacent 

to roads. 

The 2017 forest fires in the analysis area did not increase snag and down wood levels at the modeling 

level as the stands burned were already producing snags and down wood at the 100% potential population 

level. Approximately 251 acres will be producing snags and down wood at much higher levels from fire 

mortality which will not be reflected in model numbers. Additionally, low intensity fire areas are expected 

to produce slightly elevated snag and down wood levels from individual tree mortality. It is possible 

ground fire removed existing down wood which is expected to be replaced in the next few years by snags 

falling as their root systems rot. Fire suppression activities reduced down wood levels adjacent to roads 

and fire breaks which would not be expected to alter down wood levels as numbers are averaged across 

the entire stands. It is possible down wood levels were increased slightly in some areas where snags were 

felled to reduce fire spread and became down wood.

As harvest has not occurred in the planning area for many years most stands are producing down wood

through natural recruitment. 
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Elk and Deer

Environmental Consequences

Direct and Indirect Effects

Alternative 1 – No Action 

Alternative 1 would maintain the current low quality big game forage levels in the project area and would 

have no effect on open road densities or big game cover. As such, Alternative 1 would have no direct, 

indirect, or cumulative effects to big game.

Alternative 2 

Alternative 2 proposes vegetation treatments on about 3,206 acres or about 5.6% of the eight BGEAs that 

comprise the big game project analysis area. The current canopy cover and proportion of hardwoods in 

each treatment unit were estimated from stand exam data and observations made during field 

reconnaissance. Estimated changes in canopy cover were determined from stand simulations and it was 

assumed that the proportion of hardwoods remained the same, post-treatment. Changes in elk nutrition 

were then calculated for each treatment unit.

About 2,884 acres of commercial thinning, meadow restoration, sugar pine restoration, and quality early 

seral treatments (5.0% of the analysis area) would lower overstory canopy cover to a degree that would 

result in a model-predicted increase in forage quality. The understory enhancement treatments and fuel 

treatments would not measurably change overstory cover or predicted elk forage quality.

About 1,747 acres of poor quality foraging areas would be converted to low-marginal (1,575 acres), highmarginal (164 acres) or good (8 acres) foraging habitat (Table 46). The small amount of good quality 

foraging habitat that is produced is because the treatments which substantially reduce the canopy are 

mostly in the western hemlock habitat type which the nutritional model predicts can only achieve the 

high-marginal forage class.

Assuming the canopy will grow back at a rate of about 2% per year (Chan et al. 2006, Wilson and 

Puettmann 2007), the improvement in forage from the thinning treatments is expected to last about 10 

years on the average. Six harvest units totaling 56 acres, where canopy is reduced below 30%, should 

increase big game forage for about 20 years assuming full stocking with planting.

Table 43 Changes in Elk Forage Class Distributions in the Hwy 46 Project Analysis Area Due to Alternative 2

DDE Class Change in % of 

Analysis Area

Relative % 

Change* Change in Acres

1 - Poor -3.0 -8.4 -1747

2 - Low Marginal 2.7 6.3 1575

3 - High Marginal 0.3 2.1 164

4/5 - Good 0.01 0.4 8

6 - Excellent 0 0 0

*Relative % change is calculated by comparing to the 2012 model output (Table 4). 
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The reduction in poor nutritional habitat and the increase in marginal quality habitat could result in a 

small temporary increase in elk and deer populations in Alternative 2, depending on other factors such as 

weather, disease and predation. Because there would be essentially no change in good and excellent 

forage habitat, no large increase in big game populations or harvest levels are expected as a result of this 

alternative alone. The increase in habitat quality improvement from highest to lowest by BGEA is Short 

(1,495 acres), North Fork Breitenbush (404 acres), Devils (363 acres), Leone Curtis (326 acres), South 

Fork Breitenbush (154 acres), Slide (63 acres), Humbug (44 acres), and Roaring (35 acres).

Alternative 2 would have no long-term changes in roads open to the public for motorized use. There 

would be a reduction in elk and deer use within and adjacent to the treatment units during the time that 

logging, yarding, and under-burning was occurring, but elk and deer are expected to return to the area 

soon after activities ceased. Effects of disturbance would be temporary. Security and thermal cover values 

would remain high and would not be a limiting factor on the populations.

Alternative 3 

Alternative 3 proposes vegetation treatments on about 2,407 acres or about 4.2% of the eight BGEAs that 

comprise the big game project analysis area. About 2,085 acres of commercial thinning, sugar pine

restoration, and quality early seral treatments (3.6% of the analysis area) would lower overstory canopy 

cover and/or increase hardwood abundance to a degree that would result in a model-predicted increase in 

forage quality. The understory enhancement treatments and fuel treatments would not measurably change 

overstory cover or predicted elk forage quality.

About 1,179 acres of poor quality foraging areas would be converted to low-marginal (1,096 acres) or 

high-marginal (83 acres) foraging habitat (Table 47). No good or excellent forage habitat is expected to be 

created by nutritional model.

Assuming the canopy will grow back at a rate of about 2% per year, the improvement in forage from the 

thinning treatments is expected to last about 10 years on the average. Two harvest units totaling 16 acres, 

where canopy is reduced below 30%, should increase big game forage for about 20 year assuming full 

stocking with planting. 

Table 44 Changes in Elk Forage Class Distributions Due to Alternative 3

DDE Class Change in % of 

Analysis Area

Relative % 

Change* Change in Acres

1 - Poor -2.0 -5.7 -1179

2 - Low Marginal 1.9 4.4 1096

3 - High Marginal 0.1 1.0 83

4/5 - Good 0 0 0

6 - Excellent 0 0 0

*Relative % change is calculated by comparing to the 2012 model output (Table 4). 
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The reduction in poor nutritional habitat and the increase in marginal quality habitat could result in a 

small temporary increase in elk and deer populations in Alternative 3 compared to the no-action 

alternative, but less than would be observed in Alternative 2. The increase in habitat quality improvement 

in Alternative 3 is the same as Alternative 2 for all BGEAs except Short. Alternative 3 would improve 

about 696 acres of big game foraging habitat in the Short BGEA.

Similar to Alternative 2, Alternative 3 would result in no long-term changes in motorized roads open to 

the public and security and thermal cover would remain at high levels that would not limit elk and deer 

populations. In both, action alternatives, deer and elk are expected to continue to be limited by the 

availability of high quality forage habitat.

Cumulative Effects

The Hwy 46 big game analysis area is comprised of 8 BGEAs totaling about 57,000 acres. The baseline 

condition was set at 2012 when the last GNN coverage was available to calculate elk forage values from 

the nutritional model. No stand replacement fires have occurred in the analysis area since that time. There 

are no other ongoing or reasonably foreseeable activities on National Forest System lands in the big game 

analysis area that would meaningfully improve forage habitat for deer and elk.

Approximately 1.2% of the big game analysis area is comprised of non-Forest Service lands. Some of 

these are managed for timber production and are expected to provide early seral habitat when they are 

periodically clear-cut. Of the private land within the analysis area, only the Breitenbush Resort and 

Conference Center (approximately 159 acres) is within the project area and is not managed for timber 

production. Because the non-Forest Service lands are mostly in the Douglas-fir/Western hemlock series 

they should temporarily provide areas of high-marginal DDE forage when they are logged.

Determination

Alternative 1 – No Action

No improvement of elk forage would occur on Forest Service lands. Barring natural disturbances such as 

fire, previously logged area would continue to regenerate and forage would decline in the few open 

plantations that remain. Future clear-cutting on private lands would have a small effect on improving big 

game populations because it comprises about less than 1% of the area. Overall the amount of area that in 

poor nutritional quality is expected to increase and deer and elk populations are expected to remain at the 

reduced levels.

Alternatives 2 and 3

Excluding natural disturbances that cannot be predicted, Alternatives 2 and 3 would account for about 

98% and 97%, respectively, of the reasonably foreseeable actions on Forest Service lands that would 

result in a temporary improvement in big game forage. It is not possible to accurately predict future deer 

and elk populations due to the numerous factors that affect them. However, because of the expected 

reduction in areas with poor nutritional quality, there may be a small temporary increase in deer and elk 

populations in the analysis area under the action alternatives with the greatest effect likely in Alternative 

2.

Marten

Within the 69,327-acre Breitenbush River watershed, about 19,516 acres are above 4000 feet elevation on 

the Willamette NF and considered marten habitat. Both action alternatives have proposed treatment units 

in these habitat so effects to marten are analyzed further. Two 9c marten habitat management areas occur 
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197

in the Breitenbush River watershed. However, both are below 4000 elevation and no treatments are 

proposed in them. Therefore, this project would have no effect on 9c marten management areas.

Direct and Indirect Effects

Alternative 1 - No Action 

Alternative 1 would maintain the current forest habitat. Barring stand-replacement natural disturbances, 

forests would continue to develop large diameter trees, large snags, and large downed logs as the stands 

progress into old growth. The structural features that marten prefer would continue to increase over time. 

No short-term increase in berry production is expected to occur in stands that comprise Units 54, 82, 89, 

and 92. Unit 32a would continue to develop into marten habitat as the fire-created meadow continues to 

develop into a forest stand.

Alternative 2 

Alternative 2 proposes about 358 acres of treatments at or above 4000’ elevation, which is about 1.8% of 

the estimated marten area on the Willamette NF in the Breitenbush River watershed. 

One hundred and fifty five acres of the treatments (Units 54, 82, 89, 92, and 560) are for understory 

habitat enhancement. This treatment would non-commercially thin conifers less than 7 inches dbh and 

would maintain berry production in the understory of 110 acres of older forests and 45 acres of plantation 

(Unit 560). Berries are important foods for marten (Verts and Carraway1998). Thus, this treatment is 

likely to have a short-term benefit on marten habitat, especially in the older forest stands.

One hundred and eight acres of plantations (Units 55, 543, and 540) and 84 acres of natural stands (Units 

32 and 97) would be commercially thinned in marten habitat. The plantations would be thinned to about 

44-66% canopy cover and the natural stands would be thinned to about 53-54% canopy cover. Marten 

continue to use partially harvested stands, particularly if canopy is maintained above 40%. (Thompson et 

al. 2012). Therefore the commercial thinning treatments are expected to degrade marten habitat rather 

than remove it. Negative effects from thinning include loss of future snags and down wood that could 

provide resting and denning sites and habitat for prey. Longer-term, positive benefits from thinning 

include larger tree size, better developed canopies, and multi-layered stands.

Eight acres of meadow restoration (Unit 32a) are proposed in marten habitat. The cutting and removal of 

most of the conifers in the fire-created meadow would set back the development of this site into marten 

habitat in order to maintain high-quality meadow habitat for a variety of species. 

Shirk et al. (2012) evaluated marten home ranges using a 990-meter radius scale (i.e. 760-acre circle). 

Given the arrangement and size of the proposed units, Alternative 2 would degrade about 4.5% to 12.5% 

of the habitat in three potential marten home ranges. This level of impact is not expected to result in a loss 

of functional home ranges for marten, but shifting of use within territories and minor changes to the size 

of the territory to compensate for the impacts on the habitat would likely occur. Understory habitat 

enhancement in older stands may slightly benefit marten habitat in two potential home ranges.

Alternative 3 

Alternative 3 proposes about 263 acres of treatments at or above 4000’ elevation, which is about 1.3% of 

the estimated marten area on the Willamette NF in the Breitenbush River watershed. 
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The effects of treatments on marten habitat are the same as Alternative 2 for understory habitat 

enhancement and for commercial thinning in plantations. Alternative 3 would have no meadow 

restoration or commercial thinning in natural stands in marten habitat.

Using a 990-meter radius scale (i.e. 760-acre circle) to analyze for effects to marten at the home range 

scale (Shirk et al. 2012), Alternative 3 would degrade 4.5% and 7.9% of the habitat in two potential 

marten home ranges. This level of impact is not expected to result in a loss of functional home ranges for 

marten for this alternative. Understory habitat enhancement in older stands may slightly benefit marten 

habitat in two potential home ranges.

Cumulative Effects

There are no other ongoing or reasonably foreseeable actions on National Forest System lands in the 

Breitenbush River watershed that would meaningfully alter marten habitat. None of the non-FS lands in 

the watershed are above 4000 foot elevation. Thus future activities on private lands are not expected to 

have any impact on marten habitat in the watershed.

Considering direct, indirect and cumulative effects, both action alternatives would maintain the viability 

of marten in the Breitenbush River watershed. Marten habitat in the watershed is directly connected to 

marten habitat in adjacent watersheds on the Willamette and Mt Hood National Forests. No barriers to 

movement of marten along the Cascades would occur as a result of any of the Hwy 46 alternatives. Viable 

populations of marten are expected to continue to persist across the Willamette National Forest in the 

montane mixed conifer habitat zone.

Determination

The Hwy 46 project would affect marten habitat in less than 1% of the area with an increase over time 

expected in other unharvested land use allocations. Therefore, Hwy 46 would not contribute to a negative 

trend in viability on the Willamette National Forest for marten as habitat for this species is expected to 

increase over time.

3.6.13 Affected Environment – Migratory Birds

Migratory birds are protected under the Migratory Bird Treaty Act of 1918 (16 U. S.C. 703-704). The 

U.S. Fish and Wildlife Service is the lead federal agency for managing and conserving migratory birds in 

the United States. However, under Executive Order (EO) 13186, all federal agencies are charged with the 

conservation and protection of migratory birds. A Memorandum of Understanding (MOU 2008) between 

the Forest Service and U.S. Fish and Wildlife Service requires, during NEPA planning, that the FS, to the 

extent practical, evaluate and balance long-term benefits of projects to migratory birds against any shortor long-term adverse effects. It also requires the FS to consider approaches, to the extent practical, for 

identifying and minimizing take of migratory birds that is incidental to otherwise lawful activities. Region 

6 has compiled some information to assist biologists in disclosing effects to avian species during NEPA 

planning (Forest Service and Bureau of Land Management 2013). Effects to FS sensitive birds, federally 

ESA listed birds, and birds that are Management Indicator Species have been addressed above. Four 

additional migratory bird species that have been identified by USFWS as Species of Conservation 

Concern in the Northern Pacific Forest (USFWS 2008) and that have habitat in the proposed treatment

units are addressed in this section. These four species are northern goshawk, Rufous hummingbird, olivesided flycatcher, and purple finch.

An emerging concern for migratory birds in the Pacific Northwest is declining early-successional forest 

habitat (Swanson et al. 2010). Early seral conifer habitat is important habitat for many migratory bird 
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species, including three of the above Species of Conservation Concern (Altman and Hagar 2007). In 

particular, there is a lack of complex early seral habitat, which is early successional forests with abundant 

and diverse shrub understory composition, high abundance of large diameter snags and downed logs, and 

substantial green tree retention. While private logging lands may create early seral habitat, large diameter 

snags, downed logs and live leave trees are rarely retained in any quantity, and shrub and forb understory 

species may be suppressed by herbicide treatments. 

3.6.14 Environmental Consequences – Migratory Birds

Direct and Indirect Effects

Alternative 1 – No Action 

Alternative 1would have no direct effect on migratory bird habitat and would not increase habitat for 

early-seral species. The Hwy 46 units would continue to develop towards old growth forest conditions, 

resulting in improved nesting and foraging habitat for northern goshawks and other species that prefer this 

habitat.

Alternative 2 

Alternative 2 would remove about 195 acres of forest which would become early seral habitat. Early seral 

habitat would be created by meadow restoration, wildlife gaps, dominant tree release, sugar pine

restoration and quality early seral habitat creation. Early seral habitat benefits rufous hummingbirds, 

purple finch and olive-sided flycatchers.

Older forests provide habitat for bird species like the northern goshawk, which prefer older conifer 

forests. The analysis area currently provides foraging and potential nesting areas for goshawks. No 

goshawks have been reported from any of the proposed Hwy 46 units. Mitigation measures would protect 

any raptor nests that are incidentally found in the harvest units during layout or implementation.

Alternative 2 would be consistent with the Migratory Bird Treaty MOU. Early seral habitat is limiting 

populations of species dependent on this habitat type and this project is increasing early seral habitat. 

Designs features to retain large live trees over 30 inches dbh, create snags, and fall trees for dead wood

sources would provide structural features migratory birds would use. 

Migratory birds which favor shrub habitat in early seral conifer stands, such as the Rufous hummingbird 

and purple finch, would benefit for about 20 years or until dense conifer regrowth reestablishes in the 

units. Species, such as olive-sided flycatcher, which favor forest openings with large snags, would likely 

benefit for as long as the snags remain, which could be 30 or more years. Alternative 2 would have a 

beneficial effects on migratory birds with 264 acres of early seral habitat created. (Gaps 48 ac, sugar pine

shelterwood 92ac, meadow 8 ac, early seral 43ac, DTR 73 acres.)

Alternative 3 

Alternative 3 would remove about 54 acres of forest which would become early seral habitat. Early seral 

habitat would be created by wildlife gaps, dominant tree release, sugar pine restoration and quality early 

seral habitat creation. Early seral habitat benefits Rufous hummingbirds, purple finch and olive-sided 

flycatchers.

Older forests provide habitat for bird species like the northern goshawk, which prefer older conifer 

forests. The analysis area currently provides foraging and potential nesting areas for goshawks. No 
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200

goshawks have been reported from any of the proposed Hwy 46 units. Mitigation measures would protect 

any raptor nests that are incidentally found in the harvest units during layout or implementation. 

Alternative 3 would be consistent with the Migratory Bird Treaty MOU. Early seral habitat is limiting 

populations of species dependent on this habitat type and this project is increasing early seral habitat. 

Designs features to retain large live trees over 30 inches dbh, create snags, and fall trees for dead wood

sources would provide structural features migratory birds would use.

Migratory birds which favor shrub habitat in early seral conifer stands, such as the rufous hummingbird 

and purple finch, would benefit for about 20 years or until dense conifer regrowth reestablishes in the 

units. Species, such as olive-sided flycatcher, which favor forest openings with large snags, would likely 

benefit for as long as the snags remain, which could be 30 or more years. Alternative 3 would have the 

same beneficial effects on migratory birds although fewer acres (115 acres) of gaps would be created.

Cumulative Effects

No other projects in the analysis area are creating early seral habitat so no cumulative effects would occur 

in the analysis area. Some positive benefits to early seral species are expected to occur as a result of the 

2017 forest fires. Approximately 521 acres of new early seral habitat are expected as a result of the fires

3.7 Botany and Invasive Plants

3.7.1 Summary of Effects Analysis

There will be minimal adverse effects on botanical resources from proposed actions. No Regional 

Forester’s sensitive species occur within areas where ground disturbance will occur. All rare survey and 

manage species will be buffered. Some habitat for uncommon survey and manage species (Sparassis 

crispa and Peltigera pacifica) will be adversely affected by actions proposed in action alternatives. 

However, these actions will not cause a loss of viability for any of the species within the watershed. 

Special non-forested habitats would be protected with differing methods: wet habitats will be protected 

within riparian reserves while drier habitats will be protected from direct disturbance. Increases in habitat 

for invasive plant species are expected (9% increase under Alternative 2 and 6.4% increase under 

Alternative 3), especially since much of the project area is near powerline corridors. Project design 

features would be used to mitigate some increases in populations of invasive plants due to ground 

disturbance; weed increases will be minimized to the extent possible.

3.7.2 Scale of Analysis

The area analyzed for cumulative effects for sensitive and survey and manage species and special habitats 

include the sub-watersheds where the projects occur: Upper Breitenbush River, North Fork Breitenbush 

River, South Fork Breitenbush River, Lower Breitenbush River, Humbug Creek and small portions 

Boulder Creek-N. Santiam River, East Fork Collawash River and Cub Creek subwatersheds. This spatial 

analysis area was chosen because the area is ecologically similar, spatially connected and likely contains 

habitat for rare plants similar to those suspected to be in the Hwy 46 Project. The scale of analysis for all 

invasive weed species is the project area including all highways and roads leading into the units used by 

logging equipment. 

3.7.3 Affected Environment – Sensitive Botanical Species

Regulatory Framework
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Sensitive botanical species are addressed in the Forest Service Manual (FSM) 2670 and Forestwide 

Standard and Guidelines 156-161 and Amendment 158 to the Willamette Land and Resource 

Management Plan (USDA, 1990). Protection of federally listed Threatened and Endangered species is 

mandated by the Endangered Species Act. No federally listed Threatened or Endangered, nor suitable 

habitats for these listed plants are known to occur in the project area. Sensitive species are protected by 

USDA Forest Service regulations and manual direction (FMS 2672.4).

Forest management activities that may impact populations of or alter habitat for TESP (threatened, 

endangered, sensitive, or proposed) species require a Biological Evaluation (FSM 2671.44) be completed. 

The Biological Evaluation process (FSM 2672.43) is used to assist in determining the possible effects the 

proposed management activities have on species listed or proposed to be listed by the U.S. Fish and 

Wildlife Service and species listed as sensitive by the USDA Forest Service, Region 6.

There are 93 species on the Regional Forester’s 2011 Sensitive Plant List documented or suspected to 

occur on the Willamette National Forest. All species were evaluated for inclusion in the survey list for this 

project.

Current Condition 

A prefield review is conducted prior to surveys to determine whether species of concern and their habitats 

are documented in the project area. The review for this project uncovered four Regional Forester’s 

Sensitive and three Strategic species documented within the project area (Figure 1). Sensitive species 

within project area include Bridgeoporus nobilissimus, Cortinarius barlowensis, Eucephalus gormanii, 

and Romanzoffia thompsonii. In addition, three Regional Forester’s Strategic species, Chrysomphalina 

grossula, Albatrellus dispanus and Plagiothecium piliferum, are located within the project area. No 

populations are found within proposed timber harvest or restoration areas.

There are 3 known sites of Bridgeoporus nobilissimus, the noble polypore fungus, on the Detroit Ranger 

District. One site is within the project area and was documented in 2012. Fruiting bodies occur on large, 

dying and dead noble fir and Pacific silver fir in late-successional old-growth forests and on remnant 

stumps and snags in young and mature second-growth forests in the Pacific silver fir and western hemlock 

zones in western Washington and Oregon (Lebo, 2007).

Cortinarius barlowensis is a fungus species widely distributed in western Oregon and Washington. It has 

been found in western Cascades Provinces of both Oregon and Washington, and Washington’s coastal 

provinces. There are approximately 35 sites of this species throughout the Pacific Northwest. There is one 

documented site on the Willamette NF and it is on a CVS (Current Vegetation Survey) plot within the 

project area but outside of any units. 

Eucephalus gormanii is a sensitive species considered very rare and endemic. It is a sub-alpine aster that 

is only found on cliffs and open rocky areas in the vicinity of the Oregon Cascade Mountains. It is a small 

aster, growing 4-12 inches tall, glandular, with sessile leaves that are erect, crowded and overlapping up 

the stem. Ten to twelve white to pinkish ray flowers surround the base of yellow disk flowers. Three 

populations of E. gormanii occur along ridges and ridge saddles in the project area. 

Romanzoffia thompsonii is a regional endemic found only in the northwestern Oregon Cascades. It is a 

very small, ephemeral plant that grows in seepy rock gardens on rock outcrops. It is rather common 

within its range where high quality habitat exists. There are four known populations in the project area but 

none within units.
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Chrysomphalina grossula is an Oregon strategic fungus species. This taxon is a presumed 

ectomycorrhizal former. Sporocarps are solitary to gregarious in coastal to montane coniferous forest and 

fruits in autumn. This species is widely distributed in western Oregon and Washington. It has been found 

in western Cascades Provinces of both Oregon and Washington, and Washington’s coastal provinces. 

There are approximately 35 sites of this species throughout the Pacific Northwest. There is only one 

population on Willamette NF and it is found in an established campground within the project area.

Albatrellus dispanus is a wood decaying shelf fungus that is rare in Oregon. It has a large (foot wide) 

yellow fruiting body with multiple stalks and heads. It is found on the Mt. Hood and Willamette National 

Forests in the western Cascades. One population is found in the project area.

Plagiothecium piliferum occurs on trees trunks, especially red alder, along moist humid cliffs and on 

rocks along streams. This is a Regional Forester’s strategic moss. Oregon Natural Heritage Information 

Center reports P. piliferum from Clackamas, Douglas, Linn, Benton, and Tillamook Counties within the 

Coast Range and west Cascade Ecoregions. It is found on Umpqua NF and Salem, Eugene and Medford 

BLM Districts. Two populations are in the project area and are the only populations known from the 

Willamette NF. One population is found in the project area.

Figure 40 Sensitive and Survey and Manage Species documented within the project area

Field surveys using the intuitive-control method (meander through forested stands, complete inspection of 

high probability habitat) were conducted June through September of 2013, 2014 and 2015. All surveys 

were conducted by Forest Service employees. Additional information regarding sensitive plants was 

available from surveys conducted by contractors in 2011 for the Cascade Crossing transmission line 

project.

Ninety-three Region 6 sensitive plant, lichen and fungal species were evaluated to determine if they or 

their habitat would be impacted by this project. Habitat exists for 73 of the 93 species. Of the 73 species, 

16 are fungi for which single year, single season surveys are considered impractical because they fruit 

inconsistently (VanNorman, et. al, 2008, p. 4). Surveys were done for the remaining 57 species. The 

Biological Evaluation for Hwy 46 EIS is in the Project File.
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The project area is a well shaded western hemlock/Douglas fir forest with some steep terrain including 

high cliffs, many seasonal stream drainages and many wetlands. Vascular plant diversity is primarily 

found in non-forested habitats such as rock outcrops and wetlands. Lichen and bryophyte diversity is

moderate with many different types of habitats- a few exposed dry rocky outcrops, dry meadows, many 

moist rock gardens and wet meadows, some skunk cabbage swamps, seeps and ponds and well shaded, 

late successional forests. There is ample conifer habitat for rare fungi in the project area. The list of 

habitats and sensitive species surveyed is in the project file.

3.7.4 Environmental Consequences – Sensitive Botanical Species

Direct and Indirect Effects

Alternative 1 – No Action

Under Alternative 1, No-action, no direct effects are anticipated because no sensitive species would be 

disturbed by project activities.

Failure to implement the proposed action could affect sensitive plant species if it resulted in a fire that 

burned out of the range of natural or historical variability. It is hard to predict the magnitude of such a fire 

but fuel loadings and fire danger are predicted to increase as a result of self-thinning of mid-seral stands 

without fuels reduction (see Fuels Report, Alternative 1 No Action). A very hot fire could extirpate known 

sensitive species by killing all the hosts for mycorrhizal fungi and incinerating the upper organic layers 

where the mycelia or fungal body resides in the soil (Bruns, 2002).

There could also be indirect effects on fungi because of reduced species diversity in the younger Douglas 

fir monoculture plantations that are uniform in composition. Because stands would not be thinned, 

allowing diverse understory species to thrive, they would undergo a slow decline before presumably 

opening up enough to provide habitat and species diversity. Nonvascular plant diversity is correlated with 

species diversity and structure (Lesica et al, 1991).

Alternative 2

There are several sensitive species documented within the project area but none found within units. There 

will be no direct or indirect effect on sensitive vascular plants, lichens or bryophytes. However, since 

single year surveys were deemed infeasible for fungi, there could be effects to these species.

It is possible that individual sites of fungi may be negatively affected in the short term directly by host 

tree removal, physical disturbance, soil compaction, and the disruption of mycelial networks (Lippert and 

Huff, 2014) in timber harvest operations. Twelve of the 16 sensitive fungi species are mycorrhizal and 

could experience the loss of hosts. The probability of host loss will be higher in the regeneration harvest 

units. However, affected populations will most likely rebound over the short term in thinned units (10-40

years) as mycelia recolonize remaining trees. 

Indirect effects to fungi include short-term loss of moisture retention capabilities due to the drying effect 

of overstory shade removal, and the reduction of water storage with the disturbance or removal of forest 

floor organic material and large wood (Lippert and Huff, 2014). Loss of large woody material and host 

trees also represents a reduction of available nutrients and possible inoculum source for future fungal 

regeneration and expansion (Amaranthus and Perry, 1994). 

Regeneration harvest has the potential to affect sensitive fungus habitat. Late seral forest remnants 

produced substantially more truffles than the clear-cuts surrounding them (Clarkson and Mills, 1994). 

Clarkson also notes that hypogeous sporocarps are largely absent from young, slowly regenerating clear-
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cuts. Several interacting explanations probably account for observations of truffles being virtually absent 

in clear-cuts. First, decreased soil moisture on cutover areas may depress truffle production. Clear-cutting 

and burning exacerbate soil desiccation during the Northwest’s summer drought. There is a related 

reduction or loss of the organic layer in the soil following clear-cutting and burning. Low truffle 

abundance in clear-cuts may also be attributed to reduced spore dispersal. Depressed truffle production 

may reflect the loss of plant hosts in clear-cuts.

Early seral (regeneration harvest prescription) units will have a minimum of 15% of green tree retention. 

Green-tree retention may enhance seedling nutrition and survival through maintenance of mycorrhizal 

inoculum on site. Fungal diversity is maintained at higher levels in retention areas than in clear-cuts. 

Retained trees will provide some legacy of fungal diversity during the development of the next stand 

(Luoma et. al, 2006). Luoma and Eberhart (2005) found that even though green-tree retention can 

preserve ectomycorrhizal diversity, sporocarp production and ectomycorrhizal species richness was 

significantly reduced at all levels of harvest.

Prescribed fire and pile burns can affect mycelial networks through scorching of the soil, reduction of 

downed wood refugia and disrupt the nutrient cycling and soil chemistry (Emerson and Huff, 2014). 

Adverse effects to mycelia are largely dependent on fire severity. Severity is normally less in spring when 

soil moisture content is higher. Prescribed burning can be beneficial to host trees in the long term as it 

reduces the chances for catastrophic fire when forested stands are heavily stocked and there is a lot of fine 

ladder fuel. Patchy burns favor fungi.

The 910 acres of skips in stands, either as Green Tree Retention areas or as buffers should help maintain 

fungal diversity in the planning area. Research shows that both clumped and isolated leave trees benefit 

fungal diversity in a recovering landscape (Lippert and Huff, 2014).

No direct or indirect effects are expected to rare fungi from young tree removal in meadows or 

understory/fuels thinning treatments. Pruning trees should not adversely affect host trees, any soil layers 

or downed wood necessary for fungal survival.

Alternative 3

The direct and indirect effects to sensitive fungi from actions proposed in Alternative 3 would be the same 

as the effects on sensitive species in the proposed action, but with less acres of habitat affected. No fire 

regenerated stands will be thinned so there will be 650 less acres of fungal hosts removed. Associated 

activities that affect soil compaction such as yarding (527 less acres), road construction (3 acres less) and 

fuels treatments (202 less acres pile burn and 525 less acres underburn) will be reduced accordingly.

Cumulative Effects 

Alternative 1

There will be no cumulative effects on sensitive species for the No Action Alternative.

Alternative 2

The temporal scale for this analysis is 60 years because this likely represents the time period in which 

adequate data is available for known occurrences within the areas as well as time periods for reestablishment if impacted in the past. This increases the likelihood of such species existing in project area 

stream drainages.

There could be cumulative effects on sensitive fungi habitat from loss of host trees or chances to habitat 

from timber management, road construction and fuels treatments in the project area. The bulk of the 
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impact is assumed to be from timber harvest activities. Within the planning sub drainages, a total of 

13,065 acres have been harvested in the past (Table 48). This means that 42% of the area has been 

managed for timber production. This alternative proposes to harvest 8.3% of the project area, 75% of 

these acres have been previously harvested.
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Table 45 Percent of Watershed within Project Area

Sub-watershed Total 

Acres

Acres W/in 

Project area

% Acres W/In 

Project area

% acres of watershed 

within Project area

Upper Breitenbush River 20,395 19,743 96% 63%

North Fork Breitenbush 

River

16,255 5,204 32% 17%

South Fork Breitenbush 

River

13,082 5,994 46% 19%

Lower Breitenbush River 9203 113 1% <1%

Humbug Creek 10,392 213 2% <1%

Miner over lap of 3 others 50,030 28 <1% <1%

Total 119,357 31,295 =26%* =100%

*represents the total percent of sub-watersheds acres within sale area 

Alternative 3

Similar to Alternative 2, there could be cumulative effects on sensitive fungi habitat such as loss of host 

trees, soil compaction and loss of duff layer from timber management, road maintenance and construction 

and prescribed burning in the project area. This alternative proposes to harvest 6% of the project area, 

although all of these acres have been previously harvested.

3.7.5 Affected Environment – Survey and Manage Botanical Species 

Regulatory Framework 

The Northwest Forest Plan, Record of Decision (USDA and USDI, 2001) designated special management 

of just over 300 “survey and manage” species to reduce or eliminate effects of management actions on 

these old-growth associated species whose persistence is not assured through the system of reserved 

lands. The Northwest Forest Plan requires surveys for projects that could alter habitat for survey and 

manage species and management of populations if they are found.

On December 17, 2009, the U.S. District Court for the Western District of Washington issued an order in 

Conservation Northwest, et al. v. Sherman, et al., No. 08-1067-JCC (W.D. Wash.), granting Plaintiffs’ 

motion for partial summary judgment and finding NEPA violations in the Final Supplemental to the 2004 

Supplemental Environmental Impact Statement to Remove or Modify the Survey and Manage Mitigation 

Measure Standards and Guidelines (USDA and USDI, June 2007). In response, parties entered into 

settlement negotiations in April 2010, and the Court filed approval of the resulting Settlement Agreement 

on July 6, 2011. Projects that are within the range of the northern spotted owl are subject to the survey 

and management standards and guidelines in the 2001 ROD, as modified by the 2011 Settlement 

Agreement.

The 2011 Settlement Agreement states, “For projects with signed Records of Decision, Decision Notices, 

or Decision Memoranda from December 17, 2009, through September 30, 2012, the Agencies will use 

either of the following Survey and Manage species lists: (a). The list of Survey and Manage species in the 

2001 ROD (Table 1-1, Standards and Guidelines, pages 41-51) or (b) the list of Survey and Manage 

species and associated species mitigation, Attachment 1 to the Settlement Agreement.” In addition, the 

Survey and Manage Tracking forms which include Botany Species Survey and Site Management 

Summary will be completed for each project. These completed tracking forms can be found in the project 

file.
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The Hwy 46 Project applies a 2006 Exemption from a stipulation entered by the court in litigation 

regarding Survey and Manage species and the 2004 Record of Decision related to Survey and Manage 

Mitigation Measure in Northwest Ecosystem Alliance v. Rey, No. 04-844-MJP (W.D. Wash., Oct. 10, 

2006). Previously, in 2006, the District Court (Judge Pechman) invalidated the agencies’ 2004 RODs 

eliminating Survey and Manage due to NEPA violations. Following the District Court’s 2006 ruling, 

parties to the litigation entered into a stipulation exempting certain categories of activities from the 

Survey and Manage standards and guidelines, including both pre-disturbance surveys and known site 

management. Also known as the Pechman Exemptions, the Court’s Order from October 11, 2006 directs:

“Defendants shall not authorize, allow, or permit to continue any logging or other grounddisturbing activities on projects to which the 2004 ROD applied unless such activities are in 

compliance with the 2001 ROD (as the 2001 ROD was amended or modified as of March 21, 

2004), except that this order will not apply to: 

a) Thinning projects in stands younger than 80 years old: 

b) Replacing culverts on roads that are in use and part of the road system, and removing 

culverts if the road is temporary or to be decommissioned; 

c) Riparian and stream improvement projects where the riparian work is riparian planting, 

obtaining material for placing in-stream, and road or trail decommissioning; and where 

the stream improvement work is the placement large wood, channel and floodplain 

reconstruction, or removal of channel diversions; and 

d) The portions of project involving hazardous fuel treatments where prescribed fire is 

applied. Any portion of a hazardous fuel treatment project involving commercial logging 

will remain subject to the survey and management requirements except for thinning of 

stands younger than 80 years old under subparagraph a. of this paragraph.” 

Per the 2011 Settlement Agreement, the 2006 Pechman Exemptions remain in force:

“The provisions stipulated to by the parties and ordered by the court in Northwest Ecosystem 

Alliance v. Rey, No. 04-844-MJP (W.D. Wash. Oct. 10, 2006), shall remain in force. None of the 

following terms or conditions in this Settlement Agreement modifies in any way the October 2006

provisions stipulated to by the parties and ordered by the court in Northwest Ecosystem Alliance 

v. Rey, No. 04-844-MJP (W.D. Wash. Oct. 10, 2006).”

Hwy 46 Project meets Exemption A in some of the project area where there is no regeneration harvest and 

thinning only in stands less than 80 years old.

This project used the January 2001 ROD standards and guidelines and the associated January 2001 

species list, and the four categories of projects exempt from the Survey and Manage standards and 

guidelines as stipulated by Judge Pechman (October 11, 2006 Pechman exemptions). The Pechman 

exemption used was a relief from survey for stands under 80 years of age.

For stands greater than 80 years of age or for stands that surveys are triggered if there is suitable habitat 

for target species and if the proposed project is habitat-disturbing. Thirty four stands were greater than 80 

years of age and four stands were to be regeneration harvested and required predisturbance surveys.

Predisturbance surveys were completed for these areas in 2013, 2014 and in 2015. The survey protocols 

used were intuitive controlled as suggested in survey protocols developed for bryophytes, lichens, fungi 

and vascular plant species groups.
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Current Condition 

There are 91 sites of 19 survey and manage species documented within the project area. The complete list

is located in the project file. Thirty-one of these sites are within proposed project units. Most of these 

species were documented during the proposed Cascade Crossing project in 2011 and 2012. One of these 

species is category F and does not require site management. Protective measures are not required by 

Northwest Forest Plan Record of Decision (F). No further discussion is needed for these species.

If found within a unit, the rest of the categorized species may require some type of protective measure to 

maintain species viability. Exceptions to this include one Category E lichen species, Peltigera pacifica 

and a Category E fungus, Sparassis crispa.

There are 17 sites of Peltigera pacifica within units and 18 known sites outside of units within the project 

area. Only the units have been surveyed, so there are likely many more populations within the project 

area. Because this species is found to be common and well-distributed within the project area and 

forestwide (there are 164 documented populations across the forest currently in our database), no 

protective measures will be prescribed besides avoidance when possible.

Sparassis crispa is a common fungus prized as an edible. There are 5 known sites in the project area, 4 of 

which are in units. There are 14 other sites across the Forest and because it is a rather common species it 

is likely underreported. No protective measures will be prescribed for these fungi besides avoidance of 

host trees where possible.

Of the remaining 13 Manage Known Sites species (Categories A, B and E), 6 species have no sites within 

proposed project units and 6 have had sites dropped from the unit due to buffers for other sensitive or 

survey and manage species. The remaining species-Pseudocyphellaria rainierensis populations that are 

found in units have been prescribed 100 foot buffers for protection.

Pseudocyphellaria rainierensis is a leafy epiphytic lichen that grows in the canopy of older conifer 

stands in the Pacific Northwest. In the project area, it’s found in units 24 and 83 that are between 105 and 

120 years of age. This species is often associated with riparian areas as it requires a cool, moist habitats. 

According to the Conservation Assessment (Stein, 2013), the major threats to the survival of the species 

are loss of host trees and changes in microclimate such as temperature, humidity and radiation. Because 

unit 24 is prescribed to be thinned, a 100 foot buffer was prescribed. Unit 83 is a sugar pine restoration 

unit. Thirty-three of the 107 acres are to be a shelterwood cut and should require a larger buffer for 

maintenance of microclimate. However, the population is adjacent to a riparian buffer which will provide 

the needed microclimate, so a 100 foot buffer was also prescribed for this population. The Conservation 

Assessment also recommends preventing fire in Pseudocyphellaria habitat and buffer to maintain old 

growth habitat features and integrity. This population is in a unit known to have burned in the Scorpion 

fire of 2017. Spatial data showing soil and vegetation burn severity indicates that the site is located in an 

area that was unburned, therefore the population is presumed to persist and the prescribed buffer will 

remain.

The last Survey and Manage Category is D, uncommon species where we need to manage high priority 

sites. Two species will be buffered in this category due to the fact that they have limited distributions 

within the watershed and the Forest: Chalciporus piperatus and Rhizopogon truncatus.

Chalciporus piperatus is an uncommon survey and manage bolete mushroom. It is mycorrhizal, meaning 

that it has a symbiotic relationship with tree roots in the vicinity of its fruiting body. It is dependent on 

host trees for carbohydrates and in turn provides micronutrients to the trees. This species is found from 

the Canadian border down to the Californian border but its distribution is patchy. There are eight 
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populations on the Willamette NF, 3 of which are found in the project area. Populations are found in units 

13 and 24. Management recommendations suggest considering placement of retention areas around 

populations to maintain connections and viability (Huff et al., 2013, p. 21). Because both of these are 

thinning units where trees will be left in the stand and microclimate not completely altered, a 100 foot 

buffer was prescribed around each population to maintain the microclimate and host trees. Unit 13 was 

burned in the Scorpion fire of 2017. Although spatial data shows the fruiting body found in this unit was 

located in an unburned area, the site is within 50 feet of moderate and high severity burns. The population 

is presumed to persist; however the buffer recommendation for this site is increased to 200 feet to 

mitigate for the changes in microclimate due to the Scorpion fire.

Rhizopogon truncatus is a mycorrhizal truffle fungus that forms symbiotic connections with fine roots of 

host trees in the vicinity of its fruiting body. This species is scattered around western Oregon, with over 

150 locations, mostly in southwest Oregon. Populations become fewer and sparser as one goes north to 

the Mt. Hood and east to the Deschutes NF. There are 3 populations of this species in the project area and 

only 7 on the Willamette NF. Management recommendations suggest considering placement of retention 

areas around populations to maintain connections and viability (Huff et al., 2013, p. 155). One population 

of Rhizopogon truncatus is found in unit 83. This unit, as mentioned previously, was burned in the 

Scorpion fire of 2017. Because the prescription for this stand was a shelterwood cut, the resulting

understory, temperature and humidity regimes would have changed post-treatment. To maintain the host 

trees and microclimate, a tree height buffer was recommended. However, because the population is very 

near the proposed road in unit 83, a 50 foot buffer was prescribed around the fruiting body to maintain 

host and adjacent trees as suggested in regional Management Recommendations. Spatial data showing 

soil and vegetation burn severity indicates that the site is located in an area that was unburned, surrounded 

by low severity burn, therefore the population is presumed to persist and the prescribed buffer will 

remain.

3.7.6 Environmental Consequences – Survey and Manage Botanical 

Species

Direct and Indirect Effects

Alternative 1 – No Action

No direct effects are anticipated because no survey and manage species would be disturbed by project 

activities 

Indirect effects to survey and manage species would be similar to sensitive species. Stand replacing fires 

in overstocked plantations with heavy natural fuel loadings could spread to adjacent older stands. This 

could alter old-growth stands necessary for species survival, removing both hosts, microclimate necessary 

for species survival and eliminating the source of propagules over the long term. 

If plantations remain unmanaged, it will take longer for stands to grow into potential habitat for survey 

and manage species.

Alternative 2

Many parts of the proposed project will cause disturbance to the landscape as Alternative 2 proposes 2732

acres of commercial thinning and 43 acres of regeneration harvest. Some of the thinning units will have 

gaps which are like regeneration harvest in terms of tree removal. Harvest will cause soil disturbance and 

compaction. Opening and constructing roads to haul the timber will also disturb soil and cause 

compaction. Post-harvest treatment of fuels will add some disturbance to the soil. 
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There are several survey and manage species are known to occur within project units. All survey and 

manage species sites where there will be ground disturbing activity that require protective measures 

(Categories A, B and E) will have protective buffers if they are truly rare within the project area. Two 

populations of Pseudocyphellaria rainierensis will have a 100 foot buffer to maintain habitat and 

microclimate. One population of Calciporus piperatus will also have a 100 foot buffer to maintain host 

trees and microclimate. One population of Chalciporus piperatus will have a 200 foot buffer to mitigate 

for possible fire effects from the Scorpion fire of 2017. One population of Rhizopogon truncatus will have 

a 50 foot buffer to maintain host trees. All buffers are expected to maintain the species and habitat 

features required for their persistence. 

An analysis of Peltigera pacifica, and Sparassis crispa shows that the buffering of populations within 

units is not necessary for the persistence of the species within the planning area. 

Silvicultural prescriptions for this alternative would increase stand complexity over the long term by 

opening the canopy to allow more light within the understory which would increase a higher diversity in 

understory vegetation, especially in the young plantations. This would convert dense, stem exclusion 

stands into potential future late successional habitat. This could be beneficial for survey and manage 

species over the long term. Benefits to survey and manage species and their habitats in older fireregenerated stands is less clear as many of these stands are starting to show structure and are stands where 

the true old-growth associates are located.

Alternative 3

Effects to survey and manage species will be less under this Alternative. Two units that are to be buffered 

for survey and manage species, unit 83 (Pseudocyphellaria rainierensis and Rhizopogon truncatus) and 

unit 13 (Calciporus piperatus) will not be harvested. This would maintain unaltered habitat throughout 

the units for these species, providing the best chance for long-term species survival as these are oldgrowth associated species. 

One of the four units with Sparassis crispa and four of the eleven units with Peltigera pacifica (units 13, 

28, 31, 83) will not be harvested under this alternative. These species were not prescribed buffers due to 

their abundance but it is recommended that populations be avoided. These populations will have a higher 

probability of persistence under this alternative. 

This alternative will, as with Alternative 2, increase stand complexity, in dense overstocked plantations. 

This will benefit survey and manage species over the long term.

Cumulative Effects 

Alternative 1 

There will be no cumulative effects resulting from the No Action alternative. 

Alternative 2 and 3

The temporal scale for this analysis is 60 years because this likely represents the time period in which 

adequate data is available for known occurrences within the areas as well as time periods for reestablishment if impacted in the past. This increases the likelihood of such species existing in project area 

stream drainages.

Cumulative effects, loss of hosts and quality habitat for rare fungi, on survey and manage species within 

project area for the proposed action will be limited to the stands where survey and manage species will 

not be buffered which is 599 acres or 2% of the watershed. Within the planning sub drainages, a total of 
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13,065 acres have been harvested in the past; 40.2% of the habitat has been modified. This project 

proposes to add another 1% habitat modification for survey and manage species (half of the acres 

proposed for modification are plantations and would already be counted) for Alternative 2 and no 

cumulative effect for Alternative 3.

3.7.7 Affected Environment – Special Habitats

Special habitats are unique non-forested and rare forested habitats that occur on the Willamette NF. The 

Willamette LRMP (USDA, 1980) contains a standard and guideline FW-211 that states that these habitats, 

due to their contribution to the plant and animal biodiversity on the forest, need to be maintained or 

enhanced. In order to manage for these special habitats, the Special Habitat Management Guide was 

developed for inventory and maintenance of habitats across the Willamette Forest (Lippert et al., 2010). 

There are many special habitats within the project area. These include dry, wet and mesic meadows, 

skunk cabbage swamps, rocky outcrops and moist rock gardens and talus slopes (Table 49). The most 

common type of habitat documented throughout the project units were skunk cabbage swamps, in some 

cases several per unit. All unit portions containing special habitats were buffered for protection using 

riparian buffers or specially designed buffers. Wetland habitats are scattered throughout the project area 

and have many roads that access them; therefore threats of weed infestations are high. 

Table 46 Special Habitats in the Hwy 46 Project Area

Habitat Type Units Prescription

Spring/Swamp 5,19,21,22,23,34,35,45,47,52,55,64,69,73,74,75,83

94, 100,110,130,140,160,170,190,200,220,250,

270,280,300,320,410,440,490,510

25-100 foot buffers or 

riparian buffer

Mesic meadow 32, 48, 53 100 foot buffer; Special 

treatment in unit 32 (see 

below)

Rock outcrop 3,33, 51, 83 Avoid direct disturbance 

Talus 32, 530 Avoid direct disturbance 

Dry meadow 54 Avoid direct disturbance

Moist rock garden 96 Buffer from gaps, avoid 

direct disturbance

Dry rock garden 420 Within riparian buffer
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Figure 41 Special Habitats

3.7.8 Environmental Consequences – Special Habitats

Direct and Indirect Effects

Alternative 1 – No Action

Encroaching trees in or surrounding the drier meadow habitats would continue to grow, and tree 

populations will expand causing a loss of mesic meadow habitat on the landscape. Natural increases in 

fuel loadings in heavily stocked plantations could increase the potential that wildfires would adversely 

affect some habitats.

Alternative 2

The only special habitat in the project area that will be directly affected is the meadow in unit 32a. The 

direct effect will be to remove young trees encroaching from the forest edge and tree islands in the 

meadow center, the aim of which is to maintain the area as a meadow with species useful for wildlife 

forage. Indirect effects will be the opening of the canopy and restoration of the hydrologic regime. Both 

of these things should increase understory species diversity, providing additional habitat for wildlife 

species. Effects of treatment are expected to have a beneficial effect on the meadow for at least the next 

10 years.

The rest of the special habitats within the project area will be buffered or avoided through directional 

felling and skidding outside the habitat. Indirect effects could include harvest or fire activities which have 

the potential to introduce invasive species that could spread to special habitats. Design features call for an 

additional 100 foot buffer from roads to prevent weed encroachment from roads. These actions should 

protect all special habitats from management actions. 

Alternative 3

There will be no direct effects to special habitats under this alternative because there will be no meadow 

restoration and all other habitats will be buffered. There could be indirect effects from increases in weeds 

in units adjacent to special habitats but design features should limit weed encroachment. 
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Cumulative Effects 

There will be no cumulative effects for the Alternative 1-No Action or Alternative 3.

There will be a small cumulative effect, maintaining the species composition, spatial extent and 

hydrology of the meadow, to special habitats from Alternative 2- Proposed Action. The area of analysis 

for cumulative effects are the individual special habitats within the project area. Past timber harvest, road 

construction and associated activities on public and private lands have adversely affected special habitats 

by introducing invasive weeds and building roads through them. Given the protective measures of this 

action, cumulative effects are anticipated for only the 8 acres of meadow restoration in unit 32a, a very 

small portion of the watershed.

3.7.9 Affected Environment - Invasive Plants 

Regulatory Framework 

Invasive plants are addressed in the Final EIS for Pacific Northwest Region Invasive Plant Program, 

Preventing and Managing Invasive Plants (USDA, 2005); 

Amendment 259 to the Willamette Land and Resource Management Plan (USDA, 1990); and the 

Willamette National Forest Integrated Weed Management Plan (USDA, 2007). The following documents 

guide the treatment of competing and unwanted vegetation in the Pacific Northwest: 

• Guide to Noxious Weed Prevention Practices (2001) 

• Executive Order 13112 (February 3, 1999) 

• Noxious Weed Control and Eradication Act (2004) 

• Willamette National Forest Noxious Weed Prevention Guidelines (2005) 

Current Condition

Thirteen invasive weed species are documented in the project area (Figure 42). The most serious weed 

infestations in the project area are new invader species: spotted, meadow and diffuse knapweed 

(Centaurea maculosa, jacea and diffusa). There is also one population of false brome, Brachypodium 

sylvaticum, in the project area. One population of cheatgrass, Bromus tectorum, is found along the 

powerline corridor. New invaders are priority for treatment on the Forest because there is a chance to 

eradicate populations. 

Other well established species include Scotch broom (Cytisus scoparius), tansy ragwort (Senecio 

jacobaea), Himalayan and evergreen blackberry (Rubus armeniacus and laciniatus), reed canary grass 

(Phalaris arundinacea), St. John’s wort (Hypericum perforatum), oxeye daisy (Leucanthemum vulgare), 

foxglove (Digitalis purpurea) and Canadian and bull thistles (Cirsium arvense and C. vulgare). The 

strategy for established infestations is to contain existing populations except where they are causing 

unacceptable environmental damage such as meadows or wetlands.
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Figure 42 Weed infestations

Populations of spotted and meadow knapweed, tansy ragwort, scotch broom, bull and Canada thistles are 

found along Highway 46 within the project area. Scotch broom was documented along most roads and 

within or related to all units. Spotted, diffuse and meadow knapweed are documented in units 7, 9, 44, 62, 

64, 74, 370 and 540. All of these populations were documented prior to project inception. No new 

populations were found during plant surveys in 2013 and 2014.

Scotch broom has been treated along the Highway 22 and several roads in the project area in order to 

contain the spread. An area north of the Breitenbush community, where the highway parallels the 

powerline corridor for a mile has been treated by Portland General Electric (PGE), Bonneville Power 

Administration (BPA) and by the Forest Service. The Breitenbush community has also manually 

controlled Scotch broom populations on their property in the past; current practices are unknown. 

Knapweed populations are currently being treated in the project area, as most are found along powerline 

corridors.

3.7.10 Environmental Consequences – Invasive Species

Direct and Indirect Effects

Alternative 1 – No Action

No areas would be disturbed by thinning or fuels reduction projects in the No Action alternative; there 

will be no project-based machinery to spread of invasive plants in the project area creating potential 

habitat for new weed infestations.

There could be indirect effects from the No Action alternative. Roads leading into the forest and project 

area are used by forest visitors; unclean vehicles have a potential to introduce weed seed, especially along 

roads and in dispersed recreation areas when the weather is wetter and mud sticks to tires and 

undercarriages. In addition, increased intensity of fire due to higher fuel loads and more ladder fuels from 

unthinned stands could result in greater numbers of acres of invasive weed habitat being produced by 

wildfire.
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New invader species will continue to get treatment regardless of alternative. Existing infestations will be 

treated as funds allow.

Alternatives 2 and 3

Direct effects of timber harvest and hazardous fuels reduction on weed introduction and persistence are 

due to a combination of soil disturbance and transport of seed into disturbed areas from silvicultural 

prescription, harvest methods and logging systems, road maintenance and construction and pile burning.

Risk ratings are a way that risk of invasion by invasive weed populations can be explained, quantified and 

compared between alternatives. Elements of the proposed project that can create habitat for invasive 

plants are listed and quantified by alternative (Table 50). 

Table 50 Acres Affected by Weeds (in Acres)

Project element Alternative 2 Alternative 3

Thinning Acres total 2488 1872

Gaps 130 90

Shelterwoods 92 9

Early Seral/Regeneration 43 14

Landings 580 464

Roads, new and existing 9.3 6.3

RISK RATING High Moderate/High

In the action alternatives, the areas that would be opened up to light and disturbance would be most at 

risk, e.g., roads, landings and silvicultural prescriptions that open up the habitat – gaps, shelterwoods and 

early seral. These areas are subject to ground disturbance and exposure to vehicles and equipment that 

may bring seed in, especially gaps adjacent to powerline corridors that will be constantly kept in a 

disturbed condition. Ground based yarding opens up more habitat than helicopter or skyline (suspension) 

yarding. Areas that are piled and burned typically create a nice seedbed for weeds as the hot central areas 

are usually burned to mineral soil.

Risk ratings were higher for Alternative 2 than 3, largely based on the increased numbers of acres of all 

the weed habitat producing activities associated with them. Probability of creating habitat for weeds is 

highest in the early seral stands and in gaps where there is little competing vegetation for weeds after 

harvest. Both action alternatives have a high probability of creating weed habitat.

Risk of weed invasion decreases in areas where temporary roads and landings are closed, rehabilitated, 

and seeded with genetically local, native plant species. In addition, the requirement for cleaning 

equipment before it comes onto the Forest will help reduce the possibility of introducing weed seed on 

logging equipment.

To address the issue of movement of weeds from main roads and powerline corridors, there is a project 

design criterion that states all gaps should be at least 200 feet from all temporary roads. Temporary roads 

and landings and will be burned and seeded in order to avoid the spread of invasive species.

In general, roads fragment the landscape and provide vectors for weed infestations. Post-harvest, 8.88

miles of roads in the project area will be analyzed for decommission.
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Cumulative Effects 

There will be no cumulative effects for Alternative 1-No Action.

The area analyzed for cumulative effects for the Action Alternatives is the project area and project area 

road system (31295 acres). Cumulative effects consist mainly of disturbance caused by the harvest 

activities (commercial thin, gaps, early seral harvest and shelterwoods) and road construction.

The cumulative effect of creation of habitat for more weed invasion for Alternative 2- Proposed action 

includes disturbance contributed by harvest activities of 2818 acres and more than 9.3 miles of roads (65 

acres) potentially used for access= 2883 acres disturbed. This is an effect on 9.2% of the watershed.

The cumulative effect of Alternative 3 includes disturbance contributed by harvest activities of 2033 acres 

plus habitat created by building or reopening 6.3 miles of roads (44 acres)= 2077 acres disturbed. This is 

an effect on 6.4% of the watershed.

Some factors will ameliorate the effects of this large scale weed habitat creation. Project design elements

such as requirements for washing of equipment and seeding of bare ground are meant to prevent 

infestations. It is estimated that this can reduce the abundance of weeds by up to 50%. Annual treatments 

and monitoring of new sites will continue before and after the project. Early detection of new populations 

that spring up is critical to containment and will save a great deal of time and money.

Project design elements including pretreatment of invasive species that will be done before logging 

activities begin using congressional appropriated funds. Monitoring roadside disturbed areas for new 

infestations will also occur on an annual basis. This would reduce overall cumulative affects within the 

planning watershed.

3.8 Transportation

3.8.1 Summary of Effects Analysis

Approximately 216 miles of roads were analyzed within the Hwy 46 planning area. Haul routes are 

identified as suitable for all season haul where structural strength is sufficient or can be restored with 

maintenance/reconstruction.

Alternative 2 recommends reconstruction/maintenance work on approximately 108.5 miles. Alternative 2 

also recommends storage of 4.07 miles and decommissioning of 8.88 miles.

Alternative 3 recommends reconstruction/maintenance work on about 98.7 miles. Alternative 3 also 

recommends storage of 4.07 miles and decommissioning of 8.88 miles.

Five roads have been identified for road realignment within the planned transportation system. 

3.8.2 Scale of Analysis

The Willamette National Forest completed a roads analysis in 2003. The Willamette National Forest 

Roads Analysis met the requirements of roads analysis at the Forest level.

A travel analysis was conducted for this project as a guide for managing the National Forest System 

(NFS) roads in the Hwy 46 Project planning area. Field work occurred during 2014 to 2016. In the 

analysis, data from current road status such as open and stored roads, road conditions, stream culvert 

location and conditions, road maintenance levels, and road access and travel management classifications

were used to develop a travel and road management plan. Data spreadsheets display this information and 

all documented information resides in the transportation analysis file. The travel and road management 
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plan included in this EIS proposes management recommendations for roads within the transportation 

analysis area. The travel analysis and plan considered such road-related items as safety, risk to resources, 

future expected use, public and private access, emergency access, and maintenance costs. 

The 2003 Willamette National Forest Road Analysis selected a set of key forest roads. These Key Forest 

Roads “should be operated and maintained to standards consistent with its Road Maintenance Objective. 

The public will be encouraged to use the system of Key Forest Roads for access into and through the 

Forest.” (USDA, 2003).

3.8.3 Affected Environment

The road system on the Detroit Ranger District was built during the past 60 years primarily for timber 

harvests and recreational use. These roads were built with a variety of maintenance objectives and 

construction techniques. As timber-harvest related road use has declined, so have the funds to maintain 

them, resulting in poor and deteriorating conditions. The roads in this planning area have a wide range of 

needs to maintain user safety and structural resilience and to prevent negative impacts to other resources. 

There has been limited commercial activity within this planning area in the past 20 years which has 

provided insufficient road maintenance or reconstruction on the transportation network. Roads in the 

planning area are becoming overgrown with brush, have nonfunctioning ditches, and have surface 

irregularities. In addition many culverts are near the end of their design life (25-30 years) and are in need 

of replacement. 

Primary access to the Hwy 46 planning area is provided by key roads on Table 51. These primary access

roads have asphalt or aggregate surfacing. All other Non-Key roads tributary to these major access roads 

are single lane aggregate or native surfaced roads with turnouts which have been built and maintained 

primarily for timber harvest activities and powerline access. These roads are either termed collector or 

local roads. Many local roads have been closed seasonally or year-round for wildlife or administrative 

purpose. Most system roads designated for haul in the Hwy 46 planning area have had some surface and 

drainage maintenance from previous activities. The open road density for the planning area is currently at 

2.91 miles per square mile. 

Table 47 Key Forest Roads

Road Number Key Forest Road Objective Maintenance. Level 

2231000 Yes 3 – Suitable for Passenger Cars

2231840 Yes 2 – High clearance vehicles

2231890 Yes 3 – Suitable for Passenger Cars

2231893 Yes 3 – Suitable for Passenger Cars

2231896 Yes 3 – Suitable for Passenger Cars

2233000 Yes 2 – High clearance vehicles

2233000 Yes 3 – Suitable for Passenger Cars

4600000 Yes 5 – High Degree of User Comfort

4600030 Yes 2 – High clearance vehicles

4600033 Yes 2 – High clearance vehicles

4600040 Yes 2 – High clearance vehicles

4600050 Yes 2 – High clearance vehicles

4600075 Yes 3 – Suitable for Passenger Cars

4685000 Yes 3 – Suitable for Passenger Cars

4685330 Yes 3 – Suitable for Passenger Cars
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Road Number Key Forest Road Objective Maintenance. Level 

4688000 Yes 2 – High clearance vehicles

4688240 Yes 2 – High clearance vehicles

4696000 Yes 3 – Suitable for Passenger Cars

4698000 Yes 3 – Suitable for Passenger Cars

Approximately 16% of the roads used for haul also access private land holdings in the planning area 

mainly for recreational and administrative use. There are no miles of road within a Cooperative Road 

Maintenance Agreement designation and no likely future haul from private land holdings. There is 

currently a road use permit in effect along Hwy 46 and FSR 2231000 to allow access for the Breitenbush 

Community. 

A travel analysis was completed on the road systems within the Hwy 46 planning area to determine the 

intended purpose, design elements and operation and maintenance criteria for each road segment using an 

interdisciplinary process and by using the Willamette Road Investment Strategy. The Willamette Road 

Investment Strategy (RIS) (2015) was an effort used to identify risks to resources posed by roads, identify 

priorities for maintaining motorized access and to explore opportunities to manage roads differently, aided 

by feedback from the public and community outreach. The RIS recommended roads be either Remain 

Closed (RC), Analyze for Closure (AC), Analyze for Decommissioning (AD), Defer Recommendation for 

later analysis (DR), and Remain Open (RO). The RIS also identified many forest roads as Priority Roads 

(PR). The Road Status table in Appendix H show the RIS recommendations and the Hwy 46 IDT 

decisions for Alternatives 2 and 3. The recommendations of this effort were used, along with input and 

recommendations from Resource Specialists, to write a Road Management Objective (RMO) for each 

road within the planning area. The RIS will be updated based upon the additional in-depth analysis 

completed in the Hwy 46 EIS analysis and documented in the RMOs. The RMOs will guide future travel 

management decisions.

The RIS was a Travel Analysis Report (TAR) recommending the minimum road system that protects 

resources and provided access for forest management and public motorized use (Travel Management Rule 

36 CFR 212). Approximately 216 miles of road were analyzed within the Hwy 46 planning area. About 

4.07 miles of road are recommended for storage and 8.88 miles for decommissioning as shown in Table 2. 

Any storage and decommissioning work on roads used for haul routes will be done post timber sale 

activities. All roads proposed for decommissioning have been identified as roads that are no longer 

needed for management activities in the foreseeable future. All roads proposed for storage are currently 

brushed in and not drivable. Roads proposed for decommissioning and storage will not be accessible to 

motorized vehicles.

3.8.4 Environmental Consequences

Direct, Indirect and Cumulative Effects

Alternative 1 - No Action

Alternative 1 (No Action) would result in the following effects:

• The current road management objectives to keep the existing key forest roads open in the project 

area would continue. The ability to effectively implement these road management objectives will 

be reduced due to no additional road maintenance or reconstruction from timber harvest. 
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• While currently suitable for noncommercial traffic, with no immediate threat of failure from noncommercial use, forest roads would continue to deteriorate because funding is lacking to properly 

maintain the roads.

• Road maintenance and repair would continue on a prioritization basis within existing budgets, 

addressing some of the more critical maintenance items.

• At some point, all or portions of forest roads would become unsuitable for administrative and 

public uses, resulting in reduced access, loss of capital investments, and adverse impacts to 

aquatic resources from road failures.

• Non-key roads would continue to grow closed and become less accessible for vehicle use, 

including high-clearance vehicles. 

• No roads would be decommissioned, increasing the potential for damage to resources and roads 

due to lack of maintenance.

• No culverts in stream channels would be replaced or upgraded. 

• Driving conditions would continue to decline, increasing safety hazards; drivers would not be 

able to clearly locate road turnouts or safe-stopping areas when dealing with oncoming traffic on 

single-lane roads. 

Alternative 2 and 3 

Given the beneficial effects from road maintenance and reconstruction, Alternatives 2 and 3 would result 

in a cumulative beneficial effect to user safety. All action alternatives would provide road maintenance or 

reconstruction on all haul routes. The incremental cumulative effect of all action alternatives would be to 

reduce the miles of roads available for motorized access and decrease the impacts to aquatic resources. 

There would be a reduction in motorized vehicle access, but minimal impact to recreational use. 

Following consideration of the incremental impacts of the project, when added to past, present, and 

reasonably foreseeable future actions in the planning area, it is determined that there are primarily minor 

beneficial and no meaningful adverse cumulative impacts to the transportation system associated with any 

of the action alternatives. The Forest Service does not anticipate any future timber sale or public works 

projects to be conducted within the Hwy 46 planning area that could result in adverse conditions to timber 

sale haul or other activities associated with this planning effort.

Road repair and maintenance as proposed under Alternatives 2 and 3 would result in the following effects:

• About 108.5 miles (Alt.2) and 98.7 miles (Alt. 3) of forest roads would be repaired and 

maintained to improve structural strength and road surfaces to a level that would support 

commercial timber haul, safely accommodate mixed commercial and noncommercial use, and 

meet the desired condition.

• Safer driving conditions would be achieved through roadside clearing, which improves sight 

distances on key roads associated with commercial haul, and through road repair. 

• Some of the safety concerns associated with mixed commercial and public traffic would be 

addressed by temporarily closing key roads to all public traffic or rerouting traffic to alternative 

routes such as proposed haul down FSR 2231 instead of out Hwy 46 to protect values of the 

Breitenbush community and other forest users in the Breitenbush watershed. Rerouting of logging 

traffic requires road realignments, see table 52 below.

• Replacement of live stream culverts and failing ditch relief culverts would protect resources and 

capital investment in the road. Live stream culverts identified for replacement or removal have 

been identified and documented in the plan. Placement of additional ditch relief culverts would be 

designed to disconnect ditch line water from live stream channels by diverting runoff onto 

vegetated natural ground. Run off would also be diverted away from fill slopes to improve fill 

stability and reduce risks of fill failure. This would benefit water quality and potential fish habitat 

for the duration of the improvement.
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Table 48 Road Realignments

Road 

Realignments Length Decommissioned Length Access to Units Notes 

2231850 0.1 - 180, 220, 250, 260, 290

New angled approach will be 

constructed at the intersection of road 

2231000 to align haul vehicles south on 

road 2231000 to facilitate haul to Hwy 

22. Clearing of less than 0.5 acres 

needed. Haul to Hwy 22 required to 

protect noise quality near Hwy 46 and 

Breitenbush community.

2231870 0.1 -

240, 260, 280, 290, 300, 

310, 320, 340, 350, 360, 

370, 380, 390, 400

New angled approach will be 

constructed at the intersection of road 

2231000 to align haul vehicles south on 

road 2231000 to facilitate haul to Hwy 

22. Clearing of less than 0.5 acres 

needed. Haul to Hwy 22 required to 

protect noise quality near Hwy 46 and 

Breitenbush community.

4600012 0.18 0.18 45, 47, 64

Reroute to the south near MP 0.5 to 

avoid steep grade. Clearing of less than 

0.5 acres needed.

4688000 0.22 - 97 Extend end of road to access landing.

4600059 0.31 0.30 - Short Lake Reroute. To be completed 

after sale.

Decommissioning non-key forest roads, as proposed under Alternatives 2 and 3 would result in the 

following effects:

• About 8.88 miles of existing non-key forest roads would be decommissioned. These roads are 

determined to be no longer needed for management activities, closed to all vehicle traffic, and 

taken off the Forest’s road inventory.

• Road treatments may include removing stream crossings, waterbarring road surfaces, removing 

unstable side-cast material, and closing entrances with barricades, such as earthen berms, 

boulders, or guardrails or some combination thereof. These actions would improve stability of the 

road prism.

• Decommissioned roads are barricaded and motorized vehicle traffic is prohibited. Stabilizing the 

road reduces the risk of road failure, reduces risks to water quality and allows the area once 

occupied by the road bed to return to a more natural state. 

Storing non-key forest roads, as proposed under Alternative 2 and 3, would result in the following effects:

• About 4.07 miles of non-key roads would be stored. Vehicle access would be precluded on stored 

roads, with access only allowed under emergency circumstances. Storing these roads would 

reduce the backlog of maintenance needs within the analysis area. Stored roads would be 

maintained during times when they are reopened to implement future projects. 

• Road storage could add to the cost of post-harvest stand treatments and monitoring, depending on 

the timing of storages. Where possible, road storage would be timed to minimize these effects. 

• Stored roads are water barred and if necessary have culverts removed. These activities stabilize 

the road prism until the road is needed. Prohibiting motorized vehicle traffic would contribute to 

protection of resources and preserving the road for future use. 

Public motorized vehicle access is reduced under Alternatives 2 and 3. Open roads drop from 

approximately 73% to approximately 70% of road miles in the project area. The 150 miles that would 
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remain open are primarily key roads in maintenance levels 2 and 3. Alternatives 2 and 3 both respond to 

the National roads policy identified in the introduction of this document directing forest to identify and 

implement a minimum road system. Alternatives 2 and 3 meet the proposed minimum road system in the 

Hwy 46 planning area. With the implementation of roads storage and decommissioning work, the open 

road density for the planning area will decrease to 2.25 miles per square mile based on the alternative 

selected.

Temporary Spur Roads

Alternative 2 and 3 require construction and reconstruction of temporary spur roads. Alternative 2 would 

have approximately 9.3 miles and Alternative 3 would have approximately 6.3 miles of temporary roads

built within the project area. 

Under Alternatives 2 and 3, the following effects are expected from building temporary roads:

• Temporary roads would generally be limited to commercial use; these roads may provide 

opportunities for limited, short-term public use, such as firewood gathering and special forest 

products.

• Temporary road locations typically do not connect with streams, minimizing effects to hydrology. 

These criteria serve to minimize the disturbance of riparian areas. Stream crossings would be 

avoided where possible during the construction of all temporary roads.

3.9 Heritage

3.9.1 Scale of Analysis

The geographic scale used to assess direct, indirect and cumulative effects for Heritage Resources 

includes the units proposed for treatment, road construction, landings, meadow restoration and hazardous 

fuel activities within the Hwy 46 Project. All of these ground disturbing activities have the potential to 

affect the integrity of cultural resources. An archaeological survey of the Hwy 46 project was conducted 

in order to comply with Section 106 of the National Historic Preservation Act (NHPA) and other relevant 

laws and regulations. A systematic surface pedestrian search is the principal manner for implementing the 

mandated goals.

3.9.2 Assessment Methodology

The field survey of the Hwy 46 Project was performed by five crew members, utilized on different days, 

during the summers of 2013, 2014 and 2015. Pedestrian transects spaced at 15 to 20 meter intervals 

followed a specific orientation based on factors that included the shapes of units and landforms and the 

possible presence material remains and features left behind by Indian or Euro-Americans. These material 

remains and features are called cultural sites. The objective of the Hwy 46 cultural resource survey was to 

identify all cultural sites within the project’s area of potential effect (APE) with the goal of protecting 

them from ground disturbing activities. One-by-one meter shovel scrapes made with entrenching tools 

exposed mineral soil every 20 to 30 meters in areas where dense vegetation limited ground visibility. 

Bearing orientations were followed to the best of abilities, but adjustments in orientation, spacing 

intervals, and shovel scrape spacing were made in order to avoid dangerous or unreasonable conditions 

(e.g., exceptionally steep slopes or impenetrable vegetation).

Under the Hwy 46 Project a total of 1653 acres were surveyed consisting of 935 high probability acres 

and 618 low probability acres. Fourteen previously known cultural sites and isolated finds were 

monitored during completion of the Hwy 46 Project surveys and three new cultural sites and six isolated 

finds were identified and recorded during fieldwork. A total of sixteen recorded cultural sites within the 
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Hwy 46 Project area considered potentially eligible to the National Register of Historic Places (NRHP) 

and must be protected from project activities or evaluated to determine eligibility to the NRHP. No other 

known cultural sites would be affected by the proposed project actions. 

3.9.3 Affected Environment

The prehistory and history of the Breitenbush drainage have previously been summarized in Prehistoric 

Land-Use Patterns In the North Santiam Sub-basin on the Western Slopes of the Oregon Cascade Range 

(Kelly 2001), the Cultural Resource Overview for the Willamette National Forest, Western Oregon 

(Minor and Pecor 1977) the ten-year update of the above overview (Minor 1987), Archaeology of Oregon 

(2nd Edition) (Aikens 1986), the Breitenbush Watershed Analysis (and numerous other publications). 

These documents provide some detail of ethnographic and historic background for this report.

Cultural History

Ethnographic research indicates that highly mobile prehistoric and early historic Indian groups, probably 

the Molala, Kalapuya, and their ancestors used the western Cascade Mountains for the main purposes of 

seasonal hunting, fishing, and plant gathering. Ethnographic evidence also suggests that the Molala 

Indians were indigenous to the area and lived during the winter along low elevation streams, accessing the 

uplands during the summer and fall to hunt game and gather berries and other important plant resources. 

The Molala are linguistically related to Willamette Valley groups, but are thought to be composed of 

montane-based bands who were living in the western Oregon Cascades during the historic period. 

Most of what is known of the Molala comes from two of the three subgroups into which they are 

generally split: the Northern Molala located in the vicinity of Mount Hood’s drainage systems and the 

Southern Molala located west of the Klamath Lake area. Little is known of the third group, referred to as 

the Upper Santiam/Santiam band of Molala, who are thought to have inhabited Linn and Lane counties in 

the areas between the northern and southern groups. The Molala are also often culturally grouped with the 

Kalapuya who were based in the Willamette Valley, but probably made seasonal forays to the Cascades 

for large game and berries. 

Unfortunately, Indian contact with trappers, missionaries, military expeditions and settlers also brought 

them into contact with European diseases such as smallpox and influenza, which decimated their 

populations. By the mid -1800s many of the remaining Molala and Kalapuya were removed to the Grand 

Ronde Reservation in western Oregon after the signing of the Dayton and Molala Treaties of 1855. Other 

Molala shifted to the Siletz Reservation along the Oregon coast, the Klamath Reservation to the south and 

to the Warm Springs Reservation in eastern Oregon where they were absorbed into the Confederated 

Tribes of Warm Springs. Today, the Willamette National Forest works closely with our Tribal Partners 

insuring the protection of cultural resources. 

Pre-contact Indian use in the area is reflected in the cultural material they left behind including but not 

limited to chipped obsidian lithic scatters and obsidian lithic isolates, representing tool use, modification, 

or manufacture related to hunting and gathering. These sites are protected through avoidance from project 

activities. 

Historic era

Breitenbush Hot Springs

In the late 1840s, John Breitenbush, a local trapper, was the first white person to visit the Breitenbush hot 

springs via a trail from Detroit. He supposedly acquired knowledge of the springs through his association 

with the Native American Indians. In the ensuing years, trappers and hunters frequented the area during 

trips into the Breitenbush drainage. In circa 1873, John Minto and Henry States lead an expedition up the 
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North Fork of the Santiam River attempting to find an easy route over the Cascades. On this trip they met 

up with John Breitenbush at the main tributary to the North Santiam and later named this tributary after 

him. 

In 1874, another trail into the Breitenbush Hot Springs was constructed from Idanha following Native 

American routes. In 1897, John Hollingsworth started operating pack trains carrying visitors and their 

overnight bags into the springs. Access to the remote area was by trail until wagon road was constructed 

in the late 1920s. Bringing people into the newly established resort was the intent for constructing the 

wagon road. 

In 1911 Mark S. Skiff, from Salem, Oregon applied for a special use permit with the Forest Service to 

occupy about three acres of land to construct a hotel, sanitarium, and several other buildings along with 

water rights to three mineral springs along the Breitenbush River. In 1913, a final permit was issued 

granting him rights to construct the above buildings for his proposed summer resort business. Skiff was 

the first person to develop the Lower Breitenbush Hot Springs Resort located on land administered by the 

Forest Service. In 1921, it cost 5 dollars per week to stay in a cabin and 3 dollars per week to stay in a 

tent. These at best were temporary accommodations. Then in 1923, the hot springs resort was officially 

established. Over the next several decades’ accommodations improved. Thirty five cabins, a store, 

outhouses, a foot bridge spanning the Breitenbush River, a hot springs containment and hydroelectric 

development with associated dam, sluice and powerhouse provide the major modifications needed for 

resort operations. Then in 1979, the Forest Service closed the resort for unacceptable human waste 

disposal systems, an unsafe foot bridge across the Breitenbush River leading to the bath house, and 

general deteriorated condition so the bathhouse and pools, store and several of the cabins.

In 1980 the Forest Service issued a new special use permit to an individual who had plans to reconstruct 

and operate a new resort. Over the next 15 years, this new permit holder made little to no progress with 

the exception of demolition of most of the structures (some went to the Private Breitenbush Hot Springs 

owners). By the mid-1990s the Forest Service did not renew the permit due to a lack of development 

required under the special use permit.

Summer Recreation Residence Tracts

The Breitenbush and Devils Creek Recreation Residence tracts are located within the project area. The 

Devils creek tract was platted in 1929 and the summer homes constructed between 1945 and 2007 (Carter 

2007). The Breitenbush tract was originally platted in 1929 and 1933 but construction of the privately 

owned buildings did not start until the 1950s. Most of these summer homes were constructed in the 1950s 

and 1970s (Carter 2007).

The recreation residence tract development was in response to the broader Forest Service plan to bring the

public to the forest and provide them with recreational opportunities (Carter 2007). The residences were 

located and platted by the Forest Service and the individuals lots were then leased to private citizens who 

constructed a cabin at their own expense. The layout of each tract and the size and design of the cabin 

followed guidelines set forth within the Region 6 Forest Handbooks.

Both of these tracts and their individual building were evaluated to determine National Register of 

Historic Places significance. The Breitenbush Summer homes and the Devil Creek tracts were both found 

not eligible for listing on the National Register because too many of the structures had not yet reached the 

age threshold for eligibility.

Early 1900s Railroad Logging

Railroad logging on the Detroit Ranger District began prior to the creation of the national forest. 

Hammond Lumber Company, under the use of the Homestead and the Timber and Stone Acts (Rakestraw 
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1991) acquired a sizeable holding both within the Santiam National Forest and just outside its boundary. 

The period between 1894 and 1907 Hammond Lumber Company bought the Oregon Pacific Railroad 

(aka, Southern Pacific Railroad). In 1910 the regional office sent William B. Osborne Jr. to the Detroit 

area to conduct a reconnaissance. Osborne found 20 townships that held large timber values in old growth 

forests that were deteriorating (Rakestraw 1991). The Breitenbush River offered a good route to access 

the timber. To extract the logs, Hammond constructed many miles of grade and track up the Breitenbush 

River branching off the main line at the Santiam River. Many arterial branches of the railroad were 

constructed up French, Canyon and the Humbug Creek drainages. Many of the routes have been formally 

recorded in the field. The railroad grades reflect the single use of retrieving the wood and abandoning the 

grades. The technology employed during this time included ground based logging which utilized a steam 

donkey placed adjacent to the railroad tracks with winch lines 300-500 feet long. The logs would have 

been dragged on the ground to the tracks and loaded on the train. Several logging camps were located 

along the railroad line and included Camp 9, Camp 11, Camp 15 (within Idanha), Camp 5, Camp 7 and 

Camp 17 (present day Detroit) during the Hammond Lumber logging days. All of which have disappeared 

either under the reservoir or town development (Detroit). 

Approximately, 23,000 acres were logged off and burned along the North Santiam River and its tributaries 

within and outside of National Forest Land (T10S, T9S, and R. 3E, 4E, 5E and 6E). Hammond Lumber 

Company owned 20,500 of this acreage. About 680 of these acres were logged by Hammond under a 

Timber Sale contract on National Forest land and the rest logged on other private inholdings. This logging 

took place from Mill City up to Idanha. About 1⁄4 of the acreage was subsequently grass seed over an 

eighteen year period with the sole purpose of selling the land for grazing and farming along the North 

Santiam River. Hammond Lumber Company was not favorable towards reforestation. They felt that their 

lands were more valuable to them post-harvest as grazing lands. It was also their opinion that 

reforestation was the responsibility of the Federal or State government on their lands not on private lands. 

In 1922, contact between the Forest Service (Forest Supervisor C.C. Hall and Assistant Forester C.J. 

Buck) and Hammond Lumber Company began communications regarding the exchange of Hammond 

Lumber Company lands under the provisions of the March 20, 1922 Act 42 Stat. 465). Hammond Lumber 

Company was offering up lands within Township 10 South, Ranger 5 East Sections 1, 2, 3, 7-16, 18 and 

22) and Township 10 South, Range 6 East Section 18, 21, and 22. After several years of communication 

via letters, the Secretary of Agriculture approved the Hammond lumber company exchange through a 

night wire telegram dated February 21, 1930. In exchange for Hammond lands, the right to cut and 

remove an equal value of timber from about 62 acres within T.9S, R5E, and Section 21 was requested. A 

letter dated April 6, 1931 from the Assistant Regional Forester Horton states that the Department of 

Interior notified the Secretary of Agriculture that the “exchange application of the Hammond lumber Co. 

was approved and that title to the offered land as accepted by the government.” Hammond had also 

fulfilled his requirement to remove the timber that was granted under this exchange. In 1934, Mr. Olin, 

the General Manager of the Hammond Lumber Company, expressed interest in a second land exchange 

for lands in the French Creek area during a meeting with the local district ranger, Ranger Elliot. The 

ranger documented this request in a letter dated January 24, 1943 to the Forest Supervisor, P. A. 

Thompson. The Hammond Lumber Company was offering 800 acres of lands within Township 9 South, 

Range 5 East, Sections 21, 25, 26, 27, and 28, in exchange for timber on unsurveyed lands from Township 

20 South, Range 4 East, Sections 6 and 7. The official application for the land exchanged was filed on 

December 10, 1934, as application 021720. Fred W. Johnson, Commissioner, sent a letter to the register in 

Roseburg, Oregon dated September 10, 1934 that outlined the completion of the second land exchange of 

the Hammond Lumber Company.

Administrative Use
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Historic administrative use of the project area appears mainly in the form of trails which functioned as 

part of the communication network in the early days of the Forest Service. In the 1930s, with the 

inception of the CCC program, the trail system expanded across the district linking newly constructed 

guard stations and lookouts and expanding communications with the installation of miles of telephone 

line. Eventually some of the trails were replaced with roads and some of the trails fell off the system 

because they were no longer needed for administrative use. A few of these early trails include: Roaring 

Creek, South Breitenbush, Rapidan, and Mansfield Trail.

Timber harvest in the Hwy 46 project area began in the early 1900s. From 1817 to 1959 timber harvest 

and fires in the project area accounted for close to 800 acres of stand replacing disturbance. For Hwy 46 

many of the stands were originally clear-cut harvested in the 1960s through the early 1980s but continued 

into the 1990s. For most of these units, the original timber harvest occurred prior to the President signing 

Executive Order 11593 and implementation of Section 106 of the National Historic Preservation Act 

(NHPA) of 1966 (amended in 1976, 1980, and 1992). During this period prior to the mid to late 1970s, the 

Forest Service was not required to hire professional archaeologist to conduct cultural resource surveys. 

Thus few sites were known on the forest.

3.7.4 Environmental Consequences

Direct and Indirect Effects

Alternative 1 – No Action

Implementation of the no action alternative would not directly nor indirectly affect cultural resources 

since there would be no change to the integrity of cultural resource sites. However, the no action would 

protect any undiscovered cultural sites that were not found during the survey for Hwy 46. 

Alternative 2

Timber harvest, new and temporary road construction, ground base and skyline yarding and post-harvest 

fuel treatment contribute to ground disturbance. Ground disturbance can affect the surface and subsurface 

integrity of an archaeological site and thus its significance to the National Register of Historic Places. 

Since appropriate and approved surveys have been conducted and cultural site protection measures are 

already in place (see Design Elements Chapter 2 Table 13), the potential direct effects to all other 

potentially eligible sites would be in the form of inadvertent damage to the integrity of the cultural 

resources which were not discovered during initial survey. Any sites uncovered during implementation of 

the project would require all earth-disturbing activities in the vicinity of the find to be suspended, in 

accordance with federal regulations, and the zone archaeologist notified to evaluate the discovery and 

recommend subsequent courses of action. Therefore, contract clause BT6.24 (or its equivalent) must be 

included in all project prospecti and contracts. The contract clause outlines the procedures to follow in the 

event cultural resources are discovered during timber sale operations.
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Alternative 3

Implementation of Alternative 3 would result in ground disturbance on 33 less miles of road maintenance 

on haul routes, 2.2 miles less of new temporary new road construction; and 793 less acres of timber 

harvest. Post-harvest activities include 525 less acres of underburning slash and associated fire line 

construction.

Based on these numbers, Alternative 3 would result in less ground disturbance from harvest thinning

activities, thus less potential for inadvertent damage to the integrity of cultural resources which were not 

discovered during initial survey. Since appropriate and approved surveys and cultural site protection 

measures are already in place (see Design Elements Chapter 2), the potential direct effects to all other 

potentially eligible sites would be in the form of inadvertent damage to the integrity of the cultural 

resources which were not discovered during initial survey. Any sites uncovered during implementation of 

the project would require all earth-disturbing activities in the vicinity of the find to be suspended, in 

accordance with federal regulations, and the zone archaeologist notified to evaluate the discovery and 

recommend subsequent courses of action. Therefore, contract clause BT6.24 must be included in all 

project prospecti and contracts. The contract clause outlines the procedures to follow in the event cultural 

resources are discovered during timber sale operations. 

Therefore, no adverse effects are anticipated from either Alternative 2 or 3 due to the avoidance of known 

cultural resources and the application of timber sale contract clause BT6.24. 

Cumulative Effects

Alternative 1 

Based on a review of the past, present and foreseeable projects listed in Appendix C, none overlap in time 

and space that would cause cumulative effects to the known cultural sites from any of the proposed 

actions under the Hwy 46 Project. Appropriate and approved surveys and cultural site protection measures 

are already in place for this project (see Design Elements Chapter 2, avoidance clause). 

Alternative 2 and 3

Based on a review of the past, present and foreseeable projects listed in Appendix C, none overlap in time 

and space that would cause cumulative effects to the known cultural sites from any of the proposed 

actions under the Hwy 46 Project. Appropriate and approved surveys and cultural site protection 

measures are already in place for this project (see Design Elements Chapter 2, avoidance clause). 

3.10 Scenic Quality

3.10.1 Summary of Effects Analysis

Alternative 1 would have no adverse effects on scenic quality because no harvest treatments would occur 

under this alternative. This alternative would also fail to reap positive effects to scenery that would occur 

as a direct result or benefit of the proposed actions.

Alternatives 2 and 3 would not have negative long term effects to scenic quality. Views from Gold Butte, 

Fox Creek group campground, various points within the Breitenbush viewshed corridor, and along 

Highway 46 would be slightly altered, but changes would be difficult to discern from naturally occurring 

variation in the landscape. The proposed actions would provide benefits to visuals along the powerline 

corridor and would enhance the view of Mt. Jefferson from the West Cascades National Scenic Byway. 
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The proposed actions would not have any long term adverse effects to visually sensitive management 

areas, and proposed treatments would be consistent with standards and guidelines set by the Forest Plan.

3.10.2 Scale of Analysis

The geographic scale used to assess direct, indirect, and cumulative effects for scenic quality are the areas 

encompassed by the Breitenbush viewshed as well as recreation features, travelways, and other areas with 

scenic designations found in the project area.

3.10.3 Affected Environment

Valued Landscape Character

The Hwy 46 project area encompasses the Breitenbush viewshed corridor. This viewshed is an important 

scenic asset as it surrounds the Breitenbush Hot Springs Retreat and Conference Center and includes 

travel corridors that are considered sensitive to scenic quality. The stretch of Highway 46 that falls within 

the project area has two scenic designations: the West Cascades National Scenic Byway and the

Cascading Rivers State Scenic Bikeway. Sections of the South Breitenbush Gorge (designated National 

Recreation Trail), South Breitenbush, Triangulation, Mansfield, and Crag trails as well as developed and 

undeveloped recreation sites fall within the project boundary. Segments of the Breitenbush River and 

South Fork Breitenbush River, which are eligible for Wild & Scenic River designation, are within the 

project area and the Mt. Jefferson Wilderness borders the project area on the east. 

Douglas-fir and western hemlock dominate the overstory cover of the project area, which is quite densely 

vegetated in many parts. Rolling hills as well as fairly steep topography adds variation to the landscape 

and provides potential for scenic views. The project area is highly valued for its scenery by recreation 

visitors, through-drivers, and Breitenbush guests and community members. 

Visual Management System

The Visual Management System (VMS) is the primary means for planning and managing the Willamette 

National Forest’s scenic resources. The VMS was used to inventory and categorize landscape zones of 

relative scenic importance in the Forest Plan. The zones are based on attractiveness, proximity to 

travelways and use areas, and the concern Forest users have for scenic quality. These zones are assigned 

one of five Visual Quality Objectives (VQOs) that represent relative degrees of acceptable alterations of 

the natural landscape (USDA Forest Service 1977). The VMS methodology was created during an era and 

with the assumption that silvicultural treatments would be primarily regeneration harvest (clear-cuts). 

This inherent assumption in the methodology adds complexity to using the system when interpreting and 

evaluating modern commercial thinning treatments.

The VQOs for the Hwy 46 project area include preservation, retention, partial retention, modification, and 

maximum modification (USDA Forest Service 1990). These VQOs are illustrated in Figures 43 and 44

and described in detail in Table 55.
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Figure 43 Hwy 46 Visual Quality Objectives for Alternative 2
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Figure 44 Hwy 46 Visual Quality Objectives for Alternative 3
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Scenery Management System

The Scenery Management System (SMS) is an updated methodology (1996) used by the Forest Service to 

provide a visual impact assessment of effects to the scenic resources. This method aims to integrate social 

impacts to recreation visitors with physical impacts to the visitor experience. SMS objectives are 

described in terms of Scenic Integrity Levels, which describe existing conditions and the degree to which 

the landscape is perceived as visually intact or complete (USDA Forest Service 1996). 

While the current Forest Plan is tiered to the VMS method, the SMS has also been used in this analysis to 

facilitate the change in methodology. Table 53 describes the five VMS/SMS categories, associated 

SMS/Scenic Integrity Level categories, and the proposed treatment acres in each category for alternatives 

2 and 3.

Table 49 VMS/SMS Objectives and Proposed Treatments

Visual Quality Objective 

(VQO)

(VMS)

Scenic Integrity Level

(SMS)

Proposed Treatment Acres 

in Alternative 2

Proposed Treatment Acres 

in Alternative 3

Preservation:

Provides for ecological 

change only

Very High:

Landscape character is intact with only 

minute if any deviations. The existing 

landscape character and sense of place is 

expressed at the highest possible level

Retention:

In general, human activities 

are not evident to the casual 

forest visitor

High:

Landscape character appears intact. 

Deviations may be present but must repeat 

the form, line, color, texture, and pattern 

common to the landscape character so 

completely that and at such a scale that they 

are not evident

Fuels Reduction (98 acres), 

Visual Enhancement (1/3 

acre), Commercial Thinning 

(321 acres)

Fuels Reduction (98 acres), 

Visual Enhancement (1/3 

acre), Commercial Thinning 

(223 acres)

Partial Retention:

In general, human activities 

may be evident but must 

remain subordinate to the 

characteristic landscape

Moderate:

Landscape character appears slightly altered. 

Noticeable deviations must remain visually 

subordinate to the landscape character being 

viewed

Early Seral (14 acres), Fuels

Reduction (101 acres), Visual 

Enhancement (1 acre), 

Understory Habitat 

Enhancement (< 1 acre), 

Commercial Thinning (479 

acres)

Early Seral (14 acres), Fuels

Reduction (101 acres), 

Visual Enhancement (< 1 

acre), Commercial Thinning 

(391 acres)

Modification:

Human activities may 

dominate the characteristic 

landscape but must, at the 

same time, utilize naturally 

established form, line, color, 

and texture, and appear as 

Low:

Landscape character appears moderately 

altered. Deviations begin to dominate the 

valued landscape character being viewed but 

they borrow valued attributes such as size, 

shape, edge effect and pattern of natural 

openings, vegetative type changes or 

Early Seral (25 acres), 

Understory Habitat 

Enhancement (3 acres), 

Commercial Thinning (1,153 

acres)

Early Seral (5 acres), 

Commercial Thinning (731 

acres)
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Visual Quality Objective 

(VQO)

(VMS)

Scenic Integrity Level

(SMS)

Proposed Treatment Acres 

in Alternative 2

Proposed Treatment Acres 

in Alternative 3

natural occurrence when 

viewed in foreground or 

middle-ground distances

architectural styles outside the landscape 

being viewed. They should not only appear 

as valued character outside the landscape 

being viewed but compatible or 

complimentary to the character within.

Maximum Modification:

Human activity may 

dominate the characteristic 

landscape but should appear 

as a natural occurrence 

when viewed as 

background.

Very Low:

Landscape character appears heavily altered. 

Deviations may strongly dominate the valued 

landscape character.

Early Seral (15 acres), Fuels

Reduction (24 acres), 

Understory Habitat 

Enhancement (106 acres), 

Meadow Restoration (15 

acres), Commercial Thinning 

(1,658 acres)

Fuels Reduction (24 acres), 

Meadow Restoration (4 

acres), Commercial 

Thinning (1,281 acres)

3.10.4 Environmental Consequences

Direct and Indirect Effects

Alternative 1 - No Action

Alternative 1 would have no direct or indirect effects on scenic quality in the project area, and all VQOs 

would remain consistent with Forest Plan direction. Scenic quality in the project area would be unaffected 

by management activities because no treatments are proposed under this alternative. Natural processes 

would continue unimpeded by management actions, and benefits to scenery prescribed by visual 

enhancement gaps, vista openings, and improved views into the forest would not be realized. 

Alternatives 2 and 3

Proposed treatments in alternatives 2 and 3 fall well within allowable scenic quality ranges set by the 

Forest Plan. Additional assessments of valued viewpoints within and around the project area show that 

impacts to scenery would be minimal and short-term, or unapparent to the casual forest visitor (due to 

visitors driving 35-45 miles per hour or because trails in the project area offer few viewpoints facing the 

proposed harvest units). Visual enhancement gaps and thinning along transportation corridors would 

provide benefits to the scenery around the project area by opening views into the forest, providing 

variation, and softening the appearance of harsh cut lines along the powerline corridor.

Scenic Viewsheds

When considering the visual impact of vegetation management activities within the Breitenbush viewshed 

corridor, it is important to consider the distance at which different parts of the landscape are viewed. The 

Forest Plan outlines management areas that are specific to viewshed corridors and divides them by 

distance zones from which the areas would be viewed. Table 54 illustrates the allowable areas of 

disturbance and minimum height for stand recovery within the scenic management areas. At the time the 

Forest Plan was written, “disturbances” were considered large scale or cumulative vegetative disturbances 
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such as regeneration harvest, fire, or road construction over the landscape. Management activities such as 

commercial thinning, understory habitat enhancement, fuels reduction, and riparian treatments in 

alternatives 2 and 3 would not be considered “disturbances.” Early seral treatments and sugar pine

restoration (shelterwoods) are considered “disturbances” for the purpose of visual assessment.

Table 50 Viewshed Thresholds

Management Area Total Allowable 

Disturbed Area (%)

Alt. 2 Disturbed Area 

(%)

Alt. 3 Disturbed Area 

(%)

Recovered Stand Height 

(ft.)

11a- Scenic, Modification, 

Middleground

24 <1 <1 4.5

11c- Scenic, Partial 

Retention, Middleground

20 <1 <1 15-20

11f- Scenic, Retention, 

Foreground

10 <1 <1 15-20

Early seral creation is proposed for 24 acres in alternative 2 and 5 acres in alternative 3 that fall within the 

5,353 acres of the Scenic-Modification Middleground (11a) management area. Sugar pine restoration is 

proposed for 34 acres in alternative 2 and 2 acres in alterative 3 within the 11a management area. Both 

alternatives are well below the percentage threshold of allowable disturbed area set for Modification 

Middleground.

The Scenic-Partial Retention Middleground (11c) management area makes up 2,385 acres of the project 

area. This management area contains 14 acres of proposed early seral treatment in both alternatives 2 and 

3 and 5 acres of proposed sugar pine restoration in alternative 2. The combined treatment acreages are 

below the threshold set for disturbance in this management area.

The Scenic-Retention Foreground (11f) management area makes up 1,259 acres of the project area. Sugar 

pine restoration is proposed for 3 acres that fall within this management area in alternatives 2 and 3. 

Again, this acreage is well below the allowable disturbed area threshold. 

Scenic-Retention Foreground is found primarily around main travelways and the Breitenbush community 

in the project area. The Forest Plan indicates that for treatments within this management area stumps 

should be cut to four inches on the high side, cut trees or leave trees should be marked on the side away 

from road only, and slash piles should be chunked. In order to maintain the economic viability of the 

proposed vegetation management and reflect the modern management techniques proposed, this design 

feature will be used for a 100 ft. buffer on either side of the roadway for units in this management area. 

It is possible, but unlikely, that visitors may see cut sides of stumps past the 100 ft. buffer along main 

travelways with sloped sides in the project area. Visual impacts would be further reduced by limited 

viewing duration given the speed of travel.

Wild and Scenic River Eligibility

In order to maintain eligibility for Wild and Scenic River designation for the Breitenbush and South Fork 

Breitenbush rivers, a 1⁄4 mile buffer each side of the rivers are treated under guidelines set for a VQO of 

Retention. See the Scenic Quality section of Table 13 Design Elements in Chapter 2 for further 

information.
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Valued Scenic Viewpoints

Although the vegetative treatments described under alternatives 2 and 3 meet scenic quality standards 

specified in the Forest Plan, it is prudent to also consider whether the treatments would be readily seen 

from valued viewpoints around the Breitenbush community, Forest Road 46, or from vistas accessible by 

trails. Valued and visually sensitive viewpoints were identified using knowledge of the project landscape, 

input from the local community, and visualization assessment using ArcGIS and GoogleEarth.

The valued and visually sensitive viewpoints within the planning area and surrounding vicinity were 

identified as points along the South Breitenbush, South Breitenbush Gorge, Crag, McCoy-6 Boulder 

Ridge Route (in the McCoy Motorized Recreation Area), and Mansfield trails, roadside views along 

Highway 46, views from the Breitenbush community and the Fox Creek group campground, and vistas 

from Mt. Jefferson, Minto Mountain, Triangulation Peak, Gold Butte, and Hall Ridge. 

Commercial thinning treatments in alternatives 2 and 3 are proposed in Scenic-Retention Foreground 

areas along Highway 46, parts of South Breitenbush Gorge and Crag trails, and the South Breitenbush 

trailhead. The prescribed treatments and residual trees per acre planned are designed such that the 

management activities would not be visually evident to the casual forest visitor. Form, line, color, and 

texture would remain consistent with that of the characteristic landscape. Views from Forest Service 

system trails and the Fox Creek group campground near proposed commercial thinning would be further 

protected by a 50 ft. no-harvest buffer (see Scenic Quality section of the Design Elements Table 13 for 

more detail). The speed at which visitors would be viewing the landscape from Highway 46 (35-45 mph) 

would further reduce the perceptibility of proposed treatments. Thinning that is noticeable would likely 

have a beneficial effect of opening views into the forest for visitors and through-drivers and providing a 

richer mosaic of tree and vegetation diversity. Figure 46, at Fox Creek Group Site, shows a simulation of 

what an opened canopy from thinning would achieve on the ground. The level of thinning in the image 

was commensurate to the average level of harvest in a thinned unit, resulting in less canopy cover and 

more sunlight reaching the ground.

Figure 45 Fox Creek Group Site. Current conditions,
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Figure 46 Fox Creek Group Site. Photoshop simulation of thinning.

Views from the Breitenbush community would be protected by vegetation within and immediately 

surrounding the property in addition to the undulated topography of the area. A site visit showed that 

middleground vegetation located on the Breitenbush property would provide a thick screen in front of any 

management activities that are proposed in the project. None of the background landscapes that are visible 

from the site (i.e. Devils Ridge) would be affected by proposed project activities. Fuels treatments taking 

place adjacent to the Breitenbush community and summer homes would be conducted in a way to 

preserve existing site aesthetics and minimize adverse impacts to scenery (for further details, see the 

Scenic Quality section of Table 13: Design Elements).

Figure 47 Breitenbush View of Devils Ridge from Footbridge, left. View from Breitenbush Middle Pool, right.

Meadow restoration is proposed along segments of the Mansfield trail in alternative 2 and wildlife gaps in 

the McCoy 6- Boulder Ridge Route (used by snowmobiles and OHVs) in alternatives 2 and 3. Although 

treatments would be enhancing existing natural features and would be repeating form, line, color, and 

texture of the characteristic landscape, the intentions may not be evident to forest visitors. Restored 

meadows would provide trail users with variation in scenery and valuable views of alternative landscapes 
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from dense forest. Temporary educational signage would be placed along the more visually sensitive 

Mansfield trail during and immediately after project implementation. This signage would further connect 

the public to management activities on Forest Service land and provide an educational opportunity.

Understory habitat enhancement in unit 560 would encompass a segment of the Triangulation trail and the 

McCoy 3-Outerson Route. This treatment would thin smaller trees (less than 7” in diameter) to allow 

ground vegetation to thrive. Views from the trail segment and snowmobile/OHV route would not be 

altered from the original landscape character, and would provide a visual benefit of adding variation.

Impacts to scenery viewed from the Mt. Jefferson wilderness would be minimal. Views of the proposed 

treatments would not be visible from the majority of the wilderness due to dense vegetation and 

undulating topography. The vistas atop Mt. Jefferson and Minto Mountain would be too far from the 

project area for forest visitors to easily discern any of the treatment areas from the surrounding landscape. 

Views from Triangulation Peak may have some alterations to the texture of the landscape, but changes 

would be difficult to recognize from naturally occurring variation and variation resulting from past timber 

harvests. Proposed treatments would also be unlikely to be noticed by casual forest visitors atop Hall 

Ridge. Any treatments visible would conform to the landscape’s existing character and would be 

challenging to detect.
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Figure 48 View from Gold Butte Lookout 9-27-16

Proposed activities would have a minimal effect on views from Gold Butte. Any changes in scenery would borrow from existing variation in the 

landscape and would likely go unnoticed by the casual forest visitor. The following Photoshop simulation of proposed activities in alternative 2 

show that, although detectable, thinning and sugar pine restoration treatments would be difficult to identify from the surrounding variation in the 

landscape. Treatments proposed in alternative 3 would have a similar, minimal effect on views from Gold Butte.
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Figure 49 GoogleEarth view from Gold Butte facing SE towards project area

Figure 50 Photoshop simulation of proposed treatments in Alternative 2 from Gold Butte
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Scenery Enhancement

In addition to the visual benefits of varying the landscape through thinning along Highway 46, 

alternatives 2 and 3 would include visual enhancement treatments in units 28, 30, and 69. Gaps 1⁄2 acre in 

size are proposed in alternative 2 along the powerline corridor in units 28 and 30, which is visible from 

Highway 46. These gaps would soften the existing straight line along the corridor and help to create a 

more natural appearing landscape. The proposed treatment in unit 30 would remain the same for 

alternative 3, but the gap in unit 28 would be limited to a band of younger timber along the powerline 

corridor. Although this smaller gap would still aid in softening the edge, it would have a less impactful 

positive effect for visuals.

An accentuated view of Mt. Jefferson from the summit pull-out would result from the 1/3 acre gap 

proposed below Highway 46 in unit 69 in alternatives 2 and 3. This treatment would enhance the scenic 

value of this section of the West Cascades National Scenic Byway and would provide an additional scenic 

vista in the project area.

Figure 52 Conditions of Powerline Corridor Figure 51 Photoshop simulation of 1/2 acre 

gaps and thinning in units 28 and 30 in 

Alternative 2
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Cumulative Effects 

Alternative 2 and 3

Past and present natural and human caused disturbances or modifications (including fire, disease, timber 

harvest, fire suppression, prescribed fire treatments, power line corridors, private resort development, and 

road development) are visible within and adjacent to the project area. 

Since 1997, approximately 20 acres of the project area has been harvested. This acreage amounts to less 

than 0.1% of the project area, and vegetation has regrown in the majority of these areas.

During the summer of 2017 three large fires burned within the project area effecting 2,921 acres within 

the project area. Most of the higher intensity burns within the project area occurred away from open 

system roads and therefore will have minimal effects on the scenic attributes of the area. From the 

perspective of high, open viewpoints, the effects of the fire may change the overall appearance of the 

project area, but those effects will reflect a natural process at work within the project landscape.

These fires were typical of the western cascades mixed severity fire regime and had a range of effects on 

the landscape, including immediate tree and vegetation mortality, and increased tree mortality due to 

stress from the fire – both of these fire effects will have some direct impact on scenic quality. 

Figure 53: Unit 69 visual enhancement treatment
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Therefore, no long-term, adverse incremental cumulative effects to scenic quality are anticipated from the 

activities identified in this project. 

3.11 Recreation

3.11.1 Summary of Effects Analysis

Alternative 1 would have no direct, indirect or cumulative effects on recreation. Alternative 2 and 3 would 

have temporary adverse effects due to trail closures, increased noise and dust and log truck traffic during 

harvest activity. Benefits of timber harvest activity would include improved access to dispersed recreation 

areas due to road maintenance, improved scenery from secondary forest roads and an enlarged and 

improved trailhead parking area at the South Breitenbush Trail.

3.11.2 Scale of Analysis

The geographic scale used to assess direct, indirect and cumulative effects to recreation is the Hwy 46

project planning area which includes the project activity units and those portions of the Breitenbush 

watershed.

3.11.3 Affected Environment

The project area is popular for both developed and dispersed recreation activities including: camping, 

hiking, hunting, fishing, bicycling, boating, picnicking, target shooting, berry picking, viewing scenery, 

and driving for pleasure. Portions of the West Cascades National Scenic Byway and Cascading Rivers 

Scenic Bikeway are within the project area. The forested slopes along the Breitenbush River form an 

important scenic backdrop for the byway and river corridor. 

Visitor use in the project area is largely driven by river-dependent recreation activities. Private nonmotorized boating opportunities (i.e., kayaks, and rafts) are popular year round. Several developed 

recreation sites provide river access and/or day use facilities like picnic tables, restrooms and garbage 

service. Seasonal fishing (from the bank and/or boat) is popular with local residents and visitors. Several 

campgrounds along Forest Road 46 provide access opportunities to explore the area, enjoy a picnic or go 

for a short hike on a developed trail. There are four special use permits for utilities within the project area 

as well as 71 recreation residences (summer homes).

Forest Road 46 is part of the West Cascades National Scenic Byway as well as the Cascading Rivers 

Scenic Bikeway. Forest Road 46 is a popular route for scenic driving and road cycling. It is not 

uncommon to find the roads busy with individual or group road cyclists during the summer months. 

Those same cyclists also share the road with those choosing to enjoy the scenery from the comfort of their 

car. 

Overnight camping occurs in many places and in many forms in the project area including at unmanaged 

dispersed campsites and at developed campgrounds or resort style private accommodations.
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Figure 54 Recreation Uses in Hwy 46 Project area
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Recreation Opportunity Spectrum (ROS)

The Forest Service uses a land classification system to inventory and describe a range of recreation 

opportunities called the Recreational Opportunity Spectrum (ROS) from the Willamette Forest Plan FEIS, 

page III-93. This system seeks to identify recreation settings of varying characteristics that range from 

remote undeveloped areas to easily accessed highly developed sites. Settings are described in the 

following five ROS Classes: Primitive, Semi-primitive Non-motorized, Semi-primitive Motorized, 

Roaded Natural, and Roaded Modified. Primitive falls on the most unmodified natural environment end 

of the spectrum and Roaded Modified falls on the most substantially modified end of the spectrum. Table 

55 displays the ROS classes and treatment acres for each alternative within the project area. Table 56

displays ROS allocations and desired conditions.

Table 51 Management Areas and ROS Allocations

Management Allocation (MA) ROS Allocation

Acres in 

Alternative 2 

Treatment 

Units

Acres in 

Alternative 3 

Treatment 

Units

Matrix (MA 14A) – Max Modification Roaded Modified 1210.5 823.9

Adaptive Management Reserve (MA 17) – Scenic Partial 

Retention Middleground 11C Roaded Natural 298.8 197.7

Adaptive Management Reserve (MA 17) – Scenic Retention 

Foreground 11F Roaded Natural 240.5 152.8

100-acre Late Successional Reserve (MA 16B) - Dispersed 

Recreation – Semiprimitive Motorized (MA 10C)

Semi-Primitive 

Motorized 5.2 3.0

Table 52 Hwy 46 Project Area ROS Allocation Summary and Desired Conditions

ROS Class Desired Condition 

for setting

Desired Condition for Activities

Roaded 

Modified

Opportunity to get away 

from others, but with easy 

access

Environment will appear 

substantially modified

Access and travel is 

conventional motorized 

vehicle

Shape and blend 

vegetation alterations, 

foreground should be 

natural appearing

Access for people with disabilities is a moderate 

challenge 

Rustic facilities provide some comfort and site 

protection

Moderate site modification can occur

Roaded Natural

Opportunity to affiliate with 

others but with some 

chance for privacy

Access for people with disabilities is difficult
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ROS Class Desired Condition 

for setting

Desired Condition for Activities

Some obvious control of 

users

Mostly natural appearing 

setting

Vegetation modification 

done to maintain desired 

visual characteristics

No on site facilities except occasional signing site 

modification by users

Semi-Primitive 

Motorized

Moderate probability of 

experiencing solitude, 

closeness to nature, 

tranquility. High degree of 

self-reliance, challenge and 

risk in using motorized 

equipment. Predominantly 

naturally appearing 

environment.

Access for people with disabilities is difficult.

Rustic and rudimentary facilities primarily for site 

protection using native material.

Recreational Driving/Road Access

Driving for pleasure (sightseeing) is a popular activity within the project area, primarily during the 

summer months when roads are open and free of snow. There is one National Scenic Byway in the project 

area; the West Cascades National Scenic Byway. Visitors enjoying this route will sometimes stop along 

their drive to picnic at one of several developed sites, visit interpretive sites, or choose their own special 

place to relax before continuing on their journey. In addition to scenic driving on byways, visitors also 

drive other Forest Service roads for pleasure; this use fluctuates from very light on most dead end roads to 

moderate use on secondary and connector roads, with increased use during the hunting season. Forest 

Road 46 is also designated as the Cascading Rivers Scenic Bikeway, used by cyclists as a challenging 

cycling route between the towns of Estacada and Detroit. Cyclists have access to share the full lane of 

travel with motorized vehicles while travelling this route.

Developed Recreation Sites

Breitenbush, Cleator Bend Group Camp, and Fox Creek Group Site are the three developed campgrounds 

within the project area. Breitenbush Campground is extremely popular and provides 30 campsites. Cleator 

Bend Group Camp is a small, reserveable group site that has accommodations for up to 45 people. Both 

Breitenbush Campground and Cleator Bend Group Camp are near the private resort community of 

Breitenbush Hot Springs. Fox Creek Group Site is a reserveable group campground on Forest Road 46 

and provides a more primitive experience with an open gathering area, restroom and garbage facilities, 

and accommodations for groups of approximately 75 people.

Dispersed Use

Dispersed use incorporates a multitude of recreational activities within the general forest, but outside of 

developed recreation sites. Activities include, but are not limited to: scenic driving, hiking, bird watching, 

hunting, fishing, boating, water-play, mountain biking, horseback riding, and camping. There are over 160 

known dispersed campsites within the project area. These sites are usually associated with favorite 

hunting areas or are areas with some interesting natural features such as fresh water streams, lakes, rock 

formations or an appealing forest environment. There are over 40 high use campsites along Breitenbush 
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Road that provide access to the Breitenbush River and have an appealing forest environment with 

associated camping areas. The remaining sites are moderately used and are primarily in the more upland 

areas of the watershed and tend to be used by hunters during hunting season.

There are 11 rock pits within the project area. Rock pits are used primarily for recreational target shooting 

and occasionally dispersed camping. 

Trails

In the project area the entire South Breitenbush Gorge National Recreation Trail (South Breitenbush 

Gorge NRT) is 6.2 miles in length with a lower trail head near the Breitenbush Hot Springs Resort and an 

upper trail head near the Mt. Jefferson Wilderness boundary. The South Breitenbush Gorge NRT provides 

one other access point about midway its length allowing for a variety of route and transportation options. 

There are nine other trailheads within the project area:

• Mansfield – Trail #3355

• Rapidan – Trail #3360

• Crown Lake – Trail #3361

• Roaring Creek – Trail #3362

• Short Mountain – Trail #3363

• Crag Trail – Trail #3364

• Leone Lake – Trail #3367

• Triangulation – Trail #3373

• South Breitenbush – Trail #3375

Although many of these trails are lower use trails, they all receive enough use to be maintained on a 

regular basis. All of these additional trailheads have had expansion of their parking areas, due to public 

use, outside of the established area onto sensitive natural ground. These expansion areas are experiencing 

vegetation loss, erosion and soil compaction.

Special Interest Areas

Short Lake is located within the project area approximately 8.7 air miles north and east from Detroit, 

Oregon. Short Lake is located in T9S R7E Section 18 at approximately 3080 feet above sea level. The 1.7 

acre lake is surrounded by mature forests, but evidence of forest management practices are visible in the 

surrounding area. The lake is a popular destination for dispersed recreation camping, as well as fishing, 

birding, boating and wildlife viewing.

Winter Recreation

During the winter season, portions of the project area become a popular snowmobile recreation area with 

staging at the intersection of FSR 46 and the FSR 2231. During years with snow, FSR 46 is not plowed 

beyond that intersection, allowing snowmobile users to access the upper Breitenbush road systems, the 

McCoy Motorized Recreation Area, and the Olallie Scenic Recreation Area. The Breitenbush Hot Springs 

Resort plows a small portion of FSR 2231 and the entire length of FSR 890, to provide user access to 

their resort. 

Off Highway Vehicles

Off Highway Vehicle (OHV) use on the forest road system in the project area is quite common. Many 

forest users load and offload near the Breitenbush Road and explore the adjacent forest roads. 

Additionally, the McCoy Motorized Recreation Area is located within the southern portion of the project 
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area. The McCoy Motorized Recreation Area uses the existing forest road system to provide scenic 

opportunities for OHV riders.

3.11.4 Environmental Consequences

Direct and Indirect Effects

Alternative 1 - No Action

Recreation use of the National Forest in the project area would remain unchanged with the No-Action 

alternative. The recreating public would continue to use the project area for recreational purposes, and 

would continue current use of developed and dispersed campsites, day use areas, interpretive sites, boat 

launches, trails, and roads. Therefore, Alternative 1 would have no direct or indirect effect on recreation 

within the project area.

Alternatives 2 and 3

Recreational Driving/Road Access

Short term effects of proposed timber harvesting, log truck hauling, and fuels treatments would include 

the following during timber harvest: localized road closures, and disruption to hunting, hiking, camping, 

and driving in some areas. The logging activity, hauling, and fuels treatments would likely cause noise 

and dust or smoke disturbances in some instances. Due to the limited duration of the activities within the 

project area, it is not likely that people will be turned away by a closure unless there is legitimate need for 

public health or safety. Visitors may choose to turn away and recreate in different areas due to the 

activities being presented. 

No permanent roads would be constructed and 8.88 miles of roads would be decommissioned as a result 

of the Hwy 46 project. Alternative 2 would construct 5.11 miles of temporary roads and reconstructing 

4.10 of temporary roads. Alternative 3 would construct 3.0 miles of temporary roads and reconstruct 3.3 

miles of temporary roads. Road maintenance on secondary roads in the project area would improve ride 

quality and comfort for visitors seeking recreation opportunities in the area. Alternative 2 would maintain 

approximately 108.5 miles of road and Alternative 3 would maintain approximately 98.7 miles.

Post-sale activities along FSR 4600-040 would include the decommissioning of approximately 0.4 miles 

of FSR 040 will be decommissioned and rehabilitated to improve natural hydrologic function around 

Short Lake and reduce road maintenance. FSR 4600-059 would be realigned to provide access around the 

decommissioned portion of FSR 040. Decommissioning 0.4 miles of FSR 040 is included in the total 8.88 

miles of roads. 

Developed Recreation Sites

Hazardous Fuels Treatments would occur around the recreation residences and the Breitenbush Hot 

Springs Resort in the project area. These treatments would have short term direct effects such as increased 

noise during treatment periods. Slash piles would be noticeable immediately after treatments have 

occurred but would be burned, masticated and spread or removed. Stumps and other indicators of harvest 

activity would become less noticeable after vegetation recovery takes place (3-6 years). Overall, positive 

benefits would result from hazardous fuels treatments because of scenery improvements (increased depth 

of view into the forest) and for fire safety (reduced fuel loads). Proposed fuels treatments in units 170, 

210 and 270 would improve public safety in the Breitenbush and Devil’s Creek summer home tracts, as

well as the Breitenbush Hot Springs Resort, by reducing wildfire risk. A recreation specialist would be 

involved during the layout phase to ensure screening vegetation and other recreation assets are protected. 
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While these fuel treatments are not adjacent to the developed campgrounds, there may be short term 

direct effects in the vicinity of the campgrounds. Design features stipulate that no fuels treatments would 

take place when the nearby campgrounds are in fee status to ensure public access to these areas is not 

affected. 

In Alternative 2 and 3, thinning treatments are to be pursued in Units 7 and 11, which is located in and 

adjacent to Fox Creek Group Campground. Additional harvest activities in Units 30, 80, and 150, will 

occur near Cleator Bend Group Campground and Breitenbush Campground. Harvest activities would 

occur outside of the camping season when the campgrounds are closed, but there may be times when 

harvest activities need to be accomplished during the primary camping season. These activities would 

have short term direct effects such as increased noise and truck traffic during treatment periods, and 

potential campground closures. Due to the limited duration of the activities within the project area, it is 

not likely that people will be turned away by a closure unless there is legitimate need for public health or 

safety. Visitors may choose to turn away and recreate in different areas due to the activities being 

presented. 

Pre-sale tree and sale area boundary marking would be placed on the side of trees facing away from the 

road to reduce visibility. Logging slash, skid trails and exposed stumps would be noticeable in the short 

term after harvest activity has concluded but would become less noticeable over time (3-6 years) as 

vegetative recovery takes place. Design features would require removal, mastication or burning of 

logging slash, low cutting or angle cutting away from the developed portions of site and removal of 

timber sale boundary markers. A recreation specialist would be integrated into the layout phase prior to 

project implementation. Longer-term, beneficial, effects to the campground would include improvements 

to the site to improve visitor experience.

Dispersed Use

Existing vehicle access and improved access from road maintenance would occur on approximately 133 

miles in Alternative 2 and 99 miles in Alternative 3. This would improve access to much of the project 

area, improving safety and driving comfort for road users who are seeking dispersed camping 

opportunities. Indirect effects of these improvements may include increased dispersed camping use and 

other activities in areas previously not used due to poor road conditions.

Several rock pits within the project area are to be utilized for road maintenance and temporary road 

construction material during harvest operations. Two rock pits, Mansfield Pit and Lower Skunk Creek Pit 

will require development of a pit plan if deemed necessary for pit expansion, while seven rock pits will be 

used for material extraction and/or as waste areas. Use of the rock pits would cause short term effects of: 

localized road closures, and disruption to hunting, camping, target shooting, and driving in some areas. 

The activity in the rock pits would likely cause noise and dust disturbances in some instances. Indirect 

effects of these improvements may include increased trash, dispersed camping use and an increase in 

target shooting because of improved access and visibility to the rock pits.

Due to the limited duration of the activities within the project area, it is not likely that people will be 

turned away by a closure unless there is legitimate need for public health or safety. Visitors may choose to 

turn away and recreate in different areas due to the activities being presented.

Trails

The South Breitenbush Gorge National Recreation Trail (SBGNRT) is nearly parallel and southwest to 

FSR 4685 for its entire length. Units 410, 460, 470, 480, 490, and 510 are immediately adjacent on the 

northeast side of FSR 4685. Unit 510 encompasses the trail head parking area for the SBGNRT, Crag 

Trail and South Breitenbush Trail. The SBGNRT and the trail head parking area in Unit 510 would be 
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temporarily closed while logging activity is underway to ensure public safety. Due to the proximity of the 

trail to FSR 4685 and the adjacent units (410, 460, 470, 480, and 490), noise from harvest activities would 

potentially disrupt visitors along the trail. Pre-sale tree and sale area boundary marking would be placed 

on the side of trees facing away from the road to reduce visibility. Logging slash, skid trails and exposed 

stumps would be noticeable in the short term after harvest activity has concluded but would become less 

noticeable over time (3-6 years) as vegetative recovery takes place. Design features would require 

removal, mastication or burning of logging slash, low cutting or angle cutting away from the road and 

removal of timber sale boundary markers. A recreation trails specialist would be integrated into the layout 

phase prior to project implementation.

Longer term beneficial effects to the trail as a result of project implementation would include an expanded 

and improved parking area at the trailhead and improved road access and signage. The trail head in Unit 

510, is also the trail head to two other trails leading into the Mt. Jefferson Wilderness. 

In Alternatives 2 and 3, the logging activity, hauling, and fuels treatments would likely cause noise and 

dust or smoke disturbances to other trails or trail heads in the project area due to seasonal timing of 

harvest activities.

Due to the limited duration of the activities within the project area, it is not likely that people will be 

turned away by a closure unless there is legitimate need for public health or safety. Visitors may choose to 

turn away and recreate in different areas due to the activities being presented.

Special Interest Areas

Management actions within the Short Lake Lakeside Area (LA) will focus on protection of the area’s 

resources and restore hydrologic processes, while fostering public use and enjoyment. Due to the current 

road alignment, the natural hydrology in the area has been disrupted. Post-sale road realignment would 

have a direct, beneficial effect on the natural resources within the Short Lake LA (See Short Lake SIA 

Document).

Winter Recreation

In response to the public safety concerns of log truck traffic near the Breitenbush community all haul 

routes south of FSR 46 and west of FSR 4685, in Alternatives 2 and 3, have been redesigned to haul as 

much as physically possible over FSR 2231. This routing element within the project area will have a 

direct effect on winter recreation within the McCoy Motorized Recreation Area if harvest activities 

require plowing of roads. Short term effects of proposed timber harvesting and log truck hauling would 

include the following during timber harvest: localized road closures and disruption to snowmobile access 

and groomed trails. The logging activity and hauling would likely cause noise disturbances in some 

instances.

Harvest activities within the project area north of FSR 46 will have a direct effect on winter recreation 

primarily along FSR 46 if harvest activities require plowing of roads. Short term effects of proposed 

timber harvesting and log truck hauling would include the following during timber harvest: localized road 

closures and disruption to snowmobile access. The logging activity and hauling would likely cause noise 

disturbances in some instances. Due to the limited duration of the activities within the project area, it is 

not likely that people will be turned away by a closure unless there is legitimate need for public health or 

safety. Visitors may choose to turn away and recreate in different areas due to the activities being 

presented.

Off Highway Vehicles
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Off Highway Vehicle (OHV use is a recreational activity commonly pursued in the southern portion of the 

project area within the McCoy Motorized Recreation Area. OHV use is expected to be affected. In 

response to the public safety concerns of log truck traffic near the Breitenbush community all haul routes 

south of FSR 46 and west of FSR 4685, in Alternatives 2 and 3, have been redesigned to haul as much as 

physically possible over FSR 2231. This routing element within the project area will have a direct effect 

on OHV recreation within the McCoy Motorized Recreation Area. Short term effects of proposed timber 

harvesting, log truck hauling, and fuels treatments would include the following during timber harvest: 

localized road closures and disruption to OHV access. The logging activity, hauling, and fuels treatments 

would likely cause noise, dust, and smoke disturbances in some instances.

Harvest activities within the project area north of FSR 46 will have a direct effect on OHV recreation. 

Short term effects of proposed timber harvesting, log truck hauling, and fuels treatments would include 

the following during timber harvest: localized road closures and disruption to OHV access. The logging 

activity, hauling, and fuels treatments would likely cause noise, dust, and smoke disturbances in some 

instances. Due to the limited duration of the activities within the project area, it is not likely that people 

will be turned away by a closure unless there is legitimate need for public health or safety. Visitors may 

choose to turn away and recreate in different areas due to the activities being presented. 

Cumulative Effects

Alternative 1

No direct or indirect effects to recreation would occur under Alternative 1 because no timber harvest is 

proposed under this alternative; therefore, no cumulative effects would occur.

Alternatives 2 and 3

Past and present natural and human caused disturbances or modifications including timber harvest, road 

construction and wildfire, are evident throughout the project area. 

During the summer of 2017 three large fires burned within the project area effecting several units. These 

fires were typical of the western cascades mixed severity fire regime and had a range of effects on the 

landscape. 

Two timber sales have recently completed in and near the project area. These projects were French Thin 

and Breit Thin. 

The activities described in Hwy 46 would add changes through incremental improvements to the road 

conditions, visual quality, and improved access in the project area through maintenance activities, which 

may cumulatively increase all types of recreation, especially dispersed recreation. 
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3.12 Eligible Wild and Scenic Rivers

3.12.1 Summary of Effects Analysis

Alternatives 1 would have no direct or indirect effects on eligible Wild and Scenic Rivers in the project 

area. Alternatives 2 and 3 would have direct adverse effect to the scenic quality of the river corridors in 

areas where timber harvest activity occurs and stumps are not flush cut. The impact of these adverse 

effects will reduce with time as brush and moss grows, making stumps less easily visible. The actions 

proposed in Alternatives 2 and 3 will not jeopardize the eligibility of either the Breitenbush River or 

South Fork Breitenbush River for inclusion in the national Wild and Scenic River System. There will be 

no cumulative effects associated with any of the three alternatives.

3.12.2 Scale of Analysis

The geographic scale used to assess direct, indirect, and cumulative effects to Wild and Scenic Rivers is 

the Hwy 46 project planning area as well as the portions of the Breitenbush River and the South Fork 

Breitenbush River which extend either upstream or downstream from the project area. The South Fork 

Breitenbush River located above the project area is included in the Mount Jefferson Wilderness. The 

portion of the Breitenbush River below the project area is included entirely within the Willamette 

National Forest. 

3.12.3 Affected Environment

The project area includes portions of the Breitenbush River and the South Fork Breitenbush River which 

have been determined to be eligible for inclusion into the national Wild and Scenic River System. Until 

suitability is determined, the area within 1⁄4 mile on either side of the Breitenbush River is to be managed 

to meet Wild and Scenic River (Recreation) Standards and Guidelines as outlined in Management Area 6c 

in the Willamette National Forest Land and Resource Management Plan (1990). Also until suitability is 

determined, the area within the project area that is 1⁄4 mile on either side of the South Fork Breitenbush 

River is to be managed to meet Wild and Scenic River (Scenic) Standards and Guidelines as outlined in 

Management Area 6b in the Forest Plan. The location of these rivers is shown in map on the next page. 

Eligibility status of Wild and Scenic Rivers is determined by identification of the river’s free flowing 

status and it’s “Outstandingly Remarkable Values” (ORVs) as defined by the Wild and Scenic River Act. 

For the Breitenbush River, the most significant ORV is its variety and quality of recreational activities. 

The river is used for camping, fishing, commercial resort activities, kayaking, hiking, recreational driving 

and general enjoyment of the forest environment. Additional identified ORVs of the Breitenbush River 

include the quality of the ecological setting, wildlife variety, historic values, and very high water quality. 

The area includes stands of old growth forest, habitat areas for sensitive and threatened species, and is, or 

contributes to, the water supply for several communities in the North Santiam River corridor. (LRMP, 

WNF, 1990 and Breitenbush River Resource Assessment, 1993)
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Figure Eligible Wild and Scenic River
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For the lower segment of the South Fork Breitenbush River within the project area, the most significant 

ORV is its scenic quality. Its clear waters include the cascades and waterfalls as the river runs through the 

South Breitenbush Gorge emerging in old growth forest. Other ORVs include recreational use especially 

for hiking along the South Breitenbush National Recreational Trail, the rivers geology and hydrology, and 

high water quality. (LRMP, WNF, 1990 & South Breitenbush River Resource Assessment, 1993)

3.12.4 Environmental Consequences

Direct and Indirect Effects

Alternative 1 - No Action 

Alternative 1 would result in no change to the condition of ORVs or eligibility status of the Breitenbush 

River or the South Fork Breitenbush River. There are no direct or indirect effects to Wild and Scenic 

River resources.

Alternatives 2 and 3

Alternatives 2 and 3 include proposed timber harvest activities within the area 1⁄4 mile from either side of 

the Breitenbush River and South Fork Breitenbush River. Proposed activities are compliant with all 

standards and guidelines included in the Willamette National Forest Land and Resource Management 

Plan (1990) for both Scenic and Recreational Wild and Scenic River segments (Management Areas 6b 

and 6c). One standard and guide, “Stumps should be flush cut” (MA-6c-12 & MA-6b-11), is partially 

applied. As specified in the Forest Plan, this action is required unless justifiable reason exists for not 

taking action, such as an unacceptable hardship or expense (LRMP, 1990, p IV-45). Due to the high cost 

of flush cutting stumps when timber is harvested, this mitigation measure is proposed in all parts of units 

that are within the 1⁄4 mile corridor on either side of the rivers and within 100’ of forest system roads. 

These are areas most often visible to visitors and impactful to the scenic quality ORV. Additionally, a 

project design element requiring a 300’ no cut buffer along the main channels of both rivers in included. 

This element will protect the scenery most readily visible from the rivers from effects of harvest activity. 

Partial implementation of the flush cutting stumps mitigation measure in Alternatives 2 and 3 will reduce 

effects of harvest activities to scenic quality, but still result in some direct adverse effects to the river 

corridors for as long as stumps are visible in areas where harvest activity occurs and stumps are not flush 

cut. The duration of time that stumps will be visible will likely vary from a few years to twenty or more 

according to site specific conditions. Over time, the growth of brush and moss will make stumps less 

easily visible. This effect is greater for the South Fork Breitenbush River due to its most important ORV 

being scenic quality. The effect is less for the main stem of the Breitenbush River which has its most 

important ORV defined as recreational access.

The adverse effect of not flush cutting stumps in all harvest areas within the corridor is not significant and 

will not jeopardize the eligibility of either the Breitenbush River or South Fork Breitenbush River for 

inclusion in the national Wild and Scenic River System. Their free flowing status and water quality 

remain unaffected. Protecting the eligibly of the rivers is the overall guiding direction in management of 

these rivers.

Cumulative Effects 

Alternative 2 and 3

All land adjacent to the entire length of both the Breitenbush River and the South Fork Breitenbush River 

is either included in the national forest system and managed by the Willamette National Forest or included 

in the private property of the Breitenbush Hot Springs resort and conference center. 

Based on personal communication with a representative of the Breitenbush Hot Springs on October 27, 

2016, they have no current or future plans for any actions that would impact the ORVs or free flowing 

qualities of the Breitenbush River where it flows through their property.
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Other than those proposed in this project in Alternatives 2 and 3, there are no activities proposed by the 

Willamette National Forest in other past or future projects in or beyond the project area that will have 

effects on the rivers’ ORVs or other qualities of each river and their eligibility for inclusion in the national 

Wild and Scenic River system. 

3.13 Wilderness

3.13.1 Summary of Effects Analysis

Alternative 1 would have no direct, indirect or cumulative effects on Wilderness. Alternative 2 and 3 

would have temporary adverse effects to wilderness character due to increased noise during harvest 

activity. There are no direct or indirect benefits to Wilderness from any of the proposed alternatives.

3.13.2 Scale of Analysis

The geographic scale used to assess direct, indirect and cumulative effects to Wilderness is the Hwy 46 

planning area and the entire Mount Jefferson Wilderness, Bull of the Woods Wilderness and Opal Creek 

Wilderness, which are located adjacent to, or near the project area. 

3.13.3 Affected Environment

For the purposes of determining impacts to Wilderness this section will consider impacts to wilderness 

character that originate from activities occurring outside Wilderness, but within the project area. 

The Wilderness Act and Forest Service Policy clearly direct the Agency to manage Wilderness areas for 

the “...preservation of their wilderness character...”. Wilderness character has four defining qualities:

• Untrammeled; Wilderness is essentially wild, unconstrained, unhindered and free from modern 

human control or manipulation. It is untrammeled.

• Natural; Wilderness ecological systems are substantially free from the effect of modern 

civilization. They are natural.

• Undeveloped; Wilderness is essentially without permanent structures, enhancements, or modern 

human occupation. To retain its primeval character, a wilderness ideally is managed without the 

use of motorized equipment or mechanical transport. It is undeveloped.

• Outstanding opportunities for solitude or a primitive and unconfined type of recreation; Many 

visitors welcome wilderness, not only for the self-reliant, challenging, non-motorized, nonmechanized recreational experiences it provides, but as a haven for self-discovery and 

rejuvenation, a refuge from civilization. Remoteness from sights and sounds of human activity 

outside the Wilderness is an indicator for success in protecting this quality (Keeping it Wild 2; 

USFS, 2015).

3.13.4 Environmental Consequences

Direct and Indirect Effects

Alternative 1 - No Action

Wilderness use and effects would remain unchanged with the No-Action alternative. Therefore, 

Alternative 1 would have no direct or indirect effect on Wilderness within the project area.
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Alternative 2

Effects to Wilderness are shown below as related to the four qualities of Wilderness character:

Untrammeled

There will be no impacts to the untrammeled quality of the Wilderness for this project because there are 

no proposed activities within the Wilderness.

Natural

There will be no impacts to the natural quality of the Wilderness for this project because there are no 

proposed activities of a large enough scope or scale occurring in areas outside of wilderness that would 

result in changes to the natural quality inside wilderness.

Undeveloped

There will be no impacts to the undeveloped quality of the Wilderness for this project because there are 

no proposed activities within the Wilderness.

Opportunities for solitude or a primitive and unconfined type of recreation

The greatest potential for impacts to wilderness character will be to this quality of character. To analyze 

potential impacts topography was taken into consideration to determine those areas within Wilderness that 

are likely to experience impacts due to noise from harvest activities. See figures 54 and 55 for units 

within the viewshed of two points that are likely to experience moderate to high levels of use during the 

summer season. This viewshed model serves as a predictor of the likelihood that sound generated by 

activities will cause impacts within the receptor area due to topographical alignment or masking. 

Determination of which units show a likelihood of impacting the Wilderness are based on the method of 

harvest.

A threshold level of 40 dB (typical sound level in a quiet library; also the threshold in Wilderness

soundscape preservation management plans by the National Park Service) was used in this analysis as the 

level of noise at which Wilderness character will likely be affected by the sounds of operations. The three 

methods of harvest have different potentials for impact based on the distance sound is expected to travel 

from the harvest units. Table 57 shows the estimated distance of impacts from noise depending on harvest 

method. Carry distances for sound uses the general rule of a 6 dB drop for each doubling of distance 

(http://www.sengpielaudio.com/calculator-distance.htm). Ground-based activities utilize equipment such 

as chainsaws, skidders, and log trucks. The estimate for representative noise level of these types of 

equipment is 65 dB at 150 feet. Skyline harvest activities utilize the same equipment as above, with the 

addition of the yarder with its whistle, the loudest of the equipment for this system at approximately 140 

dB at source. The carry distance for noise from the yarder whistle was corrected for the absorption of 

noise from the atmosphere. This correction was only relevant to the yarder whistle calculation due to its 

high frequency (~1200Hz). This correction accounts for a .2 dB reduction in noise for every 100 feet of 

distance from source (http://www.sengpielaudio.com/calculator-air.htm). Helicopter harvest method 

displays the greatest distances of associated impacts with a representative noise level of 88 dB at 488 feet, 

and a resultant distance of impact of approximately 24 miles. 
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Figure 55 Viewshed from Firecamp Lakes vicinity
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Figure 56 Viewshed from Triangulation Peak vicinity
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None of these calculations capture noise absorption due to vegetative cover or terrain masking. Sound 

absorption from vegetation can account for approximately 100 dB reduction per mile in continuous 

vegetation (The effects of vegetation on road traffic noise; Peng; et al). It is extremely difficult to model 

vegetation screening across a landscape with such a diversity of vegetative structure and composition. 

Terrain masking can also have substantial effect on carry distance of noise. A reduction of 20 dB occurs 

after a sound source drops 30 feet behind a barrier (ridgeline) from a receptor as shown in table 57 below 

(https://www.fhwa.dot.gov/environment/noise/noise_barriers/design_construction/keepdown.cfm). This 

principle can be applied for terrain masking/damping and the resulting reduction in dB levels observed. At 

distances of greater than 30 feet below a ridgeline further sound damping will occur but 20dB was used in 

this analysis.

Noise impacts from the helicopter units have the greatest potential to reach deep into the Wilderness. 

Because of this, viewshed models were run for each helicopter unit, or cluster of units. These models 

were run from the highest points of the units (or clusters of units), with an addition of 300 feet of 

elevation to compensate for the length of long-line required to extract the timber. A long-line 150 feet in 

length is generally used for this type of operation to allow enough clearance from tree tops when hooking 

the logs, logs must then be lifted above tree tops to be transported to the landings. This requires the 

helicopter to be 250 to 300 feet higher than the highest elevation within a particular unit to extract the 

timber.

Table 53 Noise in dB of Different Logging Systems at Indicated Distances

Ground based(dB) D(ft.) D(mi)

65 150 0.0

60(40w/masking) 267 0.1

50 844 0.2

40 2667 0.5

Skyline(dB)

140 1 0.0

70(50w/masking) 1622 0.3

60(40w/masking) 2885 0.5

50 4392 0.8

40 6222 1.2

Helicopter(dB)

88 488 0.1
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70(50w/masking) 3876 0.7

60(40w/masking) 12258 2.3

50 41600 7.9

40 124800 23.6

Impacts to wilderness character and wilderness users from noise related to the proposed activities are 

summarized in three general categories. Impacts from ground-based harvest activities and noncommercial activities, impacts from skyline harvest activities, and impacts from helicopter harvest 

activities. All of these impacts will occur during operations and will not persist beyond harvest activities. 

These impacts are generally of short duration, however, if harvest activities for units that may impact 

wilderness occur through multiple years, these impacts become longer term with greater impact. Most 

recreation within the potentially impacted area occurs from approximately June 15th through October 

15th. Most operations for the proposed action will likely occur during this time period. 

Impacts from ground-based and non-commercial activities occurring in five units will likely penetrate 

approximately a quarter mile within the Mount Jefferson Wilderness. It is likely this distance will be less 

due to damping from vegetative screening. This effected area will likely result in low numbers of visitor 

experience impact because the affected areas do not experience large volumes of visitors. Noncommercial unit 560 includes proposed design elements to mitigate impacts to Wilderness character 

shown in the design elements table in Chapter 2.

Impacts from skyline activities occurring in seven units will have a larger impact to visitor experience 

penetrating up to approximately three quarters of one mile into the Mount Jefferson Wilderness. It is 

likely this distance will be less due to damping from vegetative screening. The areas potentially impacted 

by these activities do receive a moderate amount of visitation during peak season.

Impacts from skyline activities occurring in seven units will have a larger impact to visitor experience 

penetrating up to approximately three quarters of one mile into the wilderness. It is likely this distance 

will be less due to damping from vegetative screening. The areas potentially impacted by these activities 

do receive a moderate amount of visitation during peak season.

Impacts from helicopter activities will have the greatest potential to degrade Wilderness character and 

visitors’ experience of solitude across a larger portion of the landscape. Figure 57 indicates the viewshed 

analysis for areas that will be within range of expected noise impacts of helicopter units. The model 

indicates that impacts from noise can be expected in the Bull of the Woods Wilderness, Mt Jefferson 

Wilderness and the Opal Creek Wilderness. Potentially affected acres are indicated in table 58 below.
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Table 54 Acres potentially affected by helicopter noise 

Wilderness Name Potentially Affected Acres Percentage of Total 

Wilderness Acres

Bull of the Woods 3930 11

Mount Jefferson 10212 9

Opal Creek 97 .5
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Figure 57 Area (in green) with expected impacts from helicopter operations
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Collectively it is possible that all impacts due to noise will impact approximately .5% (97 ac.) of the 

wilderness landscape in Opal Creek Wilderness, 9% (10212 ac.) in Mount Jefferson Wilderness, and 11% 

(3930 ac.) in the Bull of the Woods Wilderness. While as much as 11% of the wilderness landscape will 

have diminished quality of opportunities for solitude during operations, the majority will be unaffected by 

operations offering unaffected opportunities for solitude. This estimate for affected acreage is likely an 

overestimation due to the fact that damping due to vegetative cover is not taken into account in the carrydistance calculations of noise caused by operations due to the variability in the composition and structure 

of vegetation across the project area. These impacts to Wilderness character will be intermittent in nature, 

both temporally and spatially. Impacts from noise created by operations will occur intermittently until all 

harvest activities are complete. Summer-time operations will likely have impacts on visitor experience in 

areas of the Wildernesses that experience moderate to heavy use. Wilderness character will be impacted 

any time that an operation projects noise at a level higher than 40 dB into the wilderness. This impact to 

Wilderness character is independent of whether there are visitors present to hear the noise.

Alternative 3

Effects to Wilderness are shown below as related to the four qualities of Wilderness character:

Untrammeled

There will be no impacts to the untrammeled quality of the Wilderness for this project because there are 

no proposed activities within the Wilderness.

Natural

There will be no impacts to the natural quality of the Wilderness for this project because there are no 

proposed activities of a large enough scope or scale occurring in areas outside of wilderness that would 

result in changes to the natural quality inside wilderness.

Undeveloped

There will be no impacts to the undeveloped quality of the Wilderness for this project because there are 

no proposed activities within the Wilderness.

Opportunities for solitude or a primitive and unconfined type of recreation

Effects from activities proposed in alternative 3 are essentially the same as alternative 2. The difference 

being that helicopter units (13, 24, and 95) north of highway 46 will be dropped; dropping these units 

reduces the number of effected acres in the Mount Jefferson Wilderness by 42 acres to 10170 acres. 

Design elements for non-commercial unit 560 are shown below to mitigate impacts to Wilderness 

character shown in the design elements in Chapter 2 (table 13).

Cumulative Effects

Alternative 1

There are no known activities within the project area that would contribute to cumulative effects for 

actions occur under Alternative 1 because no timber harvest is proposed under this alternative; therefore, 

no cumulative effects would occur.

Alternatives 2 and 3

A Wilderness planning effort has begun to address visitor use impacts within the Cascade Crest 

Wilderness areas including Mount Jefferson Wilderness area. Visitor use management actions under 

consideration will occur completely within the wilderness. The planning effort will attempt to improve 

Wilderness character. There are no foreseeable synergistic effects to wilderness character from the 
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proposed action and the potential visitor use management actions. Therefore, no foreseeable cumulative 

effects will occur.

3.14 Inventoried Roadless Areas (IRA)

3.14.1 Summary of Effects Analysis

Alternative 1 would have no direct, indirect or cumulative effects on Inventoried Roadless Areas. 

Alternatives 2 and 3 would treat approximately 19 acres of the 6036 acre Mt. Jefferson, North Inventoried 

Roadless Area. Alternatives 2 and 3 would thin approximately 14 acres of a 45 year old plantation in the 

IRA, reducing the stand to 70-90 tpa and harvesting approximately 186 mbf. No temporary roads would 

be built.

3.14.2 Affected Environment

Mt. Jefferson, North Inventoried Roadless Area (IRA) is 6036 acres, 2320 acres (38%) are within the 

Hwy 46 project boundary. The IRA is 7% of the Hwy 46 project area.

Mt. Jefferson, North IRA borders the west side of Mt. Jefferson Wilderness and is accessed by many 

roads and trails. The area is composed of a series of irregular areas adjacent to the northwest boundary of 

the wilderness. 

Alternatives 2 and 3 propose treatments on 19 acres in the IRA. The stand is a 45 year old plantation that 

was previously clear-cut with a ground based system and planted with Douglas-fir. The unit is 43 acres, 

19 acres fall in the IRA, as shown in figure 58. The stand is dense, with 220 tpa with a diameter greater 

than 7 inches dbh, as shown in figure 59. The average tree diameter is 12.9 inches dbh, average height is 

86 feet.
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Figure 58 Map of Unit 520

Figure 59 Unit 520 Current Conditions
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3.14.3 Environmental Consequences

Direct and Indirect Effects

Alternative 1 - No Action

No direct or indirect effects to IRA would occur under alternative 1 because no timber harvest would 

occur.

Alternatives 2 and 3

In both action alternatives 14 acres would be thinned to 70- 90 tpa, and 5 acres would be left in no cut 

stream buffers and skips. Harvest would remove approximately 186 mbf from the IRA (less than 0.5% of 

total project volume). Following harvest the slash would be treated by underburning.

All treatments in the IRA would maintain and meet the 9 roadless area characteristics in CFR 294.11.

• (1) High quality or undisturbed soils, water and air: Previously disturbed areas would be used 

during the ground based yarding. Streams are protected with 30 or 60 foot buffers to protect soils 

and water. No temporary roads would be constructed or used.

• (2) Sources of public drinking water: All streams are buffered to protect water quality.

• (3) Diversity of plant and animal communities: Currently the stand has very little plant diversity. 

The stand was planted with Douglas-fir following regeneration harvest and is dense with 

approximately 220 tpa. The proposed thinning would open the canopy to allow new plants to 

grow in the understory, increasing the diversity of plant species in the stand. The remainder of 

the IRA will be untouched, leaving all plant and animal communities as they are.

• (4) Habitat for threatened, endangered, proposed, candidate and sensitive species and for those 

species that depend on large, undisturbed areas of land: Commercial thinning in the IRA portion 

of unit 520 will improve threatened, endangered, proposed, or sensitive species habitat by 

increasing structural and species diversity as well as increase growth, which also will restore the 

characteristics of ecosystem composition and structure.

• (5) Primitive, semi-primitive non-motorized and semi-primitive motorized classes of dispersed 

recreation: The proposed thinning would not change the class of dispersed recreation in the area. 

Dispersed recreation could be temporarily displaced during operations, as well as affected by 

noise from logging operations, however these effects would be short term.

• (6) Reference landscapes: The reference landscape would not be altered. 

• (7) Natural appearing landscapes with high scenic quality: Thinning the stand to 70 to 90 tpa 

would open the stand allowing for deeper views into the forest. The landscape would remain 

natural appearing in the treatment area. The remainder of the IRA would not be affected.

• (8) Traditional cultural properties and sacred sites: None present in the proposed treatment. The 

remainder of the IRA will not be treated, and any existing cultural property and cultural sites will 

be not be disturbed by this project.

• (9) Other locally identified unique characteristics: None present in the proposed treatment. The 

remainder of the IRA will not be treated, and any unique characteristics in the IRA will be not be 

disturbed by this project.

Best Management Practices and Design Elements would be in place to protect: soil, water, and air; plant 

and animal communities and habitat for TES species; classes of recreation and landscapes; cultural 

properties and unique areas.
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Approximately 0.3% of the Mt. Jefferson, North Inventoried Roadless Area would be treated by thinning, 

the remainder of the IRA would not be affected.

Cumulative Effects

Alternative 1

No direct or indirect effects to IRA would occur under alternative 1; therefore, no cumulative effects 

would occur.

Alternatives 2 and 3

There are no known activities within, or adjacent to the IRA that would contribute to cumulative effects 

for actions occurring under Alternatives 2 or 3. Therefore, no foreseeable cumulative effects will occur.

3.15 Noise

3.15.1 Summary of Analysis

Alternative 1 would have no direct, indirect or cumulative effects from noise. Alternatives 2 and 3 would 

have temporary adverse effects due to increased noise during harvest activity.

3.15.2 Affected Environment

Noise is often described as unwanted sound. In an urban setting, street and traffic noise is often 

considered background noise by local residents. However, in a more rural setting, where street and traffic 

noise occurs less frequently, one might notice the sound of a car approaching as an unexpected 

foreground noise. Noises in a rural setting, where less ambient noise is present, are often amplified and 

more impactful to an occupant of the area. The landscape where the Hwy 46 project is planned occurs in a 

rural area such as this with less ambient noise. As such, man made noises are often more noticed by 

visitors. Noise was brought forward during the scoping period as a public concern.

National Forest System Road 46 is a heavily traveled highway. Because of this, visitors recreating along 

and near Road 46 expect to encounter more noise from traffic, including cars, motorcycles, and trucks. 

These visitors are more accustomed to and expect frequent noise in the environment and are therefore less 

impacted by these noises. Noise levels are reduced, however, by increasing distance, air density, wind, 

and obstructions (vegetative cover, and natural landscape features such as hills, ridges, and valleys 

[terrain masking]). As visitors move farther away from the heavily traveled Road 46, the noise from the 

highway is reduced by the increasing distance, air density, wind, vegetative cover, and terrain masking. 

Once away from the noise impact of Road 46, human caused noises can be more impactful on visitor 

experiences.

As described in the Draft Environmental Impact Report for Proposed Jackson Demonstration State Forest 

Management Plan (CA State Board of Forestry, 2004), “Ambient (background) sources of natural noise 

range from short-term soft sounds, as in the sound of the wind in the trees (30-50db), to short-term loud 

cracks and rumbles, as in the sound of falling rocks (60-80 dB). Ambient noise can also be loud and 

constant, as in the deafening sound of a large waterfall (100db).”

Noise from Motorcycles: National Forest System Road 46 is a heavily traveled forest road and is 

extremely popular for motorcycle touring. The loud, whiny motor noise associated with motorcycles often 

carry through the natural setting in areas of low ambient noise.
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Noise from Timber Harvesting: results from activities such as chainsaws, back-up beepers on ground 

based logging equipment, cable yarders and their associated whistle (talkie tooter), diesel motors, log 

trucks, and helicopters. Rock pit expansion may also require blasting.

Noise from Helicopters: 11.6% of the acreage in the Hwy 46 project would use helicopter as a harvest 

method in alternative 2 and 3% of the acreage would use helicopter as a harvest method in alternative 3. 

Using helicopters for logging operations reduces the amount of road building and ground disturbance, but 

can be expensive and noisy. Helicopter sounds can carry many miles, especially when they fly above 

ridges which otherwise act as natural sound barriers.

3.15.4 Noise Impact Analysis

Ambient noise in the Breitenbush Drainage is generally natural and not a problem to people. The chief 

noise-making activities in the Breitenbush Watershed currently results from forest visitors in the area –

motorcycles, cars, recreational shooting (although there is a shooting closure within 1⁄2 mile of the 

Breitenbush Road), etc. If the Hwy 46 project is implemented, added noise from timber harvest must also 

be considered. There are various types of harvest methods, and each comes with its’ associated noise 

levels:

Table 55 Noise Produced by Various Logging Equipment

Harvest Method Noise level – Equivalent Continuous Noise 

Level (Leq)* – dB

Tractor Logging w/backup alarm or log truck 65 at 150 feet

Chain Saw 65 at 150 feet

Talkie Tooter whistle from Cable Yarding 140 dB at source 

Helicopter 88 dB at 488 feet

Some comparable sound levels of common sound sources are as follows:

• Auto (60 mph) at 100 feet – 65 dB

• Vacuum cleaner at 10 feet – 70 dB

• Electric lawn mower at 3 feet – 85 dB

• Food blender at 3 feet – 90 dB

When measuring sound from a point source, the doubling rule is used to determine how quickly the sound 

drops off, or attenuates, with distance from the sound. The doubling rule states that when the distance is 

doubled from a point source, the sound level decreases by six decibels. The carrying distance for noise 

from the cable yarding whistle is reduced due to the absorption of noise from the atmosphere. This 

correction is only relevant to the yarder whistle calculation due to its high frequency (~1200 Hz). This 

correction accounts for a .2 dB reduction in noise for every 100 feet of distance from source 

(http://www.sengpielaudio.com/calculator-air.htm). 

It is worth mentioning that none of these calculations capture noise absorption due to vegetative cover or 

terrain masking. Sound absorption from vegetation can account for approximately 100 dB reduction per 

mile in continuous vegetation (The effects of vegetation on road traffic noise; Peng; et al). Terrain 

masking can also have substantial effect on carry distance of noise. A reduction of 20 dB occurs after a 

sound source drops 30 ft. behind a barrier (ridgeline) from a receptor as shown in Table 60 below 

(https://www.fhwa.dot.gov/environment/noise/noise_barriers/design_construction/keepdown.cfm). This 

principle can be applied for terrain masking/damping and the resulting reduction in dB levels observed. 

At distances of greater than 30 feet below a ridgeline further sound dampening will occur. The following 

table indicates this rule as it relates to noise point sources found in timber harvest:
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Table 60 Noise Attenuation at Increasing Distances

Ground based(dB) D(ft.) D(mi)

65 150 0.0

60(40W/terrain 

masking)

267 0.1

50 844 0.2

40 2667 0.5

Skyline(dB)

140 1 0.0

70(50w/terrain 

masking)

1622 0.3

60(40W/terrain 

masking)

2885 0.5

50 4392 0.8

40 6222 1.2

Helicopter(dB)

88 488 0.1

70(50w/screening) 3876 0.7

60(40w/screening) 12258 2.3

50 41600 7.9

40 124800 23.6

According to noise research, a sound of 50 dB is equivalent to the sound of light traffic 

(http://www.noisehelp.com/noise-level-chart.html) or the sound experienced in a normal library 

(http://www.karmayog.org/noisepollution/upload/293/Decible_Levels_Common.pdf). It is not expected 

that sound at or below this level within the natural environment present in the Hwy 46 planning area 

along with the natural background noise of the sounds of wind, water, and Highway 46 road noises will 

impact the recreation user in the area. 

In order to evaluate the sound impacts from possible timber harvest activities in the Hwy 46 planning 

area, activities will be evaluated using 50 dB to measure impacts, assuming sounds below this level will 

not impact recreating users in the mid to upper Breitenbush drainage outside of wilderness.
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Table 60 above shows the expected sound level relating to ground based, skyline, or helicopter yarding 

varying distances. These measurements are calculated assuming there are no barriers between the point 

source of the sound and the person experiencing the sound (sound receptor) at various distances. On the 

ground there is usually vegetation between the point source and sound receptor (vegetative cover), or 

even terrain breaks (terrain masking). The presence of any of these will further reduce how the sound 

carries.

From Table 60 above:

• Ground based yarding beyond 0.2 miles will produce sounds at or below 50 dB. 

• Skyline yarding beyond 0.8 miles will produce sounds at or below 50 dB.

• A helicopter beyond 7.9 miles will produce sounds at or below 50 dB. 

The above distances will be less if there is vegetative cover or terrain masking between the point source 

and the sound receptor. For example, if a helicopter is operating on the other side of a ridge from the 

sound receptor, the sound is muffled as it is experienced by the sound receptor. A reduction of 20 dB 

occurs after a sound source drops 30 feet behind a barrier (ridgeline) from a receptor as shown in Table 

60 above 

(https://www.fhwa.dot.gov/environment/noise/noise_barriers/design_construction/keepdown.cfm).

Therefore, the following limits will be used when assessing sound impacts from timber harvest operations 

assuming that sounds below 50 dB will not impact the visiting public in the area:

• Ground based yarding – activities greater than 0.2 miles from receptor.

• Skyline yarding – activities greater than 0.8 miles from the receptor unless terrain masking results 

in further muffling. If the skyline is operating in units that are behind terrain breaks, it will be 

assumed that activities beyond 0.3 miles distant will produce sounds below 50 dB [because a 

reduction of 20 dB occurs after a sound source drops 30 feet below a ridgeline – see 70 dB in 

table 60 above].

• Helicopter yarding – activities greater than 7.9 miles from the receptor unless terrain masking 

results in further muffling. If the helicopter is operating in units that are behind terrain breaks and 

can fly away from the receptor, it will be assumed that activities beyond 0.7 miles distant will 

produce sounds below 50 dB [because a reduction of 20 dB occurs after a sound source drops 30 

feet below a ridgeline – see 70 dB in table 60 above].

•

The Breitenbush Hot Springs Resort is centrally located in the project area and depends heavily on a 

natural environment. It is also located adjacent to Cleator Bend and Breitenbush Campgrounds which also 

depend on a natural forest environment. Because of the central location and extreme importance of a 

natural setting and soundscape to the Breitenbush Hot Springs Resort, sound impacts will be assessed 

from a point on this private land near the hot springs themselves.

The following map displays the units proposed for treatment in the Hwy 46 project, by harvest method, 

and whether they are visible from the Breitenbush Hot Springs Resort, assuming that those not visible are 

behind a terrain break, softening the sound produced from timber harvest (terrain masking):
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Figure 60 Hwy 46 Units Visibility from Breitenbush Resort and Conference Center

The following table lists the proposed harvest units likely to produce noise above the 50 dB limit being 

set as a goal to minimize auditory impacts to visitors and residents in the area near the Breitenbush Hot 

Springs Resort. This information was gathered by applying the 50 dB distance limits developed above to 

the units by harvest method and whether, or not, a terrain break (terrain masking) existed. Design 

Elements will reduce these impacts.

Table 56 Units with Potential Noise Impacts

Unit Alt. 2 Alt. 3 Logging System 

(Acres)

Comment 

Hel Sky Grnd

24 X 8 Hel - no terrain break and within 7.9 mi.

27 X 18 Part has no terrain break and within 0.8 mi. 

28 X 13 Part has no terrain break and within 0.8 mi. 

30 X X 7 Part has no terrain break and within 0.8 mi. 

32 X 57 Hel no terrain break and within 7.9 mi.

32a X 8 Hel no terrain break and within 7.9 mi.

42 X X 12 No terrain break and within 0.8 mi.

200 X X 28 No terrain break and within 0.8 mi.

240 X X 22 No terrain break and within 0.8 mi.

Log Truck Traffic: In addition to noise from timber harvest in units, log trucks also create noise, dust, 

and add to congestion on roads. Highway 46 is part of a National Scenic Byway, a State Scenic Bikeway, 

and also has a between 400 to 800 vehicles per day with some peak days estimated to be greater than 900 

vehicles per day. Timing of log haul should be scheduled to minimize impacts on Highway 46. Units 
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located in the southern part of the planning area that are accessed by FDR 2231 will be hauled southeast 

over Boulder Ridge and down to Highway 22 just west of Idanha. This will reduce noise and congestion 

near the Breitenbush Hot Springs Resort as well as along the mid and lower stretches of Highway 46.

Cumulative Effects

Alternative 1 

No direct or indirect effects from noise would occur under alternative 1; therefore, no cumulative effects 

would occur. 

Alternative 2 and 3 

Noise created by logging activities proposed in alternatives 2 and 3 would have cumulative effects to the 

existing sounds, natural and man-made, currently existing in the planning area. These effects would be 

cumulative during the time additional noise is being made during logging operations. As soon as logging 

operations cease, the cumulative effect of noise would end, making the cumulative effects of noise from 

logging ephemeral.

3.16 Economics

3.16.1 Summary of Effects Analysis

Alternatives 2 and 3 would have a positive benefit/cost ratio which would generate sufficient stumpage 

funds to pay for restoration activities, both required and optional. Alternative 2 would have a benefit/cost 

ratio of 1.34. Alternative 3 has a benefit/cost ration of 1.29. In a matter of fiscal return on investment, 

Alternative 2 would cover all costs plus return approximately $7.3 million to the treasury while 

Alternative 3 would cover all costs plus return approximately $3.9 million to the treasury. 

Alternative 1 would not contribute to local economy, forest sector jobs, or the National Forest Fund (NFF) 

which in turn contributes directly to local governments. Alternatives 2 and 3 would have beneficial direct 

effects to the local economy, forest sector jobs, and the NFF.

3.16.2 Scale of Analysis

The scale used to evaluate Economics associated with the Hwy 46 project is Linn and Marion Counties, 

Oregon. The project lies within Marion County, but is immediately adjacent to Linn County where several 

of the potential purchasing sawmills are located. Funds generated would contribute towards Marion 

County Title II payments. There would also be a positive economic benefit to Linn County. If part of the 

sale area was also sold as a stewardship sale, this sale could also benefit local economies through direct 

payments to purchasers under stewardship authority.

3.16.3 Affected Environment

The project area is located on both sides of Highway 46 in the upper and middle Breitenbush watershed, 

approximately 5 miles east of State Highway 22 and the City of Detroit, OR.

State Highway 22: This route is the primary link between the upper Willamette valley and central 

Oregon. It also serves as a gateway to the Cascade Mountains and the recreation areas of the North 

Santiam River area. As such, traffic volumes are high. According to information obtained from the 

Oregon Department of Transportation (ODOT) in March 2014, traffic volumes monitored at different 

locations on Highway. 22 within the Canyon in 2012 range from 3,000 to 9,000 daily trips with projected 
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2032 volumes increasing the trips to between 3,600 and 10,400. However, summer weekends demonstrate 

significant peaks well above these figures.

National Forest System Road 46: This route is one of the most heavily traveled forest roads on the 

Willamette National Forest. It is a two lane paved road similar to a typical county rural highway. This 

road is a popular link in the nationally recognized West Cascades Scenic Byway. It links Highway 22 at 

Detroit on the Willamette National Forest (NF) to Clackamas Highway 224 near Estacada on the Mt. 

Hood NF. This road also provides access to the internationally known Breitenbush Hot Springs Retreat 

and Conference Center, numerous campgrounds, and picnic areas. In 2014, this road was also designated 

under the Oregon Scenic Bikeway Program as the Cascading Rivers Scenic Bikeway travelling between 

Estacada and Detroit. It also provides access to land areas where timber management is a significant 

management objective. As a result there is a substantial mix of commercial and recreational traffic. 

Included in the mix are bicyclists and pedestrians of all ages. This route is also a popular motorcycle 

touring route in the summer. Summer seasonal traffic volumes are estimated to be in the range of 400 to 

800 vehicles per day. Peak holiday (Memorial Day, July 4 and Labor Day) traffic volumes are estimated 

to be greater than 900 vehicles per day. The road snows closed in the winter and is only plowed as far as 

the Breitenbush Hot Springs Retreat and Conference Center. 

The Hwy 46 project is located in the Breitenbush Watershed which is a 5th field watershed in the North 

Santiam Watershed. The North Santiam is located in both Linn and Marion Counties about one hour east 

of Salem, OR. The Canyon area consists of 670 square miles and includes the small cities of Lyons, 

Mehama, Mill City, Gates, Detroit and Idanha. 

The communities of the Santiam River Canyon have been severely impacted by the reduction of timber 

harvest following the listing of the spotted owl as a threatened species in 1990. Oregon Employment 

Department data from 1999 shows that logging, mills, and wood products (manufacturing) supported 

63.5% of all employment in the region. The industry continues to experience declines – in 2012, data 

shows a decline in manufacturing to 41% of employment in the region. Although timber harvest levels 

have dropped, timber harvest is still a very important component in the economy of the Santiam River 

Canyon. According to an Oregon Forest Resource Institute (OFRI) report from 2012, pg. 41, 

approximately 10.8 jobs are created with each incremental increase in million board feet made available 

for harvest.

Oregon Employment Department statistics from 2012 show that the North Santiam Canyon Employment 

by Industry is as follows:

Table 57 North Santiam Canyon Employment

North Santiam Canyon

Employment by Industry, 2012

Percent of 

Total

Manufacturing (Primarily wood products) 41%

Total All Government 17%

Leisure & Hospitality 14%

Trade, Transportation & Utilities 10%

Construction 5%

Professional & Business Services 5%

Natural Resources & Mining 4%

Other Services 2%

Education & Health Services 1%

Information & Financial Activities 1%
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Although leisure and hospitality only comprised 14% of the total employment in the North Santiam 

Canyon in 2012, this category is growing and represents an important economic sector now and into the 

future. Local economic drivers in the leisure and hospitality industry include:

• The outstandingly remarkable and accessible natural environment provided by the large amount 

of public land including Forest Service, State, BLM, County, and City lands which is a large draw 

to the recreating public.

• The nearby City of Detroit is a tourist/recreation center. It hosts annual tourist events and also 

serves as a base for recreators to access public lands. Although the 2010 census showed that 

Detroit had a population of 202 year-round residents, the number grows greatly in the summer 

months as recreation on Detroit Lake and the surrounding forest draws many summer time 

residents and campers to the area. This trend is expected to continue into the future, making 

recreation and tourism an important part of the economy in and around Detroit.

• A 2008 Oregon Marine Board Triennium Survey indicates that Detroit Lake continues to be the 

highest used lake in the state of Oregon with almost 72,000 boat use days and over 81,000

activity days (Triennial Survey Results [2008]. Oregon State Marine Board. www.oregon.gov).

• The increasing outfitter/guide industry including rafting, fishing, boating, horseback riding, 

hiking, and many other growing recreation opportunities.

• Increasing travel for pleasure including driving, motorcycling, biking, hiking, etc.

• The Breitenbush Hot Springs Retreat and Conference Center (BBHS), which lies in the heart of 

the Hwy 46 project, is an internationally known resort. BBHS brings a large number of visitors to 

the North Santiam and Breitenbush Canyons. Monthly total visitation (Guests – overnight stay + 

day use) averages from a low of 2250 guests in February to a high of 4250 guests in August.

3.16.4 Environmental Consequences

Direct and Indirect Effects

The direct economic effects of the alternatives are displayed in Table 63. A standard criterion for deciding 

whether a government program can be justified on economic principles is net future value (NFV) – the 

discounted monetized value of expected net benefits (OMB A-94). Another standard criterion for 

economic efficiency is the benefit/cost ratio (B/C ratio) which is the product of the present value of 

benefits divided by the present value of costs. 

Alternative 1 

The No-Action alternative would not harvest any timber, and therefore, would not support direct, indirect, 

and induced employment. It would not result in increased income to the regional or local economy 

(including the counties). Current levels of employment in the wood products sector would not change 

under this alternative. If the Hwy 46 project were not replaced by another project, the No-Action 

alternative could contribute to a continued decline in forestry and milling related jobs.

Alternative 2 and 3

All action Alternatives are economically viable, considering current selling values, timber volume per 

acre, yarding systems required, the proposed temporary road construction and system road maintenance 

needed, and the identified post-timber harvest projects identified in this analysis. The economic analysis 

utilized to make this determination is available in the Hwy 46 project analysis file at the Detroit Ranger 

District office. Based on the expected return to the Federal government plus the value of restoration 

activities potentially funded by stumpage, Alternatives 2 and 3 would provide a positive benefit/cost ratio. 

Though the combined economic benefit from implementation of any of the action alternatives is expected 

to be positive, each of the action alternatives from the Hwy 46 project would have a localized beneficial 
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effect for the socio-economic environment of western and central Oregon with a greater impact to Marion 

and Linn Counties. Both action Alternatives would also have a benefit in the form of revenues going 

towards the National Forest Fund (NFF). Portions of revenue generated by the sale of timber from the 

action Alternatives would be available to the county for roads and schools. 

Alternatives 2 and 3 would both increase logging activity in the area. Alternative 2 would yard 2,785

acres and alternative 3 would yard 2,006 acres. Increased logging activity would increase traffic, noise, 

and congestion in an already busy and heavily used area for recreation and leisure in the nearby Forest 

Service campgrounds, trails, summer homes, dispersed recreation sites, as well as the privately owned 

Breitenbush Hot Springs Resort and Conference Center. If this project were implemented, careful 

planning and specific design elements should be developed to minimize the impact to the leisure and 

hospitality industry which currently represents 14% of the employment in the North Santiam Canyon.

Table 58 Estimated Economic Alternatives

Alternative 1 Alternative 2 Alternative 3

Timber volume 

produced (MMBF) 0 ~40 ~24

Discounted Cost (2) $500,000 $28,442,238 $17,066,623

Discounted 

Revenues $0 $21,178,725 $14,159,898

Net Future Value 

(NFV) --- $7,263,513 $2,906,725

Benefit/Cost Ratio --- 1.34 1.29

(1) All values are for comparative purposes only. Actual values would be dependent on market values during time of sale and cost of associated 

activities at that time.

(2) Costs include approximate planning cost for the Hwy 46 project.

Employment: In general, the primary effect on timber harvest-related employment would occur from 

commercial timber harvest associated with the action alternatives from an estimated selling year of 2018 

through a final harvest year of around 2021. Both action alternatives would provide some opportunity for 

timber harvest-related employment. Assuming 10.8 jobs are created with each increase in million board 

feet made available for harvest, alternative 2 would create approximately 170 more jobs in the timber 

industry than alternative 3.

Cumulative Effects

Alternative 1 

Because this is the no action alternative, there would be no impact on the environment from the 

incremental impact of an action when added to the impacts of other past, present, or reasonably 

foreseeable future actions (40 CFR §1508.7). Current levels of employment in the wood products sector 

would not be affected. If the Hwy 46 project were not replaced by another project, the No-Action 

alternative could contribute to a continued decline in forestry and milling related jobs. 

Alternative 2 and 3 

No past, present or reasonably foreseeable projects overlap in time or space with the Hwy 46 project, 

contributing to the local economy. Therefore there are no cumulative effects.
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3.17 Climate Change

The proposed action (Alternative 2) would treat approximately 4,060 acres in the project area. Harvest 

treatments proposed include commercial thinning, dominant tree release, gap creation, quality early seral 

creation, sugar pine restoration, meadow restoration and skips. Fuels treatments include mechanical 

treatments and post-harvest underburn. Non-commercial treatments include understory habitat 

enhancement and hazardous fuels reduction.

Climate change is a global phenomenon because major greenhouse gasses (GHG) mix well throughout 

the planet’s lower atmosphere (IPCC 2013). Considering emissions of GHG in 2010 was estimated at 49 

± 4.5 gigatonnes globally (IPCC 2014) and 6.9 gigatonnes nationally (US EPA, 2015), a project of this 

magnitude makes an infinitesimal contribution to overall emissions. Therefore, at the global and national 

scales, the proposed action’s direct and indirect contribution to greenhouse gasses and climate change 

would be negligible. In addition, because the direct and indirect effects would be negligible, the proposed 

action’s contribution to cumulative effects on greenhouse gasses and climate change would also be 

negligible. 

The Intergovernmental Panel on Climate Change has summarized the contributions to climate change of 

global human activity sectors in its Fifth Assessment Report (IPCC 2014). In 2010, anthropogenic 

(human-caused) contributors to greenhouse gas emissions came from several sectors: 

• Industry, transportation, and building – 41%

• Energy production – 35%

• Agriculture – 12%

• Forestry and other land uses – 12%

There is agreement that the forestry sector contribution has declined over the last decade (IPCC, 2014, 

Smith et al, 2014, FAOSTAT, 2013) The main activity in this sector associated with GHG emissions is 

deforestation, which is defined as removal of all trees, most notably the conversion of forest and grassland 

into agricultural land or developed landscapes (IPCC 2000). 

The Hwy 46 Project does not fall within any of these main contributors of greenhouse gas emissions. 

Forested land would not be converted into a developed or agricultural condition. In fact, forest stands are 

being retained and thinned to maintain a vigorous condition that supports trees, and sequesters carbon 

long-term. US forests sequestered 757.1 megatonnes of carbon dioxide after accounting for emissions 

from fires and soils in 2010 (US EPA, 2015). However there is growing concern over the impacts of 

climate change on US forests and their current status as a carbon sink. There is strong evidence of a 

relationship between increasing temperatures and large tree mortality events in forests of the western 

United States. There is widespread recognition that climate change is increasing the size and frequency of 

droughts, fires, and insect/disease outbreaks, which will have major effect on these forests’ role in the 

carbon cycle (Joyce et al. 2014).

The project is in line with the suggested practice of reducing forest disturbance effects found in the 

National Climate Assessment for public and private forests (Joyce et al. 2014). Here specifically, the 

project proposes to improve stand conditions, diversity, density and structure with thinning, gaps, and 

dominant tree release. Thinning the overstocked stands would make more growing space and resources 

available to the remaining trees, resulting in decreased tree stress and development towards larger 

diameter stands. The release of carbon associated with this project is justified given the overall change in 

condition increases forest resistance to release of much greater quantities of carbon from wildfire, 

drought, insects/disease, or a combination of these disturbance types (Millar et al. 2007). This project is 

also consistent with options presented by the IPCC for minimizing the impacts of climate change on 
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forest carbon, and represents a potential synergy between adaptation measures and mitigation. Actions 

aimed at enhancing forest resilience to climate change by reducing the potential for large-scale, 

catastrophic disturbances such as wildfire also prevents release of GHG and enhances carbon stocks 

(Smith et al. 2014). The proposed action is consistent with these recommendations because it would 

improve stand conditions, diversity, density and structure, allowing the forest to adapt, persist and 

function better over time and into the future. 

Timber management projects can influence carbon dioxide sequestration in three main ways: (1) by 

increasing new forests (afforestation), (2) by avoiding their damage or destruction (avoided 

deforestation), and (3) by manipulating existing forest cover (managed forests). Land-use changes, 

specifically deforestation and regrowth, are by far the biggest factors on a global scale in forests’ role as 

sources or sinks of carbon dioxide, respectively (IPCC, Intergovernmental Panel on Climate Change, 

2000). Projects that create forests or improve forest conditions and capacity to grow trees are positive 

factors in carbon sequestration. The proposed action (Alternative 2) falls into this category.

Specifically Required Disclosures:

See Appendix C for a description as to how the action alternatives comply with applicable State and 

Federal Laws, regulations and policies.

3.18 Unavoidable Adverse Impacts

Implementation of any of the alternatives, including the No-Action alternative, would inevitably result in 

some adverse environmental effects. The severity of the effects would be minimized by adhering to the 

direction in the management prescriptions and Standards and Guidelines in Chapter IV of the Willamette 

Forest Plan, as amended the Northwest Forest Plan, and additional design features proposed in Chapter 2

of this document. These potential adverse environmental effects are discussed at length under each 

resource section.

3.19 Irreversible and Irretrievable Commitments of Resources

“Irreversible" commitment of resources refers to a loss of future options with nonrenewable resources. An 

"Irretrievable" commitment of resources refers to loss of opportunity due to a particular choice of 

resource uses. 

The soil and water protection measures identified in the Forest Plan Standards and Guidelines, design 

features in Chapter 2, and Best Management Practices are designed to avoid or minimize the potential for 

irreversible losses from the proposed management actions.

Concerning threatened and endangered plant, wildlife, and fish species, a determination has been made 

that the proposed actions would not result in irreversible or irretrievable commitment of resources that 

foreclose formulation or implementation of reasonable or prudent alternatives.

With all action Alternatives (2 and 3): Tree removal would result in an irretrievable loss of the value of 

removed trees for wildlife habitat, soil productivity, and other values. Little irreversible loss of soil should 

occur due to extensive design features associated with timber harvest and prescribed fire (tractor harvest 

only on slopes less than 30%, skyline yarding with partial or full suspension to meet Forest Plan

Standards and Guidelines, etc.).
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3.20 Short-Term Effects versus 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). This includes using all 

practicable means and measures, including financial and technical assistance, in a manner calculated to 

foster and promote general welfare, to create and maintain conditions under which man and nature can 

exist in productive harmony, and fulfill the social, economic, and other requires of present and future 

generations of Americans (42 CFR § 101(a)). 

The Forest Plan establishes a sustained yield of resource outputs while maintaining productivity of 

resources. The specific direction and mitigation measures included in the Forest Plan and Northwest 

Forest Plan ensure the long-term productivity of resources will not be impaired by the application of 

short-term management practices. Additionally, project Design Features, Mitigation and Enhancement, 

and Monitoring (Section 2.5, 2.6, 2.7) were developed to reduce the environmental effects of the proposed 

activities and ensure project activities are implemented to comply with standards and guidelines, goals, 

objectives, conservation strategies and Best Management Practices.
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Chapter 4 – List of Preparers

Bradford Peterson – Wilderness Manager

USDA Forest Service, Willamette National Forest, Detroit Ranger District

Contribution: Wilderness Analysis

Education / Experience: B.S. Environmental Science: Humboldt State University. 16 years of experience 

with the USFS (Willamette) as a Wilderness Ranger, Wilderness Manager.

Cara Kelly – Archeologist

USDA Forest Service, Willamette National Forest, Detroit and McKenzie River Ranger Districts 

Contribution: Heritage Resources Analysis

Education / Experience: B.S. Anthropology: University of Oregon, MAIS, Anthropology, B.S. 

Geography: Oregon State University. 27 years of experience with the USFS (Willamette) as an 

archeologist in Cultural Resource Management. 

Chris Donaldson – Fuels Specialist

USDA Forest Service, Willamette National Forest, Detroit and Sweet Home Ranger Districts 

Contribution: Fuels and Air Quality Analysis

Education / Experience: B.S. History: Southern Oregon University. 15 years of experience with the USFS 

(Willamette, Rogue River-Siskiyou) in Fire Management, currently Assistant Fire Management Officer.

Danny Matthews – Transportation Planner

USDA Forest Service, Willamette National Forest, Detroit and Sweet Home Ranger Districts 

Contribution: Transportation Analysis

Education / Experience: B.S. 7 years of experience with private sector engineering firms. 6 years of 

experience with the USDA (NRCS (Wyoming) and USFS (Willamette)) as an engineering technician and 

transportation planner.

Darrin A. Neff – Fish Biologist

USDA Forest Service, Willamette National Forest, Detroit Ranger District

Contribution: Fish Analysis

Education / Experience: B.S. Environmental Science: Oregon State University, Graduate coursework in 

Fisheries, Oregon State University. 4 years of experience as a Fish Biologist with Oregon Department of 

Fish and Wildlife, 9 years as a Fish Biologist with USDI BLM, and 6 years as a Fish Biologist with the 

USFS.

Daryl Whitmore – Wildlife Biologist

USDA Forest Service, Willamette National Forest, Detroit Ranger District

Contribution: Wildlife Analysis

Education / Experience: B.S. Wildlife: Oregon State University, 30 years of experience as a Wildlife 

Biologist with the USFS (Willamette).

Doug Shank – Forest Geologist

USDA Forest Service, Willamette National Forest,

Contribution: Soils Analysis

Education / Experience: B.S. Geology: Youngstown State University, M.S. Geology: Arizona State 

University. 36 years of experience with the USFS (Willamette, Siuslaw) as an engineering geologist, 

district ranger, district geologist and forest geologist.
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Emily Lauderdale – Natural Resource Specialist

USDA Forest Service, Willamette National Forest

Contribution: Scenic Quality Analysis

Education / Experience: B.A. German; Environmental Policy & Culture, Northwestern University, Master 

of Landscape Architecture (MLA), University of Michigan. One year experience with the USFS 

(Willamette) in natural resources.

Grady McMahan – District Ranger

USDA Forest Service, Willamette National Forest, Detroit Ranger District

Contribution: Noise Analysis

Education/Experience: B.S. Forest Management: Utah State University. 38 years of experience with the 

USFS (Utah, Alaska, Colorado & Oregon) in presale forestry/logging systems, recreation 

specialist/planning, and administration.

Jamie Sheahan Alonso – Hydrologist

USDA Forest Service, Willamette National Forest, Detroit Ranger District

Contribution: Hydrology Analysis

Education / Experience: B.S. Applied Ecology and Environmental Science, Michigan Technological 

University, M.S. Resource Management: Central Washington University. 2 years of experience with the 

USFS and 5 years prior experience with watershed management.

Jennifer Lippert – Forest Botanist

USDA Forest Service, Willamette National Forest

Contribution: Botanical Analysis

Education / Experience: B.S. Biology: Colorado College, MS in Ecology and Evolution, University of 

Oregon. 29 years of experience as a botanist (27 USFS, 2 private contractor).

Josh Weathers – Recreation Specialist 

USDA Forest Service, Willamette National Forest, Detroit Ranger District

Contribution: Developed and Dispersed Recreation Analysis

Education / Experience: A.A.S. Forest Management: Chemeketa Community College, B.A.S. Natural 

Resources: Oregon State University. 14 years of combined experience with the BLM (Salem District) and 

USFS (Willamette) as a recreation site manager and natural resources specialist (specializing in recreation 

management).

Lyn Medley – NEPA Planner

USDA Forest Service, Willamette National Forest, Detroit Ranger District 

Contribution: Project Lead, Writer/Editor, NEPA Compliance 

Education / Experience: B.S. Forestry, Michigan State University. 32 years of experience with USFS 

(Routt, Davy Crockett, Willamette) and USDI BIA (Warm Springs) in forestry and planning.

Mark Leis – District Silviculturist

USDA Forest Service, Willamette National Forest, Detroit Ranger District 

Contribution: Vegetation Analysis and Silvicultural Prescription

Education / Experience: B.S. Forestry: Michigan State University. Region 6 Certified Silviculturist. 29 

years of experience with USFS (Boise, Willamette) in silviculture and timber. 

Robert Mickey – Logging Systems Specialist and Pre-sale Lead 

USDA Forest Service, Willamette National Forest

Contribution: Logging Systems, Economic Analysis for logging activities
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Education / Experience: B.S. Forest Resource Management / Forest Operations, University of Montana, 

Missoula. 5 years of experience with the USFS (Willamette N.F.) as a logging systems specialist and 

timber sale forester. 

Suzanne Cable – Recreation, Lands and Minerals Staff Officer

USDA Forest Service, Willamette National Forest, Detroit and Sweet Home Ranger Districts

Contribution: Wild and Scenic Rivers Analysis

Education / Experience: B.A. Environmental Studies, Brown University, M.S. Resource Conservation, 

University of Montana. Over twenty years of experience with the USFS on eight national forests in five 

regions working in positions from Wilderness Ranger to Recreation, Lands and Minerals Staff

Additional Support and consultation was provided by the following individuals, Federal, State, tribal, and 

local agencies during the development of this environmental impact statement: 

Forest Service Employees

Robert Gentry, Natural Resource Officer Dean Mills, GIS

Ramon Alonso, Roads Engineer Christina Ellis, GIS

Lizandra Nieves-Rivera, Soils Scientist Charity Glade, Botanist

Chris Wagner, Botanist Steve Akers, Ecologist

Joe Doerr, Forest Wildlife Biologist
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Chapter 5 – List of Agencies, Governments, 

Organizations, and Individuals Given Notice of 

Availability

The agencies, governments, organizations, and individuals listed below were notified of the availability of 

the Draft Environmental Impact Statement (FEIS). A complete list of recipients, including names and 

contact information, is available in the Hwy 46 project file at the Detroit Ranger District.

Agencies and Governments

Bonneville Power Administration

City of Detroit

City of Idanha

Confederated Tribes of Grand Ronde

Confederated Tribes of Siletz Indians

Confederated Tribes of Warm Springs

Klamath Tribes

Linn County

Marion County

Office of Congressman Peter DeFazio

Office of Senator Jeff Merkley

Office of Senator Ron Wyden

Oregon Department of Environmental Quality

Oregon Department of Fish and Wildlife

Oregon Department of Forestry

United States Environmental Protection Agency

United States Fish and Wildlife Service

Organizations

American Forest Resource Council

Benton Forest Coalition

Breitenbush Resort and Conference Center

Cascadia Wildlands Project

Chemeketans

Frank Lumber Company

Freres Lumber Company

Friends of the Breitenbush Cascades

Forest Service Employees for Environmental Ethics

Grow Santiam

North Santiam Watershed Council

Oregon Hunters Association

Oregon Wild

Pacific Crest Trail Association

Portland General Electric

Rocky Mountain Elk Foundation

WildEarth Guardians
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Individuals

A complete list of recipients, including names and contact information, is available in the Hwy 46 project 

file at the Detroit Ranger District.
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Appendix A – Proposed Treatment Descriptions for the 

Action Alternatives

Proposed treatments for the Hwy 46 project area are thinning, gaps, skips, Dominant Tree Release (DTR), 

quality early seral habitat creation, sugar pine restoration (including shelterwood with reserves), meadow 

restoration, understory habitat enhancements, riparian treatments, hazardous fuels treatments.

Activities Common to Thinning

Thinning would maintain/increase the health and vigor of the remaining trees not harvested. Skips and 

gaps ranging between 1-3 acres (see Gaps, and DTR description below) would be placed in many of the 

stands to promote vertical and horizontal diversity (see Appendix B for a unit by unit prescription). 

Conifer trees would be removed through commercial thinning. Sugar pine would not be removed from the 

stand; however they may be cut for operational purposes. Generally, remnant large woody debris on the 

forest floor would be maintained or increased throughout the stand. Snags would be maintained on site if 

not a hazard to logging operations. Units in LSR will not have trees 20 inches dbh and greater harvested, 

unless they occur in gaps. Units not in LSR will not have trees 30 inches dbh and larger harvested. Either 

could have these trees cut for operational purposes, but not removed from the stand.

Project generated fuels may be removed with treatments such as piling and burning, underburning, 

firewood collection, whole tree harvesting or chipping. However, not every acre harvested would have 

fuels treatments prescribed. Areas which are projected to be below the standards and guidelines (FW-212 

and 252) presented by the Forest Plan would likely have minimal fuels treatments prescribed. All postharvest fuels treatments would reduce fuel loads within the stand.

Activities Common to Gaps and Quality Early Seral Habitat 

Retention trees would be left (see description below for specifics) in openings to function as legacy trees 

that would benefit a variety of resources. Live retained trees would be released to encourage large tree 

development, future snag creation, diversity in future stand structure, and development of future large 

down woody debris. 

Retention trees may be spaced both sparsely throughout the opening and also in clumps, increasing the 

diversity across the landscape. Emphasis would be placed on retaining multiple desired retention tree 

species where feasible. Live trees with ‘elements of wood decay’ may be selected as retention trees, 

which could include trees with features like dead tops, broken tops and heart rot. This would increase the 

diversity of the prescriptions across the landscape. 

Live retention trees may or may not be used as snag (wildlife) enhancement projects; however, retention 

trees meeting criteria for wildlife trees (i.e. having Phellinus pini conks or other elements of wood decay) 

would serve as a wildlife tree and offset the need for further enhancement. Snags would be maintained on 

site, if not a hazard to logging operations.

Harvest Treatment Descriptions

Thinning: The silvicultural prescriptions are designed to reduce tree density and inter-tree competition 

which will result in:

• Maintenance or improvement of stand health and vigor.
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• Acceleration of large diameter tree development due to enhanced growth.

• Increase structural and species diversity by allowing advanced regeneration to release into the 

mid and overstory.

• Increased shrub and herbaceous growth developing more understory complexity.

• Provide timber products to the local economy.

Most of the commercial thinning will be implemented using a Designation by Description (DxD) 

prescription. With this method, trees are designated as cut trees if they are within a given spacing of trees 

larger in diameter. For example, in a 15 foot DxD prescription, all smaller trees within 15 feet of the 

largest trees will be cut, leaving the largest trees spaced between 15 to 30 feet apart. This is essentially a 

“thin from below”, favoring the largest and most vigorous trees in the stand. Desired residual trees per 

acre as well as average diameter are used to calculate the spacing. Maximum diameter cut limits and 

species retention can be identified to protect relic old trees or minor species components.

A variety of thinning intensities are prescribed in this project. Heavier thinnings of 40-60 residual tpa are 

prescribed for stands with larger trees, as these trees need more space to grow than smaller ones. Most of 

the plantations are of similar age and structure and are prescribed thinnings to 70-90 tpa. A few of the 

youngest plantations will receive a thinning ranging from 80-110 residual tpa to allow the trees room to 

grow without lowering the canopy cover below 40% in riparian reserves.

Thinning to 40-100 tpa is prescribed to provide a wide range of canopy covers within the stands while 

still maximizing areas of stand and individual tree growth. This treatment is prescribed for some of the 

older stands that already have some species and structural diversity and will be applied with individual 

tree marking to ensure diversity retention and to allow for clumpiness desired for these stands. Unit 150 is 

prescribed a 60-100 thin due to its smaller average diameter and varied structure.

No Harvest Skips: No treatment areas, called skips, are proposed within the stands to promote 

complexity by providing variable density within and among stands. Skips can be areas left untreated due 

to 1) resource considerations such as protection buffers adjacent to streams and special habitat areas, 2) 

logistical considerations such as logging feasibility, 3) areas not in need of thinning or 4) leaving 

untreated areas embedded within a stand to promote complexity. This combination of treatment and no 

treatment will result in skips within the stands to promote variable density both at the stand scale and 

across the landscape.

Dominant Tree Release (DTR): Dominant tree release gaps (DTR) are proposed as a tool to promote 

complexity by providing variable density within stands, allowing for maximum tree growth, increased 

crown depth and expansion, enhanced species growth into the mid and overstory, as well as allowing for 

understory development. One or more dominant trees are left and all other trees within a radius of these 

tree(s) are removed, creating either a 1⁄4 acre gap or a 1⁄2 acre gap around the tree(s). If desirable advanced 

regeneration is present in the opening, than it is released by the treatment and grows into the overstory at 

a faster rate. If no advanced regeneration is present, than the appropriate species is planted. Generally for 

this project, 1⁄4 acre DTRs are created on northerly slopes where climax species such as western hemlock 

and western redcedar are present (planted if not present); while 1⁄2 acre gaps are created on southerly 

slopes and planted with seral species such as sugar pine, western white pine, or incense cedar. Climax 

species may be planted in the shady (southern) portions of these gaps as well. Stand selection for DTR 

placement is based on a variety of factors including plant association, stand structure, and land allocation.
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Wildlife Gaps: Gaps one to three acres in size are proposed to be located in twelve units (Units 6, 16, 18, 

21, 22, 23, 28, 32, 35, 47, 180, and 200). These gaps will contribute to the quality early seral habitat as 

described in Quality Early Seral Habitat below as well as adding species and structural complexity at both 

the stand and landscape level. Gaps would not be a conventional clear-cut treatment. The objective would 

be to leave some green trees in either scattered pockets and/or scattered throughout the opening postharvest. Seven to eight trees per acre of residual trees will be left in each gap. Gaps will be broadcast 

burned where practical and all will be planted with seral conifers. These retention trees would be released 

to grow to encourage large tree development, future snag development, diversity in future stand structure, 

and development of future large down woody debris. In 30 to 60 years the stand structure would be more 

complex with at least a two cohort stand making up the overstory. 

Visual Enhancement Gaps: To enhance scenic views, three gaps have been proposed in this project. 

Units 27 and 30 would each have a 1⁄2 acre “scallop” along the powerline corridor with residual overstory 

to soften the view of the straight line of the corridor. Unit 69 would have a 1/3 acre gap below road 46 to 

increase the view of Mt. Jefferson from the summit pull-out.

Meadow Restoration: The proposed treatment is to cut and remove most of the conifers within the 

boundaries of the historic meadow, leaving 7-8 tpa of larger live trees and retaining any relic conifers 

from before the fire. The reduction in water uptake by the trees currently there should help to restore 

moisture to portions of the meadow as well as reduce shade, allowing meadow plants to re-establish.

Sugar Pine Restoration: Proposed treatments aim to both protect and reinvigorate existing sugar pine as 

well as re-establishing it in areas suitable to its prolonged existence. Prescriptions will include 

shelterwood with reserve cuts, broadcast burning, planting of rust resistant stock, and pre-commercial 

regeneration release.

In the shelterwood with reserve cuts stands would be thinned to 10-20 or 20-30tpa, leaving the largest 

trees. Reserve trees would be spread across treatment area. Sugar pine or legacy trees would not be 

harvested. 

Quality Early Seral Habitat: The proposed regeneration harvesting will meet all Green Tree Retention 

guidelines outlined within the Northwest Forest Plan providing a minimum of 15% of each unit uncut in a 

combination of clumps and scattered trees (USDA, 1994). An average of 7-8 tpa of live larger trees will 

be left for snag recruitment. All units will be broadcast burned, planted at 150-200 tpa of seral species, 

and seeded with native grass species for big game forage. Some snags may also be created from the 

residual trees.

Post-Harvest Tree Planting

Reforestation would be expected to occur within five years of harvest, and occur from both tree planting 

and natural regeneration. Post-harvest densities would be sufficiently low to allow shade-intolerant 

species such as Douglas-fir to regenerate in addition to increasing diversity with the ingrowth of species 

such as western white pine and western red cedar. Slash and other debris would be utilized as shade and 

as a deterrent to browse by ungulates. Planting in identified root rot pockets would be species that are less 

susceptible to root rot like western red cedar, sugar pine, and white pine. No additional effects would be 

realized by completion of this project because planting has been accounted for in the Forest and Stand 

Structure analysis.

Quality early seral habitat units as well as gaps and some DTRs will be planted with the appropriate 

species. Spacing in units/gaps where early seral habitat is the objective will be planted at a wider spacing 

to keep the unit in the brush/forb stage as long as possible while still meeting the Willamette Forest Plan
Hwy 46 Project Draft EIS Chapter 5

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guidelines requiring a minimum of 150 trees per acre stocking after five years. DTRs will be planted if 

adequate advanced regeneration is not present after harvest.

Non-commercial Treatments

Understory Habitat Enhancement: These treatments include enhancement of understory vegetation and 

meadow enhancement. Units 54, 82, 89, 92, and 560 will thin conifers less than 7 inches dbh to reduce 

shading of ground vegetation. No commercial harvest of conifers is proposed for these units. The 

northwest portion of unit 73 is a dry meadow being encroached by Douglas-fir. Enhancement would 

involve falling and leaving the encroaching trees leaving approximately 190-220 tpa. Unit 560 has been 

partially treated for understory vegetation enhancement due to a fire line that was cut through the unit 

during the 2017 fire season. Some site rehabilitation and further treatment is necessary to achieve 

management objectives.

Riparian Treatments: Units 6, 100, 190, 430, and 520 would have conifers thinned to the stream bank 

for some the portions of streams. In addition, small gaps (less than 1⁄4 acre in size) would be created within 

these treatment areas in locations where it would be the most beneficial to hardwood release. Total acres 

of these gaps would not exceed 4 acres. All portions within the no-harvest buffers will be felled and left. 

Thinning intensities will match the prescription for the rest of the unit.

Hazardous Fuels Treatments: This prescription would reduce fuels in the Wildland-Urban Interface

through non-commercial methods. The primary objectives are to reduce ladder fuels and surface fuel 

loads (horizontal and vertical continuity). Stands with this treatment are generally older (>120yrs old) and 

would focus on cutting trees and shrubs no greater than 10 inches at dbh. Changes to the fuel and stand 

structure would reduce potential wildfire behavior in the Breitenbush Wildland-Urban Interface. 

Treatments include: cutting/thinning, hand piling and burning, chipping, mastication, or firewood.

Post-Harvest Fuels Treatments Description

Slash from logging would be reduced with a variety of methods. 

• Underburning: this would include both broadcast burning and jackpot burning. Variable retention 

regeneration and sugar pine restoration units would be treated with underburning as well as some 

of the wildlife gaps. Units with sugar pine in them would be protected from damage by pulling 

back slash and debris from the bole and by burning only in the fall.

• Grapple piling: a machine grapple is commonly used in ground based units to concentrate slash in 

piles away from standing trees. These piles are burned in the fall.

• Hand pile: this labor intensive treatment will generally be reserved for fuels treatment units 

adjacent to private property and other visually sensitive areas.

• Chipping: another slash disposal method used in visually sensitive areas and around structures.

The implementation of fuels treatment may vary in method from what is the proposed in the alternatives 

to meet standards and guidelines (i.e. grapple piling instead of underburning). However, the implemented 

fuels treatments would remain within the range of effects analyzed in the Environmental Impact 

Statement. 

Hand Treatments and Mechanical Treatment: Hand treatments require manually hand piling created 

slash that is ≥1 inch in diameter and ≥3 feet in length. Mechanical treatments use machines to pile or 

chip/mulch fuels. Slash piles may occur within the unit or at landing(s). Piles would generally be placed 
Hwy 46 Project Draft EIS Chapter 5

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in locations to minimize the damage of residual standing snags or live trees; however some piles could be 

located to cause tree mortality to create snags for wildlife habitat. Piles would then be burned at a later 

date after the slash has sufficiently dried and conditions would not allow fire to spread to surrounding 

area.

Hand, grapple, and landing piles are covered with approved plastic following construction. This creates a 

drier pocket of fuel in the middle of the pile and enables them to be burned in the late fall or early winter 

when there is very low risk of the piles spreading into other fuels. 

Post-Harvest Underburn: Post-harvest underburns are intended to reduce fuels created by harvest 

activities and help promote structural and biological diversity in stands. Underburning would comply with 

Forest Plan standards and guidelines in regards to consumption of fuels and maintaining down-woody 

material, duff cover, and snags. Spring-like burning conditions would reduce the risk of burning large 

woody material because of high moisture content and provide conditions for lower fire intensity meeting 

fuels treatment standards and guidelines. An objective for the post-harvest underburning would be to 

minimize overstory tree mortality; however, some mortality up to 10% would be acceptable. Mortality 

trees that occur adjacent to roads may be removed for safety reasons.

Roads Treatments

Road Maintenance: For all action alternatives, existing forest roads needed for harvest activity would be 

maintained to allow safe access to harvest areas and to reduce adverse impacts to resources. Road 

maintenance associated with haul routes would result in decreased maintenance cost, improved safety, 

and reduced potential for resource damage related to degraded roads that would be needed for current and 

future resource management. Road maintenance activities may include felling danger trees, clearing and 

grubbing, replacing drainage structures, asphalt pavement patching, repairing holes in the roadbed, 

reconstructing ditches, application of dust abatement material, and placement of aggregate surfacing. 

Temporary Road Construction and Decommissioning: Temporary roads would be created in both 

action alternatives. These roads would be placed in areas to minimize impacts to resources and would be 

decommissioned and seeded by the purchaser after use and before the sale is closed. Previously disturbed 

sites would be utilized where possible. The initial effects of the construction would be compacted soils; 

however those effects would be offset by decommissioning. The effects of decommissioning would be the 

same as subsoiling, and is generally beneficial to the residual stand because of reduced compaction and 

root growth, so increased growth is possible along skid trails and landings that have treatment.

Road Realignments: For all action alternatives, road realignments are needed to facilitate haul and for 

resource protection. In these circumstances, new portions of roads will be constructed by clearing of 

vegetation, installing ditches and drainage features, grading and compacting base material and surface 

material. The unused portion of the road will have drainage features removed and the footprint subsoiled 

and seeded. Forest Service construction standards will always be followed.

Short Lake Reroute: Post-sale activities along FSR 4600-040 would include the decommissioning of 

approximately 0.4 miles of FSR 040 will be decommissioned and rehabilitated to improve natural 

hydrologic function around Short Lake and reduce road maintenance. FSR 4600-059 would be realigned 

to provide access around the decommissioned portion of FSR 040.
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Appendix B – Detailed List of Project Activities by Unit for the Proposed 

Action

Definitions for the following table:

Harvest Prescriptions: Skips: Riparian and Non-Riparian Skips; Thin: Riparian and Non-Riparian Thinning; DTR: Dominant Tree Release;

SPSW: Sugar Pine Shelterwood Harvest; NCT: Non-commercial treatment

Logging Systems: H – Helicopter, Sk – Skyline, G – Ground Includes harvested acres, not skips

Post-Harvest Fuel Treatments: MT – Mechanical Treatment, HP – Hand Pile, UB – Underburn actual numbers would be dependent on feasibility 

and funding at harvest

Alternative 3 has same unit prescriptions. Units for Alternative 3 are: 1, 2, 3, 5, 6, 7, 11, 19, 20, 23, 25, 26, 30, 33, 34, 35, 38, 42, 44, 45, 46, 47, 

48, 49, 51, 52, 53, 54, 55, 56, 57, 58, 59, 60, 61, 62, 63, 64, 69, 70, 71, 72, 73, 74, 75, 76, 77, 78, 80, 82, 89, 92, 100, 110, 120, 130, 140, 140a, 

160, 170, 180, 190, 200, 210, 220, 240, 250, 260, 270, 280, 290, 300, 310, 320, 340, 350, 360, 370, 380, 390, 400, 410, 420, 430, 440,450, 460, 

470, 480, 490, 510, 520, 530, 540, 560, 570. Alternative 3 units are indicated with an * in the table below.

Unit Acres

Harvest Prescription Acres

Logging System Acres

Post-Harvest Fuel 

Treatment 

Acres Est. Vol.

(MBF)

Skips Thin EarlySeral Meadow 

Restoration DTR Gaps SPSW NCT H Sk G MT HP UB

1* 43 19 24 24 24 115

2* 33 0 30 3 33 33 117

3* 13 0 13 13 3 36

5* 39 20 19 17 2 10 95

6* 66 9 52 3 2 32 25 25 32 463

7* 19 4 15 15 12 207

11* 17 1 16 16 10 49

12 24 3 19 2 18 3 19 533

13 31 11 20 20 4 612

14 15 2 13 13 13 679

16 64 18 42.25 .75 3 42 4 25 1371

17 20 4 16 16 16 519

18 46 22 21.25 .75 2 14 10 20 473

19* 71 54 17 17 17 68

20* 13 0 12 1 13 102

21 59 4 50.5 1.5 3 34 21 15 20 1386
Hwy 46 FEIS Appendix 

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Unit Acres

Harvest Prescription Acres

Logging System Acres

Post-Harvest Fuel 

Treatment 

Acres Est. Vol.

(MBF)

Skips Thin EarlySeral Meadow 

Restoration DTR Gaps SPSW NCT H Sk G MT HP UB

22 56 16 36 1 3 26 14 39 1913

23* 41 24 14 3 4 13 17 448

24 47 20 25.5 1.5 7 20 9 524

25* 23 4 19 13 6 4 2 25

26* 10 4 5.75 .25 6 4 78

27 31 10 19.5 1 .5 17 4 21 289

28 31 15 13 3 12 4 4 2 364

29 8 4 0 4 4 0

30* 8 0 7.5 .5 7 1 8 30

31 22 5 17 17 17 199

32 63 6 52.5 1.5 3 57 56 1045

32a1 11 3 8 8 315

33* 39 2 33 4 34 3 37 560

34* 13 2 11 11 75

35* 24 8 10 6 16 16 248

38* 15 5 9.5 .5 3 7 7 99

39 5 0 3 2 5 5 94

40 6 0 1 5 6 6 129

41 16 2 13 1 4 10 8 214

42* 27 7 19 1 10 10 14 396

44* 12 4 8 8 8 47

45* 26 7 19 15 4 16 528

46* 7 0 7 7 7 68

47* 71 9 53.5 1.5 7 52 10 56 964

48* 23 4 17.5 1.5 19 1 105

49* 13 0 12 1 12 1 3 76

50 21 0 21 20 1 3 187

51* 38 2 34.5 1.5 29 7 5 20 143

52 17 2 14.25 .75 15 193

53* 24 9 14 1 15 74

54* 25 0 0 25 10 0

 1 Unit 32a is meadow restoration. Encroaching conifers will be removed on 8 acres. 
Hwy 46 FEIS Appendix 

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Unit Acres

Harvest Prescription Acres

Logging System Acres

Post-Harvest Fuel 

Treatment 

Acres Est. Vol.

(MBF)

Skips Thin EarlySeral Meadow 

Restoration DTR Gaps SPSW NCT H Sk G MT HP UB

55* 34 5 29 22 7 10 398

56* 24 12 11 1 12 7 86

57* 4 0 4 4 1 14

58* 10 0 9.5 .5 2 8 8 301

59* 5 3 0 2 2 2 71

60* 11 1 9.5 .5 5 5 5 147

61* 43 2 39.5 1.5 30 11 8 474

62* 29 8 21 21 21 171

63* 14 2 12 12 12 200

64* 68 33 35 35 35 557

69* 10 4 5.7 .3 6 6 243

70* 15 0 14 1 15 15 107

71* 44 0 43 1 25 19 19 6 251

72* 17 0 15.5 1.5 14 3 4 117

73* 63 12 49.5 1.5 51 51 480

74* 83 22 60 1 56 5 61 430

75* 26 12 14 12 2 8 2 161

76* 8 3 5 5 5 22

77* 31 1 28.5 1.5 23 7 6 2 310

78* 25 0 23 2 20 5 5 2 249

80* 43 0 42.5 .5 27 16 15 281

81 2 0 2 2 1 27

82* 25 0 25 5 5 0

83 107 13 30 1 31 32 44 18 83 963

84 83 24 47 12 59 59 782

87 1 0 1 1 1 4

89* 17 0 0 17 5 0

92* 43 0 0 43 15 0

93 47 5 37 5 37 5 42 199

94 40 6 28 6 30 4 34 708

95 90 21 53 16 62 7 30 772

96 25 3 18 4 22 22 463

97 20 0 20 20 413
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Unit Acres

Harvest Prescription Acres

Logging System Acres

Post-Harvest Fuel 

Treatment 

Acres Est. Vol.

(MBF)

Skips Thin EarlySeral Meadow 

Restoration DTR Gaps SPSW NCT H Sk G MT HP UB

100* 90 29 60.5 .5 40 21 34 625

110* 60 13 46.5 .5 2 45 47 222

120* 21 3 18 18 3 76

130* 45 12 33 8 25 30 182

140* 63 20 39.5 3.5 33 10 43 796

140a* 19 4 15 15 15 216

150 33 4 26 3 29 29 486

160* 19 2 15.75 1.25 17 16 341

170* 160 27 0 133 133 0

180* 31 2 23 6 29 29 414

190* 51 16 34 1 14 21 30 591

200* 55 6 45.25 .75 3 28 21 25 1060

210* 4 0 0 4 4 0

220* 75 36 37.75 1.25 39 39 941

240* 28 0 26.5 1.5 22 6 6 414

250* 11 1 9.5 .5 10 10 175

260* 27 3 23 1 9 15 15 287

270* 35 3 0 32 32 0

280* 52 5 45.25 1.75 47 20 1114

290* 90 48 40 2 37 5 5 25 555

300* 51 20 29.5 1.5 15 16 25 392

310* 12 1 10.5 .5 11 13

320* 28 10 16.5 1.5 18 194

340* 31 7 23 1 24 14 599

350* 16 9 6.5 .5 7 72

360* 16 5 10.5 .5 5 6 5 156

370* 32 8 23 1 24 24 357

380* 27 7 19 1 20 314

390* 13 5 7.5 .5 8 79

400* 26 11 14.25 .75 15 139

410* 34 4 28.5 1.5 20 10 10 530

420* 11 1 9.25 .75 10 10 125

430* 17 3 13 1 14 14 218
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Unit Acres

Harvest Prescription Acres

Logging System Acres

Post-Harvest Fuel 

Treatment 

Acres Est. Vol.

(MBF)

Skips Thin EarlySeral Meadow 

Restoration DTR Gaps SPSW NCT H Sk G MT HP UB

440* 17 10 6.75 .25 7 45

450* 27 4 22 1 18 5 8 2 23 130

460* 8 2 5.75 .25 5 1 117

470* 9 4 4.75 .25 5 5 63

480* 37 2 32.5 2.5 27 8 33 665

490* 18 2 15.25 .75 16 16 317

510* 8 1 6.75 .25 7 7 124

520* 43 14 27.5 1.5 29 29 414

530* 26 3 21 2 23 23 433

540* 48 6 40.5 1.5 42 42 350

560* 45 0 0 45 45 0

570* 24 0 0 24 0

Total 4,046 910 2488.45 43 8 72.75 47.8 92 384 317 1510 926 905 230 1107 39,997
Hwy 46 FEIS Appendix 

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Appendix C – Compliance with Laws, Regulations and 

Executive Orders

The National Environmental Policy Act (NEPA), 1969 – NEPA establishes the format and content 

requirements of environmental analysis and documentation. Preparation of the Hwy 46 FEIS was 

prepared in full compliance with these requirements.

The National Forest Management Act (NFMA), 1976 –All proposed timber harvest units are planned 

to occur on suitable land. If regeneration harvest is implemented the sites would be capable of restocking 

within 5 years of harvest by either natural or artificial means. Proposed commercial thinning would 

increase the rate of growth of remaining trees. Some locations would favor species or age classes most 

valuable to wildlife. The resultant reduced stress on residual trees would make treated stands less 

susceptible to pest-caused damage. Design features have been identified to protect site productivity, soils, 

and water quality.

The burning of activity fuels would reduce long-lasting hazards from wildfire and reduce the risk of pest 

outbreaks over the project area as a whole. Air quality would be maintained at a level that would meet 

applicable Federal, State, and local standards. All proposed activities would provide sufficient habitat to 

maintain viable populations of fish and wildlife. Critical habitat for threatened or endangered species 

would be protected through avoidance. The action alternatives would accelerate development of forest 

habitats that are currently deficient within the analysis area to enhance the diversity of plant and animal 

communities in the long-term. See discussions under the applicable resource sections above, for further 

support that proposed activities that would comply with the seven requirements associated with vegetative 

manipulation (36 CFR 219.27(b)), riparian areas (36 CFR 219.27(e)), and soil and water (36 CFR 

219.27(f)).

Forest Plan Consistency – Actions analyzed in the Hwy 46 FEIS are consistent with a broad range of 

Forest Plan Standards and Guidelines that have been discussed and disclosed throughout the document. 

The timber stand treatments associated with the project are consistent with the goals and management 

direction analyzed in the Willamette National Forest Land and Resource Management Plan FEIS and 

Record of Decision. Road improvements are designed to be consistent with the 1994 Northwest Forest 

Plan amendments to the Forest Plan and the Aquatic Conservation Strategy objectives.

Northwest Forest Plan Aquatic Conservation Strategy - The Aquatic Conservation Strategy (ACS) is 

an integral part of the Northwest Forest Plan and was developed to maintain and restore the ecological 

health of watersheds and aquatic ecosystems on public lands through implementation of four components: 

1) riparian reserves 2) key watersheds 3) watershed analysis 4) watershed restoration. Based on the 

analysis presented in this FEIS and Appendix E, the ACS Objectives would be met in each alternative.

The Preservation of Antiquities Act, June 1906 and the National Historic Preservation Act, as 

amended, October 1966 – Section 106 of the National Historic Preservation Act (NHPA) of 1966 

(amended in 1976, 1980, and 1992) is the foremost legislation governing the treatment of historic 

properties (a.k.a. heritage or cultural resources) during project planning and implementation. Other legal 

framework considered the effects of its actions on heritage resources is listed below:

36 CFR800 (Protection of Historic Properties), 

36 CFR 63 (Determination of Eligibility to the National Register of Historic Places), and 
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36 CFR 296 (Protection of Archaeological Resources), and

Executive Order 13007 – Sacred Sites

The 1995 Programmatic Agreement (PA) among the USDA Forest Service PNW, the Advisory Council on 

Historic Preservation, and the Oregon State Historic Preservation Officer (SHPO) Regarding Cultural 

Resource Management in the State of Oregon by the USDA Forest Service, (amended in 2004), provides 

a process by which the Forest Heritage Specialist may certify that the Forest has complied with Section 

106 of NHPA for the project.

In accordance with this PA, an appropriate inventory was conducted during the summers of 2013, 2014 

and 2015. All known cultural sites in the Area of Potential Effect (project area) were protected by 

avoidance, resulting in a determination of “No Historic Properties Affected” on December 28, 2016. 

Documentation was provided by SHPO and copies have been retained in the Forest and District Heritage 

files.

Clean Air Act Amendments, 1977 – The alternatives are designed to meet the National Ambient Air 

Quality Standards through avoidance of practices that degrade air quality below health and visibility 

standards. This project is consistent with by the 1990 Clean Air Act and the 1977 Clean Air Act and its 

amendments (See Chapter 3.2 and 3.12).

The Clean Water Act, 1987 – This act establishes a non-degradation policy for all federally proposed 

projects. Compliance with the Clean Water Act would be accomplished through planning, application and 

monitoring of Best Management Practices (BMPs). Based on the analysis presented in this FEIS, TMDL 

requirements for the Breitenbush River Basin would be met in each alternative (See Chapter 3.4).

The Endangered Species Act (ESA), December 1973 – The ESA establishes a policy that all federal 

agencies would seek to conserve endangered and threatened species of fish, wildlife and plants. 

Biological Evaluations for plants and wildlife have been prepared, which describes possible effects and 

impacts of the proposed action on sensitive, and other species of concern that may be present in the 

project area. A Biological Assessment (BA) was prepared for the northern spotted owl, and for spring 

Chinook salmon. 

Endangered Species Act (ESA) formal consultation with the USFWS for the Northern Spotted Owl was

completed in 2017 and evaluated by the USFWS. The Biological Assessment for Willamette Planning 

Province of Oregon for FY 2018 LAA Projects within the Willamette National Forest with a Potential to 

Modify Habitat and/or Disrupt Northern Spotted Owls of LAA Projects with the Potential to Modify the 

Habitat and/or Disrupt Northern Spotted Owls – Willamette Planning Province – FY 2016/17 was used to 

determine effects. A biological assessment was submitted August 1, 2017 and a biological opinion was 

signed August 31, 2017 which includes the Hwy 46 project. This project would need to be completed 

prior to a final decision notice being signed for this project. The determination expected to be made in the 

Biological Assessment for the Hwy 46 project, which would be completed and concurrence received from 

the USFWS prior to the final decision notice is signed, is this project may affect and is not likely to 

adversely affect spotted owls by disturbance.

Upper Willamette River spring Chinook salmon are listed as threatened on the Endangered Species list. 

This species occurs in the Breitenbush River. This analysis found that the Hwy 46 Project “may affect, not 

likely to adversely affect” Upper Willamette spring Chinook salmon. In order for the Forest Service to 

obtain authorization we must conduct consultation with the fish agencies under Section 7 of the ESA.

Magnuson-Stevens Fishery Conservation and Management Act, 1976 (MSA) – The MagnusonStevens Fishery Conservation and Management Act (MSA) requires the identification of habitat 
Hwy 46 FEIS Appendix 

293

“essential” to conserve and enhance the federal fishery resources that are fished commercially. The 

Pacific Fishery Management Council (PFMC) designated Essential Fish Habitat (EFH) for Chinook, 

coho, and Puget Sound pink salmon in their Amendment 14 to the Pacific Coast Salmon Plan, issued 

September 27, 2000. The interim final rule implementing the EFH provision of the MSA (62 FR 66531) 

requires federal agencies to consult with the National Marine Fisheries Service for any action that may 

adversely affect EFH. 

Essential fish habitat under the Magnuson-Stevens Fishery Conservation and Management Act is 

designated in all areas except above impassible dams (Big Cliff and Detroit Dams), and natural migration 

barriers. The Magnuson-Stevens Fishery Conservation and Management Act reauthorization in 1996 

established a new requirement for essential fish habitat that requires Federal agencies to consult with the 

National Marine Fisheries Service on activities that may adversely affect essential fish habitat. Essential 

fish habitat for the Pacific coast salmon fishery means those waters and substrate necessary for salmon 

production needed to support a long-term sustainable salmon fishery and salmon contributions to a 

healthy ecosystem. The species designated in the Breitenbush River is spring Chinook salmon.

Technically the Breitenbush River upstream Big Cliff and Detroit Dams is not considered EFH but since 

reauthorization of the act the USACE has constructed an adult fish collection facility and is actively 

transporting Chinook salmon above the dam. Therefore, we treat the Breitenbush upstream of Detroit 

Dam as EFH. This project would not adversely affect EFH because of the no cut buffers we established 

along EFH fish bearing streams, project design elements, and the implementation of Best Management 

Practices (BMPs).

Federal Mine Safety and Health Act of 1977, Public Law 91-173, as amended by Public Law 95-164.

Development of Rock Quarries would conform to the requirements of the act, which sets forth mandatory 

safety and health standards for each surface metal or nonmetal mine. The purpose for the standards is to 

protect life by preventing accidents and promoting health and safety.

Inventoried Roadless Areas and Wilderness – All treatments in the IRA would maintain and meet the 9 

roadless area characteristics in CFR 294.11 Best Management Practices and Design Elements would be in 

place to protect: soil, water, and air; plant and animal communities and habitat for TES species; classes of 

recreation and landscapes; cultural properties and unique areas.

Alternative 2 and 3 would have temporary adverse effects due to increased noise during harvest activity. 

There are no direct benefits to Wilderness from any of the proposed alternatives.

Prime Farmland, Rangeland, and Forestland – No prime farmland, rangeland, or forestland occurs 

within the project area. 

Survey and Manage Species – The action alternatives comply with the Northwest Forest Plan as 

amended by the 2001 Record of Decision and Standards and Guidelines for Amendments to the Survey 

and Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines. Pre-disturbance 

surveys were conducted and site management applied consistent with the January 2001 species list. 

Management Indicator Species (Aquatic) – The Willamette Forest Plan recognized anadromous and 

resident salmonids as economically important species and designated them as management indicator 

species for riparian habitat and water quality. The most common salmonid sport fish that occurs on the 

Detroit Ranger District is coastal cutthroat trout. The Hwy 46 project would maintain and improve habitat 

conditions for aquatic Management Indicator Species in the project area. Therefore, the Hwy 46 project 

would not contribute to a negative trend in viability of this species. 
Hwy 46 FEIS Appendix 

294

Management Indicator Species (Terrestrial) – The Willamette Forest Plan recognized elk and deer as 

economically important species that are commonly hunted, and designated them as management indicator 

species for winter range. Designated management indicator species for old growth and mature conifers 

are pileated woodpecker, marten, and northern spotted owl. The bald eagle was selected as a management 

indicator species for old growth conifers near large bodies of water, and the peregrine falcon was selected 

as a management indicator species for cliff nesting habitat. The Hwy 46 project would maintain habitat 

conditions for elk, deer, pileated woodpeckers, marten, bald eagles and peregrine falcons in the project 

area. The Hwy 46 project would not contribute to a negative trend in viability for any of the terrestrial

wildlife management indicator species. 

Executive Orders 11988 and 11990: Floodplains and Wetlands – Executive Order 11988 requires 

government agencies to take actions that reduce the risk of loss due to floods, to minimize the impact of 

floods on human health and welfare, and to restore and preserve the natural and beneficial values served 

by floodplains. Proposed harvest treatments would not occur within 100-year floodplains. Executive 

Order 11990 requires government agencies to take actions that minimize the destruction, loss, or 

degradation of wetlands. Streamside riparian areas, seeps, springs, and other wet habitats exist in the 

project area. These areas would be either avoided, or managed according to the amended Willamette 

Forest Plan Standards and Guidelines. Riparian Reserves would also be protected with design features. As 

a result, proposed treatments would be consistent with Executive Orders 11988 and 11990.

Executive Order 12898: Environmental Justice – Executive Order 12898 requires that federal agencies 

adopt strategies to address environmental justice concerns within the context of agency operations. With 

implementation of either action alternatives, there would be no disproportionately high and adverse 

human health or environmental effects on minority or low-income populations. Nearby communities 

would mainly be affected by economic impacts connected with contractors implementing harvest, road 

reconstruction, tree thinning, planting, and other fuels treatment activities. Racial and cultural minority 

groups could also be prevalent in the work forces that implement activities. Contracts contain clauses that 

address worker safety.

Executive Order 12962: Recreational Fishing – The June 7, 1995, Executive Order requires 

government agencies to strengthen efforts to improve fisheries conservation and provide for more and 

better recreational fishing opportunities, and to develop a new policy to promote compatibility between 

the protection of endangered species and recreational fisheries, and to develop a comprehensive 

Recreational Fishery Resources Conservation Plan. Proposed activities in the project area would promote 

the restoration of riparian function in stands in corridor and headwater aquatic reserves and to develop 

additional large wood to stream reaches that currently lack adequate amounts. This would improve fish 

habitat and would provide better future fishing opportunities for the public.

Executive Order 13186: Migratory Birds – Migratory birds are protected under the Migratory Bird 

Treaty Act of 1918 (16 U. S.C. 703-704). The U.S. Fish and Wildlife Service is the lead federal agency 

for managing and conserving migratory birds in the United States. However, under Executive Order (EO) 

13186, all federal agencies are charged with the conservation and protection of migratory birds. A 

Memorandum of Understanding (MOU 2008) between the Forest Service and U.S. Fish and Wildlife 

Service requires, during NEPA planning, that the FS, to the extent practical, evaluate and balance longterm benefits of projects to migratory birds against any short- or long-term adverse effects. It also requires 

the FS to consider approaches, to the extent practical, for identifying and minimizing take of migratory 

birds that is incidental to otherwise lawful activities. Region 6 has compiled some information to assist 

biologists in disclosing effects to avian species during NEPA planning (Forest Service and Bureau of 

Land Management 2013). Effects to FS sensitive birds, federally ESA listed birds, birds that are 

Management Indicator Species and migratory bird species that have been identified by USFWS as 
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295

Species of Conservation Concern in the Northern Pacific Forest (USFWS 2008) and that have habitat in 

the proposed treatment units are addressed in Chapter 3. 

Seasonal restrictions are recommended in the Hwy 46 design features (Table 13) on specific units to 

protect owls. This would minimize disturbances to nesting migratory birds and reduce the likelihood of 

harm to individual birds. Design features to retain existing snags where possible, and to retain live trees, 

create snags, and fall trees for dead wood sources would provide structural features migratory birds would 

use. 

Executive Order 13443: Facilitation of Hunting Heritage and Wildlife Conservation – August 17, 2007, 

Executive Order requires Federal agencies “to facilitate the expansion and enhancement of hunting 

opportunities and the management of game species and their habitat.” The proposed creation and 

enhancement of early seral habitat in both action alternatives in the project area would improve forage for 

game species and provide better hunting opportunities for the public.

Other Jurisdictions – There are a number of other agencies responsible for management of resources 

within the project area. The Oregon Department of Fish and Wildlife is responsible for management of 

fish and wildlife populations, whereas the Forest Service manages the habitat for these animals. The 

Oregon Department of Fish and Wildlife has been contacted regarding this analysis and Nancy Taylor, a 

biologist with the agency, has participated in early collaboration and has attended public field trips.

Proposed harvest treatments within riparian areas have been designed to comply with “Sufficiency 

Analysis for Stream Temperature – Evaluation of the adequacy of the Northwest Forest Plan Riparian 

Reserves to achieve and maintain stream temperature water quality standards” (USDA Forest Service and 

USDI BLM, 2004). This document was prepared in collaboration with Oregon Department of 

Environmental Quality and United States Environmental Protection Agency to provide documentation of 

Northwest Forest Plan compliance with the Clean Water Act with regard to state water quality standards 

for stream temperatures. As such, it redeems several of the Forest Service responsibilities identified in a 

“Memorandum of Understanding between USDA Forest Service and Oregon Department of 

Environmental Quality To Meet State and Federal Water Quality Rules and Regulations” (USDA Forest 

Service and Oregon DEQ, May 2002). The Sufficiency Analysis provides current scientific guidance for 

management of riparian vegetation to provide effective stream shade, including appropriate methods of 

managing young stands for riparian objectives other than shade, such as production of large wood for 

future recruitment.

Oregon Department of Environmental Quality and the Oregon Department of Forestry are responsible for 

regulating all prescribed burning operations. The USDA Forest Service Region 6 has a Memorandum of 

Understanding with Oregon Department of Environmental Quality, Oregon Department of Forestry, and 

the USDI Bureau of Land Management regarding limits on emissions, as well as reporting procedures. All 

burning would comply with the State of Oregon's Smoke Management Implementation Plan and, for 

greater specificity, see the memorandum of understanding mentioned above.

The project area includes portions of the Breitenbush River and the South Fork Breitenbush River which 

have been determined to be eligible for inclusion into the national Wild and Scenic River System. Until 

suitability is determined, the area within 1⁄4 mile on either side of the Breitenbush River is to be managed 

to meet Wild and Scenic River (Recreation) Standards and Guidelines as outlined in Management Area 6c

in the Willamette National Forest Land and Resource Management Plan (1990). The actions proposed in 

Alternatives 2 and 3 will not jeopardize the eligibility of either the Breitenbush River or South Fork 

Breitenbush River for inclusion in the national Wild and Scenic River System.
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Energy Requirements and Conservation Potential – Some form of energy would be necessary for 

projects requiring use of mechanized equipment. Commercial thinning and some partial cutting units 

would involve both heavy and small machines for yarding logs during the implementation period. 

Projects such as road reconstruction and maintenance could require heavy machinery for a small amount 

of time. Both possibilities would result in minor energy consumption. Alternatives that harvest trees could 

create supplies of firewood as a by-product, which would contribute to a supply of energy for the local 

community for home heating.
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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
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Appendix E - An Evaluation of Activities Authorized by 

the Hwy 46 Project FEIS for Consistency with the 

Aquatic Conservation Strategy

Introduction

The Aquatic Conservation Strategy was developed to restore and maintain the ecological health of 

watersheds and aquatic ecosystems contained within them on public lands. A goal of this strategy is to 

maintain a "natural" disturbance regime. In addition, management activities must comply with nine 

objectives that are included in the strategy and any associated standards and guidelines. A variety of 

tactics to accomplish these goals and objectives are incorporated into four primary components. These 

components are:

• Riparian Reserves

• Key Watersheds

• Watershed Analysis

• Watershed Restoration

These four components, along with Late Successional Reserves, are designed to operate together to 

maintain and restore the productivity and resiliency of riparian and aquatic ecosystems (Record of 

Decision for Amendments to Forest Service and Bureau of Land Management Planning Documents 

Within the Range of the Northern Spotted Owl - USFS, BLM 1994, (ROD), pages B9-B12).

The Four Components

1. Riparian Reserves

The Northwest Forest Plan defined Riparian Reserves as “portions of watersheds where ripariandependent resources receive primary emphasis and where special standards and guidelines apply” 

(ROD page B12). Riparian Reserves include those portions of a watershed directly coupled to streams, 

ponds, lakes, and wetlands - that is, the portions of a watershed required for maintaining hydrologic, 

geomorphic, and ecologic processes that directly affect standing and flowing water (ROD pgs. B-12 

and B-13).

The Riparian Reserve network in the Breitenbush watershed totals over 27,925 acres which is 40% of 

the entire land base (Breitenbush Watershed Analysis update, 2014). The Watershed Analysis made no 

final recommendations to adjust riparian reserve widths for the streams in the watershed, retaining the 

initial reserve widths (of two site potential tree heights for fish bearing streams and one site potential 

tree height for all other streams) from the ROD for all streams.

During the analysis for the Hwy 46 Project, no reductions of Riparian Reserve widths along any 

streams were proposed. However, silvicultural treatments were proposed within Riparian Reserves for 

several units in order to improve structural diversity and vegetative diversity. Timber harvest is 

prohibited within Riparian Reserves but there are 3 exceptions provided in the ROD. One of which is 

Standard and Guideline TM-1(c). 
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Standards and Guidelines (S&Gs)

TM-1(c). Apply silvicultural practices for Riparian Reserves to control stocking, reestablish and 

manage stands, and acquire desired vegetation characteristics needed to attain Aquatic 

Conservation Strategy objectives.

Standard and Guideline TM-1(c) in the Northwest Forest Plan (1994) provides direction on when 

silvicultural activities can take place in Riparian Reserves. Our task is to review all the Riparian Reserves 

in the project area and at the landscape level to determine if treatment is warranted. Based on our field 

investigations and a landscape level analysis of hardwoods in the Breitenbush watershed we developed 

recommendations for each riparian reserve. The Riparian Reserves where we propose treatment (thinning, 

gaps in the secondary shade zone, and gaps near the stream channel) are previously managed stands (i.e. 

plantations) that are densely stocked and had little or no hardwoods in the reserve.

There are no cut buffers of varying width (30 feet to 340 feet) prescribed for every stream in the project 

area. Thinning Riparian Reserves means that there will be a short-term, localized effect on the supply of 

coarse woody material and ACS objective 8 states that we maintain and restore amounts and distributions 

of coarse woody debris sufficient to sustain physical complexity and stability. The plantations where we 

propose thinning are dense and there is a need to control stocking in order to maintain a healthy stand of 

trees. Densities in proposed unit Riparian Reserves range from 75 to 397 TPA, averaging 200 TPA. In 

contrast, recent forest research in the Coast Range and Western Cascades indicates that existing old 

growth stands developed with natural stand densities of 40 to 60 conifers per acre (Tappeiner et al 1997; 

Poage & Tappeiner 2002). Having a no-cut buffer adjacent to every stream would maintain a high level of 

trees per acre compared to what has been found in these studies. In the thinned Riparian Reserves there 

would still be 40-60 tpa similar to what was found in the studies, with the exception of Unit 32a which 

would be thinned to 5-10 tpa to achieve meadow restoration objectives. Natural stand densities for units 

with Riparian reserves range from 86 to 293 tpa, averaging 165 tpa. The majority of the natural stands 

that are proposed for treatment are fire-regenerated stands and in similar condition to dense plantations. 

The previously managed stands proposed for treatment in the Hwy 46 Project Area were harvested and 

replanted using direction that pre-dates the Willamette Land and Resource Management Plan (1990) and 

prior to the Northwest Forest Plan (1994). As a result, the majority of these forest stands were set on a 

management-induced trajectory that has led to artificially dense, conifer-dominated stands, with tree 

densities above the range of natural variability expected in this area. When we conducted field 

investigations we based the no cut buffer on stream size, stream class, gradient, channel complexity, and 

how functional the existing coarse woody material was in the stream channel. We expect that the amount 

of woody material left in the no cut buffer and the remainder of the Riparian Reserve would be sufficient 

to sustain physical complexity and stability. All but 3 units along fish bearing streams have wider no cut 

buffers (i.e. from 100 feet to 1 site potential tree height (172 feet) or 2 site potential tree heights(344 feet) 

so thinning in these riparian reserves would have limited effects on fish and caddisflies. The 3 units along 

fish bearing streams have a fall and leave silvicultural prescription to accelerate riparian diversity.

The Breitenbush Watershed Analysis (1996) described past conditions, current conditions, and trends in 

riparian vegetation in the watershed. Fires, road construction, and timber harvest on some land types, and 

flooding can accelerate debris flow occurrence. Conditions of riparian stands will depend on previous 

timing of fires and pulses of debris flows. It is reasonable to speculate that the extensive fires of the Late1800s would have created open riparian stands in many of the Breitenbush drainages. Further, the fires 

combined with great flood of 1861 would have triggered debris flows in many first to third order streams 

during that period, with some affecting larger streams. By 1900, many small riparian areas would have 

shown mixed conifer / red alder stands with conifer about to go into a period of rapid height growth. For 

larger streams recovering from the impacts of 1800s fires and the 1861 flood, some red alder, cottonwood, 

or willow may have persisted near the active channel shelf, but conifers would have established and by 
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the early 1900s have overtopped the deciduous trees to dominate floodplains. By the time of the 45 year 

flood even in 1945, most of the stands would have lost remnants of red alder and little evidence of these 

events would remain. With fire suppression few large fires have occurred since the early 1900s. It is 

estimated that 160 fires have been suppressed in the watershed since the arrival of the Civilian 

Conservation Corps (CCC) in the 1930s with the majority being caused by lightning. 

The Breitenbush Watershed Analysis (1996) also discussed trends in riparian vegetation. Given the 

Riparian Reserve network established by the Northwest Forest Plan (1994), the riparian areas within the 

watershed will increase dominance in the conifer communities. Unlogged areas will continue recovery 

from the 1964 flood (the flood of record in the Breitenbush Watershed). Alder stands initiated during the 

1945 and 1964 floods will persist until the middle of the next century when they will decline under 

emerging conifers. Older floodplains reset during the 1861 flood will be old growth by that time. A major 

flood would reset succession along floodplains and would affect the least confined valleys the most. In 

the absence of large fires, however, the disturbance would be evident for a century.

We conducted a “hardwood analysis” for the all the Riparian Reserves in the Breitenbush River 

watershed. For this analysis we used satellite imagery (WorldView 2) collected on July 19, 2013 and 

Google Earth imagery. The analysis found that 4.6% of the Riparian Reserves in the Hwy 46 project area 

had a deciduous and deciduous/shrub component. Deciduous leaves have a higher nutritional quality than 

coniferous needles. Near stream treatments (comprising 20 acres in total) along certain streams we expect 

will result in hardwoods that will colonize the sites and if not we would plant hardwoods (e.g. red alder, 

vine maple, and big leaf maple) to improve the quality of allochthonous sources of energy for the aquatic 

community. These near stream treatments would not be commercial and are therefore not “timber 

harvest.” All trees felled for these near stream treatments would be left on site.

At a watershed level, coarse woody debris levels will be maintained. There are 13,502 acres of Riparian 

Reserve in the project area. Alternative 2 and 3 would thin approximately 6.0% and 4.5%, respectively, of 

the Riparian Reserve acres in the project area. The action alternatives would create 20 acres of streamside 

treatments which is approximately 0.0001% of riparian reserve acres in the project area. The trees that are 

cut to create the near stream treatments would be left on site to provide structure and down woody 

material.

The recommendations made for silvicultural treatments were based on the need to control stocking and 

achieve the desired vegetation and structural characteristics needed in those plantations in order to 

improve stand vigor and the nutritional quality of organic matter used by the stream community. Also, we 

have been suppressing wildfires since the early 1900s, eliminating an important environmental 

disturbance from the landscape. We believe that this lack of wildfire is one of the contributing factors for 

the low percentage of hardwoods in the Breitenbush watershed and due to this we are outside the range of 

natural variability.

2. Key Watersheds

The Northwest Forest Plan created an overlay of Key Watersheds that are intended to provide refugia for 

at-risk stocks of anadromous salmonids and resident fish species. Refugia are a cornerstone of the 

conservation strategy for these species, consisting of watersheds that provide high quality habitat or are 

expected to provide habitat. Two different levels of protection, or tiers, are identified, as well as non-Key 

watersheds (ROD page B19). In key watersheds, completion of a watershed analysis is required prior to 

most management activities. While not officially designated a key watershed under the NWFP, the 

Breitenbush is managed as a Key Watershed through an agreement with the City of Salem, due its source 

as municipal drinking water supply and re-introduction of ESA-listed andoramous fish through the truck 

and haul program. One of the important components of Key Watershed is that there must be no net gain in 
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302

roads. If new roads need to be built, then an equivalent mileage must be decommissioned. This project 

will result in a net decrease in road mileage of 1.99 miles. 

Standards and Guidelines

No new roads would be built in roadless areas in Key Watersheds.

The Hwy 46 project is consistent with this S&G. No new roads are proposed to be constructed in 

roadless areas.

Timber harvest cannot occur in Key Watersheds prior to completing a watershed analysis.

A watershed analysis was completed for the Breitenbush watershed in 1996 and was updated in 

2014.

Preliminary data collection at the nearby H.J. Andrews Experimental Forest in 2013 support the 

fundamental idea that historically, light regimes in these headwater ecosystems were highly variable with 

areas of low light where canopies cover the stream and areas of high light associated with canopy gaps. 

The McKenzie River Ranger District worked with Oregon State University researchers to collect 

observational information on gaps on a tributary to McCrae Creek. This creek is comparable in size to the 

streams on the Detroit Ranger District where we are proposing streamside treatments, but it has not only 

mid-seral Douglas fir forest but also sections of old growth riparian forest. This stream also has a selfsustaining population of resident wild coastal cutthroat trout. Results from this and other streams in the 

region showed that there are more gaps in the old growth reach and greater light availability to the stream 

channel compared to the plantation. In our assessments of juvenile trout growth through the summer, we 

observed greater growth rates in young-of-year cutthroat in the old growth reach as compared to the 

plantation reach. The two reaches are in close proximity in the same stream with comparable young-ofyear and large adult populations, suggesting that these differences in growth are likely due to the 

differences in stream conditions between the two reaches. 

As required by the S&Gs these activities must be analyzed to ensure that significant risk to the watershed 

values does not exist. The Breitenbush River Watershed Analysis (1996) identified the following values 

for the watershed:

• Forest Road 46 is a National Scenic Byway and National Scenic Bikeway.

• Recreation. The Breitenbush watershed provides a wide variety of recreational opportunities from 

backpacking in the Mt. Jefferson Wilderness to fishing, hunting, and camping.

• Scenic and Aesthetic. The Breitenbush River is a Candidate River under the Wild and Scenic 

Rivers Act. The “outstandingly remarkable values” identified for the Breitenbush are scenery, 

recreation, fish, and cultural.

• Spiritual. The public has expressed to the Forest Service that they find certain places in the 

Breitenbush watershed as spiritual. For example, Breitenbush hot springs and the Jefferson Park 

area of the Mt Jefferson Wilderness.

• Employment. The Breitenbush watershed provides a variety of forest products from timber to 

floral design products. A number of recreation sites are managed under contract with the Forest 

Service by concessionaire. The salmon that are produced in the Breitenbush are part of a larger 

stock of fish that provide jobs in the commercial and sport fishing industries.
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• The North Santiam River system provides the drinking water for the city of Salem and 

communities located in the Santiam canyon. The Breitenbush River is a major tributary to the 

Santiam River. 

• Ecological Values. The Breitenbush watershed provides a variety of habitats and a diversity of 

wildlife species.

Given the small scope and area relative to the rest of the Breitenbush watershed, the streamside vegetation 

diversity project will have no effect on values such as the scenic byway, recreation of any sort, the scenic 

quality of the Breitenbush SIA or Wild and Scenic River values. The project may affect ecological values 

and water quality so this analysis will focus on those watershed values.

Water quality and especially stream temperature could be affected by the removal of shade trees. Oregon 

Department of Environmental Quality (DEQ) implements the Clean Water Act. Every two years, DEQ is 

required to assess water quality and report to EPA (Environmental Protection Agency) on the condition of 

Oregon's waters. DEQ prepares an Integrated Report that meets the requirements of the federal Clean 

Water Act (CWA) for Section 305(b) and Section 303(d). Following a temperature TMDL (Total 

Maximum Daily Load) or other cumulative effects analysis, waste load and load allocations will restrict 

all point sources and non-point sources to a cumulative increase of no greater than 0.3o

Celcius (0.5

Fahrenheit) above the applicable criteria after complete mixing in the water body, at the point of 

maximum impact.

We believe that water quality standards can be met and that stream temperatures will not rise by 0.3o C 

(0.5o F) due to the following:

• The individual streamside treatment areas (See hydrology report for individual unit treatment 

acres) are relatively small. Hardwoods would be planted in some of the areas, and within 6 to 10 

years we expect that more hardwood trees would colonize the openings and provide effective 

shading.

• The streams are moderately to relatively steep (7%-29%) so the water would move quickly 

through the treatment areas. Relative to a flat stream (2% gradient) there would be less time for 

the sun to heat up the water as it passes through the treatment areas. In addition, shade will not be 

affected downstream of the treatment areas. In unit 430, the closest unit to listed fish habitat, the 

stream slope is 30% and has a north facing aspect. 

• Because these streams are relatively steep they are considered “cascades” from a stream channel 

perspective. They have a variety of substrates such as sand, gravel, cobbles, small and large 

boulders. This creates complex channel conditions and allows for hyporheic exchange which 

helps to cool the stream.

Since we do not expect a jeopardy determination from the National Marine Fisheries Service and we do 

not expect to violate the 303(d) requirements of the Clean Water Act, this project would not pose a 

significant risk to the values identified in the Breitenbush Watershed Analysis (1994).

3. & 4. Watershed Analysis and Watershed Restoration

The Breitenbush Watershed Analysis was prepared for the Detroit Ranger District in 1996 and updated in 

2014. The watershed was characterized in terms of past and current conditions, and a synthesis discussion 

was provided to guide development of management proposals to maintain and restore watershed 

conditions.

The Hwy 46 Project has incorporated information from the watershed analysis into the project design. 

Current vegetative landscape patterns reflect past management activities that did not consider what the 
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landscape might look like under natural disturbance regimes. Many of the proposed projects seek to create 

vegetative patterns, late successional stand structures, and fuel loadings that would have been typical of 

this landscape under the natural disturbance regimes that historically occurred in the area. 

Watershed restoration has been ongoing in the Breitenbush River since 1994. Most of this work has 

centered on dispersed recreation use and mitigation efforts have been focused there. Current planning 

efforts by USFS aquatics staff focus on large scale restoration efforts on the Breitenbush River, upstream 

of Cleator Bend campground and the N. Fork Breitenbush River. This planning effort will place LWD, 

rehabilitate dispersed campsite, decommission roads, replace culverts, and include planting of native trees 

and shrubs in the riparian zone. Numerous dispersed campsites adjacent to the Breitenbush have been 

closed or rehabilitated. Roads have been decommissioned and stored in the watershed and more roads are 

proposed for these treatments in the Hwy 46 project. 

Aquatic Conservation Strategy Objectives

The previous discussions highlighted the consistency of the Hwy 46 Project with the four components of 

the Aquatic Conservation Strategy. This section will outline how the activities proposed in the alternatives 

conform to the nine objectives of the ACS. The information presented is summarized from Chapters 2 and 

3 of the Environmental Impact Statement, where greater detail can be found if needed.

Objective #1 - Maintain and restore the distribution, diversity, and complexity of watershed and 

landscape-scale features to ensure protection of the aquatic systems to which species, populations 

and communities are uniquely adapted.

Alternative 1 (No Action) – This alternative would maintain landscape complexity at the current 

condition. Several hundred acres of Riparian Reserves would remain in dense homogenous stand 

conditions until natural processes created openings and down wood. This could take several decades. 

Aquatic habitats would continue to experience a low volume of large (greater than 36” in diameter at 50’ 

from the large end) in-stream wood. Until a fire or large flood disturbs the riparian habitat the Breitenbush 

River will continue to have a low percentage of hardwood vegetation in the Riparian Reserves.

Alternative 2 (Proposed Action) – The thinning treatments were developed so that they would, to the 

extent possible, emulate the effects of the natural fire regime that historically occurred in the vicinity as 

well as maintain existing habitat near streams and wetlands. Creating structural and species diversity 

within dense, homogenous Riparian Reserve stands were key drivers in the proposed treatments. The 

objective is to provide a balance between the maintenance of existing habitat for species, populations, and 

communities, with opportunities to develop landscape scale features with distribution, diversity and 

complexity of the historical landscapes. This includes aquatic and riparian elements of the landscape. 

Specific treatments are included to enhance early seral habitat which has been declining in the watershed 

as a result of past fire suppression activities and land management choices. Though no regeneration 

harvest is proposed within the Riparian Reserves, these treatments would enhance the overall diversity 

and complexity across the landscape.

Within prescribed fire units, the introduction of low severity fire into patches of Riparian Reserves is 

anticipated. Fire would be allowed to back into the Reserves and burn in a mosaic pattern rather than 

requiring a fire line around the Reserves which would potentially result in erosion. Low severity fire is 

expected to increase the plant species and stand structural diversity on a small scale. At low burn 

severities, large wood would not be removed from the Reserves. In addition with local differences in soil 

moisture and relative humidity, the pattern of burning in the Riparian Reserves is expected to resemble a 

patchwork mosaic of unburned and lightly burned sites. In the unburned portions, the existing understory 

vegetation, including conifers, would be retained. In lightly burned areas, understory conifers would 
Hwy 46 FEIS Appendix 

305

experience some mortality, but fire adapted species such as willow and other hardwood shrubs would resprout and, in some instances, be stimulated into increased growth in response to the disturbance. The net 

result would be increased plant species and stand structural diversity, with a closer resemblance to historic 

stand condition than non-thinned plantations.

Additionally, over 26,487 acres of Riparian Reserves throughout the Breitenbush 5th field would remain 

untreated.

Alternative 3 – The effects of Alternative 3 would be similar to Alternative 2 since the acres proposed for 

treatment within the Riparian Reserves are similar (372 acres). Treatments outside the Riparian Reserves 

affect fewer acres. 

This objective would be maintained.

Objective #2 - Maintain and restore spatial and temporal connectivity within and between 

watersheds. Lateral, longitudinal, and drainage network connections include floodplains, wetlands, 

upslope areas, headwater tributaries, and intact refugia. These network connections must provide 

chemically and physically unobstructed routes to areas critical for fulfilling life history 

requirements of aquatic and riparian-dependent species.

Alterative 1 (No Action) –Failing culverts and inadequately maintained roads would continue to affect the 

ability of some aquatic species to disperse. Culverts that are currently barriers to fish and other aquatic 

dependent species would not be replaced. Otherwise, implementation of this alternative would maintain 

existing spatial and temporal connectivity.

Alterative 2 (Proposed Action) – Road treatments include upgrade of stream crossings to accommodate 

100 year flood events, so that these events can flow through the landscape unimpeded and without the risk 

of catastrophic fill failures. Riparian Reserves, as established by the Record of Decision for the Northwest 

Forest Plan and re-assessed in the Breitenbush Watershed Analysis have been incorporated into the design 

of all treatment units where streams occur. Treatments are proposed within riparian reserves, where they 

have the potential to enhance functions such as the development of future large wood, stand structural 

diversity, vegetative species richness and diversity, connectivity, and other late successional 

characteristics.

Alternative 3 – Implementation of this alterative incorporates many of the same elements as Alternative 2. 

Fewer culverts would be upgraded though most of these are on intermittent streams high up on the slopes 

where fewer aquatic species reside. Also fewer (372 acres) acres of riparian thinning would occur. 

This objective would be maintained. 

Objective #3 - Maintain and restore the physical integrity of the aquatic system, including 

shorelines, banks, and bottom configurations.

Alternative 1 (No Action) – Implementation of this alternative would maintain existing conditions. Roads 

and drainage features would continue to fail creating potential for damage to channel integrity. Large instream wood levels would remain low for several decades until natural processes occurred to create it. 

The ability of some streams to store gravels would be greatly reduced during this time which would 

continue to alter the channel morphology.

Alterative 2 (Proposed Action) – All proposed treatments were designed with channel stability in mind. 

All harvest activities restrict the use of ground disturbing equipment in and around streams, and provide 

for retention of all vegetation that is contributing to the stability of banks and channels. Where aerial 
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306

yarding methods are prescribed, full suspension is required when yarding over streams and their buffers to 

prevent disturbance of stream banks and channels. Trees cut for skyline corridors would be retained on 

site as down woody material.

Trees cut for the near-stream treatments would all be maintained on site for down woody material. Tree 

stumps and their rootwads would maintain bank stability for a number of years. The duration is typically 

considered 5 years but we have noted stumps along streams providing stability for at least a decade. In 

addition, hardwoods would begin to colonize the treatment areas and their root systems would provide for 

bank stability. If natural colonization is not occurring as expected manual planting of the treatment sites 

would occur. We expect that hardwoods would be fully established in the treatment areas in six to ten 

years.

Roads are a known potential source of damage to stream habitat, where improper design or location, or 

inadequate maintenance results in failures or roadway erosion, channel confinement or fine sediment 

delivery to streams. The Hwy 46 Project addresses this concern by minimizing permanent road 

construction and upgrading numerous culverts. Approximately 117 miles of maintenance and 

reconstruction of portions of the existing road network that are in poor repair, replacement of undersized 

or old culverts, drainage improvement, and application of aggregate where necessary, will reduce chronic, 

low amplitude sources of fine sediment from the existing transportation system, and the potential of 

crossing fill failures. This will reduce the possibility of gravels and cobbles becoming embedded in fine 

materials in the stream channel bottoms. Approximately 5.2 miles of temporary roads will be constructed 

on stable locations, and all of these will be decommissioned following harvest activities. Additionally, 

approximately 1.99 miles of road would be decommissioned and 0.75 miles stored in a hydrologically 

stable condition.

Addition of in-stream large wood along 20 acres of stream (mostly fish-bearing) would occur. This would 

impact stream banks or beds by increasing a streams ability to store and sort gravels thus adding to the 

channel complexity.

Alterative 3 – Implementation of this alternative would have similar effects as Alternative 2 with the 

exception of fewer road miles maintained and 2.2 fewer miles of temporary roads. This may result in 

impacts to the streams along roads not repaired.

This objective would be maintained.

Objective #4 – Maintain and restore water quality necessary to support healthy riparian, aquatic 

and wetland ecosystems. Water quality must remain within the range that maintains the biological, 

physical, and chemical integrity of the system and benefits survival, growth, reproduction, and 

migration of individuals composing aquatic and riparian communities. 

Alterative 1 (No Action) – Implementation of this alternative would maintain existing water quality 

conditions including current levels of shade for stream temperatures. As stands continue to develop 

towards more natural conditions, conditions would improve also. This could take several years to several 

decades in streams hit heavily by historic logging (clear-cutting to the stream edge) and stream “cleaning” 

(removal in in-stream wood).

Alternative 2 (Proposed Action) – The over-all objective of any treatment within the Riparian Reserves is 

to maintain compliance with the Regional TMDL Implementation Strategy so that stream temperatures 

are not detrimentally impacted. Over 26,487 acres of Riparian Reserves throughout the Breitenbush 5th

field watershed would remain untreated. Where vegetative treatments are proposed within Riparian 

Reserves, effective stream shading is retained at levels sufficient to maintain water temperature. A 
Hwy 46 FEIS Appendix 

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minimum of 50% canopy closure is preserved throughout the Riparian Reserve to maintain 

microclimates. No-harvest buffers were developed to preserve the primary shade zone. Five units are 

proposed for streamside treatment. All of the remaining units with perennial Class 3 and Class 2 streams 

have a minimum 60-foot no-harvest buffer.

Where in-stream wood or near-stream treatments are proposed, thermal loading is naturally low. The 

lengths of stream exposed to direct solar radiation are kept to a minimum to achieve resource objectives 

while providing shaded reaches to “re-cool” the stream immediately below the treatments. Additionally, 

the creation of in-stream wood improves gravel storage and pool formation which in turn increases 

hyporehic exchange and improving cold water influx to the channels. 

Alternative 3 – Implementation of this alternative would have similar effects as Alternative 2. The acres 

Riparian Reserve treatments and the acres of stream side wood creation are the same. Design features for 

stream-side shade is also the same though there are fewer acres (372 acres) proposed for thinning in 

Alternative 3.

This objective would be maintained.

Objective #5 – Maintain and restore the sediment regime under which aquatic ecosystems evolved. 

Elements of the sediment regime include the timing, volume, rate, and character of sediment input, 

storage, and transport.

Alterative 1 (No Action) – Under natural, unmanaged conditions, the sediment regime is regulated 

overland and via streamflow’s, (big events like debris flows and ongoing small inputs like bank erosion). 

Sediment storage and transport is influenced by stream channels, including obstructions such as large 

woody debris that slow the flow, allowing sediment to settle out. Approximately 22% of the Breitenbush 

5th field watershed lies in designated wilderness, so much of the watershed would not have any change in 

sediment regime by No Action. This helps provide for landscape processes that are dominated by nature 

rather than humans. Implementation of this alternative would maintain existing anthropogenic sediment 

input at their current levels for potentially several years to several decades. Natural sediment regime 

processes would still continue, including debris flow and downstream delivery of sediment. However, 

Alternative 1 would not correct existing road erosion problems nor reduce the risk of future road or 

culvert failure.

Alternative 2 (Proposed Action) – Project design elements are intended to maintain and restore the 

physical integrity of the aquatic system, including shorelines, banks, and bottom configurations, as 

discussed above under Objective 3. These design elements will also provide protection to water quality 

from the introduction of sediment into streams and resulting effects on stream turbidity.

Roads are a known potential source of damage to stream habitat, where improper design or location, or 

inadequate maintenance results in failures or roadway erosion. The Hwy 46 Project addresses this concern 

by minimizing permanent road construction and upgrading numerous culverts. Approximately 117 miles 

of maintenance and reconstruction of portions of the existing road network that are in poor repair, 

replacement of undersized or old culverts, drainage improvement, and application of aggregate where 

necessary, will reduce chronic, low amplitude sources of fine sediment from the existing transportation 

system, and the potential of crossing fill failures. This will reduce the possibility of gravels and cobbles 

becoming embedded in fine materials in the stream channel bottoms. During culvert replacement, some 

sediment may enter the stream system. However, the amount will be minimized by following BMPs and 

the impact will be relatively short lived. Approximately 5.2 miles of temporary roads will be constructed 

on stable locations, and all of these will be decommissioned following harvest activities. Additionally, 
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approximately 1.99 miles of road would be decommissioned and 0.75 miles stored in a hydrologically 

stable condition. 

All proposed treatments were designed with sediment transport potential in mind. All harvest activities 

follow Best Management Practices (BMP) guidelines and restrict the use of ground disturbing equipment 

in and around streams. This reduces the potential of water routing along skid roads or the creation of 

overland flow due to high compaction levels. Where aerial yarding methods are prescribed, full 

suspension is required when yarding over streams to prevent disturbance of stream banks and channels. 

Trees cut for skyline corridors would be retained on site as down woody material. 

Alternative 3 – Implementation of this alternative would have similar effects as Alternative 2 with the 

exception of fewer road miles maintained or reconstructed. This may result in impacts to the streams 

along roads not repaired. 

This objective would be slightly improved. 

Objective #6 – Maintain and restore in-stream flows sufficient to create and sustain riparian, 

aquatic, and wetland habitats and to retain patterns of sediment, nutrient, and wood routing. The 

timing, magnitude, duration and spatial distribution of peak, high, and low flows must be 

protected. 

Alterative 1 (No Action) – Approximately 22% of the Breitenbush 5th field watershed lies in designated 

wilderness. This helps provide for landscape processes that are dominated by nature rather than humans. 

Implementation of this alternative would maintain existing in-stream flows. 

The area’s sub-watersheds are moving into a vegetative condition which buffers the effect of snow 

accumulation from past clear-cutting harvest. With ARP values projected to remain well above the 

threshold of concern, No Action, would result in no changes to existing peak flows based on vegetation 

removal. However, lack of density reduction and fuel treatments of overstocked stands would retain an 

increased risk of high severity wildfire or disease outbreaks, that would have the potential to increase 

peak flows in the near-term following an event. 

Alternative 2 (Proposed Action) –Implementation of a landscape design that is intended to restore 

vegetative structure, landscape patterns, and disturbance regimes to a more natural condition will result in 

a hydrology that more closely resemble those under which historic stream flow conditions developed. 

This alternative maintains current canopy cover at levels above the maximum mid-point Aggregate 

Recovery Percentage (ARP). Therefore, no altered flows are anticipated from implementation of this 

alterative.

It is anticipated that implementation of standards in the Willamette National Forest Plan would maintain 

stream flows sufficiently to create and sustain riparian, aquatic and wetland habitats, and to retain patterns 

of sediment, nutrient, and wood routing. In the short term, potential adverse effects on the timing, 

magnitude, duration, and spatial distribution of peak and high flows will be minimized by managing the 

planning subdrainages within the analysis area to Aggregate Recovery Percentage (ARP) levels. 

Alternative 3 – Implementation of this alternative would have similar effects as Alternative 2, and no 

altered flows are anticipated. 

This objective would be maintained.

Objective #7 – Maintain and restore the timing, variability, and duration of floodplain inundation 

and water table elevation in meadows and wetlands.
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Alterative 1 (No Action) – As mentioned in previous objective, approximately 22% of the Breitenbush 5th 

field watershed lies in designated wilderness which helps provide for natural landscape processes 

Implementation of this alternative would maintain existing floodplain inundations and water table 

elevations. Conifer encroachment would continue in the wet meadow in Unit 32a, reducing water 

availability for meadow vegetation and eventually losing the meadow habitat all together in the absence 

of other disturbance.

Alternative 2 (Proposed Action) – Implementation of a landscape design that is intended to restore 

vegetative structures, landscape patterns, and disturbance regimes to a more natural condition will result 

in watershed conditions that more closely resemble those under which historic stream flow conditions 

developed. Floodplains and wetland areas were excluded from consideration with the exception of Unit 

32a for harvest activities and where treatment units occur adjacent to these features. Ground based 

equipment is restricted from buffers to minimize soil and groundwater impacts. Addition of in-stream 

wood has the potential to alter floodplains. However, research has shown that this type of alteration 

usually leads in increased channel complexity and improved aquatic habitat. Conifer encroachment would 

be addressed in the wet meadow in Unit 32a, increasing shallow water availability for meadow vegetation 

and increasing wet meadow diversity.

Alternative 3 – Implementation of this alternative would have similar effects as Alternative 2, and no 

altered flows are anticipated. Conifer encroachment would continue in the wet meadow in Unit 32a, 

reducing water availability for meadow vegetation and eventually losing the meadow habitat all together 

in the absence of other disturbance.

This ACSO would be maintained. 

Objective #8 - Maintain and restore the species compositions and structural diversity of plant 

communities in riparian areas and wetlands to provide adequate summer and winter thermal 

regulation, nutrient filtering, appropriate rates of surface erosion, bank erosion, and channel 

migration and to supply amounts and distribution of coarse woody debris sufficient to sustain 

physical complexity and stability.

Alternative 1 (No Action) – This alternative would maintain landscape complexity at the current 

condition. Several hundred acres of Riparian Reserves would remain in dense homogenous stand 

conditions until natural processes created openings in which hardwoods and understory species could 

thrive. This could take several decades. Aquatic habitats would continue to experience low volumes of instream and terrestrial down wood.

Alternative 2 (Proposed Action) – Over 26,487 acres of Riparian Reserves throughout the Breitenbush 5th

field would remain untreated and provide landscape-scale diversity. Some stands in Riparian Reserves are 

proposed for treatment to encourage development of large wood and late successional stand structure and 

increasing understory species diversity. Many of the plantations showed relatively high levels of large 

down wood that was left from the original harvest, with quite large diameters over 40”, such that it will 

last many more decades. At present, these stands are dense with a homogeneous overstory dominated by 

Douglas-fir. This forms a condition which shades out almost all light before it can reach the forest floor. 

Because of this, there are very little hardwoods or herbaceous vegetation on the forest floor. Thinning 

these stands outside of the streams primary shade zone will allow more sunlight to reach the forest floor 

and encourage greater vegetative diversity than currently exists. This activity will have the short term 

effect (years to a couple of decades) of reducing coarse woody material loading in the Riparian Reserve 

outside the no-harvest buffer. However given the unnaturally over-stocked conditions of these managed

stands, in the long term (decades to a century) there will still be adequate woody material to maintained 

volumes within the natural range of variability.
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Wetlands and floodplain areas that are critical to nutrient filtering are eliminated from treatment areas and 

use of ground disturbing equipment adjacent to them is restricted. Near-stream treatments and large wood 

input will help improve the nutritional quality of organic matter delivered to streams and allow for 

increased primary productivity.

Use of low severity fire is restricted to the edges of streamside buffers where the risk of adverse effects on 

ground cover and duff retention cannot impact water quality.

Alternative 3 - Implementation of this alternative would have similar effects as Alternative 2 with the 

exception there are fewer acres (372 acres) proposed for thinning in Alternative 3.

This objective would be slightly improved.

Objective #9 – Maintain and restore habitat to support well-distributed populations of native plant, 

invertebrate, and vertebrate riparian-dependent species.

Alternative 1 (No Action) – This alternative would maintain current habitat conditions for both aquatic 

and riparian-dependent species. Many of the aquatic and riparian-dependent species need complex stand 

structures like that found in old-growth stands in order to thrive. However, several hundred acres of 

Riparian Reserves would remain in dense homogenous stand conditions until natural processes created 

openings in which hardwoods and understory species could thrive. This could take several decades. 

Meanwhile aquatic habitats would continue to experience low volumes of down wood and a lack of 

hardwood leaf litter. Deciduous trees provide leaf matter to streams that is of higher nutritional quality 

than conifer needles. 

Alternative 2 (Proposed Action) – Over 26487 acres of Riparian Reserves throughout the Breitenbush 5th

field watershed would remain untreated and provide landscape-scale diversity. In addition, this project 

complies with the Northwest Forest Plan and all of its applicable standards and guidelines. Objective 9 

was expected to maintain and restore late-successional and old-growth forest ecosystems, and provide 

adequate viability levels for all late successional species including species listed in the FSEIS ROD Table 

C-3.

As discussed in the other Objectives above, many stands in Riparian Reserves are proposed for treatment

to encourage development of large wood, late successional stand structure and understory plant diversity. 

This would help to create a rich variety of habitats for native species. Adequate amounts of down woody 

debris will be retained on site.

Thinning in the upland portion of the Riparian Reserves in Hwy 46 will help restore habitat for a variety 

of native plant species. Currently these areas are even aged Douglas-fir plantations and lack a diversity of 

understory vascular and lichen and bryophyte species. Thinning these areas could increase botanical 

species richness by creating more multi-aged and multi-canopy stands as well as increase species 

diversity. 

Many of the sensitive and survey and manage plant species in the project area are found within or 

adjacent to Riparian Reserves. These sites will be buffered to protect the sites from disturbance and 

maintain the microclimate. See the Botany Report and/or Botanical Biological Evaluation for more 

information on these sites. 

The Breitenbush River and its numerous tributaries provide excellent habitat for native fish. This is due to 

the cold, clean water. This habitat will be maintained by the implementation of no cut buffers along fish 

bearing streams. Additionally, upgrades to several culverts will provide better dispersal opportunities to 
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aquatic invertebrates and salamanders. Roads that are decommissioned will restore stream channels so 

that there will be unobstructed passage at the former road crossing.

Alternative 3 - Implementation of this alternative would have similar effects as Alternative 2 with the 

exception that Alternative 3 proposes fewer acres (372 acres) of Riparian Reserve thinning and fewer 

miles of road maintenance/repairs.

This objective would be slightly improved.
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Appendix F – DecAID Analysis

DecAID Project Analysis: Downed Logs and Snags

A collection of information, referred to as DecAID, has been developed by Region 6 to help projects 

identify the levels of snags and downed logs required to meet wildlife population needs (Forest Service 

2012). At the landscape level, DecAID recommends providing dead wood at levels within the range of 

historic variability. The proposed treatments are entirely within the 5th field Breitenbush River watershed 

which was used to evaluate deadwood at the landscape level for this project. 

DecAID evaluates deadwood levels by wildlife habitat type. The Breitenbush River watershed contains 

about 29,655 acres of Montane Mixed Conifer Forest and 31,949 acres of Westside Lowland ConiferHardwood Forest habitat (Acker 2015). Treatment units in the HWY 46 timber project are in these 

habitat types.

DecAID takes advantage of the spatially-comprehensive dataset of vegetation structure developed for 

Oregon and Washington by a team from the Pacific Northwest Research Station and Oregon State 

University using the statistical imputation method Gradient Nearest Neighbor (GNN) (LEMMA 2015). 

DecAID includes a process (“Distribution Analysis”) that allows use of GNN data to evaluate the current 

frequency distribution of different densities of snags and amounts of cover of down wood within 

geographic areas such as watersheds selected by users. By using inventory plot data from unharvested 

areas and information on historic disturbance regimes, the process also allows estimation of reference 

conditions for both snags and down wood (Forest Service 2012).

The median historic condition for the Breitenbush River watershed was estimated using levels of snags

and downed logs found in strategic plots in unlogged stands of various ages and an estimate of the 

normal distribution of seral stages derived from the assumed fire return interval (Acker 2015). Median 

values are the mid-point where half of the time deadwood levels would be at or higher than that value 

and about half the time they would be at or lower than the value. Studies have indicated that fire 

frequency and severity varied considerably in the past due to substantial variability in weather 

conditions, and fire severity varied from century to century (Wimberley et al. 2000). Therefore, levels of 

dead wood have fluctuated considerably over time and plus or minus 50% of the estimated median 

value was used to approximate the historic range of variability. 

Downed Logs: DecAID analysis (Acker 2015) found that downed logs in both total size class (> 5” 

diameter) and large size class (>20” diameter) for both Westside Lowland Conifer-Hardwood Forest and 

Montane Mixed Conifer Forest in the Breitenbush River watershed were similar to estimated historic 

median conditions. (Figures 1-4). That means that the abundance of downed logs currently is similar to 

what was historically present within the Breitenbush River watershed.
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Figure 61.DecAID analysis showing estimated current and historic downed wood for the Breitenbush River 

watershed in Westside Lowland Conifer-Hardwood Forest habitat (Acker 2015).

Figure 62 DecAID analysis showing estimated current and historic large-diameter downed wood for the 

Breitenbush River watershed in Westside Lowland Conifer-Hardwood Forest habitat (Acker 2015).
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Figure 63. DecAID analysis showing estimated current and historic downed wood for the Breitenbush River 

watershed in Montane Mixed Conifer habitat (Acker 2015).

Figure . DecAID analysis showing estimated current and historic large-diameter downed wood for the 

Breitenbush River watershed in Montane Mixed Conifer habitat (Acker 2015).
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Snags: DecAID analysis (Acker 2015) found that snags in both total size class (> 10 inches dbh) and large 

size class (>20 inches dbh) for both Westside Lowland Conifer-Hardwood Forest and Montane Mixed 

Conifer Forest were less than estimated historic median conditions. (Figures 5-8). In particular, the 

percent of area with no snags is much higher now than what historically occurred, according to the 

DecAID analysis. For snags greater than 10 inches dbh, 26% of the Westside Lowland Conifer-Hardwood 

Forest and 22% of the Montane Mixed Conifer Forest in the Breitenbush River watershed have no snags 

compared to an estimated historic median condition of 5% and 6%, respectively (Acker 2015). For snags 

greater than 20 inches dbh, 38% of the Westside Lowland Conifer-Hardwood Forest and 40% of the 

Montane Mixed Conifer Forest in the Breitenbush River watershed have no large snags compared to an 

estimated historic median condition of 11% and 15%, respectively. Past logging and fire suppression are 

likely important reasons why large areas in the watershed lack snags.

Figure 64. DecAID analysis showing estimated current and historic snags for the Breitenbush River 

watershed in Westside Lowland Conifer-Hardwood Forest habitat (Acker 2015).
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Figure 65. DecAID analysis showing estimated current and historic large snags for the Breitenbush River 

watershed in Westside Lowland Conifer-Hardwood Forest habitat (Acker 2015).

Figure 66. DecAID analysis showing estimated current and historic snags for the Breitenbush River 

watershed in Montane Mixed Conifer habitat (Acker 2015).
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Figure 67. DecAID analysis showing estimated current and historic snags for the Breitenbush River 

watershed in Montane Mixed Conifer habitat (Acker 2015).

Cavity Excavator Snag Population Potential Analysis:

The Willamette National Forest Plan has a Standard and Guideline (FW-121) that states: “Habitat 

capability for primary cavity excavators shall be maintained to provide for at least 40% or greater 

potential populations. Habitat shall be provided and monitored at the subdrainage level.” The method 

that the Forest Plan used to calculate habitat population potential is no longer considered “best science” 

for determining that viable populations will be maintained but it does provide for a minimum number of 

snags at the watershed scale.

In order to determine the current distribution of large snags and the capability of the landscape to 

support primary cavity excavators, an analysis was conducted at the forest level for all 5th field 

watersheds using the DecAID snag estimates (Willamette SO, wildlife files). 

The 20 inches dbh and above size class available in the DecAID snag analysis data was used in these 

calculations, while the snag population potential method is based on 18 inches dbh and above. 

Consequently, the results slightly underestimate population potential because snags 18-19.9 inches dbh

are not counted. Snag habitat potential in each watershed did not include acres on private land since the 

population potential standard applies to Forest Service lands.

The calculations indicate that, on the Willamette National Forest, there is a current snag population 

potential of about 54% in the Westside Lowland Conifer Hardwood habitat type and 56% in the Montane 

Mixed Conifer habitat type. In the Breitenbush River watershed, the current snag population potential is 

estimated at about 50% in the Westside Lowland Conifer Hardwood habitat type and 46% in the 

Montane Mixed Conifer habitat type. The analysis suggests that the Hwy 46 project area is above the 

minimum snag population potential, but that snag abundance is lower than the average condition across 

the Forest.
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Table 1. Estimated Snag Population Potential for the Westside Lowland Conifer Hardwood (WLCH) and 

Montane Mixed Conifer (MMC) Wildlife Habitat Types in the Breitenbush River Watershed and in Willamette 

National Forest.

Analysis Area Habitat Type Current Historic 

Breitenbush River Watershed WLCH 50% 77%

Willamette National Forest WLCH 54% 75%

Breitenbush River Watershed MMC 46% 74%

Willamette National Forest MMC 56% 74%

Total acres of land in the planning area are 31,081 acres which for this analysis is reduced by estimating 

acres in areas that are not capable of functioning as habitat in the future such as cliffs, talus, roads, 

lakes, rivers and private land. The estimated acres deducted included 160 acres of private land owned at 

Breitenbush Hot Springs, 311 acres of powerline corridor, 70 acres of cliffs and talus, 30 acres of river 

and 60 acres of roads. Total acres deducted from non-habitat acres is 631. Total acres capable of 

growing owl habitat is 31,081 – 631 = 30,450 acres. 

Of the Hwy 46 planning area 24,552 acres are within a Critical Habitat Unit (CHU) for Northern Spotted 

Owl Recovery. This represents 78.99% of the planning area in CHU. The objective of this land use 

allocations is to provide primary constituent elements (the physical and biological features of critical 

habitat essential to a species’ conservation) identified in the spotted owl critical habitat final rule include 

those features that support nesting, roosting, foraging, and dispersal (USFWS 1992b).

Of the Hwy 46 planning area 14,530 acres are within Late Successional Reserve RO214. This represents 

47.72% of the planning area in LSR. The objective of this land use allocation is to protect and enhance 

conditions of late-successional forest species. Late-successional reserves are designed to maintain a 

functional, interacting ecosystem.

As overlap occurs with CHU and LSR when these allocations are combined with overlap considered they 

total 27,452 acres or 88.32% of the Hwy 46 planning area.

The 11.68% of the analysis area outside the LSR and CHU designations contains riparian reserves which 

add to mature forest habitat.

Growth models and existing condition models are designed to assist the decision maker with 

determining what options to choose. As higher level direction has already determined that over 88.32% 

of the analysis area is focused on developing older forest habitat a detailed growth model analysis is not 

needed.

DecAID analysis suggests the current snag and down wood levels are below historic levels and above 

minimum levels for population viability. In addition to the model information two factors should be 

mentioned. 1) A large fire occurred north of the Breitenbush River and was concentrated in the Western 

part of the analysis area. There were areas to the east of this concentration that were also burned 

extending to the forest boundary. The year of origin of the trees growing in the burned area is 1893 

which in 2017 makes these trees 124 years old. The burned area is approximately 5,000 acres. Model 

results will show the burned area to be low in snag and down wood levels when in reality these trees 

have grown larger and have become mature forests. 2) The Eagle Rock fire south of the Breitenbush 

River at the western edge of the planning area occurred in 1967. The Eagle Rock stands are close to 
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319

having large enough trees for commercial thinning. During the planning process it was decided that this 

area would be deferred into the future. The model would show this area to be low in snags and down 

wood when in reality it is contributing to smaller diameter material and would soon begin producing 

larger snags and down wood.

Snags and down wood are prescribed where regeneration harvest is proposed to occur in early seral 

habitat creation and gaps over one acre. The number of snags and down wood are listed in the Forest 

Plan Section of the Snags and Down Wood analysis. A detailed unit by unit prescription will be available 

in the project file.
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Effects of fires of 2017 on snag densities

Effects of fires of 2017 on snag densities in the Breitenbush River watershed Willamette National Forest

S. Acker, Northwest Oregon Ecology Group

January 16, 2018

Introduction and Methods

To provide support for project planning on the Willamette National Forest, we used information from 

the analytical tool DecAID (Mellen-McLean et al. 2012) to estimate densities of snags in the Breitenbush 

River watershed after the fires of 2017, for comparison to quantities estimated prior to the fires. 

Interpretation of deadwood information from DecAID is most appropriately done at spatial scales large 

enough to include variability in stand structure and wildlife habitat, typically 5th-field watersheds or 

other areas of at least 20 square miles or 12,800 acres (Mellen-McLean et al. 2012). Analysis of snag 

densities within the watershed is appropriate for two wildlife habitat types identified in DecAID: 

Montane Mixed Conifer Forest and Westside Lowland Conifer-Hardwood Forest habitat types, which 

occupy 29,655 and 31,949 acres, respectively, in the watershed.

DecAID takes advantage of the spatially-comprehensive dataset of vegetation structure developed for 

Oregon and Washington by a team from the Pacific Northwest Research Station and Oregon State 

University using the statistical imputation method Gradient Nearest Neighbor (GNN) (LEMMA 2015). 

DecAID includes a process (“Distribution Analysis”) that allows use of GNN data to evaluate the current 

frequency distribution of different densities of snags within geographic areas such as watersheds 

selected by users. By using inventory plot data from unharvested areas and information on historic 

disturbance regimes, the process also allows estimation of reference conditions (Mellen-McLean et al. 

2012).

GNN uses spectral data from satellite remote sensing as well as physical environmental data to relate 

inventory plots to the vast majority of forested portions of Oregon and Washington lacking field 

measurements (LEMMA 2015). The use of remote sensing data, which are collected frequently, permits 

periodic updating of the GNN dataset to capture current conditions. The most current GNN dataset 

incorporates remote sensing data from 2012, and is incorporated into the most current version of data 

for Distribution Analysis. Major disturbances since 2012 would not be captured in the latest dataset. 

However, the DecAID team has developed an algorithm to exploit RAVG (Rapid Assessment of 

Vegetation Condition after Wildfire) data for wildfires of at least 1000 acres (U.S. Forest Service 2015) in 

ArcMap to estimate effects on density of snags (C. Belongie and K. Mellen-McLean, pers. comm.). In 

2017, this method was updated by Jeremy Hobson, Geospatial System Specialist, and Ray Davis, 

Monitoring Lead - Older Forests & Spotted Owls, (both U.S. Forest Service) to take advantage of higherresolution data from the Sentinel 2 satellites of the European Space Agency which have recently become 

available (Hobson 2017). Maps of fire severity are now available from 2012 to 2017, with Sentinel as the 

source for 2017, and RAVG for the earlier years (J. Hobson, pers. comm.).

The algorithm for updating snag quantities after wildfire employs geographic information from RAVG, or 

corresponding information derived from the Sentinel data, stratifying by the seven-category severity 

classification, as recoded into four classes for GIS overlay analysis (Table 1). The predicted proportion of 

live trees converted to snags immediately after fire varies by fire severity and tree size. The conversion 

values (“adjustment factors”) were derived from expert opinion (K. Mellen-McLean pers. comm.), and 

are quite similar to values we derived from measurements at the Warner Creek Fire on the Middle Fork 
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321

Ranger District of the Willamette National Forest (Table 2)(see Brown et al. 2013 concerning the Warner 

Creek Fire).

Table 1. Crosswalk from seven-class version of RAVG or Sentinel-derived fire severity information to 

four-class version used for updating snag densities from GNN data (source: 

T:\FS\Reference\GeoTool\r06\Toolbox\DecAID\Documentation_info\DecAID_Metadata_12202017.xlsx.

RAVG 7 

Class Description RAVG Class used in update

0 outside fire perimeter 0

1

0% basal area (BA) 

loss 0

2 0% - < 10% BA loss 1

3 10% - < 25% BA loss 1

4 25% - < 50% BA loss 2

5 50% - < 75% BA loss 3

6 75% - < 90% BA loss 4

7

90% or greater BA 

loss 4

Table 2. Comparsion of proportions used to update snag information from DecAID using fire severity 

from RAVG and median values of conversion of live trees to snags observed one year after the Warner 

Creek Fire.

RAVG Class Class definition Snag size Class Adjustment 

Factor

Warner 

Creek, one 

year post-fire 

(medians)

Class 1 0% - < 25% basal 

area loss

snag 25-50cm 0.2 0.33

snags >50cm 0.0 0.0

Class 2 25% - < 50% basal 

area loss

snag 25-50cm 0.4 0.45

snags >50cm 0.3 0.2

Class 3 50% - < 75% basal 

area loss

snag 25-50cm 0.7 0.86

snags >50cm 0.6 0.58

Class 4 75% - 100% basal 

area loss

snag 25-50cm 1.0 1.0

snags >50cm 0.9 1.0

To assess snag densities for the Breitenbush River watershed we employed the datasets and methods 

detailed by Kim Mellen-McLean, Regional Wildlife Ecologist, U.S. Forest Service, in documents describing 

the “DecAID Regional Analysis.” The analysis of snag densities prior to the fires of 2017 is contained in 

the file Breitenbush_River_deadwood_analysis_20150702.docx (in Pinyon; contact Steve Acker or Joe 

Doerr for a copy). The individual steps of data processing for the distribution analyses following the 2017 

fires are recorded in the file Fire2017_snag_dens_update_process_log.xlsx, in the folder 

T:\FS\NFS\Willamette\Program\Ecology\GIS\Workspace\DecAID_data2012\2017FireUpdates.

Results and Discussion
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322

For both the Montane Mixed Conifer Forest and Westside Lowland Conifer-Hardwood Forest habitat 

types, the fires of 2017 affected less than 10% of their total areas within the Breitenbush River 

watershed (Tables 3 and 4). Most of the area within fire perimeters burned at the lowest severity 

captured in the analysis (i.e., less than 25% loss of tree basal area). However, there were several 

hundred acres in both habitat types that burned at the highest severity (i.e., loss of 75% or more of tree 

basal area).

Table 3. Distribution of fire severity due to fires of 2017 within the Montane Mixed Conifer Forest 

habitat type within the Breitenbush River watershed.

RAVG Fire 

Severity Class Basal area loss Acres

Percentage of fire 

area by habitat 

type

Percentage of 

habitat type 

within watershed

1 0% - < 25% 1078 52.7 3.6

2 25% - < 50% 173 8.5 0.6

3 50% - < 75% 179 8.8 0.6

4 75% - 100% 615 30.1 2.1

Total 2044 6.9

Table 4. Distribution of fire severity due to fires of 2017 within the Westside Lowland Conifer-Hardwood 

Forest habitat type within the Breitenbush River watershed.

RAVG Fire 

Severity Class Basal area loss Acres

Percentage of fire 

area by habitat 

type

Percentage of 

habitat type 

within watershed

1 0% - < 25% 922 68.2 2.9

2 25% - < 50% 121 9.0 0.4

3 50% - < 75% 95 7.0 0.3

4 75% - 100% 214 15.8 0.7

Total 1352 4.2

The histograms on the following pages illustrate the estimated density of snags with two lower diameter 

limits, before and after the fires of 2017, for both the Montane Mixed Conifer Forest and the Westside 

Lowland Conifer-Hardwood Forest habitat types (Figs. 1-4; the acronym ‘WHT’ on the histograms refers 

to Wildlife Habitat Type). For the most part, differences between conditions before and after the fires of 

2017 are very minimal to non-existent. The largest change in any one category of snag density was an 

increase in the area with snags with a minimum diameter of 10 inches in the Montane Mixed Conifer 

Forest habitat type, for the category of greater than 36 snags per acre. This category increased from 

13% to 16% of the habitat type in the watershed (Fig. 1). Thus, from the perspective of available tools 

and data, the fires of 2017 caused very little change in the frequency distribution of snag densities in the 

Breitenbush River watershed.
Hwy 46 FEIS Appendix 

323

Fig. 1. Frequency distribution of density of snags with a minimum diameter of 10 inches in the Montane 

Mixed Conifer habitat type in the Breitenbush River watershed, before (upper) and after (lower) fires of 

2017.
Hwy 46 FEIS Appendix 

324

Fig. 2. Frequency distribution of density of snags with a minimum diameter of 20 inches in the Montane 

Mixed Conifer habitat type in the Breitenbush River watershed, before (upper) and after (lower) fires of 

2017.
Hwy 46 FEIS Appendix 

325

Fig. 3. Frequency distribution of density of snags with a minimum diameter of 10 inches in the Westside 

Lowland Conifer-Hardwood Forest habitat type in the Breitenbush River watershed, before (upper) and 

after (lower) fires of 2017.
Hwy 46 FEIS Appendix 

326

Fig. 4. Frequency distribution of density of snags with a minimum diameter of 20 inches in the Westside 

Lowland Conifer-Hardwood Forest habitat type in the Breitenbush River watershed, before (upper) and 

after (lower) fires of 2017.
Hwy 46 FEIS Appendix 

327

Literature Cited

Brown, M. J., J. Kertis, and M. H. Huff. 2013. Natural tree regeneration and coarse woody debris 

dynamics after a forest fire in the western Cascade Range. USDA Forest Service Research Paper 

PNW-RP-592. 50 pp.

Hobson, J. 2017. Using RAVG relative difference Normalized Burn Ratio (RdNBR) burn severity maps and 

Sentinel RdNBR data to generate a regional burn severity grid.

LEMMA. 2015. LEMMA--Landscape Ecology, Modeling, Mapping, and Analysis. 

http://lemma.forestry.oregonstate.edu/ viewed <31-March-2015>

Mellen-McLean, K., B.G. Marcot, J.L. Ohmann, K. Waddell, S.A. Livingston, E.A. Willhite, B.B. Hostetler, C. 

Ogden, and T. Dreisbach. 2012. DecAID, the decayed wood advisor for managing snags, partially 

dead trees, and down wood for biodiversity in forests of Washington and Oregon. Version 2.20. 

USDA Forest Service, Pacific Northwest Region and Pacific Northwest Research Station; USDI Fish 

and Wildlife Service, Oregon State Office; Portland, Oregon. 

http://www.fs.fed.us/r6/nr/wildlife/decaid/index.shtml

U.S. Forest Service. 2015. Post-Fire Vegetation Conditions on the National Forests. 

http://www.fs.fed.us/postfirevegcondition/index.shtml. Viewed <25-Mar-2015>
Hwy 46 FEIS Appendix 

328

Appendix G – Riparian Reserve Treatment Detail

Unit Stand 

Age

Riparian Reserve 

Acres Stream 

Class

Riparian 

Reserve 

Width 

(feet)

NoHarvest 

Buffer 

(feet)

Rationale for Treatment within Riparian Reserve Total in 

Unit

Proposed 

Treatment

1 41 15.3 4.2 4 172 30 Thin to increase structural and vegetative diversity

3 53 2.4 2.0 4 172 30 Thin to increase structural and vegetative diversity

5 45 33.5 14.1

2 344 60

Thin to increase structural and vegetative diversity, 

opportunity for additional post-sale fall and leave along 

Humbug Cr. Has large trees, hardwoods and cedars in 

riparian (meeting ACSO's, but needs more LWD,

4 172 60 Thin to increase structural and vegetative diversity

6 48 27.1 21.1 3 172 60

Very dense monoculture of DF with a thin strip of alders. No 

understory. Accelerate achievement of ACSO's by thinning in 

riparian area and increasing stand diversity.

7 54 6.2 3.8

2 344 100 Thin to increase structural and vegetative diversity

4 172 30 Thin to increase structural and vegetative diversity

11 56 3.4 2.6

1 344 >125

Thin to increase structural and vegetative diversity, paved 

Hwy 46 between the unit and the Breitenbush River negate 

need for full RR buffer.

4 172 30 Thin to increase structural and vegetative diversity

12 123 3.1 0.2 4 172 172 On way to achieving ACSO’s; No treatment in RR.

13 131 17.7 9.9

1 344 >172

Protect ACSO’s between river and paved Hwy 46 between 

the unit and the Breitenbush River. Beyond the highway does 

not contribute to riparian health. 

2 344 172

On way to achieving ACSO’s closer to stream. Thin to 

increase structural and vegetative diversity in outer riparian. 

Opportunity for additional hardwood release.

4 172 30 Thin to increase structural and vegetative diversity

16 115 36.6 18.6

3 172 60-100 Thin to increase structural and vegetative diversity. South 

side of streams have larger buffer for shade protection.

4 172 30 Thin to increase structural and vegetative diversity

17 110 2.3 0.0 4 172 30 Thin to increase structural and vegetative diversity

18 120 27.5 6.0 3 172 100-172

Much of RR is on way to achieving ACSO's with high 

amount of downed wood, cedars, diversity and canopy layers. 

Some alder pockets. Other areas in need of treatment. Thin to 

reduce density and increase structural and vegetative 
Hwy 46 FEIS Appendix 

329

Unit Stand 

Age

Riparian Reserve 

Acres Stream 

Class

Riparian 

Reserve 

Width 

(feet)

NoHarvest 

Buffer 

(feet)

Rationale for Treatment within Riparian Reserve Total in 

Unit

Proposed 

Treatment

diversity. Variable buffer with hydrologist approval on 

layout.

4 172 30 Thin to increase structural and vegetative diversity

19 39 1.1 0.0 4 172 NA No streams in unit (Cls 4 outside of unit). Old plantation, 

needs thinning for diversity.

20 30 1.3 1.3 4 172 30 No streams in unit (Cls 4 outside of unit). Old plantation, 

needs thinning for diversity.

21 113 8.2 6.8 4 172 30

Very dense stand. Thin to increase species and structural 

diversity with riparian thinning. Considered for additional 

riparian treatment (streamside hardwood release gaps) but 

low priority.

22 115 37.2 20.7

Short 

Lake 344 150+

Very dense stand. Increase species and structural diversity 

with riparian thinning and protect lake from additional user 

impact. Minimum 150’ buffer with no harvest between lake 

and road.

3 172 80-100

Very dense stand. Thin to increase species and structural 

diversity with riparian thinning. Considered for additional 

riparian treatment (streamside hardwood release gaps) but 

low priority. Buffers protect primary shade and shallow 

groundwater.

4 172 30

Thin to increase species and structural diversity with riparian 

thinning. Buffers protect primary shade and shallow 

groundwater.

23 36 19.8 2.6 4 172 100

Thin to increase species and structural diversity in outer RR. 

Protect wet areas, shallow groundwater and diversity. 

Considered for additional fall and leave treatment but not 

selected. 

24 120 24.5 4.4

3 172 100-172 Much of RR is on way to achieving ACSO's with high 

amount of downed wood, cedars, diversity and canopy layers. 

Some alder pockets. Other areas in need of treatment to 

reduce density and Thin to increase structural and vegetative 

diversity. Variable buffer with hydrologist approval on 

layout.

4 172 100-172

25 105 13.9 10.0

3 172 >100

Thin to increase species and structural diversity. Shade and 

diversity protection in inner riparian. Large wood placement 

in stream. Instability concerns. Soils scientist to assist with 

layout to avoid areas of instability.

4 172 >30

Thin to increase species and structural diversity. Thin for 

Thin to increased tree vigor and stability. Soils scientist to 

assist with layout to avoid areas of instability.
Hwy 46 FEIS Appendix 

330

Unit Stand 

Age

Riparian Reserve 

Acres Stream 

Class

Riparian 

Reserve 

Width 

(feet)

NoHarvest 

Buffer 

(feet)

Rationale for Treatment within Riparian Reserve Total in 

Unit

Proposed 

Treatment

26 50 4.6 1.5 4 172 30

Thin to increase species and structural diversity. Consider 

adding LWD for sediment storage from above with fall and 

leave treatment under KV/stewardship.

27 122 15.0 5.1

3 172 100

Density reduction while protecting stream shade and 

diversity. Opportunity to Thin to increase large wood 

component instream.

4 172 100 Thin to reduce density and increase diversity. Post-sale 

opportunity to increase large wood component instream.

28 117 18.3 3.8

2 172 Healthy riparian, no treatment needed 1st site tree potential. 

Thin outer RR to maintain diversity.

4 172 172 Healthy riparian, no treatment needed 1st site tree potential

29 93 6.7 2.4

2 344 172 Healthy riparian, no treatment needed in 1st site tree potential. 

Trees to be used for fish logs (future restoration work).

4 172 172 Healthy riparian, no treatment needed.

30 50 3.4 3.1 4 172 30 Thin to increase structural and vegetative diversity

31 114 10.4 4.9 2 344 172 Thin to increase structural and vegetative diversity in outer 

RR

32 112 8.7 6.1

3 172 80

Thin to increase structural and vegetative diversity. Protect 

primary shade zone, large wood recruitment and channel 

stability.

4 172 30-60 Thin to increase structural and vegetative diversity. Protect 

large wood recruitment and channel stability.

32a 96 4.8 2.6 4 172 30-60 Meadow restoration and channel stability protection

33 36 9.2 7.1

3 172 60 Thin to increase structural and vegetative diversity. Protect 

primary shade zone.

4 172 30 Thin to increase structural and vegetative diversity

34 31 3.4 3.0 4 172 30

Thin to increase structural and vegetative diversity. Protect 

groundwater and wet areas. Also has a wet meadow 100’ 

buffer. 

35 30 6.1 0.0 3 172 172 No treatment in RR. Protect diversity and shallow 

groundwater around streams. Includes 100’ SHAB buffers.

38 34 4.6 0.0 4 172 172 No treatment in RR. Old plantation that could use treatment, 

but has stability concerns. 

40 223 1.8 1.8 2 344 172 Minimum stream buffer. May need additional buffer width 

for stability. Consult with Soils Scientist at layout. 

41 108 6.3 4.6 4 172 60 Very dense stand, Thin to increase structural and species 

diversity
Hwy 46 FEIS Appendix 

331

Unit Stand 

Age

Riparian Reserve 

Acres Stream 

Class

Riparian 

Reserve 

Width 

(feet)

NoHarvest 

Buffer 

(feet)

Rationale for Treatment within Riparian Reserve Total in 

Unit

Proposed 

Treatment

42 44 16.3 9.3

3-E 172 172

No treatment in RR. Mansfield Slide Unit: Minimum stream 

buffer. May need additional buffer width for stability. 

Soils/geology will assist with layout. 

3-SW 172 60 Thin to increase structural and vegetative diversity. Protect 

primary shade zone.

4-E 172 172 No treatment in RR. May need additional buffer width for 

stability. Soils/geology will assist with layout.

4-W 172 30 Minimum stream buffer. May need additional buffer width 

for stability. Soils/geology will assist with layout

44 51 5.4 2.8

2 344 100

Thin to increase structural and vegetative diversity. Protect 

primary shade zone and large wood recruitment for fish 

bearing stream.

4 172 30

Not meeting ACSO’s. Thin to increase structural and 

vegetative diversity. Underplant with mixed conifer and 

hardwoods. 

45 55 8.2 2.3

3 172 100 Very dense stand. Not meeting ACSO’s; Treat to Thin to 

increase stand vigor and structural and vegetative diversity 

while protecting water quality and stream channels from 

potential drainage concerns.

4 172 100

47 44 29.9 20.2

3 172 60

Thin to increase structural and vegetative diversity. 

Opportunity for post-sale fall and leave or tree-tipping to 

release hardwoods and increase large wood component.

4 172 30 Thin to increase structural and vegetative diversity.

48 26 5.5 4.1 4 172 30 Thin to increase structural and vegetative diversity. Protect 

groundwater and wet areas. Also has a 100’ SHAB buffer.

51 42 12.5 10.1 4 172 30

Thin to increase structural and vegetative diversity. Good 

opportunity for small gaps w/in outer RR or post-sale project 

to release hardwoods.

52 28 3.7 2.5 3 172 60 Very dense stand. Thin to increase structural and species 

diversity.

53 40 10.8 3.7

3 172 172

No treatment in RR. Minimum full site tree potential buffer 

to protect against stability issues in NE part of unit. 

Soils/Geology may assist with layout if needed.

4 172 60 Very dense stand. Thin to increase structural and species 

diversity and protect channel stability. 

55 43 12.3 8.7

3 172 60

Thin to increase structural and vegetative diversity. Protect 

primary shade zone. Unit also includes a 100’ buffer around 

the seep.

4 172 30 Thin to increase structural and vegetative diversity.
Hwy 46 FEIS Appendix 

332

Unit Stand 

Age

Riparian Reserve 

Acres Stream 

Class

Riparian 

Reserve 

Width 

(feet)

NoHarvest 

Buffer 

(feet)

Rationale for Treatment within Riparian Reserve Total in 

Unit

Proposed 

Treatment

58 42 0.7 0.7 3 172 60

Thin to increase structural and vegetative diversity. Protect 

primary shade zone. Stream and no-harvest buffer are outside 

of unit boundary.

60 29 2.1 1.9 4 172 30 Thin to increase structural and vegetative diversity.

61 39 13.6 11.3 4 172 30 Prior managed and very dense. In need of thinning for 

structural and species diversity.

62 41 22.5 14.7

3 172 60 Thin to increase structural and vegetative diversity. Protect 

primary shade zone and sediment filtration.

4 172 30 Thin to increase structural and vegetative diversity.

64 52 48.8 29.2

3 172 60 Thin to increase structural and vegetative diversity. Protect 

primary shade zone and sediment filtration.

4 172 30 Thin to increase structural and vegetative diversity.

69 54 8.0 4.4

3 172 60 Thin to increase structural and vegetative diversity, and 

protect primary shade zone. Addtl 100’ buffer on SHAB.

4 172 30 Thin to increase structural and vegetative diversity.

71 37 4.8 4.0 4 172 30 Thin to increase structural and species diversity. Protect 

shallow water table.

73 48 29.2 23.2 4 172 30 Thin to increase structural and species diversity. Protect 

shallow water table. 

74 50 36.6 17.1

3 172 100

No equipment or commercial harvest within 100’ of stream. 

Fall and leave or tree tipping recommended along Cultus 

Creek for sediment storage (separate KV or stewardship).

4 172 60

Thin to increase structural and species diversity with thinning

up to 60 feet from channel on the north side of channel, using 

the top of slope as a buffer edge. Do not treat the south slope. 

Recommend tipping some trees into stream channel to 

improve stability as post-sale opportunity.

75 33 14.5 7.3 4 172 30

Improve ACSO’s: Thin to increase structural and species 

diversity. Protect shallow groundwater. 100’ buffer on 

SHABs.

77 31 6.7 5.1 4 172 30 Thin to increase structural and vegetative diversity.

82 67 2.8 2.5 4 172 30 Thin to increase structural and vegetative diversity.

83 115 37.9 26.4

2 344 100* Thin to increase structural and vegetative diversity. Protect

primary shade zone and LWD recruitment. Opportunity to 

add wood instream post-sale. *Due to 2017 Scorpion fire 

encroachment in Riparian Reserves, RR treatment needs 

3 172 60*

4 172 30*
Hwy 46 FEIS Appendix 

333

Unit Stand 

Age

Riparian Reserve 

Acres Stream 

Class

Riparian 

Reserve 

Width 

(feet)

No-

Harvest 

Buffer 

(feet)

Rationale for Treatment within Riparian Reserve Total in 

Unit

Proposed 

Treatment

and final buffer determinations will be made prior to 

layout. Consultation with hydrologist required.

84 125 52.8 29.0

2 172 172 Achieving ACSO’s. Thin to increase structural and vegetative 

diversity in outer RR.

3 172 60 Thin to increase structural and vegetative diversity. Protect

primary shade zone

4 172 30-60 Thin to increase structural and vegetative diversity.

89 450 1.4 1.24 172 30 Thin to increase structural and vegetative diversity 

(understory enhancement).

93 140 12.57.8 4* 172 60* Thin to increase structural and vegetative diversity. Protect 

instability at lower end with SHAB buffer. *Stream recorded 

as intermittent during stream survey, but should be confirmed 

at layout if perennial or intermittent-->100’ buffer if 

perennial.

94 105 11.0 6.1 4* 172 60*

95 110 23.6 2.6

3 172 100

Thin to increase structural and vegetative diversity. Protect 

primary shade and wood recruitment. Buffer may need to be 

wider to protect stability by slump area. Soils/Geology will

assist with layout.

4 172 60

Thin to increase structural and vegetative diversity and wood 

recruitment. Buffer may need to be wider to protect stability 

by slump area. Soils/Geology will assist with layout.

96 145 3.6 1.23 172 100 Thin to increase structural and vegetative diversity. Protect 

primary shade and wood recruitment.

100 45 45.8 27.5

3 172 100

East-West Class 3: Treat riparian on N-side of stream-clumpy 

gappy fall and leave to 70-90 tpa to Thin to increase 

structural and species diversity and lwd instream.

3 172 60

Thin to increase structural and species diversity. Protect 

primary shade and accelerate wood recruitment. Treat Leone 

Crk and east trib Class 3’s above road

4 172 60 Thin to increase structural and species diversity. Protect 

primary shade and wood recruitment. 

110 40 30.1 17.4

3 172 60 Thin to increase structural and species diversity, and protect 

primary shade.

4 172 60 Thin to increase structural and species diversity. 

120 45 9.1 5.6

3 172 60 Thin to increase structural and species diversity, and protect 

primary shade.

4 172 30 Thin to increase structural and species diversity. 

130 47 16.3 10.33 172 60 Thin to increase structural and species diversity. Protect 

primary shade.
Hwy 46 FEIS Appendix 

334

Unit Stand 

Age

Riparian Reserve 

Acres Stream 

Class

Riparian 

Reserve 

Width 

(feet)

NoHarvest 

Buffer 

(feet)

Rationale for Treatment within Riparian Reserve Total in 

Unit

Proposed 

Treatment

4 172 30 Thin to increase structural and species diversity.

140 47 31.2 11.6 3 172 172 On way to achieving ACSO’s. Protect slope and channel 

stability. No treatment in RR.

150 118 10.5 6.6 2 344 172 On way to achieving ACSO’s in 1st STP. Thin to increase

structural and species diversity in outer RR.

160 45 8.1 6.4 4 172 30 Thin to increase structural and species diversity. Stream 

location may need additional verification at layout.

170 No 

data 73.8 46.7 1 344 100*

Fuels unit: reduce fuel loading in RR near communities. 

Protect riparian features. Work with hydro/fish at layout 

where in RR fire can back into.

180 35 8.5 6.8 2 344 172

Meeting ACSO’s along most of Hill Creek. Unit boundary is 

right around 1st STP. At unit boundary stand is old plantation, 

very dense monoculture and needs treatment to increase 

diversity. 

190 45 33.4 19.8

2 344 100

Meeting ACSO’s in places and not in others, like north part. 

Treat streamside area along Hill Creek lightly for hardwood 

release with fall and leave. Protect stream shade and areas 

meeting ACSO’s. Thin to increase structural and species 

diversity in RR and streamside treatment areas. 

3 172 60 Thin to increase structural and species diversity. Protect 

primary shade.

4 172 30-200*

Minimum buffer to increase structural and species diversity. 

*Stream buffer connected to 100’ buffers around skunk 

cabbage swamps. Likely very little treatment inside RR.

200 45 11.8 6.5 3 172 60 Thin to increase structural and species diversity. Protect 

primary shade and wood recruitment.

210 No 

data 0.4 0.4

2 344 172

Fuels unit: Allow low intensity fire to back into RR. 4 172 50

220 45 40.8 13.9

2 344 172 Achieving ACSO’s in 1st STP of Hill Creek. Thin to increase 

structural and species diversity in 2nd STP.

4 172 60 Thin to increase structural and species diversity. Protect 

LWD source.

250 44 0.2 0.0 4 172 200+ Class 4 stream protected from harvest by 100’ SHAB buffer 

around wet meadow.

270 275 2.9 2.1

1 344 250-344

3 172 100 Fuels unit: Allow low intensity fire to back into RR. 

4 172 50
Hwy 46 FEIS Appendix 

335

Unit Stand 

Age

Riparian Reserve 

Acres Stream 

Class

Riparian 

Reserve 

Width 

(feet)

NoHarvest 

Buffer 

(feet)

Rationale for Treatment within Riparian Reserve Total in 

Unit

Proposed 

Treatment

290 47 34.0 3.5

3 172 172 Achieving ACSO’s. No treatment in RR.

4 172 60 Not achieving ACSO’s; Thin to increase species and 

structural diversity. Protect near channel stability. 

300 40 41.2 20.3

3 172 60-172

Skunk Creek Riparian area functioning in 1st STP. Protect 

ACSO’s. Thin to increase structural and species diversity in 

outer RR. 

4 172 30 Thin to increase structural and species diversity and channel 

stability and LWD source.

310 50 4.1 2.8

3 172 172 Skunk Creek Riparian area functioning in 1st STP; Protect 

ACSO’s.

4 172 30 Thin to increase species and structural diversity.

320 30 19.8 10.3

3 172 172 Full STP buffer on Skunk Creek, protect riparian achieving 

ACSO’s – keep harvest above the road. No treatment in RR.

3 172 60 Thin to increase species and structural diversity.

4 172 30*

Thin to increase species and structural diversity. Northernmost Cls 4 stream requires Hydrologist and Soil Scientist 

input at layout to avoid unstable slopes.

340 45 18.2 8.7 2 344 172+

No harvest w/in first STP, where achieving ACSO’s and 

rocky. Thinning in 2nd STP in southern part of unit where 

trees are smaller and denser to increase structural and species 

diversity.

350 39 13.7 5.5

2 344 172 Full STP on fish bearing Devils Creek. Thin to increase stand 

health in outer RR.

3 172 100

Plantation, not achieving ACSO’s. Thin to increase species 

and structural diversity in outer RR. Protect stream shade and 

large wood recruitment.

4 172 60 Thin to increase species and structural diversity, while 

protecting steep slopes and channel stability.

360 40 12.2 7.8

2 344 172 Increasing structural diversity in 2nd STP.

4 172 30-60

Not achieving ACSO’s. Thin to increase riparian area species 

and structural diversity. Wider buffer on north-most Class 4 

stream due to post-fire debris flow susceptibility from 

upstream.

370 34 23.1 15.3

2 344 172 Achieving ACSO’s, protect 1st STP. Thin to increase species 

and structural diversity om outer RR.

4 172 30 Not achieving ACSO’s, Thin to increase species and 

structural diversity.
Hwy 46 FEIS Appendix 

336

Unit Stand 

Age

Riparian Reserve 

Acres Stream 

Class

Riparian 

Reserve 

Width 

(feet)

NoHarvest 

Buffer 

(feet)

Rationale for Treatment within Riparian Reserve Total in 

Unit

Proposed 

Treatment

380 39 24.1 16.8

2 344 172 Full STP buffer to protect ACSO’s in Devil’s Creek riparian. 

Thin to increase species and structural diversity in outer RR.

3 172 60 Thin to increase species and structural diversity

4 172 30

Thin to increase species and structural diversity. *Several 

streams go subsurface mid-way down the unit, indicating 

shallow groundwater. Restrict equipment use in lower part of 

unit. Rec’d some hardwood release along Class 3 stream as 

post-sale opportunity..

390 37 8.0 3.8

3 172 172 Achieving ACSO’s. No treatment in RR.

4 172 30 Thin to increase species and structural diversity. *See Unit 

380

400 47 20.8 10.9 4 172 30 Thin to increase species and structural diversity. *See Unit 

380

420 40 2.6 1.8

2 344 172

Full site tree potential on N. Fk Breitenbush River. Protect 

ACSO’s. Thin to increase species and structural diversity in 

outer RR.

4 172 60 Thin to increase species and structural diversity. Protect 

channel stability.

430 40 9.1 5.5

2 344 172

Full site tree potential on N. Fk Breitenbush River. Protect 

ACSO’s. Thin to increase species and structural diversity in 

outer RR.

3 172 100

Historic and re-occuring debris flow 100' no-harvest buffer 

depending on debris. Fall and leave within NH buffer for lwd 

recruitment source to N. Fk Breit downslope. Also thin to 

increase species and structural diversity.

440 35 8.9 1.3 2 344 220+

Minimum buffer of 60 ft from edge of alder patch along the 

N.Fork Breitenbush riparian area, plus additional 100 ft 

buffer around SHAB/swamp. 

450 34 5.6 4.5 4 172 30 Thin to increase species and structural diversity.

460 43 3.9 2.5

3 172 60 Thin to increase species and structural diversity. Class 3 

streams go subsurface above road. All streams to be treated 

as perennial. Thin to increase riparian species and structure. 

Protect shallow groundwater/subsurface flow.

4 172 60

470 44 6.9 2.7

2 344 100 Crown Creek achieving ACSO’s in inner riparian. Thin to 

increase structure and species diversity in outer RR.

3 172 60 Thin to increase structural and species diversity. Protect 

primary shade, wood recruitment, and shallow groundwater. 4 172 60
Hwy 46 FEIS Appendix 

337

Unit Stand 

Age

Riparian Reserve 

Acres Stream 

Class

Riparian 

Reserve 

Width 

(feet)

NoHarvest 

Buffer 

(feet)

Rationale for Treatment within Riparian Reserve Total in 

Unit

Proposed 

Treatment

480 43 7.0 4.4 3 172 60-172*

Lower part near road meeting ACSO's or close to ->full STP 

buffer. Upper section is heading towards ACSO's but should 

have 'treatment to 60’ no-harvest buffer to reduce density and 

Thin to increase stand vigor. Variable buffer on layout.

490 45 7.1 5.0

3 172 60

Additional 60’ buffer around wetlands in between units. Thin 

to increase species and structural diversity in RR outside of 

buffers, promote understory growth and protect primary 

shade and microclimate. 

4 172 30 Thin to increase species and structural diversity, promote 

understory growth. 

510 40 4.0 2.8

3 172 60

Additional 60’ buffer around wetlands in between units. Thin 

to increase species and structural diversity in RR outside of 

buffers, promote understory growth and protect primary 

shade and microclimate. 

4 172 30

Thin to increase species and structural diversity, promote 

understory growth. 

520 45 33.3 24.3

3 172 60 Fall and leave and hardwood release treatment within no 

commercial harvest buffer to Thin to increase diversity of 

stand and large wood component instream. 4 172 30

530 39 2.1 0.5 4 172 60 Thin to increase species and structural diversity, promote 

understory growth.

540 40 1.4 1.4 4 172 172 Very diverse stand with small trees and good species 

diversity. No treatment needed at this time.
Hwy 46 FEIS Appendix 

338

Appendix H – Road Status and Anticipated Road Work 

Activities 

Road Status

The Road Investment Strategy (RIS) recommended roads Remain Closed (RC), Analyze for Closure (AC), 

Analyze for Decommissioning (AD), Defer Recommendation for later analysis (DR), and Remain Open 

(RO). The RIS also identified many forest roads as Priority Roads (PR). 

Maintenance Levels. Defines the level of service provided by, and maintenance required for, a specific 

road, consistent with road management objectives and maintenance criteria. (FSH 7709.58, 12.3)

Maintenance Level 1. Assigned to intermittent service roads during the time they are closed to 

vehicular traffic. The closure period must exceed 1 year. Basic custodial maintenance is 

performed to keep damage to adjacent resource to an acceptable level and to perpetuate the 

road to facilitate future management activities. Emphasis is normally given to maintaining 

drainage facilities and runoff patterns. Planned road deterioration may occur at this level. 

Appropriate traffic management strategies are "prohibit" and "eliminate". Roads receiving level 

1 maintenance may be of any type, class or construction standard, and may be managed at any 

other maintenance level during the time they are open for traffic. However, while being 

maintained at level 1, they are closed to vehicular traffic, but may be open and suitable for nonmotorized uses. (FSH 7709.58, 12.3)

Maintenance Level 2. Assigned to roads open for use by high clearance vehicles. Passenger car 

traffic is not a consideration. Traffic is normally minor, usually consisting of one or a 

combination of administrative, permitted, dispersed recreation, or other specialized uses. Log 

haul may occur at this level. Appropriate traffic management strategies are either to (1) 

discourage or prohibit passenger cars or (2) accept or discourage high clearance vehicles. (FSH 

7709.58, 12.3)

Maintenance Level 3. Assigned to roads open and maintained for travel by a prudent driver in a 

standard passenger car. User comfort and convenience are not considered priorities. Roads in 

this maintenance level are typically low speed, single lane with turnouts and spot surfacing. 

Some roads may be fully surfaced with either native or processed material. Appropriate traffic 

management strategies are either "encourage" or "accept." "Discourage" or "prohibit" 

strategies may be employed for certain classes of vehicles or users. (FSH 7709.58, 12.3)

Maintenance Level 4. Assigned to roads that provide a moderate degree of user comfort and 

convenience at moderate travel speeds. Most roads are double lane and aggregate surfaced. 

However, some roads may be single lane. Some roads may be paved and/or dust abated. The 

most appropriate traffic management strategy is "encourage." However, the "prohibit" strategy 

may apply to specific classes of vehicles or users at certain times. (FSH 7709.58, 12.3)

Maintenance Level 5. Assigned to roads that provide a high degree of user comfort and 

convenience. These roads are normally double-lane, paved facilities. Some may be aggregate 

surfaced and dust abated. The appropriate traffic management strategy is "encourage." (FSH 

7709.58, 12.3)
Hwy 46 FEIS Appendix 

339

Table 59 Road Status within Hwy 46 Planning Area

Road #

(Haul Routes 

in bold)

Haul 

Miles

Alt. 2

Haul 

Miles

Alt. 3

Existing

Road Status

Current Mtc.

Level

System Miles

Analyzed

RIS

Recommendation

Hwy 46 EIS

Alt 2 & 3 Proposal

Proposed Mtc. 

Level

Remarks

2231000 13.35 13.35 Open 2 13.54 PR RO 2 Prime road.

2231730 3.12 3.12 Open 2 3.40 PR RO 2 Prime road.

2231731 Open 2 0.21 RO RO 2

Matrix – Needed 

for future timber 

access.

2231732 0.24 0.24 Closed 1 0.40 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Matrix –

Needed for future 

timber access.

2231733 0.22 0.22 Closed 1 0.22 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Matrix –

Needed for future 

timber access.

2231734 Closed 1 0.28 RC RC 1

Matrix – Needed 

for future timber 

access.

2231735 Closed 1 0.40 RC RC 1

Matrix – Needed 

for future timber 

access.

2231736 0.05 0.05 Closed 1 0.16 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Matrix –

Needed for future 

timber access.

2231738 Closed 1 0.12 RC RC 1

Matrix – Needed 

for future timber 

access.

2231739 Open 2 0.13 RO RO 2

Matrix – Needed 

for future timber 

access.

2231740 0.10 0.10 Closed 1 0.10 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Matrix –

Needed for future 

timber access.

2231746 0.17 Closed 1 0.55 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Matrix –

Needed for future 

timber access.

2231747 0.44 Closed 1 0.44 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Matrix –

Needed for future 

timber access.

2231748 Open 2 0.06 RC RO 2 Road to remain 

open for resource 
Hwy 46 FEIS Appendix 

340

Road #

(Haul Routes 

in bold)

Haul 

Miles

Alt. 2

Haul 

Miles

Alt. 3

Existing

Road Status

Current Mtc.

Level

System Miles

Analyzed

RIS

Recommendation

Hwy 46 EIS

Alt 2 & 3 Proposal

Proposed Mtc. 

Level

Remarks

administration. 

Needed for future 

timber access.

2231749 0.09 0.09 Closed 1 0.09 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Matrix –

Needed for future 

timber access.

2231750 0.05 0.05 Open 2 0.50 RO RO 2

Road to remain 

open for resource 

administration.

2231751 Closed 1 0.37 RC RC 1

Matrix – Needed 

for future timber 

access.

2231752 Closed 1 0.20 RC RC 1

Matrix – Needed 

for future timber 

access.

2231753 Open 2 0.08 RO RO 2

Road to remain 

open for resource 

administration.

2231755 Open 2 0.09 RO RO 2

Road to remain 

open for resource 

administration.

2231757 Closed 1 0.63 RC RC 1

Matrix – Needed 

for future timber 

access.

2231758 0.07 0.07 Open 2 0.07 RO RO 2

Road to remain 

open for resource 

administration. 

Matrix – Needed 

for future timber 

access.

2231759 0.61 0.61 Closed 1 0.61 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Matrix –

Needed for future 

timber access.

2231760 Closed 1 0.38 RC RC 1

Matrix – Needed 

for future timber 

access.

2231761 0.06 0.06 Closed 1 0.06 RC AD -

Road will be 

decommissioned 

and taken off the 

system.

2231763 0.41 0.41 Closed 1 0.54 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

2231764 0.30 0.30 Closed 1 0.88 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Matrix –
Hwy 46 FEIS Appendix 

341

Road #

(Haul Routes 

in bold)

Haul 

Miles

Alt. 2

Haul 

Miles

Alt. 3

Existing

Road Status

Current Mtc.

Level

System Miles

Analyzed

RIS

Recommendation

Hwy 46 EIS

Alt 2 & 3 Proposal

Proposed Mtc. 

Level

Remarks

Needed for future 

timber access.

2231765 0.18 0.18 Closed1 0.48 RC AD-

Road will be 

decommissioned 

and taken off the 

system.

2231768 Closed1 0.22 RC RC1

Matrix – Needed 

for future timber 

access.

2231809 Closed1 0.12 RO RC1

Road to remain 

stored for resource 

protection. Needed 

for future timber 

access.

2231828 Open2 0.14 RO RO2 Needed for future 

timber access.

2231835 Closed1 0.61 RC RC1 Needed for future 

timber access.

2231836 Closed1 0.13 RC RC1 Needed for future 

timber access.

2231837 Closed1 0.04 RC RC1 Needed for future 

timber access.

2231838 Closed1 0.84 RC RC1 Needed for future 

timber access.

2231839 0.28 Closed1 0.28 RC RC1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

2231840 0.69 Open2 3.25 PR RO2 Needed for future 

timber access.

2231841 Closed1 0.28 RC RC1 Needed for future 

timber access.

2231842 Closed1 0.24 RC RC1 Needed for future 

timber access.

2231844 Open2 0.08 PR RO2 Needed for future 

timber access.

2231845 Closed1 0.24 RC RC1 Needed for future 

timber access.

2231846 Closed1 0.42 PR RC1

Road to remain 

stored for resource 

protection. Needed 

for future timber 

access.

2231847 0.53 0.53 Closed1 0.88 PR RO2

Road will be used 

then remain open. 

Access to Leone 

Lake Trailhead.

2231848 Closed1 0.25 RC RC1 Needed for future 

timber access.

2231849 0.22 0.22 Closed1 0.22 RC RC1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.
Hwy 46 FEIS Appendix 

342

Road #

(Haul Routes 

in bold)

Haul 

Miles

Alt. 2

Haul 

Miles

Alt. 3

Existing

Road Status

Current Mtc.

Level

System Miles

Analyzed

RIS

Recommendation

Hwy 46 EIS

Alt 2 & 3 Proposal

Proposed Mtc. 

Level

Remarks

2231850 1.61 1.61 Open2 4.88 PR RO2 Needed for future 

timber access.

2231851 Closed1 0.27 RO RC1

Road to remain 

stored for resource 

protection. Needed 

for future timber 

access.

2231852 Closed1 0.11 RC RC1 Needed for future 

timber access.

2231853 Closed1 0.25 RC RC1 Needed for future 

timber access.

2231854 0.48 0.48 Closed1 0.77 RC RC1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

2231855 1.06 1.06 Closed1 1.06RC RC1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

2231856 Closed1 0.21 RC RC1 Needed for future 

timber access.

2231857 0.24 0.24 Closed1 0.41 RC RC1

Road will be used 

then stored again 

for resource

protection. Needed 

for future timber 

access.

2231858 Closed1 0.08 RC RC1 Needed for future 

timber access.

2231859 Closed1 0.10 RC RC1 Needed for future 

timber access.

2231860 Open2 0.34 RC RO2

Road to remain 

open for resource 

administration. 

Needed for future 

timber access.

2231861 Open2 0.11 RO RO2

Needed for future 

timber access. 

Needed for future 

timber access.

2231862 Open2 0.05 RO RO2 Needed for future 

timber access.

2231863 Open2 0.21 DR AC1

Road to be stored 

for resource 

protection. Matrix –

Needed for future 

timber access.

2231866 Open2 0.05 RC RO2

Road to remain 

open for resource 

administration.

2231867 Closed1 0.12 RC RC1 Needed for future 

timber access.
Hwy 46 FEIS Appendix 

343

Road #

(Haul Routes 

in bold)

Haul 

Miles

Alt. 2

Haul 

Miles

Alt. 3

Existing

Road Status

Current Mtc.

Level

System Miles

Analyzed

RIS

Recommendation

Hwy 46 EIS

Alt 2 & 3 Proposal

Proposed Mtc. 

Level

Remarks

2231868 Closed1 0.29 RC RC1 Needed for future 

timber access.

2231869 Closed1 0.13 RC RC1 Needed for future 

timber access.

2231870 4.99 4.99 Open2 7.15 PR RO2 Prime road.

2231870 Open2 0.62 PR AD-

Last 0.62 miles of 

road will be 

decommissioned 

and taken off the 

system.

2231871 0.02 0.02 Closed1 0.06 AD AD-

Road will be 

decommissioned 

and taken off the 

system after use.

2231872 Closed1 0.11 RC RC1 Needed for future 

timber access.

2231873 0.14 0.14 Open2 0.14 RO RO2 Needed for future 

timber access.

2231874 0.16 0.16 Closed1 0.16 RC RC1

Road will be used 

then stored again 

for resource 

protection.

2231875 0.70 0.70 Closed1 0.92 RC RC1

Road will be used 

then stored again 

for resource 

protection but 

needed for mineral 

material access.

2231876 Closed1 0.15 RC RC1 Needed for future 

timber access.

2231877 0.40 0.40 Closed1 1.05 RC RC1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

2231878 0.10 0.10 Open2 0.09 RO RO2 Needed for future 

timber access.

2231879 Closed1 1.19 RC RC1 Needed for future 

timber access.

2231880 Closed1 0.82 RC AD-

Road will be 

decommissioned 

and taken off the 

system.

2231881 Closed1 0.51 RC RC1 Needed for future 

timber access.

2231883 0.09 0.09 Closed1 1.63 RC RC1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access. 

2231883 Closed1 0.57 RC AD-

Last 0.57 miles of 

road will be 

decommissioned 

and taken off the 

system.
Hwy 46 FEIS Appendix 

344

Road #

(Haul Routes 

in bold)

Haul 

Miles

Alt. 2

Haul 

Miles

Alt. 3

Existing

Road Status

Current Mtc.

Level

System Miles

Analyzed

RIS

Recommendation

Hwy 46 EIS

Alt 2 & 3 Proposal

Proposed Mtc. 

Level

Remarks

2231884 Closed1 0.10 RC RC1 Needed for future 

timber access.

2231885 Closed1 1.6 RC RC1 Needed for future 

timber access.

2231886 Closed1 0.08 RC RC1 Needed for future 

timber access.

2231887 0.04 0.04 Open2 0.04 AC AC1

Road to be stored 

after use for 

resource 

protection. Matrix –

Needed for future 

timber access.

2231888 Open2 0.37 DR AC1

Road to be stored 

for resource 

protection. Matrix –

Needed for future 

timber access.

2231889 Open2 0.09 DR AC1

Road to be stored 

for resource 

protection. Matrix –

Needed for future 

timber access.

2231890 Open3 1.92 PR RO3

Breitenbush 

Community Access

2231891 Open2 0.15 PR RO2 Breitenbush 

Community Access

2231892 Closed1 0.11 RC RC1 Breitenbush 

Community Access

2231893 Open2 0.32 PR RO2 Breitenbush 

Community Access

2231894 Open2 0.04 PR RO2 Breitenbush 

Community Access

2231895 Open2 0.04 PR RO2 Breitenbush 

Community Access

2231896 Open2 0.47 PR RO2 Breitenbush 

Community Access

2231897 Open2 0.05 PR RO2 Breitenbush 

Community Access

2231898 Open2 0.16 PR RO2 Breitenbush 

Community Access

2231899 Closed1 0.18 RC RC1 Breitenbush 

Community Access

2231900 0.13 0.13 Open2 0.13 RO RO2 Needed for future 

timber access.

2231901 Closed1 0.10 RC RC1 Needed for future 

timber access.

2231902 Open2 0.08 RC RO2

Road to remain 

open for resource 

administration. 

Needed for future 

timber access.

2233000 Open2 11.60 PR RO2 Needed for future 

timber access.

2233635 Closed1 0.75 RC RC1 Needed for future 

timber access.

4600000 16.55 16.55 Open5 16.5 PR RO5 Prime road.
Hwy 46 FEIS Appendix 

345

Road #

(Haul Routes 

in bold)

Haul 

Miles

Alt. 2

Haul 

Miles

Alt. 3

Existing

Road Status

Current Mtc.

Level

System Miles

Analyzed

RIS

Recommendation

Hwy 46 EIS

Alt 2 & 3 Proposal

Proposed Mtc. 

Level

Remarks

4600011 0.16 0.16 Open 2 0.23 DR RO 2

Road to remain 

open for powerline 

access.

4600012 1.28 1.28 Open 2 1.73 DR RO 2

Road to remain 

open for powerline 

access.

4600013 Closed 1 0.67 RO RC 1

Needed for future 

timber access and 

mineral materials 

access.

4600014 0.57 0.57 Open 2 0.57 RO RO 2

Road to remain 

open for powerline 

access.

4600015 Closed 1 0.30 DR AD -

Road will be 

decommissioned 

and taken off the 

system.

4600016 Open 2 0.10 DR AD -

Road will be 

decommissioned 

and taken off the 

system.

4600017 Open 2 0.13 PR RO 2 Prime road.

4600018 Open 2 0.13 DR AC 1

Road to be stored 

for resource 

protection. Needed 

for future timber 

access.

4600021 0.29 0.29 Open 2 0.76 DR RO 2

Road to remain 

open for resource 

administration. 

Powerline access.

4600022 0.55 0.55 Open 2 0.55 DR RO 2

Road to remain 

open for resource 

administration. 

Powerline access.

4600023 0.21 0.21 Open 2 0.38 RO RO 2

Road to remain 

open for resource 

administration. 

Powerline access.

46000024 0.50 0.50 Open 2 0.50 RO AC 1

Road to be stored 

after use for 

resource 

protection. Needed 

for future timber 

access.

4600025 0.13 0.13 Open 2 0.31 DR RO 2

Road to remain 

open for resource 

administration. 

Powerline access.

4600026 0.12 0.12 Open 2 0.12 RO RO 2

Road to remain 

open for resource 

administration. 

Powerline access.

4600027 0.17 Closed 1 0.15 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Needed 
Hwy 46 FEIS Appendix 

346

Road #

(Haul Routes 

in bold)

Haul 

Miles

Alt. 2

Haul 

Miles

Alt. 3

Existing

Road Status

Current Mtc.

Level

System Miles

Analyzed

RIS

Recommendation

Hwy 46 EIS

Alt 2 & 3 Proposal

Proposed Mtc. 

Level

Remarks

for future timber 

access.

4600027 Closed 1 0.05 RC AD -

Last 0.05 miles of 

road will be 

decommissioned 

and taken off the 

system.

4600028 0.23 Closed 1 1.05 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

4600030 2.27 2.27 Open 2 1.07 RO RO 2

Road to remain 

open for resource 

administration.

4600030 Open 2 1.20 RO AD -

Last 1.20 miles of 

road will be 

decommissioned 

and taken off the 

system.

4600031 Closed 1 0.10 RC AD -

Road will be 

decommissioned 

and taken off the 

system.

4600032 Open 2 0.12 DR RO 2

Road to remain 

open for resource 

administration. 

Needed for future

timber access.

4600033 1.88 1.88 Open 2 2.43 RO RO 2

Road to remain 

open for resource 

administration. 

Needed for future 

timber access.

4600034 Closed 1 0.09 RC RC 1 Needed for future 

timber access.

4600035 0.30 0.30 Closed 1 0.45 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

4600036 0.30 0.30 Closed 1 0.52 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

4600037 0.06 0.06 Open 2 0.06 AC AC 1

Road to be stored 

after use for wildlife 

protection. Needed 

for future timber 

access.

4600038 0.04 0.04 Open 2 0.04 DR AC 1

Road to be stored 

after use for wildlife 

protection. Needed 
Hwy 46 FEIS Appendix 

347

Road #

(Haul Routes 

in bold)

Haul 

Miles

Alt. 2

Haul 

Miles

Alt. 3

Existing

Road Status

Current Mtc.

Level

System Miles

Analyzed

RIS

Recommendation

Hwy 46 EIS

Alt 2 & 3 Proposal

Proposed Mtc. 

Level

Remarks

for future timber 

access.

4600039 Open 2 0.06 RC AC 1

Road to be stored 

for wildlife 

protection. Needed 

for future timber 

access.

4600040 4.23 3.10 Open 2 4.52 RO RO 2

Short Lake Reroute. 

Decommission 1.02 

miles around Lake. 

Reroute through 

4600045 and 

4600059.

4600041 Closed 1 0.96 RC RC 1

4600042 Closed 1 0.12 AD AD —

Road will be 

decommissioned 

and taken off the 

system.

4600043 Open 2 0.56 RC RO 2

Road to remain 

open for resource 

administration. 

Powerline access.

4600044 0.21 0.21 Closed 1 0.36 RC RC 1

Road will be used 

then stored again 

for resource 

protection. 

Powerline access.

4600045 3.15 3.15 Open 2 3.10 RO RO 2

Keep road open 

after sale. Short 

Lake Reroute.

4600046 0.30 Closed 1 0.32 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

4600047 0.20 0.20 Closed 1 0.51 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

4600049 0.16 0.16 Open 2 0.16 RO RO 2 Needed for future 

timber access.

4600050 Open 2 1.00 RO RO 2 Breitenbush 

community access.

4600050 Open 2 0.46 RO AD -

Decommission last 

0.46 miles and take 

off system.

4600051 Closed 1 0.09 RC AD -

Road will be 

decommissioned 

and taken off the 

system.

4600052 Open 2 0.11 DR AD -

Road will be 

decommissioned 

and taken off the 

system.
Hwy 46 FEIS Appendix 

348

Road #

(Haul Routes 

in bold)

Haul 

Miles

Alt. 2

Haul 

Miles

Alt. 3

Existing

Road Status

Current Mtc.

Level

System Miles

Analyzed

RIS

Recommendation

Hwy 46 EIS

Alt 2 & 3 Proposal

Proposed Mtc. 

Level

Remarks

4600053 0.23 Closed 1 0.23 AD RC 1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

4600054 0.26 Closed 1 0.31 AD AD —

Road will be 

decommissioned 

and taken off the 

system.

4600055 0.53 0.53 Closed 1 0.53 AD AD —

Road will be 

decommissioned 

and taken off the 

system.

4600056 0.24 Open 2 0.24 RC RO 2

Road to remain 

open for resource 

administration. 

Needed for future 

timber access.

4600057 Open 2 0.42 RC RO 2

Road to remain 

open for resource 

administration. 

Needed for future 

timber access.

4600058 0.09 Closed 1 0.30 AD AD —

Road will be 

decommissioned 

and taken off the 

system.

4600059 Closed 1 0.31 RC RO 2

Short Lake Reroute. 

Decommission 0.30 

miles and use new 

realignment of 0.30 

miles. Keep road 

open.

4600060 Open 3 0.14 RO RO 3

Road to remain 

open for resource 

administration. 

Needed for future 

timber access.

4600061 0.12 Closed 1 0.15 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

4600062 Closed 1 0.24 RC RC 1

Road will remain 

stored for resource 

protection. Needed 

for future timber 

access.

4600063 Open 3 0.37 PR RO 3 Prime road.

4600064 Open 3 0.23 PR RO 3 Prime road.

4600066 0.02 Closed 1 0.40 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Needed 
Hwy 46 FEIS Appendix 

349

Road #

(Haul Routes 

in bold)

Haul 

Miles

Alt. 2

Haul 

Miles

Alt. 3

Existing

Road Status

Current Mtc.

Level

System Miles

Analyzed

RIS

Recommendation

Hwy 46 EIS

Alt 2 & 3 Proposal

Proposed Mtc. 

Level

Remarks

for future timber 

access. 

4600067 Closed 1 0.04 AD AD -

Road will be 

decommissioned 

and taken off the 

system.

4600069 Open 2 0.02 RO RO 2

Road to remain 

open for resource 

administration. 

Needed for future 

timber access. 

4600070 Open 2 0.27 RO RO 2

Road to remain 

open for resource 

administration. 

Needed for future 

timber access. 

4600071 0.45 0.45 Open 2 0.45 RO RO 2

Road to remain 

open for resource 

administration. 

Powerline access.

4600072 Open 2 0.47 RO RO 2

Road to remain 

open for resource 

administration. 

Powerline access.

4600073 Open 2 0.11 AC RO 2

Road to remain 

open for resource 

administration. 

Powerline access.

4600074 Open 2 0.44 AC RO 2

Road to remain 

open for resource 

administration. 

Powerline access.

4600075 Open 3 0.40 RO RO 3

Road to remain 

open for resource 

administration. 

Needed for 

recreation access.

4600076 Open 2 0.27 AC RO 2

Road to remain 

open for resource 

administration. 

Powerline access.

4600077 Open 2 0.07 RO AD -

Road will be 

decommissioned 

and taken off the 

system for resource 

protection.

4600078 0.10 0.10 Open 2 0.10 AD AC 1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

4600079 Open 2 0.29 DR RO 2

Road to remain 

open for resource 

administration. 

Powerline access.
Hwy 46 FEIS Appendix 

350

Road #

(Haul Routes 

in bold)

Haul 

Miles

Alt. 2

Haul 

Miles

Alt. 3

Existing

Road Status

Current Mtc.

Level

System Miles

Analyzed

RIS

Recommendation

Hwy 46 EIS

Alt 2 & 3 Proposal

Proposed Mtc. 

Level

Remarks

4600081 Open2 0.03 AD RO2

Road to remain 

open for resource 

administration. 

Needed for 

recreation access.

4600082 Open2 0.06 DR RO2

Road to remain 

open for resource 

administration. 

Needed for 

recreation access.

4600084 Closed1 0.07 RC RC1

Road will remain 

stored for resource 

protection. Needed 

for future timber 

access.

4600084 Closed1 0.29 RC AD- Decommission last 

0.29

4600085 Open20.24 RO RO2 Needed for future 

timber access.

4600086 Open2 0.73 RO RO2 Needed for future 

timber access.

4600087 Open2 0.13 RO RO2 Needed for future 

timber access.

4600088 0.28 0.28 Open2 0.28 RO RO2 Needed for future 

timber access.

4600090 Open2 0.66 RO RO2 Needed for future 

timber access.

4600091 Open2 0.40 RO RO2 Needed for future 

timber access.

4600092 Open2 0.48 AD RO2

Road to remain 

open for resource 

administration. 

Powerline access.

4600094 0.21 0.21 Open2 0.16 AC RO2

Road to remain 

open for resource 

administration. 

Powerline access.

4600095 0.32 0.32 Open2 0.32 AC RO2

Road to remain 

open for resource 

administration. 

Powerline access.

4600097 0.63 0.63 Open2 0.63 RO RO2 Powerline access.

4600111 Open2 0.12 AD RO2

Road to remain 

open for resource 

administration. 

Needed for 

recreation access.

4600113 Open2 0.07 AD RO2

Road to remain 

open for resource 

administration. 

Needed for 

recreation access.

4600114 Open2 0.07 AD RO2

Road to remain 

open for resource 

administration. 

4600115 Open2 0.14 AD RO2 Road to remain 

open for resource 
Hwy 46 FEIS Appendix 

351

Road #

(Haul Routes 

in bold)

Haul 

Miles

Alt. 2

Haul 

Miles

Alt. 3

Existing

Road Status

Current Mtc.

Level

System Miles

Analyzed

RIS

Recommendation

Hwy 46 EIS

Alt 2 & 3 Proposal

Proposed Mtc. 

Level

Remarks

administration. 

Needed for 

recreation access.

4600116 Open2 0.13 RO RO2 Needed for future 

timber access.

4600117 0.07 Open2 0.08 AD AC1

Road to be stored 

for resource

protection but 

needed for access 

to helicopter 

landing and future 

timber needs.

4600287 Open2 0.15 AD AC1

Road to be stored 

for resource 

protection but 

needed for future 

timber needs.

4600289 0.06 0.06 Closed1 0.08 RC RC1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

4600297 0.23 Closed1 0.30 RC RC1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

4685000 8.39 8.39 Open2 8.71 RO RO2 Major recreation 

access.

4685111 Open2 0.13 DR AD-

Road will be 

decommissioned 

and taken off the 

system for resource 

protection.

4685301 Open2 0.47 RO AD-

Road will be 

decommissioned 

and taken off the 

system for resource 

protection.

4685302 3.73 3.73 Open2 3.82 RO RO2 Needed for future 

timber access.

4685307 Closed1 0.47 RO RC1 Needed for future 

timber access.

4685310 1.75 1.75 Closed1 4.75 RO RC1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

4685312 Open2 1.70 RO RO2 Needed for future 

timber access.

4685313 Closed1 1.20 RC RC1 Needed for future 

timber access.

4685315 0.22 0.22 Closed1 0.53 RC RC1 Road will be used 

then stored again 
Hwy 46 FEIS Appendix 

352

Road #

(Haul Routes 

in bold)

Haul 

Miles

Alt. 2

Haul 

Miles

Alt. 3

Existing

Road Status

Current Mtc.

Level

System Miles

Analyzed

RIS

Recommendation

Hwy 46 EIS

Alt 2 & 3 Proposal

Proposed Mtc. 

Level

Remarks

for resource 

protection. Needed 

for future timber 

access.

4685316 Open 2 0.23 RC RO 2

Road to remain 

open for resource 

administration. 

Needed for future 

timber access.

4685317 0.22 0.22 Closed 1 0.28 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

4685318 Closed 1 0.14 AD RC 1

Road to remain 

stored for resource 

administration. 

Needed for future 

timber access.

4685319 Closed 1 0.18 RC RC 1 Needed for future 

timber access.

4685320 Closed 1 1.77 RC RC 1 Needed for future 

timber access.

4685321 Open 2 1.28 AD AC 1

Road to be stored 

with berm/gate for 

resource 

protection. Needed 

for future timber 

access.

4685322 Closed 1 0.13 AD RC 1

Road to remain 

stored for resource 

administration. 

Needed for future 

timber access.

4685323 Closed 1 0.29 AD RC 1

Road to remain 

stored for resource 

administration. 

Needed for future 

timber access. 

4685324 Open 2 0.06 DR RO 2

Road to remain 

open for resource 

administration.

4685325 Open 2 0.58 DR RO 2

Road to remain 

open for resource 

administration.

4685326 Closed 1 0.17 RC RC 1 Needed for future 

timber access.

4685327 Open 2 0.12 RO RO 2 Needed for future 

timber access.

4685328 Closed 1 0.37 RC RC 1 Needed for future 

timber access.

4685329 Closed 1 0.67 RC RC 1 Needed for future 

timber access.

4685330 0.57 0.57 Open 2 1.13 RO RO 2

Road to remain 

open for resource 

administration. 
Hwy 46 FEIS Appendix 

353

Road #

(Haul Routes 

in bold)

Haul 

Miles

Alt. 2

Haul 

Miles

Alt. 3

Existing

Road Status

Current Mtc.

Level

System Miles

Analyzed

RIS

Recommendation

Hwy 46 EIS

Alt 2 & 3 Proposal

Proposed Mtc. 

Level

Remarks

Needed for future 

timber access.

4685331 Open 2 0.08 RC AC 1

Road to be stored 

with berm/gate for 

resource 

protection. Needed 

for future timber 

access.

4685332 Open 2 0.30 RC AC 1

Road to be stored 

with berm/gate for 

resource 

protection. Needed 

for future timber 

access.

4685452 0.20 0.20 Closed 1 0.22 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

4688000 6.50 6.50 Open 2 6.73 PR RO 2 Prime road.

4688099 Open 2 0.27 AC RO 2

Road to remain 

open for resource 

administration.

4688100 Closed 1 0.2 RC RC 1 Needed for future 

timber access.

4688107 0.63 0.63 Closed 1 0.78 RO RC 1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

4688111 0.17 0.17 Closed 1 0.20 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

4688112 Open 2 0.06 RO RO 2 Needed for future 

timber access.

4688120 0.58 0.58 Closed 1 0.74 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

4688124 0.09 0.09 Closed 1 0.09 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

4688125 Closed 1 0.04 AD AD —

Road will be 

decommissioned 

and taken off the 

system
Hwy 46 FEIS Appendix 

354

Road #

(Haul Routes 

in bold)

Haul 

Miles

Alt. 2

Haul 

Miles

Alt. 3

Existing

Road Status

Current Mtc.

Level

System Miles

Analyzed

RIS

Recommendation

Hwy 46 EIS

Alt 2 & 3 Proposal

Proposed Mtc. 

Level

Remarks

4688130 0.45 0.45 Closed 1 0.45 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

4688131 0.04 0.04 Open 2 0.04 RC RO 2

Road to remain 

open for resource 

administration. 

Needed for future 

timber access.

4688132 0.06 0.06 Open 2 0.06 RC RO 2

Road to remain 

open for resource 

administration. 

Needed for future 

timber access.

4688133 Open 2 0.11 RO RO 2 Needed for future 

timber access.

4688134 Open 2 0.07 RO RO 2 Needed for future 

timber access.

4688135 0.01 Closed 1 0.29 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

4688210 0.10 Closed 1 0.59 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

4688220 0.44 0.44 Open 2 1.59 AC RO 2

Road to remain 

open for resource 

administration. 

Needed for future 

timber access.

4688220 Open 2 0.87 AC AD - Decommission last 

0.87 miles.

4688221 Closed 1 0.33 RC RC 1 Needed for future 

timber access.

4688222 0.25 0.25 Closed 1 0.25 RC RC 1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

4688223 0.05 0.05 Open 2 0.05 DR AC 1

Road to be stored 

with berm/gate 

after use for 

resource 

protection. Needed 

for future timber 

access.

4688224 Open 2 0.15 RO RO 2 Needed for future 

timber access.
Hwy 46 FEIS Appendix 

355

Road #

(Haul Routes 

in bold)

Haul 

Miles

Alt. 2

Haul 

Miles

Alt. 3

Existing

Road Status

Current Mtc.

Level

System Miles

Analyzed

RIS

Recommendation

Hwy 46 EIS

Alt 2 & 3 Proposal

Proposed Mtc. 

Level

Remarks

4688229 Closed1 0.78 RC RC1 Needed for future 

timber access.

4688240 0.14 0.14 Open2 1.92 RO RO2 Needed for future 

timber access.

4688241 Open2 0.26 RO RO2 Needed for future 

timber access.

4688242 Closed1 0.45 AD AD—

Road will be 

decommissioned 

and taken off the 

system

4688243 Open2 0.26 RO RO2 Needed for future 

timber access.

4693000 2.20 2.20 Open2 5.59 PR RO2 Prime road.

4693502 0.84 0.84 Closed1 1.20 RC RC1

Road will be used 

then stored again 

for resource 

protection. Needed 

for future timber 

access.

4693503 0.08 0.08 Open2 0.17 RC AC1

Road to be stored with berm/gate 

after use for 

resource 

protection. Needed 

for future timber 

access.

4693507 Open2 0.15 DR RO2 Needed for future 

timber access.

4693508 0.41 0.41 Closed1 0.67 RC RC1

Road will be used 

then stored again 

for resource 

protection.

4693509 0.09 0.09 Open2 0.09 DR AC1

Road to be stored 

with berm/gate 

after use for 

resource 

protection. Needed 

for future timber 

access.

4693619 Closed1 0.21 RC RC1 Needed for future 

timber access.

4693620 0.18 0.18 Closed1 1.02 RC RC1

Road will be used

then stored again 

for resource 

protection.

4693639 0.24 0.24 Open2 0.24 RO RO2 Needed for future 

timber access.

4693640 0.28 0.28 Open2 2.85 PR RO2 Needed for future 

timber access.

4693641 0.43 0.43 Closed1 1.00 RC RC1

Road will be used 

then stored again 

for resource 

protection. Matrix -

Needed for future 

timber access.

4693643 Closed1 0.38 RC RC1 Needed for future 

timber access.
Hwy 46 FEIS Appendix 

356

Road #

(Haul Routes 

in bold)

Haul 

Miles

Alt. 2

Haul 

Miles

Alt. 3

Existing

Road Status

Current Mtc.

Level

System Miles

Analyzed

RIS

Recommendation

Hwy 46 EIS

Alt 2 & 3 Proposal

Proposed Mtc. 

Level

Remarks

4693645 Closed1 0.29 RC RC1 Needed for future 

timber access.

4693647 Closed1 0.78 RC RC1 Needed for future 

timber access.

4693690 Closed1 0.21 RC RC1 Needed for future 

timber access.

4693692 Open2 0.07 RC AC1

Road to be stored 

with berm/gate for 

resource 

protection. Needed 

for future timber 

access.

4696000 2.20 2.20 Open2 10.21 PR RO2 Prime road.

4696725 Open2 0.05 AD RO2 Access to dispersed 

camping sites.

4698000 3.49 1.35 Open2 6.62 RO RO2 Needed for future 

timber access.

4698807 0.25 0.25 Closed1 0.32 RC RC1

Road will be used 

then stored again 

for resource 

protection.

4698810 0.730.73 Closed1 0.83 RC RC1

Road will be used 

then stored again 

for resource 

protection.

4698811 0.20 Open2 0.20 RO AC1

Road to be stored 

with berm/gate 

after use for 

resource 

protection.

4698812 1.78 Open2 2.06 RO RO2 Needed for future 

timber access.

4698813 Closed1 0.14 RC RC1 Needed for future 

timber access.

4698814 0.24 Closed1 0.24 RC AD—

Road will be used 

then 

decommissioned 

and taken off the 

system

4698815 0.16 Closed1 0.19 RC RC1 Road will be used 

then stored again.

4698820 0.16 Closed1 0.38 RC RC1

Road will be used 

then stored again 

for resource 

protection.

4698821 Open2 0.33 RO RO2 Needed for future 

timber access.

4698835 0.45 Closed1 0.45 RC RC1

Road will be used 

then stored again 

for resource 

protection.

4698836 Open2 0.16 RC RO2 Needed for future 

timber access.

4698862 Closed1 0.25 RC RC1 Needed for future 

timber access.

Total Haul 

Route Miles 108.5
Hwy 46 FEIS Appendix 

357

Road #

(Haul Routes 

in bold)

Haul 

Miles

Alt. 2

Haul 

Miles

Alt. 3

Existing

Road Status

Current Mtc.

Level

System Miles

Analyzed

RIS

Recommendation

Hwy 46 EIS

Alt 2 & 3 Proposal

Proposed Mtc. 

Level

Remarks

(Alt. 2)

Total Haul 

Route Miles

(Alt. 3)

98.7

Total Miles 

Analyzed 216.04

Total 

proposed 

stored miles

4.07

Total 

decommission 

miles

8.88

Road Investment Strategy and IDT Recommendations

The following table displays the Willamette Road Investment recommendation and the IDT 

recommendations.

RIS Recommendations RIS Recommendations 

(Miles)

Hwy 46 Analysis 

(Stored Roads)

Hwy 46 Analysis

(Open Roads)

Analyze for Closure

(AC)

4.13 0.0 4.07

Remain Closed

(RC) 

51.10 53.44 (30.55 stored roads will 

be used then stored 

after use)

Remain Open

(RO)

57.56 0.0 149.65

Defer Recommendation 

(DR)

6.46 0.0 0.0

Prime Road

(PR)

91.58 0.0 0.0

Analyze for 

Decommissioning

(AD)

5.21 4.85 4.03

Total Miles Analyzed 216.04 58.29 157.75
Hwy 46 FEIS Appendix 

358

Anticipated Road Work Activities

The following table displays an estimate of anticipated road work activities for Hwy 46. Actual specific 

type of work, costs or location may change.

Road #

Haul

Mileage

Reconstruction

Maintenance

Estimated 

$/Mile

Estimated Total $

Estimated Total $ with 

wet weather haul

(if permitted) Road Work Activity and Remarks

Alt. 2 Alt. 3 Alt. 2 Alt. 3 Alt. 2 Alt. 3

2231000 13.35 13.35 ☒ ☒ $20,000 $267,000 $270,800 $471,200 $471,200

Expected asphalt repairs. Road and ditch 

rehabilitation, spot rock/surfacing. Culvert 

replacements. Additional 4” of surface rock needed 

for wet weather haul.

All haul volume off 2231 system to Hwy 22. 

2231730 3.12 3.12 ☒ ☒ $20,000 $62,400 $62,400 $163,627 $163,627

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Deep patch 

repairs. Culvert Replacements. Additional 4” of 

surface rock needed for wet weather haul.

2231732 0.24 0.24 ☒ ☒ $15,000 $3,600 $3,600 $11,387 $11,387

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

2231733 0.22 0.22 ☒ ☒ $15,000 $3,300 $3,300 $10,438 $10,438

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

2231736 0.05 0.05 ☒ ☒ $15,000 $750 $750 $2,372 $2,372

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

2231740 0.10 0.10 ☒ ☒ $15,000 $1,500 $1,500 $4,744 $4,744

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

2231746 0.17 - ☒ ☒ $20,000 $3,400 - $8,916 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

2231747 0.44 - ☒ ☒ $15,000 $6,600 - $20,876 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

2231749 0.09 0.09 ☒ ☒ $15,000 $1,350 $1,350 $4,270 $4,270

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

2231750 0.05 0.05 ☒ ☒ $15,000 $750 - $2,372 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

2231758 0.07 0.07 ☒ ☒ $15,000 $1,050 $1,050 $3,321 $3,321

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

2231759 0.61 0.61 ☒ ☒ $20,000 $12,200 $12,200 $31,991 $31,991

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

2231761 0.06 0.06 ☒ ☒ $15,000 $900 $900 $2,847 $2,847

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

2231763 0.41 0.41 ☒ ☒ $20,000 $8,200 $8,200 $21,502 $21,502

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

2231764 0.30 0.30 ☒ ☒ $15,000 $4,500 $4,500 $14,233 $14,233

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.
Hwy 46 FEIS Appendix 

359

Road #

Haul

Mileage

Reconstruction

Maintenance

Estimated 

$/Mile

Estimated Total $

Estimated Total $ with 

wet weather haul

(if permitted) Road Work Activity and Remarks

Alt. 2 Alt. 3 Alt. 2 Alt. 3 Alt. 2 Alt. 3

2231765 0.18 0.18 ☒ ☒ $15,000 $2,700 $2,700 $2,700 $2,700

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Rolling dips 

recommended. No wet weather haul.

2231839 0.28 - ☒ ☒ $20,000 $5,600 - $14,685 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 

Replacements. Additional 4” of surface rock needed 

for wet weather haul.

2231840 0.69 - ☒ ☒ $20,000 $13,800 - $36,187 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 

Replacements. Additional 4” of surface rock needed 

for wet weather haul.

2231847 0.53 0.53 ☒ ☒ $25,000 $13,250 $13,250 $30,446 $30,446

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Reconstructed 

turnaround north of road to facilitate haul to south. 

Minor additional clearing may be required. 

Additional 4” of surface rock needed for wet weather 

haul.

2231849 0.22 0.22 ☒ ☒ $12,000 $2,640 $2,640 $9,778 $9,778

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 

Replacements. Additional 4” of surface rock needed 

for wet weather haul.

2231850 1.61* 1.61* ☒ ☒ $30,000 $48,300 $48,300 $100,536 $100,536

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 

Replacements. New constructed approach to NFSR# 

2231-000 to facilitate haul to south. Less than 0.1 

miles anticipated. Additional 4” of surface rock 

needed for wet weather haul.

2231854 0.48 0.48 ☒ ☒ $15,000 $7,200 $7,200 $16,493 $16,493

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

2231855 1.06 1.06 ☒ ☒ $15,000 $15,900 $15,900 $50,291 $50,291

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

2231857 0.24 0.24 ☒ ☒ $15,000 $3,600 $3,600 $11,387 $11,387

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

2231870 4.99 * 4.99* ☒ ☒ $30,000 $149,700 $149,700 $311,599 $311,599

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 

Replacements. New constructed approach to NFSR# 

2231-000 to facilitate haul to south. Less than 0.1 

miles anticipated. Additional 4” of surface rock 

needed for wet weather haul. 

2231871 0.02 0.02 ☒ ☒ $15,000 $300 $300 $949 $949

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

2231873 0.14 0.14 ☒ ☒ $15,000 $2,100 $2,100 $6,642 $6,642

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

2231874 0.16 0.16 ☒ ☒ $12,000 $1,920 $1,920 $7,111 $7,111

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

2231875 0.70 0.70 ☒ ☒ $18,000 $12,600 $12,600 $35,311 $35,311

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 

Replacements. Additional 4” of surface rock needed 

for wet weather haul.

2231877 0.4 0.4 ☒ ☒ $20,000 $8,000 $8,000 $20,978 $20,978 Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 
Hwy 46 FEIS Appendix 

360

Road #

Haul

Mileage

Reconstruction

Maintenance

Estimated 

$/Mile

Estimated Total $

Estimated Total $ with 

wet weather haul

(if permitted) Road Work Activity and Remarks

Alt. 2 Alt. 3 Alt. 2 Alt. 3 Alt. 2 Alt. 3

Replacements. Additional 4” of surface rock needed 

for wet weather haul.

2231878 0.10 0.10 ☒ ☒ $15,000 $1,500 - $4,744 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

2231883 0.09 0.09 ☒ ☒ $15,000 $1,350 $1,350 $4,270 $4,270

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

2231887 0.04 0.04 ☒ ☒ $15,000 $600 $600 $1,898 $1,898

Clearing & Grubbing. Ditch Rehabilitation. 

Surfacing/Spot Rock. Additional 4” of surface rock 

needed for wet weather haul.

2231900 0.13 0.13 ☒ ☒ $15,000 $1,950 $1,950 $6,168 $6,168

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4600000 16.55 16.55 ☒ ☒ $35,000 $579,250 $579,250 $579,250 $579,250

Asphalt pothole and surface repairs anticipated. 

Ditch Rehabilitation. Portions of the pavement 

structure may need rehabilitation to be acceptable 

for wet weather haul.

4600011 0.16 0.16 ☒ ☒ $20,000 $3,200 - $3,200 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. No wet weather 

haul.

4600012 1.28* 1.28* ☒ ☒ $30,000 $38,400 $38,400 $38,400 $38,400

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Anticipated 0.1 

mile realignment to eliminate steep grade. No wet 

weather haul.

4600014 0.57 0.57 ☒ ☒ $20,000 $11,400 $11,400 $11,400 $11,400

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. No wet weather 

haul.

4600021 0.29 0.29 ☒ ☒ $20,000 $5,800 $5,800 $5,800 $5,800

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. No wet weather 

haul.

4600022 0.55 0.55 ☒ ☒ $20,000 $11,000 $11,000 $11,000 $11,000

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. No wet weather 

haul.

4600023 0.21 0.21 ☒ ☒ $20,000 $4,200 $4,200 $4,200 $4,200

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. No wet weather 

haul.

4600024 0.50 0.50 ☒ ☒ $20,000 $10,000 $10,000 $10,000 $10,000

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. No wet weather 

haul.

4600025 0.13 0.13 ☒ ☒ $20,000 $3,600 $3,600 $3,600 $3,600

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. No wet weather 

haul.

4600026 0.12 0.12 ☒ ☒ $20,000 $2,400 $2,400 $6,293 $6,293

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4600027 0.17 - ☒ ☒ $15,000 $2,550 - $8,066 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4600028 0.23 - ☒ ☒ $15,000 $3,450 - $10,912 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4600030 2.27 2.27 ☒ ☒ $22,000 $49,940 $49,940 $123,589 $123,589

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 

replacements. Additional 4” of surface rock needed 

for wet weather haul.

4600033 1.88 1.88 ☒ ☒ $20,000 $37,600 $37,600 $98,596 $98,596 Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 
Hwy 46 FEIS Appendix 

361

Road #

Haul

Mileage

Reconstruction

Maintenance

Estimated 

$/Mile

Estimated Total $

Estimated Total $ with 

wet weather haul

(if permitted) Road Work Activity and Remarks

Alt. 2 Alt. 3 Alt. 2 Alt. 3 Alt. 2 Alt. 3

replacements. Additional 4” of surface rock needed 

for wet weather haul. Alt 3 haul miles = 0.73.

4600035 0.30 0.30 ☒ ☒ $15,000 $4,500 $4,500 $14,233 $14,233

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4600036 0.30 0.30 ☒ ☒ $20,000 $6,000 $6,000 $15,733 $15,733

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 

replacements. Additional 4” of surface rock needed 

for wet weather haul.

4600037 0.06 0.06 ☒ ☒ $20,000 $1,200 $1,200 $3,147 $3,147

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4600038 0.04 0.04 ☒ ☒ $20,000 $800 $800 $2,098 $2,098

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4600040 4.23 3.10 ☒ ☒ $40,000 $169,200 $169,200 $306,441 $306,441

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 

replacements. Additional 4” of surface rock needed 

for wet weather haul. Short Lake reroute. 

Decommission approx. 1.02 mile around Short Lake 

after sale.

4600044 0.21 0.21 ☒ ☒ $18,000 $3,780 $3,780 $10,593 $10,593

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 

Replacements. Additional 4” of surface rock needed 

for wet weather haul.

4600045 3.15 3.15 ☒ ☒ $30,000 $94,500 $94,500 $196,701 $196,701

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 

Replacements. Proposed Short lake reroute. Tie in 

new road to NFSR# 4600-059. Approx. 1 mile of new 

road. Curve widening needed and reshaping needed 

due to steep grades. Additional 4” of surface rock 

needed for wet weather haul.

4600046 0.30 - ☒ ☒ $12,000 $3,600 - $13,333 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4600047 0.20 0.20 ☒ ☒ $15,000 $3,000 $3,000 $9,489 $9,489

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4600049 0.16 0.16 ☒ ☒ $15,000 $2,400 $2,400 $7,591 $7,591

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Short Lake

reroute. Additional 4” of surface rock needed for wet 

weather haul.

4600050 0.51 0.51 ☒ ☒ $15,000 $7,650 - $24,197 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4600053 0.23 - ☒ ☒ $12,000 $2,760 - $10,222 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4600054 0.26 - ☒ ☒ $15,000 $3,900 - $12,336 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4600055 0.53 0.53 ☒ ☒ $20,000 $10,600 $10,600 $27,796 $27,796

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 

Replacements. Additional 4” of surface rock needed 

for wet weather haul.

4600056 0.24 - ☒ ☒ $20,000 $4,800 - $12,587 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.
Hwy 46 FEIS Appendix 

362

Road #

Haul

Mileage

Reconstruction

Maintenance

Estimated 

$/Mile

Estimated Total $

Estimated Total $ with 

wet weather haul

(if permitted) Road Work Activity and Remarks

Alt. 2 Alt. 3 Alt. 2 Alt. 3 Alt. 2 Alt. 3

4600058 0.09 - ☒ ☒ $15,000 $1,350 $1,350 $4,270 $4,270

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4600061 0.12 - ☒ ☒ $15,000 $1,800 - $5,693 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4600066 0.02 - ☒ ☒ $12,000 $240 - $889 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4600071 0.45 0.45 ☒ ☒ $18,000 $8,100 $8,100 $22,700 $22,700

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4600078 0.10 0.10 ☒ ☒ $15,000 $1,500 - $4,744 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4600088 0.28 0.28 ☒ ☒ $18,000 $5,040 $5,040 $14,125 $14,125

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4600094 0.21 0.21 ☒ ☒ $20,000 $4,200 - $11,013 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4600095 0.32 0.32 ☒ ☒ $18,000 $5,760 $5,760 $16,142 $16,142

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4600097 0.63 0.63 ☒ ☒ $18,000 $11,340 $11,340 $11,340 $11,340

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. No wet weather 

haul.

4600117 0.07 - ☒ ☒ $12,000 $840 - $3,111 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4600289 0.06 0.06 ☒ ☒ $12,000 $720 $720 $2,667 $2,667

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4600297 0.23 - ☒ ☒ $12,000 $2,760 - $10,222 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4685000 8.39 8.39 ☒ ☒ $25,000 $209,750 $209,750 $209,750 $209,750

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 

Replacements. No wet weather haul.

4685302 3.73 3.73 ☒ ☒ $25,000 $93,250 $93,250 $93,250 $93,250

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 

Replacements. No wet weather haul.

4685310 1.75 1.75 ☒ ☒ $25,000 $43,750 $43,750 $43,750 $43,750

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 

Replacements. No wet weather haul.

4685315 0.22 0.22 ☒ ☒ $15,000 $3,300 $3,300 $3,300 $3,300

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. No wet weather 

haul.

4685317 0.22 0.22 ☒ ☒ $15,000 $3,300 $3,300 $3,300 $3,300

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. No wet weather 

haul.

4685330 0.57 0.57 ☒ ☒ $20,000 $11,400 $11,400 $11,400 $11,400

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 

Replacements. No wet weather haul.

4685452 0.20 0.20 ☒ ☒ $20,000 $4,000 $4,000 $4,000 $4,000

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 

Replacements. No wet weather haul.
Hwy 46 FEIS Appendix 

363

Road #

Haul

Mileage

Reconstruction

Maintenance

Estimated 

$/Mile

Estimated Total $

Estimated Total $ with 

wet weather haul

(if permitted) Road Work Activity and Remarks

Alt. 2 Alt. 3 Alt. 2 Alt. 3 Alt. 2 Alt. 3

4688000 6.50* 6.50* ☒ ☒ $35,000 $227,500 $227,500 $438,390 $438,390

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 

Replacements. Open end of road and extend an 

additional 0.22 miles. Additional 4” of surface rock 

needed for wet weather haul.

4688107 0.63 0.63 ☒ ☒ $15,000 $9,450 $9,450 $29,890 $29,890

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4688111 0.17 0.17 ☒ ☒ $12,000 $2,040 $2,040 $7,556 $7,556

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4688120 0.58 0.58 ☒ ☒ $15,000 $8,700 $8,700 $27,518 $27,518

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4688124 0.09 0.09 ☒ ☒ $12,000 $1,080 $1,080 $4,000 $4,000

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4688130 0.45 0.45 ☒ ☒ $15,000 $6,750 $6,750 $21,350 $21,350

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4688131 0.04 0.04 ☒ ☒ $15,000 $600 $600 $1,898 $1,898

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4688132 0.06 0.06 ☒ ☒ $15,000 $900 $900 $2,847 $2,847

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4688135 0.01 - ☒ ☒ $15,000 $150 - $474 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4688210 0.10 - ☒ ☒ $12,000 $1,200 - $4,444 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4688220 0.44 0.44 ☒ ☒ $12,000 $5,280 $5,280 $19,556 $19,556

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4688222 0.25 0.25 ☒ ☒ $12,000 $3,000 $3,000 $11,111 $11,111

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4688223 0.05 0.05 ☒ ☒ $12,000 $600 $600 $2,222 $2,222

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4688240 0.14 0.14 ☒ ☒ $12,000 $1,680 $1,680 $6,222 $6,222

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4693000 2.20 2.20 ☒ ☒ $20,000 $44,000 $44,000 $115,378 $115,378

Asphalt approach repair. Clearing & Grubbing. Road 

Rehabilitation. Ditch Rehabilitation. Surfacing/Spot 

Rock. Culvert Replacements. Additional 4” of surface 

rock needed for wet weather haul.

4693502 0.84 0.84 ☒ ☒ $18,000 $15,120 $15,120 $42,374 $42,374

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4693503 0.08 0.08 ☒ ☒ $25,000 $2,000 $2,000 $4,596 $4,596

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 

Replacements. Additional 4” of surface rock needed 

for wet weather haul.

4693508 0.41 0.41 ☒ ☒ $15,000 $6,150 $6,150 $19,452 $19,452

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.
Hwy 46 FEIS Appendix 

364

Road #

Haul

Mileage

Reconstruction

Maintenance

Estimated 

$/Mile

Estimated Total $

Estimated Total $ with 

wet weather haul

(if permitted) Road Work Activity and Remarks

Alt. 2 Alt. 3 Alt. 2 Alt. 3 Alt. 2 Alt. 3

4693509 0.09 0.09 ☒ ☒ $15,000 $1,350 $1,350 $4,270 $4,270

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4693620 0.18 0.18 ☒ ☒ $15,000 $2,700 $2,700 $8,540 $8,540

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4693639 0.24 0.24 ☒ ☒ $25,000 $6,000 $6,000 $13,787 $13,787

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 

Replacements. Additional 4” of surface rock needed 

for wet weather haul.

4693640 0.28 0.28 ☒ ☒ $22,000 $6,160 $6,160 $15,245 $15,245

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 

Replacements. Additional 4” of surface rock needed 

for wet weather haul.

4693641 0.43 0.43 ☒ ☒ $15,000 $6,450 $6,450 $20,401 $20,401

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 

Replacements. Additional 4” of surface rock needed 

for wet weather haul.

4696000 2.20 2.20 ☒ ☒ $20,000 $44,000 $44,000 $115,378 $115,378

Asphalt pothole and surface repairs anticipated. 

Ditch Rehabilitation. Pavement structure acceptable 

for wet weather haul.

4698000 3.49 1.35 ☒ ☒ $25,000 $87,250 $33,750 $200,482 $74,802

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 

Replacements. Grade sag repair at MP 0.45. 

Additional 4” of surface rock needed for wet weather 

haul.

4698807 0.25 0.25 ☒ ☒ $15,000 $3,750 $3,750 $11,861 $11,861

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4698810 0.73 0.73 ☒ ☒ $15,000 $10,950 $10,950 $34,635 $34,635

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Reshaping 

needed due to steep grade. Additional 4” of surface 

rock needed for wet weather haul.

4698811 0.20 - ☒ ☒ $15,000 $3,000 - $9,489 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4698812 1.78 - ☒ ☒ $20,000 $35,600 - $93,352 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Culvert 

Replacements. Grade sag repairs. Additional 4” of 

surface rock needed for wet weather haul.

4698814 0.24 - ☒ ☒ $15,000 $3,600 - $11,387 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4698815 0.16 - ☒ ☒ $15,000 $2,400 - $7,591 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4698820 0.16 - ☒ ☒ $15,000 $2,400 - $7,591 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

4698835 0.45 - ☒ ☒ $15,000 $6,750 - $21,350 -

Clearing & Grubbing. Road Rehabilitation. Ditch 

Rehabilitation. Surfacing/Spot Rock. Additional 4” of 

surface rock needed for wet weather haul.

Alt 2 

Haul 

Miles

108.5

Alt 3 Haul Miles 98.7
Hwy 46 FEIS Appendix 

365

Road #

Haul

Mileage

Reconstruction

Maintenance

Estimated 

$/Mile

Estimated Total $

Estimated Total $ with 

wet weather haul

(if permitted) Road Work Activity and Remarks

Alt. 2 Alt. 3 Alt. 2 Alt. 3 Alt. 2 Alt. 3

Alt 2 Total $ $2,722,950

Alt 3 Total $ $2,543,250 

Alt 2 Total $ with wet weather haul $4,837,375

Alt 3 Total $ with wet weather haul $4,337,712

* -includes realignment mileage
Hwy 46 FEIS Appendix 

366

Appendix I – Unit Restriction Table

The following table displays the operating restriction in each unit.

Dark blue indicates that activities are prohibited. Light blue indicates activity restrictions.

Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Comments

1

2

3

5 All activities prohibited Mar 1 – Jul 

15 in part of unit (WL)

6

7

11

12

Helicopter yarding prohibited Mar 1 

– July 15 (WL)

No spring burning.

13

Restrict all activities March 1 – Jul 15 

(WL) 

14

16

All activities prohibited Mar 1 – Jul 

15 on one acre(WL)

17 No spring burning.

18 No spring burning.

19

20

21
Hwy 46 FEIS Appendix 

367

Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Comments

22

23

24

No operations Memorial Day to 

Labor Day (noise)

All activities prohibited Mar 1 – Jul 

15 (WL)

Helicopter yarding prohibited Mar 1 

– July 15 (WL)

No spring burning.

25 All activities prohibited Mar 1 – Jul 

15 (WL)

26 All activities prohibited Mar 1 – Jul 

15 (WL)

27

No operations Memorial Day to 

Labor Day (noise)

All activities prohibited on western 2 

acres Mar 1 – Jul 15 (WL)

28 No operations Memorial Day to 

Labor Day (noise)

29

30 No operations Memorial Day to 

Labor Day (noise)

31

32

No operations Memorial Day to 

Labor Day (noise)

Helicopter yarding restriction Jan 15 

– Jul 31 (WL)

All activities restricted Mar 1 – July 

15 (WL)

Helicopter yarding prohibited Mar 1 

– July 15 (WL)
Hwy 46 FEIS Appendix 

368

Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Comments

No spring burning.

32a

No operations Memorial Day to 

Labor Day (noise)

Helicopter yarding restriction Jan 15 

– Jul 31 (WL)

All activities restricted Mar 1 – July 

15 (WL)

Helicopter yarding prohibited Mar 1 

– July 15 (WL)

No spring burning.

33 No spring burning.

34

35

All activities prohibited Mar 1 – Jul 

15 (WL)

No spring burning.

38

39

40

41

42 No operations Memorial Day to 

Labor Day (noise)

44

45

46

47 No spring burning.

48
Hwy 46 FEIS Appendix 

369

Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Comments

49

50

51

52

53

54

55

All activities restricted Jan 15 – July 

31 (WL)

56

57

All activities restricted Jan 15 – July 

31 (WL)

58

All activities restricted Jan 15 – July 

31 (WL)

59

60

All activities restricted Jan 15 – July 

31 (WL)

61

All activities restricted Jan 15 – July 

31 (WL)

62

All activities restricted Jan 15 – July 

31 (WL)

63

All activities restricted Jan 15 – July 

31 (WL)

64

All activities restricted Jan 15 – July 

31 (WL)

All activities prohibited Mar 1 – Jul 

15 (WL)

69
Hwy 46 FEIS Appendix 

370

Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Comments

70

71

72

73

All activities prohibited Mar 1 – Jul 

15 (WL)

No spring burning.

74 Rock source blasting prohibited Mar 

1 – Jul 15 (WL)

75 All activities prohibited Mar 1 – Jul 

15 (WL)

76

77

78

80

81

82

83

84 No spring burning.

87

89

All activities restricted Jan 15 – July 

31 (WL)

92

All activities restricted Jan 15 – July 

31 (WL)

93 Helicopter yarding prohibited Mar 1 

– July 15 (WL)
Hwy 46 FEIS Appendix 

371

Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Comments

No spring burning.

94

95

Helicopter yarding prohibited Mar 1 

– July 15 (WL)

No spring burning.

96

Helicopter yarding prohibited Mar 1 

– July 15 (WL)

No spring burning.

97

100

110

120

130

140 All activities prohibited Mar 1 – Jul

15 (WL)

140a

150

160

170

Restrict all activities with 200’ of 

Breitenbush River March 15 – Jul 15 

(WL)

180 All activities prohibited Mar 1 – Jul 

15 (WL)

190

200 No operations Memorial Day to 

Labor Day (noise)
Hwy 46 FEIS Appendix 

372

Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Comments

210

Restrict all activities with 200’ of 

Breitenbush River March 15 – Jul 15 

(WL)

220 Rock source blasting prohibited Mar 

1 – Jul 15

240 No operations Memorial Day to 

Labor Day (noise)

250

260

270

Restrict all activities with 200’ of 

Breitenbush River March 15 – Jul15 

(WL)

All activities prohibited Mar 1 – Sept 

30 (WL)

No spring burning.

280

290

300 Helicopter yarding prohibited Mar 1 

– July 15 (WL)

310 Helicopter yarding prohibited Mar 1 

– July 15 (WL)

320

340

350

360

370

380
Hwy 46 FEIS Appendix 

373

Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Comments

390

400

410

420

All activities restricted Jan 15 – July 

31 (WL)

430

All activities restricted Jan 15 – July 

31 (WL)

No spring burning.

440

450 No spring burning.

460

470

480

490

510

520

530

540

560

570
Hwy 46 FEIS Appendix 

374

Appendix J – Response to Comments on the Draft 

Environmental Impact Statement (DEIS)

Introduction

The Detroit Ranger District provided the public with a 45-day comment period for the Hwy 46 Project 

Draft Environmental Impact Statement (DEIS). The comment period began on October 20, 2017 and 

ended on December 4, 2017. Twenty-three letters were received from members of the public, federal 

officials, and public interest organizations.

Content Analysis

A standardized content analysis process was conducted to analyze the public letters received on the DEIS. 

Content analysis is designed to extract comments from each letter received, evaluate similar comments 

from different letters, and identify topics of concern. Additionally, content analysis ensures that every 

comment is considered fairly and accurately represents the breadth and depth of the public’s viewpoints. 

All letters and comments have been treated equally. They are not weighted by status of respondents or 

organizational affiliation and it does not matter if an idea was expressed by hundreds of people or a single 

person.

During the content analysis process, each letter was assigned a unique tracking number. Content analysts 

then read letters in their entirety and proceeded to identify discrete comments within them. Each letter 

may have contained anywhere from one to fifty comments. Each comment was coded based on a 

particular concern, resource consideration, or proposed management action expressed.

How to Use This Comment Response Document

While all comments were reviewed and considered, only specific written comments as identified in 36 

CFR 218.2 received a detailed response in the document below. Examples of specific written comments 

include those comments that provided new information; identified a new issue; identified a new way to 

meet the purpose and need; pointed out a flaw in the analysis; or identified a different source of credible 

research. General statements of support, opposition, or alternative preferences; comments outside the 

scope of the project; comments pertaining to issues already decided by law, regulation or policy; or 

comments already addressed in the draft Environmental Impact Statement (DEIS) are not included.

In some cases, comment may have been summarized or paraphrased and similar comments may have 

been grouped into public concern statements. Pages, chapter, or sections cited within the response to 

comments refer to the Hwy 46 Project Final Environmental Impact Statement (FEIS) unless otherwise 

noted.

A complete record of all letters, including names and addresses of individuals, agencies, and 

organizations that submitted a letter during the 45 day comment period, is available online in the Hwy 46 

EIS Public Reading Room at https://cara.ecosystemmanagement.org/Public//ReadingRoom?Project=47109 or in the project file located at the Detroit Ranger 

District. 
Hwy 46 FEIS Appendix 

375

Commenter Comment Resource Topic Response

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Why did the FS move forward with the DEIS given 

that these fires have such an enormous impact on 

the entire purpose and need for this project? It is 

wildly inappropriate that the only opportunity the 

public will have to weigh in on the FS's analysis of 

this important fire will be in the administrative 

appeal stage. The FS could have simply waited a 

month to publish this DEIS. The fires are out now, 

please re submit for public comment the DEIS with 

the fire-analysis.

DEIS/ Public 

Involvement

We moved forward with the DEIS because initial 

review of the effects from the fires indicated that 

the fires did not meet the purpose and need of the 

Hwy 46 project. The fires burned a total of 2,921 

acres in the project area, but directly affecting 

only eight treatment units. The effects from the 

fires are fully analyzed in Chapter 3 of the FEIS.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

What the DEIS does not mention is that there has 

been a large fire in or adjacent to the project area. 

There has been associated management activities, 

commercial logging, fuels reduction, fire break 

creation that is not referenced in this DEIS. The FS 

needs to take a hard look at what the impacts of 

this recent fire, and whether or not this project is 

still needed.

For example, how much of the project area burned 

this past summer? How much early seral habitat

was created? Did any of these areas contain sugar 

pine? How much of the hazardous fuel reduction 

around Breitenbush was already conducted during 

the fire-logging activities?

Please inform us if any of the burned areas 

contained sugar pine because the need for any 

sugar restoration at all could have been taken care 

of by the burning this past summer.

The FEIS analyzes the effects from the 2017 fires 

in Chapter 3. 

RAVG satellite data was used combined with 

field reconnaissance to determine the burn 

severity in the project area. Areas identified as 

moderate or high severity were judged to have 

created early seral habitat. Based on this, 521 

acres of new early seral habitat was created in 

2017.

Several units with sugar pine shelterwood 

prescriptions did burn to various degrees. The fire 

was generally very low intensity in these units, 

mostly burning ground fuels with occasional 

torching of individual trees. These areas were 

visited by the District Silviculturist and were 

judged to still be in need of treatment. The vast 

majority of trees over 7” dbh will likely survive 

so the shelterwood cuts will still be necessary to 

establish sugar pine. The FEIS addresses the fires 

impact on these units. Within the hazardous fuels 

treatment units (units 170, 210, 270) 

approximately 10% of the work proposed in unit 

170 was accomplished during fire suppression 

activities utilizing a prescription similar to the one 

proposed in the DEIS. This work involved cutting 
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Commenter Comment Resource Topic Response

and chipping material under 7” DBH or less, and 

no logging equipment was used inside these units. 

No work was conducted in units 210 or 270.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The FS does state that one purpose and need for the 

project is commercial logging to "supply a reliable 

supply of timber products." This is only applicable 

to the matrix lands within the project area, and the 

public is still not made aware of how much timber 

was commercially logged during the fire season. 

How many board feet, what age of trees, where 

was the logging located? Is there still a need to 

supply timber products after the logging associated 

with the fire for which no NEPA analysis was 

conducted. These are cumulative impacts that need 

to be considered, especially given the proximity 

and relative location to the project area.

Purpose and Need The Willamette National Forest Land and 

Resource Management Plan has a goal to produce 

an optimum and sustainable yield of timber, based 

on growth potential of the land which is 

compatible with multiple use objectives and 

meets environmental requirements for soil, water, 

air and wildlife habitat quality (USDA, 1990). 

This plan was amended by the Northwest Forest 

Plan in 1994 and recognized “the need for forest 

products from forest ecosystems is the need for a 

sustainable supply of timber and other forest 

products that will help maintain the stability of 

local and regional economies on a predictable and 

long-term basis” (pages 1 – 4). 

During the fire, some roads had a narrow strip 

(usually not more than 10 feet wide) of trees 

removed on one side to enhance the fire break 

created by the road. The stands from which these 

trees were taken were plantations, likely ranging 

in age from 30 to 50 years old. Log decks were 

created along the roads and sold as saw logs. The 

volume sold within the project area totaled 0.445 

million boardfeet. The location of these saw log 

decks were on the #810, #840, #850, and #870 

roads. Other smaller material decked in this area 

and others will either be sold as commercial 

firewood or made available to the public for 

personal use firewood. Although some of this 

fireline treatment did occur in Hwy 46 units in 

this area, the effect on vegetation within those 

units was minimal. Only trees immediately 

adjacent to the road were cut.
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Commenter Comment Resource Topic Response

Most of the higher intensity burns within the 

project area occurred away from open system 

roads. No salvage of fire killed trees has occurred 

within the project area.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

In numerous sections through the DEIS the FS 

limits operation activities to certain dates because 

of impacts to various species, impacts to 

recreation, impacts to the Breitenbush community.

These restrictions are never centralized in one 

place in the DEIS. Would the FS please put in one 

place what activities are permitted when, which 

would make monitoring of any logging operations 

feasible.

General Appendix I in the FEIS displays restrictions in 

each unit. 

The design elements for the project with specifics, 

including dates of operations or restrictions are

displayed in Table 13, FEIS page 45-60

Andy Geissler, 

AFRC

These "out of scope" issues do not result in 

development of alternatives. AFRC would like the 

Forest Service to disclose the scientific evidence 

that supported the notion that the deferral of fireregenerated stands warrants being a Key Issue

rather than an Out of Scope Issue, and thus, the 

development of alternative 3.

Issues As stated on page 30 in the DEIS a “key issue” 

represents an unresolved conflict associated with 

the proposed action. For this project harvest 

treatments in fire regenerated stands was 

determined to be a key issue because the 

“unresolved conflict” could not be resolved with 

mitigation or design elements and alternative 3 

was developed.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

We appreciate that the FS developed an alternative 

that omitted from treatment naturally fireregenerated stands from logging in Alternative 3. 

The DEIS notes that these stands are different than 

the plantations slotted for logging because they are 

older, have larger trees, have developing 

understories with a greater diversity of tree species. 

This gets to our request in the scoping comments to 

provide detailed information on the condition of 

each stand proposed for treatment. Essentially we 

wanted the FS to elaborate on the significant 

difference between the plantations in the project 

area and the fire-regenerated stands. However, the 

Alternatives As stated in the Draft Silviculture Prescriptions on 

pages 12-13 (posted on the project website):

Plantations are generally characterized by dense 

monocultures of Douglas-fir. 

Naturally regenerated stands are older than the 

plantations in this project, and tend to have larger 

trees. A few of these natural stands have relic 

older trees scattered within them that are remnants 

from before the fire that regenerated the stand. 

These stands are similar to the plantations in that 

there is high competition between the overstory 

trees and suppression in the regeneration.
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Commenter Comment Resource Topic Response

DEIS still largely lumps both of these areas 

together for analysis, simply noting that the stands 

are "similar" while proposing them for largely 

identical logging prescriptions. The public needs to 

be made aware of the significant difference of 

these forest types.

The tables included in the Draft Silviculture 

Prescriptions include individual unit information 

including Unit Current Conditions in table 11.

Andy Geissler, 

AFRC

We would recommend that the design feature focus 

on tree characteristics rather than DBH. In general, 

using DBH to describe silvicultural prescriptions 

runs the risk of prohibiting the harvest of the 

optimal tree to meet your desired end results in any 

given part of the treatment area.

Harvest 

prescription

The assumption that a legacy tree is a remnant 

from a previous stand is correct. The 30” dbh 

description for legacy trees was used to reduce 

ambiguity in interpretation of what a legacy tree 

is for this project. This diameter break was based 

on field observations and stand exam data 

collected for this project, it was never intended to 

be a default for all projects. During unit 

reconnaissance by the District Silviculturist, it 

was noted that all trees observed that were judged 

to be legacy trees were greater than 30” dbh. 

There were also no trees observed that would be 

designated for harvest in a DxD prescription that 

were over 30”. However, your comments are 

appreciated and a description of what a legacy 

tree is will be added to the prescription incase a 

situation arises that contradicts the 30” diameter 

limit.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Cascadia Wildlands and Oregon Wild urges the 

Forest Service to omit the proposed regeneration 

harvest designed to create artificial early seral 

forest. Mature forest conservation remains a much 

more important conservation priority than the 

creation of early seral forest. There is not really a 

shortage of early seral forest which is abundant on 

non-federal land. The sheer quantity of early seral 

on private lands partially compensates for the lack 

of habitat quality. Also, wildlife associated with 

early seral forest are not at risk. Those species 

Early Seral 

Habitat

As stated in the DEIS, historic amounts of early 

seral for the Breitenbush watershed were 

estimated to be 9% of the area. In 2013, analysis 

by Helmig and Kurtis indicated that the watershed 

had 4% of its acreage in an early seral stage. 

Using RAVG satellite data, it is estimated that the 

2017 wildfires contributed an additional 1.6% of 

the area in moderate to high intensity fire which 

will develop into early seral. The only non-federal 

land within the watershed is a hot springs resort, 

and does not contribute to early seral habitat. The 
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Commenter Comment Resource Topic Response

generally tend to be mobile, generalists and 

opportunistic.

intent for this project is overall watershed health. 

Both early and late seral are an important part of a 

healthy, functioning watershed. As stated in the 

DEIS, increasing both early and later seral stages 

is an important focus of the project.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

At a regional scale there is no shortage of early 

seral forest. In fact, there's already too much early 

seral in Oregon. Janet Ohmann. Trends in Early 

Seral Forest at the Stand and Landscape Scale. 

http://www.slideshare.net/ecoshare/janet-lohmann-trends-in-early-seral- forest-at-the-standand-landscape-scale. (Slides 12, 29 show there is 

"no shortage of early seral" in Coastal Oregon, and 

early seral "exceeds the HRV" [historic range of 

variability].)

Please address these conflicting scientific opinions 

and studies on the overall abundance of early seral 

habitat in the DEIS.

Early Seral 

Habitat

The scale of a landscape is relative to the metric 

being studied. For the purposes of early seral 

habitat for this project, the landscape scale is the 

5th field watershed. The overall health of the 

Breitenbush Drainage is the focus of this project. 

Analyzing at the State wide scale is beyond the 

scope of this project.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Efforts to artificially enhance or create early seral 

habitat and introduce sugar pine should recognize 

that climate change might take care of this for us, 

and in fact might make it much harder to hang on 

to the mature forests we have. "Ecologically, 

increased distribution and frequency of 

disturbances may result in increased distribution 

and dominance of early successional ecosystems 

dominated by fire adapted species..." Lemieux, 

Christopher J., Daniel J. Scott, Rob G. Davis and 

Paul A. Gray. 2008. Changing Climate, 

Challenging Choices: Ontario Parks and Climate 

Change Adaptation. University of Waterloo,

Department of Geography: Waterloo, 

Ontario...Conversely, it may become harder to 

maintain existing late-seral ecosystems and 

species, so existing late-successional old-growth 

Early Seral 

Habitat /Sugar 

Pine

The article cited was based on climate change in 

Ontario, Canada, which is in a completely 

different part of the continent and has a different 

weather pattern and completely different 

vegetation than the project area and therefore is 

not relevant to this EIS. A search of the cited 

literature did not reveal the quotation given, nor 

was any discussion of early seral habitat or sugar 

pine found. Having a healthy stand of sugar pine 

in the watershed to continue healthy, mature 

conifer coverage in climate change may be very 

critical to watershed stability in this area.
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Commenter Comment Resource Topic Response

forests should be retained in order to avoid making 

the LSOG shortage worse.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Please provide an estimate (and the scientific 

support/data for this estimation) of the amount of 

early-seral forest that existed in the Hwy 46 project 

area.

Early Seral 

Habitat

This information was provided in the Vegetation 

section (Chapter 3.1) of the FEIS. The estimate 

was 9% of the Breitenbush watershed was early 

seral habitat historically and the document cited is 

Helmig and Kurtis, 2013, which is an unpublished 

paper available in the project record.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Also given that it is recognized that private timber 

lands and small-scale agricultural lands can 

provide early-seral habitat for species like deer and 

elk, please quantify the amount of early-seral 

habitat being provided in the project area and 

watershed by these types of operations.

Early Seral 

Habitat

This information is provided in the FEIS (Chapter 

3). There is no private timber land within the 

project area to provide early seral habitat.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Also in the FEIS, please analyze the amount of 

early seral anticipated to be created in the Pacific 

Northwest and the project area from fire. This is 

especially significant here given the ongoing fire at 

the time this DEIS was published.

Early Seral 

Habitat

The amount of early seral created by the 2017 

wildfires is discussed in the FEIS. Analyzing 

projected early seral outside of the project area is 

beyond the scope of this project.

Nick Cady for 

Cascadia 

Wildlands, 

If the Forest Service does decide to proceed in 

these areas, it should develop an alternative with 

very low diameter limits on the tree felling and 

Sugar Pine 

Restoration

Using a diameter limit to select trees for harvest is 

a viable alternative for a “thin from below” 

prescription in some situations, however at least 
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381

Commenter Comment Resource Topic Response

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

limiting the logging to hand felling and leaving the 

felled trees in place to contribute to biological 

material for these areas. Again, focusing sugar pine

restoration in plantations where there will be 

greater canopy openings and access to sunlight 

would be a better area for these efforts.

two things are necessary to make this type of 

prescription effective: 1. The stand needs to be 

fairly uniform in size distribution across the area 

to be treated, and 2. very thorough data needs to 

be collected to ensure that the diameter break 

selected will yield the desired results. Most of the 

stands selected are either variable across the stand 

or have a structure in which cutting only the 

smaller trees will not provide enough reduction in 

tree competition to allow sugar pine to establish 

successfully. In addition, the amount of data 

collection required to comfortably determine what 

the diameter limit would be is not available for 

most of the units.

Considering the steep terrain in which the sugar 

pine units are located, hand felling will likely be 

the only option.

Commercial logging provides the mechanism that 

allows for the treatment of these stands. Funds are 

not currently available to pay for a service 

contract to fall the trees without the money 

generated by commercial harvest. If all the trees 

were felled and left on site, it would create a 

significant fuel buildup and hinder the planting of 

sugar pine and other species. If a fire were to 

become established within the next several years, 

the resulting high intensity burn would kill most 

of the trees in the stand, including the sugar pine. 

This past summer fire did enter unit 83, which has 

more sugar pine in it than any other unit in the 

project. The lack of fuel on the forest floor 

resulted in a cool burn in much of the unit, 

allowing most of the trees to survive. Treatment 

will still be needed in this unit to establish a new 

cohort of sugar pine.
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Commenter Comment Resource Topic Response

The selection of units for sugar pine restoration 

was primarily based on evidence of sugar pine 

existence (either past or present) in the stand, or 

based on close proximity to stands with sugar 

pine with similar elevation and aspect. Unit 33 is 

a plantation that met the proximity, elevation, and 

aspect elements and is having sugar pine planted 

in it.

Karen Sjogren According to the table, the objective of restoring 

Sugar Pine's is met not only by the shelterwood 

cut, but also by an undisclosed acreage of thinning, 

gap creation, and dominant trait release. Page 76 of 

the "Forest Vegetation" section states that a total of 

94 acres will be treated, equivalent to the 

Shelterwood acreage in table 3. Please clarify.

There is some confusion as to the total acreage 

involved, which I think is over 94 acres since some 

sugar pine will be planted in the gaps. Please 

clarify. Again, the photographs (Fig 17) are 

convincing but there needed to be more 

information on the success (?) of the 2003 project.

Sugar Pine In Hwy 46, the acres listed as Sugar Pine 

Shelterwoods are the acres intended for sugar pine

restoration. In these stands, the overstory is being 

modified to create the best possible conditions for 

sugar pine seedling establishment. In other units 

that have gaps created for wildlife, sugar pine 

may also be planted with other species, although 

conditions may not be ideal for their 

establishment. Since the underlying purpose of 

these gaps is not for sugar pine restoration, they 

were not labeled as such. If the sugar pine 

becomes established in these areas, it will be 

considered a secondary benefit.

Karen Sjogren Although sugar pine restoration is a very small part 

of this project, alternative 2 does remove a fair 

volume of timber. The justification for this should 

have included an analysis of the somewhat similar 

2003 Sugar Pine Project, which involved treating 

187 acres of existing sugar pine by heavily 

thinning a 30' radius around them. As I asked in 

my scoping comments (first paragraph), how 

successful was this project in promoting the health 

and growth of those stands of sugar pine? Did it 

make them more fire resistant? This would seem 

particularly relevant since those stands are close to 

those proposed for treatment in the highway 46 

project.

Sugar Pine Although both the shelterwood prescriptions in 

this project and the prescriptions in the 2003 

project are both designed to improve sugar pine, 

there are some key differences in the objectives of 

both projects. The prior project involved thinning

around existing sugar pine, sometimes referred to 

as “daylighting”. As sugar pine grow older they 

become less tolerant of competition from 

neighboring trees, which can ultimately lead to 

their demise either from fire, insects, or lack of 

sunlight. The prior treatments addressed that issue 

and were designed to retain the sugar pine already 

established there. These treatments were 

appropriate for that area because there were a 
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383

Commenter Comment Resource Topic Response

fairly high number of sugar pine in the stands that 

were treated. 

The units proposed for treatment in the Hwy 46 

project do not have the high stocking of sugar

pine that the previous projects stands did. Several 

of the stands do not have any sugar pine currently 

in them. The goal of these prescriptions, in which 

planting of rust resistant sugar pine is an integral 

part, is to restore the species to areas that they are 

either fading from or have already disappeared. It 

does appear that at least one stand in the 2003 

project had a similar prescription, and there is a 

picture of that stand in the FEIS. There are some 

sugar pine seedlings beginning to establish in that 

stand, either from planting or naturally 

regenerated.

As to the fire resistance of the previously treated 

stands, it is difficult to say if the sugar pine would 

survive fire in those stands, there are many factors 

to consider. The most important one is the 

intensity of the fire. If weather and fuel conditions 

support a running crown fire to enter the stand, a 

daylighting treatment would do little to save the 

trees. However, the thinning of the stand around 

the sugar pine, such as with the shelterwoods 

proposed in this project, as well as reductions of 

the slash through prescribed burning, greatly 

reduce the likelihood of such a fire taking place 

there.

Karen Sjogren Will the sugar pine planted be resistant to the bark 

beetles that killed off mature trees in the 1980's?

Sugar Pine Sugar pine have two primary threats, whitepine 

blister rust and bark beetles. There are no 

genetically bark beetle resistant sugar pine that we 

are currently aware of. There is genetically rust 

resistant sugar pine, however, and that is what 

will be planted as part of this project. The best 
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Commenter Comment Resource Topic Response

defense for bark beetles is to have healthy, 

vigorous trees. The shelterwoods prescribed will 

reduce inter-tree competition for the sugar pine 

and should increase their resistance to bark 

beetles.

Karen Sjogren Tables 6 and 8 summarize the forest age classes for 

each alternative, and address the concerns of many 

that older stands will be targeted. These tables are a 

good idea, but either some of the figures are 

incorrect or there needed to be an explanation how 

they were arrived at.

Stand ages Stand ages were determined by individual tree 

ages collected with an increment corer during 

stand exam.

Steve Sheehy Oregon's old growth forests need to be protected 

not logged

Stand age No old growth stands are being proposed for 

harvesting in any alternative of this projects. 

Hazardous fuels activities in units 170 and 270 

around the Breitenbush property will be limited to 

cutting brush and thinning trees less than 7 inches 

dbh.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The agency must protect mature forests because 

they are the best candidates to grow and develop 

into old-growth habitat in the shortest time frame

Stand age Some of the mature stands in the project area are 

experiencing competition due to high tree 

densities. Thinning treatments in these stands are 

designed to increase tree growth and accelerate 

species diversity in the mid-story, ultimately 

moving those stands to an old-growth structure in 

a shorter time frame than if left in their current 

condition.

Early seral habitat creation in some of these 

stands increases structural diversity at the 

landscape level, creating habitat for a wider 

variety of plant and animal species and replicating 

natural processes, such as fire, that shaped the 

landscape historically.

Daphne Stone with global warming, we need to do everything 

possible to keep the forests cool so that all forest 

organisms survive this gradual but drastic change

Stand condition The long term effects of climate change in the 

Pacific Northwest are uncertain at this time. One 

of the best ways to make our forests more resilient 

to changes is to reduce stress on the trees. Trees 
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385

Commenter Comment Resource Topic Response

that are experiencing less competition from other 

trees have more access to water, light, and 

nutrients and will have more resources available 

to them to cope with the possible effects of 

climate change such as drought and insects. 

Thinned stands are also more resistant to stand 

replacing fire. Treatments prescribed for this 

project, including the thinning of dense stands of 

trees, will improve forest health and resiliency to 

the possible effects of climate change in the 

future.

Andy Geissler, 

AFRC

The Highway 46 EIS indicates that 877 acres of 

potential treatment units will be "skipped" and 260 

acres will be treated to result in openings (regen 

harvest, GTRs, gaps). While this level of openings 

exceeds most Forest Service vegetation 

management projects that we review, we still 

would like to see the District strive toward a better 

balance on future projects than 877:260. With that 

said, we urge the District to at least implement 

those openings analyzed in the proposed alternative 

of the EIS

Skips Virtually all of the skips within proposed units are 

due to protection buffers for riparian areas, special 

habitat areas, or areas within the unit that do not 

need silvicultural treatment due to low stocking or 

tree size. The initial location of the proposed units 

are generally determined by the boundary of past 

harvest units, the buffer locations determined later 

which ultimately define the amount of unit 

acreage in skips. In stands where skips are 

required due to Forest Plan direction, additional 

skip acres are added if these defined skips do not 

adequately provide the required amount. This was 

only required for about four units in this project.

Linda Cummens If the use of trees were done in a sustainable 

habitat method Oregon wouldn't have groups of 

mountains stripped illegally beyond the sight of 

most citizens to unproductive dirt.

Clear cutting this area specified for a National 

Monument will turn it and a beautiful part of this 

state that earns much more through tourist 

activities into an ugly place with polluted water all 

living creatures drink.

As stated in Appendix B of the FEIS, this project 

proposes to thin approximately 2,500 acres of 

plantations and fire regenerated stands that are 

overstocked, leaving 40 – 100 trees per acre. 

Early seral units and wildlife gaps, amounting to 

93 acres, will have 7 to 8 trees per acre left in 

them and will be planted with seedlings to a 

stocking level of 150 -200 trees per acre. Native 

grasses will also be planted in these units as 

forage for big game. “No harvest” buffers will 

protect all streams and riparian areas. All 
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Commenter Comment Resource Topic Response

prescriptions are in alignment with the Willamette 

Forest Plan and the Northwest Forest Plan

direction of sustainable forestry. Historic amounts 

of early seral in the Breitenbush Watershed were 

measured at 9% of the watershed. Even with the 

new early seral created by the 2017 fires, early 

seral in the watershed is currently only at 5.6% of 

the watershed. One of the goals of this project 

was to create more quality early seral, but in 

looking for areas where plant associations would 

create true quality early seral, no additional 

opportunities were found.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Additionally in the FEIS, please take into account 

the episodic nature of fires and the natural creation 

of early seral habitat. Areas the size of this project 

area could go without large-scale stand replacing 

fires for extended periods. The current condition of 

forests in the project area may therefore be within 

the historic range of variability. Looking at larger 

scales, there are very large fires not far away from 

this project area (such as the B&B fire, and all the 

Sisters District fires) where early seral habitat is 

abundant. The project area is potentially between 

fire cycles right now, but future fire can be 

expected to create abundant early seral habitat in 

time.

Fire Fire return intervals within the western Cascades 

and the Hwy 46 planning area are indeed highly 

variable. The project only proposes a 0.3% 

increase in early seral creation within the planning 

area. This combined with the early seral created 

by the 2017 fires and that already present would 

only create approximately one third of the early 

seral that is believed to be within the historic 

range of variability, allowing for future fire 

disturbance to add to that number and still be 

within the historic range.

Freres Freres requests prebunching in skyline units be 

allowed at purchaser’s discretion

Soils Each unit was studied (field surveyed) for terrain 

suitability (i.e. unstable ground, etc.) and 

accessibility, those site conditions and slopes 

determined that at least 51 units were not feasible 

for pre-bunching operations. Pre-bunching will be 

allowed in the units where the terrain is suitable.

Nick Cady for 

Cascadia 

Wildlands, 

Our organizations prefer that there is no 

commercial logging in riparian reserves, and no 

tree removal in these areas. Even when these areas 

Riparian 

Reserves

Regarding the first comment that further tree 

removal will exacerbate problems of nutrient 

depletion in Riparian Reserves, the belief that 
Hwy 46 FEIS Appendix 

387

Commenter Comment Resource Topic Response

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

have been logged in the past, we believe these 

areas are suffering from the previous removal of 

biological material that leads to depletion in 

nutrients that would have recruited from natural 

mortality. Further tree removal will acerbate these 

problems, and again that the benefits from 

increased openings do not outweigh the costs will 

removal, and that these openings will naturally 

occur over time with natural mortality. Alternative 

3 reduces by a couple hundred acres the proposed 

riparian logging acreage, but there is no Alterative 

that omits Riparian logging or restricts riparian 

logging to an alternative that contains all noncommercial logging with all trees felled remaining 

in place. Additionally, the only riparian reserve 

areas that should be targeted, should be formerly 

logged second growth, not naturally regenerating 

areas.

these areas are already suffering from nutrient 

depletion is not based on any existing local data 

or conditions. As stated in the FEIS, p 304, the 

DECAID analysis of downed logs and snags on 

the watershed scale documents that the 

“abundance of downed logs currently is similar to 

what was historically present within the 

Breitenbush River watershed.” Project design 

features minimize additional loss of downed

wood: All existing down wood will be retained 

within Riparian Reserves to maintain aquatic 

objectives” (FEIS, p. 58).

The commenter states that the openings created 

do not outweigh the costs. The FS recognized that 

there are tradeoffs. DEIS on page 115: “In some 

cases, maintaining and/or restoring each one of 

the ACS Objectives can be a balancing act with 

trade-offs. For example, to meet the riparian 

vegetation objectives (“species composition and 

structural diversity of plant communities” and 

“habitat to support well distributed populations of 

native plant, invertebrate and vertebrate riparian 

dependent species”) in young, dense conifer 

stands, a common silvicultural tool is to remove 

overstory density to encourage understory growth 

and structural development. Removal of overstory 

density, however, could potentially lead to 

increased thermal loading or reduction of wood 

volume available for recruitment. Because of 

these trade-offs, we carefully balance conflicting 

objectives based on characteristics of each 

waterbody and adjacent riparian area.” 

Regarding the comment that these openings will 

occur on their own naturally over time, the FS 

recognizes this on page 125 of the FEIS: “Desired 
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Commenter Comment Resource Topic Response

riparian conditions – high species and structural 

diversity with large dead and down wood – would 

slowly develop over time (several decades) and 

depend solely on natural thinning events (stem 

exclusion mortality and disturbance). Without 

management to increase the abundance of 

deciduous and herbaceous vegetation in dense, 

conifer-dominant stands, ecosystem productivity 

would remain at relatively low levels.” 

Deciduous leaves along stream channels are a 

critical component to adding nutrients to these 

systems.

Alternative 3 addresses the 4th comment that 

recommended “the only riparian reserve areas that 

should be targeted, should be formerly logged 

second growth, not naturally regenerating areas”. 

In regards to the comment that [there is no 

Alterative that]. . . restricts riparian logging to an 

alternative that contains all non-commercial 

logging with all trees felled remaining in place,” 

the FS did not consider this as a viable treatment

on this scale.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Cascadia strongly objects to logging riparian 

reserve stands over 80 years old. There is just no 

need. The superficial resemblance to younger 

stands is not a reason to log these older stands. At 

this age, stand growth has slowed and they need to 

hold onto their biomass and let it begin 

accumulating in live and dead pools.

Riparian 

Reserves

In line with the Aquatic Conservation Strategy, 

the Forest Service’s goal is to improve riparian 

conditions on a watershed scale. In the Purpose 

and Need, we state (FEIS, p18): Maintain 

conditions in currently functioning portions of 

Riparian Reserves. In overstocked, coniferdominant portions lacking structural and species 

diversity, attain Aquatic Conservation Strategy 

Objectives. Regardless of their age, these stands 

are currently dense monocultures with very little 

structural or species diversity at present. 

In the Breitenbush Watershed, even-aged conifer 

dominated riparian stands are overrepresented and 
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Commenter Comment Resource Topic Response

diverse riparian communities are 

underrepresented. In the FEIS, p 113, we stated: 

“Within the scale of the Hwy 46 project area (Figure 35), approximately 91% of Riparian

Reserves are conifer-dominant and less than 2% 

are deciduous-dominant (trees and shrubs) (Table 

26). Approximately 2.6% are mixed conifer and 

deciduous, which occur primarily in late-seral 

stands along the Breitenbush River. The results of 

this landscape-scale analysis reveal a very low 

abundance of deciduous species and are 

corroborated by surveys at the stand scale, where 

dense conifers dominate Riparian Reserves and 

there is often a lack of understory development 

and species diversity.”

In the FEIS, p 115, we further state: Of 1,458

acres of Riparian Reserve within the proposed 

(Alternative 2) units, 973 acres (68% have been 

harvested in the past, and are considered 

plantations. Approximately 462 acres (31%) are 

considered fire regenerated and have not been 

managed, though most of these are in similar 

condition to past regeneration harvested Riparian 

Reserves due to stand replacing fires around the 

turn of the century. Riparian stands proposed for 

commercial thinning treatment are a combination 

of plantations created after clear-cut harvesting 

and natural fire regenerated areas. All of the 

plantation stands and most of the older fire 

regenerated stands are considered to be in the 

stem exclusion structural stage. Riparian stands to 

be treated are considered to be in the stem-

exclusion stage.

Riparian stand conditions were individually 

assessed on a unit by unit basis with multiple 
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Commenter Comment Resource Topic Response

resource specialists to determine if treatment

would benefit or retard attainment of ACS 

objectives. Studies and forest stand classifications 

have shown that the maximum mean annual 

increment (an indication of tree growth) is 

achieved much later than 80 years in these types 

of stands (and soil type) (see Section 3.1). This 

suggests that in some stands, 80 years is an 

arbitrary threshold and that there is significant 

stand and structural resemblance to younger 

stands. Alternative 3 addresses the commenters 

concern that no riparian reserves over 80 years are 

logged.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Cascadia is concerned that a reduction in instream 

wood recruitment violates the "do not retard" 

standard of the Aquatic Conservation Strategy. 

Logging in the riparian reserves to create bigger 

trees faster which would then presumably fall in 

streams emphasizes only large wood recruitment 

instream while ignoring the equally important need 

for wood recruitment in the upland portion of the 

riparian reserves. We are also concerned the Forest 

Service will perpetuate the myth that thinning

enhances future wood recruitment, when in reality 

any increase in very large wood in the distant 

future comes that the expense of significant 

reduction in wood recruitment in functional sizes 

classes. Please take a hard look at these issues and 

trade-offs in the DEIS.

Aquatic 

Conservation 

Strategy

In regard to the first and second concern, we 

acknowledge in Section 3.3.4 that "in some cases, 

maintaining and/or restoring each one of the ACS 

Objectives can be a balancing act with trade-offs. 

For example, to meet the riparian vegetation 

objectives (“species composition and structural 

diversity of plant communities” and “habitat to 

support well distributed populations of native 

plant, invertebrate and vertebrate riparian 

dependent species”) in young, dense conifer 

stands, a common silvicultural tool is to remove 

overstory density to encourage understory growth 

and structural development. Removal of overstory 

density, however, could potentially lead to 

increased thermal loading or reduction of wood 

volume available for recruitment. Because of 

these trade-offs, conflicting objectives were 

carefully balanced based on characteristics of 

each waterbody and adjacent riparian area." 

(DEIS, p 125).

We have added language to the FEIS (Section 

3.3.4) addressing wood recruitment in the upland 
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Commenter Comment Resource Topic Response

portion of the Riparian Reserves and an analysis 

of the tradeoffs. 

In regard to the third concern, a hard look was 

taken and is discussed on page 149: “Current rates 

of large wood recruitment, provided mostly by 

stem mortality (from competition, disease, wind 

and snow downed trees) and bank erosion, would 

be maintained. Alternative 1 would provide a 

slightly higher rate of natural in-stream wood 

recruitment compared to the action alternatives. 

Where the action alternatives protect about 90% 

of the wood recruitment zones, the No-Action 

alternative would protect 100%. In some streams, 

recruitment trees are of sufficient size to meet 

ACS Objectives (Appendix E), but in other 

streams with small diameter riparian stands the 

aquatic benefit is limited, namely through the 

reduced ability to store sediment and organic 

matter and contribute to habitat forming processes 

(e.g. scour). Though small wood has some value, 

particularly in the smaller headwater reaches, the 

longevity of recruited small diameter trees is 

short-lived, as they break down through abrasion 

and decomposition more rapidly compared to 

large trees. Small diameter trees are also more 

likely to be transported out of the system. In-

stream wood abundance is low for most streams 

in the project area and is largely due to the lack of 

large enough wood to remain stable in channels.”

Additionally, as discussed on page 292,

“Densities in proposed unit Riparian Reserves

range from 75 to 397 TPA, averaging 200 TPA. 

In contrast, recent forest research in the Coast 

Range and Western Cascades indicates that 

existing old growth stands developed with natural 
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Commenter Comment Resource Topic Response

stand densities of 40 to 60 conifers per acre 

(Tappeiner et al 1997; Poage & Tappeiner 2002). 

As stated in the DEIS page71, thinning to 

densities of 40-100 TPA is prescribed, which are 

still greater than natural stand densities. 

Therefore, down wood resulting from continued 

stand development is expected to be considerably 

higher in these stands than typically found in 

naturally regenerated stands.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

We suggest that any efforts to actively restore 

riparian forests for the benefit of certain species 

should be treated as scientific experiments and 

proceed cautiously, skeptically, and with robust 

pre- and post- treatment data collection efforts. 

Hypothesized effects of thinning on riparian forest 

structure and the use of that structure by targeted 

species should be tested against empirical data.

Riparian 

Thinning

No riparian thinning is being done for restoration 

of certain species, but rather as for restoration to 

increase structural and species diversity in the 

stands. The only proposed treatment that is 

targeting a certain species is the Sugar pine 

restoration and these treatment prescriptions are 

done in the uplands outside of Riparian reserves. 

The sugar pine units that also have Riparian 

Reserves would just have commercial thinning in 

the Riparian Reserves to improve stand and 

species diversity.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Density-dependent versus density-independent 

mechanisms. The agencies often emphasize that 

mortality is not a significant contributor to 

instream wood recruitment, implying that the effect 

of thinning on density dependent mortality may not 

be a big deal. However, the agencies also need to 

recognize that thinning in potential wood source 

areas significantly reduces the total amount of 

wood available for natural processes to act upon. 

Since natural disturbance occurs in both thinned 

and unthinned stands, the proper comparison is not 

between density-dependent versus densityindependent sources of dead wood, but rather the 

total recruitment of dead wood from all sources in 

thinned versus unthinned areas.

Riparian thinning In regards to the first statement, “The agencies 

often emphasize that mortality is not a significant 

contributor to instream wood recruitment, 

implying that the effect of thinning on density 

dependent mortality may not be a big deal”, in the 

FEIS on pages 124-125, the FS acknowledges that 

under no action, “Current rates of large wood 

recruitment, provided mostly by stem mortality, 

(from competition, disease, wind and snow 

downed trees) and bank erosion, would be 

maintained.” On page 128, we cite Benda and 

Bigelow’s 2014 study that “found that in managed 

forests of the Cascades Range, where bank 

erosion and tree mortality are the dominant wood 

recruitment processes, 90% of in-stream wood 
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Commenter Comment Resource Topic Response

originated from within about 8 meters (26 feet) of 

stream channels and the remaining 10% is 

supplied from a distance equivalent to one tree 

height.”

In regards to the second statement: “However, the 

agencies also need to recognize that thinning in 

potential wood source areas significantly reduces 

the total amount of wood available for natural 

processes to act upon”, the FS does recognize in 

the FEIS on pages 129-130 that thinning in 

potential wood source areas does reduce the total 

amount of wood available for natural processes to 

act on, especially in the intermediate-term. While 

these reductions in wood recruitment would occur 

in the individual unit level Riparian Reserves, the 

FS does not agree with the commenter that these 

reductions are “significant”, as the proposed 

treatment commercially thins only 2.5% of 

Riparian Reserves in the Breitenbush Watershed.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

We do appreciate that the Forest Service 

considered some "streamside fall and leave" 

treatments, DEIS at 44, but we are unclear on why 

these prescriptions were limited to the thin 60 foot 

no- harvest buffers. Trees outside of these buffers 

are going to be large enough to reach these streams 

and much of the science discussed above urges the 

retention of trees outside of these thin no-harvest 

buffers to benefit downed food in these riparian 

areas. We would like to see an explanation with 

scientific support of why the fall and leave strategy 

is not important outside of the 60-foot no harvest 

buffers selected by the FS in the FEIS.

Riparian reserves As stated in the DEIS on pages 78 and 103-106, 

the project area and Breitenbush watershed as a 

whole are deficient in hardwoods along streams. 

Hardwood foliage not only provide riparian 

diversity but important sources of nutrients and 

food sources to riparian and aquatic organisms. 

Management activities are designated to meet the 

ACS objectives on a watershed scale. It is clearly 

documented in the DEIS that riparian vegetation 

diversity is lacking on a watershed scale, in 

addition to a limited instream large-wood 

component. Increasing riparian diversity, 

specifically increasing the streamside hardwood 

component was the primary objective for these 

treatments with additional benefit of augmenting 

instream large wood component. On page 120 of 
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Commenter Comment Resource Topic Response

the DEIS, we detail how these areas selected for 

streamside treatment were carefully identified. 

While “fall and leave” treatments beyond the 

inner 60 feet no-harvest buffer would have 

additional benefits to increase upland course 

down woody debris in the Riparian Reserves, the 

watershed is currently within the range of natural 

variability for downed wood, so it was not 

targeted as a needed restorative treatment activity 

for Riparian Reserves in this project area. 

This further clarification has been provided in the 

FEIS as requested in Section 3.3.4. The FS does 

appreciate the commenter’s recognition of the 

benefits of the fall and leave treatments and will 

consider these treatments on greater scales in 

future planning areas.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The DEIS notes that both Alternatives will have 

negative impacts on stream flows in the project 

area. The chart on page 114 of the DEIS notes 

these negative riparian impacts associated with 

logging which is generally prohibited in the 

riparian areas. However, the Forest Service also 

states that these impacts "would be immeasurable 

and are therefore not anticipated to be adverse." Id. 

How are the effects immeasurable if on the 

following page the decrease in flows is measured? 

This is an ACS violation.

Riparian impacts As explained in Chapter 3, we use the Aggregate 

Recovery Percentage (ARP) model to analyze 

how the proposed alternatives will affect stream 

flows. Following the 2017 Whitewater fires, we 

re-ran the model due to changed watershed 

conditions. As we adjusted the model’s canopy 

cover inputs to reflect the changed post-fire 

conditions, we also discovered some other 

significant errors in the model’s inputs that was 

run for the DEIS. We corrected these inputs in the 

re-run of the model and as indicated in the FEIS, 

Chapter 3, resulting ARP values are and will 

remain well above the threshold for any of the 

alternatives with no impacts to stream flows 

expected. A full description of this correction and 

results is detailed in Attachment A of the FEIS 

Hydrology Specialist Report.

Karen Sjogren Prescribed burning 23% of the thinning acreage in 

Riparian Reserves strikes me as excessive for fire 

Riparian 

Reserves

Allowing fire to back down into Riparian 

Reserves would have less impact than alternative 
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Commenter Comment Resource Topic Response

which is only "backing into" the reserves. Is some 

of this acreage pile burning?

approaches, such as constructing hand-line around 

the entirety of the reserves or pile burning in 

treated areas in the reserves. In the FEIS, 23% 

represented an absolute maximum of potential 

Riparian Reserve acreages that could potentially 

be underburned. It does not represent pile burning 

acreage. It was calculated from the total acres of 

Riparian Reserves within any units that were 

proposed have underburning. A more realistic 

estimation acres of Riparian Reserves that would 

be underburned is to consider just the portions of 

units that would likely underburned (as opposed 

to the entire unit itself).

In response to this comment, the Fuels Specialist 

and Hydrologist reviewed all the proposed 

underburning units with Riparian Reserves and 

were able to provide a more realistic range of 

Riparian Reserve acres that might be impacted by 

underburning. Based on stand conditions and 

logistical needs, several units and many portions 

of units would not be underburned after all. Please 

see the FEIS, Chapter 3 for updated estimates to 

acreage of Riparian Reserve affected by 

underburning activities.

Pamela Lauer Please take into consideration that a diverse 

riparian zone creates a healthy watershed. A stand 

of only sugar pines, only douglas firs, only any one 

plant cannot adequately provide shelter, shade and 

resources for a thriving watershed.

Watershed 

management

We strongly agree with this statement. This is a 

key point about why these Riparian Reserves are 

proposed for treatment. On the watershed scale 

we are lacking diversity in our riparian areas. The 

riparian reserves proposed for treatment currently 

exhibit very low diversity in species and structure, 

essentially plantations at the present time. The 

goal of the proposed action in Riparian Reserves 

is to increase species and structural diversity in 

alignment with the ACS. Of the proposed units 

that have Sugar pine restoration, the Riparian 
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396

Commenter Comment Resource Topic Response

Reserve portions and other portions of those units 

have silvicultural prescriptions to increase species 

and stand diversity. Thinning will encourage more 

shade tolerant species such as western hemlock 

and western red cedar to grow into the mid-story, 

as well as allowing all trees to grow faster and 

produce larger snags in the future. As indicated on 

page 42 of the DEIS, zero acres of Riparian 

Reserve are proposed for Sugar Pine Restoration.

Daphne Stone Cutting forests, especially old forests, along 

riparian corridors significantly warms water in the 

streams. Right now we need to do everything we 

can to counter the warming and protect streams. 

Stream temperatures are critical for insects and fish 

in them

Stream 

temperatures

With the exception of the fall and leave treatment

streamside areas, there is no cutting of trees in the 

primary shade zone. Cutting in the secondary 

shade zone will not reduce canopy cover below 

40%. Based on the modeling in the Willamette 

TMDL (2012), this proposed treatment will not 

significantly increase stream temperature.

Karen Sjogren I know that recent fires were not reasonably 

foreseeable, but did they change any of the analysis 

in the Hydrology Section?

Hydrology / Fire 

impacts

Yes, the fire did change some existing conditions. 

Post-fire related updates to the FEIS include 

changes to Peak Flow analysis/ARP model inputs 

and results; riparian conditions, sediment delivery 

potential to streams, and suppression-line 

activities. Changes to the proposed action include 

decommissioning of additional road miles that 

were opened for the suppression activities and 

possible future changes to stream buffer widths/ 

Riparian Reserve Treatment in Unit 83. Please see 

the FEIS for more specifics.

Karen Sjogren The summaries is excellent. The first sentence, 

however, contradict the top of page 7, with respect 

to the effects of the project on UW ESU Spring 

Chinook salmon (I believe p.7 is incorrect) Why is 

Section 7 consultation with NOAA/NMFS so late? 

(May 2018)

Fisheries There was an error on Page 7. That error has been 

corrected. Section 7 consultation with NMFS is 

taking anywhere from 8-12 months. Consultation 

cannot begin until all of the design elements have 

been completed.

Karen Sjogren The wider buffers are still important to protect 

ESA listed fish, and these are detailed on p. 141. 

Fisheries There is no proposed under-burning within 172 

feet of any MIS/ESA fish bearing stream in the 
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397

Commenter Comment Resource Topic Response

The added commercial thinning n Alternative 2 is 

made more acceptable by the fact that this activity 

will not be allowed within 172' of ESA-listed fish 

habitat or the 20 units adjacent to streams with 

Management Indicator species. It is also important 

to me that no hazardous fuels treatments will occur 

within 172' of streams. Do these restrictions for 

MIS/ESA species apply to underburning/pile 

burning also?

Hwy 46 EIS. The Riparian Reserve Buffer widths 

along MIS/ESA fish bearing streams is 344’. 

Some underburning may occur (backing fire) in 

the outer portion of the Riparian Reserve (172-

344). Limited Pile burning may occur, outside 

100 feet, in ground based units near MIS/ESA 

streams.

Bill Richardson

for Rocky 

Mountain Elk

Foundation

For the past 16 years volunteers of the RMEF and 

Oregon Hunters Association, with support of the 

USFS, ODFW, BPA and PGE have developed and 

enhanced wildlife forage within the Highway 46 

Project area, primarily within the transmission line 

right of way. The purpose of the volunteer work is 

to compensate for the lack of early seral habitat

due to lack of active forest management. The 

volunteer work has been successful in making it 

possible for a remnant population of black-tailed 

deer and Roosevelt elk to persist within the project 

area.

Wildlife These projects have removed invasive plants in 

the powerline corridor and converted those areas 

to meadows and native shrub species. These areas 

have concentrations of deer and elk which have 

limited options for early seral forage in the rest of 

the project area. One of these areas is along the 

Northern boundary of Breitenbush Resort where 

deer and elk are regularly observed.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Further, from an ecological perspective there is no 

such thing as too much wood. Cascadia believes 

that the current standards for snags and dead wood

were a product of political compromise and are 

biologically outdated. More dead wood is needed 

to meet a wider variety of life needs and more 

green trees are needed over time to recruit that 

dead wood. The Forest Service can't continue to 

manage against dead wood while its standards are 

known to be inadequate.

Dead wood Willamette National Forest standards and 

guidelines for dead wood and snags are being met 

in the planning area. In addition the most recent 

science is derived from the DECAID website and 

integrated into analysis for this project area.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

Cascadia Wildlands and Oregon Wild urges the 

Forest Service to omit the proposed regeneration 

harvest designed to create artificial early seral 

forest. Mature forest conservation remains a much 

Wildlife / Early 

Seral Habitat

Maintaining all ecosystems present at a landscape 

level is an important part of Forest Service 

direction. Early seral habitat is below historical 

levels in the Breitenbush watershed. The only 
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398

Commenter Comment Resource Topic Response

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

more important conservation priority than the 

creation of early seral forest. There is not really a 

shortage of early seral forest which is abundant on 

non-federal land. The sheer quantity of early seral 

on private lands partially compensates for the lack 

of habitat quality. Also, wildlife associated with 

early seral forest are not at risk. Those species 

generally tend to be mobile, generalists and 

opportunistic.

Also given that it is recognized that private timber 

lands and small-scale agricultural lands can 

provide early-seral habitat for species like deer and 

elk, please quantify the amount of early-seral 

habitat being provided in the project area and 

watershed by these types of operations. 

private land in the Watershed is the Breitenbush 

Resort which is not expected to be converted to 

early seral habitat’

Private timber land and agricultural lands are not 

present in the project area.

Karen Sjogren The author includes some existing early seral 

habitat in the Project Area not mentioned 

elsewhere in the text besides power lines- 2 acres 

of natural meadows and 30 acres of timber harvest 

less than 20 years ago (Table 19 gives this total as 

20 acres). Nonetheless, he makes the valid point 

that early seral habitat is a low (1.15%) percentage 

of the Project Area, compared to what it was 

historically (9%). The effects analysis for 

Alternative 2 is correct, adding meadow 

restoration, quality early habitat and wildlife gaps

to arrive at about 99 acres, an increase of .31% in 

this habitat type for a total of 1.46%. However, for 

Alternative 3, the combination of early seral habitat 

creation (16 acres) and gaps (34.8) is 51 acres, not 

44. This is a .16% increase, bringing the total to 

1.31% early seral habitat. The summary figures 

should also be changed to 1.31% and 413 acres.

Wildlife / Early 

Seral Habitat

Thank you for taking such a detailed look at the 

acres involved in this analysis. This can be a 

difficult process and errors can be made in 

updating numbers as the planning process evolves 

and changes are made to proposed actions. For 

alternative 3 the spreadsheet shows 16.0 acres of 

early seral and 28.8 acres of gaps for a total of 

44.8 acres. It seems the acres were underestimated 

by 0.8 acres. Then again that 0.8 acres is two gaps 

that are 0.5 and 0.3 acres so might not be large 

enough to count toward gap acres. This is why the 

term approximate is used. Since dominant tree 

release is difficult to evaluate, acreage is often 

slightly overestimated to ensure enough acres are 

included to cover variance in prescriptions.
Hwy 46 FEIS Appendix 

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Commenter Comment Resource Topic Response

Nick Cady for 

Cascadia 

Wildlands,

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The FS states that the early-seral habitat creation 

through clearcutting will benefit the western 

bumblebee. Is there any science to demonstrate that 

western bumblbees thrive is post- logging earlyseral environments? We are curious about how this 

species fares in newly creation plantations and 

whether the application of herbicides influences the 

successful entry or re-entry of this species into 

logged and sprayed areas. Is the FS spraying the 

early-seral areas? Will this impact the bee? Do 

complex early-seral habitats benefit the species 

more than clearcut? The DEIS states that there are 

no western bumblebees in the project area, how 

will this early seral habitat benefit them if they are 

not present? How close is the nearest documented 

population? Please address these questions in the 

FEIS or the republished DEIS.

Western Bumble 

Bee

Western bumblebees have experienced declines in 

populations for unknown reasons. Providing 

flowering plant habitat as an ecosystem which 

western bumblebees could utilize is one benefit of 

maintaining early seral habitat areas. Historically 

western bumblebees were documented along the 

powerline in the analysis area, although none 

were located during surveys related to the Hwy 46 

project.

Herbicide use is not proposed in the Hwy 46 

project.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

In the FEIS, please include any data or studies that 

look at spotted owl recolonization or use of thinned 

stands (pre and post logging activities). We are 

concerned that there are short- term impacts 

associated with commercial logging that will 

displace spotted owls or interrupt essential 

behavioral activities. It be useful to see information 

on how quickly spotted owls re- inhabit thinned 

stands or if young stands that were thinned were 

later recolonized by the species.

Northern Spotted 

Owl

The thinning proposed in this project would not 

displace NSO or disrupt their essential behavioral 

activities. Because there would be no 

displacement, time for recolonization is not an 

issue. “The Biological Assessment for Willamette 

Planning Province of Oregon for FY 2018 LAA 

Projects Within the Willamette National Forest 

With a Potential to Modify Habitat and/or Disrupt 

Northern Spotted Owls” discusses these issues on 

page 38-40 and provides references. Other 

literature citations are located on Pages 111-116. 

These citations includes studies of prey species 

and of NSO habitat use patterns. One reference on 

page 115 discusses your concerns – USFWS (U.S. 

Fish and Wildlife Service). 2007. Draft: What are 

the Effects of Habitat Thinning on Northern 

Spotted Owls?
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400

Commenter Comment Resource Topic Response

Adverse effects of disturbance to NSO would be 

avoided in this project. Extensive surveys were 

conducted and where activity centers were located 

seasonal prohibitions on project activities are in 

place to avoid disruption of NSO ‘essential 

behavioral activities’.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

the DEIS fails to take a hard look at numerous 

elements of this issue, including the invasion of the 

barred owl, cumulative impacts of past/ongoing 

logging associated with the fire season, and the 

impact of thinning on owl prey species. Barred 

owls are simply not mentioned, this is 

inappropriate. If barred owls are in the project area, 

this is significant as the species displaces the 

spotted owl. If the proposed logging has an impact 

on the spotted owl, even a very short term impact 

(temporary displacement), this could create an 

opening for the barred owls to move into these 

areas and further contribute to the spotted owl's 

decline. We discussed the barred owl concerns in 

our scoping comments, please ensure this issue is 

addressed in the FEIS.

Northern Spotted 

Owl

This comment is more related to the consultation 

process and recovery plan objectives for NSO at a 

region wide perspective. Consultation documents 

and specifically Biological Opinion 01EOFWOO2017-F-0555 contains discussions related to 

barred owls and other factors affecting the long 

term viability of the NSO. Barred owls are present 

throughout the range of the NSO. Barred owls are 

mentioned and discussed in FEIS section 3.6.4 

Affected Environment – Northern Spotted Owl.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Regarding prey species, the DEIS simply 

concludes: "Variable density thinning adds 

diversity to the stands which also benefits owls by 

providing more diverse habitats for prey species." 

But in previous FS projects and BLM projects, 

commercial thinning has been acknowledged to 

have short-term impacts on prey species, and cause 

temporary displacement and potentially affect 

recolonization of the logged areas. This is 

significant and needs to be discussed.

Northern Spotted 

Owl

Each agency has projects in different areas and 

habitat types which can have different impacts on 

prey species. The term recolonization infers 

removal of NSO as a result of treatments which is 

not expected to occur with the protection 

measures integrated into project design and 

seasonal prohibitions on potentially disruptive 

activities.

The ‘Biological Assessment For Willamette 

Planning Province of Oregon for FY 2018 LAA 

Projects Within the Willamette National Forest 

With a Potential to Modify Habitat and/or Disrupt 

Northern Spotted Owls’ includes Hwy46. This 
Hwy 46 FEIS Appendix 

401

Commenter Comment Resource Topic Response

document was not available at the time the draft 

EIS was submitted for comments. This B.A. 

discusses specific prey species and provides 

references to papers which address impacts to 

Spotted Owl prey species on pages 38-40.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

This section in the DEIS is scant absent a 

Biological Assessment from Fish and Wildlife 

Service. Are these stands RA 32? Were RA 32 

stands logged in this year's fire season? Were owl 

activity sites impacted by the logging this past fire 

season? 

Northern Spotted 

Owl

The DEIS was published prior to the results of 

consultation being available. The biological 

evaluation and biological assessment from the 

USFS and biological opinion from the USFWS 

are now available for review. While logging did 

not occur during the 2017 fire season in the 

project area, suppression activities did result in 

log decks that were sold. The contingency fire 

line south of the Breitenbush community between 

Devil’s Creek and the South Fork of the 

Breitenbush River is located in RA 32, however, 

all cut material was left in the forest. The fire line 

constructed in this area was a hand line 

constructed by hand using existing user trails in 

order to minimize impacts on RA-32. Dead snags

that were safety hazards for firefighters were cut 

but most cutting was small brush and trees less 

than 7 inches. No large live trees were cut in the 

construction of this fire line. No commercial 

timber was cut in this area so there was none to 

sell as part of the log deck sale. The only 

commercial timber that was cut was the result of 

mastication work along roads that were being 

fortified as fire lines.

Karen Sjogren The effects analysis for the action alternatives was 

difficult to understand and I have struggled to 

come up with the author's figures. It may have been 

helpful to present the data in tabular form. For 

Alternative 2, using the author's own figures, I 

come up with 143 acres of suitable habitat removed 

Northern Spotted 

Owl

Habitat acres degraded remain in the habitat 

category they were in prior to project activities 

occurring. For suitable habitat removed 

approximately 20 acres is in gaps, 80 acres in 

sugar pine restoration, 35 acres in early seral and 

2 acres in road relocation. The 2 acres in road 
Hwy 46 FEIS Appendix 

402

Commenter Comment Resource Topic Response

(this includes the 6 acres downgraded to dispersal) 

and 84 acres of dispersal (this includes adding in 

the 6 acres downgraded from suitable). I assume 

that the 33 acres of "degraded" dispersal habitat 

would no longer function as such.

relocation were incorrectly listed as foraging 

habitat removed, the correct term should have 

been suitable habitat removed. For dispersal 

habitat approximately 28 acres will be removed in 

gaps, 10 acres in sugar pine restoration and 19 

acres in early seral. Total acres of approximately 

137 acres of suitable removed and approximately 

57 acres of dispersal removed have been revised 

in the final EIS. In habitat effects analysis, 

degraded means the habitat remains the same type 

of habitat after treatment. Downgrade means 

habitat was altered and reduced in quality, such as 

suitable to dispersal habitat or dispersal to nonhabitat.

Karen Sjogren Critical Habitat appears to be a very large subset of 

total suitable and dispersal habitat in the project 

area, at least for the thinning units and gaps. 

However, for dominant tree release 11 acres of 

suitable habitat and 55 acres of dispersal habitat is 

degraded, which is greater than the total figures 

degraded for this activity in the Project Area (6 & 

33, respectively, p.148, bottom). How can this be 

so? Also, meadow restoration is put in here as a 

factor reducing habitat along with early habitat 

creation, which is not mentioned for total habitat 

modification in the previous section. Please 

explain. I can accept that the effects on Critical 

Habitat are only slightly less than for project 

habitat overall, but the figures in this section need 

to be redone.

Northern Spotted 

Owl

You are correct. The numbers have been 

recalculated. There are 9.75 acres of suitable and 

60.5 acres of dispersal habitat listed under 

dominant tree release. Dominant tree release in 

CHU is 9.75 acres of suitable and 51 acres of 

dispersal habitat.

Karen Sjogren In the LSR's, the only prescribed treatment is 

thinning 808 acres in dense plantations under 80 

years old (p. 79). Thus, I was surprised that three 

acres of suitable habitat would be thinned in the 

Northern Spotted 

Owl 

This results from the owl habitat mapping not 

matching the silvicultural stand mapping. In 

reality when units are marked on the ground these 

stand edges are obvious and older suitable habitat 
Hwy 46 FEIS Appendix 

403

Commenter Comment Resource Topic Response

LSRs. Where are they? If dispersal habitat is 

"degraded", isn't it essentially removed?

is not included in the thinning unit. Dispersal 

habitat degraded remains dispersal habitat.

Karen Sjogren The dispersal figures for dominant tree release (59 

acres "down-graded) for Alternative 3 cannot be 

correct because they exceed the total acreage for 

this activity (58.25 acres). Also, if dispersal habitat 

is downgraded, it is lost as such; this was true in 

Alternative 2 calculations for the 33 acres lost to 

dominant tree release. It also does not make sense 

for this figure to exceed Alternative 2, which 

begins with a larger figure (72.75 acres) to begin 

with. 

For Critical Habitat lost/modified under 

Alternative 3, t number of dispersal acres 

"degraded" by DTR (i.e., lost) is still suspiciously 

large—45 acres, compared to 33 acres "degraded" 

under Alternative 2 for all owl habitat.

Northern Spotted 

Owl 

Dispersal habitat was degraded rather than downgraded and was presented as degraded. For 

alternative 2 the 33 acres of dispersal habitat 

degraded is approximately 60 acres plus 

approximately 10 acres of suitable habitat plus 

approximately 2.5 acres of non-habitat. For 

alternative 3 the 59 acres should be approximately 

61 acres.

Downgraded would be lost, degraded would 

remain the type of habitat it was before treatment.

Karen Sjogren For the LSRs, the figures should be exactly the 

same for both alternatives since only plantations 

are thinned or otherwise manipulated. However, 

the loss of dispersal acreage to DTR in Alternative 

3 is given as 32 acres rather than 2 (Alternative 2). 

The correct number is probably 2

Northern Spotted 

Owl

The numbers have been checked, alternative 3 has 

3.5 possible acres in two units and part of one unit 

is non-habitat. So rounding to a best estimate 

would yield 3 acres rather than the incorrect 32 

acres. The correct number for alternative 2 will be 

changed from 2 to 3 acres of DTR. 

Karen Sjogren If acreage "remains habitat", does that mean that 

habitat stays in the same category (suitable or 

dispersal)? 

Northern Spotted 

Owl

That is correct.

Freres Enclosed please review a study published in the 

journal Forest Ecology and Management which 

stated that cover in tall trees is the key habitat 

requirement for spotted owls not total canopy 

cover. It is also indicated that spotted owls largely 

avoid cover created by stands of shorter trees.

Northern Spotted 

Owl

Thank you for sharing the article.

Nick Cady for 

Cascadia 

Wildlands, 

The DEIS claims that deer and elk are struggling in 

the project area and that this is why additional 

clearcutting is needed. They base the struggling 

Big Game A purpose and need of the Hwy 46 project is to 

move stand structure from an overabundance of 

mid seral stands to increase both early and late 
Hwy 46 FEIS Appendix 

404

Commenter Comment Resource Topic Response

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

deer and elk status on "The current estimated elk 

population of about 3,000 for the Santiam WHU is 

well below the State Management Objective of 

5,200." Please analyze the basis for the State 

Management Objective, it is our understanding the 

these objectives are not based in any science but 

rather on numbers optimized to sell hunting tags. It 

is inappropriate for the FS to rely upon these 

artificial numbers. Please rely upon actual historic 

levels or drop this purported support for clearcut 

logging from the FEIS.

The FS includes in the DEIS a model to assess elk 

and deer foraging in the project area and concludes 

that these are poor foraging areas. However, the 

model assumes that Douglas fir/hemlock forests 

provide poor nutritional value for elk. The DEIS 

elsewhere states that the historical condition of 

these forests are fir/hemlock forests. Should the FS 

be altering the project area to provide more deer 

and elk habitat if this runs counter to the historical 

condition of these forests?

seral stand structure within the watershed. Early 

seral habitat creation will provide landscape 

heterogeneity and provide habitat for song birds, 

cavity nesters and pollinators, as well as 

providing benefits to big game species.

Karen Sjogren Elk and Deer. Even though these are indicator 

species, I felt that the DEIS spent a 

disproportionate time on them, especially since the 

effects of the project are negligible on their habitat. 

I agree with Cascadia Wildlands that the role of 

private lands in providing habitat for these species 

should be considered, as that's where I have most 

often seen them. It is true, however, that most 

hunting opportunities are on public land. Is less 

interest in hunting at all responsible for reduced 

harvest success? 

Big Game Private timber and agricultural land is not present 

in the analysis area. Your question about less 

interest in hunting possibly being responsible for 

reduced harvest success is an interesting one, and 

is beyond the scope of this project. Oregon 

Department of Fish and Wildlife maintains, on 

their website, statistics of hunter 

numbers/days/hunt types/etc. and success rates.

Karen Sjogren The "Affected Environment" description does a 

good job of describing how different forest types, 

stand stages, and hardwood component percentage 

Big Game The B&B fire created thousands of acres of early 

seral habitat on the Willamette N.F. most of it 

occurring at high elevations where forage 
Hwy 46 FEIS Appendix 

405

Commenter Comment Resource Topic Response

correlate to forage nutritional values for these 

species. The text and tables are also good in 

describing how poor forage acreage has increased, 

and good forage acreage declined, over the last 25 

years; the totals mask greater increases or 

decreases in individual BGEAs (p. 170). Will 

recent fires change the amount of acreage in these 

categories, as occurred, for example, as a result of 

the B & B fire in 2003? 

nutritional values are low. Recent fires in the 

analysis area are the Scorpion fire which resulted 

in approximately 16 acres of forest canopy being 

killed and the Little Devil fire which resulted in 

approximately 68 acres of forest canopy being 

killed. The Scorpion fire early seral habitat area 

would result in higher quality foraging habitat on 

16 acres. The Little Devil Fire was on a rocky 

ridgeline at higher elevation and would result in 

lower quality foraging habitat. Very little change 

resulted from 2017 fires in the analysis area. The 

Whitewater fire was mostly in the North Santiam 

watershed which is outside the analysis area. 

Some acres of this fire were in the Breitenbush 

watershed and outside the analysis area at high 

elevation and would not be higher quality 

foraging habitat. 

Karen Sjogren In the Effects Analysis, the author states (as he did 

in the Snags section) that the project will "remove" 

197 acres of forest, benefitting three of the above 

named species. I cannot come up with this figure 

from the tables, so please explain.

Meadow restoration 8 acres, early seral 45 acres, 

gaps 48 acres, sugar pine shelter wood 94 acres 

and road relocation 2 acres (total of 197 acres).

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The FS admits there is going to be snag loss 

associated with the proposed logging. Despite the 

fact that the models used by the FS show that the 

snag levels will remain above the minimum 

thresholds (although the DEIS does appear to 

disclose some recent science that went unnamed 

that invalidated these models, please elaborate in 

the FEIS), we believe that the further reduction of 

snags and habitat for cavity nesting species runs 

counter to recommendations and standards in the 

Forest Plan.

Snags The project analysis and recommendations are 

based on the best available science.

Nick Cady for 

Cascadia 

The Hwy 46 DEIS and Appendix F (DecAID) 

failed to compare the effects of logging versus not 

Snags The no action alternative, alternative 1, would be 

the condition if stand treatments were to not 
Hwy 46 FEIS Appendix 

406

Commenter Comment Resource Topic Response

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

logging on future recruitment of snags and dead 

wood. The Appendix compares current and 

reference conditions, but fails to product those 

numbers into the future as a result of logging 

versus no action.

occur. The results of treatments are discussed as 

alternatives 2 and 3.

Karen Sjogren Table 35 shows that all the planning subdrainages 

in the Project Area are currently meeting this 

requirement. Did the recent fires change these 

percentages in any of the listed subdrainages? 

Table 36 is a really nice comparison of how the 

two action alternatives would affect large snag 

density compared to the present conditions. What 

does FW-125 stand for?

Snags FW means a forest wide standard and guideline 

found in the Land and Resource Management 

Plan for the Willamette National Forest and FW125 is related to snags. An analysis of existing 

conditions was conducted after the fires which 

can be found in Appendix F DecAID Analysis. 

Basically very little changed. An analysis was 

completed for the areas where the canopy was 

visibly killed, determining that 16 acres in the 

Scorpion Fire and 68 acres in the Little Devil fire 

were killed.

Karen Sjogren In the effects analysis for snags, the author states 

that Alternative 2 proposes 197 acres of 

regeneration harvest. I have reviewed all the 

treatment prescriptions and can only come up with 

101 acres that qualify and therefore would require 

snag creation. Please clarify. The Alternative 3 

effects analysis also uses the figure of 197 acres of 

regeneration harvest, which is obviously incorrect. 

Please redo this section so the reader can 

understand where, why and to what degree 

additional snags and downed wood will be created 

as a mitigation/enhancement measure in this 

project. 

Snags Meadow restoration 8 acres, early seral 45 acres, 

gaps 48 acres and sugar pine shelter wood 94 

acres (total of 195 acres). And yes the alternative 

3 number is high and should be reduced to 54 

acres, early seral 16, gaps 29 and sugar pine 

shelter wood 9 acres.

Nick Cady for 

Cascadia 

Wildlands, 

The Forest Service cannot provide any assurance 

that its plans and projects will assure viable 

populations of native wildlife that depend on dead 

Management 

Indicator Species

This is analyzed and discussed in section 3.6.12,

Management Indicator Species.
Hwy 46 FEIS Appendix 

407

Commenter Comment Resource Topic Response

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

trees. The Forest Service does not know how many 

snags are necessary to support viable populations 

of cavity associated species. The Forest Service has 

provided no credible link between DecAID 

tolerance levels, potential population levels, and/or 

viable populations. The Forest Service has also 

failed to reliably quantify existing and projected 

habitat for snag associated species. 

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The agency's analysis of snag retention and habitat 

for cavity dependent species is faulty at both a 

programmatic level and at a project level. The 

agency must defer any decision on this project until 

it reviews all the available new information and 

amends its management plan standards to provide 

adequate snags for wildlife and all other ecosystem 

functions. 

Management 

Indicator Species

DecAID analysis integrates the most current 

scientific information for cavity dependent 

species. 

Karen Sjogren Raptors and Colonial Nesting Birds. Why weren't 

surveys done within sale units for raptors? Without 

surveys, how could it be known that the only nest 

trees are located outside of proposed harvest units?

Raptors and 

Colonial Nesting 

Birds

Surveys were conducted for only osprey nests as 

they are large, visible, ospreys are very noisy and 

they remain in the same trees for many years. 

Surveys are not done for other raptors. Raptor 

detections are included in contract language for 

timber sales with recommended procedures when 

detected. Individual trees are protected under this 

contract clause and harvest activities are 

seasonally restricted during the nesting season. 

The timber sale administrator looks for potential 

raptor nests during normal inspection activities. 

Raptors are not surveyed for as nest locations 

move yearly. During unit layout the cruisers and 

unit boundary layout crew also look for and report 

raptor nests when found.

Karen Sjogren For Alternative 3, 54 acres are "removed"; this 

figure is 44 acres on p.145, and no figure is given 

Migratory Birds The 54 acres is early seral 16 acres, gaps 29 acres 

and sugar pine shelter wood 9 acres. For the last 
Hwy 46 FEIS Appendix 

408

Commenter Comment Resource Topic Response

for the snag analysis on p. 176. If other activity 

treatments that remove habitat are added in, the 

total is 118.05 acres. The author is probably adding 

in some of the small gaps created by DTR and 

sugar pine restoration, but the methodology is not 

clear and I cannot arrive at his figures. Please 

explain. Without consistent and accurate figures 

for early seral habitat creation it is not possible to 

determine or compare effects. Please explain also 

the source of the proclamation at the top of p. 185 

that Alternative 3 would create 111 acres of gaps 

less than Alternative 2. Alternative 3 creates 13 

few acres of gaps, according t Table 9. Where does 

the other acreage come from?

sentence in Alternative 3 with 111 acres listed, 

this included dominant tree release for an 

additional 61 acres. 54 + 61 = 115 approximate 

acres. This last sentence was missed in 

Alternative 2, thank you for indirectly pointing 

that out. The acres in openings would be 268 in 

alternative 2. Gaps 48, sugar pine shelterwood 94, 

meadow 8, early seral 45 and DTR 73 acres.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The Forest Service should include in its analysis an 

assessment of how the roads in the project area are 

likely to provide a vector for the spread of invasive 

species by fragmenting the landscape and creating 

buffers that are less resistant and resilient to 

stressors sed use of those roads by log hauling 

trucks and other motorists will further exacerbate 

the risk of spreading invasive species.

Invasive Weeds This is discussed in FEIS Section 3.7.9 and 

3.7.10.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The analysis states 232 total road miles exist in the 

project planning area and that 170 miles will 

remain open under Alternatives 2 and 3. See, e.g., 

DEIS at 204.

* How many of the 232 miles of road in the project 

area are system roads?

* How many miles of unauthorized, non-system 

roads exist in the project area? Where are the 

unauthorized, or non-system roads? * How does 

the Forest Service plan to manage the non-system 

roads?

Transportation We have reviewed the roads within the planning 

area, and have corrected the miles of roads 

analyzed. 216 miles of system roads are in the 

planning area.

We will be using approximately 9.12 miles of 

temporary roads to implement the Hwy 46 

project. 

Temporary roads will be decommissioned by the 

timber purchaser following timber sales activities. 

See Table 13, Design Elements, and Appendix A, 

FEIS page 277.
Hwy 46 FEIS Appendix 

409

Commenter Comment Resource Topic Response

The Forest Service does not track unauthorized, 

non-system roads. When unauthorized, nonsystem roads are located, they are closed to public 

access.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National

Monument

The total system miles analyzed on Table 63 

appears to be incorrect. DEIS at 325.

* What is the total number of system road miles in 

the project area?

Transportation There are approximately 216 miles of system 

roads in the project area. The Road Status table 

has been updated in the FEIS. (FEIS, table 64 

page 342)

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The Forest Service references a travel and road 

management plan developed specifically for this 

project, that includes details regarding road status, 

conditions, stream culvert locations and conditions, 

road maintenance levels, and management 

classifications, which is located in a transportation 

analysis file. DEIS at 200. Much of this 

information is precisely the type of site- specific 

information that should be disclosed in the DEIS so 

as to inform the public and allow for meaningful 

comment.

Transportation This information is provided in the Road Status 

Table in Appendix H of the DEIS and FEIS.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The Forest Service states that Alternatives 2 and 3 

meet the proposed minimum road system in the 

planning area. DEIS at 204. But the minimum road 

system for the project area has not yet been 

identified. The RIS included a recommendation, 

but was not itself an agency decision.

Therefore, the language referring to "meeting" that 

system is confusing. The agency must clarify 

whether it is proposing to determine the system 

roads identified under Alternatives 2 and 3 as the 

Transportation The (now) 150 miles is referring to the open roads 

that will remain open. The remaining miles are 

either closed or are being decommissioned. The 

minimum roads needed is what is analyzed in this 

EIS as needed for haul of the proposed units and 

also to administer for current and future 

resources.
Hwy 46 FEIS Appendix 

410

Commenter Comment Resource Topic Response

minimum road system. It must also explain in its 

analysis how the resulting road system achieves the 

factors defining a minimum road system under 

subpart A. Given that there are 232 miles of forest 

roads in the project area, and here the Forest 

Service identifies 170 miles as the minimum road 

system, did the agency determine that the 

remaining 62 miles are not needed?

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

We strongly support the Forest Service's 

modification to include decommissioning of 1.99 

miles. DEIS at 200. However, this number is far 

too small given the challenges the Forest Service 

faces in maintaining its road system, the adverse 

impacts from the road system to the landscape, and 

in light of the 232 total road miles existing in the 

project area.

Road 

Decommissioning

The Forest Service has reviewed the road system 

in the planning area. Of the approximately 216 

miles of system road in the project area the Forest 

Service has included additional miles of road 

decommissioning in the FEIS, bringing the total 

to 8.88 miles of road decommissioning.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The Forest Service states that storing 1.37 miles of 

roads will reduce the backlog of maintenance 

needs in the analysis area. DEIS at 204. To the 

extent the agency is storing certain roads for 

"resource protection," it should prioritize 

decommissioning these roads. See, e.g., DEIS at 

318 (identifying Forest Road 4600044 for closure 

"for resource protection" but failing to explain 

what future need the agency might have for the 

road that prevents it from being decommissioned).

We have identified the resources that needs those 

roads to remain on the system for future use. The 

Road Status Table in Appendix H has been 

updated.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

The information provided in the DEIS and Table 

63 (Appendix H) fails to provide any estimated 

timelines for the proposed road work. It also fails 

to provide any information about the aquatic risk or 

future needs of each of the roads in the project 

area. See, e.g., DEIS at 315 (stating that a road 

identified in the RIS to be analyzed for 

Roads System roads identified and cleared for 

decommissioning will be decommissioned in the 

future when funding becomes available. By 

having these roads identified and cleared for 

decommissioning through this EIS, road 

decommissioning funding sources such as Legacy 
Hwy 46 FEIS Appendix 

411

Commenter Comment Resource Topic Response

Douglas Fir 

National 

Monument

decommissioning "needs to remain on system for 

resource administration" without addressing 

whether the road presents a high aquatic risk, or 

defining what resource administration is needed 

and how far into the future).

Roads and other internal Forest Service funding 

sources will be competed for very easily. 

Road maintenance activities will occur before and 

during the associated timber sale.

Temporary roads will be constructed by the 

purchaser prior to timber sale activities, and 

would be decommissioned by the purchaser 

following timber sale activities.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

Log hauling during wet weather has unacceptable 

water quality impacts and is decidedly NOT in the 

public interest. The NEPA analysis must take a 

hard look at the adverse water quality effects of log 

hauling during wet weather

Wet weather haul Wet weather haul has been analyzed in the FEIS, 

see Hydrology section 3.4.4. Roads not suitable 

for wet weather haul have been identified, FEIS 

Table 13, page 53. Further wet weather haul 

design elements are identified on page 58 of the 

FEIS.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The analysis in the DEIS mentions the Road 

Investment Strategy (RIS) (DEIS at 23, 201- 202), 

but fails to evaluate the road activities proposed for 

the Hwy 46 Project based on those 

recommendations. It makes no attempt to explain 

whether the road-related actions proposed in this 

project are consistent with the recommendations 

from that 2015 forest-wide report. It is possible this 

information is addressed in the travel and road 

management plan referenced in the analysis, but 

unfortunately as noted above the Forest Service 

fails to disclose this information to the public. 

DEIS at 200 (explaining the "travel analysis and 

plan considered such road-related items as safety, 

risk to resources, future expected use, public and 

private access, emergency access, and maintenance 

costs"). Appendix H to the DEIS lacks the 

Transportation The Road Status Table has been updated.
Hwy 46 FEIS Appendix 

412

Commenter Comment Resource Topic Response

necessary information to comply with subpart A of 

the roads rule. See 36 C.F.R. § 212.5(b)(2) 

("Responsible officials must review the road 

system on each National Forest and Grassland and 

identify the roads . . . that are no longer needed to 

meet forest resource management objections"). 

Instead, it merely lists the recommendations from 

the TAR (which as explained below are 

inadequate) but fails to explain any differences 

from those recommendations to the proposed road 

actions under this project. See DEIS, Appendix H 

at 312-333.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The DEIS should analyze the potential impacts on 

recreation new roads will have on this high use 

area. New roads not only attract illegal off road 

vehicle use but also attract trash dumping, firearm 

waste, littering, and other illegal activity. These 

activities could impact the desirability of the area 

and its appeal to recreationists. These activities and 

construction could also impact any wilderness or 

remoteness character of the area. Please address 

these issues in the DEIS.

Temporary Roads 

/ Recreation

The potential for these illegal activities are 

common across all National Forest Lands, 

especially in areas of timber harvest activity. In 

order to reduce the potential increase of these 

types of illegal activities, the Design Element for 

Action Alternative, indirectly address these 

concerns. In all units, the following criteria apply:

• Prevent off road travel and dispersed site

creation. Place natural obstacles such as down 

wood and rock in a natural arrangement to 

prevent creation of new dispersed sites where they 

don’t presently exist. Bury boulders 1/3 of the 

way in the ground where possible.

• Rehabilitate all landings to prevent site from 

becoming a new dispersed site. Place natural 

obstacles such as down wood and rock in a 

natural arrangement to prevent creation of new 

dispersed sites where they don’t presently exist. 

Bury boulders 1/3 of the way in the ground where 

possible.

• In units where proposed landings are currently 

dispersed sites, rehabilitation of sites will be 

necessary to restore site to desired condition for 
Hwy 46 FEIS Appendix 

413

Commenter Comment Resource Topic Response

continued use as a dispersed site or return to a 

naturalized state. Consultation with a recreation 

specialist will be required in the design phase for 

units in or adjacent to these areas. Rehabilitation 

may include: Placing natural obstacles such as 

down wood and rock in a natural arrangement to 

prevent expansion of dispersed sites. Burying 

boulders 1/3 of the way in the ground where 

possible.

• Purchaser will close temporary roads to traffic 

and rehabilitate to prevent new off road recreation 

use. Subsoil road surface of temporary roads to 

prevent new road creation. Place natural obstacles 

such as down wood and rock in a natural 

arrangement to prevent creation of new dispersed 

sites where they don’t presently exist. Bury 

boulders 1/3 of the way in the ground where 

possible.

We know from actively working in the field, 

when access into new areas due to any form of 

disturbance happens, dispersed sites tend to get 

created – increasing the likelihood of the other 

illegal activities mentioned in the question –

therefore our management practices try to reduce 

any new dispersed site creation.

Additionally, Design Elements regarding impacts 

to Wilderness Areas (areas designated by the 

Wilderness Act) only apply to Unit 560, as that 

was the only unit near the Mt. Jefferson 

Wilderness. The activities proposed for Unit 560 

will be limited by these Design Elements:

• Restrict activities to recreation off-season

• Accomplish treatment with non-motorized 

equipment

• Expedite activities to affect only 1 year
Hwy 46 FEIS Appendix 

414

Commenter Comment Resource Topic Response

With these criteria, we hope to mitigate any 

impacts, or potential impacts to Wilderness or 

remote areas.

AFRC also contains a restriction that prohibits the use of 

helicopter operations prior to 8am year-round. As 

you likely know, economically logging with 

helicopters comes as a challenge. Any additional 

parameters applied will only exacerbate that 

challenge. We would like the District to consider 

limiting this particular restriction to the weekend 

and holiday periods. Like most farmers, the 

logging community has a tradition of starting work 

early in the morning. It's not always easy, but it is 

necessary. We ask that you consider the strong 

work ethic that this community practices and allow 

a start time that they see necessary to get their job 

done.

Operations In order to balance the competing demands of a 

working economy of logging and a recreation 

economy for the project area, this restriction was 

decided on as a compromise between the two. 

Knowing that the Breitenbush area has a high 

demand for recreation use and knowing that 

helicopter operations can produce noise 

disturbances, we wanted to allow the use of 

helicopters as necessary for harvest operations, 

but within the constraints of the quiet hours of the 

nearby campgrounds. In previous helicopter 

harvest operations on the Detroit Ranger District, 

helicopter operations have impacted the recreation 

experience of campers in nearby campgrounds, to 

the point of lost revenue at those sites. Due to the 

lack of recreationists in the winter months, we 

will change the restriction to an 8:00 AM start 

time, from Memorial Day to Labor Day, only in 

units 24, 32, and 32a. We believe this is sufficient 

to reduce impacts to the recreating public and 

reduce the burden of additional restrictions.

AFRC Under the "Recreation" heading on page 47, Table 

13 describes a restriction aimed at reducing impact 

to the recreating public. This restriction also 

applies an 8 am start time to certain units yearround. We would ask the District to again consider 

the potential impacts to recreationalists during 

winter months when recreation is likely low.

Operations From October to May, all of the developed 

campgrounds along the Breitenbush corridor are 

closed for the season, and much of the project 

area typically receives enough snowfall to restrict 

access for several months at a time – leading to a 

lower number of recreationists. Due to this lack of 

recreationists in the winter months, we will 

change the restriction to an 8:00 AM start time, 

from Memorial Day to Labor Day, only in units 

24, 32, and 32a. We believe this is sufficient to 

reduce impacts to the recreating public.
Hwy 46 FEIS Appendix 

415

Commenter Comment Resource Topic Response

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The DEIS states that appx. 300 acres of areas that 

are classified as "retention" are going to be 

commercially thinned. The FS states that this will 

done in such a way that it will not be evidence to a 

forest visitor. Please elaborate further in the FEIS 

how this is possible.

What are you basing the assumption that these 

treatments will not be visible to forest visitors 

upon?

Scenic Quality Based on the analysis of the proposed treatments 

and the known, local conditions (screening 

density of vegetation from roadways, trails, etc.), 

the proposed actions in the FEIS are deemed to 

not be evident to the casual forest visitor. The 

majority of forest visitors will not notice harvest 

activities as they drive the roadway (likely driving 

35-45 miles per hour) or hike trails with few 

viewpoints facing the proposed harvest units. 

There will, however, be some scenic quality 

impacts. The remaining “seen” impacts will fade 

quickly in most cases due to the regrowth of 

vegetative screening.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The DEIS simply states that "Proposed treatments 

in alternatives 2 and 3 fall well within allowable 

scenic quality ranges set by the Forest Plan." DEIS 

at 215. This is not the hard look required under 

NEPA. What type of logging is going to take place 

in these areas, are there any proposed gaps, what 

type of yarding will be used?

Scenic Quality Just a bit further in the document, under the 

section labeled Scenic Viewsheds, the rationale 

for the comment "Proposed treatments in 

alternatives 2 and 3 fall well within allowable 

scenic quality ranges set by the Forest Plan." By 

looking at the numbers in Table 53, as well as the 

description and scenic quality mitigations further 

described in the section, we believe this project 

falls well within the allowable scenic quality 

ranges set by the Forest Plan. There are many 

units within the project area that will have 

proposed gaps. There are several types of logging 

and yarding methods that will be used within the 

project area: ground based; skyline; and 

helicopter. Each of those methods have their own 

type of yarding requirements and restrictions.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Are you generating view sheds from certain 

viewing points or trails?

Some analysis here is necessary, especially given 

the recreational popularity in this area and the 

Breitenbush River's Wild and Scenic eligibility. It 

is difficult to imagine that the forest visitor will not 

Scenic Quality We generated a viewshed analysis from multiple 

points across the landscape of the project area 

using Google Earth, GIS data, and on the ground 

surveys. We used computer software to look for 

high points, cut banks, and previously cleared 

artificial or natural openings, for example, and 
Hwy 46 FEIS Appendix 

416

Commenter Comment Resource Topic Response

Friends of the 

Douglas Fir 

National 

Monument

see fresh stumps, yarding damage, large stump 

fields in the gaps, or the temporary roads and 

landings constructed to facilitate the logging. We 

are very concerned about these impacts and the 

nearly 300 acres of logging proposed in these 

areas. Conclusory sentences in the DEIS are simply 

not sufficient.

then travelled to those sites in the field to visually 

inspect the effect of the unit treatments from those 

sites. In some cases, computer modeling was 

sufficient to extract an approximate analysis, but 

site visits were also used.

We will amend the conclusory statements in the 

FEIS to reflect these concerns, but as stated 

before, based on the analysis of the proposed 

treatments and the known, local conditions 

(screening density of vegetation from roadways, 

trails, etc.), the proposed actions in the FEIS are 

deemed to not be evident to the casual forest 

visitor. The majority of forest visitors will not 

notice harvest activities as they drive the roadway 

(likely driving 35-45 miles per hour) or hike trails 

with few viewpoints facing the proposed harvest 

units. There will, however, be some scenic quality 

impacts. The remaining “seen” impacts will fade 

quickly in most cases due to the regrowth of 

vegetative screening.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The DEIS does included an image to simulate the 

impacts of logging adjacent to a camping site 

located in the project area at some "valued scenic 

viewpoints." What level of thinning did this image 

simulate and how was the image created?

Scenic Quality The level of thinning in the image was 

commensurate to the average level of harvest in a 

thinned unit. The caption on most of the photos 

showing the simulation states that the image was 

created with (Adobe) Photoshop. A real world 

example, of what a thinned unit would look like, 

can be found on Forest Service Road 46, at about 

1000 feet west of the entrance of Humbug 

Campground, on the south side of the road. If 

requested, images of that thinned unit can be 

provided.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

The DEIS repeatedly states that view impacts will 

be minimal and perhaps not apparent to the casual 

forest visitor. How is the FS supporting this 

statement and assumption?

Scenic Quality Based on the analysis of the proposed treatments 

and the known, local conditions (screening 

density of vegetation from roadways, trails, etc.), 

the proposed actions in the FEIS are deemed to 
Hwy 46 FEIS Appendix 

417

Commenter Comment Resource Topic Response

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

not be evident to the casual forest visitor. The 

majority of forest visitors will not notice harvest 

activities as they drive the roadway (likely driving 

35-45 miles per hour) or hike trails with few 

viewpoints facing the proposed harvest units. 

There will, however, be some scenic quality 

impacts. The remaining “seen” impacts will fade 

quickly in most cases due to the regrowth of 

vegetative screening.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The FS discloses a myriad of effects on the 

numerous various recreational activities that are 

offered in the project area. However, the FS never 

attempts to cumulate these effects. How many 

folks will be turned away by closures?

How many folks will witness active operations?

Recreation Past and present natural and human caused 

disturbances or modifications including timber 

harvest and road construction are evident 

throughout the project area. Due to the limited 

duration of the activities within the project area, it 

is not likely that people will be turned away by a 

closure unless there is legitimate need for public 

health or safety. Visitors may choose to turn away 

and recreate in different areas due to the activities 

being presented.

We do not have accurate or available records of 

the number of visitors in the project area, but we 

do have estimated information from the National 

Visitor Use Monitoring report. We will amend the 

conclusory statements in the FIES to reflect these 

concerns.

Karen Sjogren There is a creative, subjective element in designing 

forest treatment prescriptions so they achieve their 

objectives but do not reduce the scenic attributes of 

the area. This project appears to do that. Did recent 

fires change any elements of this section?

Scenic Quality During the fire, some roads had a narrow strip 

(usually not more than 10 feet wide) of trees 

removed on one side to enhance the fire break 

created by the road. Although some of this fire 

line treatment did occur in Hwy 46 units in this 

area, the effect on vegetation within those units 

was minimal. Only trees immediately adjacent to 

the road were cut. Most of the higher intensity 

burns within the project area occurred away from 

open system roads and therefore will have 
Hwy 46 FEIS Appendix 

418

Commenter Comment Resource Topic Response

minimal effects on the scenic attributes of the 

area. From the perspective of high, open 

viewpoints, the effects of the fire may change the 

overall appearance of the project area, but those 

effects will reflect a natural process at work 

within the project landscape. We will amend the 

conclusory statements the FIES to reflect these 

concerns.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The FS simply admits in this section that it will 

violate the Forest Plan by leaving visible stumps, 

evidence of logging in the wild and scenic corridor. 

This is illegal. These restrictions exist for a reason, 

and these stumps could later be used to disqualify 

this area for Wild and Scenic eligibility. This is 

significant. The FS cannot simply write off these 

restrictions because they make logging in the area 

expensive. Why does any alternative simply not 

contain this illegal logging?

Wild and Scenic 

Rivers

The Forest Plan allows logging to occur within 

the 1⁄2 mile wild and scenic river corridor and 

standard and guide MA-6-12 and MA-6b-11 say 

that stumps within the corridor “should” be flush 

cut. This guideline was also developed by a forest 

plan when the common logging prescription was 

clearcutting. The thinning being proposed in these 

stands is much less visually impacting. The Forest 

Plan goes on to specify that this action is required 

unless justifiable reason exists for not taking 

action, such as an unacceptable hardship or 

expense (page IV-45). Therefore, due to the 

expense of flush cutting stumps, only the areas 

within 100’ of system roads are proposed to have 

stumps flush cut. Partial implementation of this 

measure will reduce effects to visual quality due 

to stumps in areas most often viewed by visitors 

to the forest and is consistent with Forest Plan 

direction. Visual effects from areas where stumps 

are not flush cut within the 1⁄2 mile corridor will 

be reduced with the passage of time and growth of 

surrounding vegetation. Eligibility of the rivers 

for inclusion in the national Wild and Scenic 

River System will not be jeopardized. The text in 

the Eligible Wild and Scenic Rivers section of the 

FEIS has been corrected to include this 

clarification.
Hwy 46 FEIS Appendix 

419

Commenter Comment Resource Topic Response

Karen Sjogren The McCoy 6 project for both alternatives was not 

described elsewhere in the tables or text, especially 

for Alternative 3. (DEIS page 217)

Recreation The “McCoy 6” as stated in the DEIS, may have 

been misinterpreted as a project, but is the name 

of a route in the McCoy Motorized Recreation 

Area. The complete name is the McCoy 6 Boulder 

Ridge Route. This is a loop used primarily by 

snowmobiles in the winter and some OHVs in the 

summer months. The route follows Forest Service 

Road (FSR) 2231-810 and FSR 2231. The 

majority of this loop is outside of the project area 

boundary, but a small portion of the route passes 

through Unit 73. The FEIS states “Meadow 

restoration is proposed along segments of the 

Mansfield trail in alternative 2 and the McCoy 6 

Boulder Ridge Route (used by snowmobiles and 

OHVs) in alternatives 2 and 3. Although 

treatments would be enhancing existing natural 

features and would be repeating form, line, color, 

and texture of the characteristic landscape, the 

intentions may not be evident to forest visitors. 

Restored meadows would provide trail users with 

variation in scenery and valuable views of 

alternative landscapes from dense forest.” Unit 73 

is a thinning unit. We will amend the FIES to 

clarify these concerns.

Daphne Stone we also need to retain some amount of old forests 

for recreation and wildlife habitat. Although the 

proposed sale includes a burn and a plantation, 

both are old stands. Once an old stand is cut, it is 

unlikely that it will ever be allowed to reach this 

age again

General No old stands are being proposed for harvesting 

in any alternative of this project. Hazardous fuels 

activities in units 170 and 270 around the 

Breitenbush property will be limited to cutting 

brush and thinning trees less than 7 inches dbh. 

Some stands (over 80 years old) in the project 

area are experiencing competition due to high tree 

densities. Thinning treatments in these stands are 

designed to increase tree growth and accelerate 

species diversity in the mid-story, ultimately 

moving those stands to an old-growth structure in 
Hwy 46 FEIS Appendix 

420

Commenter Comment Resource Topic Response

a shorter timeframe than if left in their current 

condition. Early seral habitat creation in these 

stands will increase structural diversity at the 

landscape level, creating habitat for a wider 

variety of plant and animal species and replicating 

natural processes, such as fire, that shaped the 

landscape historically. 

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The FS is proposing ground based logging in an 

IRA. Does this involve temporary road 

construction in the IRA? 

Inventoried 

Roadless Areas

No temporary roads would be built in the IRA. 

FEIS has been updated.

Nick Cady for 

Cascadia 

Wildlands, 

Oregon Wild, 

WildEarth 

Guardians and 

Friends of the 

Douglas Fir 

National 

Monument

The DEIS should discuss potential economic 

benefits and costs, direct and indirect, of the 

logging project and discuss the contributions to the 

local economy from the timber to be logged and 

jobs provided as compared to the economic 

benefits brought by clean water, unlogged forests, 

and recreation, particularly by the Breitenbush 

community and its over 25,000 annual guests.

The Forest Service needs to consider how much 

business Breitenbush brings to the surrounding 

counties and areas, and to contact Breitenbush 

specifically to consult on revenue and numbers on 

attendees and what percentage of these attendees 

use the surrounding forest lands, including the 

project area. These figures should be weighed 

against the purported value to the community 

generated from the project's implementation.

Local Economics We recognize the role the Breitenbush Resort 

plays in the local area, and are aware the 

community will be impacted by this project. 

Many design elements have been designed to 

minimize these impacts.

The Breitenbush Resort officials shared general 

numbers with us during the planning process, but 

did not provide the information needed to 

complete the type of analysis suggested in this 

comment. The DEIS discussed the importance of 

the Breitenbush Hot Springs Resort to its’ many 

visitors, the economics and tourism it brings to 

the area. The economics section also outlined that 

the leisure and hospitality industry currently 

represents 14% of the employment in the North 

Santiam Canyon. Because of this very fact, many 

added mitigation measures are proposed in this 
Hwy 46 FEIS Appendix 

421

Commenter Comment Resource Topic Response

project to ensure that impacts to recreation in the 

area are minimized.
Hwy 46 FEIS Appendix 

422

Comments from Cascadia Wildlands, Oregon Wild, WildEarth Guardians and Friends of 

the Douglas Fir National Monument on Climate Change

The FS should consider the economic benefits of keeping carbon stored in unlogged forests by 

calculating the avoided costs of global climate change. Disclose the Social Cost of Carbon Dioxide as a 

proxy for the impacts of GHG emissions.

DEIS page 255 says "a project of this magnitude makes an infinitesimal contribution to overall 

[greenhouse gas] emissions. Therefore, at the global and national scales, the proposed action's direct 

and indirect contribution to greenhouse gasses and climate change would be negligible. In addition, 

because the direct and indirect effects would be negligible, the proposed action's contribution to 

cumulative effects on greenhouse gasses and climate change would also be negligible." This is wrong on 

many levels. First, why does the FS say this about greenhouse gases but not about this project's 

contribution to jobs and wood products which are also infinitesimal at a global scale? Second, the FS 

cannot conclude that this projects GHG emissions do not contribute to cumulative impacts. If that was 

true then there would be no global warming problem at all, because every individual contribution is 

small in comparison to the global problem. The FS does not seem to understand that climate change is 

by definition a problem of cumulative effects. All GHG emissions (from logging and all other sources) are 

part of the problem, and all carbon capture (such as by growing trees that are not logged) is part of the 

solution.

The NEPA analysis in the Hwy 46 DEIS must avoid minimizing this project's contribution to carbon 

emissions and global warming by saying the effects of this project would be negligible on a global scale. 

This is not an appropriate framework.

The Hwy 46 DEIS failed to describe how many tonnes of CO2e would be emitted by this project, how big 

the carbon debt created by this project is, how long it would take to recapture that carbon, how much 

warming would occur during the time period it takes to recapture that carbon, and failed to quantify the 

forgone opportunity to capture carbon in unlogged forests under the no action alternative, etc.

Response:

The Forest Service acknowledges the trade-off between management activities and greenhouse gas 

(GHG) emissions. The intent of the project is not maximizing carbon, but to promote biodiversity by 

increasing landscape diversity through a number of actions (increasing/maintaining early seral 

vegetation, improving stand-structure characteristics, and increasing snag recruitment). The Forest 

Service recognizes carbon sequestration is one of many ecosystem services provided by forests and 

forest products now and into the future. Carbon sequestration should be considered in context with 

other ecosystem services (USDA FS, 2015). 

The EIS states its adherence to the suggested practices of reducing forest disturbance effects found in 

the National Climate Assessment for public and private forests (Joyce et al. 2014). We further describe in 

the EIS on pages 17 to 19 the need for maintenance and restoration of forestlands to promote healthy 

functional ecosystems. Improving stand conditions will improve forestland adaptive capacity and 

function better under threat of disturbances like fire. This improved resiliency to disturbance threats will 

improve chances of future forest persistence. 
Hwy 46 FEIS Appendix 

423

The Forest Service currently lacks standardized tools for estimating all GHG emissions and carbon 

associated with the implementation of the proposed project. Current CEQ guidance allows federal 

agencies flexibility in using the best available scientific information to qualitatively describe emissions 

and carbon tradeoffs between alternatives rather than quantifying them in the absence of available 

information/tools. For this project we do not have the analyses or information for quantification at the 

project level at this point in time. 

Several studies throughout western forests support the efficacy of thinning for reducing severity of 

potential wildfire (Agee and Skinner, 2005; Safford et al., 2009; Stephens et al., 2009; Safford et al., 

2012). There is also evidence to suggest that treatments such as thinning reduce burn probability in 

adjacent untreated stands (Moghaddas et al., 2010). Evidence does indicate a cost in terms of reduced 

carbon storage for this reduced burn severity (Campbell, Harmon, and Mitchell, 2012). However, over 

large areas and long periods of time, Campbell and Ager (2013) show forest carbon stocks are insensitive 

to a wide range in fuel reduction treatment effectiveness, lifespan, vegetation recovery rates, and other 

factors. These authors suggest “that the carbon costs to reduce wildfire effects through fuel treatment 

appear relatively small.”

Providing some context for the Willamette NF, a recent regional carbon assessment estimates that the 

entire forest stores 250 teragrams* of carbon (USFS, 2015). A second carbon assessment focusing on 

disturbance estimates the forest lost approximately 25 teragrams of potential carbon storage over the 

past 60 years (USDA FS, 2016 in press – Fig. 4d Appendix B) because of fire, harvest, and insects. From 

1991-2011, the assessment presents evidence (Figure 1q – see below) of more fire on the forest 

especially since 2003, which suggests increasing influence on lost carbon storage (USDA FS, 2016 in press

– Appendix A). Considering the size of the project area, the carbon trends of the forest as a whole will 

likely show little sensitivity to the carbon emissions caused by the proposed action.

The short-term release of GHG associated with the project be it removal of carbon stocks or the shortterm emissions occurring during implementation is reasonable given the improved longer-term 

ecological conditions. The project’s co-benefit of increased forest resilience is supported by science that 

projects higher levels of fire under future climate change, and the need to restore forests by increasing 

uneven-age, large tree stands that are more resistant to disturbance (Rogers et al., 2011). Of course 

there is uncertainty to how future climate will affect the extent and severity of fire in the future. The 

literature indicates the need to proactively promote resilience to fire and other disturbances under this 

0

1

Percentage of forest disturbed

Year

1q) Willamette

Insects

Harvest

Fire
Hwy 46 FEIS Appendix 

424

uncertainty by increasing spatial heterogeneity (landscape diversity) at multiple scales (Cansler and 

McKenzie, 2014), which is in line with the original intent of the proposed action. 

*

One teragram is one trillion grams.

Literature Cited:

Agee, J.K., Skinner, C.N. (2005). Basic principles of forest fuel reduction treatments. Forest Ecology and 

Management. 211:83-96. doi:10.1016/j.foreco.2005.01.034

Campbell, J. L., Harmon, M. E., & Mitchell, S. R. (2012). Can fuel-reduction treatments really increase 

forest carbon storage in the western US by reducing future fire emissions? Frontiers in Ecology and the 

Environment, 10(2), 83–90. doi:10.1890/110057

Campbell, J.L. & Ager, A.A. (2013). Forest wildfire, fuel reduction treatments, and landscape carbon 

stocks: A sensitivity analysis. Journal of Environmental Management. 121, 124-132. 

doi:10.1016/j.jenvman.2013.02.009

Cansler, C. A., & McKenzie, D. (2014). Climate, fire size, and biophysical setting control fire severity and 

spatial pattern in the northern Cascade Range, USA. Ecological Applications, 24(5), 1037–1056. 

doi:10.1890/13-1077.1

Moghaddas, J. J., Collins, B. M., Menning, K., Moghaddas, E. E. Y., & Stephens, S. L. (2010). Fuel 

treatment effects on modeled landscape-level fire behavior in the northern Sierra Nevada. Can. J. For. 

Res., 40(9), 1751–1765. doi:10.1139/x10-118

Rogers, B. M., Neilson, R. P., Drapek, R., Lenihan, J. M., Wells, J. R., Bachelet, D., & Law, B. E. (2011). 

Impacts of climate change on fire regimes and carbon stocks of the U.S. Pacific Northwest. Journal of 

Geophysical Research, 116(G3). doi:10.1029/2011jg001695

Safford, H. D., Schmidt, D. A., & Carlson, C. H. (2009). Effects of fuel treatments on fire severity in an 

area of wildland–urban interface, Angora Fire, Lake Tahoe Basin, California. Forest Ecology and 

Management, 258(5), 773–787. doi:10.1016/j.foreco.2009.05.024

Safford, H. D., Stevens, J. T., Merriam, K., Meyer, M. D., & Latimer, A. M. (2012). Fuel treatment

effectiveness in California yellow pine and mixed conifer forests. Forest Ecology and Management, 274, 

17–28. doi:10.1016/j.foreco.2012.02.013

Stephens, S. L., Moghaddas, J. J., Edminster, C., Fiedler, C. E., Haase, S., Harrington, M., ... Youngblood, A. 

(2009). Fire treatment effects on vegetation structure, fuels, and potential fire severity in western U.S. 

forests. Ecological Applications, 19(2), 305–320. doi:10.1890/07-1755.1

USDA Forest Service. 2015. Baseline Estimates of Carbon Stocks in Forests and Harvested Wood 

Products for National Forest System Units; Pacific Northwest Region. 48 pp. 

http://www.fs.fed.us/climatechange/documents/PacificNorthwestRegionCarbonAssessment.pdf

USDA Forest Service. (2016, in press.) Assessment of the Influence of Disturbance, Management 

Activities, and Environmental Factors on Carbon Stocks; Pacific Northwest Region. 102 pp.
Hwy 46 FEIS Appendix 

425

Appendix K – Changes from Draft to Final Hwy 46 

Project Environmental Impact Statement

The following changes have been made to the Hwy 46 Project DEIS to FEIS.

Post fire current conditions, direct, indirect and cumulative effects have been added throughout the 

FEIS. Information about the 2017 fires has been added at the beginning of Chapter 3, and throughout 

the FEIS.

FEIS Page Location DEIS FEIS

7 First line May affect, likely to adversely 

affect

May affect, not likely to adversely 

affect

Analyzed for 1.99 miles of road 

decommissioning; 1.37 miles of 

road storage 

Analyzed for 8.88 miles of road 

decommissioning; 4.07 miles of road 

storage

4, 21, 32, 

37, 42, 85, 

96

Tables Acres of treatments and miles of 

roads updated in all tables.

30 First 

paragraph

In August 2017, a final Biological 

Assessment will be submitted to 

NMFS. Letter of concurrence is 

expected from NFMS in March or 

April 2018.

This analysis found that the Hwy 46 

Project “may affect, not likely to 

adversely affect” Upper Willamette 

spring Chinook salmon. This is due to 

the potential for “take” as defined in 

the ESA. Take is prohibited by the 

ESA unless it is authorized by the 

“fisheries” agencies (National Marine 

Fisheries Service for salmon). In order 

for the Forest Service to obtain 

authorization we must conduct 

consultation with the fish agencies 

under Section 7 of the ESA. 

Consultation is anticipated to be 

completed by May 2018.

30 In August 2017, a final Biological 

Assessment was submitted to 

USFWS. Letter of concurrence is 

expected from USFWS in January 

2018. 

The Biological Assessment for 

Willamette Planning Province of 

Oregon for FY 2018 LAA Projects 

within the Willamette National Forest 

with a Potential to Modify Habitat 

and/or Disrupt Northern Spotted 

Owls of LAA Projects with the 

Potential to Modify the Habitat 

and/or Disrupt Northern Spotted 

Owls – Willamette Planning Province 

– FY 2016/17 was used to determine 

effects. A biological assessment was 

submitted August 1, 2017 and a 
Hwy 46 FEIS Appendix 

426

FEIS Page Location DEIS FEIS

biological opinion was signed August 

31, 2017 which includes the Hwy 46 

project. This project would need to 

be completed prior to a final decision 

notice being signed for this project. 

The determination expected to be 

made in the Biological Assessment 

for the Hwy 46 project, which would 

be completed and concurrence 

received from the USFWS prior to the 

final decision notice is signed, is this 

project may affect and is not likely to 

adversely affect spotted owls by 

disturbance.

35 and 40 Table 6 and 

Table 8

Acres updated

44 Table 10 Acres of Riparian Reserves proposed 

for treatment updated

49 Noise Helicopter operation restriction 

dropped on all but units 24, 32 and 

32a

66-67 Description of the 2017 fires within 

the project area added. Map showing 

location of fires in relation to project 

treatment units added.

71 Figure 10 Stand age distribution map updated 

to include 2017 fire generated early 

seral

73 Figure 11 Added photos of Douglas-fir 

plantations.

85-86 2017 fire effects section added

87 Photos showing some effects from 

the 2017 fires added.

89 2nd

paragraph

2017 fire information added, stating 

size of fires and acres within project 

planning area, as well as units 

burned.

102 Table 25 Post fire management indicators 

added

140 Table 31 Cubic yards of sediment delivered / 

year updated

286 Appendix B Acres updated.

297 Appendix D 2017 wildfires, fire suppression 

activities and road side hazard tree 

removal added to Past, Present and 

reasonably foreseeable actions
Hwy 46 FEIS Appendix 

427

FEIS Page Location DEIS FEIS

312 Appendix F Effects of fires of 2017 on snag 

densities in the Breitenbush River 

watershed Willamette National 

Forest added

328 Appendix G Appendix G updated

338 Appendix H 232 miles of road analyzed. 1.99

miles of road decommissioning, 

1.37 miles of road storage.

Road status table updated. 216 miles 

of road analyzed. 8.88 miles of road 

decommissioning, 4.07 miles of road 

storage.
Hwy 46 FEIS Appendix 

428

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Hwy 46 FEIS Appendix 

441

Glossary

A

Advanced Regeneration - Small trees, usually 

less than 1 inch in diameter, which are growing 

under mature trees prior to planned harvest 

activities.

Air Quality - The composition of air with 

respect to quantities of pollution therein; used 

most frequently in connection with "standards" 

of maximum acceptable pollutant 

concentrations. Used instead of "air pollution" 

when referring to programs.

Ambient Air Quality - defined under the Clean 

Air Act as the air quality outside of industrial 

site boundaries 

C

Canopy - The uppermost spreading branchy 

layer of a forest.

Canopy Cover - Canopy cover is a measure of 

the percentage of ground covered by a vertical 

projection of the tree canopy.

Canopy Closure - Canopy closure is the 

proportion of the sky hemisphere (measured 

from all angles) obscured by vegetation when 

viewed by a single point. Closure is affected by 

tree heights and canopy widths and takes into 

account light interception and other factors that 

influence microhabitat.

Chain – A standard measurement equal to 66

feet.

Cohort – A group of trees developing after a 

single disturbance, commonly consisting of trees 

of similar age, although it can include a 

considerable range of tree ages of seedling or 

sprout origin and trees that predate the 

disturbance.

Contiguous- In close proximity to or near.

Core Area - 0.5 mile (radius circle) around a 

known or predicted owl site, which delineates 

the area most heavily used during the nesting 

season for nesting, foraging and rearing young. 

Bingham and Noon (1997) defined the core area 

as that portion of a northern spotted owl home 

range that received disproportionately high use 

for nesting, roosting and access to prey; they 

suggested that 60-70% of owl reproducing 

season activity occurred in about 20% of the 

home range. Although Courtney et al. (2004:5-5) 

observed that core area sizes varied greatly 

among owls, Thrailkill (pers. com.) determined 

that Bingham and Noon 1997, Wagner and 

Anthony 1999, Franklin et al. 2000 and Irwin et 

al. 2004 collectively suggested a core area of 

about 500 acres.

Critical Habitat – The critical habitat 

designation is conducted by the U.S. Fish and 

Wildlife Service and is based on the current 

status and recent scientific research on northern 

spotted owl populations. Critical habitat was 

identified for specific areas within the 

geographical area occupied by the species at the 

time it was listed, on which are found those 

physical or biological features essential to the 

conservation of the species, and which may 

require special management considerations or 

protection. For the northern spotted owl, these 

features include particular forest types that are 

used or likely to be used by northern spotted 

owls for nesting, roosting, foraging, or 

dispersing habitat. In addition, the best available 

information was used to identify those areas that 

are otherwise determined to be essential to the 

conservation of the species. A habitat network 

was identified that meets the following criteria: • 

Ensures sufficient habitat to support stable, 

healthy populations across the range, and also 

within each of the 11 recovery units; • Ensures 

distribution of northern spotted owl populations 

across the range of habitat conditions used by 

the species; • Incorporates uncertainty, including 

potential effects of barred owls, climate change., 

and wildfire disturbance risk; and • Recognizes 

that these protections are meant to work in 
Glossary

442

concert with other recovery actions, such as 

barred owl management.

Cycle - As applied to uneven-aged management, 

it is the time interval between harvest entries. It 

should be noted that harvest entries in unevenaged management are to leave residual levels of 

growing stock which should not need treatment

for at least one cycle length.

D

Desirable Species - Any species of plant or 

animal which is considered to be compatible 

with meeting management goals and objectives.

Discounted Cost - Value of all cost associated 

with a project over its lifetime multiplied by a 

discount rate to determine the costs at today’s 

worth.

Discounted Revenue - Value of all revenue 

associated with a project over its lifetime 

multiplied by a discount rate to determine the 

value today.

Disturbance - Events that disrupt the stand 

structure and/or change resource availability or 

the physical environment (Oliver 1996).

Diameter Breast Height (dbh) – Diameter of a 

tree measured 4.5 feet up from the ground on the 

uphill side.

E

Early Seral - Plants which inhabit a disturbed 

site within the first few years subsequent to the

disturbance.

Early Seral Habitat – A forest structural 

condition that lasts 15-20 years after a human 

disturbance such as timber harvest, or natural 

disturbance such as wildfire. This structural 

condition can provide valuable wildlife habitat 

components including grasses, flowering forbs, 

hardwoods and dead wood habitat structures.

Emissions - A release of combustion gases and 

aerosols into the atmosphere.

F

Fire Behavior – The manner in which a fire 

reacts to the influences of fuel, weather, and 

topography.

Fire Intensity -The product of the available heat 

of combustion per unit of ground and the rate of 

spread of the fire, interpreted as the heat released 

per unit of time for each unit length of fire edge. 

The primary unit is Btu per second per foot 

(Btu/sec/ft) of fire front. Also, the rate of heat 

release per unit time per unit length of fire front. 

Numerically, it is the product of the heat yield, 

the quantity of fuel consumed in the fire front, 

and the rate of spread.

Fire Regime - A function of the historical 

frequency of fire and the degree of severity of 

those fires.

Fire Severity - Degree to which a site has been 

altered or disrupted by fire; loosely, a product of 

fire intensity and residence time.

Fuels - Vegetative matter, dead or alive, that 

burns in a fire. It is broadly characterized by the 

following categories:

• Surface or ground fuels are within a 

foot or so of the ground surface.

• Ladder fuels exist when you have a 

continuous vertical arrangement of 

fuel that allows fire to easily go 

from ground level into the tree 

canopy.

• Crown fuels are the tree limbs and 

leave that can burn with enough heat 

and/or wind.

• Live fuels are the green (live) herbs 

and shrubs.

Fuel Models - Simulated fuel complex for 

which all fuel descriptors required for the 

solution of a mathematical rate of spread model 

have been specified.
Glossary

443

H

Habitat Modification; Habitat Downgraded: 

Refers to silvicultural activities that change 

spotted owl suitable habitat to dispersal habitat

Habitat Removed: Refers to silvicultural 

activities that 1) Alter spotted owl suitable 

habitat such that it no longer supports nesting, 

roosting, foraging, and dispersal (i.e., suitable 

habitat becomes non-habitat after treatment) or 

2) Alter spotted owl dispersal habitat so that the 

habitat no longer supports dispersal (i.e., 

dispersal habitat becomes non-habitat after 

treatment).

Home Range - An estimated area for habitat use 

of a spotted owl pair. For the Oregon Cascades, 

this estimate is 1.2 miles (radius circle) around a 

known or predicted owl site (Thomas et al. 

1990, USDI et al. 2008).

Hyporheic Flow - Hyporheic flow is the mixing 

of shallow groundwater and surface beneath and 

alongside a stream bed.

I

Incidental Take (ESA) – Take that is incidental 

to, and not the purpose of, carrying out an 

otherwise lawful activity

Invasive Weed – see Noxious Weeds

K

Known Owl Site - A site that was or is occupied 

by a pair or resident single as defined by the 

survey protocol (1990-2012). The specific site 

location is determined by the unit biologist 

based on the best and/or most recent 

information. A known site may be determined to 

be inactive only in accordance with the

L

Ladder Fuels – Fuels that provide vertical 

continuity between the ground and tree crowns 

which create a pathway for a surface fire to 

move into the overstory tree crowns.

Local Road – A forest road that connects 

terminal facilities with forest collector, forest 

arterial or public highways. Usually forest local 

roads are single purpose transportation facilities. 

(FSH 7709.54, no longer in print)

M

Mechanical Treatment – Fuels reduction work 

completed by tracked or rubber tired equipment 

that may include grapple piling in slash 

concentrations, mastication, or any other 

mechanical device. 

Motor Vehicle Use Map (MVUM) – A map 

reflecting designated roads, trails and areas on 

an administrative unit or a Ranger District of the 

National Forest System. (36 CFR 261.2)

Multi-Cohort – a stand with two or more age 

classes or cohorts.

Munching - is the action of de-compacting the 

soil layers up to 18 - 24 inches deep by using 

excavator subsoiler attachments. The 

attachments are a regular excavator bucket (with 

thumb), grapple rakes (with thumb) or a 

modified bucket with added subsoiler shanks 

(and blades). The objective of the “munching” 

technique is breaking the soil layers down to 24 

inches in order to treat compaction in addition to 

applied slash above the area as an effective 

groundcover. With this technique, the soil layers 

would be de-compacted vertically and 

horizontally.

N

Nest Patch (or Stand) - 300 meters (radius 

circle) around a known or predicted owl site, 

where a spotted owl would be likely to select a 

nest tree. This is based on habitat usage of 

spotted owls within the Central Cascades Study 

Area, located on the Willamette National Forest.

Net Future Value - Difference in Discounted 

Revenue and Discounted Cost to evaluate if a 

project will have a positive or negative return on 

investment.

No Cut Buffer – Riparian buffer where no trees 

can be cut.
Glossary

444

No Harvest Buffer – Riparian buffer where 

trees may not be commercially cut and milled, 

but may be cut and felled for other purposes, 

such as streamside restoration treatment where 

specified and stream crossings or equipment 

access.

Noxious Weeds (Invasive species) - Nonnative plants listed by the State that generally 

have either economic or ecosystem impacts, or 

are poisonous to wildlife and/or livestock. They 

aggressively invade disturbed areas such as fires, 

road sides, and construction areas.

O

Obligate Predator - When the word is used as 

an adjective, obligate means "by necessity" (the 

antonym is facultative) and is used mainly in 

biology. An obligate predator is an organism 

whose survival is dependent on a diet consisting 

of animal flesh. In the case of aquatic insects 

these organisms would primarily eat other 

insects.

Off-Highway Vehicle (OHV) – Describes all 

those vehicles designed for off-highway use and 

which are classified as one of four classes of 

ATV in Oregon. (OHV Guide 2014)

P

Phytophagous - Feeding on plant material. This 

term is typically used when referring to insects.

Predicted Owl Site - An area able to support 

resident spotted owls (i.e. a potential breeding 

pair) as determined by the USDI et al. (2008) 

northern spotted owl occupancy template. This 

is used for determining effects to spotted owls 

where survey data are insufficient.

Pump Chance - A predetermined location 

where a water source can be accessed for filling 

engines or water tenders.

R

Remnant trees - Large to giant-diameter trees 

within younger-aged stands, that lived through 

past natural fire disturbances, or were retained 

after logging. Amounts and distribution of 

remnant trees within younger stands may be 

highly variable.

Road – A motor vehicle route over 50 inches 

wide, unless identified and managed as a trail. 

(36 CFR 212.1)

Road Decommissioning – Activities that result 

in the stabilization and restoration of unneeded 

roads to a more natural state. (36 CFR 212.1)

S

Salvage - Activity, usually removal or chipping, 

of material killed by a disturbance event such as 

insects, fire, wind, etc. Where possible, this 

material is used as some form of forest product 

of commercial value, such as firewood, pulp, 

and/or chips.

Seral Stages - Seral stage describes the phase of 

development of a plant community. Early seral 

species are those species you would expect to 

find on a site soon after a major disturbance, like 

fire. These are species such as pines, Douglasfir, snowbrush, fireweed, etc. They are generally 

shade intolerant species. Late seral are the 

species that can come in under a fully developed 

vegetative canopy, such as true firs, prince's 

pine, lichens, etc.

Silviculture -The theory and practice of 

directing forest establishment, composition, and 

growth for the production of forest resources to 

meet specific management objectives. The word 

is derived from the Latin word silva, which 

means "forest" and from cultura, which means 

"to develop and care for." So, it is the 

development and caring for the forest.

Silviculturist - One, who plans, assists in and 

supervises the implementation of silviculture 

projects. The Silviculturist determines 

(prescribes) the vegetative treatments necessary 

to meet the objectives for vegetation on a given 

site.

Site - A specific location where management 

activity is considered, planned, or operating.
Glossary

445

Site Potential - The specific ability of a site to 

grow vegetation. It includes the soil,

topographic, and climatic conditions that 

determine the resources available for growing 

vegetation.

Site Preparation - The removing or rearranging 

of vegetation or woody debris to meet specific 

management objectives. Most often it is used to 

describe the process(es) used to expose mineral 

soil areas suitable for planting or seeding 

desirable species of plants.

Slash - Debris resulting from such natural events 

as wind, fire, or snow breakage; or such human 

activities as road construction, logging, pruning, 

thinning, or brush cutting. It includes logs, 

chunks, bark, branches, stumps, and broken 

understory trees or brush.

Soundscape- Geographic region as defined by 

the audible sounds associated within it.

Spotted Owl Habitat Types – Suitable habitat

consists of forested stands used by spotted owls 

for nesting, roosting and foraging. Features that 

support nesting and roosting typically include a 

moderate to high canopy closure (60-90%); a 

multi-layered, multi-species canopy with large 

overstory trees (with dbh of greater than 30 

inches); a high incidence of large trees with 

various deformities (large cavities, broken tops, 

mistletoe infections, and other evidence of 

decadence); large snags; large accumulations of 

fallen trees and other woody debris on the 

ground; and sufficient open space below the 

canopy for spotted owls to fly. 

Foraging habitat generally has attributes similar 

to those of nesting and roosting habitat, but such 

habitat may not always support successfully 

nesting pairs (USFWS 2011c, p. A-10).

At a minimum, dispersal habitat consists of 

stands with adequate tree size and canopy 

closure to provide protection from avian 

predators and at least minimal foraging 

opportunities (USFWS 2011c, p. A-10). It 

consists of conifer and mixed mature coniferhardwood habitats with a canopy cover greater 

than or equal to 40% and conifer trees greater 

than or equal to 11 inches average diameter at 

breast height (dbh) with open space beneath the 

canopy to allow spotted owls to fly. Generally, 

spotted owls use younger stands to move 

between blocks of suitable habitat, roost, forage 

and survive until they can establish a nest 

territory. Juvenile owls also use dispersal habitat

to move from natal areas. Dispersal habitat thus 

includes habitat that will provide some roosting 

and foraging opportunities during the 

colonization phase of dispersal, but not at a scale 

that would support nesting pairs (in which case 

it would be classified as suitable habitat).

Suitable habitat can also function as dispersal 

habitat as it supports both territorial and 

dispersing spotted owls. However, in this 

document, dispersal habitat generally refers to 

stands that are 40-79 years old.

Stand - A group of trees of similar canopy 

structure, species composition, and/or size

growing on a continuous area. A stand is distinct 

from neighboring stands in structure, growing 

conditions, or management objectives. Stand age 

for this project is averaged and based on trees of 

commercial size which is seven inch dbh and 

greater.

Stand Density Index – SDI – A relative density 

measure based on the relationship between mean 

tree size and number of trees per unit area in a 

stand (Reineke 1933).

Stand Dynamics - The changes in forest stand 

structure with time, including stand behavior 

during and after disturbances (Oliver 1996).

Stand Structure - The physical and temporal 

distribution of trees and other plants in a stand 

(Oliver 1996).

Stream Classes - Class 1 and 2 = perennial fish

bearing streams; Class 3 = perennial non-fish 

bearing streams; Class 4 = intermittent, 

seasonally flowing streams.

Suppression - All the work of extinguishing or 

confining a fire beginning with its discovery.

T
Glossary

446

“Take” of ESA listed species - Take: to harass, 

harm, pursue, hunt, shoot, wound, kill, trap, 

capture, or collect or attempt to engage in any 

such conduct. Harm is further defined by 

USFWS to include significant habitat 

modification or degradation that results in death 

or injury to listed species by significantly 

impairing behavioral patterns such as breeding, 

feeding, or sheltering. Harass is defined by 

USFWS as actions that create the likelihood of 

injury to listed species to such an extent as to 

significantly disrupt normal behavior patterns 

which include, but are not limited to, breeding, 

feeding or sheltering.

Thinning - Any cutting or removal of 

vegetation (trees, brush, etc.) resulting in a 

reduction of competition for water, light, and/or 

nutrients between individual plants. 

• Commercial thinning refers to removing 

material that has an established dollar 

value on the open market and can be 

sold with at least a minimal net value 

sufficient to pay for the thinning

activity.

Torching - The burning of the foliage of a single 

tree or a small group of trees, from the bottom 

up. Also, single tree torching is one tree and 

group torching is more than one tree often a 

patch of multiple trees torching.

Treatment - A term used to broadly refer to the 

management actions made to meet management 

objectives. It may include thinning cutting of 

undesirable trees, prescribed fire, salvage, or any 

manipulation of the vegetative conditions. In 

addition, intentionally excluding a portion of a 

stand from harvest is a management action, or 

treatment.

Trees per Acre (TPA) – The number of trees on 

an acre of land.

U

Underburn - Using prescribed fire under the 

canopy of an existing stand of trees.

Undesirable Species - Any species of plant or 

animal which is NOT considered to be 

compatible with meeting management goals and 

objectives.

V

Vegetation Recovery- Period of time that 

allows for sufficient re-growth in harvested 

areas to make evidence of harvest activity 

largely unnoticeable to the casual observer.

W

Woody Debris - Dead pieces of woody 

vegetation such as stems, limbs, or leaves which 

are on a site. 
Glossary

447

Index

2017 Fires, xi, 70, 71, 126, 127

A

Aquatic Conservation Strategy, v, ix, 18, 116, 132, 152, 

158, 160, 161, 162, 304, 312, 313, 317, 398, 399, 447

B

Barred owl, 167, 169, 410, 452

C

Canopy cover, 1, 16, 74, 76, 80, 83, 84, 85, 86, 87, 88, 109, 

131, 143, 149, 157, 168, 180, 191, 192, 194, 203, 204, 

206, 243, 294, 321, 404, 406, 413, 443, 450, 455

Cavity excavators, 183, 330

Climate change, 285

Compaction, 7, 10, 23, 36, 41, 50, 58, 59, 61, 62, 63, 102, 

106, 107, 108, 109, 113, 125, 129, 131, 144, 145, 151, 

213, 214, 215, 219, 254, 297, 321, 453

Critical habitat, 304, 451

Critical Habitat, v, 7, 28, 170, 171, 198, 199, 331, 412, 413, 

448, 451

Cumulative effects, 69, 148, 162, 181, 220, 225

Cutthroat trout, 151, 152, 153, 158, 162, 164, 307, 315

D

Dead wood, 96, 137, 185, 199, 200, 201, 208, 209, 308, 

325, 402, 407, 416, 452

Dispersed site, 52, 422, 423, 424

Dominant tree release, xi, 1, 5, 16, 21, 34, 39, 72, 82, 165, 

179, 197, 198, 208, 209, 285, 408, 412, 413, 418

Down wood, xii, 46, 52, 63, 65, 67, 83, 99, 114, 131, 132, 

137, 159, 169, 170, 185, 190, 197, 198, 199, 200, 201, 

202, 206, 317, 322, 323, 325, 331, 332, 340, 396, 397, 

401, 422, 423, 441, 449

E

Early seral habitat, 2, 5, 6, 17, 44, 65, 70, 72, 74, 78, 83, 

84, 86, 88, 89, 90, 93, 164, 165, 166, 179, 187, 190, 196, 

200, 201, 205, 208, 209, 293, 295, 296, 308, 317, 332, 

384, 388, 389, 395, 407, 408, 409, 415, 418

Economics, viii, 12, 281, 431, 445

Eligible Wild and Scenic Rivers, 11, 28, 29, 53, 260, 429

Elk, x, 9, 183, 190, 191, 192, 194, 195, 196, 203, 204, 291, 

407, 414, 445

Enhancement, xii, 9, 10, 53, 67, 85, 86, 89, 109, 113, 160, 

170, 171, 172, 194, 197, 198, 200, 201, 203, 204, 206, 

207, 241, 242, 245, 248, 285, 287, 293, 296, 308, 311, 

416

ESA, v, 7, 31, 150, 151, 152, 154, 161, 162, 163, 167, 208, 

305, 308, 315, 406, 435, 453, 456

F

Fire behavior, 70, 90, 96, 98, 100, 434

Fire regenerated, xi, 1, 16, 32, 39, 72, 75, 77, 80, 88, 122, 

131, 132, 141, 214, 386, 395, 399

Fire regime, 13, 70, 92, 93, 249, 259, 317

Forest Plan, vi, viii, x, xi, 3, 6, 11, 19, 20, 23, 24, 25, 26, 

27, 28, 29, 50, 67, 83, 92, 112, 116, 117, 125, 126, 129, 

130, 132, 142, 152, 153, 162, 164, 178, 180, 181, 182, 

183, 185, 186, 187, 188, 189, 190, 191, 194, 195, 196, 

197, 198, 201, 215, 217, 236, 237, 240, 241, 242, 243, 

252, 260, 262, 286, 287, 293, 295, 296, 297, 304, 306, 

307, 308, 312, 313, 314, 318, 322, 323, 330, 332, 385, 

394, 395, 415, 425, 428, 440, 447

Fuels, viii, x, 2, 4, 6, 18, 22, 35, 40, 45, 46, 50, 67, 87, 89, 

92, 97, 98, 100, 101, 142, 213, 240, 241, 244, 255, 285, 

288, 296, 310, 311, 405, 452, 453

G

Gaps, xi, xii, 1, 5, 16, 23, 36, 41, 46, 47, 48, 49, 53, 56, 57, 

65, 72, 78, 81, 82, 83, 84, 85, 86, 87, 89, 98, 100, 102, 

119, 128, 132, 134, 138, 139, 143, 144, 151, 158, 164, 

165, 166, 170, 172, 179, 187, 190, 197, 198, 200, 201, 

208, 209, 219, 221, 224, 225, 241, 244, 248, 285, 293, 

294, 295, 296, 313, 315, 332, 342, 345, 391, 394, 395, 

408, 411, 412, 415, 416, 418, 425, 426

I

Invasive Weed, 453

Inventoried Roadless Area, v, 12, 273, 276

K

Key Issue, 32, 39, 49, 386

L

Land management areas, 24

Late-Successional Reserves, 2, 17, 24, 88

M

Management indicator species, 151, 153, 164, 183, 190, 

306, 307

Meadow restoration, 8, 21, 34, 39, 58, 85, 114, 115, 128, 

140, 143, 145, 165, 166, 170, 177, 179, 190, 197, 198, 

203, 206, 207, 208, 222, 230, 285, 293, 300, 313, 408, 

412
Glossary

448

N

Northern Spotted Owl, vi, 7, 23, 31, 167, 170, 178, 189, 

198, 199, 305, 312, 331, 409, 410, 411, 412, 413, 440, 

443, 448, 449

Northwest Forest Plan, 20, 23, 24, 142, 180, 183, 185, 186, 

215, 286, 287, 304, 308, 395, 447

P

Preferred alternative, iii, 3, 34

Proposed Action, viii, ix, 21, 27, 34, 222, 299, 317, 318, 

319, 320, 321, 322, 323

Purpose and need, iv, 21, 33, 34, 44, 190, 383, 384, 385, 

414

R

Riparian Reserves, ix, x, xii, 2, 3, 4, 18, 19, 21, 24, 28, 29, 

34, 35, 39, 44, 46, 47, 50, 58, 59, 63, 114, 115, 118, 119, 

121, 122, 123, 126, 130, 132, 133, 134, 137, 138, 139, 

140, 142, 143, 144, 146, 149, 160, 161, 199, 307, 308, 

312, 313, 314, 317, 318, 320, 322, 323,324, 396, 398, 

399, 400, 401, 402, 403, 404, 405, 436

Road decommissioning, 67, 112, 139, 147, 150, 420, 421, 

435, 437

S

Salmon, 31, 150, 151, 152, 154, 160, 163, 164, 305, 306, 

316, 406, 435

Scenery, 11, 13, 236, 237, 241, 244, 245, 246, 250, 255, 

262, 315, 430

Seral stage, 387

Short Lake, iii, 1, 3, 10, 11, 13, 19, 20, 34, 112, 115, 123, 

147, 152, 157, 229, 254, 255, 257, 298, 342, 356, 357, 

370

Skips, iii, xi, 5, 21, 34, 36, 37, 39, 41, 42, 46, 50, 81, 82, 

83, 88, 100, 101, 132, 137, 214, 275, 285, 293, 294, 299, 

394

Snags, xii, xiii, 23, 36, 41, 65, 78, 83, 87, 88, 98, 100, 108, 

134, 168, 170, 172, 184, 185, 186, 187, 188, 190, 196, 

197, 198, 199, 200, 201, 202, 206, 208, 209, 211, 295, 

297, 308, 325, 328, 329, 330, 332, 333, 334, 335, 336, 

337, 338, 339, 340, 396, 405, 407, 411, 415, 416, 417, 

441, 449, 455

Soils, 58, 59, 60, 102, 104, 105, 107, 108, 111, 112, 113, 

125, 128, 129, 148, 156, 157, 275, 285, 297, 304

Stand Density Index, vi, 16, 455

Stream class, 313

Sugar pine, iii, xi, 1, 2, 6, 13, 16, 18, 19, 21, 34, 39, 72, 76, 

78, 82, 84, 85, 88, 89, 90, 94, 97, 99, 101, 102, 129, 165, 

179, 190, 203, 204, 208, 209, 217, 242, 246, 285, 293, 

295, 296, 384, 388, 390, 391, 392, 393, 402, 411, 415, 

416, 418

T

Temporary roads, 23, 36, 41, 52, 59, 60, 62, 64, 109, 111, 

115, 140, 142, 144, 146, 148, 224, 230, 255, 273, 275, 

319, 321, 419, 423, 426, 430

Thinning, xi, xii, 1, 2, 5, 16, 17, 21, 34, 39, 44, 46, 47, 48, 

49, 72, 76, 77, 79, 80, 81, 82, 87, 88, 89, 97, 98, 100, 

102, 108, 109, 110, 114, 115, 122, 128, 129, 130, 131, 

132, 133, 134, 135, 136, 137, 138, 139, 140, 143, 144, 

145, 149, 151, 157, 158, 159, 160, 161, 170, 171, 172, 

179, 190, 197, 198, 200, 201, 203, 204, 206, 207, 213, 

214, 216, 218, 219, 223, 236, 237, 241, 242, 243, 244, 

246, 248, 256, 275, 276, 285, 293, 294, 296, 304, 307, 

309, 313, 317, 318, 320, 323, 324, 332, 341, 342, 345, 

346, 391, 392, 393, 394, 397, 399, 401, 402, 404, 406, 

409, 410, 412, 427, 428, 430, 433, 438, 439, 442, 444, 

446, 455, 456

Treatment, iii, xii, 3, 5, 10, 16, 23, 35, 36, 39, 41, 45, 46, 

47, 50, 51, 53, 54, 56, 58, 59, 65, 67, 68, 72, 80, 81, 84, 

85, 86, 87, 88, 90, 92, 98, 101, 102, 107, 114, 115, 116, 

118, 122, 123, 125, 128, 129, 130, 132, 133, 136, 137, 

138, 139, 140, 142, 143, 144,149, 150, 158, 159, 161, 

165, 170, 171, 172, 186, 187, 190, 194, 197, 198, 200, 

201, 203, 204, 206, 208, 216, 218, 219, 220, 221, 222, 

224, 230, 235, 240, 242, 245, 248, 252, 255, 256, 275, 

279, 294, 295, 296, 297, 299, 304, 307, 308, 313, 316, 

318, 319, 320, 322, 323, 341, 342, 343, 344, 345, 384, 

385, 386, 387, 390, 391, 392, 394, 397, 399, 401, 403, 

405, 406, 412, 413, 416, 424, 428, 433, 434, 436, 452, 

453, 454, 456

U

Underburn, 5, 23, 34, 36, 39, 41, 46, 98, 214, 285

Underburning, xii, 68, 70, 92, 93, 98, 99, 100, 114, 129, 

142, 179, 200, 201, 235, 275, 293, 296, 297, 404, 405, 

406

W

Wilderness, viii, 11, 13, 51, 73, 175, 237, 254, 257, 260, 

263, 264, 268, 269, 272, 273, 288, 290, 306, 315, 424

Wildfire, 2, 18, 95, 105, 333, 444

Wildland-Urban Interface

WUI, vii, 18, 95, 296